ML20043F776
| ML20043F776 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/21/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20043F772 | List: |
| References | |
| GL-89-14, NUDOCS 9006180118 | |
| Download: ML20043F776 (3) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULAT10M SUPPORTING AMENDMENT N05. 38 AND 5 TO FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF-85 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 INTRODUCTION
By letter dated March 23, 1990, Philadelphia Electric Company (the licensee) requested an amendment to Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2..These proposed amendments would remove the provision of Specification 4.0.2 that' limits the combined time interval of three consecutive surveillances-1 to less than 3.25 times the specified interval. Guidance on this proposed change to TS was provided to all power reactor licensees and applicants by Generic Letter 89-14, dated August 21, 1989.
("A Line.
Item Technical Specification Improvement-Removal of 3.25 Limit on ExtendingSurveillanceIntervals.")
2.0 EVALUATION s
Specification 4.0.2 includes the provision that allows'a surveillance interval to.be extended by 25 percent of the specified time interval.
This extension provides flexibility for scheduling the performance of surveillances and to permit consideration of plant operating conditions 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. Specifi--
cation 4.0.2 further limits the allowance for extending surveillance intervals by requiring that the combined time 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 provide an overall increase in the surveillance interval. Experience has shown that the 18-month surveillance 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 ~ granted requests for one-time exceptions to the 3.25 limit on extending refueling i
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 L
surveillances that are performed on a refueling outage basis.
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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 plant operating conditions exist or when safety systems 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.
Furthennore, there is the administrative burden associated with trackino the use of the 25-percent allowance to ensure compliance with the 3,25 Timit.
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 removal 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:
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 that 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 Limerick Units 1 and 2 are acceptable.
The NRC staff with the knowledge and consent of the licensM made typographical corrections to the licensee's Technical Specification pages.
3.0 ENVIRONMENTAL CONSIDERATION
These amendments involve a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that these 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 signifi-cant increase in individual or cumulative occupational radiation exposure.
The Comission has previously issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant i
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3-to10CFR51.22(b),noenvironmentalimpactstatementnorenvironmental assessment need be prepared in connection with the issuance of these amendments.
4.0 CONCLUSION
l The Commission made a proposed determination that these amendments involve no significant hazards consideration which was published in the Federal Register (55 FR 14515) on April 18, 1990 and consulted with the Commonwealth of Pennsylvania. No public comments were received and the Commonwealth of Pennsylvania did not have any comments.
1 The staff has concluded, based on the considerations discussed above, that: -(1) there is reasonable assurance that the health and safety of the p(ublic will not be endangered by operation in the proposed manner, and2) such regulations and the issuance of these amendments will not be inimical to the common defense and the security nor to the health and safety of the public.
Dated: May 21, 1990 Principal Contributor:
Richard J. Clark O
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