ML20059C498

TS Change 346 to Licenses DPR-33,DPR-52 & DPR-68, Incorporating Recommendations for Snubber Visual Insp Intervals Contained in GL 90-09, Alternative Requirements for Snubber Visual Insp Intervals & Corrective Actions

ML20059C498
Person / Time
Site:	Browns Ferry
Issue date:	12/23/1993
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18037A636	List: ML18037A635 ML20059C498
References
GL-90-09, GL-90-9, TVA-BFN-TS-346, NUDOCS 9401050278
Download: ML20059C498 (15)

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Tennessee Va iey Aunah. Pod OMce BoWA Deuk AMea Ms DEC 2 31993 TVA-BFN-TS-346 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNB FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

TECHNICAL SPECIFICATION (TS).NO. 346 - ALTERNATIVE REQUIREMENTS FOR SNUBBER VISUAL INSPECTION INTERVALS AND CORRECTIVE ACTIONS - REQUEST FOR REVIEW AND APPROVAL OF COST BENEFICIAL LICENSING ACTION RLA-04 In accordance with the provisions of 10 CFR.50.4 and 50.90, TVA is submitting a request for an amendment (TS-346) to licenses DPR-33, DPR-52, and DPR-68 to change the TSs for Units 1, 2, and 3. The proposed change incorporates the recommendations for snubber visual inspection intervals contained in Generic Letter 90-09, " Alternative. Requirements for Snubber Visual Inspection Intervals and Corrective Actions." TVA proposes that the TS requirements.for visual inspection of safety-related snubbers be revised to. increase the allowable interval between visual inspections _provided the snubbers are operating at or above a prescribed-level _of dependability. This change to the visual inspection schedule 3000ao%

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L U.S. Nuclear Regulatory Commission Page 2 DEC 2 31993 will_ provide the same confidence level of snubber operability as the existing schedule with the potential for reducing resource demands and unnecessary occupational radiological exposure.

TVA has determined that there are no significant hazards considerations associated with the proposed change and that the change is exempt from environmental review pursuant to 10 CFR 51.22 (c) (9) . The Browns Ferry Plant Operations Review Committee and the Browns Ferry Nuclear Safety Review Board have reviewed this proposed change and determined.that operation of BFN Units 1, 2, and 3 in accordance with the proposed change will not endanger the health.and safety of the public. Additionally, in accordance with 10 CFR

50. 91(b) (1) , TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health.

Enclosure 1 to this letter provides the description and evaluation of the proposed change. Enclosure 2 contains copies of the appropriate TS pages from Units 1, 2, and 3 marked-up to show the proposed change. Enclosure 3 forwards the revised TS pages for Units 1, 2, and 3 which incorporate the proposed change.

TVA requests NRC review and approval of TS-346 as a cost beneficial licensing action. Enclosure 4 (RLA-04) provides a description of the proposed change which includes the requested NRC licensing action, the basis for the request, and justification for higher priority NRC review.

Additionally, TVA requests NRC review and approval of this TS amendment by May 1, 1994. This date is necessary in order-to support resource planning and allocation-for the Unit 2-Cycle.7 refueling outage which is scheduled to begin on-October 1, 1994. TVA feels that the requested _ review and approval time is consistent with_similar Generic Letter 90-09 TS change requests performed by the staff for other utilities. If NRC is unable to support the above date,.TVA requests early notification so that an alternate date can be negotiated with the staff that will provide for implementation of the proposed TS change prior to the outage.

This is similar to a previous request, negotiated with the staff, for review and approval of BFN TS-332, Frequency of Emergency Diesel Generator Inspections. TVA also requests that the revised TS be made effective within 30 days of NRC cpproval.

U.S. Nuclear Regulatory Commission Page 3 DEC 2 31993 If you have any questions about this change, please telephone me at (205) 729-2636.

Sincerely,)

l - )l l W Pe a as Manager of Site Licensing Enclosures cc: See page 3 Subscribed and sworn to before me on this 'A ] day of h la1993.

kh n , % . . nQx ~ ,a Notary Public My Commission Expires N\\DY\8 y

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I U.S. Nuclear Regulatory Commission Page 4 DEC 2 31993 -  :

cc (Enclosures): '

American Nuclear Insurers Town Center, Suite 300S 29 South Main Street  :

West Hartford, Connecticut 06107-2445 Mr. W. D. Arndt General Electric Company 735 Broad Street >

Suite 804, James Building Chattanooga, Tennessee 37402 Mr. Johnny Black, Chairman  !

Limestone County Commission 3 310 Washington Street.

Athens, Alabama 35611 ,

Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region II ,

101 Marietta Street, NW, Suite 2900 Atlanta, Georgia. 30323 .

NRC Resident Inspector Browns Ferry Nuclear Plant i Route 12, Box 637 Athens, Alabama 35611 Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer State Department of Public Health ~t State Office Building Montgomery, Alabama 36194 I

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-l ENCLOSURE 1 .

L TENNESSEE VALLEY AUTHORITY. 'b BROWNS FERRY-NUCLEAR. PLANT'(BFN) j UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CRANGE'TS-346 i l

DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE- ~l I. DESCRIPTION OF~THE PROPOSED CHANGE The proposed change would revise the BFN. Units 1, 2, and 3 j

TS by providing an alternate visual inspection schedule for safety-related snubbers following the recommendations '

1 of NRC Generic Letter _(GL) 90-09, " Alternative .

Requirements for Snubber Visual Inspection Intervals.and-Corrective Actions," dated = December 11, 1990. The '

alternate visual inspection schedule is based on'the number of unacceptable snubbers.found during the previous .

inspection, and.the size of the snubber population or  !

categories.and provides the same' operability confidence '!

level.as the existing schedule. The1 alternate inspection '

interval is based on a fuel cycle of up.to 24 months and may be as long as two fuel cycles, or 48 months depending ,

on the number of unacceptable snubbers found during the previous visual inspection. -Additionally, the proposed- .

change will~ reduce occupational radiological exposure-to.

plant personnel and generally allow'BFN to perform visual inspections and corrective actions during plant outages. R In addition to the changes described above, certain editorial and terminology changes have-been made throughout TS 3.6.H/4.6.H and the' associated bases to  ;

provide consistency between affected: sections incorporating the changes recommended by GL 90-09'and those sections not directly affected. The specific' .:

changes are provided below: )

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1. For Units 1, 2, and 3, TS Section 3.6.H, delete  ;

specific reference to Browns Ferry (BF) Surveillance: l Instructions (SI) BF SI 4.6.H-l'and BF?SI-4.6.H-2 and refer only to " Plant Surveillance Instructions.".

The revised TS Section 3.6.H reads: ,

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snubbers shall be. OPERABLE except as 1 noted in 3.6.H.1. 'All safety-related -j snubbers'are listed'in Plant ]

Surveillance Instructions ~.

2. For Units 1,.2, and 3, TS Section 4.6.H, delete specific reference to BF SI 4.6.H-l'and BF SI 4.6.H-2 and refer only to " Plant Surveillance Instructions."

The revised TS Section 4.6.H reads:

Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 3.6.H/4.6.H. These snubbers are listed in Plant Surveillance Instructions.

3. For Units 1, 2, and 3, TS Section 4.6.H.1, delete entire secticn regarding " Inspection Groups" and replace with GL 90-09 recommendations.

The revised TS Section 4.6.H.1 reads:

Inspection Types As used in this specification, " type of snubber" shall mean snubbers of the same design and manufacturer, irrespective of capacity.

4. For Units 1, 2, and 3, TS Section 4.6.H.2, delete entire section regarding " Visual Inspection, Schedule.

and Lot Size" and replace with GL 90-09 recommendations.

The revised TS Section 4.6.H.2 reads:

Visual Inspections Snubbers are categorized as inaccessible or accessible during-reactor operation. Each of these categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.H-1. The. visual inspection interval'for each typelof snubber shall '

be determined based upon the criteria provided in '

Table 4.6.H-1 and the first. inspection interval determined using this criteria.shall be based upon the previous inspection interval as established by the requirements in effect before amendment (*) .

• NRC will include the number of the license amendment that -

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5. For Units 1, 2, and 3 add Table 4.6.H-1, " Snubber s Visual Inspection Interval," which incorporates the recommendations in GL 90-09.

TABLE 4.6.H-1 SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS l Population Column A Column B Column C-  ;

or Category Extend Interval Repeat Interval Reduce Interval ,

(Notes 1 and 2) (Notes 3 and 6) (Notes 4 and 6) (Notes 5 and 6) 1 0 0 1 80 0 0 2 100 0 1 4 150 0 3 8=

200 2 5 13 300 5 12 25 400 8 18 36 500 12 24 48 750 20 40 78 1000 or rnore 29 56 109.

Note 1: The next visualinspection interval for a snubber population or category size shall be determined based upon the previous inspection interval and the number.of unacceptable snubbers found during that interval. Snubbers may be categorized, based upon their accessibility during power operation, as accessible or inaccessible. .These categories may be examined separately or jointly. However, the licensee must make and document that decision before any inspection and shall use that decision as the basis upon which to determine the next inspection interval for that category.

Note 2: Interpolation between population or category sizes and the number of unacceptable -

snubbers is permissible. Use next lower integer for the value of the limit for Columns A, B, or C if that integer includes a fractional value of unacceptable snubbers as determined by interpolation.

i Note 3: if the number of unacceptable snubbers is equal to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.

Note 4: If the number of unacceptable snubbers is equal to or less than the number in column B but greater than the number in Column A, the next inspection interval shall be the same as the previous interval.

Note 5: If the number of unacceptable snubbers is equal to or greater than the number in Column j C, the next inspection interval shall be two-thirds of the previous interval. However, if the -

number of unacceptable snubbers is less than the number in Column C but greater than the number in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the ratio of l the difference between the number of unacceptable snubbers found during the previous- l interval and the number in Column B to the differences in the numbers in Columns B and l C. .l Note 6: The provisions of Specification 1.0.LL are applicable for all inspection intervals up to and including 48 months.

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6. For Units 1, 2, and 3, TS Section 4.6.H.3,. delete l section regarding " Visual Inspection Performance and i Evaluation" and replace with GL 90-09 recommendations. It should be noted that the -l criteria regarding transient event inspections was j not deleted from 4.5.H.3 and is shown in paragraph .)

two of the revised 4.6.H.3.

I The revised TS Section 4.6.H.3 reads:

Visual Inspection Acceptance Criteria Visual inspections shall verify that'(1) ,

the snubber has no visible indications of-  :

damage or impaired OPERABILITY, (2) attachments to the foundation or i supporting structure are functional, and  !

(3) fasteners for the attachment of the j snubber to the component and to the i snubber anchorage are functional'.

Snubbers which. appear inoperable'as a result of visual inspections shall be  ;

classified unacceptable and may be l reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that -(1)' the cause of the rejection is clearly established and remedied for that particular snubber and

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for other snubbers irrespective of type that may be generically susceptible; and (2) the affected snubber is functionally  ;

tested in the as-found condition and determined OPERABLE per Specification 4.6.H.S. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable  ;

snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS FOR OPERATION shall be met.

Additionally, snubbers attached to sections of ,

safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for 'l the possibility of concealed damage and functionally tested, if applicable, to confirm l OPERABILITY. Snubbers that have been made inoperable as the result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.H.7.and 4.6.H.8 have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval.

7. For Units 1, 2, and 3, TS Section 4.6.H.4, first paragraph, replace the word " group" with the word

" type". Also, in the second paragraph, first sentence, replace the word " groups" with the word

" types."

The revised TS Section 4.6.H.4 (first paragraph and second paragraph first sentence) reads:

During each refueling cutage, a representative sample of 10% of the total of each type of safety-related snubber in use in the plant shall be functionally tested either in place or in a bench test.

The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size and.

capacity of snubbers within the types.

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8. For Units 1, 2, and 3, TS Section 4.6.H.6, in the -

fourth sentence replace the word " group" with the word " type". Also in the fifth sentence replace the words " inspection group" with the words " functional test type."

The revised TS Section 4.6.H.6 (fourth and fifth sentences) reads: ,

For'each snubber that does not meet the FUNCTIONAL TEST acceptance criteria, an  :

additional lot equal to 10 percent of the remainder of that type of snubbers shall  ;

be functionally tested. Testing shall continue until no additional inoperable snuobers are found within subsequent lots  !

or all snubbers of the original functional  !

test type have been tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.

9. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H,  !

" Snubbers," fourth paragraph, fifth sentence, add ,

the word " visual" between the words " thorough" and

" inspection."

The revised sentence reads:  ;

A thorough' visual inspection of the snubber threaded attachments to the pipe or components and the anchorage will be made in conjunction with all required FUNCTIONAL TESTS.

10. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H,

" Snubbers," sixth paragraph, delete the second sentence in its entirety.

The deleted sentence reads:

Thus, the required inspection interval varies  ;

inversely with the observed snubber failures.

11. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H,

" Snubbers," seventh paragraph, first sentence, delete  ;

the words " exempted from being counted" and replace '

with " reclassified." Also, in the same sentence, change the word " inoperable" to " operable."

The revised TS bases sentence reads:

When the cause of the rejection of a snubber in a visual inspection is clearly i

established and remedied-for that snubber.

and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicable, that snubber may be reclassified as operable.

12. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H,

" Snubbers," seventh paragraph, third, fourth and fifth sentences, replace the words " groups," " group,"

and " groupings" with the words " types" and " type" as appropriate.

The revised TS bases sentences read:

Inspection types may be established based on design features, and installed conditions which may be expected to be generic. Each of these inspection types is inspected and tested separately-unless an engineering analysis indicates _the inspection type is improperly constituted. All suspect. snubbers are aubject to inspection and testing regardless cf inspection type.

II. REASON FOR THE PROPOSED CHANGE ,

The proposed amendment requests changes to the Browns i Ferry Technical Specifications in response to GL 90-09, ,

" Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions." The generic letter' ,

describes line-item Technical Specification improvements developed by the NRC Staff to allevi. ate problems being l encountered with the current Standard Technical Specifications snubber visual inspection requirements.

Improvements described in GL 90-09 provide an alternate schedule for visual inspection of snubbers that maintains the same confidence level for identifying defective snubbers'as the existing schedule.

Implementing the proposed changes will reduce future occupational radiological exposure and will generally allow the snubber visual inspection and corrective actions to be performed during plant outages. ' Additionally, the .

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implementation of the proposed alternative snubber visual inspection schedule'will allow for less frequent' snubber inspections provided the results of ongoing inspections. ,

are favorable.

Also, certain editorial changes have been made in the proposed amendment to provide consistency between affected sections incorporating the changes recommended by GL 90-09 and those sections not directly affected.  !

TVA is also proposing to remove reference to the specific Plant sis that list the BFN safety-related snubbers and refer only to " Plant Surveillance Instructions."

III. SAFETY ANALYSIS t i

The proposed alternate snubber visual inspection schedule would allow BFN to extend snubber visual inspection ,

intervals (in accordance with GL 90-09) without reducing the confidence level provided.by the existing visual inspection schedule. As previously discussed, verification that a snubber can operate within specified-performance limits is provided by functional testing.

This testing provides a 95 percent' confidence level that at least 90 percent to 100 percent of the snubbers operate ,

within.specified. performance limits. The-performance of visual inspections is a separate process that complements the functional testing program and provides additional confidence in snubber operability. Therefore, revising the schedule for snubber visual inspections, using the guidance'provided in GL 90-09, does not reduce the confidence level associated with snubber operability. As a result, a significant amount of resources could be saved and a substantial reduction in occupational radiological exposure could be realized.

BFN is also proposing certain editorial and terminology changes to TS Section 3.6.H/4.6.H and.the associated bases-to provide consistency between affected sections incorporating the changes recommended by GL 90-09 and those sections not directly affected. These changes ,

include removal of the specific plant SI references and substitution of the term " type" for " group" in the TS '

sections and bases describing functional testing.

The proposed change would also remove a sentence in the TS '

bases which states that the visual inspection frequency

" . . . varies inversely with the observed snubber '

failures." This statement would not be an accurate '

description of the inspection interval proposed by GL 90-09 and is therefore deleted.

The statement in Section 4.7.9.c of' Enclosure B to GL 90-09 regarding snubbers connected to an inoperable common hydraulic fluid reservoir was not included in the proposed amendment because snubbers of this type are not '

installed at Browns Ferry.

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 in accordance with the proposed change to the technical specifications, regarding alternate snubber visual inspection intervals, does not-involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a)(1), of the three standards set forth in 10 CFR50.92(c).

1. The proposed amendment does not involve a sicnificant increase in the probability or conseauences of an accident previously evaluated.  !

Implementing the guidance specified in GL 90-09 will  !

not introduce any new failure mode and will not alter any assumptions previously made in evaluating the consequences of an accident. The proposed alternate schedule for visual inspections will maintain the same operability confidence level as.the existing ,

schedule. Also, the surveillance requirement and  ;

schedule for snubber functional testing remains the same providing a 95 percent confidence' level that 90 .;

percent to 100 percent of the snubbers operate within l the specified acceptance limits. The proposed visual inspection schedule is separate from functional testing and provides additional confidence that the installed snubbers will serve their design function and are being maintained operable. The proposed ,

changes do not affect limiting safety system settings or operating parameters, and do not modify or add any accident initiating events or parameterr. Therefore, j the proposed change does not significantly increase ,

the probability or consequences of an accident  :

previously evaluated.

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2. The Droposed amendment does not' create the . i Dossibility of a new or different kind of accident ' '

from any accident Dreviousiv evaluated.- g r

Implementing the recommendations specified in  ;

GL 90-09 does not involve any physical alterations,to- o plant equipment, changes to setpoints or operating '

parameters, nor does it involve any potential  !

accident initiating event. As stated in the' generic l letter, the alternate schedule for' snubber visual  !

inspections. maintains the same confidence level as- _!

the existing schedule. Additionally, functional l testing of snubbers provides a 95 percent confidence level that 90 percent to 100 percent of the snubbers-  !

operate within specified acceptance limits. Since ,

this TS change does not physically alter the plant >

equipment and the snubber confidence level remains the same there will not be any new.or different accident resulting from snubber failure from any L accident previously evaluated.

3. The DroDosed amendment does not involve a siGnificant' reduction in a margin of safety, i The proposed change incorporates the surveillance  !

requirements for snubber visual inspection-intervals  ??

following the. guidance provided in GL 90-09. As ~  !!

stated in the generic letter, the' proposed snubber visual inspection interval maintains the same >

confidence level as the existing snutber visual inspection interval. This surveillance requirement ,

does not alter the current Limiting Condition for  !

Operation or the' accompanying actions for the t snubber (s). The requirement for functional testing l of safety-related snubbers is unchanged and remains  ;

the basis for the established margin of safety and j j

assures a 95 percent confidence level that 90 percent to 100 percent of the snubbers operate within the '

specified acceptance limits. This functional testing  :

along with the proposed visual inspection intervals

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j provides adequate assurance _that the snubber will l perform its intended function. .Therefore, the i proposed changes do not involve a significant l reduction in a margin of safety. l

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V. ENVIRONMENTAL IMPACT CONSIDERATION The-proposed change does not invol a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluent that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed change meets the eligibility i criteria for categorical exclusion set-forth in 10 CFR

51. 2 2 (c) (9) . Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed-change is not required.

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