ML18101A222
| ML18101A222 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/09/1994 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18101A224 | List: |
| References | |
| GL-90-09, GL-90-9, LCR-94-21, NLR-N94115, NUDOCS 9409210113 | |
| Download: ML18101A222 (9) | |
Text
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Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations SEP O 9 1994 NLR-N94115 LCR 94-21 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION REVISION OF SNUBBER VISUAL INSPECTION SCHEDULE SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 This letter submits an application for amendment to Appendix A of Facility Operating Licenses DPR-70 and DPR-75 for the Salem Generating Station Unit Nos.
1 and 2,
respectively.
The applications for amendment are being filed in accordance with 10CFR50.90.
Pursuant to the requirements of 10CFR50.91(b) (1), a copy of this request for amendment has been sent to the State of New Jersey.
The proposed Technical Specification changes contained herein represent changes to Section 3/4.7.9 "Snubbers" and the associated Bases for both Salem Uni ts.
The changes revise the visual inspection schedule for snubbers and are consistent with the guidance provided in Generic Letter (GL) 90-09.
The Salem Technical Specifications for both units currently specify a snubber inspection schedule based on the number of inoperable snubbers found during the previous inspection and limit the inspection interval to eighteen months.
As outlined in GL 90-09, the proposed schedule is based on the number of unacceptable snubbers found during the previous inspection in proportion to the size of the various snubber categories and increases the maximum inspection interval to forty-eight months.
The proposed changes have been evaluated in accordance with 10CFR50~5fi(a) *(1), using the criteria in *10CFR.50.9i(c) ~ a-rid-Lt has been determined that this request involves no significant hazards considerations.
In response to the NRC Cost Beneficial Licensing Action ( CBLA) initiative, Public Service Electric & Gas (PSE&G) met with the NRR Staff on November 12, 1993, to discuss our CBLA Program.
PSE&G considers this submittal a CBLA.
We have estimated that the 1 Gi,., (
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Document Control Desk NLR-N94115
- SEP 0 9 1994 proposed changes would yield a cost savings of $39,489 per refuel cycle per unit at Salem Unit Nos. 1 and 2.
Savings over the life of the plants are estimated to be $1,224,000.
PSE&G notes that changes similar to those proposed herein have been approved by the NRC for the New York Power Authority in an SER dated April 13, 1992.
A description of the requested amendment, supporting information and analyses for the change, and the basis for a no significant hazards consideration determination are provided in Attachment 1.
The Technical Specification pages affected by the proposed change are provided in Attachment 2 with pen and ink changes.
Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of
- issuance, but implemented within sixty days to provide sufficient time for associated administrative activities.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely,
Document Control Desk NLR-N94115 Affidavit Attachments (2)
- C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of P~ussia, PA 19406 SEP 09 1994 Mr. J. c. Stone, Senior Licensing Project Manager -
Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. C. S. Marschall (S09)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
REF: NLR-N94115 LCR 94-21 STATE OF NEW JERSEY SS.
COUNTY OF SALEM J. J. Hagan, being duly sworn according to law deposes and says:
I am Vice President Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief.
SubsLflted and Sw~o before me
.-~h-is.
- A day o plimlivc, 1994
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'---'"'" ~~ry' Pub iCOf ~~Jersey My Commission expires on KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission Expires April 21, 1998
ATTACHMENT 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION REVISION OF SNUBBER VISUAL INSPECTION SCHEDULE SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 I.
DESCRIPTION OF THE PROPOSED CHANGES NLR-N94115 LCR 94-21 This amendment revises specification 4.7.9.a regarding visual inspection of shock suppressors
( snubbers).
The change replaces the current surveillance Requirement with:
"All snubbers shall be categorized into two groups:
those accessible and those inaccessible during reactor operation.
The visual inspection interval for each category of snubbers shall be determined based upon the criteria provided in Table 4.7-3. 11 The proposed changes also add a new Table 4. 7-3 "Snubber Visual Inspection Interval" to the Technical Specifications and revise the corresponding Bases section by replacing the sentence:
"However, the results of such early inspections performed before the original required time interval has elapsed (nominal time less 25%) may not be used to lengthen the required inspection interval."
with:
"The inspections are performed for each category of snubbers.
The snubbers are categorized by accessibility (i.e., accessible or inaccessible during reactor operation).
- The next visual inspection for each category may be twice, the same, or reduced by as much as two-thirds of the previous inspection interval.
This interval depends on the -number of unacceptable. snubbers found in proportion to the total number of snubbers in each category from the.most recent inspection.
Intervals may be increased up to 48 months if few'unacceptable snubbers are found in these inspections.
The visual inspection interval will not exceed 48 months.
However, as for all. surveillance activities, unless otherwise noted, allowable tolerances of 25% are applicable
ATTACHMENT 1 REVISION OF SNUBBER VISUAL INSPECTION SCHEDULE NLR-N94115 LCR 94-21 for snubbers.
Table 4. 7-3 establishes three limits for determining the next visual inspection interval corresponding to the population of each category of snubbers.
For a category that differs from the representative sizes provided, the values for the next inspection interval may be found by interpolation from the limits provided in Columns A, B, and C.
Where the limit for unacceptable snubbers in Columns A, B, or c is determined by interpolation and includes a fractional value, the limit may be reduced to the next lower integer.
The first inspection interval determined using Table 4.7-3 shall be based upon the previous inspection interval as established by the requirements in effect before amendment (
). "
II.
REASONS FOR THE CHANGE The current Surveillance Requirements specify that subsequent visual inspections are based on the number of snubbers determined to be inoperable by the previous visual inspection.
Since this does not take into account the size of the snubber population, plants with a larger snubber population than those with a smaller number of snubbe_rs would have a
higher probability of failure and a
resulting increase in surveillances.
In Generic Letter 90-09, the NRC.concluded that the current visual inspection schedule is excessively restrictive for licensees with a large snubber population. To alleviate this situation, the NRC developed the alternative schedule which is proposed by this submittal.
III. JUSTIFICATION FOR CHANGES Snubbers are designed to prevent unrestrained pipe motion under dynamic loads as might occur* during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown.
These
- snubbers, mechanical and hydraulic, provide protection to the primary coolant system and other safety related components.
To ensure that the snubbers properly perform their intended function, they are subjected to periodic functional and visual inspections.
Functional tests verify that snubbers can operate within specific parameter limits. Visual inspections are the observation of the condition of installed snubbers to identify those that are damaged, degraded, or inoperable.
Visual examinations complement the functional testing program
ATTACHMENT 1 REVISION OF SNUBBER VISUAL INSPECTION SCHEDULE NLR-N94115 LCR 94-21 and provide additional assurance of snubber operability.
The existing surveillance interval is based on an eighteen month operating cycle and the number of inoperable snubbers found during the previous inspection, regardless of the number of snubbers in that category.
These criteria can result in excessive radiological personnel exposures and can entail a significant amount of site resources.
The proposed schedule would reduce radiological exposures and excessive resource demands, consistent with the Commission's policy statement on Technical Specification improvements, SECY-93-067.
Although the new visual inspection schedule would change the methodology used in determining the duration between visual inspections for the snubbers, the snubbers are still inspected based on the number of unacceptable snubbers.
There will be no changes to the interval for functional inspections which is based on the operating cycle.
The proposed inspection interval was developed based on an operating cycle of up to 24 months while maintaining the same confidence level in snubber operability.
The. grouping of snubbers allows each group to be inspected based on the. failure rates for that particular grouping.
Groups which fail visual* inspection can therefore be inspected more frequently without requiring all snubbers to be inspected at the same rate.
By concentrating plant resources on those snubbers which require increased visual inspection, these changes improve plant maintenance while decreasing personnel radiation exposures.
Implementation of the alternative requirements for snubber visual inspection by this submittal differs slightly from the arrangement in GL 90-0*9 (e.g. - removal of reference to TYPES of snubbers in the visual inspection specifications).
These differences are based on the submittal made by the New York Power Authority (NYPA),
dated November 15,
- 1991, and subsequently modified* during a *telecon-with the J.A.
FitzPatrick NRC Project Manager and the author of Generic Letter 90-09.
A revised application for amendment. was submitted by NYPA on March 11, 1992 and approved by the NRC in a SER dated April 13, 1992.
IV.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to 10CFR50. 92, reviewed the proposed amendment to determine whether our request involves a
significant hazards consideration.
We have determined that the operation of the Salem Units 1 and 2 Generating stations
ATTACHMENT 1 REVISION OF SNUBBER VISUAL INSPECTION SCHEDULE in accordance with the proposed changes:
NLR-N94115 LCR 94-21
- 1. Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes involve no hardware changes, no changes to the operation of snubbers, and does not change the ability of the snubbers to perform their intended functions.
Visual inspection of snubbers is a separate process that complements the functional testing program.
The NRC has concluded that functional testing of snubbers provides a 95 percent confidence level that 90 to 100 percent of the snubbers will operate within the specified acceptance limits.
Any change in the visual inspection frequency will not have any significant impact on the operability of the snubbers.
- 2. Will not create the possibility of a new or different kind of accident from any previously evaluated.
The proposed changes will not result in an unanalyzed condition.
Replacing the current method of determining visual surveillance intervals with a new method approved by the NRC in Generic Letter 90-09 will not change the level of confidence in snubber operability.
A new procedure for determining visual inspection frequencies will not result in an unreviewed failure mechanism.
- 3. Will not involve a significant reduction in a margin of safety.
The proposed changes incorporate the alternate Technical Specification requirements for visual inspection of snubbers identified in Generic Letter 90-09.
The alternate visual inspection criteria consider the size of the category of snubbers when evaluating inspection intervals due to failure rates.
Since the functional testing requirements remain unchanged* and* do not reduce the operability confidence levels, there is no resultant change in any margins of safety.
V.
CONCLUSIONS Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
\\
ATTACHMENT 2,
TECHNICAL SPECIFICATION PAGES WITH PEN AND INK CHANGES LICENSE AMENDMENT APPLICATION REVISION OF SNUBBER VISUAL INSPECTION SCHEDULE SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 NLR-N94115 LCR 94-21 The following Technical Specifications for Facility Operating License No. DPR-70 are affected by this License Amendment Request:
Technical Specification Pages 4.7.9.a 3/4 7-28 Table 4.7-3 3/4 7-32 (new)
B 3/4 4.7.9 B 3/4 7-6 and B 3/4 7-7 The following Technical Specifications for Facility Operating License No. DPR-75 are affected by this License Amendment Request:
Technical Specification Pages 4.7.9.a 3/4 7-23 Table 4.7-3 3/4 7-27 and 3/4 1-2a B 3/4 4.7.9 B 3/4 7-6 and B 3/4 7-7