ML022040057

License Amendment Request Relocation of Shock Suppressors (Snubbers) Requirements as Described in Technical Specification 3/4.6.I to Updated Final Safety Analysis Report

ML022040057
Person / Time
Site:	Pilgrim
Issue date:	07/05/2002
From:	Dugger C Entergy Nuclear Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.02.050
Download: ML022040057 (18)

Text

- Entergy Entergy Nuclear Generation Company Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Charles M. Dugger Vice President - Operations July 5, 2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35

REFERENCE:

LETTER NUMBER:

Dear Sir or Madam:

License Amendment Request Relocation of Shock Suppressors (Snubbers) Requirements As Described in Technical Specification 3/4.6.1 to Updated Final Safety Analysis Report NUREG 1433, Standard Technical Specifications for General Electric Plants, BWR/4.

2.02.050 Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) hereby proposes to amend the Pilgrim Station Facility Operating License, DPR-35. This proposed license amendment would relocate the "Primary System Boundary - Shock Suppressors (Snubbers)", Technical Specifications (TS) 3/4.6.1, from the TS to the Updated Final Safety Analysis Report. The affected TS contain snubber operability and surveillance requirements. This change is consistent with Standard Technical Specifications (NUREG 1433, Revision 2) and changes previously approved by the NRC for other reactor licensees. ENO has reviewed the proposed amendment in accordance with 10 CFR 50.92 and concludes it does not involve a significant hazards consideration.

ENO requests approval of the proposed amendment by March 1, 2003 to support Pilgrim's plans for snubber inspections in the upcoming refueling outage (scheduled to commence on April 19, 2003). Once approved, the amendment will be implemented within 60 days.

202050

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.02.050 Page 2 If you have any questions or require additional information, please contact Bryan Ford at (508) 830-8403.

Sincerely, Charles M. Dugger I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th day of July 2002.

Enclosure:

Attachments: 1.

2.

Evaluation of the Proposed Changes - 6 pages Proposed Technical Specification Changes (mark-up) - 4 pages List of Regulatory Commitments - 1 page 202050

Entergy Nuclear Operations, Inc.

Letter Number: 2.02.050 Pilgrim Nuclear Power Station Page 3 cc:

Mr. Travis Tate, Project Manager Office of Nuclear Reactor Regulation Mail Stop: 0-8B-1 U.S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Pilgrim Nuclear Power Station Mr. Steve McGrail, Director Mass. Emergency Management Agency 400 Worcester Road P.O. Box 1496 Framingham, MA 01702 Mr. Robert Hallisey Radiation Control Program Commonwealth of Massachusetts Exec Offices of Health & Human Services 174 Portland Street Boston, MA 02114 202050

Letter 2.02.050 Enclosure Page 1 of 6 ENCLOSURE Evaluation Of The Proposed Changes

Subject:

Relocation of Shock Suppressors (Snubbers) Requirements as Described in Technical Specification 3/4.6.1 to Updated Final Safety Analysis Report (UFSAR)

1.

DESCRIPTION

2.

PROPOSED CHANGES

3.

BACKGROUND

4.

TECHNICAL ANALYSIS

5.

REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration

6.

ENVIRONMENTAL CONSIDERATION

7.

REFERENCES 202050

Letter 2.02.050 Enclosure Page 2 of 6

1.

Description This letter is a request to amend Operating License DPR-35 for Pilgrim Nuclear Power Station.

The proposed change would revise the Operating License to relocate the Technical Specification (TS) requirements for shock suppressors (snubbers) from the TS to the Updated Final Safety Analysis Report (UFSAR). The proposed change will allow Entergy Nuclear Operations, Inc. (ENO) to revise snubber requirements in accordance with 10 CFR 50.59 without requiring a License Amendment. ENO requests approval of the proposed amendment by March 1, 2003 to support Pilgrim's plans for snubber inspections in the upcoming refueling outage (scheduled to commence on April 19, 2003).

2.

Proposed Change TS Section 3/4.6.1 provides actions for functionality and surveillance requirements to verify the operability of safety-related snubbers. It is proposed that the current requirements of "Primary System Boundary - Shock Suppressors (Snubbers)", TS 3/4.6.1 and their associated Bases be removed from the TS and relocated in their entirety to the UFSAR.

In summary, this proposed license amendment would relocate snubber operability and surveillance requirements contained in TS 3/4.6.1 and their associated Bases from the TS to the UFSAR. This change is consistent with Standard TS, General Electric Plants, BWR/4, (NUREG-1 433, Revision 2) and changes previously approved by the NRC for other reactor licensees.

3.

Background

Snubbers are devices used to prevent unrestrained pipe motion under dynamic loads as might occur during an earthquake or severe transient. The restraining action of the snubbers ensures that the initiating event does not propagate to other parts of the affected system or to other safety systems. Snubbers also allow normal thermal expansion of piping to eliminate excessive thermal stresses during startup and shutdown.

The consequence of an inoperable snubber is an increase in the probability of structural damage to piping as a result of a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect the primary coolant system and all other safety related systems or components be operable during reactor operation.

Requirements of Pilgrim's current TSs provide actions for functionality and surveillance requirements to verify the operability of safety-related snubbers. The current action for an inoperable snubber is to replace or return the snubber to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and perform an engineering evaluation of the attached component. The supported system is declared inoperable if the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> expires or the evaluation indicates that the system is inoperable. The current surveillances provide requirements for an augmented in-service inspection program including visual and functional tests. This program also contains program allowances for inspection interval, lot size, inspection evaluation, lot composition, acceptance criteria, failure analysis, attached component analysis, service life and exceptions from visual or functional tests.

Current TS Bases discussions contain the basis for requiring snubbers, the basis for the allowed snubber outage time, and clarifications regarding the application of the snubber surveillance requirements.

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Letter 2.02.050 Enclosure Page 3 of 6 Relocating TS 3/4.6.1 to the UFSAR will allow revisions to the snubber requirements in accordance with 10 CFR 50.59 without requiring a license amendment. Any change of the relocated specifications in the UFSAR will be strictly controlled in accordance with the provisions of 10 CFR 50.59.

This relocation request is similar to those granted to other operating reactor licensees (References 3 and 4).

4.

Technical Analysis Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include the TSs as part of the license. The Commission's regulatory requirements related to the content for the TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in eight specific categories. The categories are (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.

However, the regulation does not specify the particular requirements to be included in a plant's TSs.

The Commission amended 10 CFR 50.36 (60 FR 36593, July 19, 1995), and codified four criteria to be used in determining whether a particular matter is required to be included in a limiting condition for operation (LCO), as follows: (1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes that failure of, or presents a challenge to, the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier; or (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. LCOs and related requirements that fall within or satisfy any of the criteria in the regulation must be retained in the TSs, while those requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. Pilgrim's UFSAR is one such licensee-controlled document.

The proposed changes are consistent with the Standard TS for General Electric plants (NUREG-1433) and 10 CFR 50.36. NUREG-1433 does not include requirements for verification of snubber operability and the criteria in 10 CFR 50.36 for features required to be retained in TSs do not apply to the snubbers at Pilgrim as discussed below. The NRC's Final Policy Statement recommends that TSs that do not meet the screening criteria for retention may be relocated to a licensee-controlled document. The four criteria of 10 CFR 50.36 are addressed below:

(1)

The snubbers are not installed instrumentation nor do they have the ability to detect abnormal degradation of the reactor coolant pressure boundary. Therefore, the Pilgrim snubbers do not satisfy Criterion 1.

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Letter 2.02.050 Enclosure Page 4 of 6 (2)

Snubbers are design features used to prevent unrestrained pipe motion under dynamic loads as might occur during an earthquake or severe transient. However, the snubbers are not explicitly considered in the accident analysis and are not considered a required initial condition for a design basis accident or transient to maintain the integrity of a fission product barrier. The effects of an inoperable snubber are controlled by the Technical Specification requirements of the supported system. The availability of the snubbers is assured based on the performance of periodic inspections and testing.

Therefore, the Pilgrim snubbers do not satisfy Criterion 2.

(3)

Safety-related snubbers are design features that function during accidents or severe transients to prevent the propagation of an event to systems that are part of the primary success path for accident mitigation. However, snubbers are not explicitly considered in the accident analysis, but are a structural design feature whose operation is assured by an inspection program. The snubbers are not a primary success path for accident mitigation; therefore they do not satisfy Criterion 3.

(4)

Operating experiences or probabilistic safety assessments have not shown snubber parameters to be significant to public health and safety. Therefore, the snubbers do not satisfy Criterion 4.

The snubber requirements will be relocated to the UFSAR. Any changes to these requirements will be strictly controlled under the provisions of 10 CFR 50.59. Therefore, the relocation of the snubber specifications from the TSs to the UFSAR will continue to provide adequate assurance that functionality and testing of the snubbers will be assured.

In conclusion, the above relocated requirements are not required to be in the TS under 10 CFR 50.36 or section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

In addition, sufficient regulatory controls exist under 10 CFR 50.59 to assure continued protection of public health and safety.

5.

Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. is proposing to relocate Pilgrim's Primary System Boundary - Shock Suppressors (Snubbers) as described in Technical Specification 3/4.6.1 to the UFSAR.

Entergy Nuclear Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The proposed change is administrative in nature and does not involve the modification of any plant equipment or affect basic plant operation.

Snubbers are not assumed to be an initiator of any analyzed event, nor are they assumed in the mitigation of consequences of accidents.

202050

Letter 2.02.050 Enclosure Page 5 of 6 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated

2.

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

Response: No. The proposed change does not involve any physical alteration of plant equipment and does not change the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged.

The methods governing plant operation and testing remain consistent with current safety analysis assumptions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No. The proposed change is administrative in nature, does not negate any existing requirement, and does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by requirements that are retained, but relocated from the Technical Specifications to the UFSAR. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy Nuclear Operations, Inc. concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

6.

Environmental Consideration A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the proposed amendment.

202050

Letter 2.02.050 Enclosure Page 6 of 6

7.

References

1.

10 CFR 50.36

2.

NUREG-1433,"Standard Technical Specifications, General Electric Plants, BWR/4"

3.

Sequoyah Nuclear Plants, Units 1 and 2, Amendment Nos. 235 and 225, 8/28/98

4.

South Texas Project, Units 1 and 2, Amendment Nos. 109 and 96, 5/17/99 Note: References 3 and 4 relocated the TS for snubbers to each plant's Technical Requirements Manual (TRM) to be controlled in accordance with 10 CFR 50.59. Since Pilgrim does not have a TRM, the relocated specifications and bases will be relocated to the UFSAR. The difference between these identified precedents and the proposed amendment does not affect acceptability of the proposed amendment.

202050

ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

L.L" MTING CONDITIONS FOR OPERATION SnVEILIANCE REIREMENTS 3.6 PRIMARY SYSTEM BOUNDARY (Cont) 4.6 PRIMARY SYSTEM BOUNDARY (Cont)

I.

Shock Suppressors (Snubbers)

I.

Shock Suppressors (Snubbers)

1. During all modes of op ation The following surveillance except Cold Shutdown.ind requirements apply to all safety Refuel, all safety-related related hydraulic and mechanical snubbers listed/in PNPS snubbers listed in PNPS Procedures shall be operable Procedures.

except as n9.ted in 3.6.1.2 through 3.,611.3 below.

The required visual spection interval varies i ersely with the An Inoperable Snubber is a observed cumula ve number of propdrly fabricated, installed inoperable s bers found during andi sized snubber which cannot an inspectr

n.

Inspections ass its functional test.

performe before that interval has elapse may be used as a new Upon determination that a refei~encepitodtrmnth refrene point to determine the snubber is either improperly ne~t inspection.

However, the S/fabricated, installed or sized, results of such early inspections the corrective action will be performed before the original time as specified for an inoperable I

interval has elapsed may not be snubber in Section 3.6.1.2.

used to lengthen the required

2.

From and after the time that, interval.

snubber is determined to be Number of snubbers found inoperable, replace or repair inoperable during inspection or the snubber during theý next 72 during inspection interval:

hours, and initiatein engineering evaluation to Inoperable Subsequent Visual determine if the" components I

c V a supported by the snubber(s) were adversely affected by the 1

18 Months 25%

inoperaiflity of the snubbers and t*/ensure that the 2

12 Months

+/- 25%

suppdorted component remains 3,7 6

oh

+/- 25%

c~a~ble of meeting its intended on in 8,9 62 ays

+/- 25%

/',function in the specific safety 10 or more Days

+/- 25%

system involved.

\\/

Further corrective action for The re ired inspection interval this snubber, and all shal not be lengthened more than generically susceptible 0

step at a time.

snubbers, shall be determined S

ma i

by an engineering evaluation.

gnubs maysbe or

\\

/

~

~~groups, "accessible",-or "inaccessible" based on their accessibility for inspection during reactor operation.

These two groups may be inspected independently according to the above schedule.

Revision L1j7 Amendment No.

2O-69..

-I§I 3/4.6-9

/

LIMITING CONDITIONS FOR OPERATION SURVETI EANCE REQUIREMENTS 3.6 PRIMARY SYSTEM BOUNDARY (Cant)

X

.6 PRIMARY SYSTEM BO'UNDARY (Cont)\\"ý I.

fShock Suppressors (Snubbers)

I.

Shock Suppressors (Snubbers)

\\

(Cont)

(Cont)

3.

From and after the time i

1.

Visual Inspection Acceptance snubber is determined7,,6 be Criteria inoperable, impropej.J'y 71 fA.

Visual inspections shall verify:

installed or improperly sized,

1. That there are no visible if the requir9 ents of indications of damage or Section(s).6.1.l and 3.6.1.2 impaired operability.

cannot bb et then the 4

adlecte, sarety system, or

2. Attachments to the foundation affected portions of that or support structure are such sys'em, shall be declared that the functional capability J

i,0operable, and the limiting of the snubber is not sus ect.

I condition for that system entered, as appropriate.

B.

Snubbers which avppeai:NOPERABLE as a result of visaIlil inspections Snubbers may be added to, or may be determied OPERABLE for the removed from, per IOCFR50.59, purpose of tablishing the next safety related systems without visual iEpection interval prior NRC approval. The provide-that:

addition or deletion of i

is snubbers shall be reported to e cause of the rejection is RC in accordance with J -

shed7 L'.L.L anda 10CFR50.59.

remedied for that particular lCR"5 snubber, and x

2.

The affected snubber is functionally tested, when necessary, in the as found condition and determined OPERABLE per specifications 4.6.I.2.B.,

4.6.I.2.C.,

as applicable.

C.

For any snubber determined inoperable per specification 4.6.1.2, clearly establish e

cause of rejection and medy the problem for that snubber, and any generically susce ible snubber.

2.

Functional T ts (Hydraulic and Mechanical.nubbers A.

Schedule "At"least once per operating cycle, representative sample (12.5% of o////,//the'total of each type:

Revision Amendment No.

297-6g9-93,-1. 5 J/

4.

0 - lu Z

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT 3.6 PRIMARY SYSTEM BOUNDARY (,ont) 46 PRIMARY SYSTEM BOUNDARY (Gout)

I.

Shock Suppressors (Snubbers)

/

(Cont) hydraulic, mechanical) of snubbers in use in the plant shall be functionally tested, either in place or in a bench test.

For each snubber that does not et the functional test acce ance criteria of Specific ion 4.6.I.2.B, or 4.6

.2.C, as applicable, an dditional 10% of fntoathat type snubber shall be functio oay tested.

/i B.

Ge al Snubber Functional Test c peptance Criteria (Hydraulic and Mechanical)

\\

The general snubber functional S,.z test shall verify that:

z*

I. Activation (restraining action) is achieved within the SA" specified range of velocity or acceleration in both tension and compression.

2.

Snubber release, or bleedrate, as applicable, where required A

is within the specified ra e

in compression or tens' For snubbers specificajl.required not to displace 'der continuous loa',

the ability of the snub be-to withstand load withouA'displacement shall be verified.

C.

,Mchanical Snubbers Functional

."Test Acceptance Criteria The mechanical snubber functional test shall verify that:

Revision3/4.6-11 Amiendmnent o. 2OT-497-697-1517-53 3461

1

/

/

7 7-LIMITING CONDITIONS FOR OPERATION 3.6 PRIMARY SYSTEM BOUNDARY (Cont)

Z.

7 z

7/

7/

/"

is less than the specified maximum drag force.

3.

Snubber Service Life Monitoring A.

A record of the service life of each snubber, the date at which the designated service life commences and the installation andl maintenance records on which the designated service life is based shall be maintained.

B.

At least once per cle, the installation a maintenance records for*a~ch safety related snub ber s t.ed in PNPS Procedures se reviewed to verify that tindicae~d serv~ice life has not

/*been exceeded or will not be exceeded prior to the next scheduled snubber service life review.

If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated, or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

This reevaluatio <,**

replacement or recon t bning shall be indicar n the records.

s elTh i s S n u b b eber v i c e L i f ef e

sonitori Program shall become ehfe c ye July 1, 1982.l f

C Revision 77 7

Amendment 0o. 297-49-607 3/4.6-12 SURVEILLANCG, IQUIREMENTS 4ýý6 RIMARY SYSTEM BOUNDARY (Cont)

Shock Suppressors (Snubbers)

(Cont)

1. The force that initiates fr4 movement of the snubber rod either tension or compressic ee in Dn

BASES:

3/4.6 PRIMARY SYSTEM BOUNDARY (Cont)

G.

Structural Integrity The Pilgrim Nuclear Power Station Inservice Inspection Program conforms to the requirements of IOCFR50.55a(g). Where practical, the inspection of ASME Section XI Class 1, 2, and 3 components conforms to the edition and addenda of Section XI of the ASME Boiler and Pressure Vessel Code required by 10CFR50.55a(g). When implementation of an ASME Code required inspe6tion has been determined to be impractical for PNPS, a request for relief from the inspection requirement is submitted to the NRC in accordance with 1 OCFR50.55a(g)(5)(iii).

Requests for relief from the ASME Code inspection requirements will be submitted to the NRC prior to the beginning of each 10 year inspection interval for which the inspection requirement is known to be impractical. Requests for relief from inspection requirements which are identified to be impractical during the course of the inspection interval will be reported to the NRC on an annual basis throughout the inspection interval.

1.

Shock Suppressors (Snubbers)

Snubbers are designed to prevent uny estrained pipe motion under dynamic loads as might occur during an earthquake or seve transient, while allowing normal thermal motion during startup and shutdown. The co 1s equence of an inoperable snubber is an increase in the probability of structural damage to piping as a result of a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect the primary coolant system and all.o-6her safety related systems or components be operable during reactor peration.

he visual ins pYction frequency is based on maintaining a constant levJ snubber protection to systems. The cumulative number of inoperable snubbe-r detected during any inspection interval is the basis for establishment of the subsequri1linspection interval and the existing inspection interval should remain in effect until its cpn1pletion.

,When the cause of the rejection of a snubber is clearly established and remedied for that

' snubber and verified by inservice functional testir"gfthat snubber may be exempted from being counted as inoperable.

Z Generically susceptible snubbers are those which are of a specific make or model an e

the same design features directly related to rejection of the snubber by visual insp.Pontn, and are exposed to the same enviropnental conditions such as temperature, radiaiefi, and vibration.

When a snubber is found inoperable, an engineering evaluation is ijri ated, in addition to the determination of the snubber mode of failure, in order to determi Ie if any safety-related component or system has been adversely affected by the in erability of the snubber.

Initiating this evaluation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ensures that prp*mpt corrective action will be afforded.

.7z Revision(ndment N-B Amendment No. 19, 9337-114721-B3/4.6-1 I

BASES:

3/4.6 PRIMARY SYSTEM BOUNDARY (Cont)

I.

Shock Suppressors (Snubbers)

(Cont)

Hydraulic snubbers and mechanical'snubbers may each be treated as a different entity for the above surveilkince programs.

The service life of a nubber is evaluated via manufacturer input and information throughj-i-consideration of the snubber service conditions and associated instal1iation and maintenance records (newly installed

snubber, seal-,

replaced, spring replaced, in high radiation area, in high temperature areýa, etc.).

The.irequirement to monitor the snubber service life is included,-to ensure that the snubbers periodically undergo a performance evaluation'in view of their age and operating conditions.

These records will provi ef statistical bases for future consideration of snubber service life.

Thexrequirements for Xtl-le maintenance of records and the snubber service life revlýew are not intended to affect plant operation.

Due to the numberand complexity of the relevant interacting factors necessary to develop acomprehensive Service Life Program, this program shall become effective July1, 1982.

Revision 177 Amendment No. 2§-g;-6-93;T-!3 B3/4.6-12

ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS

List of Regulatory Commitments The following table identifies those actions committed to by Entergy Nuclear Operations, Inc. in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE Relocate Technical Specifications 3/4.6.1 Within 60 days of receipt of NRC approval of the and associated Bases to UFSAR.

change.