ML20012E049
| ML20012E049 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/22/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20012E048 | List: |
| References | |
| NUDOCS 9003300005 | |
| Download: ML20012E049 (3) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION j
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E W ASHINGT ON. D. C. 20666 j
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%..... 'l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i
RELATED TO AMENDMENT NO. 52 TO FACILITY OPERATING LICENSE NO. NPt-30 i
UN10h ELECTRIC COMPANY CALLAWAY PLANT. UNIT 1 DOCKET ND. 5TN 50-483
1.0 INTRODUCTION
By letter dated November 14, 1989, Union Electric Company (the licensee) proposedchangestotheTechnicalSpecifications(TS)fortheCallaway I
Plant. The proposed changes would remove the provision of Specification 4.0.2 that limits the combined time interval for three consecutive surveil-l lances to less than 3.25 times the specified interval. Guidance on this proposed change to the TS was provided to all power reactor licensees and epplicants by Generic Letter 89-14 dated August 21, 1989.
2.0 EVALUATION l
Specificetlon 4.0.2 includes the provision that allows a surveillance interval to be extended by 25 percent of the specified time interval. This extension I
provides flexibility for scheduling the performance of surveillances and to permit consideration of plant operating condit4ons that may not be suitable for conducting a surveillance at the specified time interval. Such operating conditions include transient plant operation or ongoing surveillance or maintenance activities.
Specification 4.0.2 further limits the allowance for extending surveillance intervals by requiring that the combined time I
interval for any three consecutive surveillances not exceed 3.25 times the specified time interval. The purpose of this provision is to assure that surveillances are not extended repeatedly as an operational convenience to e
provide an overall increase in the surveillance interval.
Experience has shown that the 18-month interval, with the provision to extend it by 25 percent, is usually sufficient to accommodate normal variations in the length of a fuel cycle.
However, the NRC staff has routinely aranted reauests for one-time exceptions to the 3.25 limit on extending refueling surveillances because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances. Therefore, the 3.25 limitation on extending surveillances 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.
Extending surveillance intervals during plant operation can also result in a benefit to safety when a scheduled surveillance is due at a time that is not suitable for conducting the surveillance. This may occur when transient 900330000D 900322 PDR ADOCK 05000483
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. l plant operating conditions exist or when safety syst3ms are out of service for maintenance or other surveillance activities.
In such cases, the benefit to safety of extending a surveillance interval would exceed any safety benefit derived by limiting the use of the 25-percent allowance to extend a surveillance.
Furthermore, there is the administrative burden associated with tracking the use of the 25-percent allowance to ensure compliance with the 3.25 limit.
In view of these findings, the staff concluded that Specification 4.0.2 should be changed to remove the 3.25 limit for all surveillances because its renoval will have an overall positive effect on safety. The guidance provided in Generic Letter 89-14 included the following change to this specification and removes the 3.25 limit on three consecutive surveillances with the following statement:
1 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.
In addition, the Bases of this specification were updated to reflect this change and noted that it is not the intent of the allowance for extending surveillance intervals that it be used repeatedly merely as an operational convenience to extend surveillance intervals beyond those specified.
The licensee has proposed changes to Specification 4.0.2 that are consistent with the guidance provided in Generic Letter 89-14, as noted above. On the basis of its review of this matter, the staff finds that the above changes to the TS for the Callaway plant are acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change to a requirement with respect to the instal-lation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or a change to a surveillance requirement. The staff has determined that the amendment involves no significant increase in the enounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or 1
cumulative occupational radiation exposure. The Commission has previously l
issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forthin10CFR51.22(c)(9).
Pursuantto10CFR51.22(b),noenvironmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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4.0 CONCLUSION
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The staff has cencluded, based on the considerations discussed above, that:
i (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed nenner; and (2) such i
activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Thomas G. Dunning OSB/DDEA I
S. V. Athavale, PD111-3 i
i Dated:
March 22, 1990 s.
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