ML20080P568

Proposed Tech Specs to Extend Surveillance Test Intervals for Snubber Systems to Support 24 Month Operating Cycles

ML20080P568
Person / Time
Site:	FitzPatrick
Issue date:	03/02/1995
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20080P556	List: JPN-95-011, Application for Amend to License DPR-59,to Extend Surveillance Test Intervals for Snubber Systems to Support 24 Month Operating Cycles ML20080P568
References
NUDOCS 9503080042
Download: ML20080P568 (16)

Text

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i ATTACHMENT I to JPN-95-011 I

i Proposed Changes to Technical Specification Snubber System Surveillance Test intervals to A_ccommodate 24-Month Operatina Cycles (JPTS-95-001 A)

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 I 9503080042 950302 PDR ADOCK 05000333 P PDR

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l 4.0 BASES A. This specification provides that surveillance activities C. Continued necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL interval, defined by the provisions of Specification 4.0.B, as a CONDITIONS (modes) for which the Limiting Conditions for condition that constitutes a failure to meet the OPERABILITY Operation are applicable. Provisions for additional surveillance requirements for a Limiting Condition for Operation. Under the activities to be performed without regard to the applicable provisions of this specification, systems and components are OPERATIONAL CONDITIONS (modes) are provided in the assumed to be OPERABLE when Surveillance Requirements individual Surveillance Requirements. have been satisfactorily performed within the specified time interval However, nothing in this provision is to be construed B. Specification 4.0.B establishes the limit for which the specified as implying that systems or components are OPERABLE when time interval for Surveillance Requirements may be extended. they are found or known to be inoperable although still it permits an allowable extension of the normal surveillance meeting the Surveillance Requirements. This specification also interval to facilitate surveillance scheduling and consideration clarifies that the ACTION requirements are applicable when of plant operating conditions that may not be suitable for Surveillance Requirements have not been completed within the conducting the surveillance (e.g., transient conditions or other allowed surveillance interval and that the time limits of the ongoing surveillance or maintenance activities). It also ACTION requirements apply from the point in time it is provides flexibility to accommodate the length of a fuel cycle identified that a surveillance has not been performed and not for surveillances that are performed at each refueling outage at the time that the allowed surveillance was exceeded.

l and are specified with a 24 month surveillance interval. It is Completion of the Surveillance Requirement within the not intended that this provision be used repeatedly as a allowable outage time limits of the ACTION requirements convenience to extend surveillance intervals beyond that restores compliance with the aquirements of Specification specified for surveillances that are not performed du:ing 4.0.C. However, this does not negate the fact that the failure refueling outages. The limitation of this specification is based to have performed the surveillance within the allowed on engineering judgement and the recognition that the most surveillance interval, defined by the provisions of Specification.

probable result of any particular surveillance being performed is 4.0.B, was a violation of the OPERABILITY requirements of a the verification of conformance with the Surveillance Limiting Condition for Operation that is subject to enforcement Requirements. The limit on extension of the normal action. Further, the failure to perform a surveillance within the surveillance interval ensures that the reliability confirmed by provisions of Specification 4.0.B is a violation of a Technical surveillance activities is not significantly reduced below that Specification requirement and is, therefore, a reportable event obtained from the specified surveillance interval. under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant Technical Specifications.

C. This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance Amendment No. 8% 1M 3Od

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i. JAFNPP .

3.6 (cont'd) 4.6 (cont'd) ,

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2. 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 /> 2. Visual inspection shall verify (1) that there are no visible i

during normal operation, or within 7 days during Cold indications of damage or impaired OPERABILITY, (2) -

Shutdown or Refueling mode of operation for systems attachments to the foundation or supporting structure are which are required to be operable in these modes, secure, and (3) in those locations where snubber complete .QDe of the following: movements can be manually induced without disconnecting the snubber, that the snubber has freedom of movement

n. replace or restore the inoperable snubber (s) to . and is not frozen up. ^ Snubbers which appear inoperable as operable status or, a result of visual inspections may be determined ' '

- OPERABLE for the purpose of establishing the next visual -

b. declare the supported system inoperable and follow inspection interval, providing that (1) the cause of the :i the appropriate limiting condition for operation rejection is clearly established and remedied for that statement for that system or, particular snubber and for other snubbers that may be generically susceptible; and (2) the affected snubber is

c. perform an engineering evaluation to show the functionally tested in the as found conditxm and inoperable snubber is unnecessary to assure determined OPERABLE per Specifications 4.6.l.7 or 4.6.l.8, operability of the system or to meet the design as applicable. . Hydraulic snubbers which have lost criteria of the system, and remove the snubber from sufficient fluid to potentially cause uncovering of the fluid -

the system. reservoir-to-snubber valve assembly port or bottoming of the fluid reservoir piston with the snubber in the fully extended position shall be functionally tested to determine.

operability.

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3. - With one or more snubbers found inoperable, within 72 - 3. Once every 24 months,10% of each type of snubbers shall , l

! hours perform a visual inspection of the supported . be functionally tested for operability, either in place or in a -

component (s) associated with the inoperable snubber (s) . bench test.- For each unit and subsequent unit that does .

and document the results. For all modes of operation not meet the requirements of 4.6.l.7 or 4.6.1.8, an additional

, except Cold Shutdown and Refueling, within 14 days l10% of that type of snubber shall be functionally tested until!  ;

complete an engineering evaluation as per Specification no more failures are found, or all units have been tested. ,

4.6.1.6 to ensure that the inoperable snubber (s) has not ,

adversely affected the supported component (s). For Cold Shutdown or Refueling mode, this evaluation shall be completed within 30 days.

Amendment No. 25, 9dl, JHI,1As, 3,80, 145c- ,

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3.6 (cont'd) 4.6 (cont'd) ,

c. Snubber release rate, where required, is within th'e specified range in compression or tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to

• withstand load without displacement shall be verified.

9. Snubber Service Life Monitoring A record of the service life of each snubber, whose failure could adversely affect the primary coolant or other safety-related system, the date at which the designated service life commences, and the installation and maintenance records on which the designated service life

. is based shall be maintained as required by specification 6.10.B.13.

Once every 24 months, the installation and maintenance l records for each snubber, whose failure could adversely affect the primary coolant or_other safety related system, 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 snubber 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 schedule service life review. This -

reevaluation, replacement or reconditioning shall be indicated in the records.

Amendment No. JiMf,9EI, 145g

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JAFNPP .

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3.6 and 4.6 BASES (cont'd) ,

in each category from the previous inspection. The intervals order to determine if any safety-related component or system may be increased up to 48 months if few unacceptable has been adversely affected by the inoperability of the snubber.

snubbers are found in the previous inspection. The visual The engineering evaluation shall determine whether or not the inspection interval will not exceed 48 months. However, as snubber mode of failure has imparted a significant effect or for all surveillance activities, unless otherwise noted, degradation on the supported component or system.

allowable tolerances of 25% are applicable for snubbers.

Table 4.6-1 establishes three limits for determining the next To provide assurance of snubber functional reliability, a -

visual inspection interval corresponding to the population of representative sample of the installed snubbers will be each category of snubbers. For a category that differs from functionally tested every 24 months. Selection of a l the representative sizes provided, the values for the next representative sample of 10% of each type of safety related inspection interval may be found by interpolation from the snubbers provides a confidence level within acceptable limits limits provided in Columns A, B, and C. Where the limit for that these supports will be in an operable condition. Observed unacceptable snubbers in Columns A, B, or C is determined failures of these sample snubbers shall require functional testing by interpolation and includes e fractional value, the limit may of additional units.

be reduced to the next lower integer. The first inspection interval determined using Table 4.6-1 shall be based upon the Hydraulic snubbers and mechanical snubbers may each be previous inspection interval as established by the requirements treated as a different entity for the above surveillance programs.

in effect before amendment 180. Any inspection whose results require a shorter inspection interval will override the The service life of a snubber is evaluated using manufacturer previous schedule. When the cause of the rejection of a input and information and also through consideration of the snubber is clearly established and remedied for that snubber installation and maintenance records (newly installed snubber, and for any other snubbers that may be generically seal replaced, spring replaced, in high radiation area, in high susceptible, and verified by inservice functional testing, that temperature area, etc...). The requirement to monitor the snubber may be exempted from being counted as inoperable. snubber service life is included to ensure that the snubbers Generically susceptible snubbers are those which are of a periodically undergo a performance evaluation in view of their specific make or model that have the same design features age and operating conditions. These records will provide directly related to rejection of the snubber by visual statistical bases for future consideration of snubber service life.

inspection, and are similarly located or exposed to the same The requirements for the maintenance of records and the environmental conditions such as temperature, radiation, and snubber service life review are not intended to affect plant vibration. When a snubber is found inoperable, an engineering operation.

evaluation is performed, in addition to the determination of the snubber mode of failure, in Amendment No. 20,92,180, 156a

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i ATTACHMENT 11 to JPN-95-011 1

!- Safety Evaluation j For Proposed Changes to Technical Specification l

Snubber System Surveillance Test intervals to

- Accommodate 24-Month Operatina Cycles (JPTS 95-001 A) i 3

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J New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT 4

Docket No. 50-333 1 DPR-59 i

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Attachment ll to JPN-95-011

! Snubbers SAFETY EVALUATION Page 1 of 5

1. DESCRIPTION OF THE PROPOSED CHANGES

1. Page 30d, Bases 4.0.B, change "an 18 month surveillance interval" to "a 24 month surveillance interval." The revised specification reads:

"It also provides flexibility to accommodate the length of a fuel cycle for surveillances-l' that are performed at each refueling outage and are specified with a 24 month surveillance interval." ]

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2. Page 145c, Specification 4.6.1.3, cha.1ge "Once each operating cycle" on the first'- i sentence to "Once every 24 months." The revised specification reads: l

[ "Once every.24 months,10% of each type of snubbers shall be functionally l tested for operability, either in place or in a bench test."'

3. Page 145g, Specification 4.6.l.9 (first sentence of the second paragraph), change "At ,

least once per operating cycle" to "At least once every 24 months." The revised I specification reads:  !

"At least once every 24 months, the installation and maintenance records for each snubber, whose failure could adversely affect the primary coolant or other safety related system, shall be reviewed to verify that the indicated service life q has not been exceeded or will not be exceeded prior to the next scheduled

! snubber service life review."

4. Page 156a, Bases 4.6, change "during each operating cycle" to "every 24 months" in the first sentence of third to last paragraph. The revised specification reads: '

i "To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested every 24 months."

In addition, a previously omitted reference to amendment number 180 has been corrected in the first paragraph of page 156a.

Note that the Authority previously submitted Technical Specification changes to extend snubber visual inspection intervals (Reference 1). The changes were made following the guidance provided in Generic. Letter 90-09, "Altemative Requirements for Snubber Visual Inspection intervals and Corrective Actions," which allowed extending the frequency of snubber visual inspections based on an operating cycle up to 24 months,.

not to exceed 48 months. In Reference 2, the NRC approved these changes.

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Attachment 11 to JPN-95-011 Snubbers i

SAFETY EVALUATION Page 2 of 5 II. P_UBP_QSE OF THE PROPOSED CHANGES Starting with Cycle 11 (which began in January,1993), the James A. FitzPatrick Nuclear Power Plant began implementation of 24 month operating cycles. This

application for amendment proposes to extend the snubber surveillance test intervals to accommodate operation with the 24 month cycle. The proposed change in test-frequency is every 24 months. These changes are necessary to avoid an extended mid-cycle outage. These changes follow the guidance provided by Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate 24-

. Month Fuel Cycle," (Reference 3). Extension of the surveillance test intervals and maintenance was evaluated for the snubbers and the results documented in Reference l 4.

Ill. SAFETY IMPLICATION OF THE PROPOSED CHANGES Snubbers are designed to permit flexibility of a piping system or component when subjected to slow movement such as thermal expansion and contraction during normal operation. When subjected to a dynamic load such as might be expected during a seismic event or transient, the snubber locks to limit motion of the system or component to which it is attached.

. Starting with Cycle 11 (which began in January,1993), the James A. FitzPatrick

Nuclear Power Plant began implementation of 24 month operating cycles. Currently, Technical Specification 4.6.l.3 requires functional testing of a representative sample of 10% of each snubber type once each operating cycle (i.e.,18 months). Performing the functional test requires a plant shutdown due to snubbers that are inaccessible, therefore, the interval between functional tests requires extension to at least once per 24 months to accommodate the longer operating cycle. In addition, functional testing of snubbers requires snubber removal from the system and therefore affects system operability. The Technical Specification ct!teria and the corrective actions required for i a snubber falling a functional test remain the same.

Surveillance test data from 1987 to 1994 was reviewed for all safety-related snubbers.

Sixteen snubber functional test failures have occurred at the FitzPatrick plant in this period of time (16 failures out of a safety-related snubber population of 233). The review indicated that the failures were not age related or time dependent. The Technical Specification for snubber testing are self-corrective in that if any snubber fails a functional test, Technical Specifications require additional testing of a 10%

sample of that type of snubber until no more failures are found. In addition to the regular sample, snubbers that failed the previous functional test are retested during the next functional test interval. The functional test criteria ensures a 95% confidence

Attachment il to JPN-95-011 Snubbers SAFETY EVALUATION Page 3 of 5 4

level that at least 90% of all snubbers are operable. Technical Specifications also require engineering evaluations and more stringent future functional testing of the failed unit to determine if a generic problem exi.sts.

Technical Specification 4.6.l 9 requires a once per operating cycle review of the instaliation and maintenance records for each snubber as part of the snubber service

life monitoring program. This review ensures that the designated service life of the snubber has not been or will not be exceeded prior to the next scheduled service life i review. The review of the installation and maintenance records will be scheduled to be -

consistent with the length of the 24 month operating cycle. This review will continue to ensure that snubber service life will not be exceeded prior to the next scheduled review. The frequency of removal and replacement of snubbers will remain the same.

Snubber service life will not decrease as a result of the operating cycle extension.

] The Bases sections 4.0 and 4.6 have been revised to clarify that the interval for I functional testing is once every 24 months.

The assumptions in the Fitzpatrick licensing basis are not invalidated by performing the snubber surveillances at the bounding interval limits (30 months) to accommodate the 24 month operating cycle.

I IV. EVALUATION OF NO SIGMFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with tbc proposed Amendment would not involve a significant hazards consideration as definud in 10 CFR 50.92, since it

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

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The proposed changes increase the interval between snubber functional tests. These 3

changes are consistent with the guidance provided in Generic Letter 91-04. These changes do not involve any physical changes to the plant, nor do they alter the way

snubbers function. The type of testing and the actions taken if a snubber falls a functional test remain the same. The review of the snubber installation and maintenance records will continue to ensure that the snubbers service life is not S

exceeded prior to the next scheduled review. The proposed changes to bases 4.0 and

, 4.6 clarify that the snubber functional testing interval is consistent with the length of the operating cycle. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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Attachment 11 to JPN-95-011 -  :

' Snubbers -

i SAFETY EVALUATION-  ;

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I 2. create the possibility of a new or'different kind of accident from any accident previously-evaluated.

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J The proposed changes increase the interval between snubber functional tests. These -

I changes are consistent with the guidance provided in Generic Letter 91-04. The'  !

j proposed changes do,not change the ability of the snubbers to provide dynamic load -

i support during a design basis accident. Past operating experience Indicates that the

snubber program at the FitzPatrick plant adequately identifies snubber failures _. .No i changes are proposed to the type of testing performed only to the surveillance' interval l length. The proposed changes do not modify the design or operation of plant -

equipment, therefore, no new or different failure modes are introduced. cThe Technical l' Specification for snubber testing is self-corrective. If any snubber fails a functional .

[ test, Technical Specifications require additional testing of a 10% sample of that type of snubber until no more failures are found. The functional test criteria remains I

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l, unchanged and ensures a 95% confidence level that at least 90% of the snubbers are - j j operable. The proposed changes to bases 4.0 and ~4.6 clarify that the snubber functional testing interval is consistent with the length of the operating cycle.

Therefore, the proposed changes do not create the possibility of a new or different kind i of accident from any accident previously evaluated.

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3. involve a significant reduction in a margin of safety.

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The proposed changes increase the interval between snubber functional tests. These changes are consistent with the guidance provided in Generic Letter 91-04. The proposed changes do not alter the configuration of the snubbers nor change the _

! manner in which the snubbers function. ; Operation of the facility remains unchanged _  !

by the proposed changes. An evaluation of past equipment performance indicates that snubber operability is not time dependent. The proposed changes to bases 4.0 and

4.6 clarify that the snubber functional testing interval is consistent with the length of the l operating cycle. Therefore, a longer surveillance test interval will not degrade snubber j performance and will not involve a significant reduction in a margin of safety.

V. IMPLEMENTATION OF THE PROPOSED CHANGE Implementation of the proposed changes will not adversely affectbe ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the

, environment.

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l Attachment il to JPN-95-011 l Snubbers  !

! SAFETY EVALUATION l Page 5 of 5 i l

i VI. CONCLUSION l'

The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. will not increase the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report;

2. will not create the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report;

3. will not reduce the margin of safety Es defined in the basis for any technical specification; and

4. involve no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES

1. NYPA letter to NRC, JPN-91-063, dated November 15,1991, " Proposed Change to the Technical Specifications - Snubber Visual Inspection (JPTS-91-011)."

l 2. NRC letter NYPA, B. C. McCabe to R. E. Beedle, issuing Amendment 180 to the l FitzPatric'. Technical Specifications, dated April 13,1992.

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3. Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate 24-Month Fuel Cycle," dated April 2,1991.

i 4. NYPA document JAF-RPT-MISC-00530, " Shock Suppressors (Snubbers) Surveillance

! and Maintenance Extensions," dated July 1992.

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ATTACHMENT lil to JPN-95-011 Markup of the current Tschnical Specification pages Extension of Snubber System .*urveillance Test intervals to Accommodate 24-Month Operatina Cscles (JPTS-95-001 A) e 4

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

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.lapNpp 4.0 BASES A. This specification provides that surveiNonce activities C. Contmuod necessary to insure the Limiting Conditions for Operation are .

met and will be perfonned during the OPERATIONAL interval, defined by the provisions of Specification 4.0.8, as a CONDITIONS (modoel for which the Limiting Coryhtions for condition that constitutes a failure to meet the OPERABILITY Operation are applicable. Provisions for additional surveillance requwements for a Limiting Condition for Operation. Under the activities to be performed without regard to the applocable provisions of this specification, systems and components are -1 OPERATIONAL CONDITIONS (modes) are pcovided in the assumed to be OPERABLE when Surveillance Requirements indivedual Survoinence Requirements. have been satisfactorily performed within the specified time intervel. However, nothmg in this provision is to be construed

8. Specification 4.0.8 establishes the limit for which the specified as implying that systems or components are OPERABLE when time interval for SurveiNonce Requirements may be extended. they are found or known to be inoperable although still it permits an allowable extension of the normal surveillance meeting the Surveillsnce Requirements. This specification also interval to facilitate surveiNonce scheduling and consideration clarifies that the ACTION requirements are applicable when i of plant operating conditions that may not be suitable for Surveillance Requirements have not been completed within the conducting the surveillance (e.g., trarteient conditions or other allowed surveellence interval and that the time limits of the ongoing survoinence or maintenance activities). It also ACTION requirements apply from the point in time it is provides f>mibility to accommodate the length of a fuel cycle identified that a surveillance has not been performed and not

. for survessences thetJre performed at each refueleg outage at the time that the allowed surveillence was exceeded.

and are speciNed with 1 surveiNonce interval. It is Completion of the SurveNience Requirement within the not intended that this he used i+;: My as a g allowable outage time limits of the ACTION requirements convenience to extend surveMance intervels beyond that restores a,w--t W with the requirements of Specification specified for surveMances that are not performed during 4.0.C. However, this does not negate the fact that the failure refueNng outages. The Nmitation of this specification is based to have performed the surveiNonce within the allowed on engineering judgement and the recognition that the most surveiNance interval, defined by the provisions of Specification probable result of any particular surveiennce being performed 4.0.8, was a violation of the OPERABILITY requirements of a is the verification of confonnance with the Surweillence Limiting Condetion for Operation that is subject to enforcement Requirements. The Nmit on aweension of the normet _

action. Further, the failure to perform a surveillance within the surveillance interwel ensures that the reliability confirmed by provisions of Specification 4.0.8 is a violation of a Technical surveiNonce activities is not signWicently reduced below that Specification requirement and is, therefore, a reportable event olftained from the specified surveWence interval. under the requirements of 10 CpH 50.73(aH2HiHB) because it

is a condition prchibited by the plant Technical Specifications.

C. This specification estelmshes the faNure to perform a

Surveillance Requirement within the allowed surveil;ance  ;

Amendment No. [,198 30d e

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2. 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 /> 2. Visual inspection shaN venty (1) that there are no visible -

during normal operation, or within 7 days during Cold indcations of damage or impaired OPERAbiUT.Y. (2)

Shutdown or RedudnD mode of operation for systems attachments to the foundetson or supporting structure are v4tich are required to be operable in thesopmodes, secure, and (3) in those locations where smeber completeoneof theloNowing: movements can be manuely irwtmeers without r**ennnectmg the sr=Hw, that the ar=Nw has freedom

a. replace or restore the inoperable armHw(s) to of movement and is not frozen up. Snubbers which '

i operablestatusor, appoor inoperable as a restAt of visual inapartians may be -  !

determoed OPERABLE for the purpose of antaNeahing the

b. declare tie supported system inoperable and losow next visual inspection interval, providng that (1) the r anama 8 # *P of the repection is cieerfy malmNished and remedied for that U ""I 'Y8* "' permdar ar=Hw and for other stuMws that may be i c. perform an ed::t.iii avainmeinn to show the genoncally susceptible; and (2) the affected srvHw is inoperable snubber is unnecessary to assure functionaly tested in the as found condition and operabNlty of the system or to meet the design determined OPERABLE per Speedicahons 42.1.7 or 4.6.12 critorie of tie system, and remove tie stud *w from as applicable. Hydraulic smebers which have lost the system. sufficient fluid to potentiaNy cause uncovering of the fluid ,

resentair-kysnt&ber valve assembly port or bottoming of

+ the fluid reservoir piston witi the snubber in the fuNy

' extended position shen be funchoneNy tested to determine operability.

One every 24 monk, I VINei one or more enubbers found inoperable, withen 72 3. Once each operating cycle )10% of each type of ar=Hws 3.

hours perform a visual inspection of the supported shen be functioneNy tested for operatsty, ellher in place or in a bench test. For each unit and animarymant unit that  ;

component (s) associated witt Wie inoperable snubber (s) and document the results. For au modes of operation does not meet the requrements of 4.6.l.7 or 4.6.1.8. an arersaannel 10% of that type of sr=**=r shen be functionally esscept Cold Shutdown and Refueling, within 14 days tested untN no more failures are found, or aN units have complete an engineering evolustion as per W l 4A.I.8 to ensure that Wie inoperable arPJbber(s) has not been tested.

adverseer asoci id the supported component (s). For Cold .

Shutdori or RefueNng mode, this evolushon shen be

.. _ _ _ wahin ao days.

Amendmorao. p.p.p. @.180, ,,,,

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JApWPF .

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4.4 (eeat'd)

e. sambbec release rate, where required, is withis the specified rease la

ceapression or toastoa. For sambbers specifically required not to displace mader contimeous load, the ability of the snobber to withstand load without displeasaset shall be verified.

9. Sashbor Service Life goalterlag A record of the servlee life of each saubber, whose failure could adversely affect the primary coolant- or other safety-related system, the date at which

[ the destgaated servlee life commences, and l

l the lasta11stlos and malatemance records on uttek the destgaated service life is based shall be malatataed as required by specification 6.10.3.13.

euerv 2'l monos, At least once( per 'operattag crele, the

. lasta11 stir.,a and malatemance records for i each'sambber, whose failure could adversely j , affect the primary coolent or other safety related system, shall be reviewed to verify l that. the indicated . service life has not been encoeded oc will mot be exceeded prior-to the most sheeduled sambber service life review. If the ladicated servlee life 'will be exceeded prior to the next scheduled i

sashbor service life review, the sambber service life shall be reevaluated or the sashbor shall be replaced or recondittomed i so as to extend its service life beyond the date of the sent schedule . service life review. This reevaluettoa - replacement or reconditioning shall be ladicated la the records.

Amendesat No. M 98, a 145gl

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3.6 and 4.6 BASES (cont *4 .

in each category from its prewous inspection. The intervals order to determine if any safety related civignment or sysicm may be increased up to 48 months if low unacceptable snahbors has been adversely affected by the inoper.ilniily of the snubber.

are StrJnd in #is predous inspechon. The visual inspection The engrieering evabiahnri shall delemmiu wiselher or not Itic .

Interwel we . not exceed 48 mo6ilhs. However, as for aR sr=Mw mode of failure has imparted a swinihcant ottoct or surwesence aceluties, unless otherwise noted, allowable degradahon on the supported component or :.ysicm. l' tolerances of 2SE are appuceblo Ior snubbers. Table 4.6-1 eVery 2.84 rnonOS estatWehes twee Emits for determining the next visual iriarw*wn To provide assurance Iof stuMw functional rehabshty, a

interval concepons$ng to Wie populaton of each category of representative sgmple i of the instaged samHws wiu be i

smebers. For a category tiet senas gram the i+:::": lunctionssy testedQsunna each operasina evciel maar han of a ,

3 sians provided, Wie values tar Sie next inspecolon interval may be representahve sample of 10% of each type of safety related  !

tound by interpoladon tram Wes Embs prowitted in Columns A, B, snubbers provides a confidence level wthin acceptable hmits -

and C. Inhere Wie Emit for uriaanardaada anubbers in Columns A, that these supports win be in an operable condition Observed ,

B, or C is determined by interpoledian and irwestaa a tractional tenures of these sample snubbers shaN require functsonal teshng weius, Sie EmR may be reduced to em next lower integer. The of adSelonsiunits.

Srst inspecdon interwel determined using Table 4.61 sher be based ipon om prowtous inspecean interwes as =N by f8g Hydraunc h W 6 ms may each be em reqdremones in emoct betare amendments IrrAny tressed as a deerens eney sor to above sunemance programs.

Inspecean whose scenas require a shorter inspection interval wm ovenide Sto prowtous schedido.1Atten Sie cause of sin rejection The service life of a sr=Mw is evasummare usang manufactures of a enutibor is cisedy estatWehod and remessed lor that snisber input and informehon and also throuWi considerasson of the and Io( any oIher endibers that may be genericeSy suecepetds, ir% and maintenance records (needy instated snubber.

l and werWed try inservios luncetonal teeling, Wiet snubber may be seat replaced, spring repieced, in hiWi rmeahan area, in high exempted Iroen being counted as inoperable. GenericaBy temperature ares, etc. ). The requwement to monitor the auenspaham antebers are Niose which are of a specite maho or snubber service life is irw*= tart to ensure that the snubbers '

model Wie have Sie same design testures drecWy related to perio Scary undergo a pertormance evaluelion in view of theu rejecIlon of sie snutibor by wieusi inspecelon, and are simAerty age and operating contmans. These records wiu prowde i

located er exposed to the same ensimnmental con Selons such stabielical haman for future consideration of snubber service hfe

as temperature, restellon, and wRirellon.14 hen a snisbar is The requirements for the meineenance of records and the found inoperable, an enginsedng === hamman is performed, in snieber service life review are not intended to affect plant admon to Wie determinadon of Wie anubber mode of faBure, in operamon.

i l

l Amendment No. 180,  !

t56a i

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