ML20118A285

Proposed OL Change Request 198 to License DPR-66, Incorporating Temporary License Condition to Extend Certain TS 18-month Surveillance Intervals to Coincide W/Ninth Refueling Outage

ML20118A285
Person / Time
Site:	Beaver Valley
Issue date:	08/18/1992
From:	Sieber J DUQUESNE LIGHT CO.
To:
Shared Package
ML20118A284	List: ML20118A283 ML20118A285 ML20118A286
References
NUDOCS 9208280018
Download: ML20118A285 (6)

Text

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UNITED STATES OF AMERICA llUCLEAR REGULATORY COMMISSION In the Matter of -) UNIT NO. 1

) Docket No. 50-334 Duquesne Light Company ) License No. DPR-66 Beaver Valley power Station)

APPLICATION FCR AMENDMENT TO OPERATJ3LG_JslpENSE Pursuant to Section 50.90 of the regulations of the-U.S. Nuclear Regulatory Commission, Duquesne Light Company hereby requests that the operating license be amended to incorporate a temporary license condition that would extend certain technical specification 18-month surveillance intervals to coincide with the ninth refueling outage.

The proposed operating license change is set forth in-Attachment A to this application. A safety analysis and no sieiificant hazard evaluation is set forth in Attachment B. Typed replacement pages for ,

the operating license are included in Attachment C. Based on the guidance provided by the Commission, the proposed changes have been determined to involve no significant hazards consideration in accordance with 10 CFR 50.92.

WHEREFORE, Applicant respectfully regucats that the operating license be amended in the form attached hereto as Attachment A.

Duquesne Light Company 7

By [ ./ C -

V.D. Sieber

' ice President Nuclear Group Subscribed and sworn to before me

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I ATTACHMENT A Beaver Valley Power Station, Unit No. 1 -)

Proposed Operating License Change No. 198 LICENSE CONDITION 2.C(9)

M ; W S m w 3/"" M R + W ' / tC A -v - C J ' 11 ' l i- Add the following as License Condition 2.C(9): l ! (9) Sarveillance IntervaLExtens19D j The performance interval for those surveillance i requirements identified in the licensee's request i for surveillance interval extension dated i August 18, 1992, shall be extended to 24 months to i coincide with the cycle 9 refueling outage. i l-i 1 1 5 i } i i e 1 i" ( i l

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i i i ATTACHMENT B j Beaver Valley Power Station, Unit No. 1

Proposed Operating License Change No. 198

, CYCLE 9 SURVEILLANCE INTERVAL EXTENSION p q p w m w v a m n :g ry y m m qg A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment wou?.d extend the 18 month surveillance , interval for those surveillance requirements identified in Attachment D to coincide with completion of the ninth refueling i outage. l B. BACKGROUND i Cycle 9 was designed for a cycle length of 514 effective full j power days. This is approximately equal to 20 months of power operation with an 85% capacity factor. Cycle 9 was to begin operation in June 1991 and was expected to end in February 1993, however, do- to unexpected delays, plant operation actually began ' i in the li part of July. In addition, during the first four and a hall as of operation, the plant did not operate for six weexs due to unscheduled outages. As a result of these delays, the ninth refueling outage has been rescheduled to begin April 2, 1993. This schedule will permit optimuz fuel burnup before the next refueling outage but will result in certain technical 1 specification curveillance intervals (plus technical . specification 4.0.2 allowable extensions) expiring prior to the beginning of the 1993 cutage. C. JUSTIFICATION 4 The proposed change is temporary and allows e one time extension of specific 18 month surveillance requirements for Cycle 9 to allow surveillance testing to coincide with the nintn refueling outage. The surveillance requirements for which an extension is i required can not be performed during power operntion and would

therefore require an otherwise unnecessary plant shutdown to complete. The surveillance interval identified in Surveillance Requirement 4.4.5.3 for steam generator category C-3 inspection provides a specific time limit where the relaxation provided by Specification 4.0.2 may not apply, therefore, a surveillanct  ;

} interval extension is requested for this item. The maximum i surveillance interval increase during 'which the plant is l operating at power, will be less than three months and will not i affect the reliability established by surveillance testing i performed at the other intervals. Should an outage of sufficient , length occur prior to issuance of this amendment, DLC will  ! complete as many of the required surveillances as is practical. D. SAFETY ANALYSIS Technical Specification 4.0.2 is an administrative control which i ensures that surveillance tests are performed periodically and l 4 de fi nes a reasonable extension period for such testing. The basis of this specification Gescribes the surveillance requirements as " sufficient to ensure that the reliability l

c._ 4 i 2 '

            ' ATTACHMENT B, continued                     .                             _

j Proposed Operating License Change No. 298 ! Page' 2 i l ! associated with the surveillance activity is not significantly l degraded beyond -that obtained from the nominal specified l interval." The margin of safety. assumed by- the required l refueling surveillances may be slightly reduced by extending the j surveillance intervals. HowcVer, because the maximum-allowable

extension is limited to the end cf the refueling outage,.we have l concluded that the reliability defined by the normal surveillance

intervals (e.g., daily, weekly, monthly)- will not - be

! sianificantly reduced by the extension. This conclusion is based j on the following: i Current nonatoring of instrumentation and ongoing technical j specification surveillance tests provide assurance that.the i equipment involved in the extended surveillance tests will j remain i n' an operable condition until testing is performed i at the next refueling outage. i Periodic surveillance tests have been pctformed since the i last refueling outage to monitor system .and component , { performance and to detect any significant degradation. i surveillance testing will continue to be performed during j the requested extension interval which provides added

assurance that the reliability of equipment associated with j the extended surveillance will not be significantly degraded j by this one time extension.

i Historically, the electronic components in the reactor l , protecti,on system and engineered safety features actuation , l system have shown a very high degree of reliability. l l Section XI of the ASME Code defines a refueling interval as i 18, but no more than 24 months. Based on this definition, , [ all ISI testing, required-at refueling intervals, does not . l- have to be performed until the unit-is shutdown for the refueling outage. I This change is consistent with short term chtages granted by the- ' , NRC for other plants _(e.g., BV-2 Cycle 1) to extend the 18 month-

surveillance intervals to a refueling outage. Following the i ninth refueling outage the plant will continue to comply with the '

l 18 month-surveillance intervals for future operating cycles. The i proposed changes do not affect the UFSAR since the_ changes are t temporary and only apply for Cycle _9. .Therefore, based on the above, this change has been determined to lxa safe : ani will not veduce the safety of the plant. l I { i T i ~

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        ' ATTACHMENT B,    continued Proposed Operating License change No. 198
       ,Page 3 l         E. NO SIGNIFICANT HAZARDS EVALUATION The     no significant hazard considerations involved with the proposed amendment .have been evaluated,                      focusing on the three

standards set forth in 10 CPR 50.92(c) as quoted below

j The commission may make a final determination, pursuant to )

the procedures in paragraph 50.91, that a proposed amendment j to an operating license for a facility licensed under i paragraph 50.21(b) or paragraph 50.22 o r. for a testing j facility it.volvos no significant hazards consideration, if

operation of the facility in accordance with the proposed l

amendment would not: ! (1) Involve a significant increase in the. probability er j consequences of an accident previously evaluated; or l

(2) Create the possibility of a new or different kind ol' j accident from any accident previously evaluated; or i

j l (3) Involve a significant reduction in a margin of safety.

The following evaluation is provided for .the no significant l l hazards consideration standards, i

j 1. Does the change involve a significant increase in the probability or consequences l of an accident. previously i evaluated? l 1 ! The proposed change is temporary and i allows a'one time extension of specific la no.ith surveillance requirements for i cycle 9 to allow surveillance testing to coincide with,the- ! ninth refueling outage. The proposed surveillance interval ! extension is. short and will not cause a significant reduction in L the systems system. reliability. nor affect the' ability of to perfcrm- their design function. Current i monitoring of plant conditions and continuation of l surveillance testing required during normal' plant operation. the

will continuo to be performed

! with -technical as usual to assure conformance ! proposed change specification operability-requirements.- The l does not affect with changes granted .for other ' plants, the UFSAR and is cons'istent

change does not involva a significant therefore, this

[ probability or-increase . : bi the consequences- of an accident previ'ously l evaluated, i,- h l i l l

           ' ATTACHMENT B, continued                                                                                                                          '

Proposed Operating License Change No.-190 Page'4

2. Does the change create the possibility of a new or different kind of accident from-any accident previously evaluated?

Extending the surveillance interval for the performance of specific testing will not create the .possibilit-1 >f any new or different kind of accidents. -No change is required to any system configurations, plant. equipment or analyses. Therefore, this change will not create the possibility of a-new or different kind of accident from any accident

previously evaluated

3. Does the change involve a significant reduction in a margin

, of safety? Surveillance interval extensions 'will not-impact any-plant safety . analyses since the- assumptions used 'will remain unchanged. The safety limits assumed in .the acci, dent analyses and the design function of the equipment required to mitigate the consequences of tsy postulated accidents will not be changed since only the 18 month surveillance test interval is being extended. Extending.the-surveillence test interval for the performance of.these specific teats could slightly ceduce the margin of safety derived from required surveillances. However,. surveillance . testing l performed during normal plant operation will continued to be j performed as usual to assure conformance with the technical specification operability requirements. Therefore, the I plant will be maintained within the analyzed limits and the proposed extension will not significantly reduce.the. margin of safety. F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expreseed.above, it is concluded that the activities associated with this license amendment requent satisfies the no significant hazards consideration. standards of- ' 10 CFR 50.92(c) and, accordingly, a no significant -hazards consideration finding is justified. 1

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