ML20136C532

Safety Evaluation Supporting Amend 77 to License DPR-54. Lll Technical Evaluation Rept Encl

ML20136C532
Person / Time
Site:	Rancho Seco
Issue date:	12/24/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20136C517	List: ML20136C513 ML20136C528 ML20136C532 ML20136C554
References
NUDOCS 8601030357
Download: ML20136C532 (4)

Text

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fa anc J 3. LR ITED 0TATES

!V ,; ^% NUCLEAR REGULATORY COMMISSION 5

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g- ge SAFETY EVALUATIO.'l EY THE OFFICE OF MUCLEAR RE',CT0o OEGl"_ ATICU SUPPORTING AMENDMENT NO. 77 70 FACILITY OPERATING LICENSE NO. OPR-Ed SACRAMENTO MUNICIPAL UTILITY DISTRICT PAMC40 SECO NUCLEAR GENERATIMG STATION 00CKET NO. 50-312 i

I. INTRODUCTION A. DESCRIPTION OF PROPOSED ACTION The proposed action would amend Sections 3.12 and 4.14 of Appendix A of the Technical Specifications for the Rancho Seco Nuclear

Generating Station (the facility). These sections prescribe the limiting conditions safety-related for operation and surveillance requirements for snubbers.

The revisions were proposed by the licensee to respond to changes in regulatory guid,ance.

B. BACKGROUND INFORMATION As a result of the discovery of numerous inoperable snubbers in nuclear power plants during the period 1973 to 1975, snutber surveillance requirements were added to the plant technical specifications.

1. Af ter several years of experience with these specifications, a number of deficiencies were identified. These ~

included:

1.

Mechanical snubbers were not included in the requirements.

2.

The rated capacity of snubbers was used to limit inservice

testing requirements.

3.

NRC approval was necessary for acceptance of seal materials.

4.

Inservice test requirements were not clearly defined. ,

5. In place inservice testing was not permitted.

To' correct these deficiencies, revised standard surveillance requirements were developed. These revised standards now provide as follows:  ;

1.

Mechanical snubbers (if utilized by the licensee) are now included in the surveillance program. >

p 2.

Except where specific exemptions are granted, all snubbers, regardless of capacity, are subject to inservice test i requirements.

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2 3.

Seal materials no longer need NRC approval. Instead, a monitoring program is to be implemented to assure snubbers are fanctioning within their service life.

4.

Inservice test requirements for snubbers have been efarified.

5.

Inservice testing performed in place is now permitted.

By letter dated November 20, 1980, the NRC transmitted these revised standard surveillance requirements to All Power Reactor Licensees (except SEP). This letter also requested that licensees submit an application to amend the facility license to incorporate the applicable portions of these model Technical Specifications.

By letter dated April 7, 1981 District (the licensee) respon,ded to the NRC's request ofthe Sacrame November 20, 1980. As a result of meetings and discussions-with the staff, the licensee submitted letters dated November 18, 1983, and April 9, 1985 revising and supplementing the original submittal.

By letter dated May 3,1984, the NRC transmitted to All Power Reactor Licensees (except SEP) further revisions to the standard surveillance requirements which would eliminate the need to list all safety-related snubbers in the facility technical specifications and thus, the also list. eliminate the need for the NRC to approve all changes to Licensees were not required to apply for modification of facility specifications to incorporate this change, and the licensee for this facility has not made application for such a ~ change.

i This evaluation addresses the acceptability of the changes proposed by the licensee in response to the NRC requests noted above.

II. _ EVALUATION i

The licensee's proposed changes to the technical specifications have been reviewed by the staff's contractor, Lawrence Livermore National Laboratory (LLNL).

The contractor's evaluation (Attachment 1) is based i upon the guidance contained in the NRC's letter of November 20, 1980, other staff, references as listed in the evaluation and discussions with the '

t We note that although the NRC's letter of May 3,1984,. would permit the '

j i licensee to do otherwise, the~1icensee's proposal, as revised, continues

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to use tables listing safety-related snubbers. This is done to permit  ;

'the licensee to distinguish between two classes of safety-related snubbers.

.One class consists of those snubbers for which evaluation indicates functional testing would result in significant radiation exposure or significant . risk to the physical safety of personnel. .These are listed in proposed new Table 4.14-1.  !

safety-related snubbers. The other class is: all other i (All safety-related snubbers are listed in new

. Table 3.12-1.)

I The reason for this proposed division is to limit functional testing of

, -those snubbers presenting higher risk to personnel safety, to that necessary to assure snubber oper-bility. The basis for this concern is the general provision in Section~4.14.c which requires that for each snubber.of a particular type that fails the specified functional test

3 criteria, an additional 10' percent of that type of snubber shall be tested.

in Table 4.14-1 is to relieve the licensee of uthe need to incl e these failures are due to a generic problem.special snubbers in the expand In this latter case, the snubber:

listed in Table 4.14-1 would be subject to the same testing as all other snubbers susceptible to the rame generic problem.

It is also noted that proposed Specification 4.14.e makes all snubbers subject to the Snubber Seal Replacement Program.

snubbers listed in Table 4.14-1. Because of this, This includes the the snubbers in Table 4.14-1 will initially undergo seal replacement and functional testing a minimum of approximately every five refueling intervals (which each refueling outage).is twice as often as the basic surveillance rate of of a longer seal life, this frequency could be reduced.If operating experie The proposed specification, however, limits this possible extension to 10 refueling cycles so that the snubbers in Table 4.14-1 will always be subject to the basic snubbers. 10 percent sample for functional testing that is applied to all The licensee's the estimated basis radiation dosefor inclusion incurred of snubbers in the performance in Table 4.14-1 is th of the functional testing is such that the activity would be subject to the facility ALARA (as low as reason' ably achievable) radiation exposure control program, or that functional testing could not be performed within theother to constraints of physical significant OSHA guidelines hazards. or without subjecting testnnel perso The licensee attributes the difficulty of testing some snubbers to the fact that snubbers were not made to facilitate snubber removal and replacement.part of the The staff has reviewed the snubbers proposed by _the licensee for inclusion in Table 4.14-1 and concludes the selection is appropriate.

The staff also notes that while safety-related snubbers may be added to the list given in Table apply 3.12-14.14-1.

to Table without prior NRC approval, a similar provision do es not through the process of a license amendment. Changes to Table 4.14-1 can on of safety-related snubbers for the purpose of snub lit is noted the model Technical Specifications do not include provisions .

for such a grouping. However, the staff also notes the snubbers listed the same frequency as the enubbers not on this list - i generic problem for a given type of snubber is identified.

the staff concludes the licensee's proposal provides a level of assuraAccordingly, nce of snubber operability equivalent to that pro'vided by the 'model Technical Specifications, while striking an acceptable balance between assuring the operability of the safety-related snubbers and minimizing personnel exposure therefore finds to radiation and significant this proposal acceptable.risk of physical injury. The staff The staff has also reviewed the attached LLNL Report, UCID-20454 . This exceed the requirements of the NRC model Standard Technic Specifications and recommends the NRC approve the licensee's proposal .

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3 On the basis of cur review of the LLNL report, we find we Agree with the conclusions and recomsendations presented in the report and, hence, find the licensee's proposed revisions acceptable.

The staff notes that in issuing this amendment, certain typographical errors in snubber numbers were identified in Tab l,e 4.14-1 and were corrected, s III. ENVIRON!iENTAL C0fiSIDERATION  %'

This amendment involves a change in the installation or use of a 1acility component located within the restricted area as defined in110 CFR Dart 20 and changes in surveillance requirements. The staff has determined ,

that the amendment involves no significant increase in the~ amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational' radiation exposure. The Commission has _ _.

'- previously inued a proposed find!nq that this amendment involves no .s significant herards consideration and there has been no public coment  %

on such find hg. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22f c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with @e issuance p,ffthisamendment. ^'

s' IV. CJHCLUSION ',; -  ;

x We have concl'uded, based on the considerations discussed above. that: ,1 (1) there is reasonable aysurance that the health and safety of the public will not be endangered by operation in the proposed manner,"and VT s

(2) Tuch activities will be conducted in compliance with the Comission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

hated: December 24, 1985 N '

s Principal Contributor: G. Zwetzig ,

Attachment:

As noted ,..

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