ML20093J862

Proposed Tech Spec Changes,Requiring Snubbers to Be Operable in All Modes Except Cold Shutdown & Refueling & Allowing Removal of 4-inch Bypass Line Around Recirculation Pump Discharge Valve

ML20093J862
Person / Time
Site:	Cooper
Issue date:	10/05/1984
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20093J851	List: ML20093J862 NLS8400251, Application to Amend License DPR-46,changing Tech Specs to Incorporate Mods to Snubbers & 4-inch Recirculation Bypass Lines.Fee Paid
References
NUDOCS 8410170061
Download: ML20093J862 (11)

Text

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Revised Technical Specifications for.

Snubbers (Generic' Letter 84-13) 4 Revised Pages: 137a 137b' 137c: 137d 137e~ 138-145' ^ 229:

(Deletion of Pages 137f through 137m)-

Nebraska Public JPower District requests _ a revision - to n the Technical' Specifications to incorporate changes' made possible ' under the' provisions of .a Generic Letter 84-13.

Evaluation'of this Revision with Respect to 10CFR50.92 A. 'The enclosed Technical Specification change' is_ judged to involve no significant hazards based on the-following:-

-1. .Does the-propose'd license amendment involve'a significant increase

~in the probability or consequences of an accident previously evaluated? ,

Evaluation:

No, because the recordkeeping requirements of the Technical Specifications are not altered by this request. Mditionally, any-changes to snubber quantities, types, or locations would be subject to 10CFR50.59 requirements.

2. Does the proposed license amendment create che possibility for a new or different kind of accident from any accident previously evaluated?

Evaluation:

It does not-increase the possibility for a new or different kind of accident because this change only deletes the tabular listing of -

snubbers and does not change the intent of the Technical

, Specifications.

3. Does the proposed amendment involve a significant reduction-in a margin of safety?

Evaluation:

Margin of safety will not be reduced because this change still.

imposes the recordkeeping requirements for snubbers and because any changes to snubber location, type, or quantity would still be reportable under 10CFR50.59.

l B.. Additional basis for proposed no significant hazards consideration ll determination: I

, The Connaission has provided guidance-in the form of Generic Letter 84 [ which specified the guidelines for deletion of the snubber listings in l the Technical Specifications. This request is consistent with those guidelines.

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LIMITING' CONDITION'FOR-OPERATION- -SURVEILLANCE REQUIREMENT 73.6.H = Shock Suppressors?(Snubbers) 4.6.H' Shock Suppressors (Snubbers)

1. .All safety-related' snubbers' The following surveillance require-shall be. operable in all modes ments apply tocall'anubbers as noted

'of operation except Cold Shut- in 3.6.H.1.

fdown and. Refuel.L The'only snubbers = excluded from'this 1. All snubbers shall be visually requirement are those in-- '

inspected-in'accordance'with-ses11ed on nonsafety-related the following scheduler systems and thenfonly if their ~

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Number of Snubbers Next Required

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failure would have no' adverse effect on any safety-related _Found-Inoperable Inspection system. .During Inspection- -Interval; or During Inspection

.l '2. With one or more' snubbers'in- Interval operable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> re-place or restore the inoper- 0 -

18 months j; 25%

able snubber (s) to 0PERABLE 1 12 months j;25%

status and perform an engi- 2 6 months j; 25% -

nearing evaluation per- 3, 4 124= days f; 25%

l' Specification 4.6.H.4.d on- 5,6,7 62 days + 25%

the supported component or 8 or more . 31 days + 25%

" declare the supported system or subsystem inoperable and follow The required inspection interval:

the appropriate' ACTION state- shall not be lengthened more ment for that system.- than one step at a time.

l- 3. If a snubber is determined to be Snubbers may be categorized in inoperable while the reactor is groups, " accessible" or."inac-in the shutdown or refuel mode, cessible" based on their acces-the snubber shall be made oper- -sibility forfinspection during able or replaced prior to reactor reactor operation and by' type, startup, hydraulic or mechanical. These four groups may be inspected independently according to the above schedule.

2. Visual Inspection Acceptance Criteria Visual inspections shall verify y (1) that there are no visible indications of damage or impair-ed OPERABILITY, (2) attachments to the foundation or supporting 3

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LIMITING CONDITION-FOR UPERATION' SURVEILLANCE REQUIREMENT 4.6.H ' Shock Suppressors'(Snubbers)-

. (cont'd).

- <3 structure are secure. Snubbers

~which appear inoperable as a

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result of" visual inspections may be determined OPERABLE for the. purpose of establishing the next visualminspection interval,'

providing that (1) the cause of '

the rejection is clearly estab--

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. . lished and remedied for that particular snubber and for 'other -

snubbors that may be. generically-

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. susceptible; or-(2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifi-cations 4.6.H.5-or 4.6.H.6 as l

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applicable.~ . However, when the .

, -r ' fluid port of a hydraulic snubber

! is found to'be uncovered,~the snubber shall be determined in-operable and cannot be determined OPERABLE via' functional testing.

for the purpose of establishing the nextivisual inspection-inter-i val. All snubbers' connected to-an inoperable common hydraulic fluid reservoir shall be counted >

as inoperable snubbers.

l 3. At least once per 18 months dur-ing shutdown, a representative sample, 10% of the total of 2 each type of snubber 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 func-tional test acceptance criteria i of Specification 4.6.H.S or 4.6.H.6, an additional 10% of that' l type of snubber shall be' function-

! ally tested. 1

4. The representative sample select-i- ed for functional testing shall include various configuration, operating environments and the i range of size and capacity of snubbers. l 1-

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 4.6.H Shock Suppressors-(Snubbers) l (cont'd)-

a. In addition to the regular sam- l ple, snubbers which failed the previous functional test shall be retested during the next test period. If a spare snubber has been installed in place of a failed snubber, then both the failed snubber (if it is repaired

. and installed in another' position) ~

and the spare snubber ahall be' ~

retested. Test results of these snubbers may not be included for the resampling.

b. Permanent or other exemptions l from functional testing for individual snubbers, in high radiation zones or that are difficult to remove may be granted by the Commission only if a justifiable basis for exemptica is presented and/or snubber life destructive test-ing was performed to qualify snubber operability for all design conditions at either the completion of their fab-rication or at a subsequent date.

c. If any snubber selected for l functional testing either fails to lockup or fails to move, i.e.,

frozen in place, the cause will be evaluated and if caused by manufacturer or design deficiency all snubbers of the same design and subject to the same defect shall be tested or inspected to determine if the defect is pre-sent. This testing requirement shall be independent of the re-quirements stated above for snubbers not meeting the func-tional test acceptance criteria.

d. For the snubber (s) found inoper-l able, an engineering evaluation shall be performed to determine the need for further action or testing on affected components.

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LI'MITING CONDITION FOR OPERATION ' ~ SURVEILLANCE' REQUIREMENT l 4.6.H Shock Suppressors (Snubbers)

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, .( cont'd) l l

5.- Hydraulic Snubbers Functional Test Accentance Criteria The. hydraulic snubber functional test shall verify that:

1._ Activation (restraining act--

ion) is achieved within the specified range of velocity or acceleration in both tension and compression.

2. Snubber bleed, or release 4 rate, where required, is within the specified' range in compression or tension.-

6. Mechanical Snubbers Functional Test Acceptance Criteria The mechanical snubber fune-tional test shall verify that:

1. The force that initiates free movement of the snub-ber rod in either tension or compression is less than the specified maximum drag force.-

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2. Activation (restraining act-ion) is achieved within the specified range of velocity or acceleration in both tension and compression.

3. Snubber release rate, where i

required, is within the specified range in com-pression or tension.

7. Snubber Service Life Monitoring I

A record of the service life of each snubber as noted in 3.6.H.1, l the date at which the designated service life commences, and the l installation and maintenance records on which the designated service life is based shall be maintained as raquired by Specification 6.4.2.J. l

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LIMITING CONDITION FOR OPERATION "5NRVEILLANCE REQUIREMENT 4.6.H Shock Suppressors (Snubbers)

.(cont'd)

Concurrent with the first in-l service visual ~ inspection and at least once per 18 months thereafteri the installation-and maintenance records of. ~

each snubber noted in 3.6.H.1 -l' 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.

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6.4.2.G (cont'd)

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usageevaluationperthepSMEBoilerandPressureVesselCode Section III was performed for the conditions defined in the design

, specification! The locations to be monitored shall be:

a. The feedwater nozzles

b. The shel3 at or near the waterline

c. The flange studs

2. Mo'nitoring, Recording, Evaluating, and Reportit:g;

-I a. Operational transients that occur during plant operations will, at least annually, be reviewed and compared'to the transient conditions defined in,the component stress report for the locations listed in 1 above, and used as a basis for the existing fatigue analysis.

,b. The number of trancieucs,which are comparable to or more severe than the c:ensiants evaluated in the stress report Code fatigue usage calculations will be recorded in an operating log book.

For those transients which are more severe, available data, such da the metal and fluid temperatures, pressures, flow rates, and other conditions will be recorded in the log book,

c. The number of transient events that exceed the design specification quantity and the number of transient events with a severity greater than that included in the existing Code fatigue usage calculations shall lue added. When this sum exceeds the predicated number of design condition events by twenty-five2 , a fatigue usage evaluation of such events vill be performed for the affected portion of the RCPB.

H. Records of individual plant staff members showing qualifications, training and retraining.

I. Records for Environmental Qualification which are covered under the pro-visions of Specification 6.3.

J. Records of the service lives of all hydraulic and mechanical snubbers noted in 3.6.H.1, including the date at which the service life commences l and associated installation and maintenance records.

6.4.3 2 Year Retention Records and logs relating to the following items shall be kept for two years.

A. The test results, in units of microcuries, for leak tests of sources performed pursuant to Specification 3.8.A.

B. Records of annual physical inventories verifying accountability of the sources on record.

1. See paragraph N-415.2, ASME Section III, 1965 Edition.

2. The Code rules percit exclusion of twenty-five (25) stress cycles from secondary stress and fatigue usage evaluat1on. (See paragraphs N-412(t)(3) and N-417.10(f) of the Summer 1968 Addenda to ASME Section III, 1968 Edition.)

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- Attcche:nt 2-Revised Technical Specifications for Four-Inch-Recirculation Bypass Lines Revised Page:- 116

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Evaluation of this Revision with Respect'to 10CFR50.92

- A. The enclosed Technical Specification change is judged to involve no significan* hazards based on the following:-

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation:

-No,.,because the' recirculation pump discharge valve bypass lines and valves are not needed for recirculation system operation, as shown

. in the SAR, and are not specifically addressed in either the SRP _or STS. Additionally, it , has been shown in the past (RO

. Bulletin 74-10A and IEB 74-10B) that ' bypass line cracking was occurring in BWR's. As a result, when the District replaces the recirculation system piping (IGSCC replacement program) in the next outage, the new piping will not have bypass lines.

2. Does the proposed license amendment create the possibility for a new or different kind of accident - from any accident previously evaluated? .

P Evaluation:

No it will not because the recirculation pump discharge valve bypass lines and valves are not needed for recirculation system operation, as shown in the SAR, and are not specifically. addressed in either-the SRP or STS. Additionally, it has been shown in the past (RO Bulletin 74-10A and IEB 74-108) that bypass line cracking ~ was occurring in BWR's. As a result, when the District replaces th'e .

recirculation system piping (IGSCC replacement program) in the next outage, the new piping will not have bypass lines.

3. Does the proposed amendment involve a significant reduction in 'a margin of safety?

Evaluation:

Removal of the four-inch bypass line'around the recirculation pump discharge valve will not impact the margin of. safety on which the Technical: Specifications are based. The line was originally l

installed to' allow the plant operator to control haat-up of : the.

recirculation system discharge piping following a ' loop - shutdown.

'The conditions under~which the bypass line would-be used have:not occurred.co date and are unlikely to be encountered in the future.

Loop heat-up requirements can be met through alternative means which L

do not require the. bypass line and do not compromise the margin of safety.-

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B. . Additional basis for proposed no significant hazards i consideration determination:

The Commission provided guidance concerning application of its standards set forth in 10CFR50.92 for . no significant~ hazards' consideration by providing certain examples published in the Federal Register on April 6, 1983 (48FR14870). In reviewing those ' examples for . this request it was found that this request'does not clearly fall into the-scope of any of the examples provided.

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS'

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3.5.A (Cont'd.) 4.5.A. (Cont'd.)

5.. From and after the date that one 5. When it is determined that the LPCI LPCI subsystem is made or found to subsystem is inoperable, both core be inoperable for any reason, contin- spray subsystems, the containment ued reactor operation is permissible cooling subsystem and the diesel only during the succeeding 7 days, un- generators required for operation of less it is sooner made operable, pro- such components if no external source vided that during such.7 days all of power were available shall be active components of both core spray demonstrated to be operable immediately subsystems, the containment cooling and daily thereafter.

subsystems (including ? LPCI pumps) and the diesel generators required for operation of such components shall be operable.

6. All recirculation pump discharge 6. All recirculation pump discharge l va3ves shall be operable prior to valves shall be tested for oper- l reactor startup (or closed if ability during any period of permitted elsewhere in these Reactor cold shutdown exceeding i specifications). 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, if operability tests l have not been performed during-the preceding 31 days..

7. The reactor shall not be started {

up with the RHR system supplying j cooling to the fuel pool.

8. If the requirements of 3.5.A 1,2,3,4,5,6 or 7 cannot be met, an orderly shut-down of the reactor shall be initiated and the reactor shall be in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

B. Containment Cooling Subsystem B. Containment Cooling Subsystem (RHR (RHR Service Water) Service Water)

1. Except as specified in 3.5.B.2, 1. Containment Cooling Subsystem Testing 3.5.B.3, and 3.5.F.3 below both con- shall be as follows:

tainment cooling subsystems loops shall be operable whenever irradiated Item Frequency fuel is in the reactor vessel and reactor coolant temperature is great- a. Pump & Valve Once/3 months er than 212*F, and prior to reactor Operability startup from a Cold Condition.

b. Pump Capacity Test. After pump main-Each RER service tenance and every water booster pump 3 months shall deliver 4000 gPm.

c. Air test on dry- Once/5 years well and torus headers and t

nozzles.

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