ML20004E230

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Proposed Tech Specs 3.7.10.1,4.7.10.1 & Corresponding App a Tech Spec Bases Re Snubber Surveillance Requirements
ML20004E230
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 06/08/1981
From:
PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20004E227 List:
References
TAC-11298, NUDOCS 8106110377
Download: ML20004E230 (11)


Text

l PLANT SYSTEMS O

3/4.7.10 SNuaBERS LIMITING CONDITION FOR OPERATION 3.7.10.1 All snubbers listed in Tables 3.7-Sa and 3.7-5b shall be OPERAB'.E.

APPLICABILITY:

MODES 1, 2, 3 anj 4.

(MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

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 snubber (s) to OPERABLE status, or perform an evaluation to verify system operability without the inoperable snubber, or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7.10.1 Each snubber shall be demonstrated OPERABLE by performance of the following augmented In-service Inspection Program and the requirements of Specification 4.0.5.

a.

Visual Inspections The first inservice visual incpection of snubbers shall begin during the first re'ueling ' utage commencing after the issuance o

of the Amendment incorporating this program and shall include all snubbers listed in Tables 3.7-Sa and 3.7-5b.

The snubbers may be categorized into groups and subgroups based on physical character-istics, environmental conditions, accessibility, and combinations of these characteristics.

Each group or subgroup may be inspected independently in accordance with the schedule given below.

If less l

i than two (2) snubbers are found inoperable during the first in-service visual inspection, the second inservice visual inspection shall be performed 12 months + 25 percent from the date of the first inspection.

Otherwise, subsequent visual inspections shall be performed in accordance with the following schedule:

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

No. Inoperable Snubbers Subsequent Visual [a, b, c) per Inspection Period Inspection Period 0

18 months + 25%

1 12 months T 25%

2 6 months T 25%

3,4 124 days + 25%

5,6,7 62 days T 25%

8 or more 31 days [25%

If no snubbers are found unacceptable within a group or subgroup dur-ing two successive inspection intervals, the next sample size may be limited to E0 percent of the snubbers within the eligible group or subgroup.

For subsequent inspections following inspections in which all snubbers inspected are acceptable, the sample size may be further reduced in steps to 25,15, and 10 percent of each eligible group or subgroup, provided that the total of all snubbers subject to inspec-tion at all times is at least 10 percent of the total numbers of snubbers listed in Tables 3.7-Sa and 3.7-5b.

When an unacceptable snubber is revealed during a group or subgroup inspection, the sample size for that inspection shall be increased to 100 percent for the next required inspection, unless the failure was either application induced or an isolated failure.

b.

Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that there are nn visible indications of damage or impaired OPERABILITY, and (2) attachments to the foundation or supporting structure are secure.

Snubbers whicn appear inoperable as a result of visual inspections may be deter-mined OPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible; and/or (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.10.1d or t

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

[b] The provisions of Specification 4.0.2 are not applicable.

[c] Inaccessible snubber inspection may be deferred to the next shutdown greater than 5 days in length.

Inaccessible snubbers are definea as those located (1) inside Containment, (2) in High Radiation Exposure Zones, and (3) in areas where accessibility is limited by physical constraints such as the need for scaffolding.

3/4 7-33

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.7.10.le, as applicable. However, 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 func-tional testing for the purpose of establishing the next visual inspection interval. All snubbers connected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.

c.

Functional Tests At least once per 18 months, a representative sample of 10 percent of the total of each type of snubber in use in the Plant shall be functionally tested either in place manually or in a bench test. For each snubber that does not meet the functional test acceptance cri-teria of Specification 4.7.10.1d or 4.7.10.le, an additional sample of at least 1/2 the size of the initial sample of the type of snubber shall be functionally tested. The functional testing of additional samples of at least 1/2 the size of the initial sample is required for snubbers determined to be unacceptable in subsequent functional tests.

Snubbers located in lower radiation areas may be chosen pre-ferentially over those in higher radiation areas in order to meet additional sampling requirements.

Hydraulic snubbers greater than 50,000 lb capacity are exempted from functional testing.

The representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capacity of snubbers.

At least 25 percent of the snubbers in the initial representative sample shall include snubbers from the following categories:

1.

Snubbers within 5 feet of heavy equipment (valve, pump, turbine, motor, etc.)

2.

Snubbers within 10 feet of the discharge from a safety relief valve Snubbers identified in Tables 3.7-Sa and 3.7-5b as "Especially Difficult to Remove" or in "High Radiation Exp re Zones" shall also be included in the representative sample.

Tables 3.7-Sa

[a] Permanent or other exemptions from functional testing for indivioual snubbers in these cat:' ries 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 a subsequent date.

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3/4 7-33a l

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1 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) and 3.7-5b may be used jointly or separately as the basis for the sampling plan.

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 during the next test period. Test results of these snubbers snall not result in additional functional testing due to failure.

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 for further action or testing.

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 anc compression.

2.

Snubber bleed, or release rate, where required, is within the specified range in compression or tension.

For snubbers specifically required to not displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

e.

Mechanical Snubbers Functional Test Acceptance Criteria l

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.

2.

Activation (restraining action) is achieved in both tension and compression.

3.

Snubber release, where required, occurs in compression and tension.

For snubbers specifica1', required not to displace j

under continuous load, the ability of the snuober to withstand l

load without displacement shall te verified.

3/4 7-33b

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 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 mainte-nance records on which the designated service life is based shall be maintained as required by Specification 6.10.2.m.

Concurrent with the first inservice visual inspection and at least once per 18 months thereafter, the installation ana maintenance records for each snubber listed in Tables 3.7-5a and 3.7-5b 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 service life review.

If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubbcr 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 reevaluation, replacement or reconditioning shall be indicated in the records.

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3/4 7-33c l

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TABLE 3.7-Sa SAFETY-RELATED HYDRAULIC SNUBBERS

  • SNUBBER SYSTEM SNUBBER INSTALLE0 ACCESSIBl.E OR HIGH RADIATIOh ESPECIALLY DIFFICULT NO.

ON, LOCATION AND ELEVATION INACCESSIBLE EXPOSURE ZOWE**

TO REMOVE

~

( A or I f-~

(Yes or No)

(Yes or No)

(To be-provided at a later date) u, 1

7

  • Snubbers may be added to or removed from safety-related systems without prior License Amensnent to Table 3.7-Sa provided that a revision to Table 3.7-5 is included with the next License Amendment request.
    • Modifications to this column due to changes in high radiation exposure areas may be made without prior License Amendment provided that a revision to Table 3.7-Sa is includeo with the next License Amendment request.

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TABLE 3.7-Sb SAFETY-RELATED MECHANICAL SNUBBERS

  • i SNunBER SYSTEM SNUBBER INSTALLED ACCESSIBLE OR HIGil RADIATION ESPECIALLY DIFFICULT NO.

ON, LOCATION AND ELEVATION INACCESSir F EXPOSURE ZONE **

TO REMOVE j

(A oi.;

(Yes or No)

(Yes or No) i (To be provided at a later date) w 3

%J b

1

  • Snubbers may be added to or removed from safety-related systems without prior License Amendment j.

to Table 3.7-Sb provided that a revision to Table 3.7-Sb is included with the next License Amendment request.

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    • Nodifications to this column due to changes in high radiation exposure areas may be made without prior License Amendment provided that a revision to Table 3.7-Sb is included with the next j

License Amendment request.

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3/4~7-36

_ PLANT SYSTEMS BASES In the event the fire suppression water system becomes inoperable, immediate corrective measures must be taken since this system provides the major fire suppression capability of the plant.

The requirement for a twenty-four hour report to the Commission provides for prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability for the continued protection of the nuclear plant.

3/4.7.9 PENETRATid FIRE BARRIERS The functional integrity of the penetration fire barriers ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility.

This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguishment. The penetration fire barriers (doors, walls, dampers, and seals) are a passive element in the facility fire protection program and are subject to periodic inspections.

During periods of time when the barriers are not functional, the combustible loading of the safety-related areas dictates the type of temporary protection to be provided. The combustible loadings for each room in the plant are listed in Table 3-1 of PGE-1012, Trojan Nuclear Plant Fire Protection Review. Where combustible Nadings are considered low (less than or equal to 1 lb/sq ft equivalent wood), credit is.

allowed for installed detection systems and installation of temporary fire barriers.

Either of these, in addition to an hourly fire patrol, give adequate assurance that a fire could not initiate and propacate through the nonfunctional penetration barrier. Where combustible loadings are somewhat greater (greater than 1 lb/sq ft equivalent wood) l either a tempurary tire carrier is installed, an installed detection system is provided, and an hourly fire patrol is established, or a continuous fire watch is required.

For either case, the continuous fire watch or the fire watch patrol is required to be maintained until the barrier is restored to funtional status.

l 3/4.7.10 SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the reactor coolant system and all other safety-related systems l

1s maintained during and following a seismic or otner event initiating dynamic l

loads.

Snubbers excluded from this inspection program are those installed on l

nonsafety-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-l related system.

l The visual inspection frequency is based upon maintaining a constant l

level of snubber protection to systems.

Therefore, the required inspection i

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i lPLANTSYSTEMS BASES 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.

When the cause of the rejection of a snubber is clearly established and remedied for that 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 ins' ection, or p

are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.

To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested at 18 month interval s.

Selection of a representative sample of 10% provides a confidence i

level of approximately 95% that 90% to 100% of the snubbers in the plant will be_0PERABLE within acceptance limits.

Observed failures of these sample snubbers shall require functional testing of additional units.

When a snubber is found to be inoperable due to failure to lock up or failure to move (i.e.,

frozen in place), the cause will be evaluated for further action or testing.

In cases where the cause of failure has been identified, additional snubbers that have a high probability for the same type of failure or are l

being used in the same application that caused the failure shall be tested. This requirement increases the probability of locating inoperable snubbers without testing 100% of the snubbers.

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

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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, i

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.

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0 ADMINISTRATIVE CONTROLS g.

Records of training and qualification for current members of the plant staff.

h.

Records of in-service inspections performed pursuant to these Technical Specifications.

f.

Records of Quality Assurance activities required by the QA Program for Operations.

j, Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k.

Records of meetings of the PRB and the NOB.

1.

Records of Environmental Qualification which are covered under the provisions of paragraph 6.13.

m.

Records of the service lives of all hydraulic and mechanical snubbers listed on Tables 3.7-Sa and 3.7-5b including the date at which the service life commences and associated installation and maintenance records.

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiatioc protection shall be prepared consisten+.

with the requirements of 10 CFR Part. 20 and shall be approved, maintained and adhered to for all operations in/olving personnel radiation exposure.

6.12 HIGH RADIATION AREA r

l 6.12.1 In lieu of the "contrcl device" or " alarm signal" required by l

paragraph 20.203(c)(2) of 10 CFR 20:

1.

Each High Radiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation l

monitoring device which continuously indicates the radiation dose rate in the area.

l' 2.

Each High Radiation Area in which the intensity of radiation is greater than 1000 mrem /hr shall be subject to the provisions of 6.12.1.a above, and in addition locked doors shall be pro-vided tc prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shift Supervisor on duty.

l TROJAN - UNIT 1 6-20 Order dated October 24, 1980

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