ML20072S771

Application for Amend to License NPF-29,changing TS 4.7.4 & Bases Re Snubber Visual Surveillance Requirements & Ref to Common Hydraulic Fluid Reservoirs,Per Generic Ltr 90-09 Re Visual Insp of Snubbers

ML20072S771
Person / Time
Site:	Grand Gulf
Issue date:	04/10/1991
From:	Cottle W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20072S774	List: ML20072S771 ML20072S775
References
GL-90-09, GL-90-9, GNRO-91-00060, GNRO-91-60, NUDOCS 9104170065
Download: ML20072S771 (6)

Text

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is?Entcrgy

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Operations  :

W. T. Cottle I 1

April 10, 1991 U.S. Nuclear Regulatory Commission j tiall Station Pl-137 Washington, D.C. 20555 Attention: Document Control Desk l i

Subject:

Grand Gulf Nuclear Station Unit I l

Docket No. 50-416 License No. NPF-29 Implementation of Generic Letter 90-09 Recommendations 1 Regarding Snubber Inspection; Proposed Change to the  !

Operat-ing License (PCOL-91/10, Revision 0) )

GNRO-91/00060 l

l Gentlemen: I l

Entergy Operations, Inc. Is by this letter submitting a proposed change  ;

to the Grand Gulf Nuclear Station (GGNS) Operating License. The chango '

will modify Technical Specification 4.7.4 and the bases related to snubber visual surveillance requirements and references to common hydraulic fluid reservoirs.

The change is in accordance with the NRC guidance and recommendations in Generic Letter 90-09, " Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions". Entergy Operations concurs with the NRC Staff evaluation in the Generic Letter that this change w.ill maintain the same confidence level in snubber reliability as the present requirements while avoiding a significant expenditure of manpower and radiation exposure.

The change also eliminates reference to common hydraulic fluid reservoirs since there are no GGNS snubbers which utilize common reservoirs.

In accordance with the provisions of 10CFR50.4 the original of the requested amendment is attached. The attached NL-91/09 provides the technical justification and discussion to support the requested amendment. This request for amendment has been reviewed and accepted by the GGNS Plant Safety Review Committee and the Safety Review Committee.

Based on the guidelines present in 10CFR50.92, Entergy Operations has concluded that this proposed amendment involves no significant hazards.

G9104011/SNLICFLR - 1 9104170065 91041O s* PDR ADOCK 05000416 ggO/

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April 10, 1991 GNRO-91/00060 Page 2 of 3 The proposed changes to the Technical Specifications are consistent with and conform to the guidance in Generic Let ter 90-09. Because the proposed change will result in no snubber inspections in the upcoming refueling outage and a corresponding reduction in personnel exposure, we have discontinued planning for such inspections. Therefore, to ensure no adverse impact. on the refueling outage, Entergy Operations is requesting expeditious review by the GGNS NRC Project Manager on this submittal, in accordance with Generic Letter 90-09, and approval of the proposco change by July 15, 1991.

If you have any questions or desire additional information, please advise.

Yours truly, w PCscu=--

WTC/liEK/mtc attachment:

cc: Mr. D. C. Ilintz (w/a)

Mr. J. Mathis (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr.11. L. Thomas (w/o)

Mr. F. W. Titus (w/a)

Mr. Stewart D. Ebneter (w/a)

Regional Administ rator U.S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager (w/a)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop llD21 Washington, D.C. 20555 09104011/SNLICFLR - 2

. BEFORE TiiE UNITED STATES NUCLEAR REGUI.ATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN TIIE MATTER OF MISSISSIPPI POWER 6 LIGilT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and .

SOUTil MISSISSIPPI ELECTRIG POWER ASSOCI ATION and ENTERGY ODERATIONS, INC.

AEEIMAILW I, W. T. Cottle, being duly sworn, state that I am Vice President, Operationn GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Reguintory Commission, this application for amendment of the Operating I,1 cense of the Grand Gulf Nuclear Station; that I signed this application as Vice President' Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief.

c-orc u W. T. Cottle STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIED AND SWORN TO before me, a Notary Public. ,in and for the County and State above named, this _\o day of G a m h_ , 1991.

\

(SEAL) tftd bn ds nah oom Notary Publ My commission expires:

4 bdohn Tipirei Afy 1, im G9104011/SNLICFl,R - 4

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. Attachment to GNRO-91/00060 NL-91/09 Implementation of Generic Letter 90-09 Recommendations Regarding Snubber Inspectlon 1 1. SUBJECT Facility Opernting License No. NpF-29; Technical Specification 4.7.4 and Bases 3/4,7.4.

11. DISCUSSION Current Grand Gulf Nuclear Station (GGNS) snubber visual inspection requirements are based on the inimber of inoperable snobbers found during the previous visual inspection, irrespective of t he size of the snobber populatton inspected. These aquirements are excest.ively renti i< t Ive due to the lore,o numbers of snubbers installed in UGNS.

The NRC Staff has developed new gu dance on this topic in Generic Letter 90-09, " Alternative Requ i r ement s for Snubber Visun t Inspection Intervals and Correct (ve Actions" Thn Generic Letter recommends an inspectton schndule based on thn number of unacceptable snubbers found during the previous inspectton in proportion to the size of snubber populat ion or categories.

Entergy Operations has reviewed Generic Letter 90-09 for applicability to GGNS and concurs with the NRC Staf f's evaluation that t.he recommended changes in the Generic Letter will maintain thn same level of confidence in snubber operability as current snubber acceptance limits.

This GGNS change incorporates the NRC guidance and recommendations of Generic Lett er 90-09 luto the Technical Specifications and bases. While maintaining tho existing level of confidence in snubber operability, these new requirements will result in a significant rnduction in manpower resources and radiological exposure from those required to meet the currnnt requirements.

Although Generic Letter 90-09 did not specifically address basos, appropriato information for thn GGNS bases directly from the Generic Lettnr has bnen included in the proposed change for consistency and completeness.

This change will also delete reference to snubber common hydraulic fluid reservoirs since no GGNS snubbers utilize common reservoirn.

III. JUSTIFICATION As discussed above and in Generic Letter 90-09, the current snubber inspection requirements do not. include consideration of the snubbnr populction size. The proposed new requirements (and bases) for GGNS, as recommended in Generic Letter 90-09, are based on the number of unacceptable snubbers found during the previous innpoction in proportion to the size of the snubber population or categories. Thnse new requirements provide the same levnt of con f idence in snubber operability as the previous requirements, while allowing a significant reduction in manpower resources and radiological exposure from thosn required to meet the current requirements.

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7 , Attachment to GNRO 91/00060 GGNS has no anubbers which utilize common hydraulic reservoirs.

Deleting reference to this type of reservoir will therefore clarify the Technical SpocjficatJons. l I' SIGNIFICANT ilAZARDS CONSIDERATIONS

'lho proposed chango would incorporate the NRC Stnf f recommendationn J

of Generic Letter 90-09 regarding snubber visual inspect ions luto 1 GGNS Technical Specification 4.7.4 and tho-bases, and removo l reference to sinibber common hydraul.ic reservoirs.sinco no GGNS l snubbers utilizo a common reservoir.

In accordance with the requirements of 10CFR50.92, the following discussion is provided in support of the datormination that no significant hazards are crent ed or increased by the changes l proposed in this amendment request. Our conclusions are consistent  ;

1 wit h those of the NRG Staf f in Generic Letter 90-09. l

1. No significant_ increase in the prrbability or the consequences of an accident previously evaluated results from this proposed change bncause:

The changes incorporato the guidance and recommendations of Generic Lotter 90-09 into the GGNS snubber inspection program.

Entergy Operations concurs'with the NRG Staff evaluation in the Gonoric Letter that changos consistent with the Generic Lotter recommendations maintain the same confidenco level in the operability of snubbers. Thorofore, since this confidence level is unchanged, there is no signifIcant increase in the probability or the consequences of an accident previously evaluated.

Deleting raference to a snubber feature (common hydraulic reservoira) which is not- present on any GGNS anubber, is an administrativo change which will result in no significant increase in t.be probability or consequences of an accident previously evaluated.

2. This proposed change will not croato the possibility of a now or dif ferent kind of accident than any previously evaluated because:

No physical changes or now modos of operatien in any plant equipment are to bn made by this proposed change; only the snubber inspection program will be changed and referenco to a snubber,featuro not used at GGNS (common hydraulic reservoirs) is doloted. Thorofore, the possibility of a now or dif ferent kind of accident than any previously evaluated is not created.

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Attar.hment ta GNRG-91/00060 3.- This proposed chango does not involyn a significant reduction in the margin of nafety becaunot The level of confidence in the operability (i.e. , rollability) of GGNS anubbers is not af fect ed by this proposed chango, as evaluated by the NRC Staf f in Generic Letter 90-09. No other impact on the margin of safety in possible due to the nature of this chango. Thorofore, there is no significant. reduction in thn margin of safety.

' V. REFERENCES -

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1. Generic Letter 90-09, "Alternativo Requirements for-Snubber  !

Visual Inspection Intnrvals and Corrective AcLjons".

2. GGNS Technical Specificat inn 4.7.4 and 11ases 3/4.7.4.

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