ML20082J997
| ML20082J997 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/22/1991 |
| From: | FLORIDA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20082J986 | List: |
| References | |
| GL-90-09, GL-90-9, NUDOCS 9108290131 | |
| Download: ML20082J997 (19) | |
Text
_.__-.._._ _ _
l s
' fI PLANT SYSTEMS l
l 3/4 7.10 SNUBBERS l
LIMITING CONDITION FOR OPERATION f
4 Ii 3.7.10 All safety related snubbers shall be OPERABLE.
i APPLICABILITY: MODES 1, 2, 3.and 4 (MODES 5 and 6 for snubbers located on l
systems required OPERABLE in those MODES).
j ACTION:
l With one or more safety related snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace l
or restore the inoperable snubber (s) to OPERABLE status or declare the supported system inoperable and follow the appropriate ACTION statement for that system.
SURVElt. LANCE REOUIREMENTS f
I e
4.7.10 Each snubber shall be demonstrated OPERABLE by performance of the l
following augmented inservice inspection program.
l
{
- a. *%ttual Inspections i
Visual ections shall be performed in accordance with the j
following s ule:
j No Inoperable Snu S
Subsequent Visual per Inspection Perio Inspection Period *8 Qf 0
18 months + 25%
i fl4cg i j 12monthsI25%
1 2
W/g months + 25%
i 3,4 1 2n #
12 s + 25%
~
5,6,7 Df 4 62 da
~ 25%
l 8 or more 31 days +
t
% sankan may be categorized into two groups: Those accessible and those inaccessio%rametor operation.
Each group may be inspected independently in accordance Wiu it.: 9 ve schedule.
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t 75: ' g--Hnn interval shall not be lengthened more than one step at a time unless a generic problem nas v.wu M;;tt 'M and correctedt in that event the inspection may be lengthened one _ step the first time and two s6cv. it;Mi'+=r if no inoperable snubbers are found.-
- Tt.e gmisi;n; cf Sp;;;444e*46-A g ] 3pg,gypp((ggg}
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ST. LUCIE - UNIT 1 3/4 7-29 Amendment No. 21,/A, 83
^
91oe290131 910822 gDR ADOCK 0500g'5 g
1 Insert 1 (Unit 1) a.
Insnection Tynqn As used in this specification, " type of snubbor" shall mean snubbers of the same design and manufacturor, irrespective of capacity.
b.
Visual Insoggilong Snubbers are categorized as inaccessible or accessible during reactor operation.
Each of those categorios (inaccessiblo or accessiblo) may bo inspected independently according to the schedulo datormined by Tablo 4.7-3.
The visual inspection interval for each category of snubber shall be datormined based upon the critoria provided in Table 4.7-3 and the first inspection interval datormined using this critoria shall be based upon the previous inspection interval as established by the requirements in offect before Amendment (*).
The llRC will include the number of the licenso amendment that implements this chango.
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PLANT SYSTEMS SURVEILLANCE RE0_0!REMENTS (Continued) 1 C k. Heal Inspection Acceptance Criteria a
i Visual in tions shall verify (1) that there are no visible indica-tions of damag
-impaired OPERABILITY and (2) attachments to the yt' oundation or supp ng structure are secure.
Snubbers which appear f
inoperable as a result isual inspections may be determined OPERABLE Tg for the purpose of establis the next visual inspection interval,
/ o
('
providing that (1) the cause of ejection is clearly established and remedied for that particular snub and for other snubbers that may be generically susceptible; and/or (2 affected snubber is functionally tested in the as found condition a etermined OPERABLE _
per Specifications A s7.10.d or 4.7.10.e. as applica g[ e, d %.
Functional Tests tnsed 2 9
At least once per 18 months during shutdown, a representatiYsTmple (10% of the safety related snubbers) shall be functionally tested f
f4 either in place o* in a bench test. For each snubber that does not
(
meet the fugetional test acceptance criteria of Specification 4.7.10.4e or 4,7,10.X, an additional 10% of that type of snubber shall be t
U functionally tested.
Functional test shc11 continue until no additians' snubbers are found inoperable or all safety related g gg snubber, ha.
heen tested.
The rc.
asonL ive sample selected for functional testing shall include the vi" 4
cc figurations, operating environments and the range of size at' (apt ty of snubbers.
3 Snubbers ident.fied as "Especially Difficult to Remove" or in "High l
Exposure Zu.ms During Shutdown" shall also be included in the representative sample.*
Safety related hydraulic snubber listings and safety related mechanical snubber listings may be used jointly or separately as the basis for the sampling plan, In addition to the regular sample, snubbers which failed the previous functional test-shall be retested during the next test period.
If a spare snubber has been installed in place of a faileo snubber, then both the failed snubber (if it is repaired and installed in another position) and the spare snubber shall be retested. Test results of these snubbers shall not result in additional functional testing due to failure.
l
- Permanent or other exemptions from the functional testing for individual snubbers in these categories may be granted by the Consnission only if l
justifiable-basis 'for exemption is presented and/or snubber life destructive testing-was performed to qualify snubber operability for' all design conditions at either the completion of their fabrication or at a subsequent date.
l:
ST. LUCIE - UNIT 1 3/4 7-30 Amendment No. 27,AA., 83
-=.
-,-,i
,s e-..
t l-Insert 2 (Unit 1) c.
Visual InspectionAccentangs_C.rlt;srla Visual inspections shall verify that (1) the snubber has no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) l'asteners for the attachment of the snubber to the component and to the snubber anchorage l
are functional.
Snubbers which appear inoperable as a result of 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 remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as-found condition I
and determined OPERABLE per specifications 4.7.10.o or
- 4. 7.10. f, as applicabic. All snubbers found connected to an inoperable common hydraulic fluid reservoir shall bo l
counted as unacceptable for determining the next l
inspection interval.
A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber.
If continued operation cannot be justified, the snubber shall be declared incperabic and the ACTION requirements shall be met.
l
- Insert 3 (Table 4.7-3)***
Starts llere l
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Incort 3 (tInit 1)
TABLE 4.7-5 SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS Population Column A Column 8 Column C or Category Extend Interval Repeat Interval Reduce Interval (Notes 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 13 300 5
12 25 400 8
18 36 500 12 24 48 750 20 40 78 1000 or greater 29 56 109 Note 1:
The next visual inspection interval for a snubber population or cate-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 power operation, as accessible or inaccessible. These categor-1es 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 determine the next inspection interval for that category, Note 2:
Interpolation between population or category sizes and the number of unacceptable snubbers is permissible, Use next lower integer for the 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.
Nota 3:
If the number of unacceptable snubbers is equal to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.
Note 4:
If the number of unacceptable snubbers is equal to or less than the number in Column B but greater that the number in Column A, the next inspection interval shall be the same as the previous interval.
Intort 3 (Unit 1)
Note 5:
If the number of unacceptable snubbers is equal to or greater than the number in Column C, the next inspection interval shall be two-thiros 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 interpolition, that is. the previous interval shall be reouced by factor that is one-third of the ratio of the difference between the dnumber of unacceptable snubbers found during the previous interval and the number in Column B to the difference in the numbers in Columns B and C.
Note 6:
Tla provisions of Specification 4.0.2 are -applicable for all inspec-
';;n intervals up to and including 48 months.
)
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PLANT SYSTEMS F
i S_U._RVE!LLANCE RE001REMENTS (Continued) i If any-snubber selected for fur.ctional 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
!i same 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, t
e, jM Hydraulic Snubbers Functional Test Acceptance Criteria g
i The hydraulic snubber functional te3t shall verify that:
Activation (restraining act. ion) is achieved within the specified i
/
1.
range of velocity or acceleration in both tension and compression.
2.
Snubber bleed, or release rate, where required, is within the l
specified range in compression or tension.
j I
6 i
( g.
Mechanical Snubbers Functional Test Acceptance Criteria The mechanical snubber functional test shall verify that:
1.
The force that initiates free movement of the snubber rod in either tension or compression is less than the specified
.l maximum drag force.
l 2.
Activation (restraining action) is achieved in both tension l
N and compression.
3, [. Snubber Service Life Monitoring A record of the service life of each snubber, the date at which the 4
designated service life comences and the installation and maintenance records on which the designed service life is based shall be maintained l
as required by Specification. 6.10.2.1.
Concurrent-with the first inservice visual inspection and at least once per 18 mo :hs thereafter, the installation and maintenance records for l
. each safety related snubber shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded by more than 10% prior to the next scheduled snubber service life review.
If_ the indicated service life-will be exceeded by more i-than 10% prior to the next scheduled snubber service life review,
'l the snubber service life shall be reevaluated cr the snubber-shall L
be replaced or reconditioned so as to extend its service lifeThe beyond the date of:the next scheduled service life review.
results of the reevaluation may be used-to justify a change to the q
l service life of the snubber. This. reevaluation, replacement or t.
i reconditioning shall be indicated in the records.
ST. LUCIE - UNIT 1 3/4 7-31 Amendment No. 21. t,t/, 83 L
ATTACHMENT 2 Marked-up St.
Lucie Unit 2 Technical Specification pages and inserts:
XXV 3/4 7-21 3/4 7-22 3/4 7-23 3/4 7-24 Insert 1 (Unit 2)
Insert 2 (Unit 2)
Insert 3 (Unit 2) i I
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LIST OF TABLES (Centinuec) 7A
___B_L_E.
- AGE 3.7-1 MAXIMUM ALLOWABLE LINEAR POWER LEVEL-HIGH TRIP SETPOINT WITS INCPERABLE STEAM LINE SAFETY VALVES OUR!NG OPERA.
7:0N a'!TH BOT:' STEAM GENE:ATCRS.....
3/4 7-2 1
4.7-0 STEAM LINE SAFETY VALVE 5 ER LOOP.........
3/ 4 7-3 A.7-1 SECONDARY CCC,LANT SYSTEM IPEC: TIC ACT!VITY SAMPLE AND d oo
---> 4. T-2 ANALYSIS PR0GPAM...........................
3/4 7-3 possec v wAu r N s P ac T**N INTEti/4 L
3.7-3a SAFETY-RELATED HYORAULIC 5NUSSERS........................3/4 7-26 A90 l
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3.7-4 FIRE HOSE STAT:0NS.......
3/4 7-36 3.7-5 YARD. FIRE HYORANTS AND ASSOCIATED HYORANT HOSE HOUSES....
3/4 7-32 4.d-i CIESEL 3ENEPATOR TEST SCHEDULE...........
3/4 3-5
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3.5-1 MOTOR-CPERATED VALVES THERMAL OVERLCAO P'.CTE:T::N
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a suunn... :/- ti-c 3.12-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PRCGRAM.
3/4 1*-3 l
3.12-2 REPORT!NG LEVELS FOR RACICACT!VITY CONCENTRATIONS N i
ENVIRONMENTAL SAMPLES.............................., 3/ 4 12-7 4.12-1 DETECTION CAPABILIT:E5 ~0R ENVIRCNMENTAL SAMPLE ANALYS:5., 3/4 12-3 3 4/*.4*l J.,.;tLU ee ---,
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.'CIE - UNII 2 M/
1.99 " Ca n
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.-4 PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMI11NG CCNDITION FOR OPERATION l
3.7.9 All safety-related snubbers shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4 MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.
ACTION:
With one or more safety related snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace l
or restore the inoperable snubber (s) to OPERABLE status and perform an engineering evaluation per Specification 4.7.9(.#on the supported component or declare the supported system inoperable and(follow the appropriate ACTION statement for that system, r
E PL AC E SURVEILLANCE REQUIREMENTS 4.7.9.Each snubber shall be' demonstrated OPERABLE by performance of the following augmented inservice inspection program, a.
Inspection Types -
- Q.
.i <
As used in this specification, ype of snubber shall mean snubbers of the same design and manufacturer, irrespective of capacity, b.
Ngal Inspections Visual in etions shall be performed in accordance with the following se le:
No.-Inoperable Sn rs of Subsequent Visual Each Type per Inspection riod Inspection Period *#
0 la months + 25%
1 RE PL AG 12 months 325%
2 6 months + 25%
W 'TN ays + 25%
~
34 3
5, 6, 7 I N s E R.T i 62 da
~ 25%
8 or more
-31 days +
% M:?"" inn interval for each type of snubber shall not be lengthened more than one step at a J:: "alau a generic problem has been identified and corrected; in that event the inspection i 4 r" 1 mv be lengthened one step the first time and two steps thereafter if no inoperable snubLer: 01 that type are found, g
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pr:viticr.: of Specific: tier. 5.0.2 c.r r.;t a ppl i ca bl e. *---
ST LUCIE - UNIT.2
~
3/4 7-21 Amendment No. 22 m,
.__,w.
,W
1 Incert 1 (Unit 2) b.
Visual Insnections Snubbers are categorized as inaccessible or accessible during. reactor operation.
Each of these categories (inaccessible or accessible) may be inspected independently according to the schedule determined _by Table 4.7-2.
The visual inspection interval for each category of snubber shall be determined based upon the criteria provided in Table 4.7-2 and the first inspection interval determined using this criteria shall be based upon the previouc inspection interval as established by the requirements in effect before Amendment (*).
The NRC Will include the number of the license amendment that implements this change.
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O!
i PLANT SYSTEnts
_ SURVEILLANCE RE0VIREMENTS (Continued)
Qfueling Outace inspections At leas e per 18 months an inspection shall be performed of all safety relate bers attached to sections of safety systems piping that have exp ced unexpected, potentially damaging transients as determined review of operational data and a qd Og i
visual inspection of the systems, addition to satisfying the visual inspection acceptance criteria, heQof motion of mechanical snubbers shall be verified using one4 he following:
(1) manually induced snubber movement; (2) evaluation
-place snubber piston setting; (3) stroking the mechanical snubber -Q its full range of travel Visual Inspection Acceptance Criteria Vis -
inspections shall verify (1) that there are no visble indica ns of damage or impaired OPERABILITY, (2) attachments to the founda.,Qn or supporting structure are secure. Snubbers which appear inoperttd as a result of visual inspections may be determined OPERABLE for the ose of establishing the next visual inspection interval, provided t (1) the cause of the rejection is clearly established and remedie r that particular snubber and for other snubbers, irrespective of t that may be generically susceptible; and (2) the affected snubber is nctionally tested in the as found gggf condition and determined OPERABLE Specification 4.7.9f.
When a W' rW fluid port of a hydraulic snubber is d to be uncovered the 2
snubber shall be declared inoperable and not be determined
~[rJ56 OPERABLE via functional testing unless the te is started with th piston in the as found setting, extending the pis rod in the j tension mode direction. All snubbers connected to a noperable common hydraulic fluid reservoir shall be determined to OPERABLE by visually verifying the required level of oil for operat for each affected snubber; otherwise declare the snubbers inoperab d /.
Functionai Tests i
During the first refueling shutdown and at leastonce per 18 months Rg6 thereafter during shutdown, a representative sample of either:
/
(1) At-least 10% of the total of each type of safety related snubber RE L
in use in the plant shall be functionally tested either in place or in a bench test.
For each snubber of a type that does not the m functional test acceptance criteria of Specification 4.7.
additional i 10% of that type of snubber shall be functionally tested no more failures are found or until all snubbers of that type have been 4
functionally tested or (2) A representative sample of each type of p
snubber shall be functionally tested in accordance with Figure 4.7-1 p
"C" is the total number of snubbers of a type
'hd not meeting the 6
acceptance requirements of Specification 4.7. f.8)"The cumulativp k number of snubbers of a type tested is denote f
N."
At the end of each day's testing, the new values of "N" and "C" (previous day's total plus current day's increments) shall be plotted on Figure 4.7-1.
If at any time the point plotted falls in the " Reject" region, all ST. LUCIE - UNIT 2 3/4 7-22 Amendment No. 22. 45
Insert 2 (Unit 2) c.
Y,igtu_al Inspection Acceptance Criteria visual inspections shall verify that (1) the snubber has no 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 a.ichorage are functional.
Snubbers which appear inoperable as a result of visual inspections shall be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (i) the cause of the rejection is clearly established and remedied for that particular snubber'and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per specification 4.7.10.e.
All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber.
If continued operation cannot_be justified, the snubber shall be declared inoperable and the ACTION requirements shall be met.
- Insert 3 (Table 4.7-2)***
Starts Here l
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Insort 3 (Unit 2) z.
TABLE 4.7-2 SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS Pcpulation Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval (Notes 1 and 2)
(Notes 3 and 6)
(Notes 4 ard 6)
(Notes 5 and C) 1 0
0
-1 80 0
0 2
100 0
1 4
150 0
3 8
200 2
5 13 300 5
12 25 400 8
18 36 500 12 24 48 750 20 40 78 1000 or greater 29 56 109 Note 1:
The next visual inspection interval for a snubber population or cate-gory size shall be determined based upon the previous inspection interval and the number of unacceptable snubbers found during that i nterval. Snubbers may be categorized, based upon their accessibility during power operation, as accessible or inaccessible.
These categor-1es 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 determine the next inspection interval for that category.
Note 2:
M.cerpolation between population or category sizes and the number of unacceptable snubbers is permissible. Use next lower integer for the 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.
Note 3:
If the number of unacceptable snubbers is equal to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.
Note 4:
If the number of unacceptable snubbers is equal to or less than the number in Column B but greater that the number in Column A, the next inspection interval shall be the same as the previous interval.
s.
.1 i-
-Insort 3 (Unit 2)
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-thiros of the previous interval. However, if the number of unacceptable snubbers is less than the number in Co umn C but greater than the i
l number in Column B, the next interval shall be reduced proportionally by interpolation, that i5, the previuus interval shall be reouced by d 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 Columns B 1
snd C.
l Note 6:
The provisions of Specification 4.0.2 are applicable for all inspec-
-i i
tion intervals up to and including 48 months, i
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_ - - - -. - - ~ _ - -. _. -. -
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PLANT SYSTEMS 2
l SURVEILLANCE REOUIREMENTS (Continuedi I
Functional Tests (Continued) snubbers of that type design shall be functionally tested.
If at any time the point plotted f alls in the "Accect" region, testing of that type of snubber shall be terminated.
When the point plotted I
lies in the " Continue Testing" region, additional snubbers of that type shall be tested until the point f alls in the " Accept" region or t
the " Reject" region, or all the snubbers of that type have been tested.
The representative samole selected for functional testing shall f
include the various configurations, operating environments, and the i
range of size and capacity of snubbers of each type.
The representa-tive sample should be weighted to include more snubbers from severe ge service areas such as near heavy equipment.
Snubbers placed in the
$4 y
same location as snubbers whicn failed the previous functional test shall be included in the next test lot if the failure ana,1ysis shows that failure was due to location, y
g, Jf functional Test Acceptance Criteria I
The snubber functional test shall verify that:
1.
Activation (restraining action) is achieved within the specified
[
range in both tension and compression.
2.
Snubber bleed, or release rate where required, is present in both tension and compression, within the specified range.
I 3.-
Where reqJired, the force required to initiate or maintain motion of the snuboer is within the specified range in both i
directions of travel.
4.
For snubbers specifically required not to displace under i
continuous load, the ability of the snubber to withstand load I
without displacement.
5.
Fasteners for attachment of the snubber to the component'and to
}
the snubber nnchorage are secure.
Testing methods may be used to measure parameters indirectly or parameters i
other than those specified if those results can be correlated to the i
specified parameters through established methods.
I
(,
g.
Functional Test Failuro Analysis i
An engineering evaluation shall be made of each failure to meet the T
functional-test acceptance criteria to determine the cause of the i
failure.
The results of this evaluation shall be used, if applicable, in selecting snubbers to be tested in an effort to determine the
. }e, O-OPERABILITY of other snubbers irrespective of type which may-be subject to the same failure mode.
I i
k ST. LUCIE - UNIT 2-3/4 7-23
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PdHTSYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
Functional Test Failure Analysis (Continued)
For the snubbers found inoperable, an engineering evaluation shall be performeo on the components to which the inoperable snubbers are attached.
The purpose of this engineering evaluation shall be to determine if the components were adversely affected by the inopera-bility of the snubbers in order to ensure that the component remains capable of meeting the designed service.
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 type subject to the same defect shall be functionally tested.
This testing requirement shall be independent of the requirements stated in Specification 4.7.9.e for snutbers not meeting the functional test acceptance criteria, g f(
Functional Testing of Repaired and Replaced Snubbers Snubbers which fail the visual inspection or the functional test acceptance criteria shall be repaired or replaced.
Replacement snubbers and snuobers which have repairs which might affect the functional test result shall be tested to meet the functional test criteria before installation in the unit.
These snLbbers shall have met the acceptance criteria subsequent to their most recent service, E.,
and the functional test must have been performed within 12 months before being installed in the unit.
f s h. /
Snubber Seai Reoiacement proora.
The seal service life of hydraulic snubbers shall be monitored to ensure _that the seals do not fail between surveillan:e inspections.
The maximum expected service life for the various seals, seal materials, and applications snall be estimated based on engineering information and the seals shall be replaced so that the maximum expected service life does not expire during a period when the snubber is required to be OPERA 5LE.
The seal replacements shall be documented and the documentation shall be retained in accordance with Specification 6.10.2.
[. f Exemption From Visual Insoection or Functional Tests Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and, if applicable, snubber life destructive testing was performed to qualify the snubber for the applicable design conditions at either the completion of their fabrication or at a subseauent date.
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l ST. LUCIE - UNIT 2 3/4 7-24 Amendment Nd. 22 l
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ATTACHMENT 3 SAFETY ANAL.YSIS INTRODUCTIpy These amendments are submitted to make line item improvements to the St.
Lucie Unit 1 and Unit 2 Technical Specifications in accordance with Generic Letter 90-09 " Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions."
DISCUSSION The proposed changes to the Unit 1
and Unit 2
Technical Specifications will not lead to material procedure changes or to physical modifications to the St. Lucie Plant.
Existing safety analyses and safety assumptions are r ot af f acted.
CONCLUSION The model safety evaluation attachqd to Generic Letter 90-09 applies to these proposed license amendments.
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ATTACHMENT 4 P
DETERMIl{ATION OF NO SIGRIFICANT HAZARDJ The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in 10 CFR 50.92 which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or differ ent kind of accident i.
from any accident previously evaluated; or (3) involve a L
significant reduction in a margin of safety.
Each standard is discussed as follows:
(1)
Operation of the f acility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously i
evaluated.
The changes being proposed by FPL will not lead to material proceduro changes or to physical modifications to the St. Lucie Plant.
Therefore, the proposed changes would not involve a
significant increase in the probability or consequences of an accident previously evaluated.
(2)
Operation of the f acility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
l The changes being proposed by FPL will not lead to material procedure changes or to physical modifications te the St. Lucie Plant.
Therefore, the proposed changes would not create the possibility of a new or different kind of accident.
(3)
Operation of the f acility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.
The changes being proposed by FPL do not modify the safety margins defined in and maintained by the Technical Specifications.
Since the snubber functional test program is not being altered and the alternative visual l
inspection program does not decrease the confidence level associated with this technical specification, the l_
proposed changes would not involve any significant reduction in a margin of safety.
Based on the above, we have determined that the amendment request does not (1) involve a significant increase in the t
probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety; and therefore does not involve a
significant hazards l
consideration.
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