ML20005G941

Application for Amends to Licenses NPF-68 & NPF-81,deleting Requirement That Combined Time for Any 3 Consecutive Surveillance Intervals Not to Exceed 3.25 Times Specified Interval.Amend Approval Requested by 900731

ML20005G941
Person / Time
Site:	Vogtle
Issue date:	01/15/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20005G942	List: ML20005G941 ML20005G945
References
ELV-01140, ELV-1140, NUDOCS 9001230305
Download: ML20005G941 (4)

Text

. . _ _

Georgo hwn Company 333 he:1mor0 Aw9ue i Atlanta. Goova 30308 leie;Arne 4N LPE3195 f) M r>g k & css 40 toveness Cewn P,#way l NM Off ee lka 1?95 i fiamenfwn Mahama 35PD1 1

lemr40% ?05 %B S$81 t% s ut*e n W VC w w m W. CL Halmton, HI i cervor W e hewient i NxhaHNeobons 1 January 15, 1990 ELV-01140 l 0158 j i

Docket Nos. 50-424 i 50-425 I U. S. Nuclear Regulatory Commission i ATTN: Document Control Desk Washington, D. C. 20555 i Gentlemen: l l

V0GTLE ELECTRIC GENERATING PLANT  ;

RE0 VEST TO REVISE TECHNICAL SPECIFICATION 4.0.2 In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia i Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating  ;

, Plant (VfCD) Unit I and Unit 2 Technical Specifications, Appendix A to Operating l Licenses NPF-68 and NPF-81.

The proposed amendment would revise Technical Specification 4.0.2 by deleting the requirement that the combined time interval for any three consecutive surveillance intervals is not to exceed 3,25 times the specified surveillance interval. The proposed change is based on the guidance of Generic Letter 89-14, -

"Line-Item Improvements in Technical Specifications - Removal of the 3.25 Limit i l on Extending Surveillance Intervals."

l GPC requests approval of the proposed amendment by July 31, 1990. While the proposed change is not required to address an immediate safety concern, GPC concurs with Generic Letter 89-14 in that removal of the 3.25 limit will result in a safety benefit by providing for ficxibility in scheduling of surveillance activities when plant conditions are conducive to the safe conduct of a surveillance. Additionally, removal of the limit reduces the potential for unnecessary forced shutdowns to perform surveillance activities. The first Unit ,

2 refueling outage is scheduled for September,1990. Approval of the proposed amendment by July 31, 1990 will allow ample time for implementation of this >

additional flexibility for the upcoming Unit 2 outage.

l In accordance with 10 CFR 50.91, the designated state official will be sent a copy of this letter and all enclosures. ,

9001230305 900115 d PDR ADOCK 05000424 -

P PDC fa/l .

Georgia Power A U. S. Nuclear Regulatory Commission ELV-Oll40 Paae Two Mr. W. G. Hairston, 111 states that he is a Senior Vice President of Georgia Po :e Company and is authorized to execute this oath on behalf of Georgia Power Company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

GEORGIA POWER COMPANY By: N'l. A$= ?x W. G. Hairston, 111 Sworntoandsubscribedbeforemethis]5_bayof Odiuznu , 1990.

/ 0 Y ki m (L.

Notaryfublic

/Nuh Mf M4410N EXPIRES Dic 15.1007

Enclosures:

1. Basis for Proposed Change

2. 10 CfR 50.92 Evaluation

3. Instructions for Incorporation c(w): Georaia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. P. D. Rushton Mr. R. M. Odom NORMS ,

U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. J. B. Hopkins, licensing Project Manager, NRR Mr. J. F. Rogge, Senior Resident inspector, Vogtle State of Georoia Mr. J. L. Ledbetter, Commissioner, Department of Natural Resources

. c ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATION 4.0.2 BASIS FOR PROPOSED CHANGE Proposed Chanae The Vogtle Unit I and Unit 2 Technical Specification (TS) 4.0.2 is proposed to be revised as follows:

1. Delete the requirement that the combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.

2. Revise the associated TS Bases accordingly.

11]L111 Specification 4.0.2 permits surveillance intervals to be extended up to 25 percent of the specified interval. This extension facilitates the scheduling of surveillance activities and allows surveillances to be postponed when plant conditions are not suitable for conducting a surveillance. Specification 4.0.2 also limits the extension of surveillance intervals to the extent that the combined time interval for any three consecutive surveillance intervals may not exceed 3.25 times the specified surveillance interval.

However, on August 21, 1989, the NRC issued Generic Letter 89-14, "Line-Item Improvements in Technical Specifications-Removal of the 3.25 Limit on Extending Surveillance Intervals." In this letter, the NRC staff noted that they have routinely granted requests for one-time exceptions to the 3.25 limit to accommodate variations in the length of a fuel cycle. While the 25 percent allowance is usually sufficient to accommodate variations'in cycle length, the more common occurrence has been to encounter the 3.25 limit on the combined time interval for three consecutive surveillances. The basis for these exceptions <

was that the risk to safety due to the extension of these surveillances was low-  !

in contrast to the alternative of a forced shutdown-to perform surveillance.

Furthermore, the NRC staff concluded that the elimination of this limit for surveillances that are performed on a routine basis during plant operation would also result in a significant safety benefit. The flexibility to schedule surveillances so that conditions not suitable for performing these surveillances can be avoided outweighs any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit.

GPC concurs with the conclusions of Generic Letter 89-14. Accordingly, the proposed change is consistent with the guidance found therein.

j l

ENCLOSURE 2 V0GTLE ELECTRIC GENERATING PLANT  !

REQUEST TO REVISE TECHNICAL SPECIFICATION 4.0.2 P

10 CFR 50.92 EVALUATION l

Pursuant to 10 CFR 50.92, GPC has evaluated the proposed amendment and has '

determined that operation of the facility in accordance with the proposed amendment would not involve a significant hazards consideration. The basis for ,

this determination is as follows:

1. The proposed change does not involve a significant increase in the -

probability or consequences of an accident previously evaluated. The  :

surveillance intervals will continue to be constrained by the 25 percent '

limit. The risk associated with exceeding the 3.25 limit is outweighed by the risk associated with a forced shutdown to perform surveillances which would normally be performed during a refueling outage. In addition, for those surveillances which are routinely performed during plant operation, the flexibility to schedule surveillances to avoid plant conditions which are not conducive to surveillances represents a positive safety benefit. '

Therefore, the proposed change does not involve a significant increase in ,

the probability or consequences of an accident previously evaluated.

2. The proposed change will not create the possibility of a new or different kind of accident from any previously evaluated. The proposed change would not result in any physical alteration to any plant system, nor would there be a change in the method'in which any safety related system performed its function. The change would not result in any equipment being operated in a manner different than that in which it was designed to be operated.

3. The proposed change does not involve a significant reduction in a margin of 1 safety. Deletion of the 3.25 limit will not significantly affect equipment i reliability, rather it will reduce the potential for interrupting normal plant operation due to surveillance scheduling. Surveillance intervals will continue to be constrained by the 25 percent limit. The added flexibility .

in scheduling surveillances afforded by deletion of the 3.25 limit should '

have a positive safety benefit by allowing surveillances to be performed under appropriate plant conditions.

Based on the preceding analysis, GPC has determined that the proposed change to the Technical Specifications will not significantly increase the probability or '

consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or "

involve a significant reduction in a margin of safety. GPC therefore concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve a significant hazards consideration.

l i

, . . .