ML18052B038

Application for Amend to License DPR-20,changing Tech Specs by Removing or Replacing Snubbers Listed in Tables 3.20.1 & 3.20.2 During Maint Outage Scheduled to Begin in Oct 1987. Fee Paid

ML18052B038
Person / Time
Site:	Palisades
Issue date:	05/28/1987
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18052B039	List: ML18052B038 ML18052B040
References
GL-84-13, NUDOCS 8706030350
Download: ML18052B038 (7)

Text

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consumers Power Kenneth W Berry POWERIN& Director llllCHl&AN'S PRO&RESS Nuclear Licensing General Offices: 1945 West Parn'an Road, Jackson, Ml 49201 * (517) 788-1636 May 28, 1987 Nuclear Regulatory Counnission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TECHNICAL SPECIFICATIONS CHANGE REQUEST - SAFETY RELATED HYDRAULIC AND MECHANICAL SHOCK SUPPRESSORS - SNUBBERS Enclosed is a request to change the Palisade$ Technical Specifications. The enclosed change request incorporates changes to remove the snubber lists from the Specifications as provided for in NRC Generic Letter 84-13. It also deletes specific acceptance criteria for mechanical snubbers and clarifies functional ~esting requirements for snubbers of rated capacity greater than 50,000 pounds.

Certain snubbers listed in the present Tables 3.20.1 and 3.20.2 (which are requested to be deleted) will be removed or replaced with struts during the Maintenance Outage scheduled to begin'in October 1987. Action to approve this proposed change is requested prior to the start of the outage. Approval prior to the October outage will provide the opportunity to remove some snubbers before that time and minimize outage activities.

A check in the amount of $150.00 is attached as required by 10CFR170.12.

Kenneth W Berry Director, Nuclear. Licensing CC Administrator, Region III, NRC NRC Resident .Insl'ector - Palisades 706030350 870528 PDR ADOCK 05000255 P PDR

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OC0587-0063-NL04 f¥P.\'

CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:

I. Changes A. In Specification 3.20 change the Applicability statement to read as follows:

"Applies to the operating status of the safety-related piping shock suppressors (snubbers). The only snubbers excluded from this requirement are those installed on nonsaf ety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related s~stem."

B. Change Specification 3.20.1 to read as follows:

"During all modes on operation except cold shutdown and refueling, all snubbers encompassed per Specification 3.20 shall be operable except as noted below:"

C. Add Bases statement for Specification 3.20 as follows:

"Snubbers are required to be operable to ens.ure that the structural integrity of the reactor coolant system and all other safety-related systems is maintained during and following a seismic or other event initiating dynamic loads."

D. Delete Table 3.20.1.

E. Delete Table 3.20.2.

F. In Specification 4.16, change the Applicability statement to read as follows:

"Applies to periodic surveillance of safety-related snubbers as described per Specification 3.20."

Also change footnote identifiers in 4.16.la to 1 and 2, and change the corresponding .footnotes to 1 and 2.

G. Change the double asterisk in the first paragraph of Specification 4.16.lc to a 3 and revise the footnote to read as follows:

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TSCR Snubbers 2 113 snubbers of rated capacity greater than 50,000 pounds are not to be included when defining the total number of safety-related snubbers in use at the plant."

H. Revise the second paragraph in Specification 4.16.lc to read as follows:

" *** Snubbers identified as especially difficult to remove or in high radiation zones during shutdown shall also be included in the 4

representative sample. "

Also change the asterisk footnote to footnote 4.

I. Add a new paragraph to Specification 4.16.lc to read as follows:

(see page changes)

"Snubbers of rated capacity greater than 50,000 pounds will be functionally tested in lots comprising 25% of their total during each refueling outage. In the event of one snubber failure out of the four tested, no additional snubbers will be tested provided the problem is non-generic. For each additional snubber failure, however, two additional snubbers will be tested until no further snubber failures are identified or all snubbers have been tested.

Generic failures will be handled as the specific circumstances require."

J. Change Specification 4.16.le.l. to read as follows:

"l. The force that initiates free movement of the snubber rod in either tension or compression is less than the specified maximum drag force (break away friction)."

K. Revise the second paragraph to Specification 4.16.lf. to read as follows:

" ..* records for each safety-related snubber in use in the plant shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber life review. If the indicated service life will be exceeded ..* "

L. Delete the first paragraph in the Bases for Specification 4.16.

M. In the Specification 4.16 Bases, change the second to last paragraph to read as follows:

"To provide assurance of snubber functional reliability, a representative sample of the installed snubbers, excluding snubbers of rated capacity greater than 50,000 pounds, will be functionally tested at 18 month intervals. A representative sample of snubbers OC0587-0063-NL04

TSCR - Snubbers 3 of rated capacity greater than 50,000 pounds will be functionally tested each refueling outage."

II. Discussion The changes proposed in Specification 3.20 (A, B, D and E above) are requested to delete the snubber listings from the Technical Specifications. The NRC letter of July 31, 1984 to all SEP Licensees provided Generic Letter 84-13 which concluded that snubber listings are not necessary provided the Technical Specifications are modified to specify which snubbers are required to be operable. The changes proposed in this change request are consistent with the model specifications attached to Generic Letter 84-13.

The only snubbers excluded are those snubbers installed on non-safety related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system. The applicable snubbers are those currently listed in Tables 3.20.~ and 3.20.2. The information contained in these Tables currently is being added to Engineering Manual (EM) 09-07, "Testing of Plant Snubbers". Any deletion, change in snubber classification, or change in testing requirements would constitute a revision to EM-09-07. EM-09-07 revisions are required to have a 10CFR50.59 Safety Evaluation and PRC review prior to issuance.

Therefore, an appropriate level of review is maintained to ensure control of the information currently found in Tables 3.20.1 and 3.20.2.

Also, any change to the snubbers as installed would constitute a specification or facility change, thereby necessitating a Safety Evaluation be performed.

Proposed change C provides a bases statement for Specification 3.20 that is ~onsistent with the Standard Technical Specifications. The bases for Specification 4.16 (change L) previously contained the proposed wording but was considered to be inappropriately located in section 4. This change is administrative.

Proposed changes F, H, and Kare specific changes made due to deletion of Tables 3.20.1 and 3.20.2.

Changes G and M above, with respect to the functional testing requirements of snubbers of rated capacity greater than 50,000 pounds, is being made to incorporate current plant practices in accordance with the commitment made to the NRC in response to IEIR 83-25. In the response, dated May 29, 1985, Consumers Power Company committed to functional testing 25% of the snubbers of rated capacity greater than 50,000 pounds (large bore) each refueling outage. ASME Code,Section XI, requires testing a representative sample composing 10% of the total number of safety related snubbers during each inspection period. The large bore snubbers (16) will not be counted as part of the total sample lot. By testing 4 of the 16 (25%) large bore snubbers each OC0587-0063-NL04

TSCR - Snubbers 4 refueling outage, Palisades will ensure a testing frequency that exceeds the ASME Code,Section XI requirements.

Change I requests deletion of the specific mechanical snubber functional test acceptance criteria value, i.e., 2% of the rated load of the snubber. The change provides consistency with the hydraulic snubbers specification which has no specific acceptance criteria. This change is consistent with the Standard Technical Specifications and will prevent future Technical Specifications changes when replacement snubbers are installed with different acceptance criteria.

The specific acceptance criteria value currently is contained in Technical Specifications Surveillance Procedure RM-89, Functional Testing of Mechanical Snubbers. This procedure and its associated basis document are controlled documents which, when revised, require a 10CFR50.59 Safety Evaluation and PRC review be performed.

Change J deletes the specified maximum drag force of 2% of rated load of the snubbers and proposes general acceptance criteria. The specific vendor supplied acceptance criteria will be appropriately placed in the maintenance procedures ~overing the snubber surveillance. The Standard Technical Specifications also include additional acceptance criteria in addition to the maximum specified drag force. The additional criteria states the drag force shall not have increased more than 50% since the last functional test. This criteria does not coincide with our vendor criteria which only specifies a maximum drag force for the Palisades snubbers. A Typical value for drag force for the Palisades snubbers has been 1.1% of rated load. A 50% increase to 1.65% would still be within the acceptable specified maximum drag force of 2%. Consumers Power Company does not find it appropriate to impose this 50% increase limit as a Technical Specification wherein an additional snubber would be required to be functionally tested. Consumers Power will apply the 50%

increase in drag force as an administrative limit which will require an evaluation to determine if the increase has affected the snubber operability and ensure the snubber remains capable of its intended function.

For your information there are presently 9 mechanical snubbers at Palisades. A program to reduce the plant snubbers will result in 6 snubbers being removed prior to or during the 1987 maintenance outage.

The remaining 3 snubbers will be tested at intervals of one per 18 months.

Change L deletes a bases paragraph in Specification 4.16. This paragraph has been incorporated into the applicability statement and bases for specification 3.20. where it is more appropriate.

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TSCR - Snubbers 5 Analysis of No Significant Hazards Consideration The deletion of Tables 3.20.l and 3.20.2, "Safety Related Hydraulic and Mechanical Shock Suppressors (Snubbers)", from the Technical Specifications is addressed in NRC Generic Letter 84-13, and is acceptable as long as the Technical Specifications are modified to specify which snubbers are to be operable. This has been done in Technical Specification 3.20 by stating that the only snubbers excluded from Technical Specifications requirements are those snubbers that are installed on non-safety related systems, and then only if their failure, or failure of the system on which they are installed, would have no adverse effect on any safety related system. The snubbers that the proposed requirements are applicable to are those listed in present Tables 3.20.i and 3.20.2. The information contained in Tables 3.20.l and 3.20.2 will be retained in Engineering Manual (EM) 09-07, "Testing of Plant Snubbers". Any future deletion of snubbers now listed in Tables 3.20.l and 3.20.2 would constitute a specification or facility change and require a subsequent change be made to EM-09-07; thus, requiring a 10CFR50.59 Safety Evaluation to be performed and subsequent review by the Plant Review Committee (PRC). These administrative controls governing plant modifications will ensure that neither the probability of occurrence nor the consequences of an accident or malfunction of equipment important to safety are increased by removing the tables from the Technical Specifications. The administrative controls also will ensure the possibility of an accident or malfunction of a different type will not be created with removal of the tables.

The caanges in Technical Specification 4.16.lc were made to clarify the plant's current practice of testing 25% of snubbers with rated capacity greater than 50,000 pounds each refueling outage. Snubbers in this category are considered a separate entity from all others which are functionally tested in a representative sample lot consisting of 10% of the total each inspection period per ASME Code,Section XI. Therefore, snubbers of rated capacity greater than 50,000 pounds will receive a higher frequency of testing, so that the possibility of occurrence or consequences of an accident or malfunction of equipment important to safety is decreased.

The deletion of the specific mechanical functional test acceptance criteria value from Technical Specifications will not increase the probability of occurrence of an accident or malfunction of equipment important to safety, because the specific acceptance criteria value will be (as it currently is) controlled in a Technical Specification Surveillance Procedure. This is consistent with the current treatment of hydraulic snubbers and the manner in which acceptance criteria are presented in Standard Technical Specifications. Surveillance Procedures governing the functional testing of both mechanical and hydraulic snubbers are controlled procedures requiring a PRC review, and require a 10CFRS0.59 Safety Evaluation be performed prior to procedure revision.

These administrative controls, including the procedures, reviews, and OC0587-0063-NL04

TSCR - Snubbers 6 safety evaluations will ensure the possibility of an accident or malfunction of a different type has not been created by this Technical Specifications Change. With the administrative controls, the deletion of the specific test acceptance criteria will not affect the margin of safety.

The removal of the snubber tables from the Technical Specifications in conjunction with the addition of the redefined Applicability statement in proposed Specification 3.20 does not affect the margin of safety.

The proposed functional test requirements in Specification 4.16.lc and the bases for 4.16 were changed to incorporate the commitment to test 25% of the snubbers with rated capacity greater than 50,000 pounds during each refueling outage. These proposed changes represent additional Technical Specification controls that exceed the required ASME Code,Section XI requirements for sample size (ie., 25% of the total each refueling outage versus 10% of the total each inspection period). These additional controls will increase the margin of safety that is defined in the basis of the Technical Specifications.

III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no significant hazards consideration. This change also has been reviewed under the cognizance of the Nuclear Safety Board. A copy of this Technical Specifications Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY By nolds, Executive Vice Energy Supply Sworn and subscribed to before me this 28th day of May 1987.

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Jackson County, Michigan My commission expires October 31, 1989 OC0587-0063-NL04