ML20059C149
| ML20059C149 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/22/1990 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20059C152 | List: |
| References | |
| B13578, GL-89-14, NUDOCS 9008310069 | |
| Download: ML20059C149 (5) | |
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NARTFOR cont ECTicVT 06141-02'O L
L Ta " O O 2 7.~.". C (2 m ses e August 22, 1990 Docket No. 50-245 B13578 Re:
10CFR50.90 Generic Letter 89-14 U.S. "qclear Regulatory Commission Attention:
Document Control Desk l
Washington, DC 20555 Gentlemen:
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Millstone Nuclear Power Station, Unit No. 1 Proposed Revision to Technical Specifications l
Removal of the 3.25 Limit on Extendina Surveillance Intervals f
Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby l
proposes to amend Operating License DPR-21 by incorporating the change identi-fied in Attachment 1 into the Technical Specifications of Millstone Unit No. 1.
T submittal is being made in response to Generic Letter (GL) 89-14 D_qtcription of the Proposed Chanae U
The proposed change revises the definition of SURVEILLANCE in Technical Specification 1.0.X by deleting the requirement that the combined 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 1.0.X requires that "each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the test interval." Also being added is the following guidance as recommended in GL 89-14.
The above surveillance limit for which the specified time interval for Surveillance Requirements may be extended permits an allowable extension of the normal surveillance interval to facilitate sur-veillance scheduling and consideration of plant operating condi-tions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or mainte-nance activitics.
It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each (1)
Letter to All Licenseet of Operating Plants, Applicants for Operating Licenses, and Holders of Construction Permits, "Line Item Imprevements in i
Technical Specifications--Removal of the 3.25 Limit on Extending l
Surveillance Intervals Generic Letter 89-14," dated August 21, 1989.
9008310069 900822 PDR ADCCV 05000245
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U.S. Nuclear Regulatory Commission B13578/Page 2 August 22, 1990 refueling outage and are decified' with an 18-month surveillance interval.
It is not intended tSt this provision be used repeat-edly as a convenience to extend suiveillance intervals beyond that specified for survefilance that are not performed during refueling outages. The above surveillance limitation is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of i
conformance with the Surveillance Requirements.
This provision is sufficient to ensure that the reliability ensured through surveil-lance activities is not significantly degraded beyond that obtained from the specified surveillance interval.
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._l It should be noted that this wording is being added to the Definitions portion 1
of the Technical Specifications since the Millstone Unit No. 1 Technical Specifications do not follow the Standard Technical Specification format.
Backaround The NRC issued GL 89-14 which provided guidance to licensees for the prepara-1 tion 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 Standard Techrical Specification 4.0.2 to remove an unnecessary restriction on extending surveillance requirements and a provide a benefit - to safety when plant conditions are not conducive to 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 Edison proposal, the NRC Staff concluded that the removal of the 3.25 limit from Specification 4.0.2 results in a greater benefit to safety than limiting the I
use of the 25 percent allowance to extend surveillance intervals.
The pro-posed change to the Millstone Unit No.1 Technical Specifications is consis-tent with the recommendations of Generic Letter 89-14.
Discussion on Surveillance Intervals For the purpose of clarification, NNECO hereby provides its interpretation as to what constitutes a surveillance interval for surveillances which are required to be done during plant shutdown.
It has been NNEC0's understanding that the interval begins upon initial criticality and ends upon shutdown for 1
refueling.
Therefore, surveillances can be performed at any time during shutdown.
However, when calculating the 3.25 criteria, outage. time is to be l
included. Based on recent calculations, NNECO would be required to shut down on or before November 5,1990 (prior to the next regularly scheduled refueling outage), in order to perform snubber inspections per Technical Specifica-tion 4.6.1 and to comply with the 3.25 surveillance interval.
Therefore,
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NNECO respectfully requests that this license amendment request be granted prior to November 4,1990, which would allow Millstone Unit No. I to continue to operate until March 30, 1991, as currently scheduled.
W U.S. Nuclear Regulatory Comnission B13578/Page 3 August 22, 1990 Sianificant Hazards Consideration I
NNEC0 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' i
10CFR50.92(c) are not compromised.
The proposed c_ange does not -involve a significant hazards consideration because the change would not:
I 1.
Involve a significant increase in.the probability or consequences of an accident previously analyzed.
The proposed change would remove n the 3'.25 limit on extending surveillance intervals in accordance with the i
guidance contained in Generic letter 89-14.
This change would not involve any change to the actual surveillance requirements, other than a j
small increase in the maximum _ allowable average surveillance interval.
l The increa:9 in the probability of failure of components and systems that would result from longer average surveillance intervals are within the range of expected variations in the-calculated failure probabilities associated with anticipatui changes in plant configuration during normal operation and would not cignificantly impact the probability of any a
accident.
The reliability ensured through surveillance activities following the proposed change would not be significantly _ degraded -beyond that obtained from surveillances performed within the 3.25' limit.
Therefore, this change would 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 would not alter the method of operating the plant or change the way the surveillance requirement is performed. The proposed change would allow a surveillance interval' to be-4 extended at a time that conditions are not. suitable for performing the surveillance.
No new failure modes are introduced.
Therefore, this 4
change would have no effect on the possibility of creating: a new or different kind of accident from any accident previously evaluated.
3.
Involve a significant reduction in the margin of safety.
This change would not involve any change to the actual surveillance requirements.
The reliability ensured through surveillance activities would not be significantly degraded beyond that obtained from the specified surveil-lance interval.
Therefore, it is concluded that operation of the facility in accordance with the proposed change would not involve a significant reduction in the margin of safety.
The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (March '
1986, 51FR7751) of amendments that are considered not likely to involu significant hazards consideration.
Although the proposed change is not enveloped by a specific example, the change would not involve a significant increase in the proba-bilit/ or consequences of an accident previously analyzed. The small increase in the probability of failure of components and systems that would result from
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U.S. Nuclehr Regulatory Commission B1357f/Page 4 August 22, 1990 longer average surveillance intervals are within the range of expected varia-1 tions in the calculated failure probabilities associated with anticipated changes in plant configurations during normal operation and would not signifi-1 cantly impact the probability of any accident.
The proposed change would provide an alternative to the requirements of Technical Specification 1.0.X by deleting the requirement that the combined time interval for any three consec-utive surveillance intervals is not to exceed 3.25 times the specific surveil-lance interval.
This would remove an unnecessary restriction on extending surveillance requirements and would result in a benefit to safety since surveillances would not be required' to be performed at times when~ plant conditions are not conducive to the safe conduct of that particular surveil-lance (e.g., transient plant operating conditions or other ongoing surveil-lance or maintenance activities).
Removal of the 3.25 limit would. also eliminate the necessity to shut down for the purpose of performing surveil-lances which cannot be performed on-line, which would reduce the potential for a condition that would challenge plant safety systems unnecessarily.
The removal of the 3.25 limit would provide greater flexibility in the use of the provision for extending surveillance intervals and reduce the administrative burden asrociated with its use.
The proposed change to the Millstone-Unit No.1 Technical Specifications is consistent with the. guidance provided via Generic Letter 89-14.
The Millstone Unit No.1 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.
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This change is being proposed to incorporate the provisions of Generic Let-ter 89-14 into the Millstone Unit No.1 Technical Specifications.
As stated above, approval is requested prior to November 4, 1990, in order to allow Millstone Unit No. I to operate to the end of its regularly scheduled cycle.
We request that this proposed change become effective immediately upon issu-I
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ance.
Should-you have any questions regarding this attached amendment request, please contact us.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY 4
E. C yioczka
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See next page
d U.S. Nuclear Regulatory Commission B13578/Page 5 August 22,'1990
'cc: Mr. Kevin McCarthy, Director Radiation Control Unit.
Department of Environmental Protection -
. Hartford, CT 06116 T..T. Martin, Region I Administrator M. l.. Boyle, NRC Project Manager, Millstone Unit No.1 W. J. Raymond, Senior Resident Inspector, Mf Istone Unit Nos. 1, 2, and 3 STATE OF CONNECTICUT)
) 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 Nuclear-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 and correct = to the best of his knowledge and belief.
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