Text

Proposed Tech Specs Re Alternative Requirements for Snubber Visual Insp Intervals & Corrective Actions
	ML18037A635
Person / Time
Site:	Browns Ferry
Issue date:	12/23/1993
From:	; TENNESSEE VALLEY AUTHORITY
To:	;
Shared Package
ML18037A636	List: ML18037A635; ML20059C498;
References
	NUDOCS 9401050293
	Download: ML18037A635 (109)
	v • d • e

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

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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

~be 4.2.E Title Minimum Test and Calibration Frequency for Drywell Leak Detection Instrumentation SEP 2 2 8'93

~Pa e

Ho 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 4.2.K 4.2.L Seismic Monitoring Instrument Surveillance Requirements Explosive Gas Instrumentation Surveillance ATWS-Recirculation Pump Trip (RPT)

Instrumentation Surveillance 3.2/4.2-58 3.2/4 '-62 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 4.9.A.4.C Voltage Relay Setpoints/Diesel Generator Start 3.9/4.9-16 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 Unit 1 vii AMENDMEMTNO. I g g

4.

R SYS O

LIMITING CONDITIONS FOR OPERATION

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! 3.6.H. ~ul~~

During all modes of operation, all snubbers shall be OPERABLE except as noted in 3.6.H.1.

All safety-related snubbers PIAT~

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.

'JAN i 5 889 SURVEILLANCE REQUIREMENTS 4.6.H,

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Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 3.6.H/4.6.H.

These snubbers are listed in KAar1 Surveillance Instructions Sm AT'VScuse S uzavs Foe.

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BFN Unit 1 3.6/4.6-15 AMEHDMEHTNO. X 6 3

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'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 Am Homes,,

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Avrgcuan sod BFN Unit 1 3.6/4.6-16 AMENOMENTga g g 3

LIMITINGCONDITIONS FOR OPERATION

'JAN 1 9 1999 SURVEILLANCE REQUIREMENTS 4.6.H.

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5 KE ATTACQED 54a~s FoP Rpv>sKD PA@.AGRAPH BFN Unit I 3.6/4,6-17 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 LIMITING CONDITIONS FOR OPERATION

'JAN 19 IM9 SURVEILLANCE REQUIREMENTS

4. 6.H.

~Sb~b 4.6.H.3 (Cont'd)

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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 AMENOMENTNO. I Q 3

/4 PR R

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U1D R

LIMITING CONDITIONS FOR OPERATION

'JAN i9 1999 SURVEILLANCE REQUIREMENTS 4.6.8.

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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.

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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 to 10 percent of the remainder of tha ~~ of snubbers s

a 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 Unit 1 3.6/4.6-20 F> HCTlov Aj AMENDMENTNQ. I6 3

TABLE 4.6.H-l SNUBBER VISUALINSPECTION INTERVAL NUMBER OF NACCEPTABLE SNUBBERS Population or Category INotes 1 and 2)

Column A Extend Interval INotes 3 and 6)

Column B Repeat Interval INotes 4 and 6)

Column C Reduce Interval INotes 5 and 6) 80 100 150 200 300 400 500 750 1000 or more 20 29 12 18 24 40 56 13 25 36 46 78 109 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 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.

t 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 limitfor Columns A, B, or C ifthat integer includes a fractional value of unacceptable snubbers as determined by interpolation.

Note 3:

Ifthe 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 '

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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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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.

BFN Unit 1 3.6/4.6-34 AMENDMHP<g. ~ 63

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 applicable, that snubber may be ~~&-

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

,.. ~W'IVES established based on design features, and 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 4.2.H 4.2.J 4.2.K 4.2.L Surveillance Requirements for Control Room Isolation Instrumentation Minimum Test and Calibration Frequency for Flood Protection Instrumentation.

Seismic Monitoring Instrument Surveillance Requirements.

Ezplosive Gas Instrumentation Surveillance, ATWS-Recirculation Pump Trip (RPT)

Instrumentation Surveillance 3 2/4.2-56 3.2/4.2-57 3.2/4.2-58 3.2/4.2-62 3.2/4.2-63a 3.5-1 4.9.A Diesel Generator Reliability.

3o9/4.9-16 Minimum RHRSW and EECW Pump Assignment.

3.5/4.5-11 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 Unit 2 vii AQENOMENT go. P y g

R S

S BOUN LIMITING CONDITIONS FOR OPERATION

~

! 3.6.H.

~Ssbbers During. all modes of operation, all snubbers shall be OPERABLE except as noted in 3.6.H.1.

All safety-related snubbers are listed i 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.

'JAN 19 1988 SURVEILLANCE REQUIREMENTS 4.6.H.

~Se bbe s

Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 3.6.H/4.6.H.

These snubbers are listed in ~gT Surveillance Instructions SEE ATTACHE Sore~s Fca RF.v(sm VA~RWH BFN Unit 2 3.6/4.6-15 AMENOMENTNO. X 6 O

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'JAN i 9 1888 SURVEILLANCE REQUIREMENTS 4.6.H.

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ATTACHED SHAWM Foe.

RF ViSEO TaRaGQAPH BFN Unit 2 3.6/4.6-17 AMENDMENT NO. X Q P

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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Y LIMITING CONDITIONS FOR OPERATION JAN 19 1988 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 be correlated to the specified parameters through established methods.

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a ssa dd 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 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 AMENQMEHTHo. I6 Pi FuNc7'IQNp<

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~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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 Unit 2 3.6/4.6-34 AMENDMENTNO. I8 0

3.6/4.6

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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

~yp~

temperature, radiation, and vibration.

Inspection~~may be 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 Unit 2 3.6/4.6-35

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 4.2.K 4.2.L

3. 5-1 4.9.A Seismic Monitoring Instrument Surveillance Requirements Explosive Gas Instrumentation Surveillance ATWS-Recirculation Pump Trip (RPT)

Instrumentation Surveillance.

Minimum RHRSW and EECW Pump Assignment.

Auxiliary Electrical System 3.2/4.2-57 3.2/4.2-61 3-2/4.2-62a 3.5/4.5-11 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 Unit 3 v3.1 AMENDggg go y pg

4 P

MAR S

M OU R

LIMITING CONDITIONS FOR OPERATION

'JAN ~9 )o88 SURVEILLANCE REQUIREMENTS

[ 3.6.H.

~Sut~~

During all modes of operation, all snubbers shall be OPERABLE except as noted in 3.6.H.1.

All safet -related snubbers are listed i Surveillance Instructions>

4.6.H.

~Such~

Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspec ion program and the requirements 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.

SKa Avrhcv~o 3 Hazes laQ. R.Fg i'll'D VpgwkAPH's BFN Unit 3 3.6/4.6-15 AMBOMEHTi'. I~ 4

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0 LIMITING CONDITIONS FOR OPERATION JAN i9 1888 SURVEILLANCE REQUIREMENTS

4. 6.H. ~Sub'

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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 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

t a ~~of snubbers shall be 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 Unit 3 3.6/4.6-20 AMENDMENTg0. y g g FuHCTioHAL TEST T'fPE

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3.6/4.6 ~S 3.6,H/4.6.H

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'JAN 19 1888 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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.

BFN Unit 3 3.6/4.6-34 AMfNOMENTgg. gpss

3.6/4.6 ~ (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.

K.CLASS IF 1 ED 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 p if appl icable, that snubber may be 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 Unit 3 3.6/4.6-35

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 4.2.E Minimum Test and Calibration Frequency for Drywell Leak Detection Instrumentation

~ae 1fo 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 4.2.L ASS-Recirculation Pump Trip (RPT)

Instrumentation Surveillance 3.2/4.2-63a Explosive Gas Instrumentation Surveillance 3.2/4.2-62 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 Unit 1 vii

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, all snubbers shall be OPERABLE except as noted in 3.6.H.1.

All safety-related snubbers are listed in Plant 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.

Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 3.6.H/4.6.H.

These snubbers are listed in Plant Surveillance Instructions.

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

2.

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 4.6.8-1 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 Unit 1 3.6/4.6-15

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 Unit 1 3.6/4.6-16

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 Unit 1 3.6/4.6-17

4.

PRIMARY SYSTEM BO LI ITI G CO ITIO S OR OPE 0

C UI 4.6.H."

~Sn bbe e

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 Unit 1 3.6/4.6-18

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 Unit 1 3.6/4.6-20

Table 4.6.H-l SHUBBER VISUAL IHSPECTIOH IHTERVAL OF CCE ABLE S B RS Population or Category Notes 1 and 2

Column A Extend Interval otes and Column B Repeat Interval es 4 Column C

Reduce Interval 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 Unit 1 3.6/4.6-23b

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, if the number pf 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.

BFH Unit 1 3.6/4.6-23c

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 Unit 1 3.6/4.6-34

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 Unit 1 3.6/4.6-35

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

4.2.E Minimum Test and Calibration Frequency for Dryvell Leak Detection Instrumentation.

~aero 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 4.2.L ATWS-Recirculation Pump Trip (RPT)

Instrumentation Surveillance 3.2/4.2-63a Explosive Gas Instrumentation Surveillance.

3.2/4.2-62 3.5-1 4.6.H-l 4.9.A 4;9.A.4.C 6.2.A Snubber Visual Inspection Interval.

Diesel Generator Reliability.

3.6/4.6-23b 3.9/4.9-16 Voltage Relay Setpoints/Diesel Generator Start.

3.9/4.9-18 Minimum Shift Crev Requirements 6.0-4 Minimum RHRSW and EECW Pump Assignment.

3.5/4.5-11 BFH Unit 2 vii

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, all snubbers shall be OPERABLE except as noted in 3.6.8.1.

All safety-related snubbers are listed in Plant 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.

Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 3.6.8/4.6.H.

These snubbers are listed in Plant Surveillance Instructions.

(

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

2.

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 4.6.8-1.

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 Unit 2 3.6/4.6-15

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 Unit 2 3.6/4.6-16

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 Unit 2 3.6/4.6-17

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 Unit 2 3.6/4.6-18

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 be correlated to the 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 Unit 2 3.6/4.6-20

Table 4.6.H-1 SNUBBER VISUAL INSPECTION INTERVAL ER OF CCSPTABLE S

BERS Population or Category Notes 1 and 2

Column A Extend Interval otes and Column B Repeat Interval otes 4 and Column C

Reduce Interval 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 Unit 2 3.6/4.6-23b

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 Unit 2 3.6/4.6-23c

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 Unit 2 3'/4.6-34

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 Unit 2 3.6/4.6-35

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 4.2.E Minimum Test and Calibration Frequency for Dryvell Leak Detection Instrumentation.

Pae o

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 4.2.K 4.2.L Seismic Monitoring Instrument Surveillance Requirement s

~

Explosive Gas Instrumentation Surveillance ATWS-Recirculation Pump Trip (RPT)

Instrumentation Surveillance.

3.2/4.2-57 3.2/4.2-61 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 4.'9.A.4.C 6.2.A Auxiliary Electrical System 3.9/4.9-15 Voltage Relay Setpoints/Diesel Generator Start.

3.9/4.9-17 Minimum Shift Crew Requirements 6.0-4 BFH Unit 3 vii

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, all snubbers shall be OPERABLE except as noted in 3.6.8.1.

All safety-related snubbers are listed in Plant Surveillance Instructions.

1.

With one or more snubber(s) inoperable on a system that is required to be OPERABLE in the current plant condition, vithin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follov the appropriate Limiting Condition statement for that system.

Each safety-related snubber shall be demonstrated OPERABLE by performance of the folloving augmented inservice inspection program and the requirements of Specification 3.6.H/4.6.H.

These snubbers are listed in Plant Surveillance Instructions.]

1.

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

2.

V ual 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 BFN Unit 3 3.6/4.6-15

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 Unit 3 3.6/4.6-16

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

'nspection 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.

BFN Unit 3 3.6/4.6-17

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 Unit 3 3.6/4.6-18

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 Unit 3 3.6/4.6-20

Table 4.6.H-1 SNUBBER VISUAL INSPECTION INTERVAL Population or Category Notes 1 and 2

Column A Extend Interval otes and 0

CCEPTAB S

Column B Repeat Interval otes 4 and BERS Column C

Reduce Interval 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 Unit 3 3.6/4.6-23b

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 Unit -3 3.6/4.6-23c