ML20245F163

Safety Evaluation Supporting Amends 117 & 106 to Licenses DPR-39 & DPR-48,respectively

ML20245F163
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/01/1989
From:	Office of Nuclear Reactor Regulation
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ML20245F158	List: ML20245F154 ML20245F160 ML20245F163
References
NUDOCS 8908140188
Download: ML20245F163 (6)

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%; w SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 117 TO FACILITY OPERATING LICENSE NO. DPR-39  !

l AND AMENDMENT NO. 106 TO FACILITY OPERATING LICENSE NO. DPR-48 COMMONWEALTH EDISON COMPANY ZION NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-295 AND 304 l

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1.0 INTRODUCTION

By letter dated June 13, 1989, the Commonwealth Edison Company (the licensee) requested amendment to Facility Operating License Nos. DPR-39 and DPR-48 for the Zion Nuclear Power Station. The proposed amendment would change the plant Technical Specifications (TSs) based on the recommendations provided by the staff in Generic Letter (GL) 87-09 related to the applicability of limiting conditions for operations (LCO) and the surveillance requirements of the TS 3.0 and 4.0. Specifically, the licensee has requested the following revisions to TS 4.0.3 and 4.0.4 as follows:

Specification 4.0.3 is revised to incorporate a 24-hour delay in implementing Action Requirements due to a missed surveillance when the Action Requirements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Specification 4.0.4 is revised to clarify that "This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with Action Requirements."

The licensee has also proposed to revise appropriate pages to reflect the guidance of Generic Letter 87-09 as it applies to the Bases for Section 4.0 of the Technical Specifications. In addition, the licensee has proposed to revise Section 3.3.1.F, Relief Valves, to add a statement that the provisions of General LCO 3.0.4 are not applicable. Finally, the licensee has proposed to make a few editorial changes to enhance clarity in the Technical Specifications.

2.0 EVALUATION The changes proposed by the licensee have been reviewed considering the limitations set forth in GL 87-09 for TS 3.0.4, 4.0.3, and 4.0.4 as follows.

Specification 4.0.3 In GL 87-09, the staff stated that it is overly conservative to acsume that systems or components are inoperable when a surveillance requirement has not been performed because the tast majority of surveillences demonstrate that 89001401GB 690B02 I#

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systems or components in fact are operable. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements anoly, the TS should include a time limit that would allow a delay of the required at. Mons to permit the performance of the missed surveillance.

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delr.y in completion of the surveillance. After reviewing possible limits, the str.ff concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risk associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to ccn. ply with Action Requirements before the surveillance can be completed.

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This limit does not waive compliance with Specification 4.0.3. Under Specification 4.0.3, the fadlure to perform a surveillance requirement will continue to constitute noncompliance with the operability requirements of an LC0 and to bring into play the applicable Action Requirements.

Based on the above, the following change to Specification 4.0.3 is acceptable:

Tailure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION Requirements are applicable at the time it is identified that a Surveill6nce Requirements has not been performed. Compliance with the Action Requirement may 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 /> to permit the completion of the surveillance when the allowable'cutage time limits of the Action Requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Specification 4.0.4 TS 4.0.4 prohibits entry into an OPERATIONAL CONDITION or other specified condition until all required surveillance have been performed. This could I

cause an interpretation oroblem when OPERATIONAL CONDITION changs are required in order to comp N with ACTION statements. Specifically, two possible conflicts between '.Ss 4.0.3 and 4.0.4 could exist. The first conflict arises because TS 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance interval. The licensee's proposed modification to resolve this conflict involves the revision to TS 4.0.3 to permit a delay of up to 24 hcurs in the application of the Action Requirements, as explained above, and a clarification of TS 4.0.4 to allow passage through or to operational modes as required to comply with Action

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s Requirements. The second potential conflict between TSs 4.0.3 and 4.0.4 arises because an exception tc the requirements of 4.0.4 is allowed when surveillance requirements can only be completed after entry into a mode or condition. However, after entry into this mode or condition, the requirements of TS 4.0.3 may not be met because the surveillance requirements may not have been performed within the allowable surveillance interval.

The licensee proposes to resolve these conflicts by providing the following clarifying statement to TS 4.0.4:

"This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements."

The NRC staff has provided in GL 87-09 a clarification that: (a) it is not the intent of 4.0.3 that the Action Requirements preclude the performance of surveillance allowed under any exception to TS 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in TS 4.0.3 for the applicability of Action Requirements provides an appropriate time limit for the completion of surveillance requirements that become applicable as a consequence of any exception to TS 4.0.4.

Consequently, the NRC staff finds the proposed changes to TS 4.0.4 acceptable.

Relief Valves and Containment Isolation Valves The Generic Letter 87-09 recognizes, in part, that Specification 3.0.4 unduly restricts faility operation when conforn.ance to the Action Requirements provides an acceptable level of safety for continued operation in any mode.

For an LC0 that has Actic.n Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitteo in accordance with those Action Requirements. The restriction on change in operational modes or other specified conditions should apply only where the Action Requirements establish a specified time interval in which the LC0 must be met or a shutdown of the facility would be required or where entry into that operational mode would result in entry into an Action Statement with such time constraints. However, nothing in the staff position stated in GL 87-09 should be interpreted as endorsing or encouraging plant startup with inoperable equipment. The GL 07-09 itself states that startup with inoperable equipment should be the exception rather than the rule.

The licensee has proposed to revise Section 3.3.1.F, Relief Valves, to add a statemer.t that the provisions of General LC0 3.0.4 are not applicable. The addition of the exception to the requirements of General LC0 3.0.4 is consistent with Section 3.4.4 of the Standard Technical Specifications for Westinghouse Pressurized Water Reactors. The applicable Action Requirements provide an acceptable level of Safety for continued operation in any mode, and i it is ccr.sistent with the Updated Safety Analysis Report. Therefore, the staff finds it to be acceptable.

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In addition, the licensee has proposed to correct typographical errors which stated the requirements of Section 3.9.3 on both pages 199 and 199a. The change will delete the statement from page 199. The licensee has also proposed some minor editorial changes and proposed to revise appropriate Bases Sections to reflect the guidance provided in Generic Letter 87-09. As these changes are t intended to enhance the clarity in the Technical Specifications, these changes are found acceptable by the staff.

3.0 ENVIRONMENTAL CONSIDERATION

These a'nendments involve a change in the installation or use of the facilities components located within the restricted areas as defined in 10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that these amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or

, environmental assessment need be prepared in connection with the issuance of these amendments.

4.0 CONCLUSION

We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safet not be endangered by operation in the proposed manner, such(2) y of the public will activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Chandu P. Patel, NRR/DRSP/PDIII-2 Dated: August 1, 1989

August 1, 1989 DISTRIBilTION Docket Nos. 50-295 and 50-304 Docket tile NRC & Local PDRs PDIII-2 r/f MVirgilio OGC DHagan fir. Thomas J. Kovach EJordan TMeek (8)

Nuclear Licensing Manager WJones JCalvo Commonwealth Edison Company ACRS(10) GPA/PA Post Office Box 767 OC/LFMB LLuther Chicago, Illinois 60690 PShemanski CPatel Dear Hr. Kovach The Commission has issued the enclosed Amendment No.117 to Facility Operating License No. DPR-39 and Amendment No.106 to facility Operating License No.

DPR-48 for the Zion Nuclear Power Station, Unit Nos. I and 2, respectively.

The anendments consist of changes to the Technical Specifications in response to your application transmitted by letter dated June 13, 1989.

These amendments modify Sections 4.0.3 and 4.0.4, General Surveillance Requirements, of the Technical Specifications for the Zion Station. In addition, Section 3.3.1.F, Relief Valves, is revised to include exception to General Limiting Condition 3.0.4. The proposed changes on Section 3.9.3.A, Containment Isolation Valves (Pages 199a and 199b), were withdrawn by your letter dated July 27, 1989.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's rext regular biweekly Federal Register notice.

Sincerely,

/s Chandu P. Patel, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV, V, and Special Profects

Enclosures:

1. Amendment No. 117 to DPR-39

2. Amendment No. 106 to DPR-48 i 3. Safety Evaluation l

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See next page

• See previous concurrence j

• PDIII-2 *FDIII-2 *0GC *PDIll-2 CPatel:km LLuther PShemanski ,

7/27/89 7/27/89 7/28/89 7/27/69 ]

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DISTRIBUTION

-,,  ; Docket Nos. 50-295 and 50-304 Docket file NRC & Local PDRs e PDIII-2 r/f MVirgilio ,

OGC- DHagan

Mr. Thomas J. Kovach EJordan TMeek (8)'

Nuclear. Licensing Manager WJones JCalvo

' Connonwealth Edison Company-ACRS-(10) ,GPA/PA Post Office' Box 767 -

OC/LFMB f LLuther

~" Chicago, Illinois. 60690. PShemanski / CPatel

. Dear Mr. Kovach The Consission has issued the enclosed Amendment No. 'to Facility Operating

< , License No. DPR-39 and Amendment No. to Facility O DPR-48_for the Zion Nuclear Power Station, Unit Nos.' perating I and License No.

2, respectively.

e The amendments consist of changes _ to the Technical / Specifications in response to your application' transmitted by letter dated June 13, 1989.

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These amendments modify Sections 4.0.3 and 4.0(4, General Surveillance Requirements, of the Technical Specifications'for.the Zion Station. In addition Section 3.3.1.F Reliet Valves, is' revised to include exception to General Limiting Condition 3.0.4. - The proposed changes on Section 3.9.3.A, Containment Isolation Valves, will be reviewed soarctely after we receive your submittal on Section 3.0.4. ,/

'A copy of the related Safety Evaluation is enclosed.- A Notice'of Issuance will-ba included in the' Connission's next' regular btweekly Federal Register notice.

/ Sincerely,

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/ Chandu P. Patel, Project Manager

/' Project Directorate III-2 i.

j/ Division of Reactor Projects - III, IV, V and Special Projects

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Enclosures:

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1. Amendment No. j# to DPR-39

2. Amendment No./ to DPR-48 .

3.. Safety Evaluation l  ;

/ i cc w/enclor,ure's:

See next pag,e' PD -2 PDIII-2 OGh ' D 11 2 I CPatel:km, LLutherM yu p PShemanski 7/2 7 /89 'N/47 /89 7/p/89 7/79 /89

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