ML20057F887
| ML20057F887 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/04/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20057F885 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 9310190300 | |
| Download: ML20057F887 (3) | |
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION
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l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 198 TO FACILITY OPERATING LICENSE NO. DPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK j
JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 l
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1.0 INTRODUCTION
By letter dated July 7,1993, the Power Authority of the State of New York (the licensee) submitted a request for changes to the James A. FitzPatrick-1 Nuclear Power Plant, Technical Specifications (TS). The requested changes would revise TS 4.0.C and 4.0.D and associated Bases to be consistent with the guidance provided in NRC Generic Letter (GL) 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting i
Conditions for Operation and Surveillance Requirements." The proposed changes to TS 4.0.C would incorporate a 24-hour delay in implementing the Action requirements due to a missed surveillance requirement when the Action requirements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed change to TS 4.0.0 would allow mode changes to be made as required to comply with Action requirements even if the surveillance requirements to enter a mode are not complete.
2.0 EVALUATION The changes proposed by the licensee have been reviewed considerir.g the limitations set forth in GL 87-09 for TS 4.0.C and 4.0.D as follows:
Specifications 4.0.C j
In GL 87-09, the NRC staff stated that it is overly conservative to assume
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that systems or components are inoperable when a surveillance requirement has not been performed, because the vast majority of surveillances demonstrate j
that systems or components in fact are operable.
Because the allowable outage time limits of some Action requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements apply, the TS should include a time limit that would allow a delay of the required
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actions to permit the performance of the missed surveillance.
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i This time limit should be based on considerations of plant conditions, j
adequate planning, availability of personnel, the time required to perform t.1e surveillance requirement, as well as the safety significance of the delay in i
i 9310190300 931004
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PDR ADOCK 05000333 i
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ccmpletion of the surveillance requirement. After reviewing possibis limits, the NRC staff concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time _ limit for completing a missed surveillance requirement when the allowable outage times of the Action requirements are less than this time limit or when shutdown Action requirements apply. The 24-hour time limit would balance the risks associated with an allowance of completing the surveillance requirement within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action requirements before the surveillance requirement can be completed.
This limit does not waive compliance with Specification 4.0.C.
Under Specification 4.0.C, the failure to perform a surveillance requirement will continue to constitute noncompliance with the operability requirements of a Limiting Condition for Operation and to bring into play the applicable Action requirements.
Based on the above, the following change to TS 4.0.C is acceptable:
"Faiiure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.8, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the Action requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The Action requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the Action requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Surveillance requirements do not have to be performed on inoperable equipment."
Specification 4.0.D TS 4.0.D prohibits entry into an OPERATIONAL CONDITION or other specified condition until all required surveillance requirements have been performed.
This could cause an interpretation problem when OPERATIONAL CONDITION changes are required in order to comply with Action statements.
Specifically, two possible conflicts between TSs 4.0.C and 4.0.D could exist.
The first conflict arises because TS 4.0.0 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance interval.
The proposed modification to resolve this conflict involves the revision to TS 4.0.C to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the Action requirements, as explained above, and a clarification of TS 4.0.0 to allow passage through or to operational modes as required to comply with Action requirements. The second potential conflict between TSs 4.0.C and 4.0.D arises because an exception to the requirements of TS 4.0.D is allowed when surveillance requirements can only be completed after entry into a mode or condition.
However, after entry into this mode or condition, the requirements of TS 4.0.C may not be met because the surveillance requirements may not have been performed within the allowable surveillance interval.
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i The licensee proposes to resolve these conflicts by providing the following clarifying statement to TS 4.0.D:
"This provision shall not prevent passage through or to Operational Modes as required to comply with ACTION Requirements."
i The NRC staff has provided in GL 87-09 a clarification that:
(a) it is not the intent of 4.0.C that the Action requirements preclude the performance of surveillances allowed under any exception to TS 4.0.D; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in TS 4.0.C for the applicability of Action requirements
.j provides an appropriate time limit for the completion of surveillance j
requirements that become applicable as a consequence of any exception to TS 4.0.D.
Consequently, the NRC staff finds the proposed changes to TS 4.0.0 acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a j
facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves 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 significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding l
(58 FR 46239). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
1 The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
T. Dunning j
Date:
October 4, 1993 l