ML20043G591

Application for Amends to Licenses NPF-37,NPF-66,NPF-72 & NPF-77,changing Tech Spec 4.0.2,based on Guidance in Generic Ltr 89-14,to Remove 3.25 Times Original Surveillance Interval Limitation for Consecutive Surveillances

ML20043G591
Person / Time
Site:	Byron, Braidwood
Issue date:	06/04/1990
From:	Hunsader S COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20043G592	List: ML20043G591 ML20043G595
References
GL-87-09, GL-87-9, GL-89-14, NUDOCS 9006200465
Download: ML20043G591 (6)

Text

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_ ') 1400 Opus Place Commonwealth Edison

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Downers Grove, Illinois 60515

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June 4,1990 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Consnission Washington, DC 20555 e

Attnt Document Control Desk

Subject:

Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Application f>r Amendment to Facility Operating Licenses NPF-37, NPF-66 NPF-72 and NPF-77 Appendix A, Technical Specifications NRC_ Docket Nos. 50-454. 50-455. 50-456. and 50-457 References (a) November 30, 1988, S.C. Hunsader letter to T.E. Murley (b) May 30, 1990 S.C. Hunsader letter to T.E. Murley

Dear Dr. Murley:

Pursuant to 10 CFR 50.90, Con.nonwealth Edison (Edison) proposes to amend Appendix A. Technical Specifications, of Facility Operatiiig Licenses NPF-37,

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NPF-66, NPF-72 and NPF-77. The proposed amendment requests a change to Technical Specification 4.0.2 and its associated bases, based on the guidance in Generic

. Letter 89-14, to remove the 3.25 times the original surveillance interval limitation for consecutive surveillances.

In reference (a) Edison had provided a proposed Technical Specification amendment, in accordance with the guidance of Generic Letter 87-09.

Reference (b) provided supplemental information in response to a request of the NRC Staff.

In accordance with the guidance of Generic Letter 87-09, changes were made to the

.. wording of the bases for Specification 4.0.2, and these are currently under NRR review.

N However, in accordance with the guidance given in Generic Letter 89-14, the changes, made in this amendment requeet, provide new changes to the wording of the bases of Specification 4.0.2.

These new changes supersede the changes requested in reference (a) and take precedence.

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k 9006200465 900604 PDR ADOCK 05000454 h

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June 4, 1990 Dr. T.E. Murley 2

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I Edison's procosed amendment request is subdivided as follows:

1.

Attachment A gives a sununary of the changes proposed in the amendment.

2.

Attachment B provides the Safety Evaluation and Environmental Assessment.

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Attachment C describes Edison's evaluation performed in accordance with 10 CFR 50.92(c), which has determined that no significant hazards considerations exist.

4.

Attachment D includes the marked-up Technical Specification pages with the requested changes indicated.

Edison is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.

1 Please direct any questions you may have concerning this submittal to this office.

Very truly yours,

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4 S.C. Hunsader Nuclear Licensing Administrator Att.'s: A) Summary of Proposed Changes L

B) Safety Evaluation and Environmental Assessment C) Evaluation of Significant Hazards Considerations D) Marked-up Technical Specification Pages Enclosureet GL 89-14 ces Resident Inspector-Byron l

Resident Inspector-Braidwood

't P. Shemanski-NRR S.P. Sands-NRR W. Shafer-RIII M.C. Parker-IDNS

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i AIIACEMENLA Sitt1ARLQE_ERDEQSIILCH6N. ES TO APPENDIX A C

HCHRICAL SE CIE1 CATIONS OE EACILITY OPERATING LICENSES _. NET..3L_ NET-6b_NPF-72 AND NPF-77 The proposed change is hased_on__the_guidanct_proYided_in_Geneticlat_ttr_B9.-L4, Line-Item Improvements in Technical Specifications - Removal of the 3.25 Limit on Extending Surveillance Intervals. The current Byron and Braidwood Technical Specification 4.0.2 allows a surveillance interval to be extended by up to 25 i

percent of the interval. Ilowever, the combined interval for any three consecutive j

surveillances cannot exceed 3.25 times the original surveillance interval. This Technical Specification change request seeks to remove the 3.25 limitation for consecutive surveillances.

The revised specification would allow a maximum of 25 percent extension for each surveillance period.

The intent of this change is to not increase the time between the performance of surveillances. Rather, the purpose of this change is to allow for more operational flexibility when scheduling surveillances. This flexibility will allow surveillances to be performed when plant conditions are appropria'te for the testing.

In particular, this flexibility will help accommodate survn111ances that must be done during refueling outages. The intent of this change is stated in the i

revised Bases section for Specification 4.0.2.

The proposed wording for both Specification 4.0.2 and its bases was taken directly from Generic Letter 89-14.

No exceptions to the guidance provided in the generic j

letter are being requested.

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ATTACHMENT B SAFETY EVALUAIl0N AND ENVIRONMENIAL_ASSESStiENT FOR PROEQSED CHANGES TO APPENDIX A. TECHNICAL SEECI UCA UDNS OF EACILITY_0EERAIlNG_.LICENSESJiff-32 _NPF-66._ NET-72 AND NPF-77 s

SAEEIY_EVALUAIl0N Commonwealth Edison (Edison) submitted a lead-plant proposal for the LaSalle Technical Specifications (TS) to remove the 3.25 limit for surveillances that are performed during a refueling outage and are specified with an 18-month surveillance in te rval. After discussions with the staff, Edison amended the proposal to remove the 3.25 limitation for all surveillances. The amended proposal was approved by the NRC staff on a lead-plant basis. Consistent with NRC policy, Generic Letter 89-14 provided guidance for license amendment requests to implement this line-item improvement in TS.

Experience has shown that the 18-month surveillance interval, with the provisions 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 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.

The use of the allowance to extend surveillance intervals by 25 percent can also result in a significant safety benefit for surveillances that are performed on a l

routine basis during plant operation.

This safety benefit is incurred when a I

surveillance interval is extended at a time that conditions are not suitable for l

performing the survelliance.

Examples of this include transient plant operating conditions or conditions in which safety systems are not out of service because of ongoing surveillance or maintenance activities.

In such cases, the safety benefit of allowing the use of the 25-percent allowance to to extend a surveillance interval would outweigh any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. Also, there is the administrative burden associated with tracking the use of the 25-percent allowance to ensure compliance with the 3.25 limit.

On the basis of these considerations, the staff concluded that removal of the 3.25 limit will have an overall positive impact on safety.

ENHRONMENIALASSESSMENI Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of Licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21.

It has been determined that the proposed change meets the criteria for a categorical exclusion as provided for under 10 CFR 51.21(c)(9). This determination is based on the fact that this enange is being proposed as an amendment to a license issued pursuant to 10 CFR 50, and the change affects a surveillance requirement which involves no significant hazards considerations.

There is no change in the amount or type of releases made off-site, and there is no significant increase in individual or cumulative occupetional radiation exposure.

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AIIACEMENT C EVALUA110N OF SIGNIElCANT_lLAZARDS CONSIDIRATIONS FOR PR010 SED CHANGES 10_AEEENDIK.A_IECHNLCAL_S.PECIFICAIl0NS DE l

FACILLIY OPERATING LICFESIS_NEEdL.JEF-66.. NPF-72 AND NPF-77 Commonwealth Edison has evaluated this proposed amendment and determins*

that it involves no sil;nificant hazards considerations. According to 10 (D7 50.92(c), a proposed anendment to an operating license involves no significant hazards consideratione if operation of the facility in accordance with the proposed amendment would not?

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2.

Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3.

Involve a significant reduction in a margin of safety.

A.

The_ propose Lchanae_ dona _no.t_ involve _a_significant_increage in the_prohnhility oE_ Consequences of an acnident_pleyiqugly evaluattd.

The accident analyses assume that required equipment will be operable in the event of an accident.

Surveillances are performed to verify the ability of the equipment to operate as designed. Deletion of the 3.25 criteria will allow additional flexibility in the scheduling of surveillances so that they may be conducted at times when plant conditions are conducive to their performance.

No change is being prc70 sed in the surveillance frequency, and therefore, this l

change will have no impact on the probability of an occurrence.

The B/B UFSAR Chapter 15 analyses asoume that equipment required by the proposed Specifications be capable of performing when required. The proposed change does not alter the operability requirements of any equipment. As_a.tated in NRC._ Generic _Letler_82-lb_1hnJonal_prohably result _of any parlicular s.urve111ance_la_the_reLif.ication of continued _ operability as opp _caed to the delection of inoperable equipment. Additionally, the 3.25 limitation being deleted was not considered in the evaluation of the probability of consequencet of accidents considered in the B/B UFSAR.

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There is a slight possibility of inoperable equipment remaining undetected for slightly longer period of time than currently allowed, but this possibility i

arises only if the current 1.25 allowable extension is routinely utilized. The base f requency of the surveillances remains unchanged, and every ef fort is made to perform these surveillances as close as possible to the due date.

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ATIACHMENT C (continued}

B. - Ihe_ proposed change _does_nol create _the_sossibility_nf a new or different Kind of accident f rom any ac.cident previnualv evalnated.

There is no new equipment being introduced, and installed equipment is not being operated in a new or different manner. No specific attributes verified during the conduct of the surveillances are being changed or deleted.

C.

The_propcand_ change _ dona _not involve a significant_ reduction in_RJDArgin_o1 mately.

The proposed change will allow the surveillances to be performed when plant conditions are conducive to their completion.

The current allowable extension of up to 25% per surveillance interval remains unchanged. The proposed changed will allow the scheduling ficxibility necessary to prevent a unit shutdown for the purpose of performing a surveillance.

This increased scheduling flexibility will result in a net safety benefit.

Based on the above, Commonwealth Edison concludes that this change will not increase the probability or consequences of a previously analyzed accident, Jntroduce the possibility of an accident not previously evaluated, or decrease the margin of safety. Therefore, this change does not involve a significant hazards consideration.

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