ML20034G568
| ML20034G568 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/25/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20034G564 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 9303100117 | |
| Download: ML20034G568 (3) | |
Text
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WASHINGTON. D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 78 TO FACILITY OPERATING llCENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By letter dated March 8,1990, the Union Electric Company (the licensee) requested an amendment to facility Operating' License No. NPF-30 for the Callaway Plant, Unit 1.
The proposed amendment would change the plant Technical Specifications (TSs) based on the recommendations provided by the NRC staff in Generic Letter (GL) 87-09 related to the applicability of limiting conditions for operations (LCO) and the Surveillance Requirements of TS 4.0.
Specifically, the licensee has requested the following revisions to TS 4.0.3 and 4.0.4 as follows:
Specification 4.0.3 would be revised to incorporate a 24-hour delay in implementing Action requirements due to a missed surveillance when the Action requirements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Specification 4.0.4 would be revised to clarify that "This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements."
By letter dated August 8, 1991, the licensee provided clarifying information I
and bases revisions associated with TSs 4.0.3 and 4.0.4 that did not change the initial proposed determination of no significant hazards consideration or affect the notice published June 13, 1990 (55 FR 24007).
2.0 EVALUATION The changes proposed by the licensee have been reviewed considering the limitations set forth in GL 87-09 for TS 4.0.3 and 4.0.4 as follows.
Specification 4.0.3 In GL 87-09 the staff stated that it is overly conservative to assume that systems or components are inoperable when a Surveillance Requirement has not been performed, because the vast majority of surveillances demonstrate that systems or components in fact are operable.
Because the allowable outage time limits of some Action requirements do not provide an appropriate time limit j
for performing a missed surveillance before shutdown requirements apply, the l
TS should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.
9303100117 930225 l
PDR ADOCK 05000483 p
- The NRC staff has provided in GL 87-09 a clarification that: (a) it is not the intent of 4.0.3 that the Action requirements preclude the performance of surveillances allowed under any exception to TS 4.0.4; and (b) the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in TS 4.0.3 for the applicability of Action requirements provides an appropriate time limit for the completion of Surveillance Requirements that become applicable as a consequence of any exception to TS 4.0.4.
Consequently, the NRC staff finds the proposed changes to TS 4.0.4 acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment. The' State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment involves changes to surveillance requirements. The staff has i
determined that the amendment involves no significant increase in the amounts, 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 cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (55 FR 24007). Accordingly, this amendment meets the eligibility criteria for 1
categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
I The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) 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 Contributors:
J. Stefano A. T. Gody, Jr.
Date: February 25, 1993 l
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- i This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, and the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance. After reviewing possible limits, the staff concluded that, l
based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for i
completing a missed surveillance when the allowable outage times of the Action a
requirements are less than this time limit or when shutdown Action requirements j
apply.
The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action requirements before the surveillance can be completed.
Based on the above, the following change to Specification 4.0.3 is acceptable:
i Failure to perform a Surveillance Requirement within the allowed surveillance i
interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation.
The time l
limits of the ACTION requirements are applicable at the time it 's identified that a Surveillance Requirement has not been performed.
Compliance with the ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the Action requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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Specification 4.0.4 TS 4.0.4 pro d its entry into an OPERATIONAL CONDITION or other specified
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condition until all required.surveillances have been performed. This could cause an interpretation problem when OPERATIONAL CONDITION changes are required i
in order to comply with ACTION statements.
Specifically, two possible conflicts between TSs 4.0.3 and 4.0.4 could exist. The first conflict arises because 15 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance interval.
The Union Electric Company proposed modification to j
resolve this conflict involves the revision to TS 4.0.3 to permit a delay of up i
to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the Action requirements, as explained above, and a clarification to TS 4.0.4 to allow passage through or to operational modes l
as required to comply with Action requirements.
The second potential conflict l
between TSs 4.0.3 and 4.0.4 arises because an exception to the requirements of l
4.0.4 is allowed when surveillance requirements can be completed only after l
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entry into a mode or condition. However, after entry into this mode or condition, the requirements of TS 4.0.3 may not be met because the Surveillance l
Requirements may not have been performed within the allowable surveillance
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interval.
The licensee proposes to resolve these conflicts by providing the following clarifying statement to TS 4.0.4-I
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"This provision shall not prevent passage through or to OPERATIONAL CONDITIONS l
i-as required to comply with ACTION requirements."
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