ML20087A418

Tech Spec Change Request NPF-38-120,changing TS 3.4.7.8 & Bases to Modify Snubber Visual Surveillance/Insp Requirements to Incorporate Guidance & Recommendations in Generic Ltr 90-09

ML20087A418
Person / Time
Site:	Waterford
Issue date:	01/06/1992
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20087A420	List: ML20087A418 ML20087A426
References
GL-90-09, GL-90-9, W3F191-0430, W3F191-430, NUDOCS 9201090108
Download: ML20087A418 (6)

Text

.

Entera U eai-n osa*a.. ia' i s e O,perat ons ,

y n.r. parkhur :

W31'lDl-0130 A1.05 QA January 6, 1992 U.S. Nucicar llegniatory cointnission i

ATTN: Docinnent Control Desk Waohington, D.C. 20555 Subjoelt Waterford 3 Sl:S Dochet No. 50-382 License No. NPF-38 Technical Specification Change Itequest NPF-38-120 1

1 Gentjetnen The attached atnendtnent requests a cluuige to the Waterford 3 Techtlical Speelfications that inodifies the survel!!ance requirernents for snubbers, if

" Din oved, Technical Speelfication 3/1.7.8 and the bases related to snubber visual surveillance requirernents shall be modified to lucorporate the NitC guidance and recoininendations in Generle Letter 90-09, " Alternative llequirementn for Snubber Visual luspection Intervals and Correcilve Actions". 1:ntergy Operations, Inc.

concurs with the NitC Staff evahtation in the Generic Letter that the revised snubber surveillance will rnalntain the required confidence level in snubber reliability while reducing inanpower expenditure alul future occupational radiation exposure.

Please direct any questions or coinments to T.J. Gaudet at (501) 739-GGGG.

Very truly yours, hIt Pil/llitL/ssi xV l

Attachment:

Affidavit NPF-38-120 cc: 11.D. Martin, NltC llegion IV D.L. Wigginton, NitC-Nillt

11. !! . McGehee l N.S. lleynolds NitC ltesident inspectors Office Administrator ltadiation Protection Division (State of houlslana)

I American Nuclear Insurers t

l l '

i noto; ora uO1m n4s\J I

FDR P

ADOCK 0 5 0 0 0 :. ?;;

FDR {AL

\ l

i UNITED STATES OF AMEltlCA j NUCLEAlt itEGULAToltY COMMIESION  :

i  !

1

- In the matter of )

)  !

Entergy Operations, incorporated ) Decket No. 50-382 .

Waterford 3 Steam Electric Station )

[

AFFIDAVIT l

[

11.P. liarkhurst, being duly sworn, hereby deposes and says that he is Vico i President Operations - Waterford 3 of Entergy Operations, lucorporated; that he is duly authorized to sign and filo with the Nuclear Regulatory Commission the attached Technical Speelfication Chango Request NPF-38-120; that ho in familiar with the content thereof; atid that the matters set forth therein are true and  ;

correct to the best of his knowledge, luformation and belief.

(

Ub b \A N .

i it.P. Ilarkhurst

. Vice President Operations - Waterford 3 l STATE OF LOUISl ANA ) .

) ss PAltlSil OF ST. CilAltLES -) .

r Subscribed and sworn to before me, a Notary Public in and for the Parish and Stato abovo named this (,' " day of J A N urs R.'r ,-199h 1991 c ., /. g'.4 9 -

Notary Publie Myl Commission expires \# 'T H E'FE .

(

v

t P

DEscitle' TION AND SAPI'TY ANALYSIS '

OF pilOpOSED CllANGE NPF-38-120 The follcwing provides justification for changing Waterford 3 Technical Specifleution 3/4.7.8 and bases to modify surveillance requirements for snubbers in accordance with NltC guldunce and recoannendations contained in NRC Generle Letter 90-09, " Alternative itequirements for Snubber Visual luspection Intervals  ;

and Corrective Actions".

Existing Specifientions See Attachment A proposed Specifications See Attachment B Description The requested change modifies the existing Waterford 3 snubber visual inspection -

requirements which are based on the number of inoperablo snubbers found during the previous visual inspection, irrespective of the size of the snuhbor population- .

Inspected. Technical Speelfication Section 3/4.7.8 currently establishes an '

inspection interval of 18 months (the length of a nominal fuel cycle) or a fraction thereof based on the number of inoperable snubbers of cam.: type for the previous inspection period. A snubber is considered unacceptablo if it fails to satisfy the acceptance criteria of the visual inspection, i The purpose of the requested change is to incorporate the guidance auct recommendations developed by the NRC Staff, as published in NRC Generic Letter 90-09, " Alternative Requirements for_ Snubber Visual Inspections and Corrective ,

Actions". Generic Letter 90-09 recommends an inspection schedule baned on the number of unacceptable snubbers found during the previous inspection in proportion to _the size of snubber population or categories. - Entergy Operations, ,

Inc. has reviewed Generic Letter 90-00 for applicability to Waterford 3 and concurs with the NRC's evaluation that the recommended changes in the Generic Letter will maintain the required level of confidence n. . nubbel operability.  ;

Per existing Technical Specifications, a snubber is considered unacceptable if it falls to satisfy the acceptance criteria of the visual inspection. Snubbers may be categorized as accessible or inaccessible, based upon their accessibility during power operation. The proposed change notes that these categories may be examined separately or jointly, as long as the decision is mado and documented prior to inspection and therefc,re, is used as the basis to determino the next inspection interval for that category. The proposed change also incorporates 'ha use of review and evaluation to justify continued operation with an unaccept9ble.

snubber. The Technical Specification chango does not revise or alter the functional testing requirements for snubbers.

1

. A iww table (Table 1.7-2) is added to Tecimical Specification 3/1.7.h aiul replaces tia. existing Tecimieni Specification requirmoents f or deterinhiing the next vianil inspection interval. Table .1.7-2 establishes criteria and limitn for determining the next inspection interval corresponding to the population or category size for a given type of snublu r. The next visual inspection interval may be twice, the saine, or reduced by as unich as one-third of the previous inspection interval. This interval depends on the number of unacceptable snubbers found in pronnirtion to the sim of the population or category for snubber type included in the previous inspection. While analutnining the required level of confidence in snubber reliability, the requested Technical Specification revi,lon will result in a reduction of inanpower expmaliture and future occupational radiation exposure f rom those required to meet the current req ui reme n t s .

Although Generie i.etter 90-09 did not specifically address bases, appropriate information for the Waterford 3 bases has been extracted from the guidance in the Generie Letter and inchuled in the proposed change for consistency and completeness.

Safety Analysis The proposed change described above shall be deemed to involve a significant lur/.ards conshleration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequence of any accident pieviously evaluated?

Ilesponse: No The proposed change will incorporate the NItC Staff reconunendations of Generie Letter 90-09 regarding snubber inspections into the snubber inspection program defined by Waterford 3 Technical Specification 3/.l.7.b.

Entergy concurs with the NitC's evaluation that the reconunended changes in the Generie Letter will maintain the required level of confidence in stolbber operability. Therefore, since the confidence level is adequately maintained, this change will not increase the probability or consequence of an accident previously evaluated.

?. Will operation of the f acility in accordance with this proposed change create the possibility of a new or different hind of accidem from any accident previously evaluated?

l l

Ilesponse. No The proposed change does not change the design nor the design bases of plant systems or equipment at Waterford 3. Therefore, the current plant safety analyses remain complete and accurate in addressing the licensing basis events and analyzing plant response and consequences. As such, the l plant conditions for which the design lasis accident analyses have been performed are still valid. Therefore, the proposed change can not create the possibility of a new or dif ferent hind of accident than previously ev:d u a t ed .

l 2 ]

4

~

.- 3.- Will operation of the facility in accordaneo with this proposed chango

. involve a significant reduction in a margin of safety?

Responso: No Plant safety margins are established throughout the Waterford 3 Teelutical Specifications. The required level of confidence in the operability (1.o.

reliability) of Waterford 3 anubbers is not affected by this change, in that snubber operability is still determined by visualinspection. Since thoro will be no chang i any of the existing safety margins, the proposed amendment will n i nvolvo n reduction in margin of safety.

The Commission has provided guidance cancerning the application of standards for deterndning whether a significant hazard consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to=

-involve significant hazards considerations. The changes identified in this proposal correspond to the following examplo: -1 l

l (vil) A change to make a licenso conform to changes in the regulations, where the license change results in very minor changes to facility I operations clearly in keeping with the regulations.

i This proposal most closely resembles example (vil) because the proposed changes are in accordance with the guidance and recommendations of Generle 1,etter 90-09. ,

Safety and Sinnificant flazards Determination  ;

linsed on the abovo Safety Analysis, it is concluded that: (1) the proposed changes do not constitute a sigrificant hazards consideration as defhied by 10CFR50.92; (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed changes; and (3) thin action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

t Y

3

. 1 t

1 i

i t

1 r

r t

4 1

i r,

h f

ATTACllMENT A ,

4 NPF-38-120 .

9 1

I t

'I 1

.i