ML20085G608

Proposed Tech Specs 3.16,4.16,3/4.7.8 & Bases Re Snubber Visual Insp Interval

ML20085G608
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/15/1991
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20085G606	List: 0CAN109105, Application for Amends to Licenses DPR-51 & NPF-6,changing TS 3.16 & 4.16 & Bases for Unit 1 & TS 3/4.7.8 & Bases for Unit 2 to Incorporate Changes in Generic Ltr 90-09, Alternative Requirements for Snubber Insp Intervals.. ML20085G608
References
NUDOCS 9110250135
Download: ML20085G608 (17)

Text

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- -.. 4 4.16,1 SNUllBER Yl8UAl. INSI'ECTION INTERVAL, 110g-2 5.18.1 UI'PER TUltE Si!EET VIEW OF SPECI A1 GkOUPS M'.R SPECirlCATION 11002 l

4.18.3.n.3 5.1-1 HAX1HVH AREA B00NDAl,'Y TOR RADIOACTIVE kEl. EASE CA1,CUI.ATION 111a (EXCLUSION AREA) 6.2-1 HANA C LENT ORf1ANIZAT10N CllART 119 i

6.2-2 FUNCTIONAL. ORGANIZATION FOR Pl. ANT Ol'ERATIONS 120 i

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. Amendment. No ff,,1/, 92 v1

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3;16 Shock Surnfuanta_Lhinkband Arn1 Rah 11112 i

This technical specificat.lon applies to n11 shock suppressorr (snubbers).

The only snubbirs excluded from this requirement are those installed on nonnafety-reinted systems and then only if their failure or influre of the system on which they are inntalled, would havo no advorno of fect on any safetyarclated system.

Ohlentito-To nanure ndnaunt o v. hock supprnanion protection for primary coolant nyntem piping and any other safety related system or component under dynamic londs nn might occur during an ontthquako or severo t ransient, while allowing normal e.hermal trotion during startup and shutdown.

This in done by assuring tho operability of thoso shock supprennors installnd for that purpose.

EgecificatiDll 3.16.1 Vf th one or n.orn applicable snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> olthers n.

Replace or restora the inoperable nnubbers to an OPERAlthE status and I.orform an engincoring evnluation of the attachnd comi.onents por Specification 4.16.1.f or, b.

. perform a revisw and evaluation which justifica continued operation with the inoperablo nnubber(s) and perform an engincoring evah.ntion of the attached component (s) per Speci fication 4.1t?.1. f or,

c.

Declaro the attached system inoperable and follow the approprinto ACTION statement for that system.

Raica Shock suppressors are designed to prevent unrestrained pipo motion undnr-dynamic loads as might occur during an certhquake or severo transient, while allowing normal thermal' motion durfog startup and shutdown.

The consequence of an inoperable shock suppreseor in an increnso in the prohnbility of structural damngo to piping us a result of a snismic or other event initinting dynamic loads.

It is thornfore required that all shock suppressors required to protect the primary coolant r.yntem or any other saf 'y system or component be operabin during tenctor operation.

11ecause the shock suppressor protection is required ordy during low probability events, a period'of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is nilowed for inpnirs, repincements or evaluations.

If a revelw and ovaluation of an INOPERAlli.E anutber is preformnd and documented to justify continued operation, and provided all design criterin ero met with thn IN0pERAllLE snubber, then the IN0pERAliLE snubber would not need to be restored or repinced.

In caso a shutdown in required, the allowance of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to reach a cold shutdown condition will permit an orderly shutdown consistent with standard operating procedures.

Amendment No. 13,.M JPP 661

4.16 Sil0CK SUITRESSORS (Snubbers)

Armlicohiilix This technical specificatfon oppilen to all shock suppressors (snuhbors).

The only snubborn excluded from thin requit ement aro thono installed on nonsafety-related syntems and then only if their failure or f ailure of the system on'which they are installed would have no adverse effnet on any safety-tolated system.

Okientivs Varify an acceptable levnl of opornbility of thn shock supptessors protecting the primary syst em and any other safety-rotated nyntem or l

component.

3D20.111LA11011

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- 4.16.1

- The following surveillanco requirements apply to all applicablo i

shock suppressors.

A.

Irmpaction Typn An unod in thin speelfication type of r,nubbor ohnll mean snubbers of the samn design and manufacturer, irrespective of capacity.

.Yian1_1mncs11gn b.

I Snubbers may be categorir.ed an innecnnnihin or acconsiblo during reactor operation, l'ach of these categorien (inaccessiblo and accessiblo) may bn innpocted independently acco: ding to the schedulo determined by Tabic 4.16-1.

.Thu vinnal inspection futorval for each category of snubber shnll be determined based upon the critoria provided in Table.

l 4.16.1.

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YlutG L inapaction AccePR Dco Criteria f

Visual inapections shall verify (1) that thete are no vinible Indications of damago or impaired operability, and (2) attachments to the foundat lon or support.ing structure ato functional and (3) fastners for the attachment of the snubber to 'the componout and to the snubber anchorago are functional.

Snubbers which appear inoperable an a result of visual inspections shall be clansiflod.as INOPERABbE and may be reclassified OPERABLE for the purpose of ontablishing the next visual inspect ton interval, providing that (1) the enuno of the rejsetion is clearly entablished and remedied for that particular anubber and-for other snubbors that may be generically susetptiblo; and (2) the affected anubber in i

functionally tested in the as found condition 'and determined operable per Specifications 4.16.1.d or 4.16.1.e, as applic ulo.

Ilowever, when the fluid port of a hydraulle snubber.is.found to be uncovered, the anubbor shall be determined inoperable and cannot be dotormined operablo via functional tonting for the purpose of establishing the next visual innpection interval.

All anubborn connected to a common hydraulic fluid reservoir shall be evalun'.ed for operability if any unubbar connected to that reservoir is datormined to bo inoperable.

i d.

Euntt.lunaLhnin At least onco each refueling shutdown a representativo samplo of snubbera shall be testod using, the following namplo plan.

At least 107. of the snubbora required by Specification 3.16.1 shall-be functionally tented either in place or in a bench i

test.- for each snubber that does not moot. the functional tent acceptanco criteria of Specification 4,16.1.0, an additional 107. of the snubbors shall be it.:mtionally tented until no more failuron are found or untfl-all nnubborn havn been functionally tented.

l The representativo namples for the functional tent nample.

rinns shall be randomly nelectod'from the snubbers required by Specification 3.16.1 and reviewed before beginning the testing.

The review shall ensure as far as practical that 3

thoy are representat tvo of tho_ various configurations, operating environments, rango of sizen, and capacities.

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Snubbers placed in the name locationn an snubbers which failed the previous-functional tent shall be rotested at. the time of the next functional test but shall not be included in tho-sample plan.

If during the functional testing, additional i

sampling in required due to failure of only ono type of anubber, the functional testing results shall be reviewed at _

that timo to determino if additional sampics should be limited to the type of snubber which han failed _ the functional testing.

Amendment No. O, M 110f

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Tunt11nnal Ic1LAcccin ance_ Criteria Tho snubber functionni test shall verify that:

1)

Activation (ic8 training act ion) 18 ochinved within t b specified rnnge in bot h t ension rnd compiession, except that inert in dependent, accolernt ion limit ing mechnnical snubborn may be tested to verify only that activation takes pince in both directions of travel; 2)

Snubber blee:1, or release rate where required. is prescat in both tension and comprension, within the speelfled range; 3) k'hnre required, the fotco required to initinte or maintnin motion of the snubber is within the specified innge in both direction of t ravel; and 4) for snubbers specifically required not to displace umler continuous lond, the ability of the snubber to withstand lond without dispincement.

Testing methodr. mny be used to mensurn pnramntern indirectly or parameters other thnn those specified if thasu results can bn corroint ed to the specified paramet ers through established

methods, f.

Enuttloul_IcAlln11 urn _Analy11a An ovaluntion shall bn mndo of each f ailure to n. net thn functionni test acceptanen criterin to determine the carso of the failurn.

The resultc of this evaluntion shnll bn used. If npplienble, in selecting snubbers to be tested in an effort to determinn the operability of othnr snubbers irrnspective of typa which may bn subject to thn same f ailurn mode.

For the snubborn found inoperable, an engineering evaluntion shall be performed on the components to whl:h the inoperable sinne ers are attached.

The purposn of thin enginenring evaluntion shall bn to determine if the components to which tnn inoperable snubbers are attached were ndversely nf fccted by the inopernbility of the snubbers in order to ensure that the component remnins capable of meeting the designed servico.

If any snubber selected for functionni testing citi:cr infle to activate or f ails to move, i.e.,

frozen-in-place, ths cause will be evalunted nud, if caused by manufacturer or Amendment No. U, 84 llog

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t design dof felency, all anubbers of the same typo subject to the same defect shall be ovaluated in a manner to ensure their

. operability. This testing requirement shall be independent of t

the requirements stated in Specification 4.16.1.d for anubborn

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not mooting the functional tent acceptance critoria.

8 l'rcaervico_Istilag,sLReaired. Replftctment and NryJnybhg.n prosorvice operability testing shall bo performed on repaired, 4

replacement or now snubborn prior to installation. Tonting may

. bo at tho manuf acturor's facility.

The tonting shall verify the functional test acceptance critoria in Specification 4.16.1.o.

In addition, a preservice innpection shall be performed on cach repaired. replacement or now anubber and shall verify thatt i

1)

.There are no visiblo signs of damage or impatrod opornbility an a ronuit of storago, handling or l

Juntallation; E

2)

The snubber lond rating, location, orientation, position setting and configuration (attachments, extennions, etc.), are in accordance with domign; t

3)

Adoquate swing clearanco in provided to allow anubber i

movement 4)

If applicable, (Inid is at the recommended loval and fluid is not Icaing f rom the anubber syntom; 5)

Structural connections such an pins, bearings, studn, fastenors and other connecting hardware such as lock.

nuts, tabs, wire and cotter pina are installed correctly.

h.

Snubber SettLReplancannt Procum The seal nervico life of hydraulic anuhborn shall be monitored to ensure that the servico life is not exceeded between i

surveil >ance innpoetions. The expected nervice lifo for the various seals, seal materials, and applications shall bo determined and established basod on engincoring information and the seals shall be replaced so thst the expected nervice life will not be excendod-during a period when the nnubber in required to be operable. The seal replacements shall be documented and the documentation shall be retained in.

accordance with Specification 6.9.2.

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Amendment 4.o. 84 110g-1

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IAlitt 4 <16.1

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Hi!MR_.Y15UAL 1NElEI1()N INInVA1, t

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NUMilER OF INOPERAlliI SNUllitERS l

Population Column A

. Column 11 Column L por Category Extend Interval Repent intnryn!

koduco Interval (Noten 1 and 2)

(Notes 3 nar' 6)

(Noten 4 and 6)

(Noton 5 and 6) a

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1 0

0 1

80 0

0 2

l 100 0

1 4

t 150 0

3 8

200

'2 5

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300 5

12 l 400 8

18 36 9

500 12 24 4H 750 20 40 78

-100(.or giontor 29-56 109 i

Note 1: The next visual inspection interval for n nnubber category shall be determined based upon the previous innpoet.fon interval nid t he tiumber of INOPT.RABlI nnubbers found during that interval.

L Snubborn may bn categorized. based upon their accensibility during l

pawer operation, an acconnible in inacconsible. Those categorien may bol examined separatoly or jointly.- llowever, cat egor.t on must -

l be dator.nined and documented befoto any innpectton and that determination ahn11 ba the banin upon which to dotormino the next inapection-interval for that entegory.-

Notof2: Interpolation botwoon population per category and the number of-INOPERAllLE anubborn As permissible..Uso next lower integer for the valuo of the limit for Columun A,1), and C if that irteger includes a fractional value of INOPERAllLE anubbora nn datormined t

by.interpolatlon.

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IA111Lb.16-1 (Entitittudl liEMElLX1EliL 1NSIKIl0!LiliTRYAL Noto 3: If the number of IN0pERABLE nnutd>cra in equal to or loan than the numbos in Column A, the next inspection interval may bn twice tho previous interval but not greater than 48 months.

Note 4: If thn number of IN0pERAlliE anubborn is equal to or lean than tha j

number in Column 11 but greater thnn the number in Column A, thn i

next inspection interval shall bo the namn as thn previous i

interval.

l Noto $1-If the number of INOPERAlli.E anubborn in equal to or greator than j

the numbnr in Column C, the next inspection interval ahnll bn two-thirds of thn prnvious interval, llowever, if the number of INOPERAtti,E anubborn-in lean than thn number in Column C but I;rcater-than the number in Column 11, the next. Interval shall bn i

reduced proportionally by-interpolation, that in, the previoun I

Interval shall be reduced by a factor that is one-third of the ratto of the dif ferenen between the number of IN0pERAblE nnubborn fourm during thn previous interval and the number in Column 11 to

{

. the dif f crenco in the numborn in Column 11 and C.

4

.Notn 6: Specified survoillanco intervalm may be adjuntod plus or minun 25 parennt to accommodate normal t ent and survoillance ncheduto intervatn up to and including 48 monthn, with the exceptJon that inspnction-of inaccessible snubborn may be deferred to the next

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shutdown when plant conditions allow five dayn for inspection.

J Soo Noto'7 for definition of interval an applied to anubber visual i

Inspections. Thn provinfons of Specification 4 regard!ng surveillance intervnin are not applienble.

-l Note 7 Interval an defined for tho nihock suppressors (snubborn) visual inspection aurveillanen requirements ja the perf twl of tima i

-starting when tho unit went-into cold shutdown for refueling, and o

ending when thn unit goen into cold shutdown for its next acheduled refueling.

This period of tien is nominally connidored

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.to be an 18 month period, or a 24 month period based on the type of fuel being uned, linwover, the portod'of timo (interval) could

't be'nhurter on: longer dun to plant operating variablen such an fuel life and nporating performanco.

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MES All safety reinted snubbers arn required to be opeinble to ensure thnt ihn structural integrity of the renetor coolant system and all other safety rnlated systeun is maintnined during nnd following a seismic or other event initinting dynnmic londs.

Snubbers excluded fiom this inspection program are those installed on nonsafety reinted systems and then only if their failurn, or failure of the system on which they are installed, would bnvo no adverso ef fect on any snfet y related syst em.

The visual inspection frequency is based upon maintaining a constant level of snubber protection to plant systems. Therefore, the required inspection int erynl varies based upon the number of INOPERAllLE snubbers found during the previous inspection in proportion to thn sir.cn of the various snubber populations or categories and the previous inspection inintynl as specified in NRC Generic Letter 90-09, "Alteruntive Recluirements For Snubber Visuni inspect inn Intnrvnis and Corrective

/

Actions".

Inspoctions performed before ihnt intetynl has einpsed may be used as a new reference point to determino thn next inspection.

Iloweve r,

the result of such early inspect ions per formed before the original required time intetynl has einpsed (nominni timo less 25?.) may not be used to lengthen the required inspection interval. Any inspection whose results requien a shorter inspnction interval will overrhic the previous schedule.

When the enuso of thn reject 'on of a snubber is ciently established and remedied for thnt snubbnr and for any other snubbnrs that mny be generically susceptibin, und veriffed by inservice functlonal testing, that snubber may be exempted f rom being counted as inopernble.

Generienlly susceptible snubbnts are those which are of a specific makn or model and havn the snmo design features directly related to reject ion of the snubber by visuni inspection, or are similarly located or exposed to the snmo environmental conditions such as tch ernturn, indintion and vibration.

When a snubber is found inopernble, an engineering evaluntion is performed, in addition to the determinnt.lon of the snubber modo of failurn, in ordnr to determinn if any snicty rninted component or system has been adyntsely offected by inoperability of the snubbnr.

The engineering evaluation is performed to determinn whether or not thn snubber mode of failure has imparted t. significant effect or degradn' lon on thn supported component or system.

1 If a review and evaluation of nu INol'ERABl.E snubber in performed and documented to justify continued operation, and provi*ed that all design criterin nrn met with the INOPERAllLE snubber, then t he INOPERAh! E snubber would not need the be restored or replace 1.

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4 Amendment No. fA 110g-4

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PLANI _ SYSTEMS 3f 4. 7.8 Sil0CK SUPPRESSOR$ _ (SNtil01ERSJ L1RTINQ_HOMOLEDLQfLR4TlDF 3.7.8 All snubborn shall be OPERABbE.

The only snubbers excluded from this requirement are thosa inst.a.1. led on nonsafoty-related systems and then only if their falluto.or failuro of the system on which they are

. installed, would have no adverse offect on any safety-related sys. tem.

APEhlCAll1LIII: H0 DES 1, 2, 3 and 4.

H0 des 5 and 6 for snubbers located on systems required OPERABl.E in thoso MODES.

ACTION:

With one or more applicablo snubber inoperable. within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ofthor f

a.

Replace or restore the-inoperable snubber (s) to an OPERABbE atatus and perform an engineering evaluation of the attached component (s) por Specification 4.7.8.f or.

b.

-Perform a review and evaluation which justifies continued operation whh the inoperable anubber(s) and perform an engincoring 5. aluation of the attached component (s) por Specification 4.7.8.f or, c.

Declare the attached system inoperable and follow the approprinto ACTION statement for that system.

EURYIILLANCE EIqu1EDiEliTS 4.7.8 Each applicable snubber shall be demonstrated OPERABLE by y

performance of the following augmented inservico inspection program and the requirements of Specification 4.0.5.

a.

Jpspo.tfon Tvpag As used in this specification, type of snubl4r shall mean anubbers of the same design and manufacturer, irrespectivo of capacity.

b.

Visunl-Inspratjmjs Snubbors may be categorir.ed as inaccessible or accessible during react ar operation.

Each of those categories (inaccessible and accessiblo) me be inspected independently according to the schedulo datotained by Table 4.7.8-1.

The visual inspection I

interval for cach catngory of snubber shall be determined based upon the crit eria provided in Table 4.7.8-1.

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P ARKANSAS - UNIT 2 3/4 7-22 Amendment No. f/,//,JJ)l

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Y1A11tti inspaction_AnnutAnce.Ir11&Ila Visual inspections shall vnrity that (1) thoro are no visible indications of damagn or impaired OPERADlblTY, and (C 6ttachments to the f,iundation or supporting structuro dro functional and (3) inntners for the attachment of the snubber to the component and to the snubber anchorage are functional.

Snubbers which appen inoperable an a result of visual innpections shall bc :lunnified as INOPERAllbE and may bo reclassified OPERABbE for the purpose or outablishing the next visunt int.pection interval, providing that (1) thn cauno of the reject inn in cicarly established and remedied for that particular snubber and for othnr snubbers that may be generically nunceptibin; and (2) the affected snuV la functionally tomted in the as found condition and determined OPERABLE per Specifications 4.7.8.d or 4.7.8.c as applicable.

liowever, when the fluid port of a hydraulic anubber is f ound to be-uncovered, the anubber shall bo determined inoperabin and I

cannot. be dolormined OPERABLE via functional testing for tho purpono of catablishing thn next visual inspection interval.

All snubbers connected to a common hydraul-fluid reservoir shall be ovaluated for operability if any..ubber connected to that reservoir in determined to bo inoperable, d.

Faunhonal Testa At 1 cast once cach refueling shutdown a representat.ive sample of snubbers shall be tested using the following nample plan.

At least 10% of.Iho anubbers requirod by Specification 3.7.8 shall be functionally tested either in place or in bench test.

For each snubber that does not meet the functionni test acceptanco critoria of Specification 4.7.8.o, an ndditional 10%

of.the nnubbers shall be functionally tnsted until no more failures aro found or until all snubbora have been functionally tested.

Tho.representativo samples for tho functional test sample plans shall be randomly selected from the snubbers required by Specification 3.7.8 and reviewed beforo beginning the tonting.

The review shall casure as far as practical-that they are representative of the various configurations, operating environments, rango of sizes, and capacition.

Snubbers placed in the samo locations as snubbers which failed the previous functional test shall be retented at the f

. ARKANSAS - UNIT 2 3/4 7-23 Amendmerit No. (2

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NUMBER OF INOPERABLE SNUBBERS Population Column A Column B Column C per Category Extend Interval Repeat Interval Reduce Interval (Notes 1 and 2)

(Notes 3 and 6)

(Notem 4 and 6)

(Notes 5 and 6)

. --=

1 0

0 1

80 0

0 2

100 0

1 4

menner w r ee=ww 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 Nota 1: The next visual inspection fr.terval for a snubber category shall be determined based upon the previous inspection interval and the number of _ INOPERABLE snub %rs found during that intercal.

d, based upon their accessibility during Snubbare may be ~+cg-power operation, as c.

'bic in inaccessible. These categories mny be examined sera ratet or jointly, llowever, categories must be determined and dt.umented before any inspection and that deternination shall be the basis upon which to determine the next inspection interval for t hat category.

Note 2: Int cpolatici, between population per category and the number of INOPERABLE snubbers la permissible, Use next lower integer for the value of the limit for Columns A, B, and C If t?at integer includes a f ractional value of INOPERABLE snubbers. determined by interpolatfor,.

ARKANSAS - UNIT 2 3/4 7-23a

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TABLE 4.7.8-l'(Continued)'

SNUBBER VIf;UAL-INSPECTION IRIERYAL Note 3: If the-number'of INOPERABLE anubbers is equal to or less than the f

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

r

-Note 4: If the number of 'IMOPERABLE snubbers is equal to or less than the number in Column D but greater than the number in Column A, the next inspection interval shall be the same as the previous futerval.

-Note 5: If the number of INOPERABLE. snubbers is equal to or greater than the nueber in Column C, the next inspection interval shall be two-thirds'of the previous interval. Ilowever, if the number of

_ INOPERABLE snubbers is less than the number in Column C but greater than'the number-in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the retto of 1.s difference between the number of-INOPERABLE anubbers found d*.ri'.g the previous interval and the number in Column B to the difference in the numbers in Column B and C.

Nor 6: Specified surveillance intervals may be adjusted plus or minus 25 percent to accommodat normal test-and surveillance schedule

.ntervals_up to and including 48 months, with the exception that ispection of inaccessible snubbers may' be defetred to the next tutdown when_planc-conditions allow five days.for inspection.

,e Note 7 for definition of interval as applied to snubber visual spections. The provisions of Specification 4 regarding

-urveillance intervals are not applicable.

Note 7: Interval as defined for the shock suppressors (snubbers) visual inepection-s veillance requirements is the period of time atarting when ohe unit went into cold shutdown for refueling, and conding when the unit _goes into cold shutdown for.its next--

scheduled refueling. This period of time is nominally considered-

-to be an 18_ month period, orfa 24 month-period based on the type of fu'l being used, flowever, _ the period of time (interval) could e

be shorter or longer due to plant operating variables such_as fuel life and operating performance.

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.e PLANT SYSTEMS

BMLS following all credible accident conditions.

The OPERAdIblTY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or loss whole body, or its equivalent.

This 11mitation is consistent with the requirements of General Design Criteria 19 of Appendix "A",10 CFR 50.

3/4.7.8 S110CK SUPPRESSORS (SjiUBBERS)

All snubbers are required OPERAllLE to ensure that the structural

-integrity of the reactor 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 nonsafety-related systems and then-only if their failure or failure of the system on which they are installed 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 based upon the number of INOPERABLE snubbers found during the previous.inspectioniin proportion.to the sizes of the various snubber populations or categories and the previous inspection interval as specified in NRC Generic Letter 90-09 " Alternative Requirements For Snubber Visual

-Inspection intervals-and Corrective Actions",

inspnctions performed before that interval bas elapsed may be used as a new reference point to determine t

'the next-inspection, llowever, the result of such early inspections performed

.before the original required time interval has elapsed (nominal time loss

'25%) may not be used to lengthen the required inspection interval.

Any inspection whose results require a shorter inspection interval will overrido the previous schndule.

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

susceptible and verified-by inservice functional testing, that snuhbor may.be excapted from being counted an inoperable. Generically susceptible snubbers-are those which are of a specific make or model and have the same design

-features directly related to rejection of tho.onubber by visual inspection, or = are similarly located or exposed to the same environmental conditions such

as temperature, radiation and vibration, y

When-a snubber is.found inoperable, an engineering ovaluation is performed, in addition to the determinatice of the snubber mode of failure, in order to determine if any safety-related component or system has been adversely.affected by the Inoperability of the snubber. The engineering evaluation is performed to determine whether or not the snubber-me<la of failure has imparted a significant ef fect or degradation on the supported component or system.

If-a review and evaluation of an INOPERABLE snubber is performed and documented to justify continued operation and provided thet all design criteria are met with the INOPERABLE snubber, then the TNOPERABLE snubber would not need to be restored or replaund, ARKANSAS - UNIT 2 B 3/4 7-5 Amendment No. (4 o

s L$l ~

ptANT SYSTEMS BASES. -

To-provide 'iurther-assurance of. anubber reliabillt y, a representative sample of the. installed snubbers will be functionally tested during plant

. shutdowns-at 18 month intervals.

These tests will include stroking of t he snubbers'to verify proper piston movement, lock-up and biced.

Observed failures of_these sample snubbers will require functional test-ing of additional units. To minimize pornonnel exposures, snubbers installed in areas which have high radiation fields during shutdown or in especially 1

-difficult to remove locations may be exempted from these functional testing requirements provided tho OPERABib1TY of those anubbers was demonstrated during functional testing at nither the completion of their fabrication or'at a subsequent date, M 4.7.9 SEALED SOURCE CONTAdlHAT108

-The limitatfor on.<-- vable contamination for sources requiring leak testing, including alpha emit *ers, is based on 10 CFR 70.39(c) limits for plutonium...This ? imitation w2ll ensure that leakage from byproduct, sourco, and.special nuclear material s iurces will not exceed allowable intake values.

M17.10 FIRE SURRESSJON SYFJ125

.The OPERABILITY'of the fire suppression systems ensures that adequate.

fire suppression systems ca,inbility is available to confino and extinguish' fires occurring in any portion of the facility where safety-related equipment

(

is located. - The fire suppression system consists of the water system, spray and/or sprinklera, and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety-reinted equipment and.is a major element in the facility-fire protection program.

In-the event the portions of the fire suppression systems are

' inoperable,_ alternate backup fire-fighting equipment is required to be made available in the af fected areas until the inoperablo equipment is restorad to y

L service.

l..

.In the event the fire suppression water system becomos inopotable, L.

Immediate' corrective measures.must be taken since this system provides the i

.majnr fire suppression capability of the plant. The requirement. for a L

twenty-four hour report to the Commission provides for prompt evaluation of l

the acceptability of thn corrective measures to provide adequate flere suppression capability for the continued protection of tho nuclear plant.

L, n

.g ARKANSAS - UNIT 2 B 3/4 7-6

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