ML20235U472
| ML20235U472 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/07/1987 |
| From: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| Shared Package | |
| ML20235U462 | List: |
| References | |
| TAC-66359, TAC-66360, NUDOCS 8710140104 | |
| Download: ML20235U472 (26) | |
Text
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I ATDOBENP 1 Prtposed Technical Specification Change i
Surry Power Station l
Units 1 and 2 l
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TS 4.7-1 l
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4.7 NAIN STEAM LINE TRIP VALVES 1
Applicability Applies to periodic testing of the main steam line trip valves.
1 Objective To verify the ability of the main steam line trip valves to close upon signal.
1 Specification A.
Tests and Frequencies 1.
Each main steam line trip valve shall be tested for full closure before each startup, unless a satisfactory test has been conducted within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
B.
Acceptance Criteria 1.
A full closure test of a main steam line trip valve shall be considered satisfactory if the following criteria are met:
a.
T1 less than or equal to 4.0 secords and b.
T2 less than or equal to 5.0 seconds j
where i
o_______________________._.__.________________________._
TS 4.7-2 T1 = measured elapsed time frm manual initiation of steam line isolation to initiation of main steam trip valve mtion, se.uals T2 = measured elapsed main steam trip
. valve stroke time (full open to full closed), mais Basis The main steam trip valves serve to limit an excessive Reactor Coolant System cooldown rate and resultant reactivity insertion following a main steam line break accident.
Their ability to close fully within the maxinum allowable time specified shall be verified prior to reactor startup.
The acceptance criteria reflect the ammtmtions made in the safety analysis of a main steam line break accident. The analysis arsumes a 5 second delay frun the time the system process variables readt the desicpa setpoints to initiation of valve motion, followed by a 5 second linear ramp closure of the valve.
I The acceptance criteria are established to ensure this safety analysis l
assurption is maintained. Ttius the criteria may be written as follows:
a.
I + B less than or equal to 5 seconds and b.
S less than or equal to 5 seconds
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TS 4.7-3' I
where
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I = Instrument response. tim (delay from the time' the j
rveces variable reaches the setpoint to initiation of bleedoff of instrument air fra the main steam trip valve air cylinders), seconds.
L B = Time delay fra initiation.of bleedoff of instrument air from the main steam trip valve' air cylinders to initiation of valve motion, secords.
S = Valve stroke time (full open to full closed), aamnds.
'Ibe instrument response time I is represented by a value of 1.0 seconds W on a conservative evaluation of the actual response time. 'Ihe bleedoff time B 1
l is equivalent to the measured interval T1 as defined :in the. Acceptance criteria section of the Specification.
'1he stroke ' time' S ' is conservatively approximated by the measured interval T2 as defined in'. the Specification..
Under actual steam line break conditions it is expected that S will be nucts less than T2, since valve closure is flow assisted.. '1hus the ' acceptance criterion may be rewritten as shown in Section 4.7.B.1.
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l ATDOMENE 2 i
Discussion of Proposed Chmge l
Surry Power Station l
Units 1 ard 2 l
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BPOGROUND Surry TS 4.7.A specifies the tests and frequencies, my to verify the ability of the Main Steam Trip Valves (MSTVs) to close upon signal. TS 4.7.B specifies the acceptance criteria.
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'Ihis pwe eied dange renoves the partial closure test requirunent in TS 4.7.A c
and the partial closure test acceptance criteria in TS 4.7.B.
'Ibe diamacion of the partial closure test is removed frun the Basis.
'Ihe pwycsed change also revises the full closure test frequency and test condit. ions, and revises the acceptance criteria for consistency with the accident analysis assumptions.
'Ihe Basis section is expanded to' include a die >=aion of the accident analysis aa==ntions and derivation of the acceptance criteria for valve closure time.
A parallel specification appears on Table 4.1-2A and is revised to be i
consistent with the proposed revision to TS 4.7.
l SAFEIY EVAHIATION Partial Closure Test l
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'Ihe purpose of the partial closure test is to verify the frmhn of the valve disk to function as required. 'Ibe partial closure test rotates the valve disk three (==gaes to de=Imr=Lrate valve disk freedan.
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'Ihe surveillance frequency for the partial closure test has varied since the specifications were originally issued.
'Ibe original partial closure test frequency was nonthly, later quarterly, and nost recently, before each startup.
Similarly, the surveillance frequency for the full closure test has varied.
'Ibe original frequency was every 12 nonths, then every refueling outage, and most recently, every cold shutdown.
Like the partial closure test, the full closure test verifies the freedam of the valve disk to function as required.
However, it verifies it over the entire rarge of valve notion.
In practice, Virginia Electric and Power Ocupany treats the two surveillance requirements as one.
'Ihat is, a full closure test is performed before each startup (regardless of whether the unit is starting up frtxn cold or hot l
shutdown) thus satisfying the intent and frequency requirements of both 1
i specifications. Repetitive testiry is not required if a satisfactory test has been corducted within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Conducting the test at hot 1
shutdown is preferred because test conditions are more representative of plant conditions the valve would experience if called upon to perfonn its safety function.
Because the intent of the partial closure test is achieved by means of the i
full closure test and the two test frequencies are treated identically, we propose to eliminate the requirement for a partial closure test before each startup and crniuct the full closure test instead.
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'Ihus, TS 4.7.'A.1 is pu s M to read:'
I "Each main steam line trip valve shall be tested for full closure before each startup, unless a satisfactory test has been conducted within the -
previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
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-l TS - 4.7.A.2 and 4.7.B.2 regarding partial closure testing.are deleted.
'Ihe i
discussion of partial closure testing in the Basis is likewise deleted.
'Ibe' l
couasipchling requirement in Table 4.1-2A is revised accordingly.
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Revised Closure Time Acceptance Criteria l
Response time 'esting of the Unit 1 arx12 EIV's is performed in accordance with Section 4.7.B.1 of the 'Ibchnical Specifications, which requires a Elv closure time of 5 seconds or less. 'Ibe currunt test procedure requires that the closure time be measured by manually initiating MSTV closure by turning a remote switch on the MCR benchboard and measuring the ' time interval between initiation of the closure signal and the extinguishing of the red "open" status light (i.e. full closure) on the benchboard.
Virginia Electric and Power Ctmpany is prtposing a revised Technical Specification for MIV response time testing which more accurately reflects l
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1 current accident analysis assumptions.
T.S. 4.7.B.1 is proposed to read:
"A full closure test of a main steam line trip valve shall be considered satisfactory if the follwing criteria are met:
a.
T1 less than or equal to 4.0 seconds and b.
T2 less than or equal to 5.0 seconds where T1 = measured elapsed time from manual initiation 1
of steam line isolation to initiation of main steam trip valve motion, secorris T2 = measured elapsed main steam trip valve stroke time (full open to full closed), seconds" l
l he autcznatic MSTV closure feature is designed for protection of the plant against the consequences of a main steam line break (MSIB).
We current bounding MSIB analysis is dimmM in Section 14.3.2 of the Surry UFSAR.
mis analysis was sutruitted in Reference 1 to support removal of Technical Specification requirements for the boron injection tank (BIT).
'Ihe analysis sequence of events for the limitirxJ case (break inside containment with offsite power available) is shwn in Table 1.
Note the analysis reflects two separate 5 seccod time periods associated with MSTV closure.
%e first 5 secord delay period accounts for signal processing ard the time required for air to bleed frun the air operating cylinders associated with the MSTV's to a l
pressure lw enough to allw disk motion. We second time period includes a 5 l
second ramp closure time which simulates the actual disk motion.
h p.vg;osed acceptance criteria are established to ensure this safety analysis assunption is maintained.
'Ihus the criteria. my be written as follows:
- a. (I + B) less than or equal to 5.0 seconds
- b. S less than or equal to 5.0 seconds I
where I
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Instrument resporsse tim (delay fran time process variable reaches the setpoint to initiation of bleadoff of instrument air j
frun the main steam trip valve air cylinders), secords.
i B=
Time delay from initiation of bleedoff of instrument air frun 4
the main steam trip valve air cylinders to initiation of valve motion, seconds.
S=
Valve stroke time (full open to full closed), seconds.
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'Ihe instrunent response time I is represented by a value of 1.0 seconds, based on a conservative evaluation of the actual response time. 'Ihis value includes i
considerable margin to actual response time measurements made at Surry Power Station.
h bleedoff time B is equivalent to the measured interval T1 as -
j defined in the Acceptance Criteria section of the Specification. h stroke
4 time S is conservatively approximated by the measured interval T2 as defined in the Specification. Under actual steam line break conditions it is expected that S will be much less than T2, since valve closure is flow assisted. Thus the acceptance criteria may be rewritten as defined in the proposed TS Section 4.7.B.1.
i Closure of the Main Steam Trip Valves under test conditions requires ventire j
of the ocntrol SOV's located in the Auxiliary Biilding.
'Ihese SOV's were relocated fran the Safeguards Building to the Auxiliary Biile1]rg during 1973 i
to address environmental qualification concerns.
The long run of air piping l
l between the SOV's arx1 the MSTV air cylinders results in a relatively large 1
volume of air which nust bleed off, before the valves will close. Under test conditions, air pressure must decrease fran a ncxninal 90 psig to approximately i
32 psig before the valve will start to close.
Under full steam flow l
conditions, not only will steam flow assist in rapidly closirg the valves, but rupture disks in the air cylirxlers will permit even faster depressurization.
A review of historical valve stroke times has been performed.
Prior to Dhr 1986, the surveillance test interpreted valve closure time to refer to actual valve stroke time, as indicated by the position limit switches.
A review of ASME Section XI requ h nts in 1986 resulted in a change of l
definition of " valve stroke time" to refer to the total time from actuation of the isolation signal to full closure of the valve. Since this new definition now includes air bleed off time, total recorded closure times inanediately 1
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increased. Average recorded valve stroke tim, for emmple, for 28 tests of 1-MS-TV-101A between 1984 and 1986, was approximately 3.4 seconds. The PT was revised to include the new definition in One m ber 1986.
For 11 tests performed on the same valve between WWr 1986 ard August 1987, the average recorded stroke tim was 5.5 secords. This average value includes data frun failed tests and reflects the effect of the addition of the air bleed tim to the valve stroke time.
Data frm two recent tests show closure times frm 5.37 to 7.22 seconds ard 4.89 to 6.41 seconds as reported in our October 6, 1987 letter (Serial No.87-629) which deirurukata that no degradation is occurirg in valve closure tims.
Data for the other 5 trip valves show similar effects.
l Review of the historical test data reveals no irdication of a trerd of degrad-irg valve performance. Rather, the recent difficulties in achievirq a satis-factory valve stroke time, result frm a charge in definition to be consistent with ASME XI requirements.
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10 CFR 50.59 EVAIUATICN Virginia Electric arxi Power Ctrapany proposes deletion of the main steam trip valve partial closure test specified in Section 4.7 of the Technical Specifications and replacing it with a more rigorous full closure test, to be performed at each startup. In addition, a revision to the acceptance criteria for main steam trip valve (MS'IV) closure time testing has been proposed which more accurately reflects the a m - tions of the existing safety analyses.
l Based on our review of the change, we have determined that the pivposed revision will not create an unreviewed safety question as defined in 10 GR l
50.59.
Specifically:
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h proposed change does not increase either the probability of occurrence or consequences of any accident or uIniment malfunction scenario which is inportant to safety and which has been previously evaluated in the UFSAR.
'Ihe proposed change eliminates the partial closure test, but requires a more comprehensive full closure test on the same frequency.
'Ihe full closure response time portion of the proposed charge impacts only the main steam trip valve response time and therefore has no effect on initiatirg event frequencies.
Since the proposed I
response time criteria remain bounded by the response characteristics l
a = wd in the safety analysis, the current analysis results and conclusions are uncharged.
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'Ibe possibility of an accident or malfunction of a different type than those previously evaluated in the safety analysis report is not created.
'Ihe response time characteristics of the ergineered safety features _ have no impact on the range of initiatirg events previously a-W.
Neither do the associated surveillance frequencies.
3.
The margin of safety as defined in the bases of the technical specifications is not r d W. Since the sq-wi recipcis time criteria for. the M9IV's is consistent with the safety analysis a===tions, the existing accident analysis results remain bounding. Therefore the safety margins are not inpacted.
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NO SIGNIFICANT HAZARDS CDNSIDD%fION DETERMINATICH Virginia Electric ard Power Cmpany proposec a modification to Section 4.7,
" Main Steam Line Trip Valves", of the Surry Units 1 ard 2 Technical Specifications.
N prcposed modification will result in two changes.
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first is the elimination of the partial closure test specified in Section 4.7A, which would be replaced with a more rigorous full closure test, to be performed at each startup.
'Ihe secord change irwolves a revision to the acceptance criterion for main steam trip valve (MSTV) closure time testing which results in a more accurate reflection of the assumptions of the existing safety analyses.
'ISe current safety analysis assumes a 5 second time delay frun the time the measured process variables (e.g. steam line flow, steam line pressure) reach j
the main steam line isolation setpoints to the initiation of MSTV motion, l
followed by an additional 5 secord ramp closure of the valves.
'Ihe pugsed surveillance criteria would confirm that each of these components of the MSTV response time are bcurded by the analysis a==ntions.
1 Virginia Electric ard Power Ompany has reviewed the proposed changes against the criteria of 10 CFR 50.92 ard has concluded that the charges do not pose a significant safety hazards consideration as defined therein.
Specifically, operation of Surry Power Station with the pwgsed amendment will not:
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Involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed chage impacts only the main steam trip valve response tire acceptance criterion and associated surveillance frequencies ard therefore has no effect on initiatire event frequencies. Since the proposed response time criteria remain bounded by the response characteristics assumed in the safety analysis, the current analysis results and conclusions are unchanged. The proposed charge does nct involve any increase in the probability or consequences of an accident previously evaluated.
2.
Create the possibility of a new or different kird of accident previously evaluated.
The response time characteristics of the engineered safety features have no impact on the range of initiatirg events previously assessed.
Likewise the revised surveillance frequencies will have no impact. Therefore, new or different kirds of accidents are not created.
3.
Involve a significant reduction in a rargin of safety.
Since the proposed response time criteria for the NS7V's are corsistent with the safety emalysis assumptions, the existing accident analysis results remain bounding. Therefore the safety margins are not impacted.
The revised TS surveillance request results in an increased total time for the acceptance criteria.
No reduction in a margin of safety should be inferred from this increased total time. This is because the revised
acceptance criterion requires the consideration or testing of three parameters:
instrtment response time, air bleedoff and valve stroke time, whereas the existing specification addresses only valve stroke time.
Meastuuumult or consideration of these additional parameters does not affect actual valve response times. Current test results desieobate that valve degradation is not occurring. Total valve respair.e is within the limits establistr3 by the accident analysis. Therefore, no margin of safety is actually t_ educed.
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Ietter fram W.
L. Stewart (Vepco) to H. R. Dentan (NRC), Amendment to l
Operatiry Licenses DPR-32 and DPR-37, Surry Ibwer Station Units 1 and 2, Proposed Technical Specifications diange, Serial No. 521, September 13, 1
1983.
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'IABI.E 1 SEQUDiCE OF EVDTIS MAIN STEAM LINE BREAK W/OFFSITE IMER ANALYSIS PERFORMED 08/04/83 EVENT TIME, SEC Break Initiation 0.0 High Steam Line Flw Signal fram Intact Ioops 0.002 Irv Steam Line Pressure Signal 1.2 Safety Injection Pumps Start on Coincident High Steam Flw/Iow Steam Pres.
3.2 Main Steam Trip Valves Begin to Close on Coincident High Steam Flow /Iru Steam Pres.
- and **
- 6. 2 Main Steam Trip Valves Closed
- 11.2 Safety Injection Pumps Reach Full Speed 13.2 Peak Heat Flux Occurs 2C1 Dilute Boric Acid frun Safety Injection Enters Core 231 Prun
- to
- Instrunent plus bleed time (5 second delay)
Fran ** to ** Valve stroke time (5 second delay)
Envilumedal Considerations Pursuant to 10 CFR 51.22(b), the NRC may fird that no envituwe.ulal impact statement or envitumeital awent need be prepared in connection with a proposed amendment if it falls within the scope of the categorical exclusions 1
riim, mal in 10 CFR 51.22(c). We have reviewed the categorical exclusions and consider exclusion 9 to be applicable.
10 CFR 51.22(c)(9) states:
" Issuance of an amendment to a permit or license for a mactor pursuant to Part 50 of this chapter which charges a requirement with respect to l
installation or use of a facility ccatponent located within the mstricted l
area, as defined in Part 20 of this chapter, or which changes an 1
inspection or a surveillance requirement, pmvided that (i) the amerriment involves no significant hazards consideration, (ii) them is no significant change in the type or significant increase in the amounts of any effluents that may be released offsite, ard (iii) them is no significant increase in individual or cumulative occupational radiation exposure."
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our evaluation is sumarized below:
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'Ihe facility cxxnponents affected by the proposed change are located with the Main Steam Valve House which is within the restricted area as defined 1
in 10 CFR Part 20.
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'Ibe proposed change is to a surveillance requimu=uit in Technical Specification 4.7, Main Steam Line Trip Valves.
l We have provided information supporting a determination that the proposed amerdment involves no significant hazards consideration. 'Ihe details of our determination are in the attached NSHC determination.
'Ihe proposed amendment dces not change the type of effluents that are released offsite nor does it significantly increase the amount.
'Ihe proposed change provides explicit acceptance criteria for conducting the Main Steam Trip Valve surveillance requirutent.
It establishes specific times for instrument response time, time delays, ard valve stroke time.
'Ihese acceptance criteria are conservative with respect to the assumptions for the previously approved MSIB analysis and would result in 1
offsite releases that are within accident analysis limits. No new types of effluents are created because the accident initiator is unchanged from previous aralyses.
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'Ibe proposed su=due.ct does not significantly increase an irriividual or cumilative m pational radiation expoeare.
No charge in radiation worker activities (e.g. valve maintenance) are expected to change as a result of this proposed sns diu d..
Therefore, no significant increase in individual or cunulative occupational radiation exposure is anticipated.
Based on this evaluation,_we conclude that the categorical' exclusion in 10 CFR 51.22(c)(9) is applicable and that no EIS or EA need be pu,_-M in cuumiction -
l with the proposed amendment.
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4 JUSTIFICATION FOR FMERGENCY TEGNICAL SPECIFICATION OWE - IF RBJUIRED
'Ihis discussion is provided to document the justification for an emergency technical specification should an unanticipated shutdown of either Surry 1 or 2 occur while this airerdrait is being reviewed.
On two previous occasions, the NRC has granted relief by means of discretionary enforcement - to permit the restart of a Surry unit when the acceptance criteria of Technical Specification 4.'7 could not be met based on our review of the ASME code requirements.
'Ihe issue has not been one of safety. Sufficient evaluations arrl supporting hwritation are available to dercruLrute that, based on current MSIV closure times, the results of the previously approved main steamline break accident analycas remain valid.
Nor has NRC been adverse to granting the relief. Rather, the issue has been to identify the appropriate administrative vehicle for granting relief. Based i
on our subnittal of a pu _--W Technical Specification change arri discussions
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I with NRC management, we believe that in the event another surveillance test
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needs to be corriucted, emergency approval of this pwposed Technical.
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Specification change is the most appropriate mechanism to facilitate restart 1
of a Surry unit.
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1 yj Although the issue of ocupliance with Technical' Specification 4.7 arose in early 1987, the submittal of a proposed Technical Specification.at this time should not be considered untimely. Underlying the Technical Specifications is the philosophy that the systems and v.mpeuabs are. expected to meet the
<y specifications, and that a failure to meet the specifications should.tixst result in an examination of the campcoent or equipment, not in a revision to the specification.
'Ihis approach. assures that canponents or systene J
experiencing scane type of degradation will not be permitted to go uncorrteted.
In the case of Surry, following tne 4Wr 9, 1986 accident, a perlext of increased maintenance activity and nimw=nt attention had been directed at the MSTVs.
Significant improvement in valve conditions has been achieved.
'Ihis improvement has taken several months to properly inplement and to assure ourselves that the valves are now performing as designed.
However, even in this optimum condition, it is evident from the test results that they are nch.
capable of meeting the current Technical Specification acceptance criteris' based on our review of the Asle code requirements.
Because further improvement in valve performance is unlikely, we now consider it a@ropriatb
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to prcpose a revised acceptam.e criterion for valve performance.
'Ihus, a')
Technical Specification change ' can no longer,bo avoided and is in fact appropriate at this time.
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. On the other hard, by providing justification for an emergency charge at this J
l time, the impact on NRC and Virginia Power resources is minimized if administrative relief is required prior to routine NRC approval of the i'
proposed charge.
We have. adrq2ately demonstrated that the results of the previously approved accident analyses remain valid ard that offsite does consequences remain a small fraction of the' 10 GR 100 guidelines. - We have j
determined that the proposed charge involves no.significant hazards l.
curil*$ation.
We have determined that valve closure performance is not dyradirs over time.
We have nctified apywytiate state officials of the I
J propoced. change and the possibility that the pup 0cred change might be 1
y requestal on an emergency basis.
yt In the event a request to prccnss the change on an emergercy basis were not l
granted, the affected Surry trnit would not be able to return to power operation until the NRC approved the proposed change on a toutine basis.
j Because there is no safety concern associated with revising this surveillance j
requirement's acceptanors criterion and because similar relief has been granted on two previous occasions by NRC, the failure to process /the direspq charge would place undue hardship on both the licensee, in terms of obtaining replacement power, and on the public, in terms of the,sig;nificant additional
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replacement power cost.
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M on NRC estimates of the time normally W to pwcess a Technical Specification change like this one - 45 days from the date of receipt -. we have 6ed a planned Surry 2 maintemnoe outage to _ fall outside that 4,t, x period. 'Ihis results in the Surry '2 restart -(and the' rdamx:iatbd requinamuit
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