0CAN039203, Requests Relief to Conduct Snubber Testing in Accordance W/ Tss.Util Proposes to Conduct Addl Sample Testing W/Listed Exceptions

Requests Relief to Conduct Snubber Testing in Accordance W/ Tss.Util Proposes to Conduct Addl Sample Testing W/Listed Exceptions

ML20141M068
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/26/1992
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN039203, CAN39203, NUDOCS 9203310278
Download: ML20141M068 (4)

Text

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===- Entergy ~~a o-u--

. Operations March 26, 1992 OCAN039203 U. S. Nuclear Regulatory Commission Document Control Desk Mall Station P1-137 Washington, DC 20$55

Subject:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NFP-6 Inservice Testing Program Relief Requests for Snubber Testing Gentlemen:

The Arkansas Nuclear one. Units 1 and 2 (ANO-1 & 2) Technical Specification Sections 4.16.1.d and 3/4.7.8.d respectively, state "If during the functional testing, additional sampling is required due to failure of only one type of snubber, the functional testing results shall be reviewad at the time to determine if additional samples should be limited to the type of snubber which has failed the functional testing."

The ASME Code Section XI, Article IVF-5400, " Inservice Tests for Snubbers Less Than 50 Kips" requires an additional sa aple of 10% of the total number of snubbers shall be tested when a snubber fails. -

Entergy Operations proposes to conduct additional sample testing at ANO in accordance with the requirements of IWF-5400 except for the failure of only one type of snubber. If the failure is of one type of snubber only, then Entergy operations proposes to conduct the additional sample testing in accot knee with the appropriate ANO Technical Specifications. ANO Technical Specifications requiroments do not differentiate between snubbers less than 50 kips (IWF-5400) and snubbers 50 kips and greater (IWF-5300). All plant snubbers ara addressed by the Technical Specification requirements and treated equally. In general, the Shock Suppressor (Snubber) Technical Specli1 cation Program is more conservative than the Section XI, Subs ~ tion IVF examination requirements. Therefore, Entergy Operations requests relief from the requirements of Article IWF-5400. The relief requests for ANO-1 and 2 are attached for your

' review and approval.

9203310278 920326 PDR p

ADOCK 05000313 PDR

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~ March 26. 1992

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Should you=have any questions.regarding this issue, please contact me.

Very , truly yours, b

James J. F Director, Licensing-ro f -

JJF/RWC/sjf

' Attachments a

cci Mr. Robert Martin U. S. Nuclear Regulatory Commission Region IV

.611 Ryan Plaza' Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident inspector:

Arkansas Nuclear One - ANO-1 & 2 Number 1. Nuclear Plant Road Russellville, AR-72801-

- Mr.-Thomas W. Alexion

NRR Project Manager, Region IV/ANO-1 U.;S. Nuclear Regulatory Commission NRR Mail'Stop-13-H-3 One White Flint North 11555 Rockville Pike-Rockville, Msryland 20852 Ms.LSheri Peterson

+- NRR Project Manager,~ Region'1V/ANO-2 U. S. Nuclear Regulatory Commission NRR-Mail Stop 13-H-3

-one White Flint North--

11555.Rockv111e Pike

.Rockville,' Maryland 20852 i

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_ _ REQUEST FOR RELIEF TO CONDUCT SNUBBER-TESTING

IN.ACCORDANCE VITH: UNIT 1-TECHNICAL SPECIFICATIONS

~ Components: Shock Suppressors (Snubbers)

Code 1 Requirement: '1WF-5400 LInservice Tests for Snubbers Less Than '

50 kips

" Snubbers that fail ... An additional sample of 10% of the total number of snubbers shall olso

-be tested at that time.. Additional sample testing shall be continued'until all units wittin the sample have met the requirements of Relief Requested: ANO proposes to conduct additional sample testing in accordance with Code requirements

.except-as follows (excerpt from Unit 1 Technical-

-Specifications 4;16.1.d):

"If during the functional testing, additional sampling is required due to failure of only or.e type of snubber, the functional testing results shall be reviewed at the time to determine if additional samples should be limited to the type

.of snubber which has failed the functional testing."

Basis for Relief: It isLAh0's position that in some instancea limiting additional test sampics to snubbers of the same type as the-failed snubber adequately addresses Code requirements and in-fact may be conservativc with respect to-the Code requirement by targeting specific snubber types following certcin. types of failures. By making .

the determination en a case by case basis, assurance in provided that these instances which warrant a non-specific additional rample are addressed as well as those-situations in which a more specific. sample is appropriate. If additional sampling,is determined to be ~

applicable only to t.he same -type snobber as t he failed snubber, ~ the adaitional sampling wil; he targeted to the specific snubber type. That determination will-be based upon_ engineering judgement,-taking into account factors-such as-the failure mechanism, envircamental condiitons, size and manufacturer. By testing additional snubbers of the same . type, the extent of what appears to be a generic concern is determined .

conclusively..

Alternative Testing:- ANO proposes to select cdditional samples for snubber testing following. a discovered failure as identified in the " Relief Requested" section.

o

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<. r .

REQUEST FOR RELIEF TO CONDUCT SNUBBER TESTING

, IN ACCORDANCE WITH UNIT 2 TECHNICAL SPECIFICATIONS Components Shock Suppressors (Snubbers)

Code Requirement: 1WF-5400 Inservice Tests for Snubbers Less Than 50 kips "Suubbers that fail ... An additional sample of 10% of the total number of snubbers shall also be tested at that time. Additional sample testing shall be continued until all units witllin the sample have met the requirements of Relief Requested: ANO proposes to conduct additional sample _

testing in accordance with Code requirements except as follows (excerpt from Unit 2 Technical Specifications 3/4.7.8.d):

"If during the functional testing, additional sampling is required due to failure of only one type of snubber, the functional testing results shall be reviewed at the time to determine if additional samples shoald be limited to the type of snubber which has failed the functional testing."

Basis for Relief It is AN0's position that in some instances '

limiting additional tect samples to snubbers of the same type as the failed snubber adequately addresses Code requirements and in fact may be conservative with respect to the Code requirement by targeting specific snubber types following certain types of failures. By making .

the determination on a case by case basis, assurance is provided that those instances which warrant a non-specific additional sample are addressed as well as those situations in which a more specific sample is appropriate. If additionti sampling is determined to be applicable only to the same type snubber as the failed snubber, the additional sampling will be targeted to the specific snubber type. That determination will be based upon engineering judgement, taking into account factors such as-the failure mechanism, environmental conditions, size and nanuf acturer. By testing additiona' snubbers of the same type, the extent of whe appears to be a generic concern is determined conclusively.

Alternative Testing: ANO proposes to select additional camples for snubber testing following a discovered failure as identified in the " Relief Requested" section.

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