ML19325E984

Application for Amend to License DPR-72,consisting of Tech Spec Change Request 177,deleting 3.25 Limit from Spec 4.0.2, Per Generic Ltr 89-14, Line-Item Improvements in Tech Specs-Removal of 3.25 Limit on Extending Surveillance....

ML19325E984
Person / Time
Site:	Crystal River
Issue date:	10/31/1989
From:	Boldt G FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19325E985	List: ML19325E984 ML19325E990
References
3F1089-25, GL-89-14, NUDOCS 8911130141
Download: ML19325E984 (5)

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t C O R P O R AT ION Octr* ** 31, 1989 3F1089-25 U.S. Nuclear Regulatory Canaission

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Attention: W==1t control Desk Washington,.D.C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Qiange Request No. 177

Dear Sir:

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Florida Iber Corporation (FFC) hereby submits Technical Specification CNnge 1 Request No. 177 requesting amerdment to Appendix A of Operating License No.  !

j DPR-72. As part of this request, the proposed replacement pages for Appendix A l and associated bases are prwided.

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This sutnittal proposes the deletion of the 3.25 limit frun Specification 4.0.2. This'is proposed in accordance with the guidance provided in Generic Istter 89-14, "Line-Item Inpruvements in Technical Specifications - Removal of the 3.25 Limit on Deterding Surveillance Intervals".

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FPC requests this amerdment be inplemented within 30 days after issuance to  !

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allow for sucedure revisions and training.

. Sincerely, 4*feP l Gary ldt, Vice President  !

Nuclear Production  !

-GB:DGG:wla Attachment xc: Regional Administrator, Region II

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Senior Resident Inspector l

8911130141 891031 \\

1 PDR ADOCK 03000302

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P PDC L

l i Post Office Box 219

• Crystal River, Florida 32629

• Telephone (904) 795 3802 m A Florida Progress Company

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UNTIED STA'IES OF AMERICA  !

NUCIZAR REGUIA'ICRY O2 MISSION

.i IN 'INE MATIER )

) DOCKEI' No. 50-302 FIDRIIA IOER CORPORATION )

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CERI'IFICATE OF SERVICE Gary Boldt W and says that the following has been served on the Designated State Representative and Chief Executive of Citrus County, Florida, by deposit in the United States mail, addra= W as follows:

Chairman, Administrator Board of County Comissioners Radiological Health Servicec of Citrus County Department of Health anti Citrus County Courthcs2se Rehabilitative Services Inverness, FL 32650 1323 Winewood Blvd.

l Tallahassee, FL 32301 1

i' A copy of 'Ibchnical Specification Change Request No.177, requesting Amendment l to Appendix A of Operating Licensirq No. DPR-72.

l FIDRIIA POWER 00RIORATION l

F XWh/M Gary Boldt, Vice President Nuclear Production  :

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SWORN 'IO AND SUBSCRIBED BEIVRE ME 'IHIS 31st IRY OF OCIOBER,1989.

.i M Motary Public Notary Public, State of Florida at Large My r'n=ninaion Expires: /0//9/9k NOTARY PUBLIC. STATE OF FLORIDA AT LAIIGE.

MY COMMISSION EXPIRES OCT.19.1M wo ip ario= *oac wec N" _ .. . .. .-.

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STATE OF FIIRIDA COUN1Y OF CTIRUS Gary Boldt states that he is the Vice President, Nuclear Pruhx: tion for Florida Power Ocrporation; that he is authorized on the part of f said ocmpany to sign arx1 file with the Nuclear Regulatory Cannission the information attached hereto; and that all such statements made and matters set forth therein are true ard correct to the best of his knowledge, information, and belief.

k Gary D61dt, Vice President Nuclear Production Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 31st day of October, 1989.

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Notary Public Notary Public, State of F1 ricja at Large My camission Expires: /0 ')/ 9F NaiARY POBUC. STATE OF FLOR'DA Al W MY C0wAISSION EKPlHES OCT.10. IkW se,ew, m e m a c mc

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i L, FIIRIIA PGER CIRK3ULTIN i CRl5FmL RIVER IDEIT 3 DOGET NO. 50-302/LTOBEE 10. MR-72  :'

3mynMT NO.177, REVISIN O SRICIFIOE'IN 4.0.2.b rem'r'ICR

.e i IJCENSE DOCLBENP INVOINED: Technical Specification RRFIG4S: 4.0.2.b

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IESCRIPf1W OF REQUESP:

mis subnittal requests the deletion of Specification 4.0.2.b frun Technical Specifications.

REASON RR REQUESff:

Specification 4.0.2 of the Technical Specifications pennits surveillance intervals to be extended up to 25 percent of the specified interval. Eis extension facilitates the scheduling of surveillance activities and allows surveillances to be pc4cred when plant conditions are not suitable for conducting a surveillance, for example, under transient conditions or other ongoing surveillance or maintenarx:e activities. Part b. of this specification

! also limits extending surveillances so that the ccabined time interval for any three consecutive surveillance intervals shall not aw=d_ 3,25 times the

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specified surveillan interval. We intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent.

In a literal application of Specification 4.0.2.b, time spent in refueling 3 outages is neglected. As a result, normal surveillance intervals end up being l' shortened to ensure ocuplianoe. Refueling interval surveillances, for exanple, l have ended up being reduced from 18 nonths to 12 months. m is was due to the i inclusion, in the surveillance due date calculation, of 6 months worth of L refueling / maintenance outages that occurred within the previous 2 consecutive L test intervals. mis practice has in the past caused Florida Power Corporation and NRC Iesources to be expended on processing requests for one-time exceptions for the performance of affected surveillances. As a result, the deletion of Specification 4.0.2.b is requested. m is is being done in l accordance with NRC Generic letter 89-14 (RemWal of the 3.25 Limit on ll Extending Surveillance Intervals).

EVAURfIW OF REQUESP:

Experience has shown that surveillance intervals, with provisions to extend them by 25 percent are usually sufficient to am--.- -hte normal variations in the length of a fuel cycle. However, tha NRC staff has granted requests for one time exceptions to the 3.25 limit on exterxling refueling surveillances because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances. %erefore, it has been concluded the 3.25 limitation on extending surveillances is not a practical limit on the use of the 25 percent allowance for extending surveillances that are performed on a refueling outage basis.

We uso of the allowance to extend surveillance intervals by 25 percent can result in a significant safety benefit for surveillances that are performed on

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a routine basis during plant operation. This safety benefit is incurred when a surveillance interval is extended at a time that conditions are not suitable for performing the surveillanoe. Exanples of this include transient plant operating conditions or ccriditions in which safety systems are out of service because of ongoing surveillance or maintenance activities. In such cases, the safety benefit of allowing the use of the 25 percent allowance to extend a j surveillance interval would outweigh any benefit derived by limiting thme .

consecutive intervals to the 3.25 limit. Additionally, them is the l administrative and logistic burden associated with tracking the use of the 25 I percent allowance to ensure ocmpliance with the 3.25 limit. On the basis of  !

these considerations, it is concluded that removal of the 3.25 limit will have l

an overall positive impact on safety, i SEDILY EVALIDLTIGi:

Florida Ptwer Corporation (FPC) proposes that this change does not involve a significant hazards consideration. 7he de]etion of the 3.25 limit on extending surveillances has no negative inpact on plant operation or safety. The use of the allowance to extend surveillance intervals by 25 percent results in a ,

significant safety benefit when the surveillance is extended at times when conditions are not suitable for performing the surveillance. In these cases, the safety benefit of allowing the use of the 25 percent extension would outweigh any benefit derived by limiting three consecutive intervals to the 3.25 limit.

Based on the above, FPC finds that the charge will not:

1. Involve a significant increase in the probability or consequence of an accident previously evaluated because the deletion of the 3.25 limitation recognizes that the most probable result of any particular surveillance belig performed is the verification of conformance with the Surveillance Requirements. Therefore, accident analysis assunptions reflected in these Surveillance Requirements will still be verified on a frequency sufficient to ensure that the assunptions are reliably maintained.

2. Create the possibility of a new or different kind of accident previously evaluated because the proposed change introduces no new mode of plant operation nor does it require physical modification to the plant.

Additionally, the surveillance interval will still be constrained by the 25 percent extension criteria of Specification 4.0.2.

l 3. Involve a significant reduction in the margin of safety. Any reduction in the margin of safety will be insignificant ard offset by the safety benefit gained by allowirg the surveillance to be extended at times when conditions are not suitable for performirg the surveillance ard by not forcity the plant through a shutdown transient to perform refueling interval surveillances.

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