ML18065B183

Revised Application for Amend to License DPR-20,requesting Relocation of TS Section 4.16 Snubber Testing Requirements to Plant Operating Requirements Manual (Orm).Affected Orm Pages Encl

ML18065B183
Person / Time
Site:	Palisades
Issue date:	03/13/1998
From:	Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M99656, NUDOCS 9803240295
Download: ML18065B183 (17)

Text

r .*1 A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 2490 Covert, Ml 49043 Nathan L. Haskell Director, Licensing March 13, 1998 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REVISED TECHNICAL SPECIFICATION CHANGE REQUEST - DELETION OF SNUBBER REQUIREMENTS - TAC Number M99656 The Palisades Plant submitted a Technical Specifications Change Request (TSCR) on September 3, 1997, proposing deletion of the Technical Specifications (TS) snubber requirements. That letter proposed deleting the subject requirements and placing reliance on the ASME code inspection and testing required by 10 CFR 50.55a; it also included a revised Relief Request for certain Snubber testing requirements of the ASME code. This request modifies the Technical Specifications changes proposed by that letter. A revision to the Snubber Relief Request proposed by that letter will be submitted separately.

The NRR Palisades Project Manager and the TSCR technical reviewer informed us that while 10 CFR 50.55a does require inservice inspection of snubbers in accordance with the ASME code, it does not require licensees to perform snubber testing. Therefore, our former request to delete TS Section 4.16 is hereby revised to request 11 relocation 11 of TS Section 4.16 snubber testing requirements to the Palisades Operating Requirements Manual (ORM). This l\1JJ-l*'1 I .

revised request will still delete the snubber testing requirements from the TS, but identical requirements have been added to the ORM. These ORM requirements provide an adequate level of assurance that the snubber testing will be performed. ORM changes are controlled under the requirements of 10 CFR 50.59.

9803240295 980313 PDR ADOCK 05000255 P PDR

• 2 The ~S snubber Operability and Action requirements, contained in TS Section 3.20, have been deleted from the proposed TS. These proposed changes are discussed as Changes A and B of our September 3, 1997 TSCR. The discussion of the proposed changes and the No Significant Hazards Analyses for Changes A and B submitted with our September 3, 1997 TSCR are still appropriate for this revised request. That discussion and the No Significant Hazards Analyses are repeated in Enclosure 1 to this letter.

The TS snubber survei Tl ance requirements, contained in TS section 4 .16, have been added to the Palisades ORM. This proposed change, Change E, replaces proposed Changes C and D of our September 3, 1997 TSCR. A discussion of the proposed change and a No Significant Hazards Analysis for Change E, are provided in Enclosure 1 to this letter. The affected ORM pages are included as Enclosure 2 to this letter. The ORM has previously been incorporated into the Palisades FSAR by reference.

The proposed TS pages submitted with our September 3, 1997 TSCR are still appropriate for this revised request.

Consumers Energy Company requests approval of this TSCR by April 30, 1998, to support the 1998 Refueling Outage. It is also requested that the license amendment associated with this TSCR be effective upon approval.

A copy of this letter has been sent to the appropriate official of the State of Michigan.

SUMMARY

OF COMMITMENTS This letter establishes no new commitments and makes no revisions to existing commitments.

-'tlif~~

than L. Haske 11 rector, Licensing CC Administrator, Region III, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Dennis R. Hahn, Michigan Department of Environmental Quality Enclosure

• 3 CONSUMERS ENERGY COMPANY TECHNICAL SPECIFICATIONS CHANGE REQUEST To the best of my knowledge, the content of this revised Technical Specifications change request, which deletes the explicit Technical Specifications requirements for snubber operability and testing, is truthful and complete.

Nathan L. Haskell Director, Licensing Sworn and subscribed to before me this /3),f, day of ~ 1998.

Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)

My commission expires August 26, 1999

ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REVISED TECHNICAL SPECIFICATIONS CHANGE REQUEST DELETION OF SNUBBER REQUIREMENTS

• • e CONSUMERS POWER COMPANY Docket 50-255 Technical Specifications Change Request License DPR-20 It is requested that the Technical Specifications contained in the Facility Operating License DPR-20, Docket 50-255, for the Palisades Plant be changed as described below. This request revises a Technical Specifications change request which was submitted on September 3, 1997.

The following abbreviations are used in this change request:

AOT Allowed Outage Time LCO Limiting Condition for Operation ORM Operating Requirements Manual STS Standard Technical Specifications (NUREG 1432)

TS Current Palisades Technical Specifications The proposed changes are described below. Each change is classified as one of the following categories:

ADMINISTRATIVE - A change which is editorial in nature, which only involves movement of requirements within the TS without affecting their technical content; or clarifies existing TS requirements.

MORE RESTRICTIVE - A change which only adds new requirements, or which revised an existing requirement resulting in additional operational restriction.

LESS RESTRICTIVE - A change which deletes any existing requirement, or which revises any existing requirement resulting in less operational restriction.

I. The following Changes are Proposed:

TS 3.20, "Shock Suppressors (Snubbers)", and the associated Surveillance Requirement, TS 4.16 "Inservice Inspection Program for Shock Suppressors (Snubbers)," have been deleted from the TS. TS pages 3-79b and 4-70 have been revised to show the deletion of page 3-80 and pages 4-71 through 4-71a. The revised TS pages were included in our September 3, 1997 Snubber TSCR. TS 3.20 is comprised of two requirements, LCO 3.20.1 and Action 3.20.la. The effects of deleting each of these requirements, and the effects of relocating the requirements of TS 4.16 to the ORM are discussed separately.

2 A. LCO 3.20.1, on page 3-80, has been deleted. LCO 3.20.1 states:

When systems associated with snubbers in Specification 3.20 are required to be OPERABLE, the snubbers in those systems shall be OPERABLE except as noted below:

Deletion of this explicit LCO for snubber operability will not remove the necessity for the snubber to be operable. Those snubbers in systems which are required to be operable would still be the subject of TS operability requirements because they are included in the TS definition of operability. In order for required systems, to be considered Operable (as defined in Section 1.0 of TS), required snubbers must be capable of 11 performing their related support function since they are 11 11 necessary attendant auxiliary equipment. 11 Therefore, despite deletion of the explicit snubber LCO, snubbers installed in systems required to be operable by TS.would themselves be required to be operable. This proposed treatment of snubber operability requirements is the same as that in STS.

Since snubber operability would still be required for system operability, Change A does not alter any TS requirements and is therefore classified as Administrative.

B. Required Action 3.20.la, page 3-80, has also been deleted.

Action 3.20.la states:

With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubbers to OPERABLE status and perform an engineering evaluation per Specification 4.16.1.c. on the supported component or declare the system inoperable.

TS Action 3.20.1 provides a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AOT in which to replace an inoperable snubber, to restore it to operable status, or to declare the supported system inoperable. Snubbers are considered to be 11 necessary attendant auxiliary equipment. 11 Therefore, in order for a system to be considered Operable, the associated required snubbers must be capable of performing their related 11 support function. 11 Deletion of Action 3.20.la will require that a supported system-be declared to be inoperable immediately upon discovery that a required snubber is inoperable. Plant operation would then be limited by the Actions in the LCO for the supported system. This proposed treatment of inoperable snubbers is the same as that in STS.

3 Change B represents a reduction in the time allowed for continued operation when a required snubber becomes inoperable. Therefore, Change B is classified as More Restrictive.

C. Change C proposed in the September 3, 1997, TSCR is no longer proposed.

Attachments 3 and 4 to our September 3, 1997, TSCR were associated with Change C. Those attachments are no longer applicable.

D. Change D proposed in the September 3, 1997, TSCR is no longer proposed.

Change D had proposed relocating one portion of TS Section 4.16 to the ORM. That relocation is included within the changes proposed as Change E, below.

E. The testing requirements of TS 4.16 have been relocated to the Palisades ORM.

The change would delete the TS 4.16 requirements from the TS; identical requirements have been added to the ORM. Revision 19 to the Palisades FSAR revised Section 12.3.3 to incorporate the ORM into the FSAR by reference. ORM revisions are controlled under the provisions of 10 CFR 50.59.

Change E deletes TS Section 4.16 requirements. However, identical requirements have been added to a document (the ORM) controlled under 10 CFR 50.59. Change E is classified as Less Restrictive.

4 II. Analysis of No Significant Hazards Consideration Consumers Power Company finds that this proposed TS change involves no significant hazards and accordingly, a no significant hazards determination in accordance with 10 CFR 50.92(c) is justified.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

1. Administrative Change (Change A):

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11 Administrative changes make wording changes which clarify existing TS 11 I I

requirements, without affecting their technical content. Since I 11 Administrative 11 changes do not alter the technical content of any  !

requirements, they cannot involve a significant increase in the probability or consequences of an accident previously evaluated.

2. More Restrictive Change (Change B):

"More Restrictive" changes only add new requirements, or revise existing requirements to result in additional operational restrictions. The TS, with all "More Restrictive" changes incorporated, will still contain all of the requirements which existed prior to the changes. Therefore, 11 More Restrictive" changes cannot involve a significant increase in the probability or consequences of an accident previously evaluated.

3. Less Restrictive Change (Change E):

Change E deletes the TS requirements for snubber testing, but adds identical requirements to a document (the ORM) controlled under 10 CFR 50.59.

10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report (without prior NRC approval) 11 if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased". Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, moving of a requirement from the TS to a document which is controlled under 50.59 cannot involve a significant increase in the probability or consequences of an accident previously evaluated.

5 Do the proposed changes create the possibility of a new or different kind of accident from any previously evaluated?

1. Administrative Change (Change A):

11 Administrative 11 changes make wording changes which clarify existing TS requirements, without affecting their technical content. Since 11 Administrative 11 changes do not alter the technical content of any requirements, they cannot create the possibility of a new or different kind of accident from any previously evaluated.

2. More Restrictive Change (Change B):

11 More Restrictive 11 changes only add new requirements, or revise existing requirements to result in additional operational restrictions. The TS, with all 11 More Restrictive" changes incorporated, will still contain all of the requirements which existed prior to the changes. Therefore, 11 More Restrictive 11 changes cannot create the possibility of a new or different kind of accident from any previously evaluated.

3. Less Restrictive Change (Change E):

Change E deletes the TS requirements for snubber testing, but adds identical requirements to a document (the ORM) controlled under 10 CFR 50.59.

10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report (without prior NRC approval) 11 if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created 11

• Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, relocation of a requirement from the TS to a document which is controlled under 50.59 cannot create the possibility of a new or different kind of accident from any previously evaluated.

Do the proposed changes involve a significant reduction in a margin of safety?

1. Administrative Change (Changes A):

11 Administrative 11 changes make wording changes which clarify existing TS requirements, without affecting their technical content. Since 11 Administrative 11 changes do not alter the technical content of any requirements, they cannot involve a significant reduction in a margin of safety.

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2. More Restrictive Change (Change B):

"More Restrictive" changes only add new requirements, or revise existing requirements to result in additional operational restrictions. The TS, with all "More Restrictive" changes incorporated, will still contain all of the requirements which existed prior to the changes. Therefore, "More Restrictive" changes cannot involve a significant reduction in a margin of safety.

3. Less Restrictive Change (Change E):

Change E deletes the TS requirements for snubber testing, but adds identical requirements to a document (the ORM) controlled under 10 CFR 50.59.

10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report (without prior NRC approval) 11 if the margin of safety as defined in the basis for any technical specification is reduced". Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, relocation of a requirement from the TS to a document which is controlled under 50.59 cannot involve a significant reduction in a margin of safety.

II I. Cone 1us ion The Palisades Plant Review Committee has reviewed these proposed TS changes and has determined that proposing these changes does not involve an unreviewed safety question. Further, these changes involve no significant hazards consideration. These changes have been reviewed by the Nuclear Performance Assessment Department.

ENCLOSURE 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REVISED TECHNICAL SPECIFICATIONS CHANGE REQUEST DELETION OF SNUBBER REQUIREMENTS OPERATING REQUIREMENTS MANUAL SNUBBER REQUIREMENTS 6 Pages

Standing Order 54 Revision 44 Attachment 1 Page 22 of 27 4.16 INSERVICE INSPECTION PROGRAM FOR SHOCK SUPPRESSORS fSnubbers)

Applicability Applies to periodic surveillance of safety-related snubbers.

4.16.1 Requirements Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program in addition to the requirements of Technical Specification 6.5. 7. As used in this section, "type of snubber" shall mean snubbers of the same design and manufacturer, irrespective of capacity.

a. Visual Inspection Snubbers are categorized as inaccessible or accessible during reactor operation. Each of these categories (inaccessible and accessible) may be inspected independently according to the following paragraph:

If one or more unacceptable snubbers are found, the next inspection interval shall be 2/3 (-25%) of the previous interval. If no unacceptable snubbers are found, the next interval may be doubled (-

25 %), but not to exceed 48 months. The interval extension provisions of Technical Specification 4.0.2 are applicable for all inspection intervals up to and including 48 months.

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

• Standing Order 54 Revision 44

• Attachment 1 Page 23 of 27 4.16 INSERVICE INSPECTION PROGRAM FOR SHOCK SUPPRESSORS (Snubbers)

(continued)

b. Visual Inspection Acceptance Criteria Visual inspection 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 as 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 Section 4. 1 6. 1d or 4.16.1 e, as applicable. All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval.

A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the action requirements shall be met.

Standing Order 54 Revision 44

• Attachment 1 Page 24 of 27 4.16 INSERVICE INSPECTION PROGRAM FOR SHOCK SUPPRESSORS (Snubbers)

(continued)

c. Functional Tests At least once per 18 months during shutdown, a representative sample (10% of the total safety-related snubbers in use at the plant) shall be functionally tested either in place or in a bench test. The test shall verify the snubber has freedom of movement and is not frozen up. For each snubber which did not meet the functional test acceptance criteria of Section 4.16.1.d or 4.16.1 .e, an additional 10%

of the total shall be functionally tested. 11 )

The representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capacity of snubbers. Snubbers identified as especially difficult to remove or in high radiation zones during shutdown shall also be included in the representative sample. 12)

In addition to the regular sample, snubbers which failed the previous functional test shall be retested during the next test period. If a spare snubber has been installed in place of a failed snubber, then both the failed snubber (if it is repaired and installed in another position) and the spare snubber shall be retested. Test results of these snubbers may not be included for the resampling.

If any snubber selected for functional testing either fails to lockup or fails to move, ie, frozen in place, the cause will be evaluated and, if caused by manufacturer or design deficiency, all snubbers of the same design subject to the same defect shall be functionally tested. This testing requirement shall be independent of the requirements stated above for snubbers not meeting the functional test acceptance criteria.

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.

2 Permanent or other exemptions from functional testing for individual snubbers may be granted by the Commission only if a justifiable basis for exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the

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.Standing Order 54

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Attachment 1 Revision 44 Page 25 of 27 4.16 INSERVICE INSPECTION PROGRAM FOR SHOCK SUPPRESSORS ISnubbers) 4.16.1 c. Functional Tests {continued)

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.

For the snubber{s) found inoperable, an engineering evaluation shall be performed on the components which are suppressed by the snubber{s).

The purpose of this engineering evaluation shall be to determine if the components suppressed by the snubber{s) were adversely affected by the inoperability of the snubber{s) in order to ensure that the suppressed component remains capable of meeting the designed service.

d. Hydraulic Snubbers Functional Test Acceptance Criteria The hydraulic snubber functional test shall verify that:

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

2. Snubber bleed, or release rate, where required, is within the specified range in compression or tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

e. Mechanical Snubbers Functional Test Acceptance Criteria The mechanical snubber functional test shall verify that:

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

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

• standing Order 54 Revisi~n 44

• Attachment 1 Page 26 of 27 4.16 INSERVICE INSPECTION PROGRAM FOR SHOCK SUPPRESSORS (Snubbers)

(continued)

3. Snubber release rate, where required, is within the specified range in compression or tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

f. Snubber Service Life Monitoring A record of the service life of each snubber, the date at which the designated service life commences and the installation and maintenance records on which the designated service life is based shall be maintained.

Concurrent with the first inservice visual inspection and at least once per 18 months thereafter, the installation and maintenance records for each safety related snubber 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 service life review. If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

This re-evaluation, replacement or reconditioning shall be indicated in the records.

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

Standing Order 54 Revision 44 Attachment 1 Page 27 of 27

4. 1 6 Basis (continued)

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

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

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

Hydraulic snubbers and mechanical snubbers may each be treated as a different entity for the above surveillance programs.

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