ML20055C832

Application for Amend to License NPF-49,revising Tech Spec 4.0.2 by Deleting Requirement That Combined Time Interval for Any Three Consecutive Surveillance Intervals Not to Exceed 3.25 Times Specific Surveillance Interval

ML20055C832
Person / Time
Site:	Millstone
Issue date:	06/13/1990
From:	Mrozcka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20055C833	List: B13528, Proposed Tech Spec 4.0.2,deleting Requirement That Combined Time Interval for Any Three Consecutive Surveillance Intervals Not to Exceed 3.25 Times Specific Surveillance Interval ML20055C832
References
B13528, GL-89-14, NUDOCS 9006250216
Download: ML20055C832 (4)

Text

4 General Offices e seiden Street, Berlin. Connecticut

.mim..aw.vum nin.a c=~a P.O. BOX 270

.*no*'******"

HAPTFORD, CONNECT! CUT 061410270 J Ul$lC[iU

,'O",','

(203) 665 5000 7

_A June 13, 1990 l

Docket No. 50 423 I

B13528 Re:

10CFR50.90 1

U.S. Nuclear Regulatory Commission 1

Attention:

Document Control Desk Washington, DC 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Removal of the 3.25 Limit on Extendina Surveillance Intervals Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License NPF-49 by incorporating the change identi-fied in Attachment 1 into the Technical Specifications of Millstone Unit No. 3.

j Descriotion of the ProDosed Chanae

{

The proposed change would revise a surveillance requirement in Technical Specification 4.0.2 by deleting the requirement that the combiiied time inter-val for any three consecutive surveillance intervals is not to exceed 3.25 times the specific surveillance interval.

The revised Technical Specifi-cation 4.0.2 would : require that "each ' surveillance requirement shall be performed within the specified time interval with a maximum allowable exten-sion-not-to exceed 25 percent of the specified surveillance interval."

The associated bases section is being revised to reflect the proposed change.

Backaround On August 21, 1989,U) the NRC issued Generic Letter 8914 which provided guidance to licensees for the preparation of license amendment requests to

-implement.a.line item improvement in the Technical Specifications to remove the-3.25 limit on extending surveillance intervals.

The generic letter provided an alternative to the requirements of Technical Specification 4.0.2 to remove' an unnecessary restriction on extending surveillance requirements and to provide a benefit to safety when plant conditions are not conducive to

'(1) Generic Letter 89-14:

Line Item improvements In Technical Specifications-Removal of the 3.25 Limit on Extending Surveillance Intervals, dated August 21, 1989.

/g 9006250216 900613 F

1 PDR ADOCK 05000423

'(

l g

P PDC a

'O e

U.S. Nuclear Regulatory Commission i

B13528/Page 2 June 13, 1990 the safe conduct of surveillance requirements.

A lead plant proposal was submitted by Commonwealth Edison for the LaSalle Nuclear Power Station to modify the 3.25 limitation on extending surveillance intervals.

Based upon the review of the Commonwealth U,ison proposal, the NRC Staff concluded that the. ;moval of the 3.25 limit from Specification 4.0.2 results in a greater benefit to safety than limitirr., the use of the 25 percent allowance to extend '

e surveillance intervals.

TN proposed change to the Millstone Unit No. 3 Technical Specifications is consistent with the recommendations of Generic Letter 89-14.

Sionificant Hazards Consideration

)

NNECO has reviewed the proposed change in accordance with 10CFR50.92 and has concluded that the change does not involve a significant hazards considera-tion.

The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised.

The proposed change does not involve a significant hazards consideration because the change would not:

1.

Involve a significant increase in the probability or consequences of an accident previously analyzed. The proposed change removes the 3.25 limit on extending surveillance intervals and adds the bases statements for the existing 25 percent allowance, in accordance with the guidance contained in Generic Letter 89-14. Removal of the 3.25 limit on extending surveil-lance intervals provides a safety benefit by allowing a surveillance interval to be extended at a time that conditions are not suitable for performing the surveillance (i.e., transient plant operating conditions or other ongoing surveillance or maintenance activities.)

The safety benefit of allowing unrestricted use of the 25 percent allowance to extend a surveillance interval in such cases offsets any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit.

This change does not involve any change to the actual surveillance requirements, other than a small increase in the maximum allowable surveillance interval.

The increase in the probability of failure of components and systems that would result from longer average surveillance intervals would not significantly impact the probability of any accident.

The reliability ensured through surveillance activities following the proposed change would not be significantly degraded beyond that obtained from surveillances performed subject to the 3.25 limit.

Therefore, this change does not significantly increase the probability of occurrence or the consequences of an accident previously evaluated.

2.

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

The proposed change does not a'ter the method of operating the plant or change the way the surveillar ce requirement is performed.

The proposed change allows a surveillani.e interval to be extended at a time that conditions are not suitable 'or performing the surveillance.

No new failure modes are introduced.

Therefore, this change has no effect on the possibility of creating a new or different kind of accident from any accident previously evaluated.

0 U.S. Nuclear Regulatory Commission B13528/Page 3 June 13, 1990 3.

Involve a significant reduction in the margin of safety.

Removal of the 3.25 limit on extending surveillance intervals provides a positive effect on safety by allowing a surveillance interval to be extended at a time that conditions are not suitable for performing the surveillance.

The safety benefit of allowing the use of the 25 percent allowance to extend a surveillance interval in such cases outweighs any benefit derived from limiting three consecutive surveillance intervals to the 3.25 limit.

This change does not involve any change to the actual surveillance requirements.

The reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

Therefore, it is concluded that operation of the facility in accordance with the proposed change does not involve a significant reduction in the margin of safety.

Moreover, the Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (March 6,

1986, SlFR7751) of amendments that are considered not likely to involve a signifi-cant hazards consideration. Although the proposed change is not enveloped by a specific example, the change would not involve a significant increase in the probability or consequences of an accident previously analyzed.

The proposed change provides an alternative to the requirements of Specification 4.0.2 and will remove an unnecessary restriction on extending surveillance requirements and will result in a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements.

The removal of the 3.25 limit will provide greater flexibility in the use of the provision for extending surveillance intervals, and reduce the administrative burden associ-ated with its use.

Based upon the information contained 10 this submittal, there are no signifi-cant radiological or nonradiological

'mpacts associated with the proposed change, and the proposed license amendmeat will not have a significant effect on the quality of the human environment.

The Millstone Unit No. 3 Nuclear Review Board has reviewed and approved the proposed change and has concurred with the above determinations.

In accordance with 10CFR50,91(b), NNECO is providing the State of Connecticut with a copy of this proposed amendment.

This change is being proposed to incorporate the provisions of Generic l.et-ter 89-14 into the Hillstone Unit No. 3 Technical Specifications. As such, no specific schedule for approval and issuance is requested.

However, we do request that this proposed change become effective 45 days after issuance.

i U.S. Nuclear Regulatory Commission B13528/Page 4 June 13, 1990 Should you have any questions regarding the attached amendment request, please contact our licensing representative directly.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Y

Y24/

E. J. fr6(zRa Seniof Vice Pre //

sident cc: Mr. Kevin McCarthy, Director Radiation Control Unit Department of Environmental Protection Hartford, CT 06116 T. T. Martin, Region 1 Administrator D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 W. J. Raymond, Senior Resident inspector, Millstone Unit Nos.1, 2, and 3 -

STATE OF CONNECT! CUT' ss. Berlin COUNTY OF HARTFORD Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Northeast Naclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing

-information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true ano correct to the best of his knowledge and belief.

u>d

• <IME hotaryPfic~

MyComm!!sbn Exp!reslurch31,1903

---