ML20213F117

Discusses Util 840518 Request for Amend to License NPF-14, Changing Tech Specs Re Snubbers.Elimination of Tech Spec Table 3.7.4-1 Acceptable,Per Generic Ltr 84-13.Rev to Insp Schedule for Snubbers Should Be Denied for Listed Reasons

ML20213F117
Person / Time
Site:	Susquehanna, Vogtle, 05000000
Issue date:	02/04/1985
From:	Knight J Office of Nuclear Reactor Regulation
To:	Novak T Office of Nuclear Reactor Regulation
Shared Package
ML20213E629	List: ML20213E625 ML20213F117 ML20214G397 ML20214H017 ML20214H085 ML20214H125 ML20215A123 ML20215A344 ML20215A593 ML20215A752 ML20215A782 ML20215A967
References
GL-84-13, TAC-55139, NUDOCS 8502110327
Download: ML20213F117 (3)

Text

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UNITED STATES

! , NUCLEAR REGULATORY COMMISSION

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FEB 4 1985 MEMORANDUM FOR: Thomas M. Novak, Assistant Director Division of Licensing FROM: James P. Knight, Acting Director Division of Engineering

SUBJECT:

REQUEST TO AMEND SUSQUEHANNA UNIT 1 TECHNICAL ,

l SPECIFICATIONS (TAC # 55139)

References:

1. Letter from N.11. Curtis to A. Schwencer, " Proposed Amendment 43 to License No. NPF-14." dated May 18, 1984

2. NRC Generic Letter 84-13, " Technical Specification for Snubbers," dated May 3, 1984 In Reference 1, the licensee proposed changes to Appendix A of License No.

NPF-14, the Susquehanna Unit 1 Technical Specifications. One of these proposed changes involves Technical Specification Section 3/4.7.4,

" Snubbers." The licensee is eliminating Table 3.7.4-1, " Safety Related Mechanical Snubbers" which is a tabular listing of all safety related mechanical snubbers in Unit 1.

The elimination of the tabular listing of snubbers in the Technical Specifications agrees with policy established in a recent generic letter (Reference 2) and is acceptable.

In addition to the above change, the licensee proposed a revision to the Unit 1 Technical Specifications which would place the inspection schedules of snubbers on a system basis rather than a plant or unit basis. This should be denied because it would be in conflict with established NRC policy and precedent and also in conflict with an industry standard (OM-4) which is nearing final acceptance for issuance. The title of the standard is " Examination and Performance Testing of Nuclear Power Plant Dynamic Restraints (Snubbers)."

You should be aware that the issue of " plant versus system" as the basis for inspection schedules was thoroughly debated within the OM-4 Working Group on Dynamic Restraints and it was agreed that the intent of the standard was to survey all the snubbers in a plant to locate those which may suffer from an identified failure mode which is not system specific. If the failure mode can be narrowed to a specific design, model or type of snubber then only those snubbers must be inspected. However, this selection must be made from the entire unit or plant population of snubbers, not just from the systen in which the valid failure mode was identified.

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/ We recognize that this denial will cause Units 1 and 2 to be different. We

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only recently became aware of the fact that Susquehanna Unit 2 and several other plants were issued technical specifications in conflict with our policy and that of the industry standard. We have evaluated the effect of such operation and have concluded that it does not present

. and safety of the public to operate in this manner in'3the hazard to the required time period health to rectify this matter.

This concludes the MEB action for TAC # 55139.

James P. Knight, Acting Director Division of Engineering cc: D. Crutchfield, DL R. Bosnak, DE A. Schwencer, DL M. Campagnone, DL E. Butcher, DL H. Brammer, DE b

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,g Vosta Justification for Changes to Specification 4.7,4'of thenGre-d self ..

Technical specification 'I Operating experience has indicated that snubber inoperabilities are not generally related to the systems on which they are installed. Such inoperabilities are usually caused by either: <

'1. an isolated incident such as installation 'ierror.

2. a problem related to the snubber design, or - .

3. a general environment problem, such as high temperature or radiation.

None of the above causes are system unique.

PWbA The "::h:nical Engineering Branch) believes that the visual inspections should be used to identify the tfpe of inoperable snubbers, and rein-spection intervals should be based on the number of failures within the identified type instead of the specific system to which the original inoperable snubber was attached.

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