HL-1664, Application for Amends to Licenses DPR-57 & NPF-5,revising Unit 1 TS Section 4.6.L & Unit 2 TS Section 4.7.4 Re Snubber Surveillance to Reflect Present Guidance Proposed in Encl B of Generic Ltr 90-09 Re Snubber Visual Insp

Application for Amends to Licenses DPR-57 & NPF-5,revising Unit 1 TS Section 4.6.L & Unit 2 TS Section 4.7.4 Re Snubber Surveillance to Reflect Present Guidance Proposed in Encl B of Generic Ltr 90-09 Re Snubber Visual Insp

ML20082B966
Person / Time
Site:	Hatch
Issue date:	07/11/1991
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082B969	List: HL-1664, Application for Amends to Licenses DPR-57 & NPF-5,revising Unit 1 TS Section 4.6.L & Unit 2 TS Section 4.7.4 Re Snubber Surveillance to Reflect Present Guidance Proposed in Encl B of Generic Ltr 90-09 Re Snubber Visual Insp ML20082B974
References
GL-90-09, GL-90-9, HL-1664, NUDOCS 9107170212
Download: ML20082B966 (4)

Text

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July 11, 1991 U. S. Nuclear Regulatory Comission HL 1664 ATTN: Document Control Desk Washington, DC 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50 321, 50 366 OPERATING LICENSES DPR 57, NPF 5 REQUEST TO REVISr TECHNICAL SPECIFICA110NS:

REVISION TO SNUBBER VISUAL INSPECTION INTERVALS IN ACCORDANCLVITH GENERIC LETTER 90 09 Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Georgia Power Company (GPC) hereby proposes a change to t~ne Plant Hatch - Units 1 and 2 Technical Specifications (TS), Appendix A to Operating Licenses DPR-57 and NPF-5.

Georgia Pownr Company (GPC) proposes changes which reference Generic Letter 90 09, " Alternate Requirements for Snubber Visual Inspection Intervals and Corrective Actions." This proposed change will provide consistency with the current guidance recommended by Generic letter 90 09, maintain the same confidence level as the present visual surveillance requirements, and reduce radiation exposure for plant personnel. Revisions to the wording of the Generic letter 90 09 proposed technical specifications were made to maintain consistency with the current Hatch technical specification definition of snubber categorization and disposition of visual failures. The revision of these requirements necessitates revised page and paragraph numbers and minor wording revisions throughout the remainder of the section. Certain Technical Specifications regarding snubber surveillance requirements have been revised to reflect the recommended surveillance requirements set forth in Generic letter 90-09.

Enclosure 1 provides a detailed description of the proposed change.

l Enclosure 2 details the basis for our determination that the proposed change does not involve a significant hazards consideration.

Enclosure 3 provides page change instructions for incorporating the proposed change into the TS. The proposed changed TS pages, along with a marked-up copy of the current TS pages, follow Enclosure 3.

To allow time for orderly incorporation into copies of the TS, GPC requests the proposed amendment, once approved by the NRC, be issued with an effective date to be no later than 60 days from the date of issuance of the amendment.

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Nuclear Regulatory Commission July 11. 1991 Page 2 in accordance with the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to Mr. L. Barrett of the _

Environmental Protection Division of the Georgia Department of Natural Resources.

Mr. J. T. Beckham, Jr. states that he is Vice President Plant Hatch I and is authorized to execute this oath on behalf of Georgia Power Company, and <

to the best of his knowledge and belief, the facts set forth in this letter are true.

Georgia Power Compiny BY: I J.T.Beckham,Jrg Sworntoandsubscribedbeforemethis,fl day of / ule, , 1991.

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Enclosure:

1. Basis for Change Request

2. 10 CfR 50.92 Evaluation

3. Page Change Instructions cc; Qggigift Power Company Mr. H, L. Sumner, Jr., General Managar Plant Hatch NORMS U. S. Nuclear Reculatory Commission. Washinaton. DC Mr. K. N. labbour, Licensing Project Manager - Hatch U. S. Nuclear Reaulatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch State of Georaia Mr. J. D. Tanner, Commissioner - Department of Natural Resources

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b ENCLOSURE 1 EDWIN 1. HATCH NUCLEAR PLANT UNITS 1,2 NRC DOCKETS 50 321, 50 366 OPERATING LICENSES DPR 57, NPF 5 REQUEST TO REVISE TECHNICAL SPECif! CATIONS:

REVISIONS 10 SNUBBER VISUAL INSPECTION INTERVALS IN ACCORDANCE WITH GENERIC LET1ER 90-Q2 Mils FOR CHANGE REWLSI PROPOSED CHANGE:

The proposed change will revise the Hatch Unit 1 Technical Specifications Section 4.6.L and the Hatch Unit 2 Technical Specifications Section 4.7.4 concerning snubber surveillance to reflect the present guidance proposed in Enclosure B of Generic letter 90-09, " Alternate Requirements for Snubber Visual Inspection Intervals and Corrective Actions."

DASIS FOR PROPOSED CHANGE:

The wording of Unit 1 Section 4.6.L and Unit 2 Section 4.7.4 currently specifies a schedule for snubber visual inspection based on the number of inoperable snubbers feund during the previous visual inspection. The schedules for visual inspections assume that refueling intervals will not exceed 18 months. Because the current schedule for snubber visual inspections is based only on the number of inoperable snubbers found during the previous visual inspection, irrespective of the size of the snubber population, licensees laying a large number of snubbers find that the visual inspection schedule is excessively restrictive. Some licensees have spent a significant amount of resources and have subjected plant persennel to unnecessary radiological exposure to comply with the visual exhmination requirements.

To alleviate this situation, the NRC staff developed an alternate schedule for visual inspections that maintains the same confidence level as the existing schedule and gent. rally allows the licensee to perform visual inspections and corrective actions during plant outages. This technical specification revision will reduce future occupational radiation exposure and is highly cost effective. This alternate inspection schedule as identified in Attachment B of Generic letter 90-09 is consistent with the Commission's Policy Statement on Technical Specification Improvements. Revisions to the wording of the-Generic Letter 90-09 proposed technical specifications were made to maintain consistency with the current Hatch technical specification definition of snubber categorization and disposition of visual failures.

REFERENCE:

Generic Letter 90-09, NRC Letter to All Light-Water Reactor Licensees and Applicants, " Alternate Requirements for Snubber Visual Inspection Intervals and Corrective Actions," December 11, .990.

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l ENCLOSURE 2 i i

EDWIN 1. HATCH NUCLEAR PLANT - UNITS 1,2 NRC DOCKETS 50 321, 50 366 OPERATING LICENSES DPR 57, NPF 5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REVISIONS TO SNUBDER VISUAL INSPECTION INTERVALS IN ACCORDANCE WITH GENERIC LETTER 90 02 10 CFR 50.92 EVALUATION PROPOSED CHANGE:

As discussed in Enclosure 1, this pro >osed change will revise the Hatch Unit 1 Technical Specifications Section 4.6. and the Hatch Unit 2 Technical Specifications Section 4.7.4 concerning snubber surveillance to reflect the present guidance pro)osed in Enclosure B of Generic Letter 90 09, "Alte nate Requirements for Snu)ber Visual Inspection Intervals and Corrective Actions."

BASIS FOR PROPOSED CHANGE:

Georgia Power Company has reviewed the requirements of 10 CFR 50.92 as they relate to the incorporation of the alternate inspection schedule for snubber visual inspection intervals and considers these changes not to involve a significant hazards consideration, in support of this conclusion, the following analysis is provided:

(1) The proposed changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. No physical change to the facility or its operating parameters is being made. The proposed changes were develo)ed by the NRC Staff and maintain the same confidence level as tie existing visual snubber inspection schedule as specified within Generic Letter 90 09. For these reasons, the response of the plant to previously evaluated accidents will remain unchanged.

(2) The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Since no change is being made to degrade the design, operation, or maintenance of the plant, a new mode of failure is not created, lherefore, a new or different kind of accident will not occur as a result of these changes.

(3) The proposed changes do not involve a significant reduction in a j margin of safety. The Surveillance Requirements set forth in Generic Letter 90 09 as alternate requirements for snubber visual inspection intervals were developed by tho NRC Staff and, as addressed in Generic letter 90 09, maintain the same confidence level as the present requirements. Therefore, incorporating the suggested Surveillance Requirements from Generic letter 90-09 will not reduce l any margin of safety.

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