ML20195J340
| ML20195J340 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/18/1988 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 1466, NUDOCS 8801270271 | |
| Download: ML20195J340 (3) | |
Text
't KREDO EDISON DONAU) C. GHELTON We Prewoes 4 -k1 ear (4'9)249 2399 Docket No. 50-346 License No. NPF-3 Serial No. 1466 January 18, 1988 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555
Subject:
Application of Surveillance Requirement 4.0.2 Centlemen:
The following delineates Toledo Edison's present plans for handling certain Surveillance Requirement time intervals as recently discussed with Mr. A. W. DeAgazio of your staff. Surveillance Requirement 4.0.2 of the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications states:
Each Surveillance Requirement shall be performed within the specified time interval with:
a.
A maximum allowable extension not to exceed 25% of the surveillance interval, and b.
A total maximum combined interval time for any 3 consecutive tests not to exceed 3.25 tines the specified surveillance interval.
License Amendment No. 105 extended the surveillance time intervals for certain portions of Surveillance Requirements 4.8.1.1.2d and 4.8.1.2 for the Emergency Diesel Generators (EDGs) from 18-month intervals to 26-month intervals on a one-thae basis. License Amendment No. 95 extended the surveillance time interval of Surveillance Requirement 4.4.10.lb for the Reactor Vessel Internal Vent Valves (RVVV3) from an 18-month interval to the next refueling outage (presently scheduled to commence March 11, 1988) resulting in a one-time interval of approximately 42 nonths.
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Docket No. 50-346 License No. NPF-3 Serial No. 1466 Page.2 The maximum total time interval for 3 consecutive 18-month surveillance time intervals using the criterion of Surveillance Requirement 4.0.2b is 58.5 months.
The one-time interval extension to the EDGs and RVVVs Surveillance Requirements would have already utilized 26 and 42 months, respectively, of this time-interval.- Therefore, even with the NRC Staff's previous review and approval of these surveillance testing interval extensions, Toledo Edison would be unduly impacted by the extensions when applying Surveillance Requirement 4.0.2b using an 18-month intarval.
Theretire, Toledo Edison plans to use 26-months for one interval of the next 3 consecutive intervals (including the current interval) for EDG Surveillance Requirements 4.8.1.1.2d and 4.8.1.2 (applicable portions) when calculating the total maximum interval under Surveillance Requirement 4.0.2b.
For the 25% portion of Surveillance Requirement 4.0.2b, Toledo Edison plans to use 4.5 months which is 25% cf 18-months. This would result in a total maximum interval of 66.5 months for the next 3 consecu-tive tests.
Similarly, Toledo Edison plans to use 42 months (tentatively) as one of the next 3 consecutive intervals (including the current interval) when calculating the total maximum interval for RVVVs Surveillance Requirement 4.4.10.lb.
This would result in a total maximum interval for these 3 consecutive intervals of 82.5 months (again using 4.5 months as the 25%
portion of Surveillance Requirement 4.0.2b).
Technical Specification 4.0.2a would limit the next test interval to 22.5 months (18 months plus 25%). The use of 26 months and 42 months would apply only as long as these extended intervals are within three consecutive time intervals as addressed in Surveillance Requirement 4.0.2b.
Toledo Edicon believes this calculational method is consistent with the information previously provided to the NRC (Serial Nos. 1278, 1292 and 1430) for approval ind issuance of License amendment Nos. 95 and 105.
Regarding the performance of Surveillance Requirement testing when in Modes 5 and 6 on equipment not required to be operable in these modes, Toledo Edison plans to apply the following:
For these types of Surveillance Requirement tests which are due after the beginning of an outage, but are deferred until later in the outage (for example, prior to startup), the time period between the calculated due date and the actual test performance date need not be counted as part of the surveillance time interval under Surveillance Requirement 4.0.2.
This method is justified based on the fact that the system, structure or component is not required to be operable in Modes 5 or 6, and any deferment of the test during these modes should not unduly impact the plant's future planned shutdowns. Elimination of the inclusion of this deferment period will assist in avoiding unnecessarily having to shutdown the plant to perform an 18-month (refueling) Surveillance Requirement coming due prior to the next actual refueling outage.
Dockst No. 50-346 License No. NPF-3 Serial No. 1466 Page 3 Unless comment or notification of non-concurrence is received from the NRC Staff by February 12, 1988 regarding these calculational methods, Toledo Edison plans to use these methods, at its option, during the upcoming refueling outage.
Very tru
- yours, QL/
DRWibam cc:
A. B. Davis, Regional Administrator DB-1 Resident Inspector A. W. DeAgazio, NRC/NRR Proj ect Manager