ML20086A705

Application for Amend to License DPR-16.Amend Would Eliminate Requirement to Perform Reactor Shutdown & Drywell Solely for Purpose of Inspecting Snubbers in Svc for Only 12 Months

ML20086A705
Person / Time
Site:	Oyster Creek
Issue date:	06/26/1995
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20086A699	List: ML20086A697 ML20086A705 ML20086A716
References
NUDOCS 9507050017
Download: ML20086A705 (8)

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OYSTER CREEK NUCLEAR GENERATING STATION OPERATING LICENSB NO. DPR-16 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 227 DOCKET NO. 50-219 Applicant submits by this Technical Specification Change Request No. 227 to the Oyster Creek Nuclear Generating Station Technical Specifications, modified pages 4.5-9,4.5-15, and new pages 4.5-18 and 4.5-19. )

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lohti J. htton Vice President and Director Oyster Creek Sworn to and Subscribed before me this Qlr day of h 1995.

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l cm a-A Motary Public of New Jersey Notary Public of New MyCommiselon EW D / M b P O O 9507050017 950626 PDR ADOCK 05000219 P PDR

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. l OYSTER CREEK NUCLEAR GENERATING STATION OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 227 l Applicant hereby requests the Conunission to change Appendix A of the above-captioned license as follows:

1. Sections to be Changed:

l A. Section 4.5.Q.a.; Snubber Visual Inspection Surveillance Interval  :

B. Section 4.5; Bases

2. Extent of Change: i i

A Revises the snubber visual inspection intervals to match the schedule developed by the NRC staff for use with a 24 month refueling interval. This schedule was ,

documented in Generic Letter 90-09.

B. Revises the bases for the snubber visual inspection interval to be consistent with the bases described in Generic Ixtter 90-09. ,

3. Chance Requestrd; The specific requested changes are contained on the attached " CHANGED PAGES" section -

of this document.  !

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4. Discussign; 1 During the recent 15R refueling outage, one snubber failed a scheduled sisual inspection. l This failure was located on the main steamline. An engineering evaluation was performed j as per Technical Specifications which detennined that no damage had occurred on any j component protected by the snubber. The failed snubber was replaced with a new snubber. This snubber was in service since 1977..  ;

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. i C321-95-2085 Attachment I Page 2 There were thirteen additional snubbers on the main steamline. Eleven of these were replaced and two were tested satisfactorily and reinstalled (one was originally installed in 1988 and the other in 1993).

The sample size for mechanical snubber visual inspections was 100% as required by technical specifications. The sample size for mechanical snubber functional inspections was increased from 10% to 42% since one functional failure was found on the other main steamline and subsequently was replaced. This snubber was in service since 1977.

It was determined that the causes of the snubber failures were sustained high temperatures and high frequency vibration for an extended length of service. The high temperature caused the snubber grease to degrade, whereupon the extended high frequency vibration caused excessive wear. The snubbers had been in service since 1977.

The existing Techriical Specification would require a reactor shutdown and drywell entry one year into the opemting cycle solely for the purpose of perfonning an inspection on the snubbers which were replaced or reinstalled on the main steam system in 15R. The purpose of this change request is to amend the technical specifications to not require the reactor shutdown, and update the Technical Specification requirements to those previously approved l in Generic Letter 90-09.

The exact wording of GL 90-09 has been utilized to the greatest extent practical. However, minor changes have been requested to allow for the design specifics of the Oyster Creek i Plant. Each change from the prescribed wording in GL 90-09 is discussed and evaluated l separately.  !

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C321-95-2085 -

Attachment i Page 3 OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TEC11NICAL SPECIFICATION CilANGE REQUEST NO. 227 Pursuant to 10CFR50.91, this Technical Specification Change Request has been determined to contain No Significant Hazards as required by 10CFR50.91. These evaluations are specified in 10CFR50.92.

The changes requested have been separated into two groupings: those which reflect the verbatim wording in GL 90-09; and those which have been specifically changed for the Oyster Creek Nuclear Generating Station.

1. Changes requested from the precise wording contained in Generic Letter 90-09:

This request has been determined to involve No Significant flazards in that it does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated;(or)

The proposed change does not affect the probability of occurrence nor does it affect the caesequences of an accident pn:viously evaluated as the requested visual inspection interval has been determined generically to be a safe and acceptable alternative to the existing visual inspection requirements as documented by the NRC in Generic Letter 90-09. With the completion of over 25 years of operating experience and only detecting one visual inspection failure, GPU Nuclear agrees that the existing intervals are overly conservative and can be extended to those described in the generic letter.

1 (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; (or)

As the requested change deals only with the frequency of visual inspection and not  ;

with the content, scope, or acceptance criteria of the inspection, nu new or different type of accident has been created.

(3) Involve a significant reduction in the margin of safety; The margin of safety as defined in the bases of the Technical Specifications is not reduced as the reqaested requirements provide the same degree of confidence in l snubber operability as the existing requirements.

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C321-95-2085 Attachment i Page 4 u 11. Plant Specific wording changes not contained in Generic Letter 90-09:

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j A. Section 4.5.Q.1 GL 90-09 wording: "... performance of the following augmented j inservice inspection program in addition to the requirements of 4.0.5."

TSCR 227 wording: ... performance of the following inspection program."

Reason for.the change: Oyster Creek controls the inspection and testing of the snubbers in the Technical Specifications and not in the Augmented inservice Testing Program. Further, Section 4.0.5 referenced in the Generic Letter states in Section e "Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specification."

This request has been determined to involve No Significant Hazards in that it does not: l (1) Involve a significant increase in the probability or consequences of an accident j previously evaluated;(or)

The snubber inspection program at Oyster Creek is not contained in the Augmented Inservice inspection Program. It is contained in the plant Technical Specifications.

Placing the snubber inspection requirements in the plant Technical Specifications cannot increase the probability of nor increase the probability of occurrence of any accident previously evaluated, as neither the probability of nor the consequences of an accident is be determined by the source of the requirement.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated; (or)

Placing the snubber inspection requirements in the plant Technical Specifications cannot introduce any new type of accident as types of accidents cannot be determined by the source of the requirement.

(3) Involve a significant reduction in the margin of safety:

Placing the snubber inspection requirements in the plant Technical Specifications cannot decrease the margin of safety as defined in the bases of the Technical Specifications as margin of safety is not determined by the source of the requirements.

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C321-95-2085 Attachment I Page 5 B. Section 4.5.Q.l.a GL 90-09 wording: " based on the criteria of Table 4.7.2 and the first inspection interval detennined using the criteria shall be based upon the previous inspection interval established by the requirements in effect before Amendment (*)"

TSCR 227 wording: " . based on the criteria provided in Table 4.5-1."

Reason for the Change : 1) Table 4.7.2 in the Generic Letter is Table 4.5-1 in TSCR 227. ,

2) Although there was a single visual failure during the last interval, all snubbers in the same temperature and vibration environment were either replaced or tested satisfactorily and reinstalled. There is no need to perform a plant shutdown for the sole purpose ofinspecting snubbers which have seen one year of service when the single failed snubber had been in service for seventeen years.

This request has been detennined to involve No Significant Hazards in that it does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated;(or)

The replacement / reinstallation of all snubbers in a similar application (main steam system) has effectively removed the failure mechanism for the single visual inspection failure that was observed last outage Additionally, the replacement /rcinstallation of all the snubbers in similar applications (main steam system) has significantly decreased the probability of occurrence and consequences of any accident previously evaluated as all snubbers in this application have been functionally tested during the last surveillance interval. Therefore, the one time increase in interval from the existing 12 months to 24 months is within the inspection interval which would have been in effect for the majority of the snubbers had the single failure not occurred.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated; (or)

The one time visual inspection interval extension does not create the possibility of a new or different kind of accident as surveillance interval does not affect type of accident.

(3) Involve a significant redaction in the margin of safety; s

The one time visual inspection interval extension does not decrease the margin of safety as all similar 1977 vintage snubbers on the mainsteam system have been replaced during the last refueling outage then: fore pmviding a greater confidence level that the snubbers will perfonn their intended function than if they had not been n placed and were scheduled for a twelve month inspection.

C321-95-2085 Attachment i Page 6 C. Section 4.5.Q.1.b GL 90-09 wording: "...All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for t determining the next inspection interval.

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TSCR 227 wording: --Sentence was deleted-Oyster Creek does not have any snubbers sharing a common reservoir. The requirement would be irrelevant.

This request has been determined to involve No Significant flazards in that it does not:

(1) Involve a significant increase in the probability or consequences of an' accident previously evaluated:(or)

The deletion of a requirement which does not apply to the Oyster Creek Plant cannot increase the probability of occurrence nor can it increase the consequences of an accident as the described hardware addressed by this requirement is not installed at Oyster Creek.

(2) Create the possibility _of a new or different kind of accident from any accident previously evaluated; (or)

The deletion of a requirement which does not apply to the Oyster Creek Plant cannot create a new kind of accident than previously analyzed as the hardware addressed by this requirement is not installed at Oyster Creek.

(3) Involve a significant reduction in the margin of safety; The deletion of a requirement which does not apply to the Oyst:r Creek Plant cannot reduce the margin of safety as described in the bases of the Technical Specifications as the hardware addressed by this requirement is not installed at Oyster Creek.

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TECHNICAL SPECIFICATION CHANGE REQUEST No.227 CHANGED PAGES '

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