ML20126F187
| ML20126F187 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/29/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20126F178 | List: |
| References | |
| NUDOCS 8506170387 | |
| Download: ML20126F187 (5) | |
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. The initial review of the licensee's submittal was performed by the NRC staff and its contractor Lawrence Livermore National Laboratory (LLNL).
LLNL prepared a Technical Evaluation Report (TER) No. UCID-19716 dated August 18, 1983, based on a comparison of the licensee's proposed TS with the STS and discussions with the licensee during an NRC/ licensee meeting of June 22, 1983. The TER contained detailed information of the evaluation and an integral appendix that compared the licensee's proposed TS with the STS.
The TER concluded that the licensee's proposcd TS required either additional modifications in order to conform to the STS or adequate justification for deviations. The NRC staff reviewed the TER and concurred with its basis and findings. By letter dated February 3, 1984, the NRC staff transmitted the TER to the licensee and requested a revised proposed TS be submitted.
The licensee's response letter dated May 3, 1984, provided the licensee's stated intent to modify the TS to agree with the majority of the TER positions. For several other of the TER positions, the licensee provided additional reasons why their plant specifics require variations from the STS. Shortly thereafter, by letter dated July 27, 1984, the licensee submitted revised proposed snubber TS changes.
The NRC staff review of the July 27, 1984 submittal determined there was a limiting condition for operation (LCO) omission of the STS requirement to perform an engineering evaluation on the supported components of inoperable snubbers. The licensee's latest resubmittal of revised TS, dated January 18, 1985, includes this requirement.
3.0 EVALUATION By letter dated January 18, 1985 the licensee resubmitted its revised proposed snubber TS changes.
The NRC staff has reviewed the licensee's resubmittal and verified that the TS were modified to include an LCO engineering evaluation of supported equipment requirement and Bases statements consistent with this requirement. The staff further determined that the licensee's resubmitted TS are in substantial agreement with the STS.
During the evaluation, the staff recognized that the licensee's TS are in the custom (non-STS) femat and that there could be circumstances where a plant-specific approach is warranted. The staff's evaluation of the variations from the STS are addressed below.
3.1 Cold Shutdown and Refueling Modes The licensee's proposed TS 3.6.1.1 has been modified and now includes the STS Cold Shutdown and Refueling modes of applicability. The licensee's TS 3.6.1.2 contains the provision that, when in these modes snubbers are w -
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. required to be made operable within 7 days whenever the system in which they are installed is required to be operable. The licensee's TS Bases explains that total system stress is lower when in these modes and therefore relative probability of structural damage to piping systems would be lower.
The staff recognized that this plant is not a STS plant and during the proposed snubber TS review, the general fomat of other areas of the plant's TS were also reviewed.
This review has shown that the 7 day provision is consistent with the plant's TS for other systems and equipment.
Based on the licensee's TS inclusion of previously exempted Cold Shutdown and Refueling modes, recognition of the need for consistency with other TS requirements, and the licensee's Bases explanation, the staff finds the 7-day provision acceptable.
3.2 Engineering Evaluation to Declare Affected System Operable The licensee's proposed TS 3.6.I.2.c contains an additional provision that, an engineering evaluation may be done to detemine if the inoperable snubber is necessary for operation of the system or for meeting the design criteria of the plant. The proposed TS permits snubber removal if the evaluation determines the snubber is not required.
The staff has reviewed this additional licensee's TS provision and concludes that it is consistent with the STS objectives and that it contains the necessary supplenental provisions. Therefore the staff finds it acceptable.
3.3 Engineering Evaluation of Supported Components Thi licensee's TS 3.6.1.3 has been modified to contain a provision to perform a documented visual inspection of supported components associated with inoperable snubbers within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This is consistent with the STS.
The licensee's TS also has been modified to contain provisions for an
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engineering evaluation to be perfomed on components supported by inoperable snubbers to ensure that there have been no adverse affects on the supported components.
The licensee's TS 3.6.I.3 contains a time frame of 14 days for completion of the engineering evaluation for all modes of operation except Cold Shutdown and Refueling.
For Cold Shutdown and Refueling the licensee's time frame for completion of the engineering evaluation is 30 days.
The staff has evaluated the licensee's proposed TS time frames for completion of supported corponent engineering evaluations. The staff evaluation included review of the licensee's overall TS comitment which includes a documented vistai inspection within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> followed by more complete engineering evalur. ions to be performed in every instance.
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' The staff finds that the licensee's TS 3.6.I.3 provisions are consistent with the objectives of the November 20, 1980 Generic letter as well as the STS and are, therefore, acceptable.
3.4 Functional Test Frequency The licensee's proposed snubber TS 4.6.I.3 functional test frequency has been revised to "once each operating cycle" from "once each refueling cycle", whereas the STS provision is "once each 18 months during shutdown."
The licensee's May 3, 1984 response to the TER described their reasons for
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the use of " operating cycle" as being consistent with other TS sections, and that functional testing during the operating cycle interval allows latitude to perform testing over the entire time period instead of the restrictive time span of an outage.
Because the proposed use of the term " operating cycle" meets the objective of the STS, which is to ensure that snubbers are tested at least once during each operating cycle (lasting, typically, around 18 months), the staff finds the proposed functional test frequency of "once each operating cycle" acceptable.
3.5 TS Snubber Tables The licensee's tabular listing of snubbers has been deleted from the proposed snubber TS based on the NRC Generic Letter dated May 3, 1983.
The licensee's proposed snubber TS have been revised to include TS 4.6.I.9, -
" Service Life Monitoring," TS 6.10.B.13, " Record Keeping" and TS 3.6.I.1,
" Bases Description of Applicable Snubbers," in keeping with the intent of the NRC Generic Letter dated May 3, 1984 Therefore the staff finds the licensee's proposed deletion of the snubber tabular listing acceptable.
The staff has concluded that the licensee's proposed snubber TS have clarified and increased snubber surveillance, defined testing and acceptance criteria, included mechanical snubbers, eliminated inappropriate seal material approval, and include a service life monitoring program. Based on the above evaluation, the staff finds that the licensee's proposed snubber TS meet the objectives of the above referenced Generic Letters as well as the STS and are, therefore, acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
S This amendment involves a change in the installation or use of a facility component located within the restricted area and changes in surveillance requirements as defined in 10 CFR Part 20. 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
. issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.
Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and (2) public such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Harold I. Gregg, Region I Dated: May 29,1985 O
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