ML17325A221

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Proposed Tech Specs Modifying Functional Testing Surveillance Requirements for Unit 1 & Increasing Length of Surveillance Interval & Correspondingly Increasing Number of Snubbers Tested for Unit 2
ML17325A221
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 07/22/1987
From:
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17325A220 List:
References
NUDOCS 8707270360
Download: ML17325A221 (14)


Text

ATTACHMENT 2 TO AEP:NRC:0931B REVISED PAGES FOR THE DONALD C. COOK NUCLEAR PLANT UNIT NOS. 1 AND 2 TECHNICAL SPECIFICATIONS

Pt,ANT SYSTEMS:-

3 4.7.8 SNUBBERS LIMITING CONDITION FOR OPERATION 3,7.8 All snubbers listed in Table 3.7-.4 shall be OPERABLE APPLICABILITY: MOOES 1, 2, q 7 d OPl INILE

'DES).

3 and 4. (MOOES 5 and 6 for snubbers located on 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 snubber(s) to OPERABLE status and perform an engineering evaluation per Specification 4,7.8.c on the supported component or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SURV'EILLANCE RE UIREMENTS 4,7.8 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.**

a. Visual Insoec-.',cns The first inservice visual inspection of snubbers shall be performed after four months but within 10 months cf ccmmencing POWER OPERATION and shall include all snubbers listed in Tatle 3.7-4. If less than two (2) snubbers are found inoperable during the first inservice visual inspection, the second inservice visual inspection shall be performed l2 months ~ 25% from the date of the first inspection.

Otherwise, subsequent visual inspections shall be performed in accordance wi:h :he following schedule:

No. Inoperable Snubbers Subsequent Visual er insoection Period Insoec.ion Peri od*4 0 18 month", 25m 1

12 months = 25m 2 6 months days - 25'24 25 v 5,6,7 62 days - 25 x 8 or more 31 days The snubbers may be categorized into two groups: Those accessible and those inaccessible Curing reactor operation. Each group may be inspected independently in accordance with .he above schedule.

"The inspection interval shall not be lengthened more than one step at a time.

HThe provisions of Specification 4.0.2 are not applicable.

    • The provisions of Specification 4.0.6 are applicable.

D. C. Cook Unit l 3/4 7-28 Amendment No-

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PLANT SYSTEMS SURVEILLANCE RE UIREMENTS Continued sua ns ect>on cce tance Cr>ter>a Visual inspections shall verify (1) that there are no visible indications of damage or impaired OPERABIL[TY, (2) attachments to the foundation or supporting structure are secure, and (3) in those locations where snubber movement can be manually induced without disconnecting the snubber, that the snubber has freedom of movement and is not frozen up. Snubbers which appear inoperable as a result-of visual inspections may be determined OPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that=may be generically susceptible; and (2) the affected snubber is func-tionally tested in the as found condition and determined OPERABLE per Specification 4.7.8.d. However, when the fluid port of a hydraulic snubber is found to be uncovered, the snubber shall be determined inoperable and cannot be determined OPERABLE via functional testing for the purpose of establishing the next visual inspection interval. All snubbers connected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.

c. Functional Tests At least cree per 24 months during shutdown, a representative sample

<14>,~ of the total or each type of snubber in use in the plant shall be functionally tested either ir, place or in a bench test. For each snubber that does not meet the functional test acceptance criteria of Specification 4,7.8.d an additional 10% of that type of Snubber shall be functionally tested.

The representative sample selected for functional testing shall include the various conf'gurations, operating environments and the range of size and capacity of snubbers. At least 25K of the snub-bers in the representative sample shall include snubbers '.rom the following three categories:

1. The first snubber away from each reactor vessel nozzle
2. Snubbers within S feet of heavy equipment (valve, pump, turbine, motor, etc.)
3. Snubbers within [0 feet of the discharge from a safety relief valve Snubbers identified in Table 3.7-4 as "Especially Oifficult to Remove" or in "High Radiation Zones Ouring Shutdown" shall also be included in the represer ta tive sampl e. ~

Permanent or other exemptions from functional testing for individual snubbers in these categories may be grantea by the Comnission only if a jus=ifiable basis for exemption is presented ard/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their fabricat',on or at a subsequent date.

0, C. Cook-Uni t 1 3/4 7-29 Amendment No.

PLANT SYSTEMS BASES 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM The OPERABILITY of the control room emergency ventilation system ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent.

This limitation is consisten with the requirements of General besign Criteria 10 of Appendix "A", 10 CFR 50.

3/4.7.6 ESF VENTILATION SYSTEM The OPERABILITY of the ESF ventilation system ensures that radio-active materials leaking from the ECCS equipment within the pump room following a LOCA 'are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the accident analyses.

3/4.7. 7 SEALED SOURCE CONTAMINATION The limitations on sealed sour'ce removable contamination ensure that the total body or individual organ irradiation does not exceed allowable limits in the event of ingestion or inhalation of the probable leakage from the source material. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium. guantities of interest to this specification which are exempt from the leakage testing are consistent with the criteria of 10 CFR Parts 30.11-20 and 70.19. Leakage from sources excluded from the requirements of this specification is not likely to represent more than one maximum permissible body burden for total body irradiation if the source material is inha1ed or ingested.

3 4.7.8 HYDRAULIC SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the reactor coolant system and all other safety related systems is maintained during and following a seismic or other event initiating dynamic loads. Snubbers excluded from this inspection program are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed, would have no adverse effect on any safety-related system.

D C COOK-UNIT 1 B 3/4 7-5

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BASES Continued The visual inspection frequency is based upon maintaining a constant level of snubber protection to systems. Therefore, the required inspection interval varies inversely with the observed snubber failures and is determined by the number of inoperable snubbers found during an inspection. Inspections performed before that interval has elapsed may be used as a new reference point to determine the next inspection. However, the results of such ear ly inspections performed before the original required time interval has elapsed (nominal time less 25%) may not be used to lengthen the required inspection, interval. Any inspection whose results required a shorter inspection interval will override the previous schedule.

When the cause of the rejection of a snubber is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible, and verified by inservice functional testing, that snubber may be exempted from being counted as inoperable. Generically susceptible snubbers are those which are of a specific make or model and have the same design features directly related to rejection of the snubber by visual inspection, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.

When a snubber is found inoperable, an engineering evaluation is performed,.in addition to the determination of the snubber mode of failure, in order to determine if any safety-related component or system has been adversely affected by the inoperability of the snubber. The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a significant effect or degradation on the supported component or system.

To provide assurance of snubber functional reliability, a representative sample of the. installed snubbers will be functionally tested during plant shutdowns at 24 month intervals. Observed failures of these sample snubbers shall require functional testing of additional units.

The service life of a snubber is evaluated via manufacturer's input and information through consideration of the snubber service conditions and associated installation and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc...). The requirement to monitor the snubber .service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions. These records will provide statistical bases for future consideration of snubber service life. The requirements for the maintenance of records and the snubber service life review are not intended to affect plant operation.

The number of snubbers to be functionally tested during each surveillance is based on calculations performed to allow extension of the surveillance interval from 18 months to 24 months, and therefore, the number of snubbers functionally tested deviates from the number required by the westinghouse Standard Technical Specifications (NUREG-0452, Revision 4).

D. C. COOK - UNIT I B 3/4 7-6 Amendment No.

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PLANT SYSTEMS 3/4,7,7 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.7.1 All snubbers listed in Table 3.7-9 shall be OPERABLE.

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

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 snubber(s) to OPERABLE status and perform an engineering evaluation per Specification 4.7.7. l.c on the supported component or declare the supported system inoperable and follow the appropriate ACTION statement for that, system.

SllRVEILLANCE RE UIREMENTS 4.7.7. 1 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.*+

Visual Ins ection The first inservice visual inspection of snubbers shall be performed af.er four months but within 10 months of commencing POWER OPERATION and shall include all snubbers listed in Table 3.7-9. If less than two (2) snubbers are found inoperable during the first inservice visual inspection, the second inservice visual inspection shall be performed 12 months + 25K from the date of the first inspection.

Otherwise, subsequent visual inspections shall be performed in accordance with the following schedule:

No. Inoperabl'e Snubbers Subsequent Visual,<

Der Inspection ?eriod Insoection Period*

0 18 months = 25>

1 12 months = 25~

2 6 months 25>

3,4 124 days + 25>

5,6,7 62 days + 25>

8 or;.ore 31 days ~ 25~

The snubbers may be c tegorized into two groups: Those accessible and those inaccessible during reactor operation. Each group may be inspected independently in accordance with the above schedule.

11 1 1 g 1 1 1 gg d 1 1 The provisions of Specification 4.0.6 are appli'cable.

iThe provisions of Specification 4.0.2 are not applicable.

D. C. Cook Unit 2 3/4 7-20 Amendment No.,

4 I

~J ~ r PLANT SYSTEMS SURVEILLANCE RE UIREMENTS Continued b, Visual Ins ection Acceptance Criteria Visual inspections shall verify ( 1) that there are no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are secure, and (3) in those locations where snubber movement can be manually induced without disconnecting the snubber, that the snubber has freedom of movement and is not frozen up. Snubbers which appear inoperable as a result of visual inspections may be determined OPERABLE for the purpose of establishing the next visual inspection interval, providing that ( 1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible; and (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specification 4.7.7. l.d as applicable. However, when the.

fluid port of a hydraulic snubber is found to be uncovered, the ".nubber shall be determined inoperable and cannot be determined OPERABLE via functional testing for the purpose of establishing the next visual inspection interval. All snubbers connected to an inoperablc common hydraulic fluid reservoir shall be counted as inoperable snubbers.

Ce Functional Tests At least once per 24 months during shutdown, a representative sample (14%) of the total of each type of snubber in use in the'lant shal 1

-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 4,7.7. 1.d an additional 10" of that type of snubber shall be functionally tested.

The representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capaci:y of snubbers. At least 25" of the snubbers in the representative sample shall include snubbers from the following three categories:

1. The first snubber away from each reactor vessel nozzle
2. Snubbers within 5 feet of heavy equipment (valve, pump, turbine, motor, etc.)
3. Snubbers wi:hin 10 feet of the discharge from a safety relief valve Snubbers identi, ied in Table 3.7-9 as "Especially Difficult to Remove" or in "High Radiation lones During Shutdown" shall also be included in the representative sample.>>

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

0. C. COOK - UNIT 2 3/4 7-21 Amendment No.

t 1

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A 0 S T The OPERABILITY of the ESF ventilation system ensures that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the accident analyses. r All snubbers are required OPERABLE to ensui e that the structural integrity of the reactor coolant system and all other safety related systems is maintained during and following a seismic or other event initiating dynamic loads. Snubbers excluded from this inspection program are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed, would have no adverse effect on any safety-related system.

The visual inspection frequency is based upon maintaining a constant level of snubber protection to systems. Therefore, the required lnspection interval varies inversely with the observed snubber failures and is determined by the number of inoperable snubbers found during an inspection.

Inspections performed before that interval has elapsed may be used as a new reference point to determine the next inspection. However, the results of such early inspections performed before the original required time interval has elapsed (nominal time less 25$ ) may not be used to lengthen the required inspection interval. Any inspection whose results required a shorter inspection interval will override the previous schedule.

When the cause of the rejection of a snubber is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible, and verified by inservice functional testing, that snubber may be exempted from being counted as inoperable. Gener ically susceptible snubbers are those which .are of a specific make, or model and have the same design features directly related to rejection of the snubber by visual inspection, or are similarly located or exposed to the same environmental conditions such as temperature, radiation,'nd vibration.

When a snubber is found inoperable, an engineering evaluation is per formed, in addition to the determination of the snubber mode of failure, in order to determine if any safety-related component or system has been adversely affected by the inoperability of the snubber. The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a significant effect or degradation on the supported coaponent or system.

To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested during plant shutdowns at 24 aanth intervals. Observed failures of these sample snubbers shall recpxire functional testing of additional units.

D. C. COOK - UNIT 2 B 3/0 7-5 Amendment No.

4 The service life of a snubber is evaluated via manufacturer's input and information through consideration of the snubber service conditions and associated installation and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc...) . The requirement to nenitor the snubber service life is included to ensure that the snubbers periodically undergo a perfornence evaluation in view of their age. and operating conditions. 'Ipse records wilL provide statistical bases for future consideration of snubber service life. The recpuxanents for the maintenance of records and the snubber service life review are not intended to affect plant operation.,

The number of snubbers to be functionally tested during each surveillance of the surveillance interval is based on calculations performed to allow extension functionally from 18 months to 24 months, and therefore, the number of snubbers Technical tested deviates from the numbe. reauired by the t;estinghouse Standard Specifications (NUREG-0452. Revision 4).

3/4-7. 8 SEAL193 SOUSE CC5TZ ~TICN The limitations on ratable contaaunation for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium. This limitation will ensure that leakage fran byproduct, source, and special nuclear material sources will not exceed allowable intake values.

3/4.7. 9 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occuring in any portion of the facility where safety related equipnent is located. The fire suppression system consists of the water system, spray and/or sprinklers, CO2, Halon and fire hose stations. The collec-tive capability of the fire suppression systems is adequate to minimize potential damage to safety related equipnent and is a major elarent in the facility fire protection program.

In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service.

D. C. COCK - UNIT 2 B 3/4 7-6 Amendment NO.

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