ML18037A635
| ML18037A635 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/23/1993 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18037A636 | List: |
| References | |
| NUDOCS 9401050293 | |
| Download: ML18037A635 (109) | |
Text
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROGANS FERRY NUCLEAR PLANT (BFN)
UNITS 1g 2i AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-346 MARKED PAGES SEE ATTACHED 0
940i050293,931223 PDR ADOCK'05000259 P PDR
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ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROGANS FERRY NUCLEAR PLANT (BFN)
UNIT 1 PROPOSED TECHNICAL SPECZFZCATZON (TS) CHANGE TS-346 MARKED PAGES
SEP 2 2 8'93
~be Title ~Pa e Ho 4.2.E Minimum Test and Calibration Frequency for Drywell Leak Detection Instrumentation . 3.2/4.2-53 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation . 3.2/4.2-54 4.2.G Surveillance Requirements for Control Room Isolation Instrumentation. 3.2/4.2-56 4.2.H Minimum Test and Calibration Frequency for Flood Protection Instrumentation . 3.2/4.2-57 4.2.J Seismic Monitoring Instrument Surveillance Requirements . 3.2/4.2-58 4.2.K Explosive Gas Instrumentation Surveillance . 3.2/4 '-62 4.2.L ATWS-Recirculation Pump Trip (RPT)
Instrumentation Surveillance . 3.2/4.2-63a 3.5-1 Minimum RHRSW and EECW Pump Assignment . . . . . . . 3.5/4.5-11 4.9.A Auxiliary Electrical Systems . 3.9/4.9-16 4.9.A.4.C Voltage Relay Setpoints/Diesel Generator Start 3.9/4.9-18 6.2.A Minimum Shift Crew Requirements. . . . . . . . . . . 6.0-4 4,lo.g I 5H<60RR Vls~AL ZNsP~cTIOH IN TERYAL 3,L/4,$ -$3$ .
BFH vii AMENDMEMT NO. Ig g Unit 1
- 4. R SYS O
'JAN SURVEILLANCE REQUIREMENTS i 5 889 LIMITING CONDITIONS FOR OPERATION 3.6.H.
~ ~ ~ ~ul~~ 4.6.H, ~S g~b s T~ During all modes of operation, Each safety-related snubber all snubbers shall be OPERABLE shall be demonstrated OPERABLE except as noted in 3.6.H.1. by performance of the following All safety-related snubbers augmented inservice inspection program and the requirements PIA Instructions, of Specification 3.6.H/4.6.H.
These snubbers are listed in KAar1 .
Surveillance Instructions
- 1. With one or more snubber(s) inoperable on a system that is required
'to be OPERABLE in the current plant condition, 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 Sm engineering evaluation AT'V Scuse on the attached component or declare the attached S uzavs system inoperable and Foe.
follow the appropriate RnrsSsg Limiting Condition statement for that system. RgAGQAPHS 2 ~
3.6/4.6-15 AMEHDMEHT NO. X6 3 BFN Unit 1
0
/4 S S 0
'JAN 19 1999 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 4.6.H. ~Sub e s 4.6.H.2. (Cont'd)
Six ATTACHED SHEvrs Fee REVi5Q)
PARAGRAPH A'sD NEW p/+p FoQ. hJKA T'ABLE A m Homes,, 5FE.
Avrgcuan sod AMENOMENT ga gg3 BFN 3.6/4.6-16 Unit 1
'JAN 1 9 1999 LIMITINGCONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 4.6.H. ~Su~bb ~
3 ~
5 KE ATTACQED 54a~s FoP Rpv>sKD PA@.AGRAPH BFN 3.6/4,6-17 Unit I AMENpggp'gg y 8~
Ins ection T es 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 categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.H-1. The visual inspection interval for each type of snubber shall be determined based upon the criteria provided in Table 4.6.H-1 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 (*).
- NRC will include the number of the license amendment that implements this change.
Visual Ins ection Acce tance Criteria 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) fasteners 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 unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) 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 (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.6.H.5. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS FOR OPERATION shall be met.
Additionally, snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY.
Snubbers which have been made inoperable as the
4.6.H.3 (continued) result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.H.7 and 4.6.H.S have been met and any other appropriate corrective action implemented, shall not be counted in determining the'next visual inspection interval.
/4 PRINA v SvS 0 D
'JAN 19 IM9 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
- 4. 6.H. ~Sb~b 4.6.H.3 (Cont'd)
SEE A~pc.BED SHmvS FoR Rcv tsar PAaAGRaPN 4, C 0 Sc ed e o S C o o During each refueling outage, a representative sample of 10Ã of the total of each oep of safety-related snubbers in use in the plant shall be functionally 'tested either in place or in a bench
'test e The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size and capacity of snubbers vithin th The representative sample should be weighed to include more snubbers from severe service areas such as near heavy equipment.
The stroke setting and the security of fasteners for attachment of the snubbers to the component and to the snubber anchorage shall be verified on snubbers selected for FUNCTIONAL TESTS.
BFN Unit 1 3.6/4.6-18 AMENOMENT NO. I Q 3
/4 PR R S S U1D R LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
'JAN i9 1999 4.6.8. SrrSubbe e 4.6.8.5 (Cont'd)
- e. 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.
- 6. C 0 a u s dd t'o a i~S An engineering evaluation shall be made of each failure to meet the FUNCTIONAL TEST acceptance criteria to determine the cause of the failure.
The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determ'ine the OPERABILITY of other snubbers which may be subject to the same failure mode.
Selection of snubbers for future testing may also be based on the failure analysis.
For each snubber that does not meet the FUNCTIONAL TEST acceptance criteria, an additional lot equal TypE. of tha s a
~~
to 10 percent of the remainder of snubbers e functionally tested. Testing shall continue until no additional inoperdble snubbers are found within subsequent lots or all snubbers of the original have been tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.
BFN 3.6/4.6-20 AMENDMENT NQ. I6 3 Unit 1 F> HCTlov Aj
TABLE 4.6.H-l SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF NACCEPTABLE SNUBBERS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval INotes 1 and 2) INotes 3 and 6) INotes 4 and 6) INotes 5 and 6) 80 100 150 200 13 300 12 25 400 18 36 500 24 46 750 20 40 78 1000 or more 29 56 109 Note 1: 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 accessibility during power operation, as accessible or inaccessible.
These categories may be examined separately or jointly. However, the licensee must t
make and document that decision before any inspection and shatl use that decision as the basis upon which to determine the next inspection interval for that category.
Note 2: 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 inter polation.
Note 3: 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 the 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 interval.
h '
Note 5: lf 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 unacceptable snubbers is less than the number in Column C, but greater than the number in Column B, the next interval shall be reduced proportionaiiy 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 1.0.LL are applicable for all inspection intervals up to and including 48 months.
3.6/4 ' ~S S 3.6. H/4. 6". H ~Sibf~s Snubbers are designed to prevent unrestrained 'pipe or component motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and l shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping or components as a result of a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
Because the protection is required only during relatively low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to replace or restore the inoperable snubber to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the snubber has adversely affected any safety-related component or system.
To verify snubber operability FUNCTIONAL TESTS shall be performed during the refueling outages, at approximately 18-month intervals.
These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples, will require an engineering analysis and testing of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (i.e., seized components) is the result of manufacture or design deficiency, all snubbers subject to the same defect shall be functionally tested. A thorough inspect on of the snubber. threaded attachments to the pipe or components and the anchorage will be made in conjunction with all required FUNCTIONAL TESTS. The stroke setting of the snubbers selected for functional testing also will be verified.
All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.
AMENDMHP <g. ~ 63 BFN 3.6/4.6-34 Unit 1
3.6/4.6 ~S (Continued)
The visual inspection frequency is based upon maintaining a constant level of snubber protection.
The number of inoperable snubbers found during a required inspection determines the time interval for the next required 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 percent) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.
RE('A,Ss ) FlED When the cause of the rejection of a snubber in a visual inspection is clearly established and remedied for that snubber and for any other snubbers that'ay be generically susceptible and operability verified by inservice functional testing, if as +operable.
applicable, that snubber may be ~~&-
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, or are similarly established based on design features, and
, .. ~W'IVES located or exposed to the same environmental conditions such as installed conditions which may be expected to.be generic. Each of these inspection s inspected and tested separately unless an engineering analysis indicates the inspection ~p- is improperly constituted. All suspect snubbers are subject to inspection and testing regardless of inspection ~sykege I BFN Unit 1 3.6/4%6-35
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNIT 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-346 MARKED PAGES
SEP 2 2 1993 4.2.E Minimum Test and Calibration Frequency for Drywell Leak Detection Instrumentation. 3.2/4.2-53 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation. 3.2/4.2-54 4.2.G Surveillance Requirements for Control Room Isolation Instrumentation . 3 2/4.2-56 4.2.H Minimum Test and Calibration Frequency for Flood Protection Instrumentation. 3.2/4.2-57 4.2.J Seismic Monitoring Instrument Surveillance Requirements. 3.2/4.2-58 4.2.K Ezplosive Gas Instrumentation Surveillance, 3.2/4.2-62 4.2.L ATWS-Recirculation Pump Trip (RPT)
Instrumentation Surveillance . 3.2/4.2-63a 3.5-1 Minimum RHRSW and EECW Pump Assignment. . . . . . . 3.5/4.5-11 4.9.A Diesel Generator Reliability. 3o9/4.9-16 4.9.A.4.C Voltage Belay Setpoints/Diesel Generator Start. . . 3.9/4.9-18 6.2.A Minimum Shift Crew Requirements . 6.0-4 4 G. H- i SNusaap P<q~gt. Xggyzcr(oN Twmnvpc 3k/4g-23'FH vii AQENOMENT go. P yg Unit 2
R S S BOUN
'JAN 19 1988 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.6.H.
~ ~ ~ ~Ssbbers 4.6.H. ~Se bbe s During. all modes of operation, Each safety-related snubber all snubbers shall be OPERABLE shall be demonstrated OPERABLE except as noted in 3.6.H.1. by performance of the following All safety-related snubbers augmented inservice inspection are listed i Surveillance program and the requirements Instructions. of Specification 3.6.H/4.6.H.
These snubbers are listed in ~gT Surveillance Instructions
- 1. Mich one or more snubber(s) inoperable on a system that is required to be OPERABLE in the current plant condition, 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 SEE status and perform an engineering evaluation ATTACHE on the attached component or declare the attached Sore~s system inoperable and Fca follow the appropriate Limiting Condition statement RF.v(sm for that system.
VA~RWH AMENOMENT NO. X6 O BFN 3.6/4.6-15 Unit 2
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'JAN SURVEILLANCE REQUIREMENTS i9 1888 LIMITING CONDITIONS 4.6.H. ~Subbe s 3 ~
ATTACHED SHAWM Foe.
RF ViSEO TaRaGQAPH BFN 3.6/4.6-17 AMENDMENT NO. XQ P Unit 2
Ins ection T es 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 categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.H-l. The visual inspection interval for each type of snubber shall be determined based upon the criteria provided in Table 4.6.H-1 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 (*).
- NRC will include the number of the license amendment that implements this change.
Visual Ins ection Acce tance Criteria 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) fasteners 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 unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) 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 (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.6.H.5. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS FOR OPERATION shall be met.
Additionally, snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY.
Snubbers which have been made inoperable as the
0 4.6.H.3 (continued) result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.H.7 and 4.6.H.8 have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval.
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S 0 Y JAN 19 1988 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REOUIREMENTS 4.6.H. ~Sub' 4.6.H.5 (Cont'd)
- e. Testing methods may be used to measure parameters indirectly or parameters other than those specified if those results can correlated to the specified be parameters through established methods.
6 ~ O S a ssa dd An engineering evaluation shall f be made o each failure to meet the FUNCTIONAL TEST acceptance criteria to determine the cause of the failure.
The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the .subsequent lot in an, effort to determine the OPERABILITY of other snubbers which may be subject to the same failure mode.
Selection of snubbers for future testing may also be based on the failure analysis.
For each snubber that does not meet the FUNCTIONAL TEST acceptance criteria, an additional lot equal to 10 percent of the remainder of th g~ of snubbers shall e functionally tested. Testing shall continue until no additional inoperable snubbers are found within subsequent lots or all snubbers of the original have been tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.
BFN Unit 2 3.6/4.6-20 AMENQMEHT Ho. I6 Pi FuNc7'IQNp< TGS7 7 yp~
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3 '/4.6 ~B SES JAN 19 18BS 3.6.H/4.6.H. ~Snubber Snubbers are designed to prevent unrestrained pipe or component motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping or components as a xesult of a seismic or other event initiating dynamic loads. It is therefore requixed that all snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
Because the protection is required only during relatively low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to replace or restore the inoperable snubber to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the snubber has adversely affected any safety-related component or system.
To verify snubber operability FUNCTIONAL TESTS shall be performed during the refueling outages, at approximately 18-month intervals.
These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these. samples will require an engineering analysis and testing of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (l.e., seized components) is the result of manufacture or design deficiency, all snubbers subject to the same /ISAAC defect shall be functionally tested. A thorough inspect on of the snubber threaded attachments to the pipe or components and the anchorage will be made in conjunction with all required FUNCTIONAL TESTS. The stroke setting of the snubbers selected for functional testing also will be verified.
All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.
BFN 3.6/4.6-34 AMENDMENT NO. I8 0 Unit 2
3.6/4.6 ~B S S 3.6/4.6 ~SES (Continued)
The visual inspection frequency is based upon maintaining a constant level of snubber protection.
The number of inoperable snubbers found during a required inspection determines the time interval for the next required 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 percent) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override. the previous schedule.
QKCt Ass )Fiats Hhen the cause of the rejection of a snubber in a visual inspection is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicable, that snubber may be ~yeeet-.
as +operable. 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, or are similarly located or exposed eo che same environmental conditions a~noh temperature, radiation, and vibration. Inspection~~may be ~yp~
established based on design featuresp and installed conditions which ma be expected to be generic. Each of these inspection s nspected and tested separately unless an engineering analysis indicates the inspection~p-is improperly constituted. All suspect snubbers are subject to inspection and testing regardless of inspection~~~ge-.
'TYPE-BFN 3.6/4.6-35 Unit 2
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNIT 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-346 MARKED PAGES
(Cont'd) 4.2.E Minimum Test and Calibration Frequency for Drywell Leak Detection Instrumentation. 3.2/4.2-52 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation 3.2/4.2-53 4.2.G Surveillance Requirements for Control Room Isolation Instrumentation. 3.2/4.2-55 4.2.H Minimum Test and Calibration Frequency for Flood Protection Instrumentation 3-2/4.2-56 4.2.J Seismic Monitoring Instrument Surveillance Requirements 3.2/4.2-57 4.2.K Explosive Gas Instrumentation Surveillance 3.2/4.2-61 4.2.L ATWS-Recirculation Pump Trip (RPT)
Instrumentation Surveillance. 3-2/4.2-62a
- 3. 5-1 Minimum RHRSW and EECW Pump Assignment. 3.5/4.5-11 4.9.A Auxiliary Electrical System . 3.9/4.9-15 4.9.A.4.C Voltage Relay Setpoints/Diesel Generator Start. . . 3.9/4.9-17 6.2.A Minimum Shift Crew Requirements 6.0-4 BFN v3.1 AMENDggg go Unit 3 y pg
4 P MAR S M OU R
'JAN ~9 )o88 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
[ 3.6.H. ~Sut~~ 4.6.H. ~Such ~
During all modes of operation, Each safety-related snubber all snubbers shall be OPERABLE shall be demonstrated OPERABLE except as noted in 3.6.H.1. by performance of the following All safet -related snubbers augmented inservice inspec ion are listed i Surveillance program and the requirements Instructions> of Specification 3.6.H/4.6.H.
These snubbers are listed in 74hgp Surveillance Instructions
- 1. With one or more snubber(s) inoperable on a system that is required to be OPERABLE in the current plant condition, 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 SKa status and perform an engineering evaluation Avrhcv~o on the attached component or declare the attached 3 Hazes system inoperable and laQ. R.Fg i'll'D follow the appropriate Limiting Condition statement VpgwkAPH's for that system.
BFN 3.6/4.6-15 AMBOMEHT i'. I ~ 4 Unit 3
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4 S 0 JAN i9 1888 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
- 4. 6.H. ~Sub'
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Q~ 4~~uso SHsavS Wa Ravine.g QARAGRh PH BFN Unit 3 3.6/4.6-17 AME(fPMEg go. yp j
Ins ection T es 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 categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.H-1. The visual inspection interval for each type of snubber shall be determined based upon the criteria provided in Table 4.6.H-1 and the first inspection interval determined using this criteria shall be based upon the previous inspection interval as established by the rec{uirements in effect before amendment (*).
- NRC will include the number of the license amendment that implements this change.
Visual Ins ection Acce tance Criteria 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) fasteners 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 unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) 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 (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.6.H.5. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS FOR OPERATION shall be met.
Additionally, snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY.
Snubbers which have been made inoperable as the
4.6.H.3 (continued) result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.H.7 and 4.6.H.8 have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval.
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'JAN 19 1989 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 4.6.H. ~Sobs 4.6.H.5,(Cont'd)
- e. Testing methods may be used to measure parameters 'ndirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods.
6.
dd o An engineering evaluation shall be made of each failure to meet the FUNCITONAL TEST acceptance criteria to determine the cause of the failure.
The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determine the OPERABILITY of other snubbers vnich may be subject to the same failure mode.
Selection of snubbers for future testing may also be based on the failure analysis.
For each snubber that does not meet the FUNCTIONAL TEST acceptance criteria, an additional lot equal to 10 ercent of the remainder o
shall t a be
~~of snubbers functionally tested. Testing shall continue until no additional inoperable snubbers are found vithin subsequent lots or all snubbers of the original have been tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.
BFN 3.6/4.6-20 AMENDMENT g0. ygg Unit 3 FuHCTioHAL TEST T'fPE
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3.6/4.6 ~S 'JAN 19 1888 3.6,H/4.6.H ~S i~~~
Snubbers are designed to prevent unrestrained pipe or component motion under dynamic loads as might occur dhtring an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping or components as a result of, a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect, the primary coolant system or any other safety system or component be operable during reactor operation.
Because the protection is required only during relatively low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to replace or restore the inoperable snubber to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The enginee'ring evaluation is performed to determine whether the mode of failure of the snubber has adversely affected any safety>>related component or system.
To verify snubber operability FUNCTIONAL TESTS shall be performed during the refueling outages, at approximately 18-month intervals.
These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples will require an engineering analysis and testing of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (i.e., seized components) is the result of manufacture or design deficiency, all snubbers subject to the same $ 15<++
defect shall be functionally tested. A thorough nspection of t e snubber threaded attachments to the pipe or components and the anchorage will be made in con)unction with all required FUNCTIONAL TESTS. The stroke setting of the snubbers'elected for functional testing also will be verified.
All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.
AMfNOMENTgg. gpss BFN 3.6/4.6-34 Unit 3
3.6/4.6 The
~ (Continued) visual. inspection frequency is based upon maintaining a constant level of snubber protection.
The number of inoperable snubbers found during a required inspection determines the time interval for the next required 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 percent) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule. LASS ED K.C IF 1 When the cause of the rejection of a snubbe in a visual inspection is clearly established and remedied for that snubber d for any other snubbers that may be generically susceptible and operabili verifi,ed by inservice functional testing if appl icable, that snubber may be p as
+operable. 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, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.
Inspectio q~w-may be established based on design features, and installed conditions which may be expected to be generic. Each of these inspection
~ape- is inspected and tested separately unless an engineering analysis indicates the inspection s improperly constituted. All suspect snubbers are subject to inspection and testing regardless of inspection
~8$ 6%h~o BFH 3.6/4.6-35 Unit 3
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWSES FERRY NUCLEAR PLANT (BFN)
UNITS 1 2 AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-346 REVZSED PAGES I AFFECTED PAGE L1ST vii 3.6/4.6-15 3.6/4.6-16 3.6/4.6-17 3.6/4.6-18 3.6/4.6-20 3.6/4.6-23b 3.6/4.6-23c 3.6/4.6-34 3.6/4.6-35 (Revised pages are the same for Units 1, 2, and 3)
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNIT 1 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-346 REVZSED PAGES
I (Cont'd)
Table ~ae 1fo 4.2.E Minimum Test and Calibration Frequency for Drywell Leak Detection Instrumentation . 3.2/4.2-53 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation . 3 '/4 '-54 4.2.G Surveillance Requirements for Control Room Isolation Instrumentation. 3 '/4.2-56 4.2.H Minimum Teat and Calibration Frequency for Flood, Protection Instrumentation . 3.2/4.2-57 4.2.J Seismic Monitoring Instrument Surveillance Requirements . 3 '/4.2-58 4.2.K Explosive Gas Instrumentation Surveillance . . . . . 3.2/4.2-62 4.2.L ASS-Recirculation Pump Trip (RPT)
Instrumentation Surveillance . 3.2/4.2-63a 3.5-1 Minimum RHRSM and EEGW Pump Assignment . . . . . . . 3.5/4.5-11 4.6.H-1 Snubber Visual Inspection Interval . 3.6/4.6-23b 4.9.A Auxiliary Electrical Systems . . . . . . . . . . . . 3.9/4.9-16 4;9.A.4.C Voltage Relay Setpoints/Diesel Generator Start . . . 3.9/4.9-18 6.2.A Minimum Shift Crew Requirements. . . . . . . . . . . 6.0-4 BFN vii Unit 1
4 PRIMARY S S 0 LIMITI G CO ITIO S FOR OPERA 0 SUR I CE RE UIREME S 3.6.H. Snubbers 4.6.H. ~Snubbe e During all modes of operation, Each safety-related snubber all snubbers shall be OPERABLE shall be demonstrated except as noted in 3.6.H.1. OPERABLE by performance All safety-related snubbers of the following augmented are listed in Plant inservice inspection program Surveillance Instructions. and the requirements of Specification 3.6.H/4.6.H.
- 1. With one or more These snubbers are listed in snubber(s) inoperable on Plant Surveillance Instructions.
a system that is required to be OPERABLE in the l. I s ection es current plant condition, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace As used in this or restore the inoperable specification, "type of snubber(s) to OPERABLE snubber" shall mean status and perform an snubbers of the same engineering evaluation design and manufacturer, on the attached component irrespective of capacity.
or declare the attached system inoperable and 2. Visual Ins ections follow the appropriate Limiting Condition Snubbers are categorized statement for that system. as inaccessible or accessible during reactor operation. Each of these categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.H-1. The visual inspection interval for each type of snubber shall be determined based upon the criteria provided in Table 4.6.8-1 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 BFH 3.6/4.6-15 Unit 1
4 PRIMARY SYS BO ARY LIMITI G CONDITIO S FOR OPERATIO SURVEIL CE RE UIREME S 4.6.B. ~Subb rs 3~ V sual Ins ection ce tance Criteria 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) fasteners 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 unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) 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 (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.6.H.5. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS FOR OPERATIOH shall be met.
BFH 3.6/4.6-16 Unit 1
4 PR SS BO LIMITI G 'CO ITIO S FOR OPERAT 0 SURVEI CE RE UIRENE S 4.6.H Snubbers 4.6.H.3 (Cont'd)
Additionally, snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY.
Snubbers which have been made inoperable as the result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.H.7 and 4.6.H.S have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval.
BFN 3.6/4.6-17 Unit 1
- 4. CTIO AL TEST Schedule Lot Size d Com osition During each refueling outage, a representative sample of 10K of the total of each type of !
safety-related snubbers in use in the plant shall be functionally tested either in place or in a bench test.
The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size and capacity of snubbers within the types. The representative sample should be weighed to include more snubbers from severe service areas such as near heavy equipment.
The stroke setting and the security of fasteners for attachment of the snubbers to the component and to the snubber anchorage shall be verified on snubbers selected for FUHCTIOHAL TESTS.
BFH 3.6/4.6-18 Unit 1
4 PR MARY S S BO LIM TI Q CO ITIO S FOR OPERA IO CE RE U REME S 4.6.H. Snubbers 4.6.H.5 (Cont'd)
- e. 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.
- 6. CT 0 AL TES Failure s s and Additional Trente An engineering evaluation shall be made of each failure to meet the FUHCTIOHAL TEST acceptance criteria to determine the cause of the failure. The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determine the OPERABILITY of other snubbers which may be subject to the same failure mode. Selection of snubbers for future testing may also be based on the failure analysis. For each snubber that does not meet the FUHCTIOHAL TEST acceptance criteria, an additional lot equal to 10 percent of the renainder of that type of snubbers shall be functionally tested. Testing shall continue until no additional inoperable snubbers are found within subsequent lots or all snubbers of the original FUHCTIOHAL TEST type have been )
tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.
BFH 3.6/4.6-20 Unit 1
Table 4.6.H-l SHUBBER VISUAL IHSPECTIOH IHTERVAL OF CCE ABLE S B RS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval Notes 1 and 2 otes and es 4 otes and 12 10 or more Note 1: 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 accessibility during power operation, 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.
Hote 2: 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.
Note 3: 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.
BFH 3.6/4.6-23b Unit 1
Table 4.6.8-1 (Continued)
SHUBBBR VISUAL IHSPBCTIOH IHTERVAL Hote 4: If the 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 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, number pf unacceptable snubbers is less than the number in if the 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 1.0.LL are applicable for all inspection intervals up to and including 48 months.
BFH 3.6/4.6-23c Unit 1
3.6/4.6 BASES 3.6.H/4.6.H Snubbers Snubbers are designed to prevent unrestrained pipe or component motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping or components as a result of a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
Because the protection is required only during relatively low probability events, a pegiod of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to replace or restore the inoperable snubber to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the snubber has adversely affected any safety-related component or system.
To verify snubber operability FUNCTIONAL TESTS shall be performed during the refueling outages, at approximately 18-month intervals.
These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples will require an engineering analysis and testing of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (i.e., seized components) is the result of manufacture or design deficiency, all snubbers subject to the same defect shall be functionally tested. A thorough visual inspection of the snubber threaded attachments to the pipe or components and the anchorage will be made in conjunction with all required FUNCTIONAL TESTS. The stroke setting of the snubbers selected for functional testing also will be verified.
All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.
BFN 3.6/4.6-34 Unit 1
3.6/4.6 BASES (Continued)
The visual inspection frequency is based upon maintaining a constant level of snubber protection. The number of inoperable snubbers found during a required inspection determines the time interval for the next required 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 percent) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.
When the cause of the rejection of a snubber in a visual inspection is clearly estaglished and remedied for that snubber and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicable, that snubber may be reclassified as operable. Generically susceptible snubbers are those I which are of a specific make or model and have the same design features directly related to re)ection of the snubber, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration. Inspection types may be established based on design features, and installed conditions which may be expected to be generic. Each of these inspection types is inspected and tested separately unless an engineering analysis indicates the inspection type is improperly constituted. All suspect snubbers are subject to inspection and testing regardless of inspection type.
BFH 3.6/4.6-35 Unit 1
ENCLOSURE 3 TENNESSEE VALLEY AUTHORZTY BROGANS FERRY NUCLEAR PLANT (BFN)
UNZT 2 PROPOSED TECHNZCAL SPECZFZCATZON (TS) CHANGE TS-346 REVZSED PAGES
L 0 (Cont'd)
Tab e ~aero 4.2.E Minimum Test and Calibration Frequency for Dryvell Leak Detection Instrumentation. 3.2/4.2-53 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation. 3.2/4.2-54 4.2.G Surveillance Requirements for Control Room Isolation Instrumentation . 3.2/4.2-56 4.2.H Minimum Test and Calibration Frequency for Flood Protection Instrumentation. 3.2/4.2-57 4.2.J Seismic Monitoring Instrument Surveillance Requirements' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o o ~ 3.2/4.2-58 4.2.K Explosive Gas Instrumentation Surveillance. . . . . 3.2/4.2-62 4.2.L ATWS-Recirculation Pump Trip (RPT)
Instrumentation Surveillance . 3.2/4.2-63a 3.5-1 Minimum RHRSW and EECW Pump Assignment. . . . . . . 3.5/4.5-11 4.6.H-l Snubber Visual Inspection Interval. 3.6/4.6-23b 4.9.A Diesel Generator Reliability. 3.9/4.9-16 4;9.A.4.C Voltage Relay Setpoints/Diesel Generator Start. . . 3.9/4.9-18 6.2.A Minimum Shift Crev Requirements . . . . . . . . . . 6.0-4 BFH vii Unit 2
4 PR MARY SYS BO ARY LIMITI G CO ITIO S FOR OPERATIO SURVEI CE RE UIREME S 3.6.H. Snubbers 4.6.H.'nubbers During all modes of operation, Each safety-related snubber all snubbers shall be OPERABLE shall be demonstrated except as noted in 3.6.8.1. OPERABLE by performance All safety-related snubbers of the following augmented are listed in Plant inservice inspection program Surveillance Instructions. and the requirements of Specification 3.6.8/4.6.H.
- 1. With one or more These snubbers are listed in snubber(s) inoperable on Plant Surveillance Instructions. (
a system that is required to be OPERABLE in the l. I s ection es current plant condition, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace As used in this or restore the inoperable specification, "type of snubber(s) to OPERABLE snubber" shall mean status and perform an snubbers of the same engineering evaluation design and manufacturer, on the attached component irrespective of capacity.
or declare the attached system inoperable and 2. Visual Ins ections follow the appropriate Limiting Condition Snubbers are categorized statement for that system. as inaccessible or accessible during reactor operation. Each of these categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.8-1. The visual inspection interval for each type of snubber shall be determined based upon the criteria provided in Table 4.6.8-1 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 BFH 3.6/4.6-15 Unit 2
4 PRIMARY SYS BO AR LIMITI G CONDI IO S FOR OPERATIO SURVEIL CE RE UIREME S 4.6.H. ~Subbers 3~ V sual I s ection e tance Criteria 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) fasteners 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 unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) 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 (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.6.H.5. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot
'e justified, the snubber shall be declared inoperable and the LIMITIHG CONDITIONS FOR OPERATION shall be met.
BFH 3.6/4.6-16 Unit 2
4 PRIMARY SYS BO A LIMITI G CO TIO S FOR OPERATIO SURVE L C UIREME S 4.6.H ~Sgbb~
4.6.H.3 (Cont'd)
Additionally, snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY.
Snubbers which have been made inoperable as the result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.8.7 and 4.6.H.S have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval.
BFH 3.6/4.6-17 Unit 2
4 PRIMARY SYSTEM BO ARY LI ITI G CO ITIO S FOR OPE TIO SURVEI CE RE UIREME S 4.6.H. Snubbers
- 4. CTIO AL TEST Schedule Lot Size and Cpm osition During each refueling outage, a representative sample of lOX of the total of each type of !
safety-related snubbers in use in the plant shall be functionally tested either in place or in a bench test.
The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size and capacity of annbbara within the types. The representative sample should be weighed to include more snubbers from severe service areas such as near heavy equipment.
The stroke setting and the security of fasteners for attachment of the snubbers to the component and to the snubber anchorage shall be verified on snubbers selected for FUNCTIOHAL TESTS.
BFH 3.6/4.6-18 Unit 2
4 PRIMARY SYS BO AR LIMITI G CO ITIO S FOR OPE 0 4.6.H. >SuChbbm 4.6.8.5 (Cont'd)
- e. Testing methods may be used to measuxe parameters indirectly or parameters other than those specified if those results can correlated to the be specified parameters through established methods.
- 6. CTIO AL TEST Failure Ana sis and Additional Test Lots An engineering evaluation shall be made of each failure to meet the FUHCTIOHAL TEST acceptance criteria to determine the cause of the failure. The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determine the OPERABILITY of other snubbers which may be sub)ect to the same failure mode. Selection of snubbers for futuxe testing may also be based on the failure analysis. For each snubber that does not meet the FUHCTIOHAL TEST acceptance criteria, an additional lot equal to 10 percent of the remainder of that type of j snubbers shall be functionally tested. Testing shall continue until no additional inoperable snubbers are found within subsequent lots or all snubbers of the original FUHCTIOHAL TEST type have been tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.
BFH 3.6/4.6-20 Unit 2
Table 4.6.H-1 SNUBBER VISUAL INSPECTION INTERVAL ER OF CCSPTABLE S BERS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval Notes 1 and 2 otes and otes 4 and otes and 24 1 or oe Note 1: 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 accessibility during power operation, as accessible or inaccessible. These categories may be examined separately or jointly. However, the licensee must make anti 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: 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.
Note 3: 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.
BFN 3.6/4.6-23b Unit 2
I
Table 4.6.H-l {Continued)
SNUBBER VISUAL IHSPECTIOH INTERVAL Note 4: If the 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 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 unacceptable 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.
Hote 6: The provisions of Specification 1.0.LL are applicable for all inspection intervals up to and including 48 months.
BFH 3.6/4.6-23c Unit 2
3 6/4 6 ggjEE 3.6.H/4.6.H ~S ubbe 8 Snubbers are designed to prevent unrestrained pipe or component motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping or components as a result of a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
Because the protection is required only during relatively low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to replace or restore the inoperable snubber to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the snubber has adversely affected any safety-related component or system.
To verify snubber operability FUHCTIOHAL TESTS shall be performed during the refueling outages, at approximately 18-month intervals.
These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples will require an engineering analysis and testing of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (i.e., seined components) is the result of manufacture or design deficiency, all snubbers subject to the same defect shall be functionally tested. A thorough visual inspection of the snubber threaded attachments to the pipe or components and the anchorage will be made in co+unction with all required FUHCTIOHAL TESTS. The stroke setting of the snubbers selected for functional testing also will be verified.
All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.
BFN 3 '/4.6-34 Unit 2
- 3. 6/6. 6 ~BASE 3.6/4.6 BASES {Continued)
The visual inspection frequency is based upon maintaining a constant level of snubber protection. The number of inoperable snubbers found during a required inspection determines the time interval for the next required 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 percent) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.
When the cause of the rejection of a snubber in a visual inspection is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicable, that snubber may be reclassified as operable. l'enerically 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, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration. Inspection types may be established based on design features, and installed conditions which may be expected to be generic. Each of these inspection types is inspected and tested separately unless an engineering analysis indicates the inspection type is improperly !
constituted. All suspect snubbers are subject to inspection and testing regardless of inspection type. !
BFN 3.6/4.6-35 Unit 2
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNIT 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-346 REVISED PAGES
L 0 (Cont'd)
Table Pae o 4.2.E Minimum Test and Calibration Frequency for Dryvell Leak Detection Instrumentation. 3.2/4.2-52 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation . 3 2/4.2-53 4.2.G Surveillance Requirements for Control Room Isolation Instrumentation. 3 '/4.2-55 4.2.H Minimum Test and Calibration Frequency for Floogl Protection Instrumentation . 3.2/4.2-56 4.2.J Seismic Monitoring Instrument Surveillance i
R e qu r em ent s ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 3.2/4.2-57 4.2.K Explosive Gas Instrumentation Surveillance . 3.2/4.2-61 4.2.L ATWS-Recirculation Pump Trip (RPT)
Instrumentation Surveillance. 3.2/4.2-62a 3.5-1 Minimum RHRSW and EECW Pump Assignment. . . . . . . 3.5/4.5-11 4.6.8-1 Snubber Visual Inspection Interval 3.6/4.6-23b (
4.9.A Auxiliary Electrical System . . . . . . . . . . . . 3.9/4.9-15 4.'9.A.4.C Voltage Relay Setpoints/Diesel Generator Start. . . 3.9/4.9-17 6.2.A Minimum Shift Crew Requirements . . . . . . . . . . 6.0-4 BFH vii Unit 3
4 PRIMARY SYSTEM BO AR LIMITIHG CO ITIO S FOR OPERA IO SURVEIL CE RE UIREME S
- 3. 6.H. ~Subbers 4.6.H. ~S~~be~s During all modes of operation, Each safety-related snubber all snubbers shall be OPERABLE shall be demonstrated except as noted in 3.6.8.1. OPERABLE by performance All safety-related snubbers of the folloving augmented are listed in Plant inservice inspection program Surveillance Instructions. and the requirements of Specification 3.6.H/4.6.H.
- 1. With one or more These snubbers are listed in snubber(s) inoperable on Plant Surveillance Instructions.]
a system that is required to be OPERABLE in the 1. tio es current plant condition, vithin 72 hours replace As used in this or restore the inoperable specification, "type of snubber(s) to OPERABLE snubber" shall mean status and perform an snubbers of the same engineering evaluation design and manufacturer, on the attached component irrespective of capacity.
or declare the attached system inoperable and 2. V ual Ins ections follov the appropriate Limiting Condition Snubbers are categorized statement for that system. as inaccessible or accessible during reactor operation. Each of these categories (inaccessible and accessible) may be inspected independently according to the schedule determined by Table 4.6.H-l. The visual inspection interval for each type of snubber shall be determined based upon the criteria provided in Table 4.6.H-1 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 BFN 3.6/4.6-15 Unit 3
3 6 4 6 PRIMARY SYSTEM BO AR LIMITI G CO I IO S FOR OPERA 0 S I UI 4.6.H.'ag]~s 3~ a Ins ection tanc er a 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) fasteners 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 unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) 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 (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.6.8.5. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS FOR OPERATION shall be met.
BFH 3.6/4.6-16 Unit 3
PRI R S S BO LIMITI G CO OS FO OP 0 4.6.H ~S pbbss 4.6.8.3 (Cont'd)
Additionally, snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last period shall be 'nspection evaluated for the possibility of concealed damage and functionally tested, confirm if applicable, OPERABILITY.
to Snubbers which have been made inoperable as the result of unexpected transients, isolated damage, or other random events, when the provisions of 4.6.8.7 and 4.6.H.S have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval.
BFN 3.6/4.6-17 Unit 3
4 PRIMARY S STEM BO ARY LIMITI G 'CO I IO S FOR OPERATIO SURVBI CE RE UIREME S 4.6.H. Sxgsbbe~s
- 4. 0 AL S Schedule L Size and Com osition During each refueling outage, a representative sample of lOX of the total of each type of safety-related snubbers in use in the plant shall be functionally tested either in place or in a bench test.
The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size and capacity of snubbers within the types. The representative sample should be weighed to include more snubbers from severe service areas such as near heavy equipment.
The stroke setting and the security of fasteners for attachment of the snubbers to the component and to the snubber anchorage shall be verified on snubbers selected for FUHCTIOHAL TESTS.
BFH 3.6/4.6-18 Unit 3
- 4. PRIMARY SYS BO ARY LIMITI G CO ITIO S FOR OPERATIO SURVBI CE UIREME S 4.6.H.
4.6.8.5 (Cont'd)
- e. 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.
- 6. O S a r Anal sis and Additional Test Lots An engineering evaluation shall be made of each failure to meet the FUHCTIOHAL TEST acceptance criteria to determine the cause of the failure. The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determine the OPERABILITY of other snubbers which may be subject to the same failure mode. Selection of snubbers for future testing may also be based on the failure analysis. For each snubber that does not meet the FUHCTIOHAL TEST acceptance criteria, an additional lot equal to 10 percent of the remainder of that type of snubbers shall be functionally tested. Testing shall continue until no additional inoperable snubbers are found within subsequent lots or all snubbers of the original FUHCTIOHAL TEST type have been tested or all suspect snubbers identified by the failure analysis have been tested, as applicable.
BFH 3.6/4.6-20 Unit 3
Table 4.6.H-1 SNUBBER VISUAL INSPECTION INTERVAL 0 CCEPTAB S BERS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval Notes 1 and 2 otes and otes 4 and otes and 12 1 or more Note 1: 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 accessibility during power operation, as accessible or inaccessible. These categories may be examined separately or )ointly. 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: 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.
Note 3: 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.
BFN 3.6/4.6-23b Unit 3
Table 4.6.H-l (Continued)
SNUBBER VISUAL INSPECTION INTERVAL Note 4: If the 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 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 unacceptable 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 1.0.LL are applicable for all inspection intervals up to and including 48 months.
BFN 3.6/4.6-23c Unit -3
3.6/4.6 BASES 3.6.H/4.6.H Snubbers Snubbers are designed to prevent unrestrained pipe or component motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping or components as a result of a seismic or other event initiating dynamic loads. It is therefore required that all snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
Because the protection is required only during relatively low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to replace or restore the inoperable snubber to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the snubber has adversely affected any safety-related component or system.
To verify snubber operability FUHCTIOHAL TESTS shall be performed during the refueling outages, at approximately 18-month intervals.
These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples will require an engineering analysis and testing of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (i.e., seized components) is the result of manufacture or design deficiency, all snubbers subject to the same defect shall be functionally tested. A thorough visual inspection of the snubber threaded attachments to the pipe or components and the anchorage will be made in conjunction with all required FUHCTIOHAL TESTS. The stroke setting of the snubbers selected for functional testing also will be verified.
All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.
BFH 3.6/4.6-34 Unit 3
3.6/4.6 BASES (Continued)
The visual'nspection frequency is based upon maintaining a constant level of snubber protection. The number of inopsrsble snubbers found during e required inspection determines the time interval for the next required 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 percent) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.
When the cause of the rejection of a snubber in a visual inspection is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicable, that snubber may be reclassified as operable.
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, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration. Inspection types may be established based on design features, and installed conditions which may be expected to be generic. Bach of these inspection types is inspected and tested separately unless an engineering analysis indicates the inspection type is improperly constituted. All suspect snubbers are subject to inspection and testing regardless of inspection type.
BFN 3.6/4.6-35 Unit 3
ENCLOSURE 4 TENNESSEE VALLEY AUTHORITY BROGANS FERRY NUCLEAR PLANT tBFN)
UNITS 1 2 AND 3 REQUEST FOR COST BENEFICIAL LICENSING ACTION RLA-04 PROPOSED TECHNICAL SPECIFICATION TS CHANGE TS-346
SUMMARY
OF RLA-04 BFN Units 1, 2, and 3 Technical Specifications (TS) 3.6.H/4.6.H, "Snubbers," provides visual inspection intervals for all safety-related snubbers.
As part of its Operating and Maintenance Cost Reduction Program, TVA has developed proposed changes to TS 3.6.H/4.6.H and its associated bases to provide alternate visual inspection intervals for safety-related snubbers.
The proposed changes incorporate the recommendations of Generic Letter 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions." The proposed TS changes are estimated to yield nearly $ 100,000 per unit. in one time cost savings and an additional $ 50,000 per unit in annual cost savings. The proposed TS changes (TS-346) are being submitted to NRC as Enclosures 1, 2, and 3 to this letter.
BACKGROUND The existing TS specifies a schedule for snubber visual inspections that is based on the number of inoperable snubbers found during the previous visual inspection.
This schedule assumes that refueling cycles will not exceed 18 months. Because the current schedule for visual inspections is based only on the number of inoperable snubbers found during the previous visual inspection, irrespective of the size of the snubber population, NRC determined that the visual inspection schedule is excessively restrictive. As a result, NRC developed an alternate schedule for visual inspections that maintains the same confidence level as the existing schedule and generally will allow licensees to perform visual inspections and corrective actions during plant outages.
NRC issued the alternate schedule in Generic Letter 90-09.
The alternate visual inspection schedule is based on the number of unacceptable snubbers found during the previous inspection in proportion to the size of the various snubber populations or categories.
0 TVA proposes changes to BFN TS 3.6.H/4.6.H and associated bases to incorporate the recommendations of Generic Letter 90-09. Additionally, TVA has proposed certain editorial and terminology changes to provide consistency between affected sections incorporating the recommendations of Generic Letter 90-09 and those not directly affected. The proposed changes will reduce occupational radiological exposure to plant personnel and generally allow BFN to perform visual inspections and corrective actions during plant outages.
RE VESTED NRC LICENSING ACTION TVA requests NRC review and approval of these proposed changes to the BFN Units 1, 2, and 3 TS by May 1, 1994.
This date is necessary in order to support resource planning and allocation for the Unit 2 Cycle 7 refueling outage scheduled to begin on October 1, 1994. These changes are being submitted as Enclosures 1, 2, and 3 to this letter.
BASIS FOR RE VESTED NRC LICENSING ACTION The proposed alternate snubber visual inspection schedule would allow BFN to extend snubber visual inspection intervals (in accordance with GL 90-09) without reducing the confidence level provided by the existing visual inspection schedule. Verification that a snubber can operate within specified performance limits is provided by functional testing. This testing provides a 95 percent confidence level that at least 90 percent to 100 percent of the snubbers operate within specified performance limits. The performance of visual inspections is a separate process that complements the functional testing program and provides additional confidence in snubber operability. Therefore, revising the schedule for snubber visual inspections, using the guidance provided in GL 90-09, does not reduce the confidence level associated with snubber operability. As a result, a significant amount of resources could be saved and a substantial reduction in occupational radiological exposure could be realized.
J V ZUSTZFZCATZON FOR HZGHER PRZORZTY REVZEN 1~ RLA-04 is Safet Neutral The proposed TS change will not result in a decrease in plant safety, since the proposed visual inspection schedule will maintain the same snubber operability confidence level as the existing schedule. Also, the surveillance requirement and schedule for snubber functional testing remains the same providing a 95 percent confidence level that 90 percent to 100 percent of the snubbers operate within the specified acceptance limits. The proposed visual
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inspection schedule is separate from functional testing and provides additional confidence that the installed snubbers will serve their intended design function and are being maintained operable.
2 ~ RLA-04 Provides Si nificant Cost 8avin s and Other Benefits TVA estimates that this TS change will result in a one time savings of $ 100,000 per operating unit and an annual savings of $ 50,000 per operating unit. The one time savings will be realized as a result of extending (to 36 months) the current inspection interval based on the number of unacceptable snubbers identified during the previous inspection. Additional savings will be realized on an annual basis as a result of maintaining the inspection interval at double (36 months) the current interval.
Furthermore, the TS change is expected to substantially reduce occupational radiological exposure.
Additional savings would be realized by reducing the probability of a mid-cycle outage imposed by the present TS visual inspection schedule. Under the present TS schedule one unacceptable snubber (regardless of snubber population) would reduce the visual inspection interval to 12 months (+25 percent), thus dictating a mid-cycle outage to perform snubber visual inspections. The proposed TS change would eliminate the loss of power generation revenue and the cost incurred for the purchase of replacement power resulting from a mid-cycle outage.
VI ~ CONCLUSION The current TS requirements impose a'burden on TVA without adding a safety benefit. The proposed TS changes are consistent with the guidance provided in Generic Letter 90-09.
TVA has determined that the proposed TS amendment is a cost beneficial licensing action since it is safety neutral and provides significant cost savings. Therefore, TVA requests expeditious NRC review of this proposed TS change.
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