LR-N10-0363, License Amendment Request: Changes to Snubber Surveillance Requirements

License Amendment Request: Changes to Snubber Surveillance Requirements

ML102780066
Person / Time
Site:	Salem
Issue date:	10/04/2010
From:	Fricker C Public Service Enterprise Group
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
LR-N10-0363
Download: ML102780066 (26)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 O PSEG Nuclear LLC LR-N 10-0363 October 4, 2010 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 10 CFR 50.55a 10 CFR 50.90

Subject:

License Amendment Request: Changes to Snubber Surveillance Requirements Pursuant to 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests amendments to the Facility Operating Licenses listed above for Salem Generating Station, Units 1 and 2. The proposed amendments would revise the Technical Specification (TS) surveillance requirements (SRs) for snubbers to conform to planned revisions to the inservice inspection (lSI) program. to this letter describes the proposed changes and provides justification for the changes. PSEG has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92. Attachment 2 provides the marked up Technical Specification pages. Marked up TS Bases pages are provided for information only in Attachment 3.

PSEG Nuclear requests approval of the proposed amendment by October 4,2011. Once approved, the amendment shall be implemented within 60 days. Approval by the requested date will support implementation of the revised lSI program for Salem Unit 1.

There are no regulatory commitments contained in this letter.

These proposed changes have been reviewed by the Plant Operations Review Committee.

We are notifying the State of New Jersey of this application for changes to the TS and Operating License by transmitting a copy of this letter and its attachments to the designated State pfficial.

If you !have any questions or require additional information, please contact Mr. Paul Duke at 856-339-1466.

95-2168 REV. 7/99

LR-N 10-0363 October 4, 2010 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on _--.::::O:..:::c.:!:to~b.::::,er=-4..:,.t!-=2:..:::0..:..1 O~ __

(date) cc:

Administrator, Region I, NRC R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector - Salem P. Mulligan, Manager IV, NJBNE L. Marabella, Corporate Commitment Tracking Coordinator H. Berrick, Station Commitment Tracking Coordinator Salem Attachments (3)

1.

Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

2.

Markup of Technical Specification pages

3.

Markup of Technical Specification Bases pages (information only)

LR-N10-0363 October 4, 2010 Page 3 bcc:

President/Chief Nuclear Officer Site Vice President - Salem Plant Manager - Salem Director - Regulatory Affairs Manager - Licensing Regulatory Assurance Manager - Salem Manager - Program Engineering - Salem Records Management

LR-N10-0363 LAR S10-04 ATTACHMENT 1 License Amendment Request Salem Generating Station NRC Docket Nos. 50-272 and 50-311 Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

Subject:

Changes to Snubber Surveillance Requirements

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

7.0 REFERENCES

LR-N10-0363 LAR S10-04 Page 1 of 5 DESCRIPTION OF PROPOSED CHANGES, TECHNICAL ANALYSIS, AND REGULATORY ANALYSIS

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating Licenses DPR-70 and DPR-75 for Salem Nuclear Generating Station, Unit Nos. 1 and 2, respectively.

The proposed change would revise the Technical Specification (TS) surveillance requirements (SRs) for snubbers to conform to planned revisions to the inservice inspection (ISI) program.

2.0 PROPOSED CHANGE

TS Surveillance Requirement (SR) 4.7.9 would be revised to replace the TS requirements for snubber examination, testing and service life monitoring with reference to the inservice inspection program for snubbers. The revised SR 4.7.9 would be revised to read as follows:

Each snubber shall be demonstrated OPERABLE by performance of the program for examination, testing and service life monitoring for snubbers.

Reference to SR 4.7.9c in TS ACTION 3.7.9 would be replaced with reference to the program for snubbers.

3.0 BACKGROUND

For the current third 10 year inservice inspection intervals, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.9 in lieu of the requirements contained in American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI, Article IWF-5000. The NRC authorized use of TS 3/4.7.9 in lieu of ASME Code requirements pursuant to 10 CFR 50.55a(a)(3)(i) for the third 10-year ISI intervals for Salem Unit Nos. 1 and 2 (References 1 and 2, respectively).

10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of the 120-month inspection interval. If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program.

For the Unit 1 fourth 10 year ISI interval beginning May 20, 2011, as permitted by 10 CFR 50.55a(b)(3)(v), PSEG intends to adopt Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2004 Edition, in place of the requirements for snubbers in Section XI, Articles IWF-5200(a) and (b) and IWF-5300(a) and (b). PSEG also intends to adopt Subsection ISTD 2004 Edition for the remainder of the Unit 2 third 10 year interval which ends November 27, 2013.

The proposed changes to TS 3/4.7.9 are required to conform the technical specifications to the revised ISI program for snubbers.

LR-N10-0363 LAR S10-04 Page 2 of 5

4.0 TECHNICAL ANALYSIS

Licensees are required to perform the ISI and testing of snubbers in accordance with ASME BPV Code,Section XI or the OM Code and the applicable addenda as required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v), except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3). 10 CFR 50.55a(a)(3) states that licensees may use alternatives to the requirements of 10 CFR 50.55a(g) when authorized by the NRC if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

As noted in Regulatory Information Summary 2010-06 (Reference 3), licensees have the option to control the ASME Code-required ISI and testing of snubbers through their TS. For plants using their TS to govern ISI and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4),

licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRC-approved alternative used in lieu of the Code requirements. The TS governing the snubber ISI and testing program do not eliminate the 10 CFR 50.55a requirements to update the program at 120-month intervals, in accordance with 10 CFR 50.55a(g)(4), or to request and receive NRC authorization for alternatives to the Code requirements, when appropriate.

The proposed change replaces the specific TS requirements for snubber examination, testing and service life monitoring with reference to the program for examination, testing and service life monitoring for snubbers, thereby ensuring the TS are consistent with the revised program for Salem Unit 1. For Unit 2, the proposed change makes the TS consistent with Unit 1, thereby permitting use of common procedures for the Salem snubber program.

Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The change to TS ACTION 3.7.9 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.9. The program for ISI and testing of snubbers in accordance with ASME BPV Code,Section XI or the OM Code and the applicable addenda as required by 10 CFR 50.55a(g) is required to include evaluation of supported components/systems when snubbers are found to be unacceptable.

LR-N10-0363 LAR S10-04 Page 3 of 5

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes revise Surveillance Requirement 4.7.9 to conform the technical specifications to the revised inservice inspection program for snubbers. Snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g) except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

Snubber examination, testing and service life monitoring is not an initiator of any accident previously evaluated. Therefore, the probability of an accident previously evaluated is not significantly increased.

Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The proposed change to TS ACTION 3.7.9 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.9. Therefore the proposed change does not adversely affect plant operations, design functions or analyses that verify the capability of systems, structures, and components to perform their design functions. The consequences of accidents previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not involve any physical alteration of plant equipment. The proposed change does not change the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged. The methods governing plant operation and testing remain consistent with current safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

LR-N10-0363 LAR S10-04 Page 4 of 5

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes ensure snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g) except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3). Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The proposed change to TS ACTION 3.7.9 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.9.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, PSEG concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements/Criteria 10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of the 120-month inspection interval.

If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program.

The proposed change amends the TS Surveillance Requirements to conform the TS to the inservice inspection program for snubbers which shall meet the requirements of 10 CFR 50.55a(g) except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released LR-N10-0363 LAR S10-04 Page 5 of 5 offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

Salem Nuclear Generating Station, Unit No. 1 - Relief from ASME Code Requirements Related to the Salem Inservice Inspection Program, Relief Request S1-RR-F01, (TAC No. MB6098), Accession No. ML032090200

2.

Salem Nuclear Generating Station, Unit No. 2, Evaluation of Relief Request S2-I3-RR-F01 (TAC No. MC6668), Accession No. ML051180344

3.

NRC Regulatory Issue Summary 2010-06, "Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)," June 1, 2010, Accession No. ML101310338.

LR-N10-0363 LAR S10-04 ATTACHMENT 2 Salem Generating Station NRC Docket Nos. 50-272 and 50-311 Changes to Snubber Surveillance Requirements Markup of Proposed Technical Specification Page Changes Revised Unit 1 TS Pages 3/4 7-28 3/4 7-29 3/4 7-30 3/4 7-31 3/4 7-32 Revised Unit 2 TS Pages 3/4 7-23 3/4 7-24 3/4 7-25 3/4 7-26 3/4 7-27

PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All snubbers shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4. (MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, replace or restore t

. 0 erable

~r(s) to OPERABLE status and perform an engineering evaluation pe S

. c 0

~n the supported component or declare the supported system inoperable an appropriate ACTION statement for that system.

-t'" ~ '/\\'o 1,0 VV'" *0 C

~ ~ \\ v*~ c....e.....

\\ '\\. {<-

SALEM - UNIT 1 3/47-28 Amendment No. 297

PlANT SYSTEMS SlRVEII.LANCE REQUIREMENT Continued

b. Visual In ection Acee ta e Criteria

c.

Visual inspections sha verify (1) th there are visible indi ations of damage or impaired OP ABILITY. (2) ttachments to the fa dation or suppo 1n9 structure re secure, a (3) in those 1 cations where s bber movement n be manuall induced withou disconnnect1ng t snubber. that he snubber s freedom of mo ement and is not fro n up. Snubbers which appear inoperable as a esult of visual fnspee ons may be det 1ned OPERA for the purpo e of establishin the next visual lnspect10n 1 terval. prov1d1 that (1) the cause the rejection s clearly e ablished and re died for that part1 cul snubber and fo other sMubrs that may be "er1 cally suseept 'le; and (2) the affected sn bar is function 1y tested in the as fo d condition and eterminad ERABL! per Spec1 fcation 4.7.9d or 4.7.

as applicable. However, w en the fluid po of a hydraulic sn bar is found to uncovere, the snubber sha be declared 1 operable and can ot be deter. fned OPERABLE vi functional test 9 for he purpose of es abl1shing e next visual in pection interval All snubbers connee d to an i perable common h raulic fluid re rvoir shall be count d as fnopa able snubbers

• 1 months during sh tdown, a repres tative sample of lO~ of he total each type of sn ber in use in t plant shall be funct onally tes ed either in plac or in a bench t st. For each type of ubber tna does not meet th functional test ccaptance crfteri of pecificat on 4.7.9d or 4.7.

t an additional 10' of that type ubber shal be functionally ested

• The repre entative sample elected for func onal testing shal include the veri us configurat10

• operating env1 onments and the r ge of size a capacity of sn bers. At least 51 of the snubbe in the repre entat1ve sample hall include SMU Irs from the fol1 wing three cat arias:

1. The first sn ber away from ea

2. Snubbers thin five feet 0 heav,y equipment (~ lve, pump,

motor, c.)

3. Snubbers withtn ten fee of the dfseharge valve 1-30 t..~\\00~~

~/L/ 32 ~o",e...

ciQ..~e..t~.

SA LEM.. IJUT 1 3/4 7.29 Amendment No. 93

PtANT SYSTEMS SURVEILLANCE

d.

tion to, the

sample, bel's which ted.dudng installed in ed !Snubber (i the spare snubbers may ous functi st shall be iod. If a.p snubber has b failed snubber, both the f installed in...... DLIU *..,. position) retested.

results of next test e of a is repaired and shall be included fo~ the r functional i.e., frozen

.......... )01'... by manuf ac design subject ins either fails to lace, the cause will be design deficiency all the same defect shall be irement sh~ll be For the s shall be snubber(

dete~mi advers to the

2.

. This testing, requirements s ional test accep

1.

force that thet' tension maximum drag f above fot snubbers not criteria.

required, is at' tension. F lace W'lder withstand load verify that:

2.

) is achieved accelerat I

SALEM - UNIT 1

e*

/

PLANT SYSTEMS

" :1 I;,

SURVEILLANCE

f.

Snubber relea e rate, whe required, 's within the speeifi a range in Q mpression 0 tension.

For snubb s speoifica y required ot to displac under conti ous load, e ability of the s ber to wi tand load thout disp acement shal each signated se life*

installation and mainten ce records designated ervice life is based sha as requir a by Specif' ation 6.10.2.m.

rr the date enoes and the which the be maintained first inserv. ce visual inspection per 18 month thereafter, the ins allation an maintenance ecords for each snubber s

revi ed to verify, that the indicated service ife has not een exceede or will not be exceeded prior to th next sched ed snubber service life review. I the indicat ~ service life will be exceeded prior to he next se duled snubber service life review" the snubber service life shall be reevaluated or th snubber sh 1 be replaced or reconditioned so extend its service life beyond the date of the soheduled ervioe life review. This reevaluation, reconditioning sh~ll be indicated in

/

/

/

,/

SALEM -

UNIT 1

~dmen

/

TE.BLE Snubbers Population 1,2

!Category Colu

..3,6 xtend Interval Co 1M C5*6 Reduce Interval 1

150 Notes:

1.

2.

o a

o o

o 3

1 2

4 8

e next visual ins ection interval for the population 0 a

snubber category all be determi d based upon the mo recent inspection inter al and the numb r of unacceptabl~ s bbers found during that in erval: Snu~ber may be categorized based upon their access' ility during p er operation, as a essible or inaccessib These catego ies may be examine separately or jointly.

This decision s all be made and do mented before any inspect 'on and used as e basis upon whic to determine 7the next inspe ion interval f that category.

Int rpolation betw n population or ca egory sizes and the n er unacceptable s ubbers is permissi e.

Where the l~mit r

nacceptable sn bers in Columns A S, or C is determine by interpolation nd includes a fraa ional value, the lim', may be reduced to t e next lower inte r.

3.

If the nu er of unacceptab snubb~~~ is equal t or less than the nu r in Column A, t~ next inspection int val may be twice the pr vic'JS interval b i not greater than 48 onths.

4.

If e number of unac eptable snubbers is qual to or t

number in colu B but greater than e number in A,

e next inspecti interval shall be e same, as the c lnterval.

If *the number f unacceptable sn bers is equal t or greater than' the nu er in Column C, t e next inspeotio interval s~all be two-th' ds of the current interval.

Howev

, if the*numbe of unaccept le snubbers is ss than the numb in Column C t

greate than the number 'n Column S, the interval s 11 be redu d proportionall by interpolatio is:

I,..

where:

I Io U

B C

Io

=

next ' spection umber of unacce able snubbers f the previous ' spection interval number in lumn 6 number n Column C during

6.

The provi 'ons of Specifi ation 4.0.2 are inspection intervals up 0 and including 4 cable for all Amendment No. 161

PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMITING CONPITION FOR OPERATION 3.7.9 All snubbers shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4. (MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, replace or restore the inoperable

~r(s) to OPERABLE status and, perform an engineering evaluation pe~c;pto[j)

~on the supported component or declare the supported system inoperablean appropriate ACTION statement for that system.

SALEM - UNIT 2 3/47-23 Amendment No. 279

s

b.

V ual inspections sha verify (1) that here are no visible ndications of damage r impaired OPERA ILITY t (2) tachments to tne foundation or suppa n9 structure ar secure, and

3) in tnose locations where s ber movement can be manually nduced without disconnnect1ng t snubber, that t snubber ha freedom of move nt and is not froz up.

Snubbers w feh appear i operable as a r ult of ons may be deter ned OPERAS for the purpose of he next visual i spect10n int rval. providing hat (1) the cause the rejection f clearly est 11shed and reme ed for that particula snubber and for ther snubber that may be ge r1cally suscepti e; and {2} the fected snubb r is functional tested in the as fou condition and d term1ned OPE BLE per Specifi atfon 4.7.9d or 4.7.

as applicable.

owever, when he fluid port 0 a hydraulic snu r is found to b uncovered, t e snubber shall e declared in rable and canno be determin OPERABLE via f etional testin t

purpose of est 115h1n9 the xt visual inspe ion interval.

ubber5 connecte to an 1noper 1e common nydra lie fluid rese shall be counted as inoperable snubbers.

At least on e per 18 mont during shutdow, a represent VI sample of 10% of th total of each ype of snubber n use in the p ant shall be function 1y tested eit er in place or i a bench test For each type of snub er that does n t meet the funet anal test a tance crfteria of Spe ification 4.7. d or 4.7.ge. an dd1tional 10%

that type of snub r shall be fun t10nal'y tested Tn representative sample selected for functional t e various confi uratio"s, opera 1n9 enviro ize and caple1 of snubbers.

t least 25% of representative ample shall in ude snubbers f categories;

1. The fir. t snubber away

2. Snub ers within five eet of heavy mo r. etc.)

esting shall in ude and tt'le range snubbers 1 n the fo 11 0.1 n

• turbine.

3. Snubbers within t n feet of the di harge from a s ety relief val v.

1-1-1 SA IlM

• UNIT 2 3/4 7*24 Amendmen t No. 68 I

I

PUNT S,{S1'~S SuRVULtA."lCE REQUIREMENTS (C¥inued) '.

.............. aa..............

~..... ~.*

Q...................

.=====~

d *

e.

In addition t the regular sample;,,!:! tlb~ers which failed the pnviousf tional test shal.:. be'tQsted during t~ next cest period, I a spare snubber has b en installed in p~ce of a failed s ubber, the>> both the ailed snubber (if it is repaired and instal ed in another positio and the spare s bber shall be

. rete ad: Test result-Lof ese snubbers may ot be7'nc1ded for the re-amphng.

f any snubber se~.c. d for functional sting ei~ner fails to lockup or fails to ove, i ***, frozen n place, (he cause will be evaluated and caused by manuf turer or~Sisn deficiency all snubbers of the ~ame design subje to the same defect shall~e functionally t sted. This tastin requirem,nt shall be in~e?endent of the requi ments stated abo forznUb ers not meeti g the functional est acceptance c teria.

For the ubber(s) fpund noperable. n engin.erin evaluation shall performed on t

• component~ which are su por~ed by che snubb (s). The purpo of this an~lnearing e~ra 6at1on shall be to termine if the omponents s~pported by t snubber(s) were ad rsaly affected y the inope~bility of t snubber(s) in

~

o der to ensure at the suppo tod componen remains capabl~f eeting the des gned service.

The hydr lie snubber f etional tes~, sh~ll verify

1.

tivation (res raining aetio~ is achieved within the specified ran of velocity r acealarati in both tension and 1,)'J)l't'ession.

2.

Snubber baed. or reiaa ratFl~ \\~her.i equired, is within

• speCified r ge in compre,siorl or tension, For snub be s specifit,;ally required tCl cSt displace under cont' load~ the ability of the snubber 0 withstand load withe t dis aeement shall e verified.

ctional Ace tanee Criteria Th mechanical snu b~~ fun~tiona~test shall verify at:

1.

The force at i.nitiate. free movement of the snubber rod in e her tension 0 compression is les than the specified maximum ijrag force.

Ac vat ion (restra ning action) is ach eved within the ecified range 0 velocity or accel ation in both tension and com ession.

o SALEM - UNIT 2 3/4 7-25 Amencimen t No. 75

/'

/

PLANT SYSTEMS SURVEILLANCE REQUI SALEM -

3.

rat, where required, i i

oompression or tens' on. For snubbers speoifically re ired not to displac under continuous load, the ~il' y of the snubber t withstand load w displac.~ent hall be verified.

mainte os reoords on whic

.shall be maintained o

each snubber, mmences and the the designated date at which stallation and nioe life is oification 6.10.2.m.

s required by S

/

current with the fi inspeotion an at east once per 18 mo s thereafter, e installation d

maintenanoe records for each snubb shall be review to verify that the indicate service life s not been excee d or will not be exceeded rior to the ne scheduled an r servioe life review. If the indioated serv' e life will be ceedad prior to the next soh uled snubber rvice life revi

, the snubber servioe lif shall be ree~ luated or the s r shall be replaoed recondition so as to exten 1ts beyond da te of the t scheduled. s nioe life review.

is reeval ant or reoondit' ninq shall be in. atad Amendment I

LE '1~

AL

~fumbe r 0 f pn Snubbers

~ - -- - - - - - - - - - - -- - - - -. -- - -. - -- - - - - -7~ -- - -- - -- ~ - - -

Column A3,6 Col'lmn B4,6 e'olumn C5,6 Population 1,2

/Category Extend Repeat

/

Reduce Interval Interval Interval 1

80 100 150 Note.

/

o o

o o

o 1

3 4

8

1.

The next v' ual inspection po ulation of a snubber c tegory shall be etermined based on the most recent inspect on interval and he number of una eptable snubbers fa durin that interval.

snubbers may be tegorized, based up the' ion, as accessible e categories may e examined separate or This de and documented be are any inspection an used as the basi upon which to deter 'ne the next inspection i terval for that tegory.

2.

Interpola lon between popu tion or category s and the number of unac ptable snubbers s permissible.

the limit for unacc table snubbers' Columns A, B, or s determined by inte polation and in udes a fractional v ue, the limit re uced to the nex~ iower integer.

3.

f the number of *(inacceptable snubb s is equal to or le s than the number in lumn A, the next. spection interval y be twice' the previous nterval but not 9 ater than 48 month.

4,

5.

If the nu ar of unacceptabl less than the numb r in Column B but reater than the Column A, the ne t inspection inte val shall be the s current inty al.

~_t~e number of u is equal to or greater han-the number' Column C, the n inspection interval shall be two-thirds the current int val.

However, if the numbe of nubbers is less an the number in Column C b t greater the number in umn 8, the next interval s 11 be reduced roportionally by 'nterpolation, that is:

I,

=

Io where:

I, I

UI B

C

=

=

U -

B c - B next inspection int val current inspect' n interval number of un oceptable snubbers fa d during s inspection interval number B

nu er in Golumn C

6.

The provisions of Spe 1fication 4.0.2 are inspection interval up to and includin for all SALEM - UNIT 2 3/4 7-27 Amendment No. 142

LR-N10-0363 LAR S10-04 ATTACHMENT 3 Salem Generating Station NRC Docket Nos. 50-272 and 50-311 Changes to Snubber Surveillance Requirements Markup of Technical Specification Bases Page Changes (for information only)

Unit 1 TS Bases Pages B 3/4 7-6 B 3/4 7-7 Unit 2 TS Bases Pages B 3/4 7-6 B 3/4 7-7 LR-N10-0363 LAR S10-04 INSERT 1 The program for examination, testing and service life monitoring for snubbers is required to be performed in accordance with ASME BPV Code,Section XI or the OM Code and the applicable addenda as required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v), except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

PLANT SYSTEMS EASES 3/4,7,9 SNUBBERS All snubbers are required OPERABLE to integrity of the reactor coolant system and all other safety systems is maintained during and following a seismic or otha initiating dynamic loads.

Snubbers excluded from i

~ pe t' n program are those installed on nonsafety related systems an 0- Y:L their failure or failUre of the system on which they wereld.!!fl:allad, would :Z* 1 no adverse effect on any safety related system.

l r-.J S ~R '\\ L location plant op dations of snubbQr

50.

The vis level of sn interval v be operable per the of snubber location and

" plant iri accordance

,sibili of each snubber upon mainta'ning a constant

, efore, the quired. inspectio /

snubber fai es and is rs found uring an inspec 'on.

may ba used II inspections are catago ing reactor Q ration),.

be twice, the same, or f the prev:i.

s inspection 'terval. This,.-

unacceptab e snubbers fo d in proportion in each ea qory from the ost recent increased to 48 months' few una~cep inapections.

'!'he visual in paction interv:

48 months However, a for all surv.' lance activi llowable tol ances of 25%

e applicable stablishea rae limits for determining

%Val corraspo ding to the p ulation of e tegory that

. ffer. from e rapreaantat e sizes s for the nax inspection in erval may c. ound. by olation fr the limits p ovidad in Col s A, S, and Where the for unacc ptable snubber in Columns A 2, or C is ermined by interpolation

d. includes a ractional val e, the limit y be reduced to the next low r integer.

'.rh first inspec on interval d te:m.inad using Table 4.7-shall be basad upon the prev' us inspection interval as establis d by the requir ents in affe t be fora amen ant (161).

Any inspec 'on whose result a sho ter inspectio interval will override the previous SALEM -

tJNI'r 1 B 3/4 7-6 Amendm.ent No. 225

e*

e-PLANT SYSTEMS

.';i... ~<.... !,..

'!,,: i:.

BASES SNUBBERS (Continued) ubber is c.early established and snubbers t may be nerically ctional t ting, that nuhber may be Gener' ally susce ible snubbers or model d have the same design i

d to reject'on of the s ubber by v ual inspect'on or or exposed the conditions such as and vibr tion, is found inoperable, n engineer'ng evaluati t

determinat on of the s ubber mode f

afetYMrelat h

inoperabili e whether not the sn ber mode 0 significant effect or d radation on the support d ubber funct anal reliabi ity, a repre will be ctionally sted during downs at 18 month interv ls, Observ d failures 0 these sample snubbers ting of ad ent or other. exemptions rom the surve llance progr for individua snubbers ma be granted y the Commis on if a just'fiable basis for exem tion is pres nted and, i applicable, ubber life structive testin was performe to qualif the snubbers ble design condi ons at eith the campl ion of their abrication 0 at a subsequen date Snubbers so exempted s 11 be listed the list of individual sn cating the e tent of th Hydraul'c snubbers different e ity for th service lif of a snubber's evaluated input and on through onsideration 0 the snubbe service condi ons and ed install ance recor (newly instal ed snubber, in radiation area, in high t mperature ar etc."

),

The r irement to m iter the s ubber service fe is includ d to en ure that the snubbers perio ically und go a performan of their age a d operating 00 ditions.*

ese records wi bases for fut re considerati n of snubb r service life.

The require ents the maintena ce of records nd the sn ber service life review are intended to affect plant o. eration.

SALEM M UNIT 1 Amendment No, 161

( * *****

PLANT SYSTEMS BASES

~~=~~~~===~==========~==~==~-

~~--===~=~======~~===================~~~===

3/4.7.9 SNUBBERS All snubbers ensure that the structural all other safety related systems

~~~~~~~Rr other event initiating dynamic on nonsafety related systems system on which they were ~~~~~~~~~~~

safety-related system.

rs required to be operable per the technical specifications

' formation of nubber lac tion and size and of system affecte lable at th lant in a ordance with Section 50.71(c) of bilityof ch snubber all be determined nd approved y the Stati Operation Review Co

'ttee.

The ion shall b existing r iation lev perform a v; ual inspect'on in each ubber loca on as well fact rs associate with access' ility duri plant ope tions (e.g,/.

te erature, at sphere, lac ion, etc.)

nd the endations a Regulatory ide 8.8 and

.10.

The a ition or d etion of snubber sha' be made in

.59 of 10 R Part 50.

visual ins ction freq mainta'ing a const snubber pr tection to the qui red inspe tion inte varies i versely wi the observ ~ snubber fa' Utes and is termined by he number 0 inoperable snubbers fa d during an nspection.

I spections rformed bef e that int rval has el sed. may be,ed as a new r erence point to de rmine the ext inspect' n.

The ins 6tions are per ormed for each cate ry of snub ers.

The s bbers are c (gorized by ac essibility cessible 0 inaceessib during reae r operation).

The next vis category y be twice, e same, or red ced by as mue two-irds of t e previous ' spection inte val.

This int rval depends 0 the nu er of una ceptable snu ers found in roportion to e total numbe of ubbers in each categor from the mas recent inspect'on.

Intervals may be increased p to 48 man s if few unac eptable snubbe s are found in hese inspect' ns.

The vis al inspection nterval will t exceed 48 mo ths.

Howev I as for all surveillance tivities, unle s otherwise no d, allowabl tol ances of 25%

re applicable for snubbers.

able 4.7-3 est lishes thr l' its for deter ining the nex visual inspec on interval co esponding the population of each categ y of snubbers.

For a category that differ from the represen tive sizespr vided, the val s for the next nspection ' terval may be fou by interpoia on from the li its provided in Columns A,

, and C.

Where the imit for una eptable snubbe in Columns A,

, or C is termined by inte alation and i eludes a fracti nal value, the imit may be reduced to the n t lower integ The first i pection interv determine using Table 4.7-shall be bas upon the previ us inspection' terval as e tablished by the requirements' effect before menclment (142)

Any inspec ion whose results require on interval w' 1 override schedule.

SALEM - UNIT 2 B 3/4 7-6 Am~ndment No. 142

3/4.7 PLANT SYSTEMS BASES

~=~======~========~============~~=====~=============~===~=========~==:

SNUBBERS (Continued) t e rejection~f a snubber is clearly established and remedied for t snubb and for a ;f other S~bbers that may be generically nd verifed by inser ice funct'onal testing, that snubber may be exempted fr m being unted as i perable.

Generically/susceptible snubbers are those hich are of a specif'c make odel and h 1e the same d~sign features directly elated to r jection 0 the snubbe by visual in£pection or are si llarly,'lo ated or exp sed to th, mental condi~/ions, such as temp ature, r

iation, vibratio

/

ff

/'

When snubber is ound inop rable, an e ineering evay{lation is erformed, in addition to the de rmination 0 the snubber~de of failure, ~n order to etermine i any safet -related co ~onent or sys'Sfom has been i/

adverse y affected y the inop rability of he snubber. Jhe engineering~

evalu ion shall termine w ther or not the snubber ~{je of failure rrs impa ted a 5igni icant efte or degrada ion on the su orted compon7en~ or sys em.

To pro ide assura ce of snubbe functional r~abilitY, a reJresentative sample of e installe snubbers w' 1 be function9tly tested duri/g plant shutdown at lS-mont intervals.

Observed failu~ks of these za tle snubbers shall r qUlre funct'onal testin of additional units, 2ermanent 0 other exe, tions from the ~veillance prJgram for vidual snub rs may be ~anted by the CO~~~Sion if a ~6stifiable basis exemption's presented and, if applica e, snubber 1if~ destructive

, asting was fl' rformed to ualify the snub ers for the ap licable design conditions either th completion of t eir fabricatio or at a subsequ nt

date, Snu ers so exe pted shall be l' ted in the lis of individual s ubbers the exten of the exemptio s.

ydraulic sn,bbers and mecha~ cal snubbers m ent entity or the aboveJU ~eillance progr m.

The ser~ ce life of a snu er is evaluate via manufacture~ input and information rough considerat on of the snu~r service condit' ns and associated 'nsta1lation and intenance reco s (newly install snubber, seal replaced, spring replaced, 'n high radiatioy area, in high te erature area, etc.., ).

The requirement to monitor the $nubberservice li is included to ensure hat the snubbers; eriodically ungirgo a performance evaluation in view of their age and operatung conditions. ~h~se records will provide statistical bases for future consi~ration of snubger service life.

he requirements for the maintenance of re/ords and the sn4bber service life eview are not intended to affect plant operation.

SALEM - UNIT 2 B 3/4 7-7

~nendment No. 142