ML20041F642

Proposed Changes to Tech Specs Incorporating Addl Requirements for Insp of Snubbers

ML20041F642
Person / Time
Site:	Browns Ferry
Issue date:	03/09/1982
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20041F639	List: ML20041F638 ML20041F642
References
TVA-BFNP-TS-158, NUDOCS 8203170255
Download: ML20041F642 (46)

Text

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ENCLOSURE 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS BROWNS FERRY NUCLEAR PLANT I

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UNITS 1 AND 2 PROPOSED CHANGES l

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LIST OF TABLES (Cont'd) s Table Title Page No.

- 4.2.F Minimum Test and Calibration Frequency for Surveillance Instrumentation .......... 105 4.2.G ' Surveillance Requirements for Control Room Isolation Instrumentation ......... 106 4.2.H Minimum Test and Calibration Frequency .

for Flood Protection Instrumentation ...... 107 4.2.J. Seismic Monitorino Instrument Surveillance .... 108 3.5.1 MAPLHCR ' SUS AVERACE PLANAR EXPOSURE. ..... 171,172,172a 4.6.A Reactor Coolant System inservice Inspection Schedule . . . . ................ 209 3.7.A Primary Containment Isolation Valves ....... 250 3.7.B Testable Penetrations with Double 0-Ring Seals . . . . . . . . . . . . . . . . . . . . . . 256 3.7.C Testable Penetrations with Testable Bellows . . . . 257

"%g 3.7.0 Primary Containment Testabic Isolation Valves . . . 258 3.7.E Suppression Chamber influent Lines Stop-Check Globe Valve Leakage Rates . . . . . . . . . . . . 263 3.7.T Check Valves on Suppression Chamber Influent ...

Lines ..................... 263 3.7.H Testable Electrical Penetrations ......... 265 4.0.A Radioactive Liquid Waste Sampling and Analysis .. 287 4.8.B Radioactive Gascous Waste Sampling and Analysis . . 288 3.11.A Fire Protection System Hydraulic Requirements . . . 324 6.3.A Protection Factors for Respirators ........ 343 i

6.8 A Minimum Shift Crew Requirements . . . . . . . . . . 360

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• LIST OF ILtVSTRATIONS Flaure Ti t1,q Page No.

2.1.1 #PRM Flow Reference Scram and APRM Rod Block ,,,,

Settings .................... 13 2.1-2 APRM. Flow Bias Scram Vs. Reactor Core Flow .... 26 4.1-1 Graphic Aid in the Selection of an Adequate

• Interval Between Tests ............. 49 4.2-1 System Unavailability . . . . . . . . . . . . . . . 119 3.4-1 Sodium Pentaborate Solution Volume Contentration Requirements .................. 130 3.4-2 Sodium Pentaborate Solution Tenperature Requirements .................. 139 3.5.2 Kg Factor . . . . . . . . . . . . . . . . . . . . . 173 3.6-1 Minimum Temperature 'F Above Change in Transient

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Tempe ra tu re . . . . . . . . . . . . . . . . . . . 194 3.6-2 Change in Charpy V Transition Teinperature Vs.

Neutron Exposure . ............... 195

'6.1-1 TVA Office of Power Organization for Operation of Nuclear Power Plants . . . . . . . . . . . . . 361 6.1-2 Functional Organization . . . . . . . . . . . . . . 362 6.2-1 Review and Audit Function . . ........... 363 6.3-1 In-Plant Fire Program Organization ........ 364 I

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.6 PRIMARY SYSTEM BOUNDARY 4.6 PRIMARY SYSTEM BOUNDARY H. Seismic Restraints. Suoports, H. Seismic Restraints. Supports, and Snubbers and Snubbers

1. During all modes of operation The surveillance requirements except Cold Shutdown and Re- of paragraph 4.6.0 are the fuel, and seismic restraints, only requirements that apply supports, and snubbers shall to any seismic restraint or be operable except as noted support other than snubbers.

in 3.6.H.2 and 3.6.H.3 below.

All safety-related snubbers Each safety-related snubber shal:

are listed in Surveillance be demonstrated OPERABLE BY.

Instruction BF SI 4.6.H. performance of the following augumented inservice inspection

2. With one or more seismic program and the requirements of restraint , support, or snubber Specification 3.6.H/4.6.H.

inoperable; within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> These snubbers are listed in replace or restore the inoper- Surveillance Instruction able seismic restraint (s), BF SI 4.6.H.

support (s), or snubber (s), to OPERABLE status and perform 1. Inspection Groups an engineering evaluation on the attached component or The snubbera may he cate-declare the attached system gorized into two major inoperable and follow the groups based on whether the appropriate LIMITING CONDITION snubbers are accessible or statement for that system. inaccessible during reactor operation. These major

3. If a seismic restraint, support, groups may be further or snubber (SRSS) is determined subdivided into groups to be inoperable while the based on design, envir-reactor is in the shutdown or onment, or other features refuel mode, that SRSS shall be which may be expected to made operable or replaced affect the operability of prior to reactor startup. If the snubbers within the the inoperable SRSS is attached group. Each group may be to a system that is required inspected independently in OPERABLE during the shutdown accordance with 4.6.H.2 or refuel mode, the appropriate through 4.6.H.9.

LIMITING CONDITIONS statement for that system shall be 2. Visual Inspection, Schedule, followed. and Lot Size The first inservice visual inspection of snubbers not previously included in .these technical specifications and whose visual inspection has not been performed and

, documented previously, shall be performed within six months for accessible snub-bers and before resuming

power after the first refueling outage 185 k

, ,e LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports, H. SeismicReAtraints, Supports, and Snubbers (continued) and Snubbers (continued)

2. Visual Insnection, Schedule, and Lot Size (continued) for inaccessible snubbers subsaquent to being included in these specifications. The results of these inspections shall be used in the schedule table below to determine the subsequent visual inspection period. Snubbers previously included in these technical.

specifications shall continue on their previously earned inspection schedule without affect from adding snubbers not within their group.

No. Inoperable

• Subsequent Snubbers per Visual Inspec-Inspection tion Period Period 0 18 months + 25%

1 12 months + 25%

2 6 months + 25%

3,4 124 days + 25%

5,6,7 62 days + 25%

8 or more 31 days + 25%

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

3. Visual Insoection Performance and Evaluation Visual inspections shall verify (1) that there are no visible indications of damage or im-paired OPERABILITY, (2) bolts attaching the snubber to the foundation or supporting structure are secure, and (3) snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last inspection period 186 6  %

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LIMITING CONDITIONS FOR OPERATION SURVEILLA' ICE REQUIREMENTS H. Seismic Restraints, Supports, H. Seismic Restraints, Supports, and Snubbers (Continued) and Snubbers (continued)

3. Visual Inspection Perform-ance and Evaluation (cont'd) shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm operability.

Snubbers which appear in-operable as a result of visual inspections may be determined CPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) the cruse of the rejec-tion is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible; and (2) the affected snubber is functionally tested, if applicable, in the as-found condition and determined OPERABLE per Specification 4.6.H.5.

Also, snubbers which have been made inoperable as the result of unexpected transients, isolated damage, or other such random events, when the provisions of 4.6.H.7 and 4.6.H.8 have been met and any other appropriate corrective action implemented, shall not be counted in determining

. the next visual inspection interval.

4. Functional Test Schedule, Lot Size, and Composition During each refueling outage, a representative sample of 10% of the total of each 187

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• LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 1

H. Seismic Restraints, Supports, H. Seismic Restraints, Supeorts, and Snubbers (Continued) and Snubbers (continued)

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4. Functional Test Schedule.

Lot Size, and Comeosition (continued) group of safety-related snubbers in use in the plant shall be function-ally tested either in place or in a bench test.

The representative sample

selected for functional testing shall include the various configurations, operating environments, and the range of size and capacity of snubbers with-in the groups. The repre-sentative sample should be weighed to include more snubbers from severe service areas such as near heavy equipment.

The stroke setting and the security of fasteners for attachment of the snubbers to the component and to the snubber anchorage shall be verified on snubbers selected for functional tests.

5. Functional Test'Aaeepeance Criteria The snubber functional test shall verify that:

a. Activation (restrain-ing action) is achieved in both tension and compression within the specified range, except that inertia dependent, acceleration limiting mechanical snubbers may be tested to verify 188

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LIMITING CONPI1 TONS FOR OPERATION SlfRVEILLANCE REQUIRD:ENTS H. Seismic Restraints, Supports, H. Seismic Restraints, Suoports, and Snubbers (continued) and Snubbers (continued)

5. Function Test Acceptance Criteria (continued)

a. (continued) only that activation takes place in both directions of travel,

b. Snubber bleed, or release where required, is present in both 3

compression and tension within the specified range.

c. For mechanical snubbers, the force required to initiate or maintain motion of the snubber is not great enough to overstress the attached piping or component during thermal movement, or to indicate impending failure of the snubber,

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

e. Testing methods _ may be used to measure para-meters indirectly or parameters other .than those specified if those results can be correlated to the specified parameters through established methods.

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports, H. Seismic Restraints, Supports, and Snubbers (continued) and Snubbers (continued)

, , 6. Functional Test Failure Analysis and Additional Test Lots An engineering evaluation shall be made of each failure to meet the func-tional test acceptance criteria to determine the cause of the failure.

The result'of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determine 1 the operability of other snubbers which may be subject to the same failure mode.

Selection of snubbers for

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future testing may also be.

based on the failure analysis.

For each snubber that does not meet the functional test acceptance criteria, an additional lot equal to 10% of the remainder of that group of snubbers shall be functionally tested. Testing shall I

continue until no additien-al inoperable snubbers are ..

found within subsequent lets' or all snubbers of the original inspection. group have been tested or all suspect snubbers identi-fied by the failure analysis have been tested, as

! applicable.

If any snubber selected for functional testing either fails to lockup or fails to move, i.e.,

frozen in place, the cause vill be evaluated and if caused by manufacturer or i design deficiency, all snubbers of the same 190 i

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LIMITING CONDITIONS FOR OPERATIOJ SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports, H. Seismic Restraints, Supports, and Snubbers (continued) and Snubbers (continued)

6. Functional Test Failure Analysis and Additional Test Lots (continued) 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.

The discovery of loose or missing attachment fasteners will be evaluated to determine whether the cause may be localized or generic. The result of the evaluation will be used to select other suspect snubbers for verifying the attachment 1

fasteners, as applicable.

A v 7. Functional Test Failure -

Attached Component Ansivsis For the snubber (s) found inoperable,'an engineering evaluation'shall be performed on the componants which are restrained by the snubber (s).

1 The purpose of this engineer-

ing evaluation shall be to determine if the compo-

' nents restrained by the snubber (s) were adversely l affected by the inopera-bility of the snubber (s),

' ' and in order,to ensure that the restraindd component remains capable of meeting the designed service.

8. , Functional Testing Of Repaired and Spare Snubbers

Snubbers which fail the vis-ual inspection or the func-791 tional test acceptance

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports, H. Seismic Restraints Supnorts, and Snubbers (continued) and Snubbers (continued)

8. Functional Testing of Repaired and Soare Snubbers (continued) criteria shall be repaired or replaced. Repla' cement snubbers and snubbers which have repairs which might affect the functional test p, results shall meet the

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functional test criteria before installation in the unit. These snubbers shall have met the acceptance criteria subsequent to their

[ most recent service, and the functional test must have been performed within 12 months before being installed in the unit.

9. Exemption from Visual Inspection or Functiona.

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Permanent or other exemptions from visual inspections and/or functional testing for individual snuFbers may be granted by the Commis-sion if a justifiable basis for exemption is presented and if applicable snubber life destructive testing was performed to qualify snubber operability for the applicable design con-ditions at either the-completion of their fabri-cation or at a subsequent date. Snubbers so exempted shall continue to be listed in the plant instructions with footnotes indicating the extent of the exemptions.

i 10. Snuhber Service Life Program The service life of snubbers

.) may be extended based on an evaluation of the records of I

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIRDENTS H. Seismic Restraints, Supports, H. Seisu.ic Restraints, Supports, and Snubbers (continued) and Snubbers (continued)

10. Snubber Service Life Program (continued) functional tests, main-tenance history, and environmental conditions to which the snubbers have been exposed.

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. t 3.6.H/4.6.H Seismic Restraints Supports, and Snubbers Seismic restraints, supports, and snubbers (SRSS) are designed to prevent unrestrained pipe or ccmponent motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable SRSS is an increase in the probability of structural damage to piping or components as a result of a seismic or other event initiating dynamic Ic ads. It is therefore required that all SRSS required to protect the primary coolant system or any other safety system or component be operable during reactor operation.

Because the SRSS protection is required 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 to replace or restore the inoperable SRSS(s) to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the SRSS has adversely Effected any safety-related component or system.

3.6/4.6 BASES To verify snubber. operability functional tests shall be performed during the refueling outages, at approximately 18 months intervals.

These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples will require an engineering analysis and terting of additional units. If the engineering analysis results in the determination that the failure of a snubber to activate or to stroke (i.e. seized components) is the result of manufacture or design deficiency, all snubbers subject to the same defect shall be functionally tested. A thorough inspection of the ,

snubber threaded attachments to the pipe or components and the anchorage will is made in conjunction with all required functional tests. The stroke setting of the snubbers selected for functional testing also will be verified.

All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of proper orientation, adequate fluid level if applicable, and proper i attachment of the snubber to piping and structures. The removal of j insulation or the verification of torque values for threaded fasteners i

is not required for visual inspections. ,

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3.6/4.6 BASES (Continued)

The visual inspection frequency is based upon maintaining a constant level of snubber protection. Thus, the required inspection interval varies inversely with the observed snubber failures. The number of inoperable snubbers found during a required inspection determines the time interval for the next required inspection. Inspections performed before that interval has elapsed may be used as a new reference point to determine the next inspection, liowever, the results of such early-inspections performed before the original required time interval has elapsed (nominal time less 25 percent) may not be used to lengthen the required inspection interval. Any inpsection whose results reouire a j shorter inspection interval will override the previous schedule.

When the cause of the rejection of a snubber in a visual inspection is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicable, 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, or are similarly located or exposed to the same environmental conditions such as tempera-ture, radiation, and vibration. Inspection groups may be established based on design features, and installed conditions which may be expected to be generic. Each of these inspection groups is inspected and tested separately unless an engineering analysis indicates the inspection group is improperly constituted. All suspect snubbers are subject to inspection and testing regardless of inspection groupings.

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PROPOSED CHANGES f

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. .e 4.2.E Minimum Test and Calibraticri Trequency f or Drywell Leak Detection Instrumentation tot

4. 2. F Minimum Test and Calibration Frequency for Surveillance Instrumentation - '

10 2

4. 2. C Surveillance P) quire ents for Control Room Isolation Instrumentation 10J 4.2.H Minimum Test and Calibration Frequency f or Flood Protection Instrumentation 104 4.2.J Seismic Monitoring Instrument surveillance Requirements 105 4.6.A Reactor Coolant System Inservice Inspection 209 Senedule 3 5.I HAPLxca vs. Average Planar Fxposure liff,182 3.7.A Primary Containment Isolation Valves 262

3. 7. B Testable Penetrations with Double O-Ring Seals 268 3.7.C Testable Penetrations with Testable Bellows 269

3. 7. D Primary Containment Testable Isolation Valves 3.7.E Suppression Chamber Influent Lines Stop-Check Globe Valve Leakage Rates 279

3. 7 ; F Check Valves on suppression Chamber Influent Lines 280 3.7.G Check Valves on Drywell Influent Lines 281

3. 7. H Testable Electrical Penetrations 283 4.8.A Radioactive Liquid Waste Sarnpling and Analysis 310

4. 8. B Radioactive Gaseous Waste Sampling and Analysis 311 6.3.A Protection Factora for Respirators 37J Minimum Shift Crew Requirements 6.8.A 390 vii Anendment No.

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LIST OF ILLUSTRATIONS T_iguge g3,1f f.12.*

2.1- 1 APM Flow Ref erence Scram and APM Rod Block Settings 14 2.1-2 ' APRM Flow Bias scraa adelationship to Normal Operating Conditions 25 4.1-1 Graphic Aid in the Selection of an Adequate Interval Between Teste 48

e. 2- 1 System Unavailability 117 3.4-1 Sodium Pentaborate Solution Volume concentration Requirements 141

3. 4- 2 S odiu m Pentaborate Solution Temperature R eq ui r ement s 142 l

3. 5. 2 Kp Factor vs. Percent Core Flow 183

3. 6- 1 Temperature-Pressure Limitations 207 3,6-2 Change in Charpy V Temperature vs.

Neutron Exposure 208 6.1- 1 TVA Of fice of Power Organizaticn for Operation of Nuclear Power Plants 391 6.1- 2 Functional Organization 392 6.2-1 Review and Audit Function 393 6.3-1 In-Plant Fire Program Organization 394 l

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Amendment No.

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• i LIh1 TING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.6 PRIMARY SYSTEM BOUNDARY 4.6 PRIMARY SYSTEM BOUNDARY H. Seismic Restraints, Supports, H. Seismic Restraints, Supoorts, and Snubbers and Snubbers

1. During-all modes of operation The surveillance requirements except Cold Shutdown and Re- of paragraph 4.6.G are the fuel, and seismic restraints, only requirements that apply supports, and snubbers shall to any seismic restraint or be operable except as noted support other than snubbers.

in 3.6.H.2 and 3.6.H.3 below.

All safety-related snubbers Each safety-related snubber shal' are listed in Surveillance be demonstrated OPERABLE BY Instruction BF S1 4.6.H. perfctmance of the following augumented inservice inspection

2. With one or more seismic program and the requirements of restraint , support, or' snubber Specification 3.6.H/4.6.H.

inoperable; within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> These snubbers are listed in replace or restore the inoper- Surveillance Instruction able seismic restraint (s), BF SI 4.6.H.

support (s), or snubber (s), to.

OPERABLE status and perform 1. Insoection Groups an engineering evaluation on the attached component or The snubbers may be cate-declare the attached system gorized into two major inoperable and follow the groups based on whether the appropriate LIMITING CONDITION snubbers are accessible or statement for that system. inaccessible during reactor operation. These major

3. If a seismic restrainc, support, groups may be further or snubber (SRSS) is determined subdivided into groups to be inoperable while the based on design, envir-reactor is in the shutdown or onment, or other features refuel mode, that SRSS shall be which may be expected to made operable or replaced affect the operability of prior to reactor startup. If the snubbers within the the inoperable SRSS is attached group. Each group may be to a system that is required inspected independent 1v in OPERABLE during the shutdrwn accordance with 4.6.H.2 or refuel mode, thr appropriate through 4.6.H.9.

LIMITING CONDITIONS statement for that system shall be 2. Visual Inspection, Schedule, followed. and Lot Size The first inservice visual inspection of snubbers not previously included in these technical specifications and whose visual inspection has not been performed and documented previously, shall be performed within six months for accessible snub-bers and before resuming power after the first refueling outage 198

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. LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREw.ENTS H. Seismic Restraints, Supports, H. Seismic Restraints, Supoorts, and Snubbers (continued) and Snubbers (continued)

2. Visual Insoection, Schedule,

[

and Lot Size-(continued) 9 L for inaccessible snubbers subsequent to being included in these specifications. The results of these inspections shall be used in the schedule table below to determine the subsequent visual inspection period. Snubbers previously included in these. technical.

specifications shall continue on their previously earned inspection schedule without affect from adding snubbers not within their group.

No. Inoperable

• Subsequent Snubbers per Visual Inspec-Inspection tion Period Ieriod 0 18 months + 25%

1 12 months _+ 25:

2 6 months + 25%

3,4 124 days + 25%

5,6,7 62 days + 25%

8 or more 31 days + 25%

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

3. Visuni Innnection Performance and Evaluation Visual inspections shall verify (1) that there are no visible indications of damage or im-paired OPERABILITY, (2) bolts i

attaching the snubber to the i

foundation or supporting structure are secure, and (3) snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since che last inspection period 199 l

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• LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 11 . ,Seipmic Restrainen d upports, 11 . Seinmic Rentraints. Supyorts, and Snubbers (Continued) and Snubbern (continued)

3. Visual Insoection Perform-

, ance and Evaluation (cont'd) shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm operability.

Snubbers which appear in-operable as a result of visual inspecticns may be determined OPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) thr cause of the rejec-tion is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible; and (2) the affected snubber is functionally

, tested, if applicable, in the as-found condition and determined OPERABLE per Specification 4.6.H.S.

Also, snubbers which have been made inopccable as the result of u> expected transients, isolated. damage, or other such random events, when the provisions of 4.6.H.7 and 4.6.H.8 have been. net and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection

. interval.

4. Functional Test Schedule, Lot Size, and Composition During each refueling outage, a representative sample of 10% of the total of each 200

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREME:ITS H. Seismic Restraints, Supports, H. Seismic Restraints. Supnerts, and Snubbers (Continued) and Snubbers (continued)

4. Functional Test Schedule, Lot Size, and Comoosition (continued) group of safety-related snubbers in use in'the plant shall be function-ally tested either in place or in a bench test.

The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of sir.e and capacity of snubbers with-in the groups. The repre-sentative sample should he weighed to include more snubbers from severe service areas such as near heavy equipment.

The stroke setting and the securfty of fasteners for attachment of the snubbers to the component and to the snubber anchorage shall be verified on snubbers selected for functional '

tests.

5. Functional ~ Test Acceptance criteria The snubber functional test shall verify that:

i i

a. Activation (restrain--

ing action)'is achieved  ;

in both tension and I

compression within the specified range, except I that inertia dependent, acceleration limiting mechanical snubbers may be tested to verify 201

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. LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports, H. Seismic Restraints. Supports, and Snubbers (continued) and Snubbers (continued)

5. Function Test Acceptance Criteria (continued)

a. (continued) only that activation takes place in both directions of travel.

b. Snubber bleed, or release where required, is present in both I

compression and tension within the specified range.

c. For mechanical snubbers, the force required to initiate or maintain motion of the snubber is not great enough to overstress the attached piping or component during thermal movement, or to indicate impending failure of the snubber.

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

e. Testing methods may be used to measure para-meters indirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods.

202

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. e LIMITING CONDITIONS FOR OPERATION SURVEILLASCE REQUIREMESTS.

H. Seismic Restraints, Supports, H. Seismic Restraints, Suonorts, and Snubbers (continued) and Snubbers (continued)

6. _ Functional Test Failure Analysis and Additional Test Lots An engineering evaluation shall be made of each failure to meet the func-tional test acceptance criteria to determine the cause of the failure.

The result of this analysis shall be used, if applicable, in selecting snubbers to be tested in the subsequent lot in an effort to determine the operability of other m 2bbers which may be subject

.he same failure mode.

S. etion of snubbers for

' .o te testing may also be base on the failure analysis.

For each snubber that does not meet the functional test acceptance criteria, an additional lot equal to 10% of the remainder of that group of snubbers shall be functionally tested. Testing shall continue until no addition-al inoperable snubbers are found within subsequent lots or all snubbers of the original inspection group have been tested or all suspect snubbers identi-fied by the failure analysis have been tested, as applicable.

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 design deficiency, all snubbers of the same 203 4

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports', H. Seismic Restraints Supports, and Snubbers (continued) 4 and Snubbers (continued)

6. Functional Test Failure Analysis and Additional Test Lots (continued) 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.

The discovery of loose or missing attachment  :

fasteners will be evaluated '

to determine whether the cause may be localized or  ;

gene ic. The result of l the -valuation will be  ;

used to select other suspect snubbers for verifying the attachment -

fasteners, as applicable.

7. Functional Test Failure -

Attached Component Analysis For the snubber (s) found inoperable, an engineering [

evaluation shall be performed l on the components which are '!

restrained by the snubber (s). .

The purpose of this engineer- '

ing evaluation shall be to determine if the compo-4 nents restrained by the snubber (s) were adversely affected by the inopera-bility of the snubber (s),

i and in order to ensure that the restrained component remains capable'of meeting the designed service.

8. Functional Testing Of Repaired and Spare Snubbers i

Snubbers which fail the vis-ual inspection or the func-204 tional test acceptance

- - -, s - - - e g'- ---- r--- - - + - + + - > -

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Seismic Restraints, Supports, H. Seismic Restraints. Sunports, and Snubbers (continued) and Snubbers (continued)

8. Functional Testing of Repaired and Spare Snubbers (continued) criteria shall be repaired or replaced. Replacement snubbers and snubbers which have repairs which might affect the functional test results shall meet the functional test criteria before installation in the unit. These snubbers shall have met the acceptance criteria subsequent to their most recent service, and the functional test must have been performed within 12 months before being installed in the unit.

9. Exemption from visual Inspection or Functional Tests Permanent or other exemptions from visual inspections and/or functional testing for individual snubbers may be granted by the Commis-sion if a justifiable basis for exemption is presented and if applicable snubber life destructive testing was performed to qualify snubber operability for the applicable design con-ditions at either the completion of their fabri-cation or at a subsequent date. Snubbers so exempted shall continue to be listed in the plant instructions with footnotes indicating the extent of the exemptions.

10. Snubber Service Life Frogram The service life of snubbers may be extended based on an 5 v lu ti n f the records of

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS l H. Seismic Restraints, Supports, H. Seismic Restraints, Supports, and Snubbers (continued) and Snubbers (continued)

10. Snubber Service Life Program (continued) functional tests, main-tenance-history, and environmental conditions to which the snubbers have been exposed.

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Curve #"A Minimum temperature for core operation o (criticality)

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i METuco AAEAS or INTEPEST ACCESS 5 IMsP. IN INSP. flerERVAL FREDOINCY A. Seactor Vessel i

1. Longitudinal and Those welds above 101 of accessible longitudinal code (1) Volumet ri c j circumferential sacrificial shield and 5 welds outside core all in closure head SE of accessible circumferential region and in ves- are accessible from

set head vessel o.d.

I 2. Vessel-to-flange From flange surface 1001 code (2) Volumetric circumf erential weld l B ea d- to- fl an g e From o.d. of head 1001 code (2) Volumetric I circumferential weld

( code (2)

3. Primary nozzle-to- All nortles 4 inches 1001 welds l vessel welds and and greater will be

• i nozzle-to-vessel in- accessible f rom vessel

! ,, side radii o.d. Inside radii at the 6 and 12 code (2) volume tric c) o' clock positions e

Ja. CBD housing-to-stub During refueling from 1005 At time of Visual tube and etub tube- CPD area for signs of system hydro-to-vessel welds and leakage stat l

t incore penetration

4. Primary nostles to All nozzles 4 inches 1005 code (2) visual, s urf ace, saf e-end Dissimilar and larger will be and volueetric Metal welds accessible 1005 code (2) Visual, surf ace,

5. closure st'uds and studs in place, nute and volumetric nuts on removal

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Table s.6.A PE.ACTop COOTANT SYST134 INSF31VICE INSPECTION SCR EDULE 5 JNSP. IN INSP. INTEpvAL _FR D00 ENCY M ETHOD AptAS or INTEREST ACCESS on removat 1005 Code (2) visual

6. Closure washers, When made accessible Visual Bushi ng s In place, when stude are removed one foot minimum length Code (23 volunet ric

7. Integrally welded Two sections 2 f eet vessel supports long each, 188 arurt, 18 0* a pa r t - two spot s accessible in sugport skirt to vessel weld During refueling - 6 predetermined patches Code (2) Visual

8. Vessel clad 31ng vessel 1.d. (36 in.e eachl Accessible areas First refuela Visual

9. vessel internals Accessible areas ing and every and integrally during normal re- third refueling welded internal fueling thereafter support s M loos Code (2) Volumet ric

10. vessel flange- During refueling

[g ligaments between threaded stuS holes B. Elpine Pressure Boundary Code (2) visust and sar-Vessel, pump, an d From pipe o.d. 1005

1. face and valve safe ends-to- vol umet ric primary pipe dissimilar metal welds and saf e ends in branch piping welds e inches and larger 1

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2. circumferential and Removable insulation 255 of circusterential welds code (2) Visual and

' longitulinal pipe plus 1 f oot of adjacent volumetric welds 4 inches and longitudinal welds over Cir cu mf er ential- Removable Insulation All those listed in Section code (1) Visual an3 type welds 4.6.C.4 of Technical volumetric

- pipe whip Speci ficat ions prot e ction

3. Pres s ur e-reta ining 2 inches and larger 1001 code .(1) Visual and bolting volumetrie

' Bolting under 2 1005 Signs of inches on piping 4 leakage dur- Visual inches and over ing normal maintenance

[3 4. Piping eupports and

>. h angers

a. Int egrally Scaffolding - as 2005 visual, code (2) Visual and

. welded required 255 Vol. (if suitable geometry) volumetric

b. Monintegrally Scaf folding - as 1005 Code (2) visual welded supports required C. Puno Pressure Boundag.y I

i 1. Pump *cesing i -

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M EAS O F TNT EPIST ACC ES.S

f. Pump pressure boun- E. INSP. IN INSP. !!rTEJtVA1, EtOUDeCT NEYNOD dary interior Prom pump 1.d. only

{

when saintenance One pump with or without requires removat of welds it disassembled code (1) Visual internals if disassembled

.I 2.

] Pres s ure-retaining bolting 2 inches and larger 1001 I

code (1) visual and Bolting under 2 volumetric inches 1005 51;.s of Visual leakage dur-i ing corr.a1

! maintenance

3. suppo rt s outage

' a. Integrally

,, welded Scaffolding as 251 required I$ code (2) visual and

b. Monintegrally Scaf folding as volumetric a welded required 2005

4. code (2) visual Mor al e-to-sa fe end dissimilar metal welds memovable insulation 1001 .

D. code (2) Visual and Yalve Pressure Boundary volumetric

' 1. Valve body seam welds From valve o.d. 1005 code (1) visual and volumetrie i

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Table 4.6.A LEAc!Os CVOIMT SYSTDs Ipeitzrvict INSPECTION SCREDULE AREAS OP INTEPEST ACCTSS 5 INSP. IN INSP. INTF3tVAL UfOUETICY N!THOD valve pressure bouna Pros valve 1.d. only One valve with or without code (1) Visua l dary interior when aatotenance welds if disassembled if disassembled requires removal of internals

2. Valve-to-safe end Removal insulation 1005 code (2) Visual and dissiallar metal volumetric welds

3. Pre s s ure-ret aining 2 inches and larger 2005 code (1) visual and bolting volumetric Bolting under 2 inches 2005 Signs of Visual leakage 60 during nor-

[ mal maintenance outage 4 Supports and hangers -

a. Integrally Seaf folding - as 255 vol. (if suitable geometry) code (2) visual and welded required 1005 visual volumetric l*

b. Monintegrally Scaffolding - as 1005 code (2) visual welded required e

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. Enopection Frequency: .

code ~(1) - Program such that all areas of interest will be inspected durias L'a

• inspection interval.

Code (2) - Program each that at least 255 of the required examinations shall have been completed af ter one-third

" , of the inspection interval has expired (with credit for no mare than 33-1/35 if a$ditional examinations i

' are ccupleted) aM at least 505 af ter two-thirds of the inspection interval has espired (with credit f or no mor e than 66-2,*35) . The remainder shall be coarleted by the end of the inspection interval.

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7. 6/4.' 6 B,A_S ES It is intended that the required examinations and inspection be

• completed during each 10-year interval. The periodic examinations

are shutdown to be periods.

done during refueling outages or other extended plant Only proven nondestructive testing techniques will'be used.

More frequent inspections shall be performed on certain cirrumferential pipe welds against pipe wh!o. as listed in Section 4.6.C.4 to provide additional protection These welds were selected in respect tn their distance

. f rom hangers or supports wherein a f ailure of the weld would permit the unsupported segments of pipe to strike the drywell wall or nearby auxiliary systems or control systems. Selection was based on judgment from actual plantInspection drawings. observation ofofallhanger and support locations and review of these welds -during each 10-year inspection interval will result in three additional examinations above the requirements of Section XI uf ASHl: Code.

i REFERENCES 1.

Inservice Inspection and Testing (BrNP FSAR Subsection 4.12) +-

2.

Inservice Inspection of Nuclear Reactor Coolant Systems.

Section X1, ASME Boiler and Pressure Vessel Code 3.

ASPI Boiler and Pressure Vessel Code. Section 111 (1963 edition) 4 American Society for Nondestructive Testing No. SNT-TC-1A (1968 edition) 3 . 6 . 11 / 4 . 6 . 11 Seismic Restraints 1Supports and Snubbers Seismic restraints, supports and snubbers (SRSS) are designed to prevent unrestrained' pipe or component ention under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable SRSS is an increase in the probability of structural damage to piping or components as a result of a seismic or other event initiating dynamic loads.

It is therefore required that coolant all SRSS required to protect the primary reactor operation. system or any other safety system or component he operable durin,g Because the SRSS protection is required o'nly during relativciv 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 to replaec or restore the inoperable SRSS(s) to operable status and perform an engineering evaluation on the supported component or declare the supported system inoperable and follow the appropriate limiting condition for operation statement for that system. The engineering evaluation is performed to determine whether the mode of failure of the SRSS has adversely affected any safety-related component or system.

228

3.6/4.6 BASES (Continued) .

To verify snubber operability functional tests shall be performed during the refueling outages, at approximately 18 monthn intervals.

These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. Ten percent represents an adequate sample for such tests. Observed failures on these samples will require an engineerinC analysis and testing of additional units. If the engineering analysis-results in the determination that the failure of a snubber to activate or to stroke (i.e. seized components) is the result of manufacture or design deficiency, all snubbers subject to the same defect shall be functionally tested. A thorough inspection of the snubber threaded attachments to the pipe or components and the anchorage will be made in conjunction with all required functional tests. The stroke setting of the snubbers selected for functional testing also will be verified.

All safety-related snubbers are also visually inspected for overall integrity and operability. The inspection will include verification of .

proper orientation, adequate fluid level if applicabic, and proper attachment of the snubber to piping and structures. The removal of insulation or the verification of torque values for threaded fasteners is not required for visual inspections.

The visual inspection frequency is based upon maintaining a constant Icvel of snubber protection. Thus, the required inspection interval varies inversely with the observed snubber failurcs. The number of inoperable snubbers found during a required inspection determines the time interval for the next required inspection. Inspections performed before that interval has elapsed may be used as a new reference point to determine the next inspection, llowever,"the results of such catly' inspections performed before the original required time interval has elapsed (nominal time less 25 percent) may not be used to lengthen the required inspection interval. Any inpsection whose results require a shorter inspection interval will override the previous scheGule.

When the cause of the rejection of a snubber in a visual inspection is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible and operability verified by inservice functional testing, if applicabic, that snubber may be exempted from being counted as inoperable. Cencrically 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, or are similarly located or exposed to the same environmental conditions such as tempera-ture, radiation, and vibration.

Inspection groups may be established based on design features, and installed conditions which may be expected to be generic. Each of these inspection groupn is inspected and tested separately unless an engineering analysis indicates the inspection group is improperly constituted. All suspect snubbers are sub]cet to inspection and testing regardless of inspection groupings.

229

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Page 230 Deleted e

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ENCLOSURE 2 JUSTIFICATION AND DESCRIPTION OF CHANGES 4.6.H.2 The option for reduced visual inspection lot size based on successive no-failure inspections has been deleted even though we believe the proposal is justified. We understand the visual inspection program wan based on the March 1, 1975 note to Dennis L. Ziemann from Joseph Sapir of Operating Reactors Branch No. 2. The formula which was used and the assumptions which were made appear to be independent of the snubber population and to project an initiating event (earthquake or severe transient) every five years, and the best performance of all anubbers is to fail once per year. The functional testing program which was not mentioned in the March 1 note has grown from testing 10 snubbers each refueling to testing 10 percent with additional lots for every failed snubber; and to more sophisticated sampling plans for plants with large numbers of onubbers. We understand these plans are designed to provide a satisfactory degree of confidence as to the operability of the snubbers independent of the visual inspection program, but the original visual inspection program remains in full force. (We also understand the mathematical basis for the Sapir plan is being reviewed by NRC.)

Hydraulic anubbers (the only snubbers known when the technical specifications were initiated) now typically require seal replacement at five- to ten-year intervala and functional testing at the rate of at least 10 percent per refueling outage, or at a rate that will provide a specified confidence level of the anubber operability. This degree of attention coupled with inspections r equired for damage resulting from unexpected severe transients should at least permit reduced visual inspection lots for snubbers with no-failure histories.

Mechanical snubbers, not having the leakage problems which precipitated the visual inspection program, should be exempted from the visual inspection program except when activities have been conducted in the area which might result in damage to the anubbers. The functional test program provides the degree of confidence specified for the operability of the mechanical and hydraulic snubbers.

s 4.6.H.2 Minor editorial changes were made to the first paragraph of this section. These changes do not alter the meaning or intent of the paragraph and are consistent with the wording contained in the approved Sequoyah Nuclear Plant unit 2 technical specifications. A requirement was added to this section to verify stroke setting. The purpose of this addition is to integrate a requirement of Section XI, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, into the snubber technical specifications.

4.6.H.5a Changes were made to this section as suggested in your November 18, 1981 letter. In addition, a statement was inserted with detailed acceptance criteria to be utilized for testing of a specific design of mechanical snubbers. The addition is consistent with the wording contained in the approved Sequoyah Nuclear Plant unit 2 technical specification.

4.6.H.5b Changes were made to those paragraphs an suggested in your 4.6.H.5c November 18, 1981 letter.

4.6.H.5e This paragraph allows alternate testing methods to be used when the measured parameters can be correlated to the specified parameters by established methods. This added paragraph is consistent with the wording contained in the approved Sequoyah Nuclear Plant unit 2 technical specifications.

4.6.H.6 The paragraph containing the requirement for testing of additional snubber lots based on manufacture or design deficiency was added to this section, rather than 4.6.H.S.

This is an orgaizational improvement which does not alter the meaning or intent of the paragraph.

4.6.H.9 We believe there may possibly be circumstances which would justify a somewhat extended interval or abbreviated visual inspection for proven reliable snubbers in low traffic, high radiation areas. Comments regarding visual inspections were presented previously under section 4.6.H.2. The authority to grant exemptione to the visual inspection program remains with NRC. Therefore, provision for making exemptions to the functional testing and the visual inspection program after approval by NRC has been retained in this section. Inclusion of the exemption is consistent with the provisions of the approved Sequoyah Nuclear Plant unit 2 technical specifications.

4.6.H.10 This section was added in compliance with a recommendation contained in your November 18, 1981 letter.

I

l i

i I 4 j Several editorial and organizational changes were made to the bases of l the technical specifications. These changes are minor and are consistent i with the revised version of the technical specifications.

We believe these technical specifications provide a very comprehensive surveillance program for these normally passive components which have a i very low probability of being required to perform their primary design fuction during the life of the plant.

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