ML20087L329

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Proposed Tech Spec Changes,Removing Details of Section XI Inservice Insp Program
ML20087L329
Person / Time
Site: Pilgrim
Issue date: 03/20/1984
From:
BOSTON EDISON CO.
To:
Shared Package
ML20087L149 List:
References
NUDOCS 8403270143
Download: ML20087L329 (10)


Text

{{#Wiki_filter:i 1.IRITING CONDITIONS FOR-OPERATION 5%RcEINLANCE REQUIRE *EmT

     3.6.D. Safety Relicf Valvss (Cont'd)             E. Jet Pumos from the initial discovery of dis-        Whenever there is recirculation charge pipe temperatures in excess        flow with the reactor irt the start-of 212*F for more than 24 hours           up or run modes, jet pume coer-without prior NRC approval of the         ability shall be checked daily by verifying that the following con-engineering evaluation delineated in 3.6.D.3.                               ditions do not occur simultaneously.
5. The limiting conditions of opera- 1. The two recirculation loo:s have tion for the instrumentation that a flow imbalance of 15t or more monitors tail pipe tem erature when the cumos are ocarated at are given in Table 3.2.F. the same speed.

E. Jet Pumos 2. The indicated value of core f b rate varies from the value

1. Whenever the reactor is in the derived from loco flow measure-startup or run modes, all jet ments by more than 10%.

pum:s shall be operable. If it is detennined that a jet pump is in- 3. The diffuser to lower pleaum operable, an orderly shutd:wn shall differential pressare reacing be initiated and the reactor shall on an individual jet pume varies be in a Cold Shutdown Condition from established jet pume P within 24 hours. characteristics by more tnan 10t. F. Jet Pum: riew Mismatch F. Jet Pum: Flow Wis at:h

1. Whenever both recirculation pum:s Recirculatien cumo sceeds shall be
               ' are in operation, pump speeds snail         checked and logged at least once be maintained within lot of eacn           per day.

other when power level is greater than 80% and within 15% of each other when cower level is less - than or equal to 80t. t 2. If Soecification 3.6.F.1 is ex-I caeded imediate corrective action shall be taken. If re-circulation pump speed mismatch is not corrected within 30 minutes, l an orderly shutdown shall be in-

itiated and the reactor shall be in the Cold Shutdown condition l within 24 hours unless the re-circulation pump speed mismatch is brougnt within limits soonee.

Structural Integrity G. Structural Intecrity G.

1. The structural integrity of the The nondestructive examinations primary system boundary shall be listed in the Inservice Inspection maintained at the level required Program shall be performed as by the ASME Boiler and Pressure specified. The results obtained Vessel Code, Section XI " Rules for f rom compliance with this program Inservice Inspection of Nuclear will be evaluated at the completion Power Plant Components", IWA, IWB, of the ten year interval and the IWC, IWD, IWF and mandatory /non- conclusions of this evaluation will mandatory appendices, 1980 be reviewed with the NRC.

l 127 Amendment No. C'403270143 840320 PDR ADOCK 05000293 P PDR

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.6.G. Structural Intearity (Cont'd) edition, Winter 1980 Addenda. Where the specific requirements of this edition

               -of ASME.Section XI cannot be compiled. Boston Edison Compary has requested specific code relief as detailed in the Inser vi;;

Inspection Program for the Second Ten Year Interval", which was submitted to the Nuclear Regulatory Commission. l l 127A Amendment No. w - w-- - - + - - ,w--- , e., ---, ,

~ SURVEII. LANCE REQUIREMENTS LIMITING CONDITIONS POR OPERATION 4.6.H High Energy Piping (outside

       .3.6.R High Energy Piping (outside                     containment) containment)

The inspections listed in Table

1. The high energy line sections 4.6.2 shall be performed as identified in Table 4.6.2 shall be specified to verify the structural ma'intained free of visually observable integrity of the specified high through-wall leaks. energy line sections. The If a leak is detected by the standards of Section XI of the ASME
2. Boiler and Pressure Vessel Code, surveillance program of 4.6.H. 1980 edition, Winter 1980 Addenda ef forts to identify the source Article IWB-3000 shall be used *.n of the leak shall be started these inspections.

immediately.

3. If the source of leakage cannot be identified within eight hours of detection or if the leak is found to be from a break in the sections identified in Table 9 4.6.2, the leak shall be isolated or the reactor shall be in a cold shutdown condition within 48 hours.
4. When the modifications, described
              -in FSAR Amend =ent No. 34, to provide protection against high energy line breaks outside of the primary containment have been completed, Technical Specifications 3.6.H and 4.6.H will no longer be required.

127B 19 Amendment No.

1' LIMITING CONDITION FOR OPERATION I SURVEILLANCE REQUIREMENT 4.6.1 Shock Supprassern (Snubbers)

      .3.6.1 Sh ek ,5,uppresscrs (Snubbars)                                                                                                            l
1. During all' modes of operation The following surveillance
                      'except Cold Shutdown and                                                             requirements apply to all hydraulic Refuel, all safety-related                                                           and mechanical snubbers listed in snubbers listed in ISI Program                                                       ISI Program and Table 3.6.I(b).          l and Table 3.6.I(b) shall be operable except as noted in                                                          The required visual inspec-3.6.1.2 through 3.6.1.3 below.

tion interval varies inverselv

                    .                                                                                       with the observed cumulative An Inoperable Snubber is a                                                            number of inoperable snubbers properly fabricated, installed                                                        found during an inspection.

and sized snubber which can. Inspections performed before that interval has elapsed not pass its functional test, may be used as a new reference Upon determination that a snubber point to determine the next is either improperly fabricated, inspection. However, the installed or sized, the correc- results of such enriv inspec-

tive action will be as specified tions performed before the for an inoperable snubber in original time interval has Section 3.6.I.2. elapsed may not be used to lengthen the required inter-
2. From and after the time that a val.

snubber is determined to be in-operable, replace or repair the Number of snubbers found in-

                      -snubber during the next 72 hours,                                                     operable during inspection or and initiate an engineering evalu-                                                   during inspection interval:

ation to determine if the com-ponents supported by the snubber (s) subsequent were adversely affected by the Inocerable visual Inspec-inoperability of the snubbers and snubbere tion Interval

                      .to ensure that the supported component remains capable of                                                         0               18 Fonths
  • 25'.'

meeting its intended function in 1 12 Months i 25%

                       -the specific-safety system in-                                                        2                6 Ponths      25%

volved. 3,4 124 Days t 25% 5,6,7 62 nays t 25% Further corrective action for this 8 or more 31 Davs snubber, and all generically sus.- ceptible snubbers, shall be The required inspection inter-determined by an engineering val shall not be lengthened evaluation more than one step at a time.

3. From and after the time a snubber snuhbers may be categorized is determined to be inoperable, in two groups, " accessible" improperly fabricated, improperly or " inaccessible" based on installed or improperly sized, if their accessibility for inspec-the requirements of Section(s) tion during reactor operation.

3.6.I.1 and 3.6.I.2 cannot be met. These two groups may be in-thc-n' the affected safety system, spected independently accord-or affected portions of that ing to the above sched'ule-system, shall be declared inoper-able, and the limiting condition 1. Visual Inspection Acceptance for that system entered, as criteria - appropriate. A. Visual inspections shall verifv:

    .            Amendment No.                                                                                                                 137a
          - ,                    _    _ _ . _ -      _ . _ ~ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _

SURVEILLANCE REQL' IRE.ENT LIMITING CONDITION FOR OPERATION

  • 4.6.1 Shock Suppressors (Snubbers)
1. That thera era no visible in-dications of damage or impaired
4. ' Snubbers may be added to, or operability.

removed f rom, per.10 CFR 50.59, 2. Attachments to the founda-

                 -safety-related systems without                 tion or support structure prior NRC approval.to the ISI                  are such that the func-program or Table 3.6.I(b).                     tional capability of the Revisions to Table 3.6.I(b)                    snubber is not suspect.

shall be included with.the next license amendment request. B. 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 provided that:

1. The cause of the rejection is clearly established and remedied for that particular snubber, and .
2. The affected snubber is functionally tested, when i

necessary, in the as found condition and determined OPERABLE per specifications 4.6 I.2.B. applicable.,4.6.I.2.C.,as

3. For any snubber determined inoperable pe- specifica-tion 4.6.I,.2, clearly establish the cause of re-jection and remedy the prob-lem for that snubber, and any generically susceptible snubber.

I

2. Functional Tests (Hydraulic _

and Mechanical Snubbers) A. Schedule l At least once per operating l: ' cycle (18 months), a representa-l

                      ;                                              tive sample (10% of the total l
                    .'                                               of each type: hydraulic, mechanical) af snubbers in use in the plant shall be functionally teste8, either 16 place or in a bench test.

For each snubber that does not meet the functional test

                                                                     ' acceptance criteria of

( 137b i Amendment No.

LIMITINGCONDITIONFOROPERATION SURVEILLA.NCE RIOL'IREMINT 4.6.1 Shsek suppressers (Snubbsrs) of each snubber, the date at which the designated service life commences and the instal-lation and maintenance records on which the designated service life is based shall be maintained.

. At least once per cycle, B.

the installation arid mainten.ance records for each snubber listed in the ISI Program and Table 3.6.I(b) shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber service life review. If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated, or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review. This reevaluation, replacement or reconditioning shall be indicated in the records. C. This Snubber Service Life ' Monitoring Program shall become effective July 1, 1982. l 137d Amendment No.

r-BASES: 3.6.c and 4.6.G-Structural Integrity A preservice inspection of accessible components, in what is now defined as class _1, was conducted before the initial fuel loading to assure the system is free of gross' defects and as a reference for future Inservice Inspections. The.ISI program has been developed based on IWA, IWB, IWC, and IWD - 2000 and tables IWB, IWC, IWD - 2500-1 of Section XI of the A.S.M.E Boiler and Pressure Vessel code 1980 edition, Winter 1980 Addenda, except where accessi-bility for inspection was not_provided and when it was impractical to modify the original design. Due to the age of the Pilgrim Nuclear Power Station, Boston Edison Company has elected to select category J circumferential pipe welds for examination in the class 1 and class 2 systems in accordance

                        ~
               . with the 1974 edition, Summer 1975 Addenda of A.S.M.E. Section XI.

The biological shielding surrounding the vessel was modified during construc-tion to allow for access to specific reactor pressure vessel and nozzle welds. The access requirements for inspection was predicated on codes approved in 1970 and 1971 which are not as restrictive as the 1980 edition. The inspection program and the modifications described above were developed by the Boston Edison Company with assistance from its contractors. The services of Southwest Research Institute were retained to provide advice on practical- l

                 ~ modifications-to existing designs for improved inspectability and to perform the preservice inspection. It is not possible, however, to make all changes 4

that might be desired to insure literal compliance with all areas of the current inspection code. The areas of exclusion and reasons for this exclusion are discussed below. l Category B-A Accessibility has been provided to perform the required examinations as g I stated in Inservice Inspection Program of selected lengths only of these welds. The shielding and insulation designs were modified to permit access

                  'to these ' areas and minimize this testing program-and has and will continue to_make every reasonable effort to comply. Although it is believed the flexibility provided by the design will permit the inspections to be performed with_ presently available equipment, if experience reveals these examinations to be impractical because of high radiation exposure to personnel, an evaluation will be submitted to the NRC for approval of any variance from the specified program. _It-is the intent of the Boston Edison Company to continue with its consultants to develop examination techniques to lessen the radiation exposure to personnel during the examinations.

149

                  ~ Amendment No.

r, BASES: 3.6.G and'4.6.G Structural Integrity Category B-B In addition to the exclusion bases stated for Category A welds, at the present

        . time there is no practical way to vo lumetrically inspect welds in the bottom head because of the combination of insulation and control rod and in-core monitor housings configuration on the outside of the' vessel and jet pumps and core shroud on the inside of the vessel.

Category B-D In addition to the exclusion bases stated for Category A welds, definitive volumetric examination by ultrasonic methods from external locations on nozzle internal radii is expected to be limited to ten percent of its perimeter (those portions of the nozzle inner radius lying perpendicular to the reactor vessel centerline). However, these are believed to be the most highly stressed

        -areas on the nozzle inner radii. Modifications were made to the shielding and insulation designs around the nozzles with the intent to permit the inspec-tions to be performed with minimal radiation exposure to personnel using presently available equipment.

It it the intent of the Boston Edison Company to continue with its consultants in the development and implementation, if practicable, of new techniques so as to include any excluded. areas within the inspection program. Category B-E At the present time there is no practical way to volumetrically or visually inspect the bottom head penetrations or drain nozzle weld because of the combination of insulation and control rod and in-core monitor housings con-figuration. Also, the design of core differential pressure and shell instrumentation nozzles is such that present day volumetric inspection tech-niques are not practical to utilize. The combination of hydrostatic test and visual checks to be performed do provide reasonable assurance these examination areas are free of gross defects. Category B-L-2 . It is the intent that no internal examination te performed on the recirculation pumps.unless they are disassembled for maintenance because of the high personnel radiation exposures which would be involved. Category B-M-2 , There are several valves in the primary pressure boundary which cannot be inspected unless the reactor fuel is removed and reactor water level lowered to the level of the entrance to the jet pump mixer assembly resulting in high personnel radiation exposures from the loss of shielding from the water. Therefore,'those valves which would require the reactor water levelare to be lowered below the low-low water level protection system trip point excluded from the requirement of visual inspection of internals. 150 Amendment No.

7-4: ' i g BASES: 3.6.G and 4.6.G a. Structural Integrity (Cont'd)~ Th'e more frequent inspections delineated for the Category J. Group I pipe

                 ~

welds is to provide additional conservatism in the overall approach of-protection against pipe whip which has the potential to breach the contain-

      - ment. .A pipe whip protection system is being installed consisting _of steel members attached to a reinforcing plate and located such that the postulated
      . pipe weld faulure will not breach the containment. Additional inspection of critical welds is also included in the inservice inspection program.

The Group I welds listed are those pipe welds of interest. t 3.6.H and 4.6.H

       -High Energy Piping Outside of Containment Analyses performed and submitted to the AEC as Pilgrim Nuclear Power Station, Unit #1, FSAR Amendment #34 indicate that certain modifications to the station would increase the protection against the potential effects of postulated high encrgy piping failures outside the primary containment.

In order to provide greater assurance that the integrity of the high energy piping outside the primary containment is maintained at an acceptable level in the interim until these modifications can be completed, an increase in the frequency of inspections of the areas of concern will be initiated. The monthly visual inspection of high energy piping outside the containment while the station is operating will provide greater assurance of the timely detection of postulated piping failures and allow appropriate corrective action to be performed. Reference to Article IWB 3000 of the 1974 ASME Boiler and Pressure Vessel Code ensures that-appropriate in-service visual examination techniques and-evaluations are used to implement the requirements of Tech-nical Specification Table 4.6.2. These in-service visual examinations will normally be made with the. indicated piping and insulation in its operating

condition. Subsequent to the completion of the modifications, the original in-service inspection _ requirements defined in Section 4.6.G of these Tech-nical Specifications will provide adequate inspections to allow timely detection of postulated failures.

w,: 151

       . Amendment No.

3,** ../ - y

                          . J.

E

             ? BASES ~

m  : 3.6~. I & 4.6. I: SHOCK SUPPRESSORS (SNNBBERS) Snubners'are' designed to prevent unrestrained pipe motion under dynamic loads f

ss might occur during an earthquake or severe transient, while allowing normal thermal motion'during startup and shutdown. The ccnsequence or an inoperable snubber is an increase in the: probability. of structural damage to piping as a result of-a seismic or other event initiating dynamic loads. It is therefore required that:all snubbers required to protect the primary coolant system and fall other safety related systems or components be operable during reactor.

operation. The visual inspection frequency ~is based on the. requirements of ASME, Section XI, ble snubbers 11980 Edition,' Winter Addenda. The cumulative number of inopera detected during.any inspection interval is the basis for establishment of the subsequent-inspection interval and the existing inspection interval should remain in effect until-its completion. When the cause of the rejection of a snubber is clearly established and remedied for'that' snubber and. verified by inservice functional testing, that snubber may

  -             ' be exempted ' f rom being counted as 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 the i

       '         . snubber by visual-inspection,-and are exposed to the same environmental condit ons
 *               'such as temperature, radiation,'and vibration.

When a snubber is found inoperable, an engineering evaluation is initiated, d Lin addition to.the determination of the snubber mode of failure, in or er to determine if any-safety-related component or system has been adversely affected Initiating this evaluation within 72 uby the inoperability of-the snubber. hours ensures that prompt corrective action will be afforded. Hydraulic snubbers and mechanical snubbers may each be treated as a different

                  . entity for the'above surveillance programs.

The service life of a snubber is evaluated via manufacturer input and informa-tion through consideration of the snubber service conditions and associated l installations and maintenance. records (newly installed snubber, seal replaced, spring-replaced, in high radiation area, in high temperature area, etc...). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically. undergo a performance evaluation in view of their These records will provide statistical bases age'and operating conditions. The requirements for the for future consideration of snubber service life. maintenance of records and the snubber service life review are not intende to affect plant operation. Due to.the number and complexity of the relevant

    '                 interacting factors necessary to develop a comprehensive Service Life Program,
                    .this program shall become effective' July 1, 1982.

151a Amendment;No. =}}