ML20206C559

Forwards Application for Amend to License NPF-3,deleting Tech Spec 4.0.2.b Re 18-month Surveillance Requirements.Fee Paid

ML20206C559
Person / Time
Site:	Davis Besse
Issue date:	10/31/1988
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206C561	List: ML20206C559 ML20206C565 ML20206C576
References
1588, NUDOCS 8811160322
Download: ML20206C559 (2)

Text

~_ --risgg TOLEDO

%mm EDISON a-,, - ,

DON 40 C. SHELTON

w. n om um Docket No. 50-346 License Nc. NPF-3 Serial No. 1588 October 31, 1988 United States Nuclcar Regulatory Commission Document Control Desk Vashington, D. C. 20555 Subj ec t : License Amendment Application to Delete Technical Specification 4.0.2.b Applicability to 18-Month Surveillance Requirements Gentlemen:

Enclosed is an application for an Amendment to the Davis-Besse Nuclear Po'rer Station, Unit No. 1, Operating License No. NPF-3, Appendix A, Technical Specifications.

Technical Specification 4.0.2.a provides for a maximum allovable extension of surveillance requirement intervals by 25 percent. Technical Specification 4.0.2.b requires that the total combined interval for any three consecutive tests not exceed 3.25 times that specified surveillance interval. This application requests that Technical Specification 4.0.2.b and Basis 4.0.2 be revised to reflect the change attached. The proposed changes involve deleting Technical Specification 4.0.2.b applicability to 18-month surveillance requirements. This vill better provide for the scheduling and performance of 18-month surveillance requirements during refueling outages. It vill eliminate the need for a mid-cycle shutdovn solely for the performance of an 18-month surveillance due as a result of Specification 4.0.2.b criterion.

Technical Specification 4.0.2.a vill continue to limit the allovable.

tolerances to 25 percent for performing surveillances to ensure adequate reliability of affected systems when deviations from nominal specified surveillances occur.

This "permanent" change is being requested rather than a one-time Technical Specification amendment relief request for a specific situation for the following reasons:

- Vith the uncertainties in the lengths of future fuel cycles and refueling outages, a "one-time" Technical Specification relief would not solve the problem, i.e., additional "one-time" Technical Specification relief requests may be necessary in the future.

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Page 2 The same quantity of resources (both Toledo Edison and NRC staff) are required for the preparation and approval of a one-time Technical Specificatlor, amendment request as for a "permanent" change. These resources weald likely need to be expended again if only one-time i extensions,are approved.

.; . Based on ther.e considerations, it is prudent to revise Technical Specificat bn 4.0 2.b to be not applicable to 18-month surveillance requirer"nts.

Tsedo Edison requests that these changes be issued by March 1, 1989 (for implementation within 45 days) in order to allow for planning and scheduling of surveillance tests with minimum impact on continued plant operation.

Enclosed is a check for $150.00 as required by 10CFR170.12(c) for a License Amendment Application.

Very truly yours, i'

f~

CAB /dle i

j Enclosure j cc DB-1 NRC Resident Inspector

A. V. DeAgazio, DB-1 NRC/NRR Senior Project Manager NRC Region III, Regional Administrator (2 copies)

State of Ohio i

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