JPN-92-013, Proposed Tech Specs Pages 145b & 156 Re Visual Insp of Snubbers.Revised Safety Evaluation Encl
| ML20090K570 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/11/1992 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20090K560 | List: |
| References | |
| JPN-92-013, JPN-92-13, NUDOCS 9203190142 | |
| Download: ML20090K570 (8) | |
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4 ATTACHMENT I to JPN 92413 REVISED PAGES 145b and 156 TO PROPOSED TECHNICAL SPECIFIC ATION CHANGE I
SNUBBER VISUAL INSPECTION SCHEDULE (JPTS-91011) e New York Power Authority 3
JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50 333 DPR-59 9203190142 920311 PDR ADOCK OS000333 P
JAFNPP 3.6 - (cont'd) 4.6 (cont'd) 1.
Shock Suppressors (Snubbers) 1.
Shock Supp cews (Snubbars)
Applicability Acciicability Applies to the operational status of.the shock suppressors Applies to the periodic testing requirement for the shock (snubbers).
suppressors (snubbers).
Objective Objective -
To assure the capability of the snubbers to:
To assure the capability of the snubbers to perform their intended functions.
Prevent unrestrained pipe motion under dynamic loads as might occur during an earthquake or severe transient, and A!!ow normal thermal motion dudng startup and shutdown.
Specification Speci canon Each snubber shall be demonstrated operable by performance of the following augmented inservice inWon program.
1.
During s!i modes of operation except Cold Shutdown and 1.
All snuobers shall be categorized into two groups-those Refuekng, all snubbers which are required to protect the accessible and those inaccessible during reactor primary coolant system or any other safety related system operation. The visual incpcstion interval for each category or component shall be operable. During Cold Shutdown or of snubbers shall be determined based upon the criteria Refueling mode of operation, only those snubbers sha!! be provided in Table 4.6-1.
operable which are en systems that are required to be operable in these modes.
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JAFNPP 3.6 and 4.6 BASES (cont'd)
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supported component (s) associated with the inoperab!e snubber (s) and the resuits shall be documented. For a!! modes of operation except Cold Shutdown and Refueling, within 14 1.
Shock Suppressors days an engineering evaluation shall be performea to ensure that the inoperable snubber (s) has not adversely affected the Snubbers are designed to prevent unrestrained p;pa motion supported component (s). For Cold Shutdown or refueling under dynamic loads as might occur during an earthquake or mode, this evaluation snal! be completed within 30 days. A severe transient, while al:owing normal thermal motion during period of 7 days has been selected for repair or replacemed of startup and shutdown. The cons %,uence of an inoperable the inoperable snubber during cold shutdown or refuc!ing snubber is an increase in the probability of structural damage mode of operation becuase in these modes the relative to pioing as a resuit of a seismic or other event initiating procability of structure' damage to the p; ping systems would dynamic loads. It is therefore requirec det a!I snubbers be lower due to lower values of total s*resses on the piping required to protect the primany coolant system or any other systems. In case a shutdown is required,ine a!!owance of 36 safety system or component be operable' denny reactor hours to reach L cold shutdown condition will permit an orderfy operation. Snubbers excluded from this inspection program shutdown consistent with standard operating procedares.
are those installed on non-safety related system and then only j
' if their failure or failure of the system on which they are The visual inspection frequency is basec upon maintaining a installed would have no adverse effect on any safety-related constant leve! of snubber protectinn to systems. Therefore, the system. Because the snubber protection is required ony required inspection interva! varies inverse!y with the observed '
during low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (for norrnal sr.ubber fa!!ures and is determined by the number of ir.operabie operation) or 7 days (for coio shutdown or refue!;ng mode of snubbr-rs found during an inspection. Inspections performed operation) is a!! owed for repairs or replacement of the snuboer before that interval has elapsed may be used as a riew prior to taking any other action. Fo!!owing the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (or 7 reference point to determins the 9axt inspedjon. The day) period, the supported system must be declared inspections are performed for each category of snubbers. The inoperable and the limiting Cordition of Operation statement snubbers are categonzed by accessibility (i.e., accessible or for the supported system fo!! owed. As an a!temative to inaccessible during reactor operation). The next visual snubber repair or rectacement an engaeering evaluation may inspection for each category may be twice, the same, or be performed: to show that the inoperable snubba is reduced by as much as two-thirds of the previous inspection unnecessary to assure operability of the system or to meet the intervat. This interva! depends on the number of unacceptr.ble i
design criteria o' the system; and, to remove the snubber from snubbers found in proportion to the tota! number of snubbers the system. Witn one or mora snubbcts found snoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a visual irepection shall be performed on the a
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- j. 1 to JPN 92 013
- REVISION 1 TO SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES SN'JBBER VISUAL INSPECTION SCHEDULE (JPTS-91-011]
a
. ll DESCRIPTION OF THE PROPOSED CH ANGES A
This application for an amendment to the Jamos A. FitzPatrick Technical Sponifications proposes a revised schodu% for visualinspoction of chock suppressors (snubbors) Tho proposed changos are as follows:
Paco vi, Ust of Tablos item 4.6-1 Replace the title " Comparison of the James A. FitzPatrick Nuclear Power Plant inservico Inspection Program to ASME Inservico inspection Codo Requiromonts* and pago *157* with the following title "Snubbor Visual inspection !ntorval* and pago *161.*
i Pago 145b, Specification 4.6.11 Deleto the column tillos,"UMITING CONDITION FOR OPERATION" and
- SURVEILLANCE REQUIREMENT *
~ Replaco -
- Snubbord shall be v!sually inspected in accordance with the following schodulo:
t No.'Inoperablo Snubbers Subsequent Visual g
por Inspection Porlod _
inspection Porlod *#
O 18 months 125%
1 12 months 125%
2:
6 months
- 25%
. 3, 4 124 days 2 25%
5, 6, 7
-62 days 2 25%
8 or moro 31 days 125%
- Tho inspection interva! may not be extended more than one stop at the timo."
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- All snubbors shall be categorized into two grcups: thoce accessible arxl thoso l'
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' inaccessibio during reactor operation. The visual inspection interval for each category s
of snubbers shall be dotorminod based upon the critoria provided in Table 4.6-1,*
Page 145c, Specifications 3.6.l.2 and 4.6.l.1 i
Movo the beginning of Specification 3.6.l.2 from pago 145b to the top of the first column.
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' 1 to JPN 92-013 SAFETY EVALUATION (REVISION 1)
Pago 2 of 5 From Specification 4.6.l.1. doloto the foctnoto:
'# Tho snubbcts may bo categorized into two groups: Those accessible and thoso inaccessible durlag reactor operation. Each group may bo inspocted indopondently in accordanco with tho above schedulo."
Pace 145d, Spe,cifications 4.6.l.2 and 4.6.1.3 Movo the romainder of Specification 4.6.1.2 and all of Specification 4.6.l.3 to the end of the second column of pago 145c.
Pago 1450, Specificatica 4.6.l.4 Movo the romaindor of Specification 4.6.l.4 to the end of the second column of pago 145d.
,Pago 156a Basos 3.8 and 4.6 I Replaco the sontonco "However, the results of such early inspection performod before the original required fimo intorval has elapsed (nominal timo loss 25%) may not be used to longthen the requlred inspection intorval.'
with the following paragraph "The inspec'Jons are porformed for each catogory of snubbers. The snubbers ato catogorized by access!bility (i.e., accessibio or inaccessibio during reactor operation),
j The next visual inspection for each category may bo twice, the same, or reduced by
- as much as two-thirds of the previous inspection interval. This intarval doponds on the number of unacceptable snubbors found in proportion to the total number of snubbers in each category from the previous inspection. The intervals may bo increased up to 48 months if few unacceptablo rnubbors are found in the previous inspection. The visual inspection interval will not exceed 48 months. However, as for l
ett survoijanco activitlos, untoss othorwise notod, allowable tolerancos of 25% are applicablo for snubbors. Table 4.6-1 establishoJ throo limits for dotormining the next visual inspection interval correspondin0 to the population of each category of L
snubbers. For a category that ditfors from the representativo sizes providod, tho l
values for the next inspection interval may be found by intorpolation from the ilmits provided in Columns A, B, and C. Where the limit for unacceptablo snubbers in p
_ Columns A, B, or C !s determined by interpolation and includos a fractional value, the limit may bo reduced in the next lower integer. The first inspection interval L
dctorminod using Table 4.6-i shall be based upon the previous inspection interval as L
established by the ioquiromonts in offect beforo amendment (
)."
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Attachment il to JPN 92-043 SAFETY EVALUATION (REVVSION 1)
Page 3 of 5 P,ago_1,_56a, Bases 3.6 and 4.6 i Move the starting point of the paragraph "Tho visual inspection frequency. *, to the end of the second column of page 156.
Pago 157162, !ntentionally Blank Replace the phraso 'through and including 162* with the phraso "through and including 160-Ronumber the pag 3 as "157 160.*
Pages 161 and 162. Tao!o 4.61, insert a now Tablo 4.6-1, " Snubber Visual inspoction Interval."
ll.
PURPOSE OF THE PROPOSED CHANGES The proposed changos to Section 4.6.1 of the James A. FitzPatrick Technical Specifications reviso the schedulo for visual inspection of snubbers consistent with the guidanco provided in Genoric Lotter 90-09 (Reference 3). The revised visualinspection scheduto is based on the number of unacceptablo snubbors found during the previous inspection, the size of the various snubber populations or categorios and the longth of tne previous inspection interval.
Ill.
SAFETY IMPUCATIONS OF THE PROPOSED CHANGES Snubbers are designed to prevent unrestrained pipe motion under dynamic loads as might occur during an earthquake or sovoro trans!cnt, whilo allowing normal thormal motion during startup and shutdown. Those snubbers - nochanical and hydraulic, provido protection to the primary coolant aystem and other safety rotated components.
To ensure that the snubbors proporly perform their intended function, they are subjected to l-periodic functional and visual inspections. Functional tests verify that snubbers can operate within specific parameter limits. Visual inspections are the observation of the condition of installed snubbors to identify those that aro damaged, degraded, or inoperable. Visual examinations i
l complomont the functional testing program and provido additional assurance of snubbor operability.
l The existing survoillanco interval is based on an eightoon month operating cycle and the number of inoperablo snubbers found during the previous inspoction, regardless of the number of snubbers in that category. These critoria can result in excessive radiological personnel exposures and can entail a significant amount of sito resources which the alternato schedule will climinate.
This reduction is consistent with the Commission's policy statomont on Technical Specification improvements.
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Attachmont il to JPN 92-Ot3 SAFET( EVALUATION (REVISION 1)
Page 4 of 5 Although the now visua; inspoction schodulo wil! chango the methodology used in dolormining the duration betwoon visual inspections for the snubbor 3, the snubbers are still inspocted based on the number of unacceptable snubbers. There will be no changes to the interval for functional inspecticns which is based on the oporating cycle. The proposed inspection intorval was developnd based on an operating cycle of up to 24 months while maintaining tho samo confidence lovel in snubber oporability.
The grouping of snubbers allows cach group to bo inspected based on the failuio ratos for that l
particular grouping. Groups which fail visual :nspoction can thorofore bo inspected more troquently without requiring all snubbors to be inspected at the same rato. By concontrating p! ant resources on thoso snubbers which require increased visual inspection, those changos irnprovo plant maintenance whilo decreasing personnot radiation exposuros.
IV..
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordanco with the proposed Amendment would not involvo a significan; hazards considoration as defined in 10 CFR 5192, sinco it would not:
1.
Involvo a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes involve no hardwaro changes, no changos to the operaticn of
.the snubbers, and do not chango the ability of the snubbers to perform their intended functions. An increase in visual inspection frequency will not affect the confidence lovel in operability developed from functional testirig.
2.
create the possibility of a now or dinerent kind of accident from those previously evaluatod.
The proposed changos invoivo no hardware changes, no changos to the operation of the snubbors, and do not changc the ability of the snubbers to perform their intended funct!ons. The now visual inspection interva! does not change the love! of confidence in snubbor oporability developed from functional testing and thereforo no unroviewed failuro mechanism can result.
3.
- involvo a significant roduction in ths margin of safety.
The proposed changes involvo no hardware changos, no changos to the oporation of t
the snubbors, and do not change the ability of the snubbors 1o perform their intended functions. Tno proposed ams.snont incorporates the altomato Technical Specification requirements for visualinspection of noubbers identified in Genoric Lotter 90-09. The alternato visualinspection critoria considor the sizo of the category l
of snubbers when ovaluating inspoction intervals due to failure rates. They uo not l
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t l-Attachmont ll to JPN 92-013 SAFETY EVALUATION (REVISION 1)
Page 5 of 5 reduce the confidence level in snubbor operability. The functional testing requirements rombin enchanged and do r'ot toduce operabmty confidonco lovols.
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IMPLEMENTATION OF THE PROPOSED CHANGES
' mplementation of the proposed changos will not adverso!y affect the ALARA or Firo Protection i
Program at the FitzPatrick plant, nor will the changos impact tne environment. The results of these changes are expected to reduce the dose to plant personn31 since the number of
. Inspections performod in close proximity to radiological sources will be roduced. The proposed l
changes will_not change the inspection methodology currently in place and therefore can have no impact on the Firo Protectl21 program or the environment LVI}
CONCLUSION.
1These changos, as proposed, do not constitute an unroviewod safoty question as defined in 10 CFR 50.59. That is, they:
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will not inemaso the probability of occurronce or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis
' report;
- b. ' will not increase the possibility for an accident or malfunction of a typo difforont from any eveklated previously in the safety analysis report; c,
wi!! not reduce the margin of safety as defined in the basis for any technical specification; and d.: Invoivos no significant hazards consideration, as defined in 10 CFR 50.92.
c Vil.
REFERENCES
{1.
James A;FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Section 12.5.4.
2.
James A. FitzPatrick Nucioar Power Plant Safety Evaluation Roport (SER), dated November 20,1972, and Supplomonts.
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NRC Gonoric Letier 90-09, "Altomativo Requirements for Snubber Visua! Inspection intervals and Corrective Actions", dated Docomber.11,1990.
E4.
NYPA letter; J. C. Brons to the NRC, dated December 28,1990, (JPN/4078, IPN 060),TNew Projects."
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