RBG-33339, Application for Amend to License NPF-47,removing Spec 3/4.7.4 Re Snubbers,To Eliminate Requirements to Inservice Testing Program

Application for Amend to License NPF-47,removing Spec 3/4.7.4 Re Snubbers,To Eliminate Requirements to Inservice Testing Program

ML20058M755
Person / Time
Site:	River Bend
Issue date:	08/03/1990
From:	Odell W GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058M759	List: ML20058M760 RBG-33339, Application for Amend to License NPF-47,removing Spec 3/4.7.4 Re Snubbers,To Eliminate Requirements to Inservice Testing Program
References
RBG-33339, NUDOCS 9008130035
Download: ML20058M755 (7)

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GULF' STATES - UTILITIES COMPANY Rf%T A SEN0 61 ATiOh Post OFFICE BOX 220 ST. FRANCISVILLE. LOutsiANA 70775 ARE A CODE $34 635 6094 346 R651 August 3 , 1990 RBG- 33 339 File Nos. G9.5, G9.42 U. S. Nuclear Regulatory Carmission Doctrnent Control Desk j Washington, D. C. 20555 j '

Gentimen: <l River-Bend Station - Unit 1 Docket No. 50-458 -i Gulf States Utilities (GSU) Cmpany subnitted on March 21,-1988 (RBG-30380) an application to amend the River Bend Station - Unit i 1 -Technical Specifications. This change requested-to remove the specification. relating to snubbers to' eliminate- redundant i requirments to the ISI program. As a result of discussions with the NRC staff during May and June of 1990; regarding- that submittal, GSU Lis providing' this letter to supplement that application to retain certain portions of the previousL technical '

specification. This will allow the inp1 mentation of the l currently approved ISI program and will eliminate- redundant.  !

programs; A discussion of the proposed changes to specification .)

3/4.7.4 are contained in the enclosure.

Please contact Mr. L. L. Dietrich at (504) 381-4866 if additional information is required.

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W. H. Odell Manager-Oversight i River Bend Nuclear Group  !

.--mmn 900813003'5 900803 PDR ADOCK 05000458

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; U.-! S. Nuclear. Regulatory Comission T

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Ms.-Claudia-Abbate

- Up S. Nuclear' Regulatory Comission

-11555 Rockville Pike'

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iNRC ResidentiInspector-PostL0ffice' Box.1051 St. Francisville, LA. 70775:

.Mr, WilliamLH.' Spell,LAdministrator

Nuclear. Energy Division-.

Louisiana Department of Environmental Quality 4)in Post.0ffice-Box;14690-

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LA 70898 m,

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s UNITED. STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION STATE OF-LOUISIANA- )

PARISH.OF WEST-FELICIANA )

Docket Ec. 50-458 In the Matter of. )  ;

GULF STATES UTILITIES COMPANY ) 1 (River Bend Station - Unit 1)  ;

AFFIDAVIT i W,.H. Odell, being duly sworn, states that he is a Manager  !

- Oversight for Gulf States Utilities Company; that he is authorized on the part-of said company to sign and file with j

'the Nuclear Regulatory Commission the documents attached

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hereto; and that- all such documents are true and correct to the best of his knowledge,-information and belief.

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W. H. ~ Olleli  ;

Subscribed an'd sworn to before me, a Notary Public in and for the State and Parish above named, this ;4B6db- day of I44 , 19 90

. My Commission expires with Life.

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Claudia F. Hurst or Gladys B. Shelton Notary Public in and for West Feliciana Parish, Louisiana i

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ENCIDSURE

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On March 21, - 1990 GSU subnitted a proposed change to the RBS technical specifications (RBG-30380). This change requested toL renove=. the specification relating to snubbers to elimir. ate redundant requirenents to '

the ISI program. As a result of discussions with the NRC staff during May and- June of- 1990 regarding that subnittal, GSU now proposes to retain certain portions of the previous technical specification with the revisiens indicated. This will allow the 'impimentation of the currently approved ISI program and_will eliminate redundant programs and ~certain restrictions-contained in the license.-

The proposed technical specifications as revised maintain the Limiting Condition for Operation (LO3) , Applicability and ACTION requirements while only referencing the approved ISI Program in the Surveillance requirenents.

' t ese changes will also state the action necessary to revise the ISI Program.. The explanation of the proposed changes to specification 3/4.7.4 are discussed below for each insert of the attachnent. _

Discussion of insert 'A' l

The addition of the word ' required' in the LIMITING 00NDITION IOR ]

OPERATION and ACTION statment is to limit this specification to only  !

those snubbers that must beOPERABLE in the applicable operational  !!

mode (s) of the plant. The ACTION statment is also subdivided to j delineate the time periods for the engineering evaluations previously j required by item g to be empleted. These evaluations are addressed in  !

further detail by section-12.2.9 of the current ISI Plan and include: j An evaluation - to decide if the system or cmponent meets design "

requirements. This evaluation is required before. returning' the - j system or cmponent to service. An evaluation that returns'a required snubber to operation without removing it. also must be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of determining it inoperable or the system ACTION must be followed. l t

An evaluation of the snubber to determine the cause of failure, his evaluation is not required before returning the system or  :

cmponent to . service unless the snubber is to be repaired and  !

returned to service.

A failure node evaluation to determine if snubbers of the same a design are subject.to the same failure. No evaluation is required i before returning the system or snubber to service.

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3 Discuss 1on of insert 'B'- *

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. We basis for rcunoval of the detailed surveillance requimnents is the  ;

hmC review and approval of the ISI Program as discussed- in the '

original- subnittal. This approval results in the specification creating a redundant program that also must be updated to maintain a consistent program.-

The currently approved ISI Program meets or exceeds the examination '

requirments of OMa,- Part 4, 1988 Edition, except for the visual examination frequency. The currently approved ISI Program allows for ,

examinations of inaccessible snubbers at scheduled outages or .

-shutdowns of sufficient duration to provide reasonable access to the snubbers. The justification for this schedule remains as originally '

subnitted. We present RBS Technical Specification and OMa-41988 use the same visual' examination frequency table which, based on the number of unacceptable snubber examinations, may require a plant shutdown to' perfom . subsequent examinations of inaccessible snubbers at increased frequencies.

Research done by. the- Brookhaven National Laboratory has led to the L developnent of a proposed outage--based visual examination table. This' l table is being considered for inclusion in future editions of OMa-4 .

.. W e new table allows the examination period frequency to -be extended-

k. up to 36 months with a percentage of failures. The RBS ISI. Program-only allows for a maximum period of 18. months with no failures therefore the ISI Program is clearly more conservative than the L proposed table.

t' The ISI Program meets or exceeds the functional test requirements of CNa-4. One sample. plan presently allowed by OMa-4, known as the "10%" -

plan, requires an initial sample' size of at least 10% of 'each type of snubber to be tested each outage. The.ISI Program also allows the 10%

plan and is selected as the bases for the examination schedule.-The actual examinations during the last two outages were over 16% of each

, type of snubber required-to meet the ASME Section XI requirement of E 100% snubber testing in a 10 year period, again exceeding OMa-4 requirements. The present 0Ma-4 only. requires additional test lot-sizes to'be one half the size of the original sample. The present -ISI Program additional sample lots are the same size as the initial samples thereby providing additional assurance of snubber operability..  !

Discussion of. insert.'C' Since 3/4.7.4 will remain in the RBS Technical Specification, the ~

PASES will remain with the proposed nodifications. These changes will

• reference the approved ISI Program instead of specific specification L rcquirements.

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As discussed:above this change will not result in a change to the presently..

approved. ISI: Program. . As currently written, -the present' technical

~ specifications 5 may result .in unnecessary administrative and operational restrictions.: Based on that, GSU requests the review of this change- be j

. cmpltd e e - :before the refueling; outage presently scheduled to begin )

September 28,1990. Because -the revisions proposed in this letter. are i ccnservative to those proposed in the original request = and in'the approved -!

ISI program, GSU proposes that these changes do not result in a significant hazard to the public.

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' INSLT&S FOR SPECIFICATION '3/4.7.4 , SNUBBERS INSEIU A Action statornent under LIMITING CONDITION FOR OPERATION changed to read as follows:

' A. With one or more required snubbers inoperable on a systen, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber (s) to OPERABIE status or declare the attached system inoperable and follow the appropriate ACTION statenent for that systs.

B. . Perfonn engineering evaluations per the -- applicable section of the -

appIoved ISI Program.

INSERT B i'

SURVEITJRCE REQUIRDens changed to read as follows:

4.7.4 Each snubber shall be dmonstrated to be OPERABLE by implementing the ,

examination and test requirements of the approved IS1 Program and as 4 indicated in Specification 4.0.5. Only a previously approved revision .of the -ISI Program may he impicmented. Subsequent revisions to the program shall be subnitted to the NRC in -accordance with the requirements of- ,

10CFR50. 55a (g) . i INSERP C a

'Ihe following shall be inserted in section 3/4.7.4 SNUBBERS paragraph 3 of:

the BASES as.indi~ated:

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... maintained in accordance with the ISI Program. I i

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