ML20077M458

Proposed Tech Spec 3/4.7.8 & Associated Bases,Requesting Rev to Snubber Visual Insp Intervals & Corrective Actions

ML20077M458
Person / Time
Site:	Callaway
Issue date:	08/01/1991
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20077M449	List: ML20077M447 ML20077M458
References
NUDOCS 9108130360
Download: ML20077M458 (16)

Text

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ULNRC-2452 ATTACIIMENT 1 TECilllICAL SPECI FICATION CllANGES 1

9108130360 910801 PDR ADOCK 05000483 P

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INDE X_

LIMITING _ CONDITIONS FOR OPERATION AND SURVEILLANCE RE l

PAGE SECTION PL ANT SYSTEMS. (Ccntinued)

STEAM LINE SAFETY VALVES PERL00P.....................

3/4 7-3 TABLE 3.7-2 3/4 7-4 Au x il i a ry F e edw a t e r S y s t em...................

3/4 7-5 Con d ens a :e 5: r t9 e T ank...............................

S p ec i f i c Ac ti v i ty........................................

3 / 4 7 - 7 SECONCARY CCCLANT SYSTEM FECIFIC ACTIVITY 3/4 7-8 T ABLE 4. 7-1 l

5 AMP L E AN D AN AL Y S I S P R0 G P.AM..........................

Main S team Line I sol ation Y a1ves.........................

3/ 4 7-9 Main reeewater 5ys:em....................................

3/4 7-9a l

I Steam Generator At.Tcsoneric S team Oump Valves............

3/4 7-9b i

I STE.'M GENERATOR PRE 55URE/ TEMPERATURE LIMITATION..........

3/4 7-10 3/4.7.1 CCMP ONENT C00L ' NG W AT E R SY 5T EM...........................

3 / 4 7 - 11 3/4.7.3 E5S ENTI AL SERV ICE W ATER 5YST EM...........................

3/ 4 7-12 3/4.7.4 3/4 7-13 3/4.7.5 ULT'. MATE MEAT SINK....

CONTROL ROOM EMERGENCY YENTILAT *0N 5Y STEM................

3/4 7-14 3/4.7.5 EME RG E NCY E XHAU ST S Y 5 T EM.................................

3 / 4 7 - 17 3/4.7.7 SNU55ERS.................................................

3/4 7-19 3/4.7.3 3/4 7-24 SAMPLING PLAN 2) FOR SHU53ER FUNCTIONAL TEST...

r-FIGURE 4.7-1 S EAL ED SOURC E CONT AMI NAT !0N.............................

3/ 4 7 - 2 5 3/4.7.9 3/4.7.10 Delet ed 3/'.7.11 Deleted AREA T EMPERATURE MONiiORING.............................

3/ 4 7-37 3/4.7.12 3/4 7-38 TABLE 3.7-4 AREA T EMP E RATURE MONITORI NG....................

4 T*ASLE 4.T-2.

stiUBBER VI.SUAL THsPECT)ON INTEMAL W

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y ptwT sysnys 3 /a.7. 8 SHbEBERS t!MIT1M CCHOITICH FOR OPERAT!OH 3.7.8 All snuctors shall te OPERASLE.

The only snutters excluded frca the require =ent are those installed on ncnsafety-related systems anti then only if their f ailure or f ailure ef the systes en which they are installed woulc nave no adverse effect en ar./ safety-related system.

APPLICABILITY: M DES 1, 2, 3, and 4'.

MCCES 5 and 'i for snutters located on systems required OPERASLE in these NOES.

ACTION:

Vith one or rore snutters inc;erable on any systaa, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace er restore the ineparabit snutter(s) to CPERABLE status and ;erf: m an engineering evaluation per Scecification 4.7.8g, on the attacned ccecenent or ceclare :ne for attacned system inceersole and foliw the acpropriate ACTICH statecen:

tnat system.

SURVEILLANCE REOUIRE.MENTS

4. 7. 5 Each snub:er sna11 te demonstrated OPERABLE by :erf ormance of the follcwing augmented inservice inspection pre; ram in lieu of the requirecents of Specification 4.0.5.

a.

Ins:ection Tv:es As usac in this s:ecificatien, :):e of snutter shali ean snt.:ters of tne same cesign and.anuf acturer, irrespec.ive of c e acity, b.

Visual inscections ers are c?.tegori:ed as inaccessitie er accessible during r "

,.c a..

Each of these groups (inaccessible 4no-access 4 s may ce ecerat..

inspected in,, -dently according to *.no schecile ta' The first inservice visual in

-*lon of each ty;e of s- _. rs shall te cerfor.ed after 4 montns but within. -antas of -

encing PCVER OPERATICN anc snal) inclece all hydraulic anc '

nical snutters.

If all snuccers o f eat.h type are f ot m CF

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during.

M rst inser* ice visual inspection, tne seg#Gservice visual inspe, *" of that type snali te cerformac

...e ( ' st refueli.g outag. Otne rn a

'uesacuent visual i c.icns of a given type shall to perfernec in ac..

ance

. ne folicwing scnedule:

REPL4CE WI(H INMRT' Y i

CAL.LAWAY - UNIT 1 3/4 7-13

INSERT "A" j

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b.

Visual-Inspections snubbers are categorized as inaccessible or accessible l

during reactor operation.

Each of these categories (inaccessible and accessible) may be inspected independently according to the schedulo determined by Table 4.7-2.

The visual inspection interval for each type of snubber shall be determined based upon the critoria provided in Table 4.7-2 and the first inspection interval determined using this l

criteria shall be based upon the previous inspection interval as established by the requirements in effect before amendment (*).

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• NRC will include the number of the license amendment that implements this change.

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PLANT. SYSTEM,5,

_ SURVEILLANCE REQUIREMENTS (Continued)

No. In,.

le Snubbers of Each Type Subseau **

sual tion Perioc"W a

• on Period 18 months : 25%

cer n.

0 12 months : 21%

1-6 months': 25%

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..' days e 25%

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- 25%.

5,6,7 31 days : e

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8 or more m

Visual Inscection Acceptance Criteria (1) that inere are no visib;e ine c..

isual inspections shall vetify:

the 4 of damage or impaired OPERASILITf, and (2) attachmen*

1

.asteners

or supporting structure are functional, and ca.

.ne snubber founda.

for attachme. the snu:ber to the compenent and *noperable as a anchorage are func.. -a1.

Snubbers which apcaed ces m ts for tne p;.,r-REPLACE resuit or visual inspec., may be det ;

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nspection interval, provicec

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u pose of establishing the nex s clearly established and (1) the cause of tha rr" other snuboers irrespec-

.w H!hvy that:

remedied for that partie snubber anse generically susceptu' or (2). the a ffected

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tive of type that a snubber is fu"..onally tested in the as-found cc d'4cn and deter '

ected to-

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All snubbers E per Specification 4.7.8f.

.g mined OPC' as e'racle common hydraulic fluid reservoir shall be coun.

N an r

.cperable snubbers.

Transient Event Insoection d.

An inspection shall be performed of all hydraulic and mechanical snubbers attached to sections of systems that have experienced unexpected, potentially camaging transients as deter-nined from.a review of operational cata and a visual inspection of the systems In aedition to satisfy-within 6 months following such an event.

ing the ylsual inspection acceptance criteria, freedom-of-c.otio mechanical snubbers-shall.be verified using at least one of the (1) manually incuced snuober movement; or (2) evaluation of in-place snumber piston settir.g; or-(3) stroking the mechanica fo11 ewing:

snubber through its full range of travel.'

a 1

interval for each type of-snubber shall not be len?blem 4scaction i

than on'.-gtime unless a gener c pro ce lengthened one step i.

in tna u s /--' the inspection interv. -o inoperabic sneboers of that corrected:

't the first time and two steps s..

type are found.

specification 4.0.2 are not applicable.

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y DELETE 3/4 7-23 CALLAWAY - UNIT 1 i

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INSERT "B"

c.

Visual Ingnection Acceptance Criteria Visual inspections shall verify that (1) there are no r

visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) fasteners for the attachment of the snubber to the component and to the snubber anchorage are functional.

Snubbers which appear inoperable as a result of

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visual inspections shall be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that: (1) the cause of the rejection is clearly established and remedicd for that particular snubber and for other snubbers irrespective of type that may be generically susceptibic; or (2) the affected snubber is functionally

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tested in the as-found condition and determined OPERABLE por Specification 4.7.8f.

All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted a

as unacceptable for determining the next inspection L

interval.

A review and evaluation shall be performed and documented to determine operability with an unacceptable snubber.

If operability cannot be justified, the system shall be declared inoperable and the ACTION requirements shall be met.

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-.wSERr C (App TABLE 4 7-2.B&ME F/GUAE 4*7-l)

TABLE 4.7-2 SHUBBER YlSUAL INSPECTION INTERVAL l

HUMBER OF UNACCEPTABLE SHUBBERS Ecpulation Column A Column B Column C or Ce.tegory Extend Interval Repeat interval Reduce Interval (Hotes 1 and 2)_

(Notes 3 and 6)

(Notes 4 and 6)

(Notes 5 and 6) 1 0

0 1

80 0

0 2

100 0

1 4

150 0

3 8

200 2

5 13

'5 2

300 5

12 400 8

18 36 500 12 24 48

~

750 20 40 78 E.

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1000 or greater 29 56 10$_

The next visual inspection interval for a snubber population or cate-Note 1:

gory size shall be determined based upon the previous inspection interval and the number of unacceptable snubbers found during that interval.

Snubbers may be categorized, based upon their accessibility during pcwer operation, as accessible or inaccessible.

These categor-ies may be examined separately or jointly.

However, the licensee must make and document that decision before any inspection and shall use that decision as the basis upon which to deterniine the next inspection interval for that category.

!nterpolaticn between population or category sizes and the number of Note 2:

Use next lower integer for the unacceptable snubbers is permissible.

value of the limit for Columns A, B, or C if that integer includes a fractional value of unacceptable snubbers as determined by inter-polation.

If the number of unacceptable snubbers is equal to or less than the Note 3:

number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.

If the number of unacceptable snubbers is equal to or less than the Note 4:

number in Column B but greater that the number in Column A, the next inspection interval shall be. the same as the previous interval.

gy CNsEAT C If the number of unacceptable snubbers is equal to or greater than the Note 5:

number in Column C, the next inspection interval shall be two-thirds of the previous interval.

However, if the number of unacceptable snubbers is less than the number in Column C but greater than the number in Column B, the next interval shall be reduced proportionally

~ by ' interpolation, that is, the previuus interval.stiall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable snubbers found during the previous interval and the number in Column B tu the difference in the numbers in Columni 3 dnd C.

Note 6:

The provisions of Specification 4.0.2 are applicable for all inspec-tf6n"ih'tervals up to and including 48 months.

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• REVisloy 1

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BAM'.*,.

3/4.7.B SNUBBERS All snubbers-are required OPEPABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems are main-tained during and following a seismic or other event initiating dynamic loads.

)

Snubbers are classified and grouped by design and manuf acturer, but not by size.

For example, mechanical snubbers utilizing.the same design features of the 2-kip,10-kip and 100-kip capacity manuf actured by' Company "A" are of the same type.

The same cesign mechanical snutbers manuf actured by Company "B" for the purposes of this Technical Specification would be of a diffs. rent type, as would hydraulic snubbers f rom either manuf acturer.

Snubbers may also be classified and grouped by inaccessible or accessible for visual inspection Therefore, tach snubber type may be grouped for inspection in purposes.

accordance with accessibility.

A list of individual snubbers with detailed information of snubber lccation and siz.e and of systems affected shall be available at the plant in accordance with Section.50.71(c', of 10 CFR Part 50. The accessibility of each snuceer shall be determined and approved by the On-Site Review Comittee. The deter-mination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each snutter location as well as other f actors associated with accessibility during plant operations (e.g., tempera-ture, atmosphere, location etc.), and the recommendations of Regulatory Guides 6.8 and 3.10.

The addition or deletion of any hydraulic or meenanical snubber shall-be made in accordanct witn Section 50.59 of 10 CFR Part 50.

The visual inspection frequency is based upon maintaining a constant of snu

• protection during an earthquake or severe transient.

The fe, the required in

-tion interval v u les inversely with the observed

. Ber.fri10res and-is determine the number of inoperable snubbers fo -

uring an inspec-tion of each type, t

- er to establish the inspecti

.requency for each ggg.

type of snuober on a safety ated system, it w ssumed that the frequency M) @

of snubber failures and initiati.3 vents I

.nstant with time and that the ggg failure of any snubber could cause tn

. tem to be unprotected and to result in f ailure during an assumed int '. ng av Inspections performed before D

that interval has elaosed me e used as a new rence point to determine the next inspection.

How the results of such early. aections cerformed Imlore the origin required time interval has elapsed (nv.. '- I time less 25%)

m.iy not be to lengthen the required inspection interval.

inspection j

whuw t.s reuuire a shorter inspection interval will override t..

aevious N

lule.

the acceptance criteria are to be used in the visual inspection to deter-mine OFERABillfY uf the snubbers. - For example. If a fluid port of a hydraulic

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CALLAWAY - UNIT 1 3 3/a 7-5

INSERT "D" The visual inspection frequency is based on the number of unacceptable snubbers found during the previous inspection in proportion to the size of the various snubber populations or categories.

The Snubber Visual Inspection Interval is determined in accordance with Table 4.7-2.

The maximum inspection interval can be as long as two refuel cycles but not more than 48 months, provided the requirements of Taole 4.7-2 are met.

A snubber is considered unacceptable if it fails the acceptance criteria of visual inspection.

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i ULNRC-2452

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ATTACHMENT 2 SAFETY EVALUATION B

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ULNRc 2452 Page 1 of 3 SAFETY EVAlUATIO!J Thin amendment opplication requents revisionn to Technical Specification. '1/4.7.8 and annociated Basen to change the enubber vinual innpoetion interval and corrective actions.

Technical Specification 3/4.7.8 imponen nurveillance requirementn for vinual innpection on all safety-related snubbers.

The current snubber inspection schedule.in based on the number of inoperable snubbers found during the previous innpection.

This requirement is considered very restrictive and exposen plant personnel to unnecensary radiological exponure.

Generic Letter 90-09 (Reference 1) provides guidance on implementing an alternative inspection schedule based on the number of inoperable snubbern found during the previoun inspection in proport. ion to the sinen of snubber populations or cat egories.

A visual inspection in the obs<rvation of the condition of installed snubbers to identi f y those that are damaged, degraded, or inoperable t.s caused by physical means, leakage, corrosion, or environmental exposure.

To verify that a enubber can operate within specific performance limita, a f ut ction test is performed that typically involves removing the snubber and testing on a test bench.

A visual innpection complements the functional tes ting progra:" and providen additional confidence in snubbtr operability.

All nafety-related snubbern are required to be operable to ensure that the structural integrity of the reactor coolant nyntem and all othnr safety-related systemn are maintained during and following a seismic or other event initiating dynamic loads.

The visual inspection frequency in baned upon maintaining a constant a seinmic or nevere trannient level of snubber protection during event. Therefore, the required inspection interval varien inversely wi th the obner*/ed number of unacceptable snubbers and in determined by the number of unacceptable snubbers found during an inspection of each type.

In order to establish the innpoetion frequency for each type of nnubber on n safety-telated nystem, it van assumed that the frequency of snubber failure and initiatinq event 10 countant with time and that the failute of any enubber could cause the system to be unprotected and to renult in failure during an aenumed initiatinq event The. current requirements in Technical Specification 3/4.7.8 specify a nchedule for snubber visual inspections that in baned on the number of inoperable snobbers found during the previous visual inspection.

The schedules for visual innpectionn and for the functional testing annume that tefaeling intervals will not exceed 18 months.

Encause the current achedule for visual innpoetions in baned only on the number of inoperablo snubborn found during the previous vieual inspection a rrespective of the nize of the snubber population, plants with a large snubber population find that the visual inspection nchedule in

ULNRC-2452 Page 2 of-5 excessively restrictive.

Some plants _ have spent a significant amount of resources and subjected plant personnel to unnecessary radiological exposure to comply wi th the visual inspection requirements, In Reference 1, the NRC described an alternative inspection

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schedule for visual inspections that maintains the same confidence level as the existing schedule and generally allows the performance-of v3 sual.inspcctions and corrective ections during plant outages.

This schedule is based on the number of inoperable snubbers found duri : *-he previous inspection in proportion to the sizes-of vat

.s snubber populations or categories. -The proposed Technical Specification improvoment will reduce' future operational radintion exposure to personnel and is-hinhly cost effective.

The proposed inspection schedule and acceptance criteria are consistent with the Comminsion'a policy statement on Technical Speci fication Improvements.

The proposed changes to Technical Specification 3/4.7.8 do not involve an unreviewed safety question because operetion of the-Callaway Plant with this change would not:

1.

Increase the probability of occurrence or consequences of an accident or! malfunction of equipment important to safety previously evaluated in the safety analysis report.. The changes provide an alternative innpecti on interval.for visual inspection that maintain the same confidence level as the existing schedule and generally allow the performance of visual inspections an1 corrective actions during plant ou t a g e r,.

The changes do not impact the reliability ner availability of plant equipment.

2.

Create the possibility for an accident or malfunction of a different type than any=previously evaluated in the safety analysis report.

The proposed changen permit an inspection interval based on-the number of inoperable snubbers found 1'

during.the previous-innpection in: proportion to the sizes of various snubber populations or categorien.

There is no new type of accident or malfunctjon bejng created and the method and_ manner of plant operation remains unchanged.

3.

Reduce the margin of safety as defined in the basis for any technical specification.

The changes provide an alternative inspection interval 1for visual. inspection-that maintain the-same confidence level as the existing schedule and generally allow the performance of visual inspections and corrective actions during plant outages.

The chances-do not impac t -.the reliability nor availability of plant equipment.

Given the above discunsions, as wel1 as those presented in the Significant Hazards Consideration, the proposed-changes do not adversely affect or endanger the health or safety of the general public or involve a.signi ficant safety hazard.

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4 ULl4RC-2452 pago.3-of;3-3 Reforencps o

1) -: U.S.- 11uclear. Regulatory Commission. Generic-Letter 90-09,

"- Alternative Requirements for. Snubber-Visual. Inspection ii

--intervals-and: Corrective ' Actions," December 11,:1990 s

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ULNRC-2452 s

b ATTACHMENT 3 SIGNIFICAMT IIAZARDS - EVALUATION 1

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ult!RC-2452 Page 1 of 1 i

S I G!LI FICAt_1T JiAZARDS_ EVALUAT10tj This amendment application requests revisions to Technical Specification 3/4.7.8 and associated Bases to incorporate alternative snubber vi sual inspection intervals and corrective actions as provided by fWC Generic Letter 90-09.

The proposed change to Technical Specification 3/4.7.8 does not involve a significant hazards consideration because operation of the Callaway Plant with this change would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated.

The changea provide an alternative innpection interval for visual inspection that maintain the same confidence level as the exinting schedule and generally allow the performance of visual inspections and corrective actions during plant cutages.

The changen do not impact the reliability nor av,ilability of plant equipment.

2.

Create the possibility of a new or different kind of accident from any previously evaluated.

The proposed changen permit an inspection interval based on the number of inoperable snubbers found during the previous inspection in proportion to the sizes of varioun snubber populations or categories.

There is no new type of accident or malfunction being created, and the method and mn:.nor of plant operation remain unchanged.

3.

Involve a significant reduction in a margin of safety.

The changea provide an al ternative inspection interval for visual inspection that maintain the name confidence level as the existing schedule and generally allow the performance of visual inspections and corrective actions during plant outages.

The changeo do not impact the reliability nor availability of plant equipment.

As discunned above, the proposed changed do not involve a significant increase in the probability or consequences of an accident previously evaluated or create the possibility of a new or different kind of accident from any previously evaluated result in a significant reduction

>a a margin of safety.

Therefore, it has been determined t. hat the proposed changes do not inv ve a significant hazards consideration.