ML20078D154

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Safety Evaluation Supporting Amend 68 to License NPF-58
ML20078D154
Person / Time
Site: Perry 
Issue date: 01/20/1995
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20078D121 List:
References
NUDOCS 9501270289
Download: ML20078D154 (3)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 68 TO FACILITY OPERATING LICENSE NO. NPF-58 TIIE CLEVELAND ELECTRIC ILLUMINATING COMPANY. ET AL.

PERRY NUCLEAR POWER PLANT. UNIT NO. I DOCKG NO. 50-440

1.0 INTRODUCTION

By letter dated September 19, 1994, the Cleveland Electric Illuminating Company, et al. (licensees), proposed changes to the Technical Specifications (TSs) for the Perry Nuclear Power Plant, Unit No.1.

The proposed changes involve TS 3/4.7.4, " Snubbers," and its bases. The proposed changes provide alternative requirements for snubbers based on the guidance contained in NRC Generic Letter (GL) 90-09, " Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions," dated December 11, 1990.

By Telecon of December 12, 1994, the licensee (R. Cook) requested NRC (J.

Hopkins) that the two footnotes on the bottom of TS page 3/4 7-9 also be deleted. This change is administrative in nature, and does not significantly change the application as noticed in the Federal Reaister, and does not change the staff's evaluation of the application. Therefore, the application is not being renoticed.

2.0 EVALUATION Technical Specifications impose surveillance requirements for visual inspection and functional testing of all 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 operate within specific performance limits, the licensees perform functional testing that typically involves removing the snubber and testing it on a specially-designed test stand.

Functional testing provides a 95 percent confidence level that 90 to 100 percent of the snubbers operate within the specified acceptance limits. The performance of visual examinations is a separate process that complements the functional testing program and provides additional confidence in snubber operability.

Existing schedules for snubber visual inspections are based only on the number of inoperable snubbers found during the praious visual inspection, irrespective of the size of the snubber population.

Licensees having a large i

number of snubbers find that the visual inspection schedule to be excessive.

Some licensees have spent a significant amount of resources, and have subjected plant personnel to unnecessary radiological exposure to comply with

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the visual examination schedule.

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The alternate inspection schedule contained in GL 90-09 is based on the number of unacceptable snubbers found during the previous inspection, in proportion i

to the sizes of the various snubbers' populations or categories.

The staff stated in GL 90-09, that the alternate schedule for visual inspections maintains the same confidence level as the existing schedule and generally will allow the licensee to perform visual inspections and corrective actions during plant outages. This will redcce future occupational radiation exposure.

The requested amendment differs slightly from the model TS contained in GL 90-03, in that the initial inspection period is proposed to be 18 months from

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the last visual snubber inspection, in order to perform the next inspection during its next refueling outage. The model TS would have the next inspection of inaccessible snubbers 12 months from the last inspection, based on initially using the old inspection schedule and on finding one inoperable snubber, which would result in a mid-cycle shutdown. Based on the model TS, the next inspection of accessible snubbers would be 6 months from the last inspection based on initially using the old inspection schedule, and on finding two inoperable snubbers. ine three inoperable snubbers have had corrective action taken to make them operable.

Perry has a total of approximately 1200 snubbers divided fairly, evenly between accessible and inoccessible. Previously, except for the first and most recent visual inspection, Perry performed visual inspections based on their inspection plan, which was a 10 percent sample of snubbers.

Converting to the GL 90-09 inspection criteria is an improvement over the 10 percent sample inspection plan. Also, a total of three inoperable snubbers out of 1200 snubbers is not a large percentage, and does not warrant a mid-cycle shutdown.

Lastly, an 18-month interval is commensurate with the future inspection schedule.

Therefore, the NRC staff finds that the initial visual inspection interval of 18 months is acceptable.

The NRC staff has reviewed the licensee's proposed TS changes and finds that except as discussed above, they are consistent with the guidance contained in GL 90-09. Therefore, the license amendment is acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment.

The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding i

' (59 FR 53843). Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

5.0 CONCLUSION

t The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such l

activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: J. Hopkins Date:

January 20, 1995 i

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