ML17223B300

Amends 110 & 51 to Licenses DPR-67 & NPF-16,respectively, Revising Tech Specs Per Generic Ltr 90-09, Alternative Requirements for Snubber Visual Insp Intervals & Corrective Actions

ML17223B300
Person / Time
Site:	Saint Lucie
Issue date:	10/22/1991
From:	Berkow H Office of Nuclear Reactor Regulation
To:
Shared Package
ML17223B301	List: ML17223B300 ML17223B302
References
GL-90-09, GL-90-9, NUDOCS 9111120081
Download: ML17223B300 (23)

Text

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0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555 FLORIDA PONER 5 LIGHT COMPANY

'OCKET NO. 50-335 ST.

LUCIE PLANT UNIT NO.

1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.

110 License No.

DPR-67 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The. application. for amendment by Florida Power 8 Light Company, et. al. (the licensee)',

dated.. August-22;. 1991, complies with.

the standards and requirements of the Atomic Energy Act of 1954, as amended-;(the Act). and the Commission's rules and.regulations set forth in 10 CFR:Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by, this amendment, can be;conducted without. endangering the health and safety of. the public, and (ii) th'at suchactivities will be conducted in compliance with the Commission's regulations; D.

The issuance of'his amendment will,not be inimical to.the-common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the:Commission's regulations and.all., applicable requirements.,;:,

have. been -satisfied.

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2.

Accordingly, Facility Operating License No.

CPR-67 is amended by changes to the Technical-Specifications as indicated in the attachment to this license amendment, and hy amending paragraph 2.C.(2) to read as follows:

(2)

Technical S ecifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 110, are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Attachment:

Changes to the Technical Specifications.,

~ Herbert N. Berkow, Director Project Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Date of Issuance:

October 22, 1991

ATTACHMENT TO LICENSE AMENDMENT NO.

110 TO FACILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Replace the following pages of the Appendix "A" Technical Specifications with the enclosed pages..

The revised pages are identified by amendment number and contain verticalines indicating the area of'hange.

The corresponding overleaf pages are also provided to maintain document completeness.

Remove Pa es 3/4 7-29 W

3/4 7-30 3/4 7-31 Insert Pa es 3/4 7-29 3/4 7-29a 3/4 7-29b 3/4 7-30 3/4 7-31

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4 7.10 SNUBBERS LIMITING CONDITION FOR OPERATION QQRRRRRCSa mmR RaaaaSCRÃ$ 'SSCRRQQRQRRRRCCtCCQCC C

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. 3.7.10 All safety related snubbers shall be OPERABLE.

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1 d systems required OPERABLE in those MODES).

ACTION:

With one or more safety related 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 snubber(s) to OPERABLE status or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7'. IO:;

Each snubber o sha'll be-.demonstrated OPERABLE-by. performance: of. the.

foTTowfng augmented inservice inspection program.

b.

As used in this specification, "type of snubber" shall mean snubbers of the same design and manufacturer, irrespective of capacity.

Visual Ins ections Snubbers

.are.categorized

.as. inaccessible. or accessible. during reactor operation.

Each of these categori'es (inaccessibl'e or accessible) may be inspected independently according to the schedule determined by Table 4.7-3.

The.visual inspection interval for each category of snubber'hall be determined'tbasedd upon the criteria provided in Table 4.7-3 and the first inspection interval determined using this criteria shall be based upon the previous inspection interval as established by the requirements in effect before Amendment ST.

LUGIE UNIT I 3/4 7-29 Amendment No. Rb-44,83, 110, 51

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SURVEILLANCE RE(UIREHENTS (Continued)

C.

s Ins ection Acce tance Criteri Visual inspections shall verify that (1) the snubber has no visible indications of damage or impaired OPERABILITY, (2) attach-ments to the foundation or supporting structure are functional, and (3) fasteners for the attachment of the snubber to the compo-nent and to the snubber anchorage are functional.

Snubbers which appear inoperable as a result of visual inspections shall be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (i) the cause of the rejection is clearly estab-lished and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per specifica-tions 4.7. 10.e and 4.7. 10.f, as applicable.

All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable. for determining the. next -inspection

'nterval.

A'eview and evaluation shall be performed and docu-mented to justify continued operation with an unacceptable snub-ber.

If continued. operation cannot be. justified; the snubber shall be declared inoperable and the ACTION requirements shall be met.

TABLE 4.7-3 SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF UNACC PTABL SNUBBERS Population or Category Notes 1 and' Column A

Extend Interval Notes 3 and 6

Column B

Column C

Repeat Interval Reduce Interval Notes 4 'and 6

Notes 5 and 6

1 80 100.

150 200 300 400 500 750 1000.,or greater,.

12 20.

29..

3 5

12 18 24 40 56, 8

13 25 36 48 78 109 ST.

LUCIE UNIT, 1 3/4 7-29a Amendment No.

110, 51

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SURVEILLANCE RE(UIREHENTS (Continued)

CSQQRCS'RSRCCXCCSSSCCQO?RCQCL2$

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X2QSCR2CCQQRRZSCORRORRQCQRCSSSSR5tRSCSQ Note I:

The next visual inspection interval for a snubber population or category size shall be determined based upon the previous inspec-tion interval and. the number of unacceptable snubbers found during that interval'.

Snubbers may be categorized, based upon their accessibility during power operation, as accessible or inaccessi-ble.

These categories may be examined separately or jointly.

However, the--licensee must make and-document that decision before any inspection and shall use that decision as the basis upon which to'etermine the next inspection interval for that category.

Note 2:

Note 3:

Note '4:

Interpolation between population or category sizes and the number of unacceptable snubbers is permissible.

Use next lower integer for the value of the limit for Columns A, B, or C if that integer includes a fractional value of unacceptable snubbers as determined by interpolation.

If the number of unacceptable snubbers is equal to or less than the number in Column A, the, next inspection interval-may be twice the, previous interval but not greater than 48 months.

If th'e.number of unacceptable.snubbers.

is equal to or less than the number in Column B but greater than the number in Column A, the next inspection interval shall be the same as the previous inter-val.

Note 5:

If the number of unacceptable snubbers is equal to or greater than the number in Column C, the next inspection interval shall be two-thirds of the previous interval.

However, if the number of unac-ceptable snubbers-is. less..than.

the..number, 'in Column, C but. greater, than the number in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable'snubbers found during.

the previous interval and the number in Column B to the difference in the numbers in Columns B and C.

Note 6:

The provisions of Specification 4.0.2 are applicable for all inspection. intervals. up to.-.and including 48. months..

ST.

LUCIE UNIT"I" 3/4'-29b Amendment No'. 110, 51

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SURVEILLANCE REQUIREMENTS (Continued) d.

Functional Te ts At least once per 18 months during shutdown, a representative sample (10X of the safety related snubbers) shall be functionally tested either in place or in a bench test.

For each snubber that does not meet the functional test acceptance criteria of Specification 4.7. 10.e

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or 4.7.10.f, an additional 10X of that type of snubber. shall be, functionally,tested.

Functional test shall continue until no additional snubbers are found inoperable or all safety related snubbers have been tested.

The representative sample selected for functional testing shall include the various 'configurations, operating environments and the range of size and capacity of snubbers.

Snubbers identified as "Especially Difficult to Remove" or in "High Exposure Zones During Shutdown" shall also be included in the representative sample.,~ Safety related hydraulic.snubber listings and safety related. mechanical.

snubber",'1,istings"may.

be. used.-.jointly or.separately.,

as the basis,far the sampling plan.

In addition to'he regular

sample, snubb'ers which failed'the previous functional test shall be retested during the next test period. If a spare snubber has been installed in place of a failed snubber, then both the failed snubber (if it is repaired and installed in another position) and the spare snubber shall be retested.

Test results of these snubbers shall not result in additional functional testing due to failure.

• Permanent or other exemptions from the functional testing for individual snubbers in these categories may be granted by the Commission only if justifiable basis for exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their fabrication or at a subsequent date.

ST.

LUCIE UNIT I 3/4 7-30 Amendment No. 84-,44-,8$, 110, 51

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SURVEILLANCE REQUIREMENTS (Continued) asa-aa

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If any snubber selected for functional testing either fails to lockup'r fails to move, 'i.e., frozen in place, the cause will be evaluated and if caused by manufacturer or design deficiency, all snubbers of the same design subject to the same defect shall be functionally tested.

This testing requirement shall be independent of the requirements stated above for snubbers not meeting the functional test acceptance criteria.

H draulic Snubbers Functional Test Acce tance Criteri The hydraulic snubber functional test shall verify that:

1.

Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.

2.

Snubber bleed, or release

rate, where required, is within the specified range in compression or tension.

Mechanical Snubbers Functional Test Acce tance Criteria The mechanical snubber functional test shall verify that:

1.

The force that initiates free movement of the snubber rod in either tension or compression is less than the specified maximum drag force.

2.

Activation (restraining action) is achieved in both tension and compression.

g..

- Snubber Service ife Honitorin A record of the service life of each

snubber, the date at which the designated. service life commences and the installation and maintenance records on which the designed 'service life is. based shall be maintained as required by Specification 6. 10.2. 1.

Concurrent with the first inservice visual inspection and at least once per 18 months thereafter, the installation and maintenance records for each safety. related snubber shall be reviewed to; verify that the

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indicated:service life.has not been exceeded'r will"-not be exceeded by more than 10X prior to the next scheduled snubber service life review. If the indicated service life will be exceeded by more than 10X prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

The results of the reevaluation may be used to justify a change to the service life of the snubber.

This reevaluation, replacement or reconditioning-shall be indicated in the 'records.. ',

ST.

LUGIE UNIT 1 3/4 7-31 Amendment No. Rk

, 4~

110.

51

TABLE 3.7-2a In m

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555 FLORIDA POWER

& LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST.

LUCIE PLANT UNIT NO.

2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.

51 License No. NPF-16 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power 5 Light Company, et al. (the licensee),

dated August 22, 1991, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act). and,.the Commission',s rules,and regulations set forth in 10 CFR'Ch'apter I';

B.

The facility will operate in conformity with the application, the. provisions:" of. the. Act,. and the rules and. regulations. of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be, conducted in compliance-with the Commission's regulations;;

D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, Facility Operating License No. NPF-16 is amended by changes to the Technical Specifications as indicated'n the attachment to this license amendment, and by amending paragraph 2.C.2 to read as follows:

2.

Technical S ecifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. 51, are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION e

Herbert N.: Berkow', Director Project Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Speci fications-...

Date of Issuance:

October 22, 1991

ATTACHMENT TO LICENSE AMENDMENT NO.

51 TO FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Replace the following pages of the Appendix "A" Technical Specifications with the. enclosed pages.

The revised pages are identified by amendment number and. contain vertical lines indicating the area of change.

The corresponding overleaf pages are also provided to maintain document completeness.

Pemove Pa es XXV 3/4 7-21 3/4 7-22 3/4 7-23'/4.7-24 Insert Pa es XXV 3/4 7-21 3/4 7-22 3/4 7-22a 3/4 7-22b 3/4 7-23 3/4 7-24

~IND LIST OF TABLES (Continued) aaaaaaaaassaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaassaaaaaaassaaaaaaaaaaaaaaaaaaaaaaa

/ABEL 3.7-1 4.7-0

4. T-I 4.7-2 3 ~ 7 31 PAG MAXIMUMALLOWABLE LINEAR POWER LEVEL-HIGH TRIP SETPOINT WITH INOPERABLE STEAM LINE SAFETY VALVES DURING OPERA-TION WITH BOTH STEAM GENERATORS......................

3/4 7-2 STEAM LINE SAFETY VALVES PER LOOP....................

3/4 7-3 SECONDARY COOLANT SYSTEM SPECIFIC ACTIVITY SAMPLE AND ANALYSIS PROGRAM.....................................

3/4 7-8 SNUBBER VISUAL INSPECTION INTERVAL...................

3/4 7-22 SAFETY-RELATED HYDRAULIC SNUBBERS....................

3/4 7-26 3.7-3b SAFETY-RELATED MECHANICAL SNUBBERS...................

3/4 7-27 3.7-4

3. T-5 4.8-1 4.8-2 3.8-1 MOTOR-OPERATED VALVES THERMAL OVERLOAD PROTECTION BYPASS DEVICES....

3/4 8-18 FIRE HOSE STATIONS.................................

3/4 7-36 YARD FIRE HYDRANTS AND ASSOCIATED HYDRANT HOSE HOUSES 3/4 T-'3F DIESEL GENERATOR'TEST SCHEDULE;...........'.......,....,

3/4 8-8 BATTERY SURVEILLANCE REQUIREMENT....................

3/4 8-12 4.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS P ROGR" i....;...';...,.

4.11-2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS ROGRAMsos ~ ~ o ~ ~ ~ ~ ~ ~ o iot ~ ~ ~ ~ s ~ ~

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P 3/4. 11-.2 3/4 11-8 3.12-1 3.12-2 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM........

REPORTING LEVELS FOR RADIOACTIVITYCONCENTRATIONS IN ENVIRONMENTAL SAMPLES................................

3/4 12-3 3/4 12-7 B 3/4.2-1 ELETED..............................................

D B 3/4.4-1 REACTOR VESSEL TOUGHNESS.............................

4.12-1'ETECTION CAPABILITIES FOR ENVIRONMENTAL'AMPL'E':

NALYSIS~

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A 3/4 12-8 B 3/4 2-3 3/4 4-9 5.7-1 6.2-1 COMPONENT CYCLIC OR TRANSIENT LIMITS.................

5-5 MINIMUM-SHIFT CREW COMPOSITION TWO UNITS WITH TWO'-

.SEPARATE. CONTROL. ROOMS...,...........................,,.........6.-5:

ST.

LUCIE UNIT 2 XXV Amendment No. 8,

110, 51

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~E4 7.9 KNUBB RS LIHITING CONDITION FOR OPERATION ss ss a a ss a ss a a a a a a a a a ss a a a a a a a a a a a a a a a ss a a ss ss a ss a a a a a a ss ss a a a a ss ss a a 'a 'ss ss a a a a a a 3.7.9 All safety-related snubbers shall be OPERABLE.

APPLICABILITY:

NODES 1, 2, 3 and 4.

HODES 5 and 6 for snubbers located on systems required OPERABLE in those HODES.

ACTION:

With one or more safety related 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 snubber(s) to OPERABLE status and perform an engineering evaluation per Specification 4.7.9f.

on the supported component or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REOUIREHENTS aaaaassaaaaaaaaaaaaaaaaaa a-aaa aa aaaaaaaaaaassaaaaaassaassassssaaaaaaaaaaaaaa 4'.7.'9 Each snubber shall be'emonstrated-OPERABLE by. performance of: the.

following augmented inservice inspection program.

a.

Ins ection T es As used in this specification, "type of snubber" shall mean snub-bers of the same design and manufacturer, irrespective of capacity.

b.

Visual Ins ections Snubber.s are.-categorized.

as inaccessible or. accessible during reactor operation.

Each-:of these categories'inaccessibl'e or

'ccessible) may be inspected independently according to the schedule determined by Table 4.7-2.

The visual inspection interval for each category of--snubber:=shall be. determined: based'pon. the..criteria.,

provided in Table 4.7-2 and the first inspection interval determined using this criteria shall be based upon the previous inspection interval as established by the requirements in effect before Amendment ST.

LUCIE UNIT 2 3/4 7-21 Amendment No. 28,

110, 51

JP, T SYSTEMS, ~

SURVEILLANCE REQUIREMENTS (Continued) aaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaassaaaaaaaaaaaaassssaaaaaaaaa c.

Vi al Ins ection Acce tance Criteri Visual inspections shall verify that (1) the snubber has no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) fast-eners for the attachment of the snubber to the component and to the snubber anchorage are functional.

Snubbers which appear inoperable as a result of visual inspections shall be classified as unaccept-able and may be reclassified acceptable for the purpose of estab-lishing the next visual inspection interval, provided that (i) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as-found condition and determined OPERA-BLE per specification 4.7.10.e.

All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval.

A review and. evaluation shall. be performed and documented to justify contin-ued. operation. with arr unacceptable'snubber."

If-continued operation..

cannot be justified, the snubber shall be declared inoperable.

and the ACTION requirements;,shall.e met'..

TABLE 4.7-2 SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTAB SNUBB S

Population or Category Notes 1 and 2

-Column A; Column. B

.Column C

Extend Interval'.

Repeat "Interval "

Reduce Interval Notes 3 and 6

Notes 4 and 6

Notes 5 and 6

1

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80 100 0

0 0

0, 1

2 150.

200 300 3

5 12 8

13 25 400 8

500 12 750 20 1000 or greater--'-;

29 18 24 40 56 36 48 78 109 ST.

LUCIE UNIT 2.

3/4 7-22 Amendment No. 82-,-45,110, 51

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SURVEILLANCE REQUIREMENTS (Continued)

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The next visual inspection interval for a snubber population or category size shall be determined based upon the previous inspection interval and the number of unacceptable snubbers found during that interval.

Snubbers may be categorized, based upon their accessibil-ity during power oper ation, as accessible or inaccessible.

These categories may be examined separately or jointly.

However, the licensee must make and document that decision before any inspection and shall use that decision as the basis upon which to determine the next inspection interval for that category.

Note 2:

Note 3:

Interpolation between population or category sizes and the number of unacceptable snubbers is permissible.

Use next lower integer for the value of the limit for Columns A, B, or C if that integer in-cludes a fractional value of unacceptable snubbers as determined by interpolation.

If the number of unacceptable snubbers is equal to or less than the number. in Column. A,. the. next inspection interval,.may. be twice the previous.interval but not greater than;48 months.

Note. 4 If'he; number-of; unacceptabl'esnubbers is. equal, to...or less. than.the number in Column B but greater than the number in Column A, the next inspection interval shall be the same as the previous interval.

Note 5: If the number of unacceptable snubbers is equal to or greater than the number in Column C, the next inspection interval shall be two-thirds of the previous interval.

However, if the number of unac-ceptable snubbers is less than the number in Column C but greater than.the, number., in Column B,. the next,interval,shall, be reduced proportiona'lly:by int'erpoTation, that'is; the previous'nterval shall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable snubbers found during the'previous; interval and the numberin Column B.-to.the difference in the numbers in Columns B and C.

Note 6:

The provisions of Specification 4.0.2 are applicable for all inspec-tion intervals up to and including 48 months.

ST.

LUCIE UNIT 2 3/4 7-22a Amendment No. 110, 51

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QP ANT SYSTEMS

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SURVEILLANCE RE(UIREHENTS (Continued) d.

Functional Tests During the first refueling shutdown and at least once per 18 months thereafter during shutdown, a representative sample of either:

(I) At least 10X of the total of each type of safety related snubber in use in the plant shall be functionally tested either in place or in a bench test.

For each snubber of a type that does not meet the functional test acceptance criteria of Specification 4.7.9e.

an additional

[

IOX of that type of snubber shall be functionally tested until no more failures are found or until all snubbers of that type have been functionally tested or (2)

A representative sample of each type of snubber shall be functionally tested in accordance with Figure 4.7-1.

"C" is the total number of snubbers of a type found not meeting the I

acceptance requirements of Specification 4.7.9e.

The cumulative number of snubbers of a type tested is denoted by "N".

At the end of each day's testing, the new values of "N" and "C" (previous day' total plus cur rent day's increments) shall be plotted on Figure 4.7-1.

?f at any. time the point. plotted falls in the "Reject" region,, all snubbers of that type design shall be functionally tested.. If at any time the point plotted falls in the "Accept" region, testing of that type of snubber,-shall be. terminated.

When the point plotted lies in the "Continue Testing" region, additional snubbers of that type shall be tested until the point falls in the "Accept" region or the "Reject" region, or all the snubbers of that type have been tested.

The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size. and:capacity of'nubbers of each type.

The. representa-tive sample should be weighted to include more snubbers from severe-service areas such as near heavy equipment.

Snubbers placed in the same location as snubbers which failed the previous functional test shall be included in the next-test lot if the failure analysis shows that failure was due to location.

e.

Functional Test cce tance Criteria The snubber functional test..shall verify that-:

l.

Activation (restraining action) is achieved within the specified range in both tension and compression.

2.

Snubber bleed, or release rate where required, is present in both tension and compression, within the specified range.

3.

Where required, the force required to initiate or'maintain motion of the snubber is within the specified range in both directions.of. travel.

ST.

LUCI E UNIT 2 3/4 7-22b Amendment No.

110, 51

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SURVEILLANCE REgUIREHENTS (Continued)

F cti na cce tance riteri (Continued) 4.

For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement.

5.

Fasteners for attachment of the snubber to the component and to the snubber anchorage are secure.

Testing methods may be used to measure parameters indirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods.

Functional Test Failure Anal sis An engineering evaluation shall be made of each failure to meet the functional test acceptance criteria to determine the cause of the failure. The. resu'1ts. of this evaluation shall be used, if applicable, in selecting snubbers to be, tested, in an effort to. determine, the OPERABILITY of other snubbers irrespective of type which may be subject to the same.-failure, mode.

For the snubbers found inoperable, an engineering evaluation shall be performed on the components to which the inoperable snubbers are attached.

The purpose of this engineering evaluation shall be to determine if the components were adversely affected by the inopera-bility of the snubbers in order to ensure that the component remains capable of meeting the designed service.

If any snubber 'selected for functional testing either fails to lockup or fails to move, i.e., frozen in place, the cause will be evaluated and if caused by manufacturer or design deficiency all snubbers of. the'ame type subject to the same. defect shall. be functionally tested.

This testing requirement shall be independent of the requirements stated in Specification 4.7.9.e for snubbers not meeting the functional test acceptance criteria.

Func tonal Testin of Re aired and Re laced Snubbers Snubbers which fail the visual inspection or the functional test acceptance criteria shall be repaired or replaced.

Replacement snubbers and snubbers which have repairs which might affect the functional test result shall be tested to meet the functional test criteria before installation in the unit. These snubbers, shall have met the acceptance criteria subsequent to their most recent service, and the functional test must have been performed within 12 months before being installed in the unit.

ST.

LUGIE - UNIT 2 3/4 7-23 Amendment No. 110, 51

PLANT SYSTEMS SURVEILLANCE RE(UIREHENTS (Continued).

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Re lacement P o ra The seal service life of hydraulic snubbers shall be monitored to ensure that the seals do not.fail between surveillance inspections.

The maximum expected service life for the various seals, seal materials, and applications shall be estimated based on engineering information and-the seals. shall be replaced so that the maximum-expected service life does not expire during a period when the.

snubber is required to be OPERAHLE. The seal replacements shall be documented and the documentation shall be retained in accordance with Specification

6. 10.2.

Exem tion From Visual Ins ection or Functional Tests Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and, if applicable, snubber life destructive. testing was -performed to qualify the snubber.,for the applicabl'e design conditions-at. either'he 'compl'etion of-'heir fabrication or at a subsequent date.

ST.

LUGIE - UNIT 2 3/4 7-24 Amendment No. 88,

110, 51