ML20206L502

Application for Amend to License DPR-40,changing Tech Spec Sections 2,3 & 5 to Implement Recommendations of Generic Ltr 84-13, Tech Specs for Snubbers. NSHC Discussion Encl

ML20206L502
Person / Time
Site:	Fort Calhoun
Issue date:	08/15/1986
From:	Andrews N OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20206L499	List: ML20206L494 ML20206L502 ML20206L507
References
GL-84-13, TAC-62173, NUDOCS 8608200210
Download: ML20206L502 (4)

Text

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of )

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Omaha Public Power District ) Docket No. 50-285 (Fort Calhoun Station )

Unit No. 1) )

APPLICATION FOR AMENDMENT OF OPERATING LICENSE Pursuant to Section 50.90 of the regulations of the U. S. Nuclear Regulatory Commission ("the Commission"), Omaha Public Power District, holder of Facility Operating License No. DPR-40, herewith requests that Sections 2, 3, and 5 of the Technical Specifications set forth in Appendix A to that License be amended to implement the recommendations of NRC Generic Letter 84-13, " Technical Specifications for Snubbers."

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, The proposed change in Technical Specifications is set forth in l Attachment A to this Application. A discussion, which demonstrates that the proposed change does not involve significant hazards considerations, is appended in Attachment B. A check for the application fee, $150.00, accompanies this Application. The proposed changes in Specifications I would not authorize any change in the types or any increase in the amounts of effluents or any change in the authorized power level of the facility.

WHEREFORE, Applicant respectfully requests that Sections 2, 3, and 5 of the Technical Specifications set forth in Appendix A to Facility Operating License No. DPR-40 be amended in the form attached hereto as Attachment A.

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A copy of this Application, including its attachments, has been submitted to the Director - Nebraska State Division of Radiological Health, as required by 10 CFR 50.91.

OMAHA PUBLIC POWER DISTRICT By Division Manager Nuclear Production l

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Subscribed and sworn to before me * " " "

this lsa day of August, 1986. "$7Q*YNM w e.... n, lPL \. A 211M.A Notary 'Public 1

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ATTACHMENT B 1

Discussion, Justification and No Significant Hazards Consideration In May 1984, the Commission issued Generic Letter 84-13 regarding Technical Specifications for snubbers. This letter noted that in the last several years, numerous license amendments have been required to add, delete, or modify the snubber listing contained within the Technical Specifications. The NRC has therefore reassessed the inclusion of the snubber listing in the Technical Specification and has determined that this inclusion is unnecessary. Licensees were given the option of modifying their Technical Specifications to delete these tables.

Like most licensees, OPPD has processed several changes to the Fort Calhoun Station Technical Specifications in order to add to, delete from, or modify the snubber l i stir.gs . These proposed Technical Specifications would delete the snubber listings, and references to those listings. If these proposed changes are granted, the snubber listing will remain under administrative control but will no lutger be found in the Specifications.

Deleting reference to the snubber tables re' quired clarifying wording concerning the selection of snubbers to be tested. The methodology for selecting sample size described in our current specifications and the standard specifications is applicable for a large number of safety-related snubbers. This is true in the case of hydraulic snubbers. The proposed specification has been reworded to delineate the representative sample of hydraulic snubbers as being selected according to this criteria. The Standard Technical Specifications provide that a representative sample of 10% shall also be considered acceptable. According-ly, the specification for mechanical snubbers is proposed in a format utilizing the "10%" selection process. This is an acceptable methodology for smaller sample sizes.

Sionificant Hazards Considerations The following discussion is provided in support of OPPD's position that this amendment application does not involve a significant hazards considerations.

(1) Will the change involve a significant increase in the probability or consequences of an accident previously evaluated?

No, because this change is administrative in nature. It only involves removal of the Tables listing safety-related srubbers from the Technical Specifications and the references thereto. Absence of this Table from the Technical Specifications will not increase the proba-bility or consequences of any accident previously anal-yzed. The current Technical Specification requirement for an engineering analysis to support changes, dele-tions, or additions has been maintained.

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(2) Will the change create the possibility of a new or difference kind of accident from any accident previously evaluated?

No. This change, as stated above, is administrative in nature and will not create the possibility of a new or different accident than those previously evaluated.

(3) Will the change involve a significant reduction in a margin of safety?

No. As stated above, the changes are administrative in nature and do not affect any margin of safety. Addition-ally, they will allow for consistent bookkeeping with respect to snubber inventory. The delay time between installation of a new snubber, submittal of a "Applica-tion for Amendment of Operating License", NRC review and issuance time will be eliminated.

The Commission has provided guidance concerning the application of the stand-ards for determining whether a significant hazards consideration exists by pro-viding certain examples (51 FR 7751) of amendments that are considered not likely to involve significant hazards considerations. Example (i) relates to a change which is administrative in nature, intended to achieve consistency or correct an error. The proposed change is representative of Example (i) in that it eliminates tables which may be inaccurate from time to time, due to process-ing or modification. The proposed change removes reference to the Tables to maintain consistency throughout the specifications. Further, clarity is in-creased by better delineating (through description) which snubbers are within the scope of the specification.

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