ML18139C267
| ML18139C267 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/08/1983 |
| From: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| Shared Package | |
| ML18139C266 | List: |
| References | |
| NUDOCS 8303150404 | |
| Download: ML18139C267 (7) | |
Text
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ATTACHMENT l PROPOSED TECHNICAL SPECIFICATION CHANGE
TS 4.17-3
- 2.
Snubbers which appear inoperable as a result of visual inspections may be determined operable for the purpose of establishing the next visual inspection interval, providing that the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible and the affected snubber is functionally tested in the as found condition and determined operable per Specification 4.17-D or 4.17-E, as applicable.
- 3.
When the fluid port of a hydraulic snubber is found to be uncovered, the snubber shall be determined inoperable and cannot be determined operable via functional testing for the purpose of establishing the next visual inspection interval.
All snubbers connected to an inoperable common hydraulic fluid reservior shall be counted as inoperable snubbers.
C.
Functional Tests
- 1.
At least once per 18 months during shutdown, a representative sample of 10% of the total of each type of snubber used in the plant shall be functionally tested either in place or in a bench test.
- 2.
The representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capacity of snubbers.
- 3.
At least 25% of the snubbers in the representative sample shall include snubbers from the following three categories:
- a.
The first snubber away from each reactor vessel nozzle
- b.
Snubbers within 5 feet of heavy equipment (valve, pump, turbine, motor, etc.)
l e
TS 4.17-4
- c.
Snubbers within 10 feet of the discharge from a.safety relief valve.
- 4.
Snubbers identified in Tables 4.17-1 and 4.17-2 as "Especially Difficult to Remove" or in "High Radiation Zones During Shutdown" shall also be included in the representative sample.*
- 5.
In addition to the regular sample, snubbers which failed the previous fun~tional 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 re-sampling.
- 6.
For each snubber that does not meet the functional acceptance criteria of Specifications 4.17-D or 4.17-E, an additional 10%
of that. type of snubber shall be functionally tested.
- 7.
For snubbers of 50 kips and above that are extremely difficult to remove or in high radiation zones that fail the functional testing, an engineering evaluation is required to determine the failure mode.
If the failure is determined to be non-generic; an additional 10% of that category will be tested during the next functional test period.
- Permanent or other exemptions from functional testing* for individual snubbers in these categories may be granted by the Commission only if. a justifiable basis for exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their fabrication or at subsequent date.
D.
TS 4.17-5
- 8.
If any snubber selected for functional testing either fails to lockup or fails to move, i.e., frozen in place, the cause will be evaluated and if caused by manufacturer or deaign 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.
- 9.
For the snubber(s) found inoperable, an engineering evaluation shall be performed on the components which are supported by snubber(s).
The purpose. of this engineering evaluation shall be to determine if the components supported by the snubber(s) were adversely affected by the inoperability of the snubber(s) in order to ensure that the supported component remains capable of meeting the designed service.
Hydraulic Snubbers Functional Test Acceptance Criteria
- 1.
The hydraulic snubber functional test shall verify that:
- a.
Activity (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.
- b.
Snubber bleed, or release rate, where required, is within the specified range in compression and tension.
For snubbers specifically required to not displace under continuous load, the ability of the snubber to withstand load without displace-ment shall be verified.
ATTACHMENT 2 DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE
DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE This proposed change is to revise the schedule of functional test requirements of snub be rs in the 50 kips and above category.
Currently, the -requirement is to test 10% of the snubbers in this category at each functional test period.
In the event of a failure during testing, an additional 10% of the snubbers in this category are tested.
Vepco will continue to test 10% of the snubbers at_
each functional test period.
In the event of a failure, the schedule for testing the additional 10% of snubbers in this category will be determined based on an engineering evaluation.
If the evaluation determines the failure to be non-generic, that snubber will be repaired or replaced as necessary and an additional 10% of the snubbers in the 50 kips and above category will be tested at the next functional test period.
If the failure is determined to be generic, an additional 10% of the snubbers in this category will be tested during the present test period.
This does not pose a safety hazard as testing of the additional 10% is rescheduled only if the failure is determined to be non-generic.
A large maintenance effort is required to remove the 50 kips and above category snubbers which are then sent offsite for testing.
Testing an additional 10% of the snubbers in this category during the same test period is not warranted solely because of a specific non-generic failure.
Testing during the next test interval allows for scheduling of work to support the maintenance effort and will minimize the impact of snubber surveillance and maintenance on the plant.
The probability of occurrence or the consequence of an accident or malfunction of equipment important to safety and previously evaluated in the UFSAR is not increased since the changes do not affect the overall snubber operability and snubber service life.
The potential for an accident or malfunction of a different type than previously evaluated in the Safety Analysis Report is not increased because the overall snubbers performance will not be changed.
The required margin of safety of the basis of Technical Specifications is not reduced because the overall operability of snubbers will not be affected.
COMMONWEALTH OF VIRGINIA)
)
CITY OF RICHMOND
)
The foregoing document was acknowledged before me, in and for the City and Connnonwealth aforesaid, today by W. L. Stewart, who is Vice President-Nuclear Operations, of the Virginia Electric and Power Company.
He is duly authorized to execute and file the foregoing document in behalf of th_at Company, and the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this gd-day of ~
, 19 J> 3 My Conunission expires:
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, 19
,a S Notary Public (SEAL)
M2/004