ML20245J028
| ML20245J028 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/08/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245J026 | List: |
| References | |
| NUDOCS 8908170433 | |
| Download: ML20245J028 (3) | |
Text
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~g UNITED STATES NUCLEAR REGULATORY COMMISSION n
3 E WASHINGTON, D. C. 20555
%..... gl' SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 81 TO FACILITY OPERATINC LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-395
1.0 INTRODUCTION
By letter dated May 22, 1989, the South Carolina Electric & Gas Company (the licensee) requested an amendment to Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit No.1. The proposed amendment would change the plant Technical Specifications (TS) 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 TS 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."
2.0 EVALUATION The changes proposed by the licensee have been reviewed considering the limitations set forth in GL 87-09 for TS 4.0.3 and 4.0.4 as follows.
1.1 Specification 4.033 In GL 87-09, the staff stated that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed, because the vast majority of surveillance demonstrate that 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 apply, the TS should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.
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- l 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 delay in completion of the surveillance. After reviewing possible limits, the i
staff 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 that this time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with allowing the completion of the l
surveillance within this period against the risks associated with the shutdown of the reactor to comply with Action Requirements before the surveillance can be completed and the potential for a plant upset and challenge to safety systems.
This limit does not waive compliance with Specification 4.0.3.
Under Specification 4.0.3, the failure 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 l
Requirements.
Based on the above, the following change to Specification 4.0.3 is acceptable-
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Failure to perform a Surveillance Requirement within the allowed l
surveillance interval, defined by Specification 4.0.2, shall l
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 1dentified that a Surveillance Requirement has not been performed. The ACTION Requirements 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 allowabic 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 />. Surveillance Requirements do not have to be performed on inoperable equipment.
2.1. 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 cause an interpretation problem when OPERATIONAL CONDITION changes are required in order to comply with ACTION statements.
Specifically,
two possible conflicts between TSs 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 Requirements. T.he second potential conflict between TSs 4.0.3 and 4.0.4 arises because an exception to 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.
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i TT 3-1 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 j
MODES as required to comply with ACTION requirements.
The NRC staff has provided a clarification in GL 87-09 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 an exception to TS 4.0.4 i
Consequently, the NRC staff finds the proposed changes to TS 4.0.4 acceptable.
3.0 ENVIRONMENTAL C0tGIDERATION This amendment involves a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance require-ments. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any -
1 effluents that may be released off site, and that there is no significant increase in individual or cumulative. occupational radiation exposure. The Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration, and there has been no public coment on such finding.
Accordingly, this amendment meets the eligibility I
criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement nor environmental assessment need be prepared in connection with the issuance of this amendment.
4.0 CONCLUSION
The Commission made a proposed determination that this amendment involves no significant hazards consideration which was published in the FEDERAL i
REGISTER dated July 12,1989 (54 FR 29411) and consulted with the State of South Carolina.
No public comments were received, and the State of South Carolina did not have any comments.
l The staff has concluded, based on the considerations discussed above, that:
i (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the j
common defense and security or to the health and safety of the public.
Principal Contributor:
J. J. Hayes, Jr.
Dated:
August 8,1989
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