ML20082K960

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Proposed Changes to Tech Specs Pages 3/4 7-26,3/4 7-26b, B3/4 O-3 & B3/4 7-5 to Increase Specified Snubber Functional Testing & Svc Life Monitoring Surveillance Intervals to Accomodate 24 Month Fuel Cycles
ML20082K960
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/27/1991
From:
BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20082K959 List:
References
NUDOCS 9109030134
Download: ML20082K960 (12)
v • d • e


Text

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NITACllMENTA UNIT 1 REVISED TECllNICAL SPECIFICATION PAGES 3/4726 3/4 7 26b D3/40-3 B3/4 7 5 9109030134 910827 PDR ADOCK 050 7

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PLANT SYSTEMS SURVEILLANCE REQUIREtlENTS (Continued) b.

Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that t,cre are no visible indica-tions of damage or impaired OPERABILITY, and (2) that the snubber installation exhibits no visual indications of detachment from foundations or supporting structures.

Snubbers which appear inoper-able as a result of visual inspections may be determined OPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) the cause of the rejection is clearly established and' remedied for that particular snubber and for other snubbers that may be generically susceptible; and/or (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specification 4.7.8.d. as applicable.

When the fluid port of a hydraulic snubber is found to be uncovered, the snubber shall be determined inoperable unless it can be determined OPERABLE via functional testing for the purpose of establishing the next visual inspection interval.

For the snubber (s) found inoperable, an engineering evaluation shall be performed on the component (s) which are supported by the snubber (s).

The scope of this engineering evaluation shall be consistent with the licensee's engineering judgment and may)be limited to e visual inspection of the supported component (s.

The purpose of this engineering evaluation shall be to determine if the component (s) supported by the snubber (s) were adversely affected by the inoperability of the snubber (s) in order to ensure that the supported component remains capable of meeting the designed

service, Functional Tests ?.7t/-

c.

6& months /(U ructING 1 NTE k VhO At least once per d_urhg=shutdern, a representative l

sample of 10% of each type of snubTe'FsMn use in the plant shall

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be functionally tested either in place or in a bench test.' For each snubber that does not meet the functional test acceptance criteria of Specification 4.7.8.d. an additional 5% of that type l

snubber shall be functionally tested until no more failures are found or until all snubbers of that type have been functionally l

tested.

  • The Steam Generator snubbers 1-63-13 through 1-63 28 need not be functionally tested until the refueling outage following June 30, 1985.

CALVERT CLIFFS - UNIT 1 3/4 7-26 AmendmentNo.EE.6/,N),h

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) e.

Snubber Service Life Monitoring i

A record of the service life of each snubber, the date at which the designated service life comrnences and the installation and maintenance records on which the designated service life is based shall be main-tained as required _by Specification _6.10.2.nu gy I' z( _

Demid pntry@

At least once per $nonthsbthe iristallation an maintenance records 1l for 'eac.h safety related snubber shall be reviewed to verify that the indfcated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber service life review.*

If the l

indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be re-evaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

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

4 The provisions of Specification 4.0.2 are applicable.

n ne (itd snubt. service. hRe reseu) 9ebAvg AmAntd Ale (40 she.h h.

per6tued tJ&\\n \\T rocwk' tA b previce review.

CALVERT CLIFFS - UNIT 1 3/4 7-26b AmendmentNo,M.M),[fb

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APPLICABILITY BASES mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE or likewise satisfy Specification 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABLE).

In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6 Specification 3.0.5 is not a>plicable, and thus the individual ACTION statements for each applicable.imiting Condition for Operation in these MODES must be adhered to.

4.0.1 This specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable.

Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.

Surveillance Requirements for Special Test Exceptions need only be perfonned when the Special Test Exception is being utilized as an exception to an individual specification, t

4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended.

It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating l

conditions that may nnt be suitable for conducting the surveillance, e.g., transient conditions or other ongoing surveillance or maintenance activities.

d It also provides flexibil,Lty to accomodate the length of a p)g K..a_.c.ycle for s_urveillances_that arejpwTPSM enh

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  • Vi t i s not b

t' E ii proTision T 5Ie D e~peafiiliy A a'c5 venience to extend surveillance inty@.v_als beyond that specified for surveillances

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that are not._oeaformed]

ri F ae'ea e4 re-"- W r:n eith)

.$tNg 3?E00"!C Y $ ' (i_G mundd_rc'e-14 aa[ThTTilmationMpec,irication 4.o.2 is-6

~ based on engineering 7udgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements.

This provision is I

sufficient to ensure that the reliability ensured through surveillance i

activities is not significantly degraded beyond that obtained from the specified surveillance interval.

i j

CALVERT Cliffs - UNii !

L 3/4 0 3

.anendment No. U/J/J3k

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Q7wS GUlDANCE Pgo m g g g h:.a Q y

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Generic Letter 91-04 per'ofmed when it te consistent w' h safe plant operati However, th con-sid /ation is vald for other s ve'llar.ces thet are erformed durint ower op ration, plan startue, or utdown, but is not ddressed by res cting the nduct of t

se surveilis es.

The staff oncludes tha' the TS need not r,trict surveilla es as only being perform' curing shut wn.

Nevertheles safety dictates at when refueling inter surveillan s are performed ing power opera.on, licensees give pro regard for heir effect on t safe operation the plant. If the r-fo anct of a r fueling interval rveillance duri plant operation wo d i versely aff t saf ety, the l'..ensee should pos one the surveillan until the unit is hut down for re' eling or is in 1 ondition or mode t is con-51 stent wd n the safe con t of that surve

.ance.

The N provided an u ated basis for T 4.0.2 in Generic ters (GLs) 87-i "S

ons 3.0 and of Standard Tec ical Specificati on the Applica ity i

imiting Cond ons for Operatio and Surveillance quirements," a 89 14, ined tem Imp vements in Techni 1 Specifications Removal of the

.25 Limit on Extendin urveillance Inter 1s."

However,o TS changes to connodate a longer fue cycle will also er the basis fo is 4.0.2.

There re, licensees should u ate the Bases Se ton of TS a.O.2 be consistent w these TS chang and particularly 4th respect to e safe conduct of efueling interval sur illances.

The c ges to the ass ated paragraph o' he previous guid-a e on the Bases 5 tion of TS 4.0.

are underlined, a ollows:

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  • A f

h bN ? i : ^~ S d b l (5'e0 fied to be pe N o~rNe a

least once each REFUEL NG INTERVAL.] it i: * ^ t * * *W %, XT

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  • U Mau 2(7. h [4 tIh' e1515 Ih[

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= m ':_- U nce etch REFUEllNG INTERVAL.

Likewise. it is not j/

lhe intent that REFUELING INTERVAL surveillances be oerf ormed during power operation unless it is consistent with safe plant toyer a tion 1/ The 17'tation of,5vC1fication 4.0 3/T...

Licensees bould incorporate se changes to the ases Section of TS 4 A t t:here cy have been modif*

as identified in 87-09 and 89<.

Knerwi se, th ases Section shoul e updated to ref1

, the intent of this idance.

e proposed amendmt request should in de a copy of the uct d Bases Section for TS 4.

The surveil te interval for pe orming the second ins r91ce inspection of steam g ators is currently ecified with a boundi time limit of 24 ca dar ths after the previ inspection.

The inte ai for subsequent in-ec-is may be extended t maximum of 40 months the results from tw onsec-utive inspections, e uding the preservice ection, are within t C-1 Category or if tw onsecutive inspection monstrate that previo y observed degradation ha ot continued and no ad ional degradation has curred. How-ever, for p ts having inspection r ults in the C-2 Categor rom inspections of steam nerators (SGs) during

.ther of the two previous.nspections, the bound tnterval for the nex nspection would be 24 m

. 5 from the last ins ction.

i PLA.T SYSTEMS r

BASES environment.

The operation of this system and the resultant effects on of fsite dosage calculations was assumed in the accident analyses.

3/4.7.8 SNUBBERS e

All safety related snubbers are required OPERABLE to ensure that the structural I

integrity of the reactor coolant system and all other safety related systems is maintained during and following a seismic or other event initiating dy v',P loads.

I Snubbers excluded from this inspection program are those installed 4 w A'ety related systems and then only if their failure or failure of the s W 1 o; f h they are installed would have no adverse effect on any safety relaW Upn The visual inspection frequency is based upon maintaining a constan V /

snubber protection to systems.

Therefore, the required inspection itN 61 e es inversely with the observed snubber failures and is determined by the number of inoperable snubbers of each type

  • found during an inspection.

Inspections performed before that interval has elapsed may be used as a new reference point to detemine the next inspection.

However, the results of such early inspections performed before the original required time interval has elapsed (nominal time less 25t) may not be used to lengthen the required inspection interval.

Any inspection whose results require a shorter inspection interval will override the previous schedule.

When the cause of the rejection of a snubber is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible.

and verified by inservice functional testing, that snubber may be exempted from are (1) of a specific make or model, (2)y susceptible snubbers are those whichof being counted as inoperable.

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

These characteristics of the snubber installation shall be evaluated to determine if further functional testing of similar snubber installations is warranted.

When a snubber is found inoperable, an engineering eva19ation is performed, in addition to the determination of the snubber mode of failure, in order to deter-mine if any safety-related component or system has been adversely affected by the inoperability of the snubber. The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a significant effect or degrada-tion on the supported component or system.

To provide assurance of snubber functional reliability, a representative sample of the installed snubbers of each typc* will be functionally tested during plant shutdowns at month interval Observed failures of these sample snubbers y

shall requ functional testino of additional units.

24 [curunmo snrenvasD The serv ce life of a snubber is evaluated via manufacturer input and information

~

hrough consideration of the snubber service conditions and associated installa-tion and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high tempera ture a rea, etc.... ).

The requirement to monitor the snubber service life is included to ensure that the

CALVERT CLIFFS - UHT 1 B 3/4 7-5 Amendment No. H. })f,[h l

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ATTACllMENT H i

UNIT 2 REVISED TECilNICAL SPECIFICATION

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3/4726 l

i 3/4 7 26h 153/403 i

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PLANT SYSTEMS SURVE!LLANCE REQUIREMENTS (Continuad) b.

Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that there are no visible indica-tion; of damage or impaired OPERABILITY. and (2) that the snubber installation exhibits no visual indications of detachment from i

foundations or supporting structures.

Snubbers which appear inoper-able as a result of visual inspections say be determined OPERA 8LE for the purpose of establishing the next visual inspection interval.

i providing that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptib1'e; and/or (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specification 4.7.8.1.d. as applicable. When the fluid l

port of a hydraulic snubber is found to be uncovered, the snubber r

shall be determined inoperable unless it can be determined OPERA 8LE i

via functional testing for the purpose of establishing the next I

visual inspection interval.

i For the snubber (s)' found inoperable. an engineering evaluation shall be perfonned on the component (s) which are supported by the snubber (s).

The scope of this engineering evaluation shall be

)

consistent with the licensee's engineering judgment and may)b limited to a visual inspection of the supported component (s.

The purpose of this engineering evaluation shall be to determine if the component (s) supported by the snubber (s) were adversely affected by the inoperability of the snubber (s) in order to ensure that the supported component remains capable of meeting the designed service.

c.

Functional Tests O REVMCLING ZA)TQHAL C> T

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l At least once per<

months

  • Le _:__L...Ja~ representative ll sample of lot of ea type of snubbers in use -in the plant shall be functionally tested either in place or in a bench test.

For each snubber that does not meet the functional test acceptance criteria of Specification 4.7.8.lgd an additional $1 of that type snubber shall be functionally tested untti no more failures are found or until all snubbers of that type have been functionally tested.

[

i 9

  • - Effective at 11:59 p.m. on May 17. 1989 or upon reaching 199.9'T average reactor coolant system (RCS) temperature during initial RCS heatup following E

the Unit 2 Cycle 9 refueling outage, whichever occurs first.

Replaces page 3/4 7-26(t).

CALVERT CLIFFS - UNIT 2 3/4 7-26 Amend ant No. H.)S.Jf.73.}0'0'. h '

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PLANT SYSTEg, SURVEILLANCE REQUIREMENTS (Continued) e.

Snubber Service Life Monitoring l

A record of the service life of each snubber, the date at which the designated service life comences and the installation and maintenance records on which the designated service life is based shall be main-tained as required by Specification 6.10.2.i 4

~

(RCFlifttH6syrElvAkhgf At least once per months inrtallation and maintenance records l\\

' for each safety r ed snu er shall be reviewed tp verify that the i

indicated service life has not been exceeded or will not be exceeded prior to tne 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 re-evaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

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

l

  • The provisions of Specification 4.0.2 are applicable.

nh hst subt servie.v. Me review 6bM lbewled do b0 d*N C per%rmeA i4% \\9 mes of k previous revieu.

t CALVERT CLIFFS - UNIT 2 3/4 7-26b AmendmentNo.Mff>,73,[h W-u an.a n,.s se,nru Ly un wu mr-M

APPllCABillTY MSIS mean that for one division the emergency power source must be OPERABLE (as must be the compenents supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE or likewise satisfy Specification 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABLE).

In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6 Specification 3.0,5 is not applicable, and thus the individual ACTION statements for each applicable Limitin Condition for Operation in these MODES must he adhered to.

4.0.1 This spectitcation provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable.

Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.

Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual specification.

4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended.

It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating condition: that may not be suitable for conducting the surveillance.

M e.g., transient conditions or other ongoing surveillance or maintenance activities.

It also provides flexibility to accomadate the lenath of a iy 1 cycle for surveillances_tha gx "g.ivi w a e kh rei d in; dt: $

b

^

WM site: M St cil kn;; int:rv h f Itl s not e

otended that this provision be used repeatedly as a convenience to pd[

extend surveillance in als bevond that specified for surveillances

-: fREf. p ? m eenth:) h y' M Q ; 3 t:;-i ::.;., w e:Phe;:eih ht r

... he

..~ f ine limitation o" 5)ecification 4.0.Z 1s g

ased on engTheering Judgm0Tt'and the recognition t1at the most probable.

result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements.

This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

CALVERT CLIFFS - UNIT 2 B 3/4 0-3 AmendmentNo.##ff,M

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Generic L.etter 91 CA I

owever, this con-perior $ when it is t nsistent with sa'e o'.nt operatioS.

side tion is valid r other f.ur, Plictic. that are perf med during power op ation, piknt s rtuo, or shutdown, t is not addre ed by restrictin the nduct of thes* surweillances.

theless, safety [t d not restric urveillances as ly being The staff co udes that the TS n dictates that wh refueling performed d ing shutdown.

New interval rveillances are pe ormed during opder operation, licpisees give properr/}gardfortheirtif t on the safe fieration of the 01 eft. If the per.

forman of a refueling i erval surveill ce during plant op ation would adver ely affect safsty the licensee sh 1d postpone the s veillance until/

6 the snit h shut down or refueling or.s in a condition mode that is c? -

5 tent with the saf conduct of tha surveillance.

The NRC provided n updated basis or TS 4.0.2 ir. Ger ric Letters (Gle 87-09,

" Sections 3.0 d 4.0 of Standa Technical Specifi ations on the Ap icability of Limiting nditient for Op stion and Surveill ce Requirements and 89-14,

  • Line-Item provements in T hnictil Specificat ns - Removal of e 3.25 timi on Extend' ig Surveillance tervals." However the TS changes acconnodat a longer el cycle will a n alter the basis r TS 4.0.2.

The fore, lice ees shoul update the Bases aection of TS 4.0.

to e consistent ith these Te cha es atid particult,y with respect to he scfe conduct refueling i terval si eillances.

Thef anges to the assp.iated paragraph the previou guid-follows:

A ce on the Basesfr1:ction of TS 4.0.Vare underlined, it :M ;7 Mde' 4WSi'it3 t cas.d t; W-b4n vi.Jul pS(M n:MgMcMified to be performed at d,gggr;_ :- _tr: @IUEC NG INTERVAh i t }

O t' 1; s e Ust thir efsl ouce cach RE

,,,,, y nign;; !; 0-!09 d

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%ggy ( 9 cm h si_._u[tM 7 944 - ' y

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'-t M. h N - hi.~ stet-i44e 4 f v o m u ' 1 i n o m t.io s ms-Likewise, it is not w ;; ' - W fo,,nte etch REF6EI~II4G INTERVAL.

{tTe intent that'l[EIMlTW7TEbl.L surveillances be performedcuring povtr op looeration.j ter-4.m.o..vn v Fim u n;e e en

!,..s

/

Licensees s aid incorporate ttf e changes to the B es Section of TS 4 i

t:here tb have been nodifie is identified it, G 87-09 and 89-14

erwise, the Be 5 Section should pdated to reflee he intent of this sidance.

The oposed amendment quest should inct a copy of the u ted Bases S

ion for TS 4.0.2p The surveillanc[nterval for perf-ing the second fervice insp tion of steam gentra s t$ currently up ified with a b tng time li of 24 calen-dar months ter the previous 3spection.

The erval for 5 sequent inspec-tions ma e exte;.ded to a imum of 40 me if the resu s from two cons utive spections, excluptg the presery inspection, or within the C-1 at previously o erved Cate ry or if two conrrcutive inspectis s demonstrate de adation has i.ot sntinued and ny (dditional degra tion has occurr How-Category from i pections er, for plants t ing inspectirperctults in the s

previous inspec ns, the of steam genera es(SGs)durigeitherofthei e 24 months fro he last ld bounding int al for the ntA inspection wou/

inspection l

1 l

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PLANT SYSTEMS BASES environment.

The operation of this system and the resultant ef fects on of fsite dosage calculations was assumed in the accident analyses.

3/4.7.8 SNUBBERS All safety related snubbers are required OPERABLE to ensure that the structural l

integrity of the reacto" coolant system and all other safety related systems is

}

maintained during and following a seismic or other event initiating dynamic loads.

Snubbers excluded from this inspection program are those installed on non-safety related systems and then only if their failure or failure of the system on which they are instal, led would have no adverse effect on any safety-related system.

The visual inspection frequency is based upon maintaining a constant level of snubber protection to systems.

Therefore, the required inspection interval varies o

inversely with the observed snubber failures and is determined by the number of inoperable snubbers of each type

  • found during an inspection.

Inspections performed before that interval has elapsed may be used as a new reference point to determine the next inspection.

However, the results of such early inspections performed before the original required time interval has elapsed (nominal time less 25%) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.

When the cause of the rejection of a snubber is clearly established and remedied for that snubber and for any other snuboers that may be generically susceptible, and verified by inservice functional testing, that snubber may be exempted from are (1) or a specific make or model, (2)y susceptible snubbers are those which being counted as inoperable.

Genericall of the same design, and (3) similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.

These characteristics of the snubber installation shall be evaluated to determins if further functional testing of similar snubber installations is warranted.

When a snubber is found inoperable, an engineering evaluation is performed, in addition to the determination of the snubber mode of failure, in order to deter-mine if any safety-related component or system has been adversely affected by the inoperability of the snubber.

The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a significant effect or degrada-tion on the supported component or system.

To provide assurance of snubber functional reliability, a representative sample of the install d snubbers of each type

  • will be functionally tested during plant shutdowns at month intervals Observed failures of these sample snubbers ll t ~.

re functional _ tutin,dhi.Mditional units.

shall re M

f(Rcrutons rarrk rMs l

The serv ce life of a snubDer is evaluf e ia manufacturer input and information l

through consideration of the snubber service conditions and associated installa-tion and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high tempera ture a rea, etc.... ).

The l

requirement to monitor the snubber service life is in:luded to ensure that the l

CALVERT CLIFFS - UNIT 2 B 3/* 7-5 Amendment No. 6. IN. M 1

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