ML20127A603
| ML20127A603 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Farley |
| Issue date: | 05/19/1983 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Lainas G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082410334 | List: |
| References | |
| FOIA-85-243 TAC-51408, NUDOCS 8306010090 | |
| Download: ML20127A603 (2) | |
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UNITED STATES i
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yay 191953 MEMORA!;DUM FOR:
Gus C. Lainas, Assistant Director for Operating Reactors, DL FROM:
Frank J. Miraglia, Assistant Director for Safety Assessment, DL
SUBJECT:
REQUEST TO INCREASE. SURVEILLANCE INTERVALS FOR FARLEY - UNITS 1 AND 2 (DOCKET NOS. 50-348/364)
As recuested by E. A. Reeves (ORPM for Farley), the Standard Technical See:ifications Section staff has reviewed the request by Alabama Power. -
Comoany to increase 'the surveillance intervals in the Farley-Units 1 and 2 Tecnnical Specifications from 18 months to 24 months and from 12 months t: 15 msnths. -The licensee's basis for the request is that it plans to implement 18-montn fuel cycles rather tnan :ne current 12-month fuel cycles for the Farley Plant.
The licensee's intent of the proposed change is to maintain the same 6-month contingency period for surveillance intervals as currently exists for a 12-month fuel cycle. A similar proposal was recently received from the Crystal River-Unit 3 licensee and although a TAC has not teen assigned, the following discussions are also applicable to that proposal.
It a: pears tha :nere is a misunderstanding by Alabama Power Company as to ne casis for tne surveillance intervals given in the technical specifications fc ne Farley Plant, specifically, and for any power plant, generally.
The 15-mon n surveillance intervals contained in the Farley Technical Specifications anc in the Standarc Technical Specifications (STS) were established curing ne criginal deveicoment of STS af ter consultations witn various senior staff tr:c s :.
.:1-. tre rea: tor anc fuel venc:rs.
This 15-mor.th surveillance
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- . es.a:iisned to provice a 6-montr. cen ingency seri:0 as sug-geste sy the Farley licensee, but was estaclished based upon knowledge that s:me rea:ters woulc ce utilizing 18-month fuel cycles.
The 18-month surveil-iance interval was established to accomodate the planned 18-month fuel cycles.
Coerating experience was also considered in establisning the 18-month surveil-lance interval.
- should be noted that the Farley Technical Specifications, the STS, and most custom technical specifications include a provision which permits any surveillance interval to be extended by 25% of the nominal interval proviced that over any three consecutive surveillance intervals, the total time interval
- es n:: exceec 3.25 times the specified surveillance interval.
This provision
- r: vices necessary Operational flexibility which may be requireo cue to scheculing 39: ce-fermance consicerations.
If the Farley proposal to change all of tne
'.i-r:-.n surveillance intervals to 24-months was aoproved, the maximum interval w:i.c nen be 30 months as opposed to the present maximum allowable interval
- f 21.5 months.
We believe tna; the 30-month interval is unacceptacly long.
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ainas lSY 1 : 1E3 Tne effect of extenced outages was also considered curing the oevelopment a.c estsolisnment of the 18-month surveillance interval.
It was concluged tnn if a ciant incurs an extended outage curing a fuel cycle,.ne licensee sr.oulc cerform the appropriate surveillances curing tne extencec outage so tna re:uired surveillances will not become cue oefore completion of the fuel cycle.
Tne Farley licensee has also proposed to increase the 12-month surveillance intervals applicable to certain portions of the fire protection (fire water systems) technical specifications to 18-month intervals and to increase the surveillance intervals applicable when specified numbers of snubDers are found inoperable. The establishment of the 12-month intervals for the fire water systems in the Farley Technical Specifications and the STS was based upon annual climatic conditions rather than on the length of a fuel cycle; tnerefore, we celieve these intervals should not be changed.
' As statec ir, tne Farley Technical Specifications and the STS Bases for the snuo;ers, estaolishment of the 'snubbe'r surveillance intervals. was basec upon maintaining a constant level of~ protection. The assumptions useo for main-taining One constant level of protection would be invalidated if the surveil-iance intervals are changed; therefore, we believe this proposal shoulc be cenied too.
Based upon the foregoing ciscussions, we recomend the subject proposals from the Farley and Crystal River licensees and any similar proposals from cther licensees be denied.
In an attempt to eliminate similar proposals, we are creparing a generic letter on this issue to be sent to all pcwer reactor applicants and licensees.
Tais cc: pietes our action on TACs 51t.03 and 51409.
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Orank J. M,itag.,;.-dsinant Direct:r for Safety Arse.ssinent Division of Licensing cc:
F. Anderson
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D. Hoffman E. A. Reeves M. Fairtile D. Brinkman C. Thcmas
- 5. Varga D. Vassallo E.. Clark J. Stolz T. Novak E. J. Youngolood A. 5:nwencer G. Knignton E. ACersam
- . Crut:nfield W. Russell I. '.0001ito R. kess~,an
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MEMORANDUM FOR: Roger J. Mattson, Director Division of Systems Integration FRDM:
Darrell G. Eisenhut Director Division of Licensing l
58SJECT:
REVISION TD STANDARD TECHNICAL SPECIFICATION, SECTION 3/4.8.1 In your manorandum dated May 5,1983, on the above subject, you recomended certain changes to Standard Technical Specification (STS) Surveillance Requirement 4.8.1.1.2 regarding diesel fuel impurity level tests. These changes have been made to the STS in accordance with NRR Office Letter No. 38 and a generic letter to all applicants for operating licenses and holders of construction pemits for power reactors has beer issued to notify them of these changes.
You also recommended that all operating plants be audited by the Regional staff to detemine their degree of compliance with the above changes to the STS. We have reviewed the requirements in plant-specific technical specifi-cations for diesel fuel impurity level tests and find that they do not contain all of the above requirements. Therefore, the above changes to the STS would not be a clarification for operating plants but would be an imposition of adit tional requirments.
Therefore, we believe that your request in regard to operating plants should be pursued in accordance with NRR Office Letter No. 40 rather than NRR Office Letter No. 38 In view of the above, we have completed our actions requested in your memorandum of May 5,1983.
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l Darrell G. Eisenhut, Director Division of Licensing DISTRIBUTION:
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