ML20043C812

Application for Amend to License DPR-46,revising Tech Spec Section 1.0, Definitions to Allow Extension of Specified Surveillance Intervals by 25% W/O Limiting Such Extension to 3.25 Times Specified Interval for Three Intervals

ML20043C812
Person / Time
Site:	Cooper
Issue date:	06/01/1990
From:	Kuncl L NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20043C813	List: ML20043C812 ML20043C814
References
GL-89-14, NLS9000209, NUDOCS 9006060210
Download: ML20043C812 (5)

Text

_. ._.

P.O. BOX 490, C LU S. E A$KA let02-0400 w

Nebraska Public Power District *0i3lPJ2" -1 1

I I

NLS9000209 June 1, 1990 U.S. Nuclear Regulatory Commission 1 Document Control Desk I Washington, D.C. 20555 Gentlement

Subject:

Proposed Change No. 80 to Technical l Specifications '

Definition of Sur .411ance Frequency Cooper Nuclear Station NRC Docket No. 50-298, DPR-46 In accordance with the applicable provisions specified in 10CFR50, Nebraska Public Power District proposes the attached changes to Section 1.0 " Definitions" of the Cooper Nuclear Station Technical Specifications. The proposed change will revise the existing definition of

" Surveillance Frequency" by allowing the extension of specified surveillance intervals by 25 percent without limiting such extension to 3.25 times the specified interval for (three) 3 consecutivo intervals. This proposed change is an NRC recommended line-item improvement and is made in accordance with the guidance of NRC Generic Letter 89-14 of August 21, 1989.

l The Attachment contains a description of the proposed l

change, the attendant 10CFR50.92 ovaluation, and the i applicable revised Technical Specification page. This l proposed change has been reviewed by the necessary Safety Review Committees and incorporates all amendments to the CNS Facility Operating Licenso through Amendment 133 l issued April 12, 1990.

In addition to the signed original, 37 copies are also submitted for your use. By copy of this letter and l attachment the appropriate State of Nebraska of ficial is i

being notified in accordance with 10CFR50.91(B) (1).

Copies to the NRC Region IV Office and the CNS Resident Inspector are also being sent in accordance with 10CFR50.4(b) (2).

9006060210 900601 PDR P

ADOCK 05000298 PDC U[h[

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... June 1,11990 Should ' you have any questions or require additional )

information, please contact me. j

)

Sincer y,  ;

l L.'G. Kuncl l Nuclear Power Group Manager j l

LGKtdmr 8506 i Attachment cet H. R. Borchert i Department of Health

• State of Nebraska  ;

i NRC Regional Office i Region IV Arlington, TX  :

L NRC Resident Inspector Office

.s Cooper Nuclear Station  ;

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, P^g3 3 June 1, 1990 STATE OF NEBRASKA )

)ss PLATTE COUNTY )

L. G. Kuncl, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the statements contained horcin are true to the best of his knowledge and belief.

W L. G. K6nc1 Subspribed in ny pres,qnce and sworn to before me this

/DC day of U, U A2 , 1990.

CD -

NOTARY PUBLIC /

Gluem ammme a en.u ecuseN M 4 essa se as.KuTA 4, ages L

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i}7 k;, , Revised Technical Specification Page l p~ Definition of Surveillance Frequency  ! Cooper Nuclear Station 1 Revised Page: $a i Present Cooper Nuclear. Station (CNS) Technical Specifications, in Section 1.0 Y , CSurveillance Frequency", limits the ' combined time interval for any ( three

              . consecutive surveillance intervals to no more than 3.25 times the specified                        a curveillance interval. The 3,25 limit is used in conjection with another limit                     q cpecified -in Section 1.0.Y of the CNS Technical Specifications that permits-                          l i           - surveillance intervals to be extended up to 25 percent of the specified interval. .                   i Per Ceneric Letter 8914, the intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent,                             ,

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               - In Ceneric Letter 8914, the NRC encouraged licensees and applicants to propose                       ,

lL, changen to their plant Technical Specifications to remove the 3.25 limitation l

             - using the provided guidance. A safety benefit'can be realized by-applying the                          i 25 percent to surveillance intervals without the limitation imposed by the three consecutive interval requirement. The safety benefit results when a surveillance
 >              interval is extended around plant conditions that could be unsuitable for performing the surveillance or maintenanco activities. Examples of unsuitable plant conditions include transient plant operating conditions or conditions                           ,
              - involving safety systems being out of service for surveillance or maintenance                        ;
              - cctivities. Also, there is the administrative burden associated with tracking i               the use of the 25 percent allowance to ensure compliance with the 3,25 limit.

The District requests to revise the CNS. Technical Specifications to implement' -! the recommended actions of Ceneric 1.e t te r 89 14 The proposed changes are

              - consistent with the guidance of the generic letter in that they:                                     .

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1) .; Delete the 3.25 limitation in Specification l'.0.Y on Page Sa.

2). Utilize the exact, suggested wording of tho generic letter in Specification 1.0.Y for the 25 percent surveillance allowance. ' 3)... .. Incorporate the suggested bases. of the generic letter into the body of Specification 1.0.Y, since the CNS Technical Specifications do. not use l the Standard Technical Specification format and have no comparable. bases section i a Evnluation of This Revision with Respect to 10CFR5n.92 i

           ' ' ' The enclosed Technical Specification change is judged to involve no significant                     ,

hazards based on the following:

1. Does the proposed license amendment involve a significant increase in the  !

probability or consequences' of an accident previously evaluated? Evaluation:  ! The proposed amendment would remove f rom the plant Technical Specifications l L

                       -the limit- on the combined time interval for any three consecutive                           i

!' surveillance' intervals to not exceed 3.25 times the specified surveillance - interval. Removal'of this 3.25 limit on surveillance extension does not 1

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   ,                . involve a physical change or alteration to any plant component or system which could cause the probability of an accident or transient to increase, Plant Technical Specifications will continue to limit the extension of surveillance intervals by no more than 25 percent of the intervals. This g                 25 percent allowance can realize a safety benefit by. permitting F                 surveillance intervals to be extended at times when plant conditions may L                .not be suitable for performing that surveillance such as transient plant operating conditions or equipment being out of service for on going surveillance or' maintenance,     In such cases the safety benefit obtained by.use of the 25 percent allowance for extending the surveillance interval would me be restricted by the 3,25 limit which is being removed by this license arnendment.

Existing equipment surveillance requirements are not affected by this license amendment and the extension of surveillance intervals will continue.

   ;L                to be limited by the allowable 25 percent extension limit discussed above.

[ The equipment on which the surveillances are being performed will continue j to be proven operable and will continue to be available to respond to and , f mitigate any previously evaluated transients or accidents. U For the reason above, the proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. I 2. Does the proposed license amendment create the possibility of a new or different kind of accident froin any accident previously evaluated? Evaluation: The proposed license amendrnent does not change the plant equipment: configuration or. operation and is, administrative in nature. The proposed license amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated. L . . i 3. Does the proposed license amendment involve a significant reduction in the margin of safety? 4 4 Evaluation: The proposed amendment would remove from the plant Technical Specifications . the . limit on the combined timo interval for any three consecutive b -surveillance intervals to not exceed 3.25 times the specified surveillance

                    . interval,   Surveillance intervals will continue to be constrained by the 25 percent extension limitation retained-- in. the plant Technical Specifications. This surveillance limitation is based on engineering judgement and . the recognition that tho most probable result of any particular surveillance being performed is the verification of conformance with the surveillance requirements. Removal of the 3.25 limit will allow more: flexibility in' the performance of equipment surveillance around
                   -certain plant conditions that' may present . increased likelihood of unnecessary transients or challenges to safety systems.

The proposed license amendment does not change any plant operating setpoint or limiting plant' safety system setting and does not involve a significant reduction l in the margin of safety. 2

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