NRC-91-0152, Application for Amend to License NPF-43,changing TS 3/4.7.5 Re Alternate Snubber Visual Insp Intervals,Per Generic Ltr 90-09

Application for Amend to License NPF-43,changing TS 3/4.7.5 Re Alternate Snubber Visual Insp Intervals,Per Generic Ltr 90-09

ML20091N895
Person / Time
Site:	Fermi
Issue date:	01/28/1992
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091N899	List: ML20091N907 NRC-91-0152, Application for Amend to License NPF-43,changing TS 3/4.7.5 Re Alternate Snubber Visual Insp Intervals,Per Generic Ltr 90-09
References
CON-NRC-91-0152, CON-NRC-91-152 GL-90-09, GL-90-9, NUDOCS 9201310145
Download: ML20091N895 (13)

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A4% V uni w. tu operenone Jancury 28. 1992 NPC-91-0152 U. G. Nuclear Regulatory Ccamission Attnt Documer Control Desk Washingt on. D. C. 20555 Peferences: 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Generic Let ter 90-09. " Alt enint e Requirements for Snubber Visual Inspection Intervala and Corrective Actions" Subjects Proposed Technieni Specification Change (License Atiendtuent) - Alternate Snubber Visual Inspection

%ntetvals in Technical Specification 3/4.7.$ '

(Implenent ation_ of Generic Letter 90-09 Culdance)

-Pursuant to 10CPR50.90. betroit Edison Com},any hereby proposec to ,

amend Operating License NPF-43 for the Fermi 2 plant by incorporating

the enclosed changes into the Plant Technical Speci!! cottons (TS).

The propcsed amendment changes the snubber f nspection schedule irom one that is baced on the total number of snubbers in a Liven system found ineperablo durin6 thn previous inspection to une that in based on the numbeer of snubbets within various snubber populations or categories round unacceptsble during the previoup inspection. This

. change in a line item TS improvement as described in Reference 2.

Dottoit Edison han deviatal f rom the model TS in Reference 2 in order to make the proponed changes compatible with Fermi TS. The dif ferences do not alter the requirements or the intent of the snubber '

inspection intervals proposed in Reference 2. These dif ferences at e described in the attsched evaluation, Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFP30.92 and determined that no significant har.ards consideration is -involved. The Fermi 2-Onsite Review Orgar.ization has approved and the Nuclear "rfety Review Croup has reviewed the proposed Technical Specifications and concura vi+ the enclosed deteuninations. In accordance with 10CFR50.91. De' it Edison has provided a copy of this letter t o the Stat e of Muhigaa.

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• Janua ry 28. 1992 HRC-91-0152 Page 2 Detroit Edison requests that this aniendment be approved prior to the third refueling outage currently scheduled to commence on September 12, 1992 to ensure t hat. the benefits of this generic letter con be realf red as soon as possible.

In addition. Detruit Edison requeatu that this amendment be ef f ective 30 days af ter NRC isseance to allow suf ficient time to implecient these changes.

If you have any questions, pleave contret Mr. David 11. Brown at (313) 586-4213, Sincerely. .

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Enclosurect Enclosure 1 - Evaluation of Ptoposed Change Enclosure 2 Proposed Technical Specifications Mark-up Enclosure 3 - Technical Specification Change Pages ces T. G. Colburn A. B. Davis R. W. DeFayet t e S. Stasek Supervisor. Elect ric Operators. Michigan Public Service Commission - J. P. Fadget t l

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USNRC Janua ry 28, 1992 1:RC-91-015 2 l' Page 3

1. WILLI A!. S. ORSER. do hereby affitu that the foregoing stetteents are based on f act s and cittuost aneen which ar e t rue and accurate t o the best of my knowledge and belief.

WILLI AM S. ORSl;R b -?-

Senior Vico Trosident On thin O, dayof( 1 v// Q4/~ . 1992 bef ore me 4 personally appeared William S. proer, befng first duly cworn and says that he executcd ti.e foregoing.as his free act and deed.

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T Enclosure to NRC-91-0152 Page 1 INTR 0bOCTION Technical Specification (TS) 4.7.5.b currently specifies a snubber vi- m1 inspection schedule that it. Msed on the number of snubters in a given system found inoperable du-1'.t the prevte's visual inspection, irrespective of the size of the snubber popuid;;on. The existing TS requirements establish inspection ititervals in fractions of the nominal 18 month fuel cycle. These intervals are described in a table contained in TS 4.7 5.b. The purpose of this proposal is to change the snubber visual inspection interval to one that is based on the number of unacceptable snubbers found in proportion to the size of the population or category of snubbers included in the previous inspection. The next visual inspection interval may be twice (,p to 48 months maximum), the same, or reduced to two-thirds of the previous l inspection interval depending on the number of unacceptable snubbers found in the previous inspeci; ion.

TROPOSED TECilNICAL SPECIFICATION CilANGES The proposed Tf changa are attached. The proposed TS 3/4.7.5 incorporates the changes for alternate snubber visual inspection intervals. The proposed TS Table 4.7.5-1 provides the requirements for determining the next inspection interval and replaces the existing table in TS 4.7 5.b. The proposed TS changes are writtun in accordance with NRC Ganeric Letter 90-09 (Reference 2) with the exceptions described alcw. Additionally, TS Bases 3/4.7.5 has been changed to reflect the changes in TS 3/4.7.5.

Changes to the tert .n. 'S 3/4.7.5 have been made which, while consistent with 'rw ir:i ..b and objectives of Reference 2, deviate from the wording of L:o w as for alternative snubber visual inspection intervals used in tre nr: del TS contained in Reference 2. In addition, a typographical error was corrected in TS Bases 3/4.7.5 These changes are as follows:

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1. TS 4.7.5.b The proposed TS 4.7.5.b has been reworded to provide consistency with I the nomenclature used in the rest of TS 4.7.5.b. If the exact wording of the changes f'or alternate snubber visual inspection intervals in l

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the Reference 2 model TS-was incorporated into Fermi 2 TS 4.7.5.b,

" Visual Inspcotions", it would read as followar

<" Snubbers:are categorized as_ inaccessible or accessible during reactor operation. Bach of these categories (inaccessible and accessible) may be inspected independently according to the

. schedule determined by Table 4 7.5-1. The visual inspection interval for each type of snubber shall be determined bated upon the criteria provided in Table 4.7.5-1 and the first inspection-interval determined using this criteria shall be based upon the ',

previous. inspection interval as established by the requirements

-in effect before Amendment ~

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the ame'.doent that implements this change.)

Tha propo6hJ TS.4.7.5.b rer : as shown below _ The_ underlined word,

" category",-indicates a deviation from the change presented in the  :

Reference 2 model TS.

" Snubbers are categorized as inaccessible or_ accessible during reactor operation.- Each of these_ categories (inaccessible and accessible) may be-inspected independently according to the-schedule determined by: Table 4.7 5-1. Tna visual inspection interval for each category of snubber shall be determined based upon the criteria provided in Table 4.7.5-1. The.first >

inspection interval determined using this criteria shall te based upon-the previous inspection interval as . established by the requirements.in effect before Amendment . " (The aaendment number wi 1-be the amendment that:impicments this change.)

The word " category" has'been subs'!tuted for " type" to provide. ,

consistency with the wording usea a the discussion of inaccessible and~ access!ble snubber categories contained-in the,first two sentences of proposed TS 4.7.5.b and in the proposed TS Table 4.7.5-1. The-

• mode TS change for TS 4~.7 5.b states that the snubber. visuals in- s lion interval for each " type" of snubber shall be determined by T' e-4.7 5-1. " Type", as defined in Fermi-2 TS 4.7.5.a, refers to a of the same: design and manufacturer. . Snubber " typed is to be me6 .i snubber functional: testing because-snubber functional testing ,

tilures are more readily grouped by design and manufacturer.

However, the- type of snubber is not a factor iny determining the . .

snubber visual inspection interval as defined in the Reference 2 model snubber visual' inspection-interval table and the proposed TS Table

'4 7 5-1. Snubber population or. category is ti.e determining factor.

. Therefore; when used.in-the context of snubber visual-inspections, it is-acceptable to substitute " category" for " type".

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'7 ' Eac109ues to NRC-91-0152 Page 3 Tne third sentence of t,he above model TS has been broken into two sentences. The third sentence of the model TS describes two recairements: (1) that the snubbcr visual inspectic.n intervals are determined by Table 4 7 5-1 and, (2) t, hat the first snubber inspection interval shall be based on the previous inspection interval established by the TS in effect prior to the approval of-this amendment. The proposed TS breaks the third sentence of the model TS into two sentences t.o separate the two requirements. This change provides assurance that the reader of this TS will understand that t,wo separate requirements exist and avoid the possibility of misreading the requirements. There is no change to the wording of the requirements other than accommodate the punctuation changes i required to split the original sentence into two sentences.

2. SS 4.7.5.c The proposed TS 4.7 5.c has been reworded t) provide consistency with the existing nomenclature used in the rest, of TS 3/4.7 5. If the exact won' ding of t,he changes for alternate snubber visual inspection intervals in the Reference 2 model TS was incorporated into Fermi 2 TS 4.7.5.c, " visual Inspect. ion Acceptar.co Criteria", it would read as follows:

" Visual inspections shall verify that: (1) theres are no visible indications of damage or impaired OPERABILITY and (2) attachments to the foundation or supporting structure are secure, and (3) 4 fasteners for attachment of the snubber to the component and to the snubber anchorage are secure. Snubbers which appear inoperable as a result of visual inspect. ions shall be classified as unacceptable and may be reclassified acceptable for the 1 purpose of establishing the next visual inspection interval, provided that (1) the cause of the rejection is clearly c

est,ablished and remedied for that particular snubber and for i other snubbers irrespective of type on that system that may be generically susceptible; and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE por SpecificatJons 4.7.5f. For those snubbers common to .

more than one system, the OPERABILITY of such snubbers shall bc l'

considered in assessing the surveillance schedule for each cf the related systems. A review and evaluation shall be performed and l

' documented to justify continued operation with an unacceptable L anubber. If continued operation cannot be justified, the snubber

[ shall be declared inoperable and the ACTION requirements shall be met."

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• '- Enclosure to NRC-91-0152 Page 4 The proposed TS 4.7.5.c, " Visual Inspection Acceptance Criteria" reads as shown below. The underlined words and phrases indicate deviations from the changes presented in the Reference 2 model TS and nomenciature changes from the current Fermi 2 TS 4.7.5.c:

" Visual inspections shall verify that: (1) there are no visible indications of damage or impaired OPERABILITY and (2) attachments to the foundation or supporting structure are functional, and (3) fasteners for 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 sneber and for other snubbers that may be generically susceptible; and (2) the affected snu'ober is functionally tested in the as-found condition and determined OPERABLE per Specifications 4.7.5f. For those snubbers common to more than one system,-the OPERABILITY of such snubbers shall be considered in assessing the OPERABILITY of each ci the related systems. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the ACTION requirements shall be met."

The word functional" has been substituted for " secure". " Functional" better describes the condition of the foundation / supporting structure attachments and component / snubber anchorage fasteners required for a

- successful visual inspection of a snubber. This is a nomenclature change from the existing Fermi 2 TS and is not part of the changes for alternate snubber visual' inspection intervals .in-Reference 2 model TS . - It is consistent with the nomenclature used in the current Standard Technical Specifications format.

The phrase "0PERABILITY of" is substituted for the phrase

" surveillance achedule" to better define that equipment operability is being assessed when snubbers common to more than one system are declared inoperable.- This is a nomenclature change from the existing Fermi 2 TS and is not part of the changes for alternate snubber visual inspection intervals in Reference 2 model TS. However, this change is needed because the Reference 2 changes no longer require a surveillance schedule for each system.

The phrase " irrespective of type on that system" in the second sentence of the current TS 4.7.5.c has been cemoved. This phrase is currently included in the requirement mat the cause of rejection for a

. - ' Enclosure to NRC-91-0152 Page 5 a particular snubber be remedied, not, only for the affected snubber, l but, for.all other snubbers on the same system that may be generically susceptible. As stated above, the reference to " type" is being j removed from the snubber visual inspection requirements to maintain consistent nomenclature in the snubber visual inspection requirements. The phrase is not needed because the wording requires that the cause of the rejection be remedied "for other snubbers that may be generically susceptable". If the cause of the rejection is generic, then the type of snubber has no bearing on determining which ,

snubbers are affected. The reference to " system" is eliminated l because the propose i snubber visual inspection intervals are based on l snubber population cr cat,egory. l

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A typographical error was found in the the description of the snubber functional testing methods in TS Bases 3/4.7 5. Method "1" states i that an additional 10% of a type of snubber will be tested for each i functional testing fa i. lure . This does not agree with TS 4.7 5.e.1 which states that an additional 5% of that type of snubber shall be l functionally tested for each failure. TS Bases 3/4.7.5 has been i corrected to agree with TS 4.7.5.e.1.

l DISCUSSION l

The snubber TS imposes aurveillance requirements for functional testing and visual inspection of all safety related snubbers.

Functional testing verifies that a snubber can operate within specific performance limits. Functional testing involves removing the snubber and testing it on a specially designed test stand. Functional testing provides a 95 per cent confidence level that 90 to 100 per cent of the snubbers operate within the specified weeptance limits. A visual inspectics .is tf's coservat,iB of the condition of installed snubbers to identify those that are samaged, degraded, or inoperable due to external physical damage, leakage, corrosion, or environmental exposure. The visual examination is a separate process that complement:. the functior.a1 testing program and provides additional confidence in snubber oparability.

Plants having a large snubber population, such as Fermi 2, find that 1- the current visual inspection schedule .ts excessively restrictive.

According to Reference 2, some plants have spent significant resources and have subjected plant personnel to unnecessary adiological i exposure to comply with the visual examination requirements.

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Enclosure to NRC-91-0152 Page 6 As stated in Reference 2, the NRC has developed an alternative inspection schedule based on the number of unacceptable snubbers found during the previous inspection, the tot,al population or category size for each snubber type, and the previous inspection interval. A snubber is considered unacceptable if it fails to meet its visual inspection acceptance criteria. The licensee shall perform and document a review and evaluation to justify continued operation with en unacceptable snubber. If continued operation cannot be justified, the licensee shall declare the snubber inoperable and shall meet the applicable action requirements. To determine the next surveillance interval, the licensee may reclassify the unacceptable snubber as acceptable ift (1) The cause of the rejection is determined and corrected for t.e affected snubber and other snubbus that may be generically susceptable and; (2) The affected snubber is functionally tested in the as-found condition and determined operable. . Snubbers may be categoriced as accessible or inaccessible and may be examined separately or jointly. The licensee must make and document that decision before any inspection and use that decision as the basis upon which to determine the next inspection interval for that category, l Use of this alternate inspection schedule will reduce personnel radiation exposure because it will be possible to reduce the number of inspections through extended inspection intervals and by allowing the added flexibility to schedule inspections during refueling outage l

timeframes. Extended surveillance intervals will also be cost effective becau.se reducing the number of inspections will reduce inspection man-hours and the associated material commitments.

EVALUATION This proposal only changes the method by which the snubber visual inspection intervals are determined and clarifies that, if continued operation cannot be justified with an unacceptable snubber, the snubber is declared inoperable and the TS 3/4.7.5 action requirements shall be followed. There is no change to the snubber functional testing intervals. This change does not alter the design, function, or operation of the snubbers or plant systems on which they are installed. This proposal does not change any accident analysis assumptions. The confidence level associated with this change is equivalent to that provided by the existing snubber visual inspection and functional testing requirements. Therefore, there is no reduction l in snubber reliability. As discussed above, this change will reduce l personnel radiation exposure because it will be possible to reduce the L

number of inspections through ertended inspection intervals and by l

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1 Enclosure to NRC-91-0152 Page 7 allowing the added flexibility to schedule inspections during refueling outage timeframes. Extended surveillance intervals will also be cost effectiva because reducing the number of inspections will reduce inspection man-hours and associated material commitments.

Based on the snubber visual inspection results of the first and second refueling outages, there is a high probability that 100% snubber visual inspections would only be required every other refueling outage. This change represents an enhancement to plant operation 3 and is, therefore, acceptable.

SIGNIFICANT llAZARDS OCNSIDERATION In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that operation in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a margin of safety.

The propo.aed amendment changes the snubber visual inspection interval in TS 3/4.7.5. It changes the snubber visual inspection interval from j

one based on the number of snubbers in a gk an system found inoperable during the previous visual inspertion, irrespcutive of tl e snubber population size, to one that is based on the number of unaoceptable snubbers found in proportion to the sine of the population or category of snubbers included in the previous inspection. Editorial changes are also made to provide consistent nomenclature; clarify requirements, and ensure that the snubber TS and TS bases agree.

l These changes are conslLtent with the objectives and intent of Reference 2. These changes will enhance plant operations by extending snubber visual inspection intervals with a subsequent reduction in personnel radiation exposure and inspection costs.

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1) Does not involve a significant increase in the probability or consequences of an accident previously evaluated. Snubbers are installed to maintain the structural integrity of systems and components which mitigate the consequences of previously analyzed accidents. This amendment does not alter the design, function, or operation of the snubbers or the systems in which they are

Enclosure to NHC-91-0152 Page 8 Installed. This amendment does not change the snubber functional testing requirements. As stated in Reference 2, the proposed changes were developed by the NRC staff and maintain the same level of rnubber reliability r.s the exiuting visual snubber inspection schedule. Therefore, the reliability of the snubbers is not reduced.

Providing consistent nomenclature and clarifying requirements in the proposed TS 3/4.7.5 meets the objectives and intent of Reference 2. Changes to TS Bases 3/4.7.5 are consistent with the guidance in Reference 2. A typograpnical error is also corrected in TS Bases 3/4.7 5 These chnges are, therefore, considered to be editorial in nature.

2) Does not create tne possibility of a new or different kind of accident from any accident previously evaluated. The proposed change does not alter the configuration of the facility, plant operations, or the accident analysis assumptions. No % mode of failure is being created because this change dou not degrade the design, operation, or maintenance of the plant. As stated in Reference 2, the proposed TS chang;a maintains the same le' a of snubber reliability as the existing snubber visual D'spection interval. The editorial changes in TS 3/4.7.5 cet the objectives and intent of Reference 2. The Ganges to TS Bases 3/4.7.5 are consistent with the guidanc', in Reference 2. The correction of the typographical erese in TS Bases 3/4.7.5 is an editorial change.

a) Does not involvo a s%oiricant reduction in a margin of safety.

The proposed amiament incorporates the surveillance requirements for tha muober visual inspection interval in accordance with the g.adance in Reference 2. As. stated in Reference 2, the proposed-snubber visual inspection interval maintains the same confidence level as the existing snubber visual inspection interval. The editorial changes in TS 3/4.7.5 meet the objectives and intent of Reference 2. The changes to TS Bases 3/4.7 5 are consistent with the guidance in Reference 2. The correction of the typographical error in TS Bases 3/4.7.5 is an editorial change.

Based on the above, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. TM proposed change does not involve a significant

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• • Enclosure to NRC-91-0152 Page 9 hazards consideratioit, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFP51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement, c6MCLUSION 11ased on the evaluation above: 1) there is reasonable assurance that j the health and safety of the public will not be endangered by operation in the proposed manner, and 2) such activities will be conducted in compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.

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