ML20154R922

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Application for Proposed Amend 136 to License DPR-54, Correcting Tech Spec Section 1.9 Re Time Interval for Surveillance Tests Due to Editorial Errors.Fee Paid
ML20154R922
Person / Time
Site: Rancho Seco
Issue date: 03/20/1986
From: Reinaldo Rodriguez
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Miraglia F
Office of Nuclear Reactor Regulation
Shared Package
ML20154R928 List:
References
RJR-86-101, TAC-61472, NUDOCS 8603310247
Download: ML20154R922 (6)


Text

SACRAMENTO MUNICIPAL UTILITY DISTRICT E 6201 S Street, P.O. Box 15830. Sacramento CA 95852 1830 (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA RJR 86-101 March 20,1986 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTENTION FRANK J MIRAGLIA DIRECTOR PWR-B DIVISION U S NUCLEAR REGULATORY COMMISSION WASHINGTON DC 20555 DOCKET N0. 50-312 LICENSE NO. DPR-54 PROPOSED AMENDMENT NO. 136 In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District proposes to amend its Operating License DPR-54 for Rancho Seco Nuclear Generating Station Unit No. 1.

Proposed Amendment No. 136 consists of two editorial changes to Section 1.9 of the Rancho Seco Technical Specifications.

These changes are discussed in detail in Attachments I, II and III, which are the Safety Analysis, "No Significant Hazards" Evaluation and Description of Prcposed Changes, respec-tively.

Pursuant to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health Services has been informed of this proposed amendment by mailed copy of this submittal.

Enclosed is a check in the amount of $150.00 as required by 10 CFR 170.21,

" Schedule of Fees."

Should you require any further information with respect to this Proposed Amendment, please contact Mr. Ron W. Colombo at Rancho Seco Nuclear Generating ti n Unit No. 1.

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t, ATTACIMENT I SAFETY ANALYSIS Proposed Amendment No. 136 consists of two editorial changes being made to Section 1.9 (Time Periods) of the Rancho Seco Technical Specifications. The details of these changes and their effect on plant safety are discussed be-low:

1.

The second sentence of the introductory paragraph of Section 1.9 states:

"The total maximum combined interval time for any three consecutive tests shall not exceed 3.25 times a single specified surveillance interval."

l The word " tests" is considered misleadingly ambiguous, and is being changed to " intervals" to more appropriately denote a time period.

2.

The time period " Fortnightly" is used twice in Table 3.22-1 (Items 3.b.

and 4.a) to specify radiological environmental sampling and collection frequencies, but heretofore has not been defined in Section 1.9.

The word

" Fortnightly," with definition, is being added as Section 1.9.4 to correct this omission.

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Both of the above changes are considered improvement in quality to the techni-cal specifications and are judged as having no involvement with plant safety.

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ATTACMENT II l

"N0 SIGNIFICANT HAZARDS" EVALUATION Proposed Amendment No. 136 consists of two editorial changes being made to Section 1.9 of the Rancho Technical Specifications.

The first change replaces the word " tests" with " intervals" in the second sentence of the introductory paragraph of Section 1.9, TIME PERIODS. The existing sentence states: "The total maximum combined interval time for any three consecutive tests shall rot exceed 3.25 times a single specified sur-veillance interval." The word " tests" is considered misleadingly ambiguous and is being changed to " intervals" which more appropriately denotes a time period.

The second change involves the addition of a previously undefined time period as Section 1.9.4 and the corresponding renumbering of existing Sections 1.9.4 through 1.9.9 as Sections 1.9.5 through 1.9.10.

The terms " fortnightly" and

" fortnight" are used in Table 3.22-1 (Items 3.b. and 4.a., respectively) to specify radiological environmental sampling and collection frequencies, but heretofore was undefined in Section 1.9.

The proposed changes do not involve a significant hazards consideration be-cause operation of Rancho Seco Unit 1 in accordance with the changes would not:

1.

involve a significant increase in the probability or consequences of an accident previously evaluated. The substitution of the word " tests" with

" intervals" is an editorial change which brings the wording into agreement with that used in NUREG-0103, Rev. 4, Technical Specifications for B&W Pressurized Water Reactors, Specification 4.0.2b (Surveillance Requirements).

This change clarifies the limitations in applying the allowed +25% sur-veillance interval time extensions.

Since this change has no direct effect on plant design or operation, it cannot be seen that the probabi-lity or consequences of a previously evaluated accident would be increased.

Adding the definition " FORTNIGHTLY," a frequency term used twice in Table 3.22-1 resolves its present omission from Section 1.9.

This change too is one of improvement to the technical specifications, having no direct involvement with plant design or operation.

Thus, this change also can-not be seen as increasing the probability or consequences of a previously evaluated accident.

2.

create the possibility of a new or different kind of accident from any previously analyzed. As discussed above, both the substitution of the word " tests" with " intervals," and the addition of the time period

" FORTNIGHTLY"are editorial changes which will result in improvements to the technical specifications.

Neither of these changes involve operational matters or plant designs.

Consequently, it is considered very improbable that the changes would create the possibility of a different kind of acci-4 dent from any previously analyzed.

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involve a significant reduction in a margin of safety. The two proposed changes are improvements to Section 1.9 of the technical specifications which cannot be seen to have any direct effect on safety margins.

If anything, the changes will prevent any misinterpretations of the allowed application of the +25% time extension to consecutive intervals, and of 3

i the time duration meant by " fortnightly" thereby preserving the established

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safety margins.

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The Commission has provided guidance concerning the application of the j

standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration. Example (i) relates j

to a purely administrative change to technical specifications: for example, a change to achieve consistency throughout the technical specifications, correc-tion of an error, or a change in nomenclature.

In both cases, the proposed changes to Section 1.9 of the technical specifications are purely administra-tive changes that the Sacramento Municipal Utility District judges do not involve significant hazards considerations.

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ATTACIM NT III DESCRIPTION OF PROPOSED CHANGES 1.

Table of Contents, page ii; Renumbered Sections 1.9.4 through 1.9.9 as I

Sections 1.9.5 through 1.9.10, and added new Section 1.9.4.

2.

Section 1.9, page 1-5; Replaced the word " tests" with " intervals" in 4

the second sentence of the introductory paragraph.

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Section 1.9.4, page 1-5; The time period, " Fortnightly" cnd its defini-tion were added, and previous Sections 1.9.4 through 1.9.9 were renumbered 4

as Sections 1.9.5 through 1.9.10.

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