ML20197B065

Proposed Tech Specs 3.3.2 & 3.3.4,removing Refs to Initial Base Line Inservice Insp & Specific Version of ASME Section XI Code

ML20197B065
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/17/1986
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20197B047	List: ML20197B042 ML20197B065
References
2265K, NUDOCS 8610270463
Download: ML20197B065 (10)

Text

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ATTACHMENT 1 PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIPICATION SECTIONS 3.3.2 AND 3.3.4 PRESSURIZATION AND SYSTEM INTEGRITY STRUCTURAL INTEGRITY Pages Modified: 80 99 100 101 102 103 2265K l

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LIMillNG CONDil10N FOR OPERA 110N SURVEllLANCE REQUIREMENT 3.3.2 (Continued) 4.3.2 B. lhe limit lines shown in Figures 3.3.2-1 and B. Not Applicable 3.3.2-2 shall be recalculated periodically as required, based on results from t'ne material surveillance program.

C. The secondary side of the steam generator must not be pressurized above 200 psig if C. Not Applicable the temperature of the primary and secondary coolant is below 70'F.

D. The pressurizer heatup rate shall not exceed D. Not Applicable 100*F/hr and the pressurizer cooldown rate not exceed 200*F/hr. The spray shall not be used if the temperature difference between the pressurizer and the spray fluid is greater than 320*F. -

E. Hydrostatic Testing E. Not Applicable

1. System inservice leak and hydrotests shall be performed in accordance with the requirements of ASME Boiler and Pressure Vessel Code;Section XI.

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.3 4.3

4. STRUCTURAL INTEGRITY 4. STRUCTURAL INTEGRITY The structural integrity of the primary system A. General boundary shall be naintained at a level comparable to the original acceptance standards The baseline inspection and all subsequent throughout the life of a unit. Weld repairs In-Service Inspections shall be done by shall be made to the original acceptance levels. -

individual contracts. As each contract period nears expiration, a review of the previous inspections shall be made in order to correlate past and future inspections. During this negotiation period, reviews vill be conducted to take advantage of improvements in technology and to utilize the latest developed equipment for the inspection procedures.

As always, decisions in regard to new inspection techniques shall be made to comply with Section XI of the A.S.M.E Code regarding In-Service Inspections.

a B. Not applicable.

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LIM 111NG CONDITION FOR OPERATION . SURVEILLANCE REQUIREMENT i

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IIMlllNG CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 4.3.4 C. In-Service Inspection and Testing

1. Inservice Inspection and Testing of the ASME Code Class 1, Class 2, and Class 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10CFR50, Section 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10CFR50, Section 50.55a(g)(6)(i).

Inservice Inspection and Testing activities should be incorporated into other specified surveillance requirements. The program shall be written in accordance with requirements of the A.5..M.E.Section XI Inservice Inspection Code and will include the utilization of the procedures developed for the 3-1/3, 6-2/3, and 10 year Inservice

Insepctions. These procedures shall be used to perform baseline examination of the planned Inservice Inspection areas and shall also be used as a basis for comparing the baseline examination of the welds in the system to future Inservice Inspectin Results, as required by the ASME Section XI Inservice Inspection Code.

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.3.4 4.3.4.C l

2. Inspection following a Refueling Af ter a Reactor Coolant System is i closed following opening for refueling all accessible pressure-retaining i

components, piping and/or valves of the reactor coolant pressure boundary f shall be visuall?/ examined in accordance with Examination Category

! B-P, Table IWB-2500-1 of the ASME Section XI for evidence of reactor coolant leakage while the system is under a test.  ;

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ATTACHIENT 2 EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION PROPOSED CHANGES TO ZION TECHNICAL SPECIFICATION APPENDIX A - SECTIONS 3.3.2 AND 3.3.4 PRESSURIZATION AND SYSTEM INTEGRITY STRUCTURAL INTEGRITY DESCRIPTION OF AMENDMENT REQUEST An amendment to the Zion Facility Operating License is proposed to delete references to the Inservice Inspection baseline inspection and specific versions of the ASME Section XI code.

BACKGROUND 10 CPR 50.92 states that a proposed amendment will involve a no significant hazards consideration if the proposed amendment does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

In addition, the Commission has provided guidance in the practical applica-tion of these criteria by publishing eight examples in 48 FR 14870.

The discussion below addresses each of these three criteria and demonstrates that the proposed amendment involves a no significant hazards consideration.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Does the proposed amendment:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety?

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l DISCUSSION - ITEM #1 The inservice inspection and testing program implemented at Zion Station provides additional assurance that Zion's structural integrity will not degrade with time from the high level of quality established during the l

. plant's construction. The structural integrity of the Zion Station systems helps to ensure that the probability or consequences of all accident previously evaluated remains well within the bounds of the analyses contained in the Zion FSAR.

This proposed amendment clarifies some of the adininistrative details surrounding the performance of the required inservice inspection program. The deletion of the reference to the baseline inspection is of no consequence since this was a one-time inspection that has been completed.

The references to the specific versions of the ASME Section XI code are currently outdated since the Zion units have entered into their second ten-year inspection interval. Thus, the deletion of a reference to a specific version is merely a reflection of Zion Station's ongoing compliance with 10 CPR 50.55a.

Therefore, this proposed amendment is a administrative clarification of the manner in which the inservice inspection and testing program is conducted at Zion Station. The actual conduct and effectiveness of this

inspection program will not be altered. The probability or consequences of any accident previously evaluated will not be changed.

DISCUSSION - ITEM #2 As discussed above, the clarification of administrative details and the deletion of outdated references has no effect on the actual conduct of the inservice inspection program at Zion Station. Thus, this proposed

amendment can have no effect on the actual operation or on the structural integrity of Zion Station.

Therefore, this change cannot create the possibility of a new or

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different kind of accident from any previously evaluated for Zion Station.

DISCUSSION - ITEM #3 The actual conduct and effectiveness of the inservice inspection program at Zion Station will not be altered. This proposed change involves the clarification of administrative details and the deletion of outdated references.

Thus, this proposed amendment does not affect the margin of safety ,

at Zion Station.

The minor changes contained in this proposed amendment are intended to delete outdated references and clarify the administration of the inservice inspection test program at Zion Station. Thus, example (i) is applicable in this instance. Example (1) states:

(1) A purely administrative change to Technical Specifications: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.

Therefore, since the application for amendment satisfies the criteria specified in 10 CFR 50.92 and is similar to examples for which no significant hazards consideration exists, Commonwealth Edison Company has made a determination that the application involves no significant hazards consideration.

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