ML20092K962

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Revised Application for Amend to License NPF-30,changing Rev to TS 3/4.7.8, Snubber Visual Insp Intervals & Corrective Actions, Per Generic Ltr 90-09, Alternative Requirements for Snubber Visual Insp Intervals..
ML20092K962
Person / Time
Site: Callaway 
Issue date: 02/19/1992
From: Schnell D
UNION ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-90-09, GL-90-9, ULNRC-2563, NUDOCS 9202260089
Download: ML20092K962 (5)


Text

.

19mounas Post owe 90s 149 SL Ion Mmun (;]!bC -

' D4 b5SX50 UNION oor, sis r. schnett

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February 19, 1992 U.S.

Nuclear Regulatory Commission Attn:

Document Control Desk Mail--Station P1-137

' Washington,.DC-20555 Gentlemen:

ULNRC-2563 CALLAWAY PIANT DOCKET NUMBER 50-483 REVISION-TO TECHNICAL SPECIFICATION 3/4.7.8 SNUBBER VISUAL INSPECTION INTERVALS AND ACCEPTANCE CRITERIA Ref:

1.

ULNRC-2452, 8/1/91, "Callaway Plant / Docket Number 50-483/ Revision to. Technical Specification 3/4.7.8-/ Snubber Visual Inspection Intervals and Corrective Actions" 2.

Generic Letter 90-09, " Alternative

-Requirements for Snubber Visual Inspection Intervals and Corrective Actions,"

December'11, 1990 Union Electric Company herewith revises its

'previously submitted application _for amendment to Facility Operating License Number NPF-30 for the Callaway Plant (Reference _1).

Specifically, Union Electric Company revises its original request to revise

Technical Specification'3/4.7.8 and associated Bases-to change the snubber' visual inspection intervals and acceptance criteria in accordance with Generic Letter

' ("GL".) ~ 9 0-0 9 (Reference - 2)'.

The_" Visual Inspection Acceptance Criteria" as

. stated in_GL 90-091-specify two conditions which must be satisfied in order to reclassify snubbers as acceptable

which are initially-classified as-unacceptable as'a result.of visual inspections.. Generic Letter 90-09 specified these condi_tions using the logical connector "and,"Li.e'.,-both conditions must be satisfied in order.

'_to reclassify an unacceptable snubber.

Reference 1~(See

. Insert B of Attachment 2 of Reference 1) specified these conditions--using the logical connector "or,"

i.e.,

g either condition may be satisfied to reclassify an 0fIv spyquage

_ P.-

, U.S.

Nuclear Regulatory. Commission Page 2 unacceptable snubber.

Following recent conversations with the NRC project manager for the Callaway Plant, it has been determined that "and" is the more appropriate connector, Note that the current Technical Specifications of the callaway Plant use the logical connector "or."

The word " system" has also been added to clarify the second to last sentence of the section addressing visual inspection acceptance criteria.

The pertinent text as herewith revised (Attachment 1) is consistent with the guidance of GL 90-09.

The conclusions of Reference I that the subject j

amendment application does not involve any unroviewed 1

safety question as defined in 10CFR50.39 nor a significant hazard consideration as determined per 10CFR50.92 remain valid.

If you have any questions on this matter, please contact us.

very truly yours,

/,

f

$gb j

4h Donald F.

Schnell GAC/ dis

Attachment:

1.

Revision to Technical Specification Changes

d-STATE OF MISSOURI ~)

)

SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first. duly sworn upon oath says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By fkg' d

Donald F.

Schnell Senior Vice President Nuclear SUBSCRIBED and sworn to before me this M

- day of M/ Lum +

1992.

A k/A D YA-//

DARDARA J. PFAF[/ Eh Y

g NOTARY PUBLIC, STATE Of MISSOURI MY COMMISSION EXPIRES APRIL 22, 1993 -

ST. LOUIS COUNTY

ULNRC-2563 INSERT "B"

c.

Visual Inspection Acceptance Criteria Visual inspections shall verify that (1) there are no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) fasteners for the attachment of the snubber to the component and to the snubber anchorage are functional.

Snubbers which appear inoperable as a result of visual inspections shall be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that: (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically and susceptible;jrf (2) the affected snubber is functionally tested in the 'as-found condition and determined OPERABLE per Specification 4.7.8f.

All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval.

A review and evaluation shall be performed and documented to determinefoperability with an unacceptable

) g, snubber.

If operability cannot be justified, the system shall be declared inoperable and the ACTION requirements shall be met, i

l l

. _ _. _ _... _. ~..

cc:

T. A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

. Washington, D.C. 20037 Dr. J. O. Cermak CFA, Inc.

18225-A Flower Hill Way Gaithersburg, MD 20879-5334 R..C.

Knop Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799' Roosevelt Road Glen Ellyn,-Illinois 60137 Bruce Bartlett Callaway Resident Office U.S. Nuclear Regulatory. Commission RR#1 Steedman, Missouri 65077 L. R. Wharton-(2)

Office of Nuclear Reactor Regulation U.S. Nuclear _ Regulatory Commission 1 White Flint, North, Mail Stop 13E21-11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O.

Box 360 Jefferson City,lMO 65102 Ron.Kucera Department of NaturalLResources P.O. Box 176 Jefferson City,-MO 65102 4

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