ML18065B181
| ML18065B181 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/13/1998 |
| From: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-90-09, GL-90-9, NUDOCS 9803240191 | |
| Download: ML18065B181 (4) | |
Text
A CMS Energy Company March 13, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Tel: 616 764 2276 Fax: 616 764 2490 Nathan L. Haskell Director, Licensing REQUEST FOR APPROVAL OF REVISED SNUBBER RELIEF REQUEST NO.. 1
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On January 17, 1996, Consumers Energy submitted a Snubber Relief Request.:*,lhat relief request sought NRC approval to use the Generic Letter (GL) 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions/'.and<<the Technical Specifications (TS) instead of ASME OMa-1988, Part 4. On June2'8; 1996, the NRC approved the Snubber Relief Request but stated that the visual examination acceptance criteria of ASME OMa-1988, Part 4 should be used in conjunction with TS 4.16.1. This letter requests approval of a revision to the previously approved Snubber Relief Request.
On September 3, 1997, Consumers Energy submitted a Technical Specifications Change Request (TSCR) to remove the snubber inspection, testing, and operability requirements from the Technical Specifications. The Technical Specifications requirements were interpreted to be unnecessary since 10 CFR 50.55a specified the use of ASME OMa-1988, Part 4. A revised Snubber Relief Request was included with that :scR submittal in order to delete reference to the Technical Specifications A-.J 'f "1---
requirements.
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- The NRR Palisades Project Manager and the TSCR technical reviewer advised that, while 10 CFR 50.55a does require inservice inspection of snubbers in accordance with the ASME Code, it does not require licensees to perform snubber testing. *Therefore, the TSCR previously submitted on September 3, 1997, is being revised and resubmitted separately, to "relocate" the snubber inspection and testing re*q'iiitenie'rits to the Palisades Operating Requirements Manual (ORM).
98032401911 980313
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2 A new revision to the Snubber Relief Request is needed to coordinate with the proposed change to the TS. The revised relief request will allow implementation of inspection requirements contained in ASME OMa-1996, Subsection ISTD. Because Subsection ISTD contains the same requirements as those previously contained in GL 90-09, there will be no change to our snubber inspection program. This new relief request revision will align the snubber inspection requirements to the same code edition the NRC has proposed to be permitted for snubber testing (62 FR 63893). The new relief request revision, identified as Snubber Relief Request No. 1, is attached.
Consumers Energy requests approval of revised Snubber Relief Request No. 1 in order to support the currently scheduled 1998 refuelif!g outage, starting April 24, 1998. The September 3, 1997, Snubber Relief Request and the associated TSCR have been the subject of review by the NRC un<;Jer TAC No. M99656. The approval of Snubber Relief Request No. 1 should be coincident with the approval of the revised TSCR, being submitted separately.
SUMMARY
OF COMMITMENTS This letter contains no riew commitments and no revisions to existing commitments.
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than L. Haskell rector, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment
ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REVISED SNUBBER RELIEF REQUEST NUMBER 1 1 Page
SNUBBER RELIEF REQUEST BASIS NUMBER 1 CODE CLASSES: Various COMPONENTS:
Snubbers as listed below CLASS:
1, 2, and 3 FUNCTION:
Snubbers (shock suppressors) prevent the unrestrained movement of safety-related components (including piping) during an earthquake or severe transient to prevent failure of the restrained component or adjacent safety-related equipment.
EXAMINATION REQUIREMENTS:
. The 1989 edition of ASME Section XI, Subsection IWF-5300 states, "lnservice examinations (of snubbers) shall be performed in accordance with the first Addenda to ASME/ANSI OM-1987, Part 4 (published in 1988), using the VT-3 visual examination method described in IWA-2213."
ALTERNATIVE REQUIREMENTS:
As an alternative, ASME OMa-1996, Subsection ISTD examination requirements will be used in lieu of those contained in ASME OMa-1988 (ASME/ANSI OM-1987), Part 4.
BASIS FOR RELIEF:
ASME OMa-1996, Subsection ISTD contains the scheduling interval provisions originally outlined in Generic Letter 90-09, "Alternative requirements for Snubber Visual Inspection Intervals and Corrective Actions." The NRC staff developed GL 90-09 to provide an alternate schedule for visual inspections. These interval guidelines were approved for use at Palisades as documented in Docket 50-255, dated June 13, 1992 and Technical Specification Amendment Number 164, dated April 20, 1995. Adoption of ASME OMa-1996, Subsection ISTD for snubber examination will therefore provide the same acceptable level of safety and quality as those contained in current plant examination r~quirements and GL 90-09.
JUSTIFICATION:
The proposed alternative provides for 100% visual examination of the snubber population and for a decrease in the examination frequency (increase in the examination interval) in the event that no unacceptable snubbers are found. If one or more unacceptable snubbers are found during visual examination, the next examination interval shall be 2/3 of the previous interval. Occupational radiation exposure will be reduced by performing examinations during outages and potentially at a reduced frequency.