ML20055G947

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Safety Evaluation Supporting Amends 90 & 80 to Licenses NPF-10 & NPF-15,respectively
ML20055G947
Person / Time
Site: San Onofre  
Issue date: 07/17/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20055G946 List:
References
GL-89-14, NUDOCS 9007240388
Download: ML20055G947 (3)


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NUCLEAR REGULATORY COMMISSION-UNITED STATES 8

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 90 TO FACILITY OPERATING LICENSE NO. NPF-10 AND AMENDMENT NO.'80 TO FAC,ILITY OPERATING LICENSE NO. NPF-15 SOUTHERN CALIFORNIA EDISON COMPANY.

SAN DIEGO GAS AND ELECTRIC COMPANY THF CITY OF RIVERSIDE. CALIFORNIA, THE CITY OF ANAHEIM CALIFORNIA SAN ONOFRE NUCLEAR GENERATING STATION. UNIT NOS. 2 AND 3 DOCKET HOS.-50-361'AND 50-362 l '. 0 INTRODUCTION et al. (SCE

-By letter dated May 14, 1990,. Southern California. Edison,ifications for or the licensee) requested a change to the Technical Spec Facility Operating License Nos. NPF-10 and NPF-15 that authorize operation of San =0nofre Nuclear-Generating Station, Unit Hos. 2 and 3 in San Diego County, California. The proposed change removes the-provision of-Technical Specification 4.0.2 that. limits the combined time interval for three consecutive-surveillances 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.

2.0 EVALUATION Technical Specification'4.0.2 includes the provision that allows a surveil-lance' interval:to be extended by 25 percent of the.s)ecified time interval.

This extension provides flexibility for scheduling tie 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.

Specification 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.

The provision to extend a surveillance interval by 25 percent is usually sufficient to acconinodate normal variations in the length of a fuel cycle.

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However, the NRC' staff has routinely granted requests for one-time excep-tions 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 pee.orm 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.

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. Furthermore, there is the administrative burden associated with tracking the use of the 25 percent allowance to ensure-compliance with the 3.25-limit.

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 lprovided 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 specifi'id surveillance interval with a maximum' allowable r

extension not to exceed 25 percent of the specified surveillance interval.",

In addition, the Bases of this specification were updated to reflect this changeland 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 con-sistent 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 San Onofre Unit Nos. 2 and 3 are acceptable.

3.0: CONTACT WITH STATE OFFICIAL The NRC staff has advised the State of California of the proposed deter-mination of no significant hazards consideration. No comments were received.

4.0 ENVIRONMENTAL CONSIDIRATION The amendments involve changes to requirements with res)ect to the installation or use of a facility component located wit 1in the restricted 4

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'l area'as defined in 10 CFR Part 20 or changes an inspection or surveillance requirement. The staff has; determined that the amendments involve no significant increase in the amounts, and no significant change in the types oT any effluents that may be released offsite and that there is no significantincreaseinindividualorcumulativeoccupationalradiation exposure. The Comission has previously issued a proposed finding that the amendments involve no significant hazards consideration'and-there has been no public coment on such finding. Accordingly, the amendments meet the elig(ibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)9).

Pursuant to 10 CFR 51.22(b) no environmental impact state-ment nr environmental assessment need be prepared in connection with the issuance of these amendments.

5.0 CONCLUSION

We have concluded, based on the considerations discussed above that: (1)

L there is reasonable assurance that the health and safety of the will not be endangered by operation in the pro)osed manner; (2) public t

I such activities will be conducted in compliance wit) the Comission's regula-tions; and (3) the issuance of the amendments will not be inimical to the comon-defense and' security or to the health and safety of the public.

Principal Contributors:

Thomas G. Dunning Lawrence E. Koka;ko Dated:- July 17, 1990

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