ML20035A783
| ML20035A783 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/22/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20035A781 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 9303290300 | |
| Download: ML20035A783 (5) | |
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UNITED STATES
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Y SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i
REl ATED TO AMENDMENT NO. 59 TO FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 38 TO FACILITY OPERATING LICENSE NPF-81 l
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V0GTLE ELECTRIC GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425 l
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1.0 INTRODUCTION
By letter dated May 27, 1992, as supplemented December 7,1992, Georgia Power Company, et al. (the licensee) proposed license amendments to change the 1
Technical Specifications (TS) for Voutle Electric Generating Plant (Vogtle),
l Units 1 and 2.
The proposed changes would revise Sections 3.0 and 4.0 of the 15 to incorporate the changes recommended in NRC's Generic Letter (GL) 87-09,
" Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the l
Applicability of Limiting Conditions for Operation and Surveillance Requirements."
In thi.s letter the NRC has concluded that certain recommended
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modifications to TSs 3.0.4, 4.0.3 and 4.0.4 would clarify the intent of these lbs and would resolve three problems associated with the existing i
requirements, as follows:
(1) the revision of TS 3.0.4 would remove unnecessary restrictions on operational mode changes in those cases where conformance with Action Statement requirements provides an acceptable level of safety for continued operation for an unlimited period of time: (2) the J
l revision of TS 4.0.3 would provide a 24-hour delay before implementing TS Actinn Statement Requirements due to a missed surveillance, in those cases where the required restoration time is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (3) the 1
revision of TS 4.0.4 would assure that its Surveillance requirements do not j
prevent the plant's passage through or to Operational Modes as required to comply with TS Action Statement requirements.
2.0 EVALUATION r
l Technical Specification 3.0.4 l
The existing 1S 3.0.4 specifies, in part, that " Entry into an Operational Mode 3
or other specified condition shall not be made unless the conditions for the Limiting Condition for Operation (LCO) are met without reliance on provisions contained in the Action requirements." The staff position in GL B7-09 is that
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this TS, as presently written to exclude reliance on provisions contained in the Action requirements, " unduly restricts facility operation when conformance 9303290300 930322 ADOCK 0500 $.-.4 PDR
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to the Action Requirements provides an' acceptable level of safety. for continued operation.
For an LCO that has Action Requirements permitting continued operation for an unlimited period of-time, entry into an operational i
made or other specified condit. ion of operation should be permitted in accord:r.cc with those Action Requirements.
This'is consistent with f4RC's f
regulatory requirements for an LCO. The restriction on a change in I
operational modes or other specified conditions should apply only where the l
Action Requirements establish a specified time interval in which the LCO must i
be met or a shutdown of the facility would be required. However, nothing in l
this staff position should be interpreted as endorsing or encouraging a plant st art un wit h inn,nerable e pipmeat.
The staff believes that good practice
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should dictate that the plant startup should normally be initiated only when i
all required equipment is operable and that startup with inoperable equipment
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must be the exception rather than the rule."
I In accordance with this position, the staff recommended in GL 87-09 the f ollowing change to replace the first sentence of TS 3.0.4:
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Entry into an OPERATIONAL MUDE or other specified condition shall not be j
made when the conditions for the i.imiting Conditions for Operation are j
not met and the associated ACTION requires a shutdown if they are not met l
within a specified time interval.
Entry into an OPERATIONAL MODE or varifiad ennditinn may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for t
an unlimited period of time.
The licensee's proposed changes to TS 3.0.4 conforms to the above staff recommendation and is, therefore, acceptable.
The revised TS 3.0.4 eliminated the need for exceptions to it in TSs for a number of individual systems.
For such systems -the exceptions to TS 3.0.4 l
are deleted in the proposed TS changes.
Since these deletions'are consistent with the revised form of TS 3.0.4, we find that they are acceptable.
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Technical Specification 4.0.3 Vogtle IS 4.0.3 presently states that failure to perform a Surveillance i
Requirement within the specified surveillance interval shall constitute a failure to meet the operability requirements for an LCO. When an LCO is not met. TS 3.0.3 requires that shutdown actions be initiated within I hour.
In GL 87-09, the staff finds:
f 11 is overly conservative to assume that systems or components are
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inoperable when a surveillance requirement has not been performed.
The opposite is in fact the case; the vast majority of surveillances demonstrate that systems or components in fact are operable.
When a i
surveillance is missed, it is primarily a question of operability that i
has not been verified by the performance of the required surveillance.
i Because the allowable outage time limits of some Action' Requirements do i
not provide an appropriate time limit for performing a missed i
surveillance before shutdown requirements may apply, the Technical
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Specifications should include a time limit that would allow a delay of i
the required actions to permit the performance.of the missed i
surveillance.
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The time limit should be based on considerations of plant conditions, l
adequate planning, availability of personnel, the time required to I
i perform the surveillance, as well as the safety significance of the delay l
in completion of the surveillance. After reviewing possible limits, the 3
staff has concluded that, based on these considerations, 24-hours would i
be an acceptable time limit for completing a missed surveillance when the limit or when shutdown Action Requirements apply.
The 24-hour time limit i
would balance the risks associated with an. allowance for completing the l
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surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the l
alternative is a shutdown to comply with Action Requirements before the
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surveillance can be completed.
I The staff recommended in GL 87-09 the following reeired version of TS. 4.0.3:
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Failure to perform a Surveillance Requirement within the allowed i
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survcillance interval, defined by Specification 4.0.2, shall constitute i
noncompliance with thu OPERABILITY requirements for a Limiting Condition l
for Operation.
The time limits of the ACTION requirements are applicable j
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at the time it is identified that a Surveillance Requirement has not been t
l performed.
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 l
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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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In GL 87-09, the staff also recommended the deletion of the statement that exceptions to TS 4.0.3 are stated in individual specifications.
This l
l-statement is deleted because TS 4.0.3 is always applicable and there are no l
exceptions for individual specifications.
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The licensee's proposed change to TS 4.0.3 is identical to the above version j
l recommended by the NRC staff and is, therefore, acceptable.
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Technical Specification 4.0.4 l
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Vogtle TS 4.0.4 currently requires that before a new Operational Mode is
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entered, Surveillance Requirements pertaining to the new mode are to be j
l performed within time limits specified by TS 4.0.3.
A conflict arises when Action Requirements require a mode change, but the Surveillance Requirements 1
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which become applicable in the new mode have not been performed within the j
specified interval so that IS 4.0.4 does not permit a mode change.
If an
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exception to TS 4-.0.4 is allowed (e.g., for cases where the Surveillance 5
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2 Requirements can only be completed af ter entry into the mode to which they i
apply), there may still be a conflict with TS 4.0.3 if the Surveillance l
Requirements have not been performed within thE allowed surveillance internal.
In GL 87-09, the staff took the following position:
I The potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply i
with Action Requirements.
It is not the intent of Specification 4.0.4 to j
prevent passage through or to operational modes to comply with Action l
P.c:;uirements cr.d it should r.ct apply when mode changes are imposed by i
Action Requirements. Accordingly, Specification 4.0.4 should be modified i
to note that its provisions shall not prevent passage through or to i
j operational modes as required to comply with Action Requirements. A i
similar provision is included in Specification 3.0.4.
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" h not the intent of Specification 4.0.3 that the Action Requirements should preclude the performance of surveillances when an exception to 2
i Specification 4.0.4 is allowed.
However, since Specification 4.0.3 has l
been changed to permit a 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 the applicability of l
4 the Action Requireme.ts, an appropriate time limit now exists for the i
l completion of those Surveillance Requirements that become applicable when cn exceptica to Specificatica 4.0.4 is allowed.
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Based on these considerations, the staff recommended in GL 87-09 that the j
following sentence be added to TS 4.0.4:
i This provision shall not prevent passage through or to OPERATI0t4AL MODES n rce,m cd to ccmply..ith ACT'0" Recidirements.
l The licensee's proposed change to TS 4.0.4 is identical to the NRC staff's j
recommendation and is, therefore, acceptable.
I Bases for TSs 3.0 and 4.0 j
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i The licensee's proposed revisions to the Bases for TSs 3.0 and 4.0 are i
icentical to those recommended by the staff in GL 87-09, except for three
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added sentences providing an example intended to clarify the shutdown time j
i requirements of TS 3.0.3.
The added example is consistent with the bases of TS 3.0.3 and is, therefore, acceptable.
The remaining Bases for TSs 3.0 and l
j-4.0 are identical to those recommended by the staff and are, therefore, l
l acceptable.
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3.0 STATE CONSULTATION
l In accordance with the Commission's regulations., the Georgia State official was notified of the proposed issuance of the amendments. The State official f
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4.0 ENVIRONMENTAL CONSIDERATION
i The amendments change requirements with respect to installation or use of a l
i facility component located within the restricted area as defined in 10 CFR i
Part 20 and change surveillance requirements. The NRC staff has determined i
r that the amendments involve 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 the amendments involve no significant hazards consideration, and there has been no public comment on such finding (58 FR 593 dated January 6, 1993). Accordingly, the amendments meet the eligibility criteria fur tate 9urital exclusion set forth in 10 CFR i
1 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or
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environmental assessment need be prepared in connection with the issuance of i
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the amendments.
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5.0 CONCLUSION
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J The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the
-i 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 the amendments will not be inimical to the common i
defense and security or to the health and safety of the public.
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i Principal Contributors:
S. Kirslis D. Hood d
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cate:
sorch 22, 1993 i
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