ML20235Z326
| ML20235Z326 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/06/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-268, NUDOCS 8903150331 | |
| Download: ML20235Z326 (4) | |
Text
.
au--
-m-l Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 1
March 6, 1989 l
LIC-89-268 l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No.50-285 2.
Letter from OPPD (R. L. Andrews) to NRC (Document Control Desk) dated June 22, 1987 (LIC-87-425) 3.
Letter from 0 PPD (K. J. Morris) to NRC (P. D. Milano) dated January 6, 1989 (LIC-89-032) 4.
Letter from OPPD (K. J. Morris) to NRC (Document Control Desk) dated February 28, 1989 (LIC-89-194)
Gentlemen:
This letter supersedes the "No Significant Hazards Consideration Analysis" in Reference 3 as requested due to administrative clarifications.
In addition, the Affidavit in Reference 4 was not notarized.
Please find enclosed a notarized Affidavit.
Please feel free to contact us if you have any questions.
Sincerely, f) fY K U.
orris Division Manager Nuclear Operations KJM/sa Discussion, Justification and No Significant Hazards Consideration Analysis Affidavit c:
LeBoeuf, Lamb, Leiby & MacRae P. D. Milano, NRC Project Manager R. D. Martin, NRC Regional Administrator P. H. Harrell, NRC Senior Resident Inspector h6 l Harold Borchert, Director - Nebraska Division 89031so33['f Radiological Health hM ADock$$.hl$Elfjg5 l }
PDC 45 5I24 Employmen in u opportunny
DISCUSSION, JUSTIFICATION AND NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS Generic Letter 87-09 provided guidance, in part, to the general requirements on the applicability of surveillance requirements in the Standard Technical Specifications, and encouraged licensees to propose changes to their Technical Specifications that are consistent with the guidance provided.
OPPD is proposing to incorporate a general section to the beginning of Section 3 of Fort Calhoun's Technical Specifications. The proposed change will make the Fort Calhoun Station Technical Specifications closer to the Standard Technical Specification, and fulfills commitments made in LER 88-006 Revision 1, dated September 29, 1988.
This Amendment will provide the FCS Technical Specifications with the following provisions:
1.
A 25% extension for surveillance intervals, but the total interval for three consecutive surveillance intervals shall not exceed 3.25 times the specified intervals.
2.
The regular surveillance intervals are defined.
3.
A 25% extension applicable to all codes and standards referenced within.
4.
The action statements for a Technical Specification can be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under certain conditions, j
5.
Inoperable equipment does not need to have surveillance performed on it.
Any general items that appear within other surveillance requirements have been removed to avoid duplication.
Specifically:
pages 3-1, 3-6, 3-12a, 3-16c, 3-17, 3-63, 3-69, 3-72, 3-73 and 3-80.
10 CFR 50.91(a)(1) requires that licensees requesting an Amendment provide an analysis addressing the issue of no significant hazards consideration as defined in 50.92. This Amendment would not involve a significant hazard for the following reasons:
1.
This Amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change is a change to achieve consistency throughout Section 3 of the Technical Specifications. This change is not deemed significant, because it incorporates guidance provided by Generic Letter 87-09.
2.
This Amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
This is a purely administrative change to the Technical Specifications, it does not alter the manner in which equipment is operated and does not eliminate any surveillance required by the Technical Specifications.
Page 1 of 2
3.
This Amendment will not cause a significant reduction in the margin of safety.
Providing clarification for the applicability of surveillance requirements does not change the method of operation and, therefore, does not reduce the margin of safety. This Amendment, based on Generic Letter i
87-09, is consistent with the recommendations of NUREG-1024 " Technical Specifications -- Enhancing the Safety Impact" and the Commissions Policy Statement on Technical Specification Improvements.
OPPD does not believe this change involves significant hazards considerations.
Page 2 of 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
In the Matter of
)
Omaha Public Power District Docket No. 50-285 (Fort Calhoun Station
)
Unit No. 1)
)
i AFFIDAVIT K. J. Morris, being duly sworn, hereby deposes and says that he is the Division Manager - Nuclear Operations of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached information concerning the response to No Significant Hazards Consideration Analysis; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and belief.
1 R0 hnh K'.LJ'. M6fri si Division Manager l
Nuclear Operations STATE OF NEBRASKA)
)
ss COUNTY OF DOUGLAS)
Subscribed and sworngo before me, a Notary Public in and for the State of Nebraska on this b
day of March, 1989.
M "n7a74f
~
Notary Public m we. sw 1
4
_