ML20011D407

Application for Amend to License NPF-58,revising Tech Spec Section 4.0.2 & Bases Re Removal of 3.25 Limit on Extending Surveillance Intervals

ML20011D407
Person / Time
Site:	Perry
Issue date:	12/18/1989
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20011D408	List: ML20011D407 ML20011D410
References
GL-87-09, GL-87-9, GL-89-14, PY-CEI-NRR-1103, NUDOCS 8912270131
Download: ML20011D407 (6)

Text

.

a THE CLEVELAND ELECTRIC ILLUMINATING COMPANY  !

P.O. SOX 07 3 PERRY, OHIO 44001 5 TELEPHONE (216) 2604737 5 ADDRESS 10 CENTER ROAD )

FROM CLEVELAND: 241 1960

]

Serving The Best location in the Nation i Al Kaplan PERRY NUCLEAR POWER PLANT l VCE PRESIDoNT December 18, 1989 PY-CEI/NRR-1103 L  ;

i U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.- 20555 Perry Nuclear Power Plant Docket No. 50-440 j Technical Specification Change Request - r Removal of the 3.25 Limit on -

Extending Surveillance Intervals Gentlemen:

l The Cleveland Electric Illuminating Company (CEI) hereby requests amendment of Facility Operating License NPF-58 for the Perry Nuclear Power Plant, Unit 1. . (

In.accordance with the requirements of 10CFR50.91(b)(1), a copy of this request for amendment has been sent to the State of Ohio as indicated below. I This amendment requesto revision of Technical Specification Section 4.0.2 and the Bases for Technical Specification 4.0.2. This change follows the guidance ,

provided by the NRC staff in Generic Letter 89-14 dated- August 21, 1989.

The changes to the 4.0.2 Bases proposed in this amendment assume that the {

changes to the 4.0.2 Bases previously proposed in a pending Technical '

Specification Change Request pursuant to Generic Letter 87-09 will be processed before or at the same time as this change. A response to an NRC request for additional information on the G.L. 87-09 changes is currently being prepared, which will allow for issuanco of those changes in parallel with this amendment request.(reference CEI letter PY-CEI/NRR-1067L dated <

-10/6/89).

If you have any questions, please feel f ree to call.

Ver tru o es, 5

Al Kaplan Vice President Nuclear Group AK:njc ,

Attachments

' c'c : - T. Colburn P. Hiland l ty USNRC Region III J. Harris { State of Ohio)

" 8912270131 891218  ;

DR ADOCK 05000400

- . -- - ____ _ _ R D l _ -

I' ,' 4' 4

• ~

PY-CEI/NRR-1103 L >

. Attachment 1 Page 1 of 5 i

SUMMARY

/ SAFETY ANALYSIS The purpose of this License Amendment Request is to propose a change to the Perry Nuclear Power Plant (PNPP) Technical Specification (T.S.) 4.0.2.

Technical Specification 4.0.2 contains a provision that allows surveillance intervals to be extended up to 25 percent of the specified interval. This extension is designed to facilitate the scheduling of surveillance activities and allow for the postponement of surveillances when plant conditions are not suitable for conducting e surveillance, for example, under transient conditions or other ongoing surveillance or maintenance activities.

Specification 4.0.2 also currently 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 this 3.25 limit is to preclude routine use of the provision for extending a i surveillance interval by 25 percent. This T.S. Change Request proposes the ,

I removal of the 3.25 limitation on extending surveillance intervals required by  !

T.S. 4.0.2.b.

l This request is consistent with the guidance provided by the NRC in Generic l' Letter 89-14, "Line Item Improvements In Technical Specifications, Removal of the 3.25 Limit on Extending Surveillan u Intervals," and is similar to the License Amendments issued by the NRC for various other plants. This change is sought to be implemented prior to September 14, 1990, the scheduled date for commencement of PNPP's second refueling outage.

Surveillances That Are Performed At Each Refueling Outage and Are Specified With an 18-Month Surveillance Interval ,

Specification 4.0.2a permits surveillance intervals to be extended up to 25 percent of the specified interval. This extention is designed to facilitate the scheduling of surveillance activities. Many surveillances have a specified surveillance interval of 18 months to allow the surveillance to be performed when the unit is shut down during a refueling outage. Therefore, i the actual time interval for the performance of these surveillances is dependent on the length of a fuel cycle, but it currently cannot exceed either (1) 18 months plus the 25 percent allowance (1.25 limitation) or (2) eighteen months total, if the 25% allowance has been used up within the last two performances of the surveillance (3.25 limitation). The safety benefit of performing these surveillances during a plant shutdown is that systems do not have to be removed from service at a time that they are required to be .

operable. This minimizes the amount of time that systems are unavailable during power operation due to surveillance requirements, thereby minimizing the impact on safety.

In a few instances, the Technical Specifications specifically require some surveillances to be performed during a plant shutdown, for example, surveillances that cannot be performed in Mode 1. When a limit is reached on extending an 18-month interval, a forced plant shutdown to perform these surveillances is generally the only alternative short of a license amendment that defers the performance of these surveillances until the end of the fuel cycle.

p -

y . -.- ,_-,-.,rr-..-.r -, - . - . - -

m ,

.. i PY-CEI/NRR-1103 L

$ Attachment 1 Page 2 of 5  ;

t Us.lally,.the length of a fuel cycle would not exceed 18 months by more than  !

the 25 percent allowance, i.e., 4-1/2 months. The more common situation experienced throughout the industry has been to encounter the 3.25 limit on  ;

the combined time interval for three consecutive surveillance intervals. The NRC Staff has routinely had to approve one-time amendment requests to valve +

the performance of 18-month surveillances until the end of the fuel cycle when they vould exceed the 3.25 limitation on consecutive surveillances yet would not exceed the 25 percent allowance for extending the 18-month surveillance interval. Because many surveillances on 18 month intervals are performed during refueling outages when the plant is in a desirable condition for conducting these surveillances, i.e., when the plant is shutdown and safety risk minimized, the safety risk of performing these surveillances during plant operation is greater than the alternative of exceeding the 3.25 limit so long -

as the surveillance is performed within the 25 percent extension limit. Also, for those tests that must be performed during shutdown, a forced shutdown in order to avoid exceeding the 3.25 limit to perform these surveillances is not justified from a safety risk standpoint when the extension for these surveillances is within the 25 percent allowance from the last performance.

This Tech Spec change vill have an additional benefit for Technical Specification Surveillances that cannot be performed during plant operation L

and do not have an appropriate interval to accommodata an 18 month refueling i cycle of a BVR. For example, T.S. 4.3.8.2.c requires disassembly and inspection of Main Turbine Control Valves and Stop Valves at least once per 40 months. This change vill allow CEI to avoid either an early shutdown or the j necessity for requesting NRC extensions when such T.S. surveillance intervals ,

I_

do not correspond with PNPP's refueling cycles in the future.

Surveillances Not Performed During Refueling Outages '

t In addition to its application to refueling outage surveillances, the use of L

the 25 percent allowance for extending surveillance intervals can have a

' safety benefit when it is used during plant operation. When plant conditions .

are not suitable for the conduct of surveillances due to safety systems being s [

out-of-service for maintenance or due to other ongoing surveillance activities, safety may be enhanced by the use of the allowance that permits a surveillance interval to be extended. In such cases, the safety benefit of l

l extending a surveillance interval up to 25 percent would outweigh any benefit I that might be derived by conforming to the 3.25 limitation. Furthermore, there is an administrative and logistical burden on licensees associated with tracking the use of and exceptions to the 25 percent allowance for prior  ;

surveillance intervals to ensure compliance vith the 3.25 limit. This results in a diversion of resources and attention from more safety significant activities.

As previously stated, the intent of the 3.25 limit on extending surveillance intervals is to preclude routine use of the provision for extending a j

surveillance interval by 25 percent. CEI does not intend that this Amendment l

PY-CEI/NRR-1103 L l

+- Attachment 1 Page 3 of 5 1

i i be used as a convenience to allow surveillance intervals to be repeatedly i extended beyond their specified interval for surveillances that are intended to be performed on a routine basis during plant operation (i.e., surveillances  ;

not intended to be pt.rformed during refueling outages). CEI has included a l statement of this policy within the proposed revised bases to T.S. 4.0.2 (see  !

Attachment 2 to this letter).

No Significant Basards Consideration The Nuclear Regulatory Commission (NRC) has promulgated standards in 10CFR50.92(c) for determining whether a proposed amendment to a facility operating license involves no significant hazards consideration. A proposed i amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would nott l (1) Involve a significant increase in the probability or consequences of an accident previously evaluatedt or (2) Create the possibility of a new or different kind of accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

l CEI has reviewed the proposed amendment with respect to these stendards and j has determined that the proposed changes do not involve a significant hasard i

because: 1 L

(1) The proposed chs ge does not involve a significant increase in the probability or cons w ences of a previously evaluated accident for a number of reasons. First, the 3.25 surveillance interval extension criteria of T.S.

4.0.2.b was not depended upon in the accident / transient analyses of PNPP's Updated Safety Analysis Report (USAR) Chapter 15. Also, removal of the 3.25 limit on extension of surveillance intervals does not involve a physical change or alteration to any plant component or system which could cause the probability of an accident or transient to increase.

Third, the allowance to extend surveillance intervals by 25 percent can result in a significant safety benefit for surveillances that are performed on n  :

routine basis during plant operation. This safety benefit is incurred when a surveillance interval is extended at a time when conditions are not suitable for performing the surveillance, for example, during transient plant operating :

l conditions or when safety systems are out-of-service due to on-going surveillance or maintenance activities. During transient operating conditions, performance of a surveillance could render systems or components inoperable while the plant is in a transient state involving changing plant conditions that offer the potential for an upset that could lead to a demand for the system or component being tested. When safety systems or components I are out-of-service due to ongoing surveillance or maintenance activities, rendering related or redundant systems or components inoperable in order to perform a surveillance vould reduce the number of systems available for 1

-. i I  !

re. . . .

<w 'PY-CEI/NRR-1103 L Attachment 1 j

• j Page 4 of 5 response to a plant emergency, as well as create the potential for not reeting LCOs, which could then force initiation of plant shutdowns. Performance of a l' surveillance during a time period when it would place the plant into an LCO or during plant shutdown would also increase the pressure on the plant staff to expeditiously complete the surveillance so that the plant could be returned to normal operation. This may further increase the potential for a plant upset ,

when both the shutdown and surveillance activities place a burden on the plant  !

operators. In addition, performance of surveillances when related safety i systems or components are already out-of-service may result in an increased j and unnecessary potential for an inadvertant scram and subsequent safety '

system challenges. In such cases, the safety benefit obtained by use of the 25-percent allowance for extending the surveillance interval unrestricted by the 3.25 limit would outweigh any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit.

I Fourth, the 3.25 limit has not been a practical limit on the use of the 25-percent allowance for extending surveillances that are performed on a '

refueling outage basis because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances. I i

Fifth, equipment vill continue to be proven operable on a regular basis in accordance with new Specification 4.0.2: l (1) Specification 4.0.2a currently permits surveillance intervals to be ,

extended up to 25-percent of the specified interval in order to i facilitate scheduling of surveillance activities and to allow for postponement when plant conditions are not suitable for conducting a surveillance, for example, under transient conditions or other j on-going surveillance or maintenance activities. Thus, the 25-percent limit has been determined to be a safe and practical limit on the extension of surveillance intervals. It is overly conservative to assume that systems or components are inoperable l vhen a surveillance requirement has not beu performed within the 1 3.25 (T.S. 4.0.2b) utension limitation where performance of the .

surveillance is otherwise possible within the allovable 25-percent extension limit of T.S. 4.0.2(a).

1 (ii) Extension of surveillance intervals vill continue to be limited by I the current 25-percent restriction of T.S. 4.0.2a; Generic Letter 89-14 has expressed agreement with these concepts.

1 Since this change does not result in a physical change or alteration to any l component or system, and since the equipment on which the surveillances are l being performed vill continue to be proven operable and vill continue to be available to respond to' mitigate any previously evaluated transients or accidents, the consequences of such events vill not be increased.

i l

l

PY-CEI/NRR-1103 L Attachment 1

! Page 5 of 5 (2) The proposed change does not create the possibility of a new or different kins of accident from tny accident previously evaluated because the proposed change does not involve a change f.: the design of any plant system or component nor does it involve a change in the operation of any plant system or component. The surveillance interval vill continue to be limited to the 25-percent interval extension criteria of the current T.S. 4.0.2a.

(3) The proposed change does not involve a significant reduction in the

' margin of safety because surveillance intervals vill continue to be constrained by the 25-porcent extension limitation of the current T.S. 4.0.2a, .

which provides an allowable tolerance for performing surveillance requirements beyond those specified in the normal surveillance interval. The surveillance limitation of T.S. 4.0.2a is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the surveillance requirements. It is maintained that the 25 percent limitation is sufficient to ensure that the reliability of equipment verified through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

The NRC Staff has also expressed their agreement with this pesition in Generic Letter 89-14, and equivalent wording has been provided in the proposed bases for this Technical Specification change.

ENVIRONNENTAL CONSIDERATION l The Cleveland Electric Illuminating has reviewed the proposed Technical Specification change against the criteria of 10 CFR 51.22 for environmental ,

considerations. As shown above, the proposed change does not involve a significant hazards 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 foregoing, CEI l concludes that the proposed Technical Specification change meets the criteria 1 given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement ,

for an Environmental Impact'Statemc...

l l

l NJC/ CODED /2878 1

l l

_.