ML20012A152

Application for Amend to License DPR-16,consisting of Tech Spec Change Request 184,removing 3.25 Limit on Extending Surveillance Intervals,Per Generic Ltr 89-14

ML20012A152
Person / Time
Site:	Oyster Creek
Issue date:	02/23/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20012A151	List: ML20012A150 ML20012A152 ML20012A154
References
GL-89-14, NUDOCS 9003080411
Download: ML20012A152 (6)

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l GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR = GENERATING STATION Provisional" Operating License No'. DPR-16 Technical Specification Change Request No. 184 Docket No. 50-219 Applicant submits,.by this Technical Specification Change Request No. 184 to the Oyster Creek Nuclear Generating Station Technical Specifications, a change to pages 1.0-5, 1.0-6, and 1.07.

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By E. E. Fitzpat'rlek Vice President and Director l ' Oyster Creek  ;

I Sworn'and Subscribed to beforo me this. T M ' day of Mg 990. s l:

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A Notary Public of l'J l t l DIANA M. DeBLASIO -

NOTARY PUBUC OF NE JE

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1

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.In the Matter of ) i

) Docket No. 50-219 GFU Nuclear Corporation' ) >

f GEET1."ICATE OF SERVICE This is to certify that a copy'of Technical Specification Change Request No.

184'for Oyster Creek Nuclear Generating Station Technical Specifications,

~ filed with the U.S. Nuclear Regulatory Commission on Februnry 23, 1990-has this day of Februnry 23, 1990 , been served on the Mayor of

~ Lacey Township, Ocean County, New Jersey by deposit in the United States mail, addressed as'follows:

s The Honorable Debra Madensky Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731-By

'E. E. Fitzpa' trick Vice President and Director Oyster Creek e

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g1TTER CREEK NUCLEAR GENERATING STATION

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I'**** PROVISIONAL OPERATING LICENSE NO. DPR-16 i DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 184 ,

t Applicant hereby requests the commission.to change Appendix A to the above captioned ,

license as below, and pursuant to 10CFR50.91, an analysis concerning the

• determination of ne significant hazards consideration is also presented ,

1.0 SECTIONS TO BE CHANGED l

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Definition Section 1.24. i

.i 2.0 EXTENT OF CHANGE This change is requested to modify the OCNGS Technical' specifications to remove -!

the 3.25 limit on axtending surveillance intervals and to add the bases for the existing 25% allowance, in accordance with the guidance contained in NRC Gensric Letter 69-14, 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.

3.0 CHANGES REOVESTED The requested-change is shown on~ attached Technical Specification page 1.0-5.

Attached pages 1.0-6 and 1.0-7 have been retyped due to the change to page 1.0-5.

4.0 DISCUSSION 4 OCNGS Technical Specification Definition;1.24, Item "B", which currently specifies that a total maximum combined interval time for.any three consecutive, surveillance intervals 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 Ceneric Letter 89-14.. The existing-Definition 1.24, Item "A" permits a maximum allowable extension of 25% of all normal surveillance intervals to facilitate surveillance scheduling and N' consideration of plant operating conditions that may not be suitable for-

-conducting the surveillance (e.g. transient conditions, or other ongoing n surveillance or maintenance activities).

I b d ItLalso provides flexibility to accommodate the length of a fuel cycle for

-surveillances that are performed au each refueling outage and are specified with fa fuel cycle length surveillance interval. It is not intended that this L'

. provision be used repeatedly as convenience to extend surveillance intervals beyond that specified for curveillanced that are not performed during refueling outages.

r The use of the allowance to extend surveillance intervals by 251 provides a p safety benefit when a surveillance interval is extended at a time that conditions are not suitable.for performing the surveillance. Examples 1 include transient plant operating conditions or conditions in which safety systems are g out of service because of ongoing surveillance or maintenance activities. The safety benefit.of allowing the use of the 25% allows m a to extend a surveillance

~ interval in'auch cases outweighs any benefit derived by limiting three consecutive surveillance intervals to the 3.25. limit. Therefore, there is an 3,'"

L .overall positive effect on safety.

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.i iThe. administrative burden of tracking the use of the 25% allowance to ensure.

coepliance with the 3.25 limit is also eliminated.

5.0 DETERMINATION

, Jo GPUN has determined that this Technical Specification Change Request involveo 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 i consequences of an accident previously evaluated. The proposed amendment i removes the 3.25 limit on extending surveillance intervals and adds the Bases statementa for the existing 25% allowance, in accordance with the guidance contained in HRC Gencric 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 not '

suitable for performing the surveillance (e.g. tra . tent plant operating conditions or.other ongoing surveillance or mainte:.ance activities). The safety benefit of allowing the use of the 25% allowance to extend a

,uurveillance 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 reliab+11ty ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval. Therefore, this change does not increase this probability of occurrence or the consequences of an accident previously >

evaluated.

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2. Operation of the facility in accordance with the proposed amendment 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 l the actual surveillance requirements and allows a surveillance interval to be extended at a time that conditions are not suitable for performing the surveillance. Therefore, this change han 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 curveillance interval in such cases outweighs any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. This chenge 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.

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.

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" The commission has provided guidelinen 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 (i)'of amendments that are: considered not likely to involve significant hazards consideration.in that the proposed change constitutes a purely administrative change to Technjcal Specifications. This-change is similar in that it implements the guidance contained in NRC Generic Letter 89-14 for removal of the 3.25 limit on extending surveillance intervals. Implementation of the proposed amendment in accordance

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-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.

6.0 IMPLEMENTATION s

It is requested that the amendment authorizing this change become effective upon yp issuance. ,

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