ML20082K960

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
Issue date:	08/27/1991
From:	BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20082K959	List: ML20082K956 ML20082K960
References
NUDOCS 9109030134
Download: ML20082K960 (12)

Text

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NITACllMENTA l

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UNIT 1 REVISED l

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

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 limited to e visual with the licensee's inspection of theengineering judgment(sand supported component . may)be 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 ?.7t/-

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

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

m.__sie i 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

[d - A,te dvwd Ne . 're ke hn t ke A kg t \ E %U ^?Pt oVS\ \

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

. ,w-e for m es_urveillances_that m = m .e ' u-... arejpwTPSM enh '=J =;TQ , l b t' E ii proTision T 5Ie D e~peafiiliy A a'c5 venience to m .... i o. .."

• Vi t i s not

{ extend that are surveillance inty@.v_als ri F beyond that ae'easpecified for surveillances _

not._oeaformed] 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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Pgo m g g g h: ...ae Q Generic Letter 91-04 Q7wS___GUlDANCE s However, th con-per'ofmed when it te consistent w' h safe plant operati .

ower sid /ation is vald for other s utdown, ve'llar.ces thet are erformed durint op ration, plan startue, or but is not ddressed by res cting the nduct of t se surveilis es.

es as only being The staff oncludes tha' the TS need not r ,trict surveilla at when refueling perform' curing shut wn. Nevertheles safety dictates 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 t isuntil con-the unit is hut down for re' eling or is in 1 ondition or mode 51 stent wd n the safe con t of that surve .ance.

l provided an u ated basis for T 4.0.2 in Generic onters (GLs) 87- , i The N the Applica "S ons 3.0 and of Standard Tec ical Specificati ity i ons for Operatio and Surveillance quirements," a 89 14, '

imiting Cond ined tem Imp vements in Techni 1 Specifications Removal of the .25 Limit TS changes to connodate a on Extendin urveillance Inter 1s." However,o There re, licensees longer fue cycle will also er the basis fo is 4.0.2. ,

be consistent w these TS should u ate the Bases Se ton of TS a.O.2 e safe conduct of efueling interval chang and particularly 4th respect to ges to the ass ated paragraph o' he previous guid-sur illances. The c are underlined, a ollows:

a e on the Bases 5 tion of TS 4.0.

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,.3m . .o u , <3 m 4 3, s m ...-~u- *A / > >

g7 hleast bNonce  ? each i : ^~ S d b l --i-1 it i: * ^ t * * *W %f, XT (5'e0 fied to be pe N o~rNe a ,

REFUEL NG INTERVAL.]

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• U Mau 2(7. h [4 tIh' e1515 Ih[ M j/

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= m ':_- U nce etch REFUEllNG INTERVAL. Likewise. it is not 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 cy have been modif* as identified in 87-09 and 89< . Knerwi se, t:here 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 ators is currently ecified with a boundi time limit of 24 ca -

inspection. The inte ai for subsequent in- ec-steam g dar ths after the previ 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 monstrate that previo y observed Category or if tw onsecutive inspection ional degradation has curred. How-degradation ha ot continued and no ad rom inspections ever, for p ts having inspection r ults in the C-2 Categor

.ther of the two previous .nspections, the of steam nerators (SGs) during nspection would be 24 m . 5 from the last bound tnterval for the nex 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 being counted as inoperable. Genericall are (1) of a specific make or model, (2)y susceptible snubbers are those whichof 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

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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

• Small bore (<8") and large bore (>B") hydraulic snubbers are examples of different tyiies of snubbers.

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 -l PAGES i 3/4726 l i

3/4 7 26h 153/403 i B3/4 7 5 [

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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 The scope of this engineering evaluation shall be snubber (s).

)

consistent limited to a visualwith inspection the licensee's engineering of the supported judgment component (s . and may)be  ;

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 O c.

l REVMCLING ZA)TQHAL \] C> T At least once per< months

• Le _:__L...Ja~ representative sample of lot of ea type of snubbers in use -in the plant shall ll 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 reactor coolant or upon reaching 199.9'T average 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 t of k previous revieu.

per%rmeA i4% \9 mes 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

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

iy b 1 cycle

^

e WM for surveillances_tha site: M St gx "g.ivi w a e kh rei d in; dt: $

cil kn;; int:rv h f Itl s not otended that this provision be used repeatedly as a convenience to pd[ extend surveillance in ht r

-: fREf...~

als bevond that specified for surveillances

... he p ?f m eenth:) h y' ine MQ  ; 3 t:;-i

.;., w e:Phe;:eih 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

=

l $ $UIb/W CE P bF{ G l G.'/-c:vre D y,.)

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.

d not restric urveillances as refueling ly being The staff co udes that the TS n theless, safety [t performed d ing shutdown. New dictates that wh interval rveillances are pe ormed during opder operation, licpisees give properr/}gardfortheirtif t on the safe ce fieration of the 01 eft. If the per.

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

mode that is c?6 -

the snit h shut down or refueling or .s in a condition 5 tent with the saf conduct of tha surveillance.

87-09, The NRC provided n updated basis or TS 4.0.2 ir. Ger ric Letters (Gle icability d 4.0 of Standa Technical Specifi ations on the Ap

" Sections 3.0 ce Requirements and 89-14, of Limiting nditient for Op stion and Surveill hnictil Specificat ns - Removal of e 3.25 timi

• Line-Item provements in T tervals." However the TS changes acconnodat a on Extend' ig Surveillance fore, lice ees longer el cycle will a n alter the basis r TS e 4.0.2.

consistent The ith these Te shoul update the Bases aection of TS 4.0. to refueling i terval cha es atid particult ,y with respect to he scfe conduct the previou guid-si eillances. Thef anges to the assp.iated paragraph 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 O t' 1; s e Ust thir d,gggr;_  :- _tr:

efsl ouce cach RE @IUEC NG INTERVAh it}

.9+, ,,,,, y nign;; !; 0-!09 d

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%ggy ( 9 cm h si_ ._u[tM 7 944 - ' y An: '-t M. h N - hi.~ stet-i44e 4 f v o m u ' 1 i n o m t.io s ms-M y(A7 w ;; ' - W fo,,nte etch REF6EI~II4G INTERVAL. Likewise, it is not

{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 ttfiseiidentified changes to the B es Section of TS 4 erwise, .

t:here tb have been nodifie it, G 87-09 and 89-14 pdated to reflee he intent of this sidance.

the Be 5 Section should a copy of the u ted Bases The oposed amendment quest should inct S ion for TS 4.0.2p fervice insp tion of The surveillanc[nterval for perf- ing the second tng time li of 24 calen-steam gentra s t$ currently up ified with a b erval for 5 sequent inspec-dar months ter the previous 3spection. The e exte;.ded to a imum of 40 me if the resu s from two cons -

tions ma inspection, or within the C-1 utive spections, excluptg the presery at previously o erved Cate ry or if two conrrcutive inspectis s demonstrate tion has occurr How-de adation has i.ot sntinued and ny (dditional degras Category from i pections er, for plants t ing inspectirperctults in the previous inspec ns, the of steam genera es(SGs)durigeitherofthei e 24 months fro he last bounding int al for the ntA inspection wou/ld inspection 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 o snubber protection to systems. Therefore, the required inspection interval varies 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 being counted as inoperable. Genericall are (1) or a specific make or model, (2)y of susceptible snubbers the same design, are and (3) those which 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 t ~.

shutdowns at month intervals Observed failures of these sample snubbers ll shall re re functional _ tutin,dhi.Mditional units.

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 *5 mall bore (<8") and large bore (>8") hydraulic snubbers are examples of different types of snubbers.

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