ML18227C716

Letter Transmitting Proposed Amendment to Facility Operating Licenses, Changing to Tech Spec Relating to Surveillance of safety-related Hydraulic Snubbers at Turkey Point Units 3 and 4

ML18227C716
Person / Time
Site:	Turkey Point
Issue date:	03/22/1976
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-76-119
Download: ML18227C716 (29)

Text

NRC FORM 195 I2 76)

U.S. NUCLEAR REGULATORY CI MMISSION DOCKET NU14BER WF-'~)f251 NRC DISTRIBuTION FoR PART 50 DOCKET MATERIAL FILE NUMBER Mr. VS Stello FROM:

FPL Miami, Fla.

33101 R.E. Uhrig DATE OF DOCUMENT 3-22-76 DATE RECEIVED 3-29-76 BETTE R XROR IGINAL OCOr Y ONOTOR IZED ZRUNC LASS I F I E D PROP INPUT FORM NUMBER OF COPIES RECEIVED 3 Orig & 37 CC DEscRIPTIDN Ltr requesting or am t to PP of OL/DPR-31 & DPR-41 related to hydraulic snubbers

& trans the following:

ENctosURE Revised

& addi pages to Proposed Chan e

i'n re to hydraulic snubbers...

(40 cys encl rec'd)

PLANT NAME.

Turkey Pt. Units 3 & 4 SAFETY ASSXGNED AD BRANCH CHIEF:

FOR ACTION/INFORMATION ASSXGNED AD:

BRANCH CHIEF

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ENVIRO D

3-30-76 PROJECT hfANAGER:

IC, SST,:

PROJECT MANAGER !

LIC~ ASST G F LN L

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NRC PDR L+

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I&E GOSSICK & STAFF PROJECT MANAGEMENT BOYD P,

COLLINS HOUSTON PETERSON MELTZ HELTEMES SKOVHOLT LPDR Mia

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TIC NS ASLB SE RC FORM 195 I2.76)

INTERNALD EN INEER N KNIGHT SXHImXL PAWLXCKI REACTOR SAFETY ROSS NOVAK ROSZTOCZY CHECK AT & I SALTZlfAN RUTBERG EXTERNAL DISTRIBUTION NATL LAB REG, V-IE LA PDR CONSULTANTS

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ISTRl BUTION BENAROYA BROOKfIAVEN NATL LAB ULRIKSON(ORNL)

IPPOLITO OPERATING REACTORS STELLO OPERATING TECH EXSENHUT SHAO BAER SCHIOENCER GRIMES SITE. SAFETY & ENVIR ANALYSIS DENTON & HULLER ERNST ALLARD SPANGLER SITE TECH GAMMXLL STEPP HULMAN SITE ANALYSXS VOLIPIER BUNCH J

COLLINS KREGER CONTROL NUMBER Q/0 T

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~g FLORIDA POWER 8L LIGHT COMPANY

,.March 22, 1976 L-76-119 M

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Director of Nuclear Reactor Regulation Attention:

Mr.-'i.ctor,'Stello, Jr., Director Division of Operating Reactors U.

S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Stello:

Re:

Turkey Point Units 3 and 4

Docket Nos. ~and 50-251 Proposed Amendment to Facility Operatin Licenses DPR-31 and DPR-41 0+X+ ~Z> >

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'0 Xn accordance with 10 CFR 50.30, Florida Power s Light, Company submits herewith three (3) signed originals and forty (40) conformed copies of a request to amend Appendix A of Facility Operating Licenses DPR-31 and DPR-41.

This submittal proposes Technical Specification changes relating to the surveillance of safety-related hydraulic snubbers at, Turkey Point Units 3 and 4.

The proposal supplements and modifies our proposal of November 6, 1974 and is based on model Technical Specifications transmitted to Florida Power 6 Light Company by your staff on December 24, 1975.

Th'e proposed Technical Specification changes are as described below and as shown in the accompanying Technical Specification pages bearing the date of this letter in the lower right hand corner.

P~ae ii The Table of Contents is revised to include Sections 3.12 and 4.14.

Pacae iii The Table of Contents is revised to include Sections B3.12 and B4.14.

Pacae iv The List of Tables is revised to include Table 3.12-1-.

HELPING BUILD FLORIDA

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Director of Nuclear Reactor Regulation Page

Two,

,March 22; 1976 Page'

3. 12-1,'

new specification 3.12 is added to define the limiting con-ditions for operation applied to the operability of safety-related hydraulic snubbers.

Table 3.12-1, Sheets 1 throu h 4

A new Table 3.12-1 is added to identify all safety-related hydraulic snubbers on Units 3 and 4.

The table has four categories which identify snubbers that are (a) in high radiation areas, (b) especially difficult to remove, (c) inaccessible during normal operation, and (d) accessible during normal operation.

There are currently no hydraulic snubbers which fall in three of the four categories,

however, these categories are included for ease of future amendment should hydraulic snubbers ever be installed in such areas.'lthough they are not inaccessible during power operation, it is proposed that hydraulic snubbers located inside containment be inspected independently from those outside containment in order to prevent unnecessary radiation exposure to those per-sonnel who perform snubber inspections.

Historically, most inoperable snubbers have been found outside containment, there-fore, flexibilityin this Technical Specification is considered advisable to preclude unnecessary containment entry during power operation.

Pa es 4.14-1 and 4.14-2 A new specification 4.14 is added to designate the surveillance requirements applicable to safety-related hydraulic snubbers.

Pages B3.12-1 and B3.12-2 A new section B3.12 is added to provided bases for new specification 3.12.

Page B4.14-1 A new section B4.14 is added to provide bases for new specifica-tion 4.14.

The proposed amendment has been reviewed and the conclusion reached that it does not involve a significant hazards considera-tion, therefore, prenoticing pursuant to 10 CFR 2.105 should not be required.

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Director of Nuclear Reactor Regulation P~ae Three March 22, 1976'e request that, upon approval of this proposed amendment, the snubber inspection reporting requirements of the Directorate of Licensing letter of November 8,

1973 from R.

C.

DeYoung to Robert E. Uhrig be eliminated.

Very truly yours, Robert E. Uhrig Vice President REU/MAS/cpc Attachment cc:

Mr. Norman C. Moseley Jack R.

Newman, Esquire

TABLE OF CONTENTS (Continued)

Section 3.7 3.8 3.9 3.10 3.11 3.12 4

4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12 4.13 4.14 5

5.1 5.'2 5.3 5.4 Pa e

,,P.-XQ 3.8-1 3.9-1 3.9-1 3.9-2 3.9-3 3.10-1 s Sources

3. 11-1 3%12 1

4. 1-1

'4. 1-1 Inspection

'4.2-1 4.3-1 4.4-1 ost Operational 4.4-1 4.4-1 4.4-2 4.4-3 4.4-3 4.4-4 nce 4.4-6 4.4-7 4.5-1 4.6-1 Title 4.7-1 4.8-1 4.9-1 4.10-1 4.11-1 4.12-1 4.13-1 4.14-1 5.1-1 5.1-1 5.2-1 5.3-1 5.4-1 Electrical Systems Steam and Power Conversion Systems Radioactive Materials Release Liquid Wastes

.Gaseous Wastes Containerized Wastes Refueling Miscellaneous Radioactive Material Hydraulic Snubbers SURVEILLANCE REQUIREMENTS Operational Safety Review Reactor Coolant System In Service Reactor Coolant System Integrity Containment Tests Integrated Leakage Rate Test P

Local Penetration Tests Report of Test Results Isolation Valves Residual Heat Removal System Tendon Surveillance End Anchorage Concrete Surveilla Liner Surveillance Safety Injection Emergency Containment Cooling Systems Emergency Containment Filtering and Post Accident Containment Vent Systems Emergency Power System Periodic Tests Main Steam Isolation Valves Auxiliary Feedwater System Reactivity Anomalies Environmental Radiation Survey Radioactive Materials Sources Surveillance Hydraulic Snubbers DESIGN FEATURES Site Reactor Containment

-Fuel Storage 6

6.1 6.2 6.3 6.4 6.5 6.6 6.7 6.8 6.9 ADMINISTRATIVE CONTROLS Responsibility Organization Facility Staff Qualifications Training Review and Audit Reportable Occurrence Action Safety Limit Violation Procedures Reporting Requirements 6.1-1 6-1 6-1 6-5 6-5 6-5 6-14 6-14 6-14 6-16 3/22/76

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LE OF CONTENTS (Continued) ~

Section Title

~Pa e

6-10 6-11 6-12 6-13 B2 1 B2.2 B2 3 Record Retention Radiation Protection Program Respiratory Protection Program High Radiation Area Bases for Safety Limit, Reactor Core Bases for Safety Limit, Reactor Coolant System Pressure Bases for Limiting Safety System Settings,'rotective Instrumentation 6-27 6-29 6'-29 6-33 B2.1-1 B2 2-1 B2.3-1 B3el B3.2 B3 3 B3;4 B3 5 B3.6 B3 7 B3.8 B3.9 B3.10 B3 11 B3.12 Bases for Limiting Conditions for Operation, Reactor Coolant System Bases for Limiting Conditions for Operation, trol Rod and Power Distribution Limits Bases for Limiting Conditions for Operation, Containment Bases for Limiting Conditions for Operation,

Engineered Safety Features Bases for Limiting Conditions for Operation, Instrumentation Bases for Limiting Conditions for Operation, Chemical and Volume Control System Bases for Limiting Condition for Operation, Electrical Systems Bases for Limiting Conditions for Operation,

.Steam and Power Conversion Systems Bases for Limiting Conditions for Operation,'adioactive Haterials

Release, Bases for Limiting Conditions for Operation, Refueling Bases. for Limiting Conditions for Operation, HisceU.aneous Radioactive Materials Sources Bases for Limiting Conditions for Operation, Hydraulic Snubbers Con-B3 1-1

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B3 2-1'3

~3-1 B3.4-1 B3.5-1 B3.6-1 B3.7-1 B3.8-1 B3.9-1 B3.10-1

.:. B3.11-1

$3-12-1 B4.1 B4.2 B4.3 B4.4 B4.5 B4.6

'4.7

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B4.8 B4.9 B4.10 B4.11 B4.12 N4.14 Bases for Operational Safety Review Bases for Reactor Coolant System In Service Inspection Bases for Reactor Coolant System Integtity Bases for Containment Tests Bases for Safety Injection Tests Bases for Emergency Containment Cooling System Tests Bases for Emergency Containment Filtering and Post Accident Containment Venting System Tests Bases for Emergency Power System Periodic Tests Bases for Hain Steam Isolation Valve Tests Bases for Auxiliary Feedwater System Tests Bases for Reacrtivity Anomalies Bases for Environmental Radiation Survey Bases for Hydraulic Snubbers e

B4.1-1 B4 2>>1 B4.3-1 B4.4-1 B4.5-1

'4.6-1 B4.7-1 B4.8-1 B4.9-1 B4 ~ 10-1 B4.11-1 B4.12-1 B4 14-1 3/22/76

eLIST OF TABLES Table Title 3.5-1 3.5-2 3 ~ 5 3 TECHNICAL SPECIFICATIONS Instrument Operating Conditions for Reactor Trip Engineered Safety Feactures Actuation Instrument Operating Conditions for Isolation Functions 3.5-4 Engineered-Safety Feature Set Points 3.12-1 Safety Related Hydraulic Snubbers 4; 1-1

4. 1-2

4. 2-.1 4.12-1 4.12-2

6. 2-1

6. 12-1 Minimum Frequencies for Checks, Calibrations and Test of Instrument Channels e

Minimum Frequencies for Equipment and Sampling Tests Reactor Coolant System In Service Inspection Schedule Operational Environmental Radiological Surveillance Program Oper'ational Environmental Radiological Surveillance Program Types of Analysis Operating Personnel Protection Factors for Respirators 3/22/76

3.12 HYDRAULIC SNUBBERS.

hydraulic pipe restraints (snubbers).

~Ob ective:

To define the limiting conditions for operation applied to the operability of safety-related hydraulic snubbers.

and Refueling Shutdown, all hydraulic snubbers listed in Tabl'e 3.12-1 shall be operable except as.

noted in 3.12.2 through 3.12.4 below.

2.

Prom the time that a hydraulic snubber is determined to be inoperable, continued reactor operation is permissible only during the succeeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

If the snubber is made operable within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time frame, reactor shutdown is not required.

3. If the requirements of 3.12.1 and 3.12.2 cannot be

met, an orderly shutdown shall be initiated and the reactor shall be in a" cold shutdown condition within 36'ours.

4. If a hydraulic snubber is determined to be inoperable while the reactor is in the cold shutdown mode or the refueling mode, the snubber shall be made operable prior to'eactor startup.

5.

Changes to Table 3..12-1 may be made without prior License Amendment provided that safety evaluations, documentation, and reporting are provided in accordance with 10 CFR 50.59 and that a revision to Table 3.12-1 is included with a subsequent License Amendment request.

3.12-1 3/22/76

1 TABLE 3.12-1 SHEET.1 SAFETY RELATED HYDRAULIC SNUBBERS - UNIT 3'PL Tag No.

o on Approximate Elevation et Snubbers in High Radiation Areas Durin Shu down

Snubbers

-Especially Difficult,to Remove

'nubbers Inaccessible During Normal 0 er tion Snubbers Accessible During Normal 0 eration 32 33 34 35 36 38 39 40 41 42 45 46 47 48 49 50 51 60 61 Pressurizer Relief Pressurizer Relief Pressurizer Relief Pressurizer Relief Pressurizer Relief RHR Containment Spray Containment Spray Containment Spray Steam to Aux. Feed Steam to Aux. Feed Steam to Aux. Feed Steam-to Aux. Feed Main Steam Main Steam Main Steam

'Main Steam 30 30 30

, 30

- 30 0

0 0

0, 12

12 22 22.

22

. 30 26 26 26'6

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X

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X

'TABLE 3.12-1 SHEET 2 SAFETY RELATED HYDRAULIC SNUBBERS - UNIT 3

PPL Tag No.

75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90-91 Main Steam Main Steam Main Steam Main Steam Feedwater Peedwater Peedwater Feedwater Peedwater Feedwater Peedwater Feedwater Peedwater Peedwater Peedwater Peedwater Feedwater

.Approximate.

Elevation feet

'26 26

- 26

-26 58

~ 58 56

'2'2

'58 55

. 55 56

.56 58 55 Snubbers in High

~ Radiation Areas Durin Shu down Snubbers-Especially Difficult to Remove Snubbers Inaccessible During Normal 0 eration Snubbers Accessible During Normal 0 eration

'X X

X X

TABLE 3.12-1 SHEET 3

'APETY RELATED HYDRAULIC SNUBBERS - UNIT 4

'PL Tag No.

7 18 19 20 21 22 23 49 50 51 52 53 54 55 57 58 59 60 Feedwater Peedwater Feedwater Peedwater Peedwater Peedwater Feedwater Feedwater RHR RHR Containment Spray Containment Spray Main Steam Main Steam Main Steam Main Steam Approximate Elevation et 30 30 58 58

.58 58 58 58 0

0 s

0 0

10

-'2 12 26 26 26 26 Snubbers in High Radiation Areas Durin Shu down.

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Especially Difficult to Remove Snubbers Inaccessible During Normal 0 er tion Snubbers Accessible During Normal 0 eration 0

X X ~

X X

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TABLE 3.12-.1 SHEET 4 SAPETY RELATED HYDRAULIC SNUBBERS - UNIT 4'PL Tag No.

80 81 82 83 85 86 0

Feedwater Peedwater Feedwater.

Main Steam Main Steam Main Steam Main Steam Approximate Elevation

'eet 56 56

'26 26 26 26 Snubbers in High Radiation Areas Durin Shu down Snubber's Especially Diffic'ult,to Remove Snubbers Inaccessible During Normal 0 eration Snubbers Accessible During Normal 0 eration X

X ~

X X

X

4. 14, HYDRAULIC SNUBBERS hydraulic pipe restraints (snubbers).

~Ob ective:

yo verify operability of safety-.related hydraulic saubbers listed in Table 3.12-1.

All safety-related hydraulic snubbers whose seal

~ material has been.tdemonst:.rated'y'perating experience, laboratory testing, or laboratory analysis to be compatible with the operating environment shall be visually inspected to verify snubber operability.

This inspection shall include, but not necessarily be limited to, inspection of the hydraulic fluid reservoir, fluid connections,

and, linkage connections to the piping and anchor.

The inspections shall be conducted in accordance with the schedule described below.

Early inspections as h

defined in the bases are permitted but may not be used to extend the required interval set by the previous regularly scheduled inspection.

Number of Snubbers Found Inoperable During Inspection or During 'Inspection Interval 3,4 5,6p7

>8 Next Required Inspection Interval 18 months + 25%

12 months + 25%

6 months + 25%

124 days + 25%

62 days + 25%

31 days + 25%

The required inspection interval shall not be lengthened more than one step at a time.

4.14-1 3/22/76

Snubbers may be categorized in two groups, "accessible" oz "inaccessible" based on their accessibility for inspection during reactor operation.

These two groups may be inspected independently according to the above schedule.

In addition, snubbers inside con-tainment may be inspected independently from those outside containment in order to prevent unnecessary containment entries caused by inoperable snubbers found outside containment during power operation.

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2.

A3.1 hydraulic snubbers whose s'eal materials are other than ethylene propylene or other material that has been demonstrated to be compatible with the operating environment shall be visually inspected for operability every 31 days.

3.

The initial inspection shall be performed within 6 months from the date of issuance of these specifications.

For the purpose of entering the schedule in Specification, 4.14.1, it shall be assumed that the facility had been on a 6 month inspection interval.

4.

Once each refueling cycle, a representative sample of 10 snubbers or approximately 10% of the snubbers, whichever is less, shall be functionally tested for operability including verification of proper piston movement, lock up, and bleed.

For each unit and subsequent unit found inoperable, an additional 10%

or ten snubbers shall be so tested until no more failures are found or all units have been tested.

To provide sufficient lead time for the purchase of test equipment, this functional test requirement becomes applicable during the second refueling cycle following the effective date of Specification 4.14.

4.14-2 9/22/76

B3.12 BASES FOR LIMITING CONDITIONS FOR OPERATION HYDRAULIC SNUBBERS Snubbers axe designed to prevent unrestrained pipe motion under dynamic loads which might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown.

The conse-quence of an inoperable snubber is an increase in the probability of structural damage to piping as a result of dynamic loads initiated.by seismic or other events.

Therefore, all 'hydraulic snubbers required to protect the primary coolant system or any other safety system'r component are required to be operable during reactor operation.

Because snubber protecti'on is'equiied only 'during relatively low probability

events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for repairs or replacements.

In case a shutdown is required, the allowance of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to reach a cold shutdown condition will permit an orderly shutdown consistent with standard operating procedures.

Since plant startup should not commence with known defective safety related equipment, Specification 3.12.4 prohibits startup with inoperable snubbers.

All safety related hydraulic snubbers are visually inspected for overall integrity and operability.

The inspection will include verification of proper orientation, adequate hydraulic fluid level, and proper attachment of snubber to piping and structures.

The inspection frequency is based upon maintaining a constant level of snubber protection.

Thus the required inspection interval vaxies inversely with the observed snubber failures.

The number of inoperable snubbers found during a required inspection determines the time interval before the next inspection is required.

Inspections performed before the minimum interval (nominal time less 2$%) has elapsed may be used as a new reference point to determine when the next inspection is required.

However, the results of early inspections performed before the original required time interval has elapsed may not be used to lengthen the required inspection interval.

Any inspection whose results require a shorter inspection interval will override the previous schedule.

B3.12-1 3/22/76

Experience at operating facilities has shown'that the required surveillance program should assure an acceptable level of snubber performance provided that the seal materials are compatible with the operating environment.

Snubbers containing seal material which has not been demonstrated by operating experience, lab tests, or lab analysis to be compatible with

~ the operating environment should be inspected more frequently (every month) until material compatibility is confirmed or an appropriate changeout is completed.

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Examin'ation of defective snubbers at reactor facilities and material testa performed at several laboratories (Reference

1) has shown that millable gum polyurethane deteriorates rapidly under the temperature and moisture conditions present in many snubber locations.

Although molded polyurethane exhibits greater resistance to these conditions, it also may be unsuitable for application in the higher temperature environments.

Data are not currently available to pre'cisely define an upper temperature limit for the molded polyurethane.

Lab tests and in-plant experience indicate that seal materials are available, primarily ethylene propylene compounds, which should give satisfactory performance under the most severe conditions expected in reactor installations.

To further increase the assurance of snubber reliability, functional tests should be performed once each refueling cycle.

These tests will include stroking of the snubbers to verify proper piston movement, lock-up, and bleed.

Ten percent or ten snubbers, whichever is less, represents an adequate sample for such tests.

'bserved failures on these samples should require testing of additional units.

Those snubbers designated in Table 3.12-1 as being in high radiation areas or especially difficult to remove need not be selected for functional tests provided operability was previously verified.

Reference 1

Report H. R. Erickson, Bergen Paterson to K; R. Goller, NRC, October 7, 1974

Subject:

Hydraulic Shock Sway Arrestors B3.12-2 3/22/76

B4.14 BASES FOR HYDRAULIC SNUBBERS The bases for specification 4.14 are the same as for specification 3.12.

B4.14-1 3/22/76

0 SAFETY EVALUATION The proposed amendment is basically administrative and will not result in any physical change to plant equipment or systems.

Although the inspection frequency is expected to be lower than the current inspection frequency, the hydraulic snubber failure rate at Turkey Point has been low enough to reasonably justify a reduced inspection frequency.

Also, the functional test requirement is new and will provide increased confidence in snubber integrity and will act to reduce the probability of snubber failure.

Based on these considerations, (1) the change does not increase the probability or consequences of accidents or malfunctions of equipment important to safety and does not reduce the margin of safety as defined in the basis for any technical specification, therefore, the change does not involve a significant hazards consideration,

( 2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (3) such activities will be conducted in compliance with the Commission"s regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

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