ML20070S499

Application for Amends to Licenses NPF-68 & NPF-81,changing Tech Specs 4.7.8b & 4.7.8c to Revise Surveillance Requirements for Visual Insp of Snubbers,Per Generic Ltr 90-09

ML20070S499
Person / Time
Site:	Vogtle
Issue date:	03/29/1991
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20070S503	List: ML20070S499 ML20070S505
References
GL-90-09, GL-90-9, MSV-00446, MSV-446, NUDOCS 9104020310
Download: ML20070S499 (6)

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r-Georg'a Power Company j

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40 inverren Center Pwkway "

Post Ofke Box 1295 Birrrrngham Alabama 35?O1 Tdeotone 205 877 7122 C. K. McCoy Vce Preutent. Nuclem GeorgiaPower Vogtle Project Ite sout/Myn e'wltc system -

MSV-00446

1. 1465 Docket Nos. 50-424  :

50-425

-V Nuclear Regulatory Commission I ATTM -Document-Control Desk i Washington, D. C'. 20555 Gentlemen:

V0GTLE ELECTRIC GENERATING PLANT REQUEST-TO REVISE TECHNICAL-SPECIFICATIONS

'4.7.8b AND A.7.8c

'In accordance with tne provisions of 10 CFR 50.90 and'10 CFR 50.59, Gsorgia Power Company hereby proposes to amend thetVogtle Electric Generating Pl.7nt (VEGP), Unit 1 'and Unit 2 Technical Specifications, Appendix 4. to.0perating Licenses -NPF-68 and NPF 81 The pro)osed-amendment-'would revise the surveillance requirements relative to tie visual inspection of snubbers..

Specifically, the visual inspection schedule (Specification 4.7.8b) and-the -

visual inspection acccptance criteria (Specification 4'.7.8c) -would be revised to be consistent with the discussion, in NRC GenericLletter 90-09,  ;

" Alternative. Requirements for snubber Visual' Inspection Intervals And-Corrective : Actions," dated December 11, 1990. Further,:the' Bases section of Specification 3/4.7.8 relative :to snubbers and the Index would be -

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-revised to- reflect _the- proposed change to Technical Specifications. The' '

proposed change and its basis are described in

Enclosure:

1. Our evaluation pursuant to 10 CFR 50.92 showing that the proposed change does -not involve significant hazards considerations- is- -provided in Enclosure ' : 2.

Instructions for incorport:. tion of the proposed change into the Technical -t

-Specifications 2.nd- revised pages:are provided in Enclosure 3.-

Georgia' Power Company requests-approval =of the proposed amendment by June ,

14, 19917 in . order to support planning / scheduling activities associated with the third VEGP-1 maintenance / refueling outage scheduled to begin in-September 1991.

In accordance with 10 CFR 50.91, the designated-state-cfficial will- be senti copy of this lecter and all enclosures.

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V. S. Nuclear Regulatory Commission MSV-00446 Page Two Mr. C. K. McCoy states that he is a Vice President of Georgic Power Company and is authorized to execute this oath on behalf of Georgia Power Company and that, to the best of his knowledge and belief, the facts set forth in this letter are true.

Georgia Power Company By: ,, .

. McCoy,

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Sworn to and subscribed before me this c2 7 day of 2f'/4d[/ 1991.

E am hb o'aryfublic CKM/JAE/jr

Enclosures:

1. Basis for Proposed Change

2. -10 CFR 50.92 Evaluation

3. Instructions for Incorporation e(w): Georaia Power Comoe n Mr. S. H. Chesnut Mr. P. D. Rushton Mr. W. B. Shipman Mr. L. A Ward N09.MS U. S. Huclear Reaulate"y Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manag" . NRR-Mr. B. R. Bonser, Senier Resi< lent Insps. tor, Vogtle _l State of Georgiq Mr. J. D. Tanner, Commissiorer, Department of Natural Resources a

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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT-kEQUEST TO REVISE TECHNICAL SPECIFICATIONS 4.7.8b AND 4.7.8c BASIS FOR PRCPOSED CHANGE Pr. goosed Chanae The Vogtle Unit 1 and Unit 2 Technical Specifications % the visual inspection of snubbers and the a:ceptance criteria there/or (Technical Specifications 4.7.8b and 4.7.8c) are preo wd to be revised as follows:

1. Revise the surveillance requirements of Specification 4.7.8b to' utilize an alternate inspection schedule as discussed in NRC Generic Letter 90-09, " Alternative Requirements for Snubber Visual Inspection Intervals And Corrective Actions," dated December 11, 1990.

Specifically, the subject Specification is revised to reference Table 4.7-2 which is added to th_e Technical Specifications by this proposed change and provides the necessary criteria for determining the snubber visual inspection interval. Further,' Specification 4.7.8b is revised' to note that the first ins)ection interval will be_ determined us' s the criteria provided in Ta)le 4.7-2 and -is based upon the previous  !

inspection interval. as established _by.the requirements in effect before issuance of the Technical Specification amendments which will-implement the proposed change for the Vogtle units. Per Enclosurc 8 toi NRC Generic letter 90-09, the- NRC is to add the appropriate license amendment number (s) to the text of Specification 4.7.8b. The-proposed change is consistent with that discussed in'NRC Generic Letter 90-09..

2. Revise the surveillance requirements of Specif. cation 4.7.8c which concerns snubber visual inspection acceptance criteria. Specifically, the subject specification is revised to address the reclassification of i unacceptable snubbers as acceptable snubbers provided that certain i i* criteria-which currently exist in Specification 4.7.8c are met. 'The term "other snubbers" in Criteria concerning reclassiTication of snubbers with regard to acceptability is being clarified.to indicate that any type of snubber is meant. Further, the requirement concerning hydraulic snubbers found connected to an inoperable common hydraulic fluid reservoir is revised to indicate that _the snubber shall be counted as unacceptable and may be reclassified as acceptable for determining the next visual inspection interval provided that certain criteria which. currently exist in Specification - 4.7.8c are met.

Requirements for the review of the unacceptable snubber, evaluation-therefor, documentation to justify any continued-' operation, an_d' action.

requirements should continued operation not be justified are added.

The proposed change is consistent _with NRC Generic Letter 90-09 except:-

-that minor wording changes, e.g., use of the word " category" vice 3- " type", have been incorporated base:1 on a discussion between othar utility personnel and NRC; staff omonnel. The minor wording changes were made in order to clarify the intent of Enclosure B to'NRC Generic Letter.90-09.

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s ENCLOSURE 1 (CONTINUED)

RE0llEST TO REVISi TECHNICAL SPECIFICATIONi 4.7.8b AND 4.7.8c BASIS FOR PROPQSED CHANGE

3. Add Table 4.7-2 which provides the criteria for determining the snubber visual inspection interval to Specification 3/4.7.8.

4. Revise the Bases for Specification 3/4.7.8 to reflect the proposed-snubber visual inspection schedule and -visual inspection acceptance criteria. Comparisons between the existing inspection schedule and the proposed inspection schedule are included as well as the basis for each.

5, Revise the Index to reflect the addition of Table 4.7-2, " Snubber Visual Inspection Interval," which provides the necessary criteria for determining the snubber visual-inspection interval.

Basis Technical Specifications impose surveillance requirements for visual inspection and functional testing of all.srcLbers. The only snubbers excluded from these requirements are those irMalled on nonsafety-related systems and then only if their failure or failure of the : system on which they are installed would have no adverse effect on arty safety-related system. A visual inspection is the observation of the condition of Installed snubbers to identify -those that are damaged,_ degraded, or inoperable as a result of physical means., . leakage, corrosion, or environmental exposure. Functional testing .is performed to verify that a snubber can oporate within specific performance limits and provides -a 05 percent confidence level that 90 to 100 percent.of the snubbers operate  ;

within specified acceptance limits. Me performance of visual- examinations '

is a separate inspection that supplements the functional testing orogram and provides additional confidence in snubber operability.

The current Technical Specifications. specify'a schedule for' snubber visual.

inspections that is based on the number of inoperable snubbers found during the previous visual inspection, irrespective of the size of-the snibber population.- Generally, the existing -Technical -Specification requirements establish visual inspection intervals of_18 months '(the length of a nominal fuel cycle) or a fraction thereof; based on the number of' inoperable snubbers of each type for the )revious' inspection. ' Plants having a large numbei of snubbers have found t1at the extsting visual-inspection schedule is excessively restrictive. Significant resources,. including subjecting plant personnel to unnecessary radiological exposure, have been expended'in ordar to comply with the visual inspection requirer ents.

United States Nuclear Regulatory Commissica (NRC) Generic Letter-90-09,.

"Alterciative Requiremente. For Snubber Visual Inspection Intervals And' t,orrective Actions," dated December 11, 1990 discussos an alternate l

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e ENCLOSURE 1 (CONTINUED)

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-REQUEST TO REVISE TECHNICAL SPECIFICATI0NSL4.7.8b AND 4.7.8c.

.DASIS FOR PROPOSED CHANGE y

schedule for visual ins)ection meant to o alleviate the situation discussed  !

above. The alternate scledule.is intended to replace the existing- schedule- j for visual inspections and maintains .the same confidence-level as the '

existing schedule. It' is based on the: number-of unacce) table: snubbers i found during the inspection in_ proportion to tie sizes - of< the various snubber - populations previous or categories.- It also- allows inspection-l intervals- to be compatible with a 24-month. fuel cycle. Benefits from the '

alternate schedule include reductioni of future occupational radiation-exposure and better cost effectiveness.

The alternate . method for determining the.next interval for the Lvisual- i inspection of snubbers is_ provided based upon the number of unacceptable .

snubbers found during -the previous inspection,1the total population or-  !

category. size for each snubber type, and-the. previous inspection interval.

Snubbers may-be categorized, based upon their accessibility:during power operation, as accessible aor inaccessible. These categories may be examined-separately or jointly. Categorization of: snubbers as - accessible. or inaccessible ~ and inspection thereof must be madefand documented prior to

- any inspection-and that decision will- constitute the basis;for-determining  :

the next inspection interval-for that category.-

• A snubber is considered unacceptable if it. fails to satisfy -the acceptance criteria of _the - visual ' inspection. lShould= review Land: evaluation 1 not-justify continued operation with an unacceptable: snubber, the snubberf shall be declared . inoperable and the _ applicable actioneraquirements shall be met. q To determine -the-next surveillance interval,: an unacceptable snubber may be- 1 reclassified as- acceptable ~ if it can be demonstrated thati the' snubber is' "

operable in its as-found .conditioniby the performance of -ae functionalLtest- ~,

and if. it satisfies the acceptance criteriaLfor-functional testing.

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The next visual inspection interval may be twice, the:same. or r'duced to T

as much as-two-thirds of the-previous _ ins)ection-interval.: This interval? ,

depends on the number of unacceptable: snub)ers found.in proportion:to.the

_ size of the population or category, for cach~ type of snubber / included:in the previous inspection. The interval may bel 1.ncreased to every other-7 refueling outage for plants on a 24-month fuel cycle.or up to 48 months for plants with other fuel cycles if few unacceptable snubbers were found from the previous inspection. Limits for detormining the next: visual inspection interval = -have been established and are -consistent with those discussed in NRC_ Generic Letter 90-09.

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ENCLOSURE 2 l L

V0GTLE ELECTRIC GENERATING PLANT REQUEST TO REVI3E TECHNICAL SPECIFICATIONS 4.7.8b AND 4.7.8c-10 CFR 50,RRUATION Pursuant to 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the proposed amendment and has- determined that operation of the facility. in accordance with the proposed amendment would not involve _a significant hazards consideration. Tne basis for this determination is as follows:

1. The 3roposed change does not involve a significant-increase in the-

probaaility or consequences

of an accident previously evaluated. -The proposed change involves the requirements-that -ensure the operability-of snubbers is maintained through visual, as well as- functional, testing. Operation of the plant under-the provisions of the proposed amendment will continue to ensure that snubber operability -is- y

'echnical Specification requirements.for visual inspection maintaineo, will continue - '

met but on a schedule based on the number of ,

unacceptable snubiars found during the previous inspection- in~  !

proportion to the size - of various snubber populations or categories  !

vice the number- of unacceptable snubbers:found during the. previous

!_ inspection, irrespective of-the size of the~ snubber population. The alternate inspection schedule: - for - the visual . inspection -of snubbers i maintains the same confidence - level as :the existing schedule.

Therefore, the-probability or consequences of any accident previously evaluated will _ not be affected. -

2. The proposed change does not create the. possibil'ity.of.. a new -or different kind of accident from any accident previously evaluated. The-change does not introduce any new equipment into the plant.or require any existing equipment to be operated in a manner different than that-in which it was designed to be operated._ Snubber operabil.ity. will continue to be maintained under-the_ proposed surveillancearequirements-by visual, as well as- functional,- testing, ,

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3. The proposed change does not involve'a significant reduction'.in the L'

margin of safety. Snubber operability will -continue'~to be maintained through visual = inspection and functional-testing. The alternate visual inspection schedule - proposed by .~this_ change maintains the. same confidence level of snubber operability- as the existing schedule and

! replaces it'. Based on the'toregoing, there will be no reduction in the l margin 'of safety.

Based. on the' preceding analysis, .GPC has determined that .the proposed change to .the Technical Specifications will not significantly increase the' probability or consequences of any accident 'previously evaluated, create the possib_il_ity of 'a new or different kind of accident from any previously evaluated, or involve a significant reductioniin -a margin. of safety.

Therefore,-GPC_ concludesthat-the proposed change' meets the requirements of.-

10 CFR 50.92(c) and does.not: involve a significant hazards consideration.

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