ML20070F537
| ML20070F537 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/05/1991 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20070F540 | List: |
| References | |
| ET-91-0044, ET-91-44, NUDOCS 9103080345 | |
| Download: ML20070F537 (10) | |
Text
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W4) NUCLEAR OPERATING LF CREEK Fonest i Rhodes vice Preseent Engrneenno & Tectmal Services March 5, 1991 ET 91-0044 U. S. Nuclear Regulatory Cortmission ATTN:
Document Control Desk Pail Station F1-137 Vashington, D. C.
20555
Reference:
Letter dated December 11, 1990 from J. G. Partlow.
NRC to all Light-Water Reactor Licensees and Applicants
Subject:
Docket No. 50-482: Revielon to Technical Specification 4.7.8 - Snubber Visual Inspection Intervals Gentlemen:
The purpos*
this letter is to transmit an application for amendment to.
Facility Oparating License No.
NPF-42 for Wolf Creek Generating Station (WCGS) Unit No.
1.
This license amendment request proposes revising Technical Specification 4.7.8 to incorporate an alternative snubber visual inspection schedule as -provided in the Reference.
Wolf Creek Nuclear Operation Corporation (WCNOC) requests approval of this proposed amendment prior to the upcoming WCGS refueling outage scheduled to begin mid-September, 1991.
Attachment I provides a description of the amendment along with a Safety Evaluation.
Attachment II provides the Significant Hazards Consideration Determination.
Attachment III provides the Environmental Impact Determination.
The proposed change to the Tec3nical Specifications is provided as Attachment IV.
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I 9 i O'30'80 34B 91 o 305 P.O. Box 411/ Burlington, KS 66839 i Phone: (316) 304 8831 gg/
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ET 91-0044
'Page 2 of 2 In accordance with 10 CPR 50.91, a copy of this application, with attachments, is being provided to the designated Kansas State Official.
If you have any qucations concerning this matter, please contact me or Mr. H. K. Chernoff of my staff.
Very truly yours.
/
M Forrest T. Rhodes Vice President Engineering & Technical Services I
l FTR/jra Attachments:
1 - Safety Evaluation II - Significant Hazards Consideration Determination i
III - Environmental Impact Determination IV - Proposed Technical Specification Changes cci G. V. Allen (KDHE), w/a A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a M. E. Skow (NRC), w/a t
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STATE OF IANSAS
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) SS COUNTY OF COFFEY
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h Forrest T. Rhodes, of Ir,wful age, being first duly svotn upon oath says that he is Vice President Engineering and Technical services of k'olf Cretk fluelear Operating Corporations that he has rear'.- the foregoing document and knows thu content thereof that hai has executed that same for and on becalf
_ of said Corporation with full power and authority to do so and that the facts therein stated are true und correct to the best of his knowledge, information and belief.
By_
Forrest T. 7.hodes Vice President Engineering & Technical Services SUBSCRIBED and sworn to before tre thip b day of NpA.aA,1991.
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. Attachment I to ET 91-0044 Page 1 of 3
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ATTACIMENT I SAFETY EVALUATION
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. Attachment I to ET 91-0044 Page 2 of 3 Safety Evaluat'an Proposed Change The purpose of the proposed Technical Specification change is to revise Specification 4.7.8 to incorporate an alternative snubber visual inspection schedule as provided by Generic Letter 90-09,
' Alternative Requirements for Snubber Visual Inspection Inte:vals and Corrective Actions".
Background
Technical Specification 4.7.8 imposes surveillance requirements for visual snapection and functional testing of safety-related snubbers.
A visual inspection is the observation of the condition of installed snubbers to identify those that are damaged, degraded, or inoperable as caused by physical means, leakage, corrosion, or environmental exposure.
To verify that a snubber can cr.erate within specific performance limits, a
funciloral test is performed that typically involves removing the snubber antt testing it on a specifically-designed test stand.
The performance of vitual examinations is a separate process that complements the functional testing program and provides additional confidence in snubber operability.
Evaluation All snubbers are required operable to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems is maintained during and following a seismic or other event initiating dynamic loads.
The visual inspection frequency is based upon maintaining a constant level of snubber protection during an earthquake or severe transient.
Therefore, the required inspection interval varies inversely with the observed snubber failuro and is determined by the number of inoperable snubbers found during an inspection type.
In order to establish the inspection frequency for each type of snubber on a safety-related system, it was assumed that the frequency of snubber failure and initiating evento is constant with time and that the failure of any snubber could cause the system to be unprotected and to result in failure during an assumed initiating event.
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q Attachment I to 2T 91-0044 Page 3 of 3 Techn.' cal Specification 4.7.8 specifies a schedule for anubber inspections that is based on the number of inoperable snubbers found
- . 4ut the previous visual inspection.
The schedules for visual inspections and for the functional testing assume that refueling intervals will not exceed 18 months.
Because the current schedule for snubber visual inspections is based only on the number of inoperable snubbers found during the previous visual inspection, irrespective of the size of the snubber population, plants having a large number of snubbers find that the visual inspection schedule is excessively restrictive.
Some plants have spent a significant amount of resources and have subjected plant personnel to unnecessary radiological exposure to comply with the visual examination ree.uirements.
The -NRC developed an alternative inspection schedule for visual inspections that maintains the same confidence level as the existing schedule and genocally allows the performance of visual inspections and corrective actions during plant outages.
This schedule is based on the number of unacceptable snubbers found during the previous inspection in proportion to the sizes of the various snubber categories.
Because -this line-item Technical Specification improvement will reduce future occupational radiation exposure and is highly cost effective, the alternative inspection schedule is consistent with the Commission's policy statement on Technical Specification Imprevements.
Since the proposed changes do not alter the function or capabilities of existing plant equipment, these changes do not involve an increase in probability or consequences of any previously evaluated accident.
This change revises the WCGS Technical Specifications to incorporate an alternate snubber visual inspection schedule, however, no new or different types of accident is created.
Since no changes are proposed to any system operational acceptance criteria, no change in the margin of safety exists.
Therefore, the requested changes do not alter the safety design basis of WCGS or adversely effect the health and safety of the public.
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. Attachment II to ET 91-0044 Page 1 of 2 l
ATTACHKENT II SIGNIFICANT 11AZARDS CONSIDERATION DETERMINATION l
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, Attachment-II to ET 91-0044 Page 2 of 2 Significant Hazards Consideration Determination The proposed change would revise Technical Specification 4.7.8 to incorporate an alternative snubber visual inspection schedule as provided by t
Gcneric Letter. 90-09.
The following sections-discuss the inspection schedule proposed change under the three standards of 10 CFR 50.92.
Standard l'- Involves a
Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
The proposed change to the snubber visual inspection schedule does not involve a significant-increase in -the probability or consequences of an accident previously evaluated.
This change provides. an alternative inspection'..hedule for visual inspections that maintains the same
'4 confidence level as the existing schedule and generally allows the performance of visual inspections and corrective actions during plant outages.
This-change-does not appreciably impact the reliability or
. availability of plant equipment.
Standard 2 -. Create the Possibility of a New of Different Kind of Accident frem any-Previously Evaluated.
The proposed change to'the snubber visual. inspection schedule does not create the possibility of a new of different kind of accident from any previously_ evaluated.
The proposed change does not alter the method and manner of plant operations.
It permits an inspection schedule based cm the number of. unacceptable snubbers found during the previous inspection in proportion to-the sizes of the various snubber categories.
Standard 3~- Involve a Significant Reduction in.the Margin of Safety.
The proposed change to the snubber visual inspection schedule does not involve a'significant reduction in a margin of-safety.
The change does not affect any Technical Specification margin of safety and it maintains :he same confidence level as the existing schedule.
Based upon the above discussions it has been determined that the. requested
. Technical-Specification ~ revision does not involve a significant increase in the probtaility or consequences of an accident or other -adverse condition over previous evaluations; or create the possibilityEof a new or different kind of accident or condition over previous-evaluations; or involve a significant reduction in a margin of safety.
.The requested license amendment does not involve a significant hazards consideration.
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.Attschm:nt III to ET 91-0044 Page 1 of 2 ATTACIMENT III ENVIRONMENTAL IMPACT DETERMINATION
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, Attachment III to ET 91-0044 Page 2 of 2 Environmental Impact Determination 10 'CFR 51.22(b) specifies the criteria for-categorical exclusions from the requirement for a specific environmental. assessment per 10 CFR 51.21.
This amendment request meets the criteria specified in 10 CFP. 51.22(c)(9).
Specific criteria contained in this section are discussed below.
(1) the-amendment involves no significant hazards consideration As demonstrated in the Significant Hazards Consideration Determination in Attachment II, the requested license amendment does not involve any significant hazards considerations.
(ii)- there is no significant change in the types or significant increase in the amounts of any effluents that may be release offsite.
The requested license amendment involves no change to the facility or operating procedures which would cause an increase in the amounts of effluents or create new types of effluents.
(iii) there is no significant increase in individual or cumulative occupational radiation exposure The proposed change does not impact plant design-features or operations that affect radiation protection, radioactive effluent processing, radioactive waste handling, or radiological environmental monitor.
The proposed change will reduce future ' occupational radiation exposure by allowing increased inspection intervals.
s Based on the above, it is. concluded that there will be no -_ impact on the environment resulting from this change and the change meets the criteria specified-in.10 CFR 51.22 for a categorical exclusion.from the requirements of,10: CFR. 51.21 relative to specific environmental assessment by the Commission.
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