ML20094C252
| ML20094C252 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/27/1984 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20094C225 | List: |
| References | |
| JPN-84-51, NUDOCS 8408070428 | |
| Download: ML20094C252 (16) | |
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ATTACHMENT I TO JPN-84-51 PROPOSED TECHNICAL SPECIFICATION CHANGES RELATED TO SNUBBER SURVEILLANCE NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 o
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's JAFNPP LIST OF TABLES (CONT'D)
Table Title Page 3.6-1 Safety Related Shoci' Suppressors (Snubbers) 156b l Delete 4.6-1 Comparison of the James A. FitzPatrick Nuclear 157 Power Plant Inservice Inspection Program to ASME Inservice Inspection Code Requirements 3.7-1 Process Pipeline Penetrating Primary Containment 198 4.7-1 Minimum Test and Calibration Frequency for 210 Containment Monitoring Systems 4.7 Exception to Type C Tests 211 6.10-1
' Component Cyclic or Transient Limits 261 6.11-1 Protection Factors for Respirators 262 1
Amendment No. M, //
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1 JAFNPP LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.6 (cont'd)
-4.6 (cont'd) 3.6.I
' Shock Suppressors (Snubbers)-
4.6.I shock Suppressors (Snubbers)-
Applicability Applicability Applies to the operational status'of the
. Applies to the periodic testing shock suppressors (snubbers).
requirement for.the'shockLsuppressors (snubbers).
Objective Objective To assure the capability of the snubbers to:
To assure the operability of.the snubbers to perform their intended functions.
Prevent unrestrained pipe motion under dyr.amic loads as might occur Specification during an earthquake or severe o
transient, and Each snubber shall be demonstrated operable by performance of the following Allow normal thermal motion during augmented inservice inspection program.
startup and shutdown.
1.
Snubbers shall be visually inspected Specification in accordance with the following schedule:
1.
During all modes of operation except Cold Shutdown and Refueling, all
'No. Inoperable Snubbers Subsequent Visual snubbers which are required to per Inspection Period Inspection Period *#
protect the primary coolant system or any other safety related system 0
18 months j; 25%
or comporent shall be operable.
1 12 months j; 25%
During Cold Shutdown or Refueling 2
6 months j; 25%
mode of operation, only those 3,4 124 days j; 25%
snubbers shall be operable which are 5,6,7 62 days j; 25%
on systems that are required to be 8 or more 31 days
+ 25%
operable in these modes.
The inspection interval may not be 2.
With one or more snubbers extended more than one step at a time.
inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during normal operation, or within 7 days Amendment No. S&'
145a
(I 7
JAFNPP 3.6 (cont'd)-
4.6 (cont'd)~
during Cold Shutdown or Refueling The snubbers may be categorized into two mode of operation for systems which groups: Those accessible and those are' required to be operable'in these.
inaccessible during reactor operation.
modes, complete ' one of the following:
Each group may be inspected independently in accordance with the
-a. replace or restore the inoperable above schedule.
snubber (s) to operable. status.or, 2
Visual inspection shall verify (1)
- b. declare the supported system that there are no visible inoperable and follow the indications of damage or impaired appropriate limiting condition for OPERABILITY, (2) attachments to the operation statement for that system, foundation or supporting structure or, are secure, and (3) in those locations where snubber movements
- c. perform an engineering evaluation can be manually induced without to demonntrate the inoperable disconnecting the snubber, that the snubber is unnecessary to assure snubber has freedom of movement and operability of the system or to meet is not frozen up.
Snubbers which the design criteria of the system, appear inoperable as a result of and remove the snubber from the visual inspections may be determined system.
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 (2) the affected snebber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.6.I.6 or 4.6.I.7, as applicable. Hydraulic snubbers which have lost sufficient fluid to potentially cause uncovering of the fluid reservoir-to-snubber valve assembly port or bottoming of the e
Amendment No. 36" 145b
JAFNPP 4.6'(cont'd)
I fluid reservoir piston with the snubber in the fully extended position shall be functionally tested to determine operability.
- 3. ~ Once each operating cycle,10% of each type of snubbers shall be functionally testad for operability, either in place or in a bench test.
For each unit and subsequent unit that does not meet the requirements of 4.6.I.6 or 4.6.I.7, an additional 10% of that type of snubber shall be functionally tested until no more failures are found, or all units have been tested.
4.
The representative sample selected for' f unctionally testing shall include the various configurations, operating environments and the range of size and capacity of snubbers.
At least 25% of the snubbers in the representative sample shall include snubbers from the following three categories:
a.
The first snubber away from reactor vessel nozzle.
b.
Snubbers within 5 feet of heavy equipment (valve, pump, turbine, motor, etc.).
c.
Snubbers within 10 feet of the discharge from a safety relief valve.
Amendment No.
145c
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. 4'6 (cont'd)f In addition to:th'e regular. sample, 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 shall be
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retested. Test results'of these snubbers may not be. included for the re-sampling.
5.
If any snubber selected for
' functional testing either fails to lockup or fails to move,.i.e., is frozen in place, the cause will be evaluated and if due to manufacturer or design deficiency, snubbers of the same design subject to the same defect shall be functionally tested.
This testing. requirement shall be independent of the requirements stated above for snubbers not' meeting the' functional test acceptance criteria.
For the snubber (s)'found inoperable, an engineering evaluation shall be performed on the components which are supported by the snubber (s).
The purpose of this engineering evaluation shall be to determine if the components supported by the snubber (s) were adversely affected by 4
the inoperability of the snubber (s)
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in order to ensure that the supported component remains capable of meeting j
the designed service.
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l Amendment No.
145d l
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'JAFNPP i
-4.6-(cont'd) 6.
The hydraulic snubber functional test shall verify that:-
a.
Activation (restraining action) is achieved within-the'specified' range of velocity or acceleration in both tension and l c ompression.
- b. - Snubber bleed, or release rate, where required, is within the specified range in compression or tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.
7.
The mechanical snubber functional test shall verify thats a.
The force that initiates free movement of the snubber rod in either tension or compression is less than the specified maximum drag force. Drag force shall not have increased more than 50 % since the last functional
- test, b.
Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.
Amendment No.
145e
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c... Snubber release. rate,1where;
-required,'is within the specified range in compression
- or tension. For snubbers specifically required not to displace under continuous load,-
the ability of the snubber to withstand load without!.
displacement shall be verified.
8.
Snubber Service Life Monitoring A record of the service life of each snubber, whose failure could adversely affect'the primary coolant or other safety-related system, the date at which the designated service life commences, and the installation and maintenance records on which the designated service life is based shall be maintained as required by specification 6.10.B.13.
At -least once per operating cycle, the installation and maintenance records for each snubber, whose failure could adversely affect the primary coolant or other safety related system, 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 Amendment No.
145f l
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JAFMPP 4.G (cont'd)'-
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-shall'be. replaced or reconditioned ~
is.
, iso as tb~ extend its service life-
'beyond the date.of the next scheduled service life review. 'This reevaluation, replacessent or reconditioning shall be indicated in the records.
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i Amendment No.
145g i
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7 JAFNPP 3 A and 4m6 UASES (ContU) a period of 72 houra (fcr nrrmal operation) y at + 10 percent and + 15 percent of the or 7 days (for cold shutdown or refueling average speed for the above and below 80 mode of operation) is allowed for repairs or percent power cases, respectively. If the replacement of the snubber prior to taking reactor is operating on one pump, the loop any other action. Following the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (or select logic trips that pump before making 7 day) period, the supported system must be the loop selection.
declared inoperable and the Limiting Condition of Operation statement for the Requiring the disch-ge valve of the lower supported system followed or an engineering speed loop to remain closed until the speed evaluation shall be performed to demonstrate of the faster pump is below 50 percent of that (1) the inoperable snubber is its rated speed provides assurance when unnecessary to assure operability of the going from one to two pump operation that system or to meet the design criteria of the excessive vibration of the jet pump risers system and (2) remove the snubber from the will not occur.
system. A period of 7 days has been selected for repair or replacement of the I.
Shock Suppressors inoperable snubber during cold shutdown or refueling mode of operation because in these Snubbers are designed to prevent modes the relative probability of structural unrestrained pipe motion under dynamic loads damage to the piping systems would be lower as might occur during an earthquake or due to lower values of total stresses on the severe transient, while allowing normal piping systems.
In case a shutdown is thermal motion during startup and shutdown.
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 The consequences of an inoperable snubber is a cold shutdown condition will permit an an increase in the probability of structural orderly shutdown consistent with standard damage to piping as a result of a seismic or operating procedures.
other event initiating dynamic loads. It is therefore required that all snubbers The visual inspection frequency is based required to protect the primary coolant upon maintaining a constant level of snubber system or any other safety system or protection to systems. Therefore, the component be operable during reactor required inspection interval varies operation. Snubbers excluded from this inversely with the observed snubber failures inspection program are those installed on and is determined by the number of non-safety related syscens and then only if inoperable snubbers found during an their failure or failure of the system on inspection. Inspections performed before which they are installed would have no that interval has elapsed may be used as a adverse effect on any safety-related new reference point to determine the next system. Because the snubber protection is inspection. However, the results of such required only during low probability early inspection performed before the
- events, Amendment No.,26 156
'd JAFRIPP
.i 3.6 and 4.6 BASES (Cont'd) original required time interval has elapsed snubber functional reliability, a (nominal time less 25%) may not be used to representative sample of the installed. snubbers lengthen the req 2 ired inspection interval.
will be functionally tested during plant Any inspection whose results require a shutdowns for refueling. Selection of a shorter inspection interval will override representative sample of 10% of each type of the previous schedule. When the cause of saf(ty related snubbers provides a confidence the rejection of a snubber is clearly level within acceptable limits that these established and remedied for that snubber supports will be in an operable condition.
and for any other snubbers that may be Observed failures of these sample snubbers generically susceptible, and verified by shall require functional testing of additional inservice functional testing, that snubber units.
may be exempted from being counted as inoperable. Generically susceptible Hydraulic snubbers and mechanical snubbers may 4
snubbers are those which are of a specific each be treated as a different entity for the j
make or model that have the same design above surveillance programs.
l features directly related to rejection of j
the snubber by visual inspection, and are.
The service life of a snubber is evaluated similarly located or exposed to the same using manufacturer input and information and environmental conditions such as also through consideration of the installation temperature, radiation, and vibration. When and maintenance records (newly installed r
I a snubber is found inoperable, an snubber, seal replaced, spring replaced, in engineering evaluation is performed, in high radiation area, in high temperature area, addition to the determination of the snubber etc...).
The requirement to monitor the j
mode of failure, in order to determine if snubber service life is included to ensure that l
any safety-related component or system has the snubbers periodically undergo a performance j
been adversely affected by thc inoperability evaluation in view of their age and operating of the snubber. The engineering evaluation conditions. These records will provide shall determine whether or not the snubber statistical bases for future consideration of 1
mode of failure has imparted a significant snubber service life. The requirements for the j
effect or degradation on the supported maintenance of records and the snubber service component or system. To provide assurance of life review are not intended to affect plant operation, a
d Amendment No. [
156a
s (B) Tho following records shall be retained for the duration of the Facility Operating License:
1.
Records of any drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.
2.
Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.
3.
Records of facility radiation and contamination surveys.
4.
Records of radiation exposure for all individuals entering radiation control areas.
5.
Records of gaseous and liquid radioactive material released to the environs.
6.
Records of transient or operational cycles for those facility components identified in Table 6.10-1.
7.
Records of training and qualification for current members of the plant staff.
8.
Records of in-service inspections performed pursuant to these Technical Specifications.
9.
Records of Quality Assurance activities required by the Quality Assurance Manual.
- 10. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
- 12. Records for Environmental Qualification which are covered under the provisions of paragraph 6.15.
- 13. Records of the service life of all hydraulic and mechanical snubbers, whose failure could adversely affect any safety-related system, including the date at which the service life commences and associated installation and maintenance records as of the effective date of this ammendment.
6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared and Cdhered to for all plant operations.
These procedures shall be formulated to maintain radiation exposures received during operation and Eaintenance as far below the limits specified in 10 CFR 20 as practicab.ie.
The procedures shall include planning, preparation, and training tor operation and maintenance activities.
They shall also include exposure allocation, radiation and contamination control techniques, and final debriefing.
Amendment No. JY, JT Order dated October 24, 1980 255 m
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L ATTACHMENT II TO JPN-84-51 SAFETY EVALUATION
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RELATED TO SNUBBER SURVEILLANCE NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 t
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-Section I - Description of the Changes The-proposeo. changes to the Technical Specifications are shown in Attachment I.
Sections-3.6.I.1, 3.6.I.2 and sections 4.6.I.1, 4.~6.I.2 and 4.6.I.3 have been revised.
New sections 4.6.I.4,
'4.6.I'.S, 4.6.I.6, 4.6.I.7 and 4.6.I.8 have been added.
Bases in section 3.6 and 4.6, have been revised and expanded.
Sections
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-3.6.I.3,;3.6.I.4 and 3.6.I.5 and Table 3.6-1 have been deleted.
- These proposed changes result from the NRC letter dated November 20, 1980,' signed by Mr. Darrell G. Eisenhut, addressed to all power reactor licensees ~" Technical Specification Revisions for Snubber
. Surveillance" (Reference 5).
That letter requested licensees to
~
submit a license amendment application incorporating applicable portions of newly revised Standard Technical Specifications which were enclosed with the letter.
The Authority's initial submission of i
July.13,.1981-(Reference 1) is superceded by this submission to
. reflect additional changes'as per References 2, 3 and 4.
Reference 2 transmitted the NRC's review of Reference 1 with respect to the 1
Standard Technical Specifications.
The Authority's response to this
?.
.was provided to the NRC via Reference 4..
Generic letter 84-13,
" Technical Specification for Snubbers," dated May 3, 1984 provided an option to delete Table 3.6-1 from the Technical Specifications and s
this" change.has been1 incorporated in this submittal.
Section~II - Purpose of the Changes T
The purpose of the~ changes is to revise, update and expand the'JAF L
Technical Specifications to increase the operability and surveillance
- requirements for snubbers' This change should result in an improvement in the over all safety of the plant.
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.Section III - Impact of the Changes
.The proposed changes to the Technical Specifications do not change E
any system or subsystem and will not alter the conclusions of either 3
the FSAR or SER accident analysis.
The Authority considers that this L
proposed amendment can be classified as not likely.to involve
-significant hazards considerations since the change constitutes additional-limitations not presently included in-the Technical Specifications.
In particular, these new limitations will impose adoitional operability.and surveillance requirements.
This is clearly in-keeping with' example (ii) included in Federal Register, Vol.. 48 No. 67 dated April 6, 1983 page 14870, (Examples of Amendments that are Considered not Likely to Involve Significant 1 Hazards Consideration which states:
"A change that constitutes an additional limitation, restriction, or control not presently. included in the technical specifications: for example, a more stringent surveillance requirement.")
Section IV - Implementation of the Changes
'The proposed changes will not impact the Fire Protection Program at
-the JAF plant nor will the changes impact the environment.
The f!
increased testing of snubbers-will impact ALARA by increasing
.occupationalradiat{ondosesbyafactoroftwoormore.
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Section V - Conclusion The incorporation of these changes:
a) will not change the probability nor.the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety
-Analysis Report; b) will not increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report; c) will not reduce the margin of safety as defined in the Bases for any Technical Specification; d) does not constitute an unreviewed safety question; and, e)~ involves no.significant hazards considerations, as defined in 10 CFR 50.92.
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Section VI - References PASNY letter, J.
P. Bayne to T. A.
Ippolito, dated July 13, 1981
- 2. ' NRC letter, D. B. Vassallo to J. P.
Bayne, dated February 3, 1984 regarding Hydraulic and Mechanical Snubbers.
3.
NRC Generic Letter 84-13, " Technical Specification for snubbers,"
dated May 3, 1984.
1:
4.-
NYPA letter, J.
P. Bayne to D.
B. Vassallo (NRC), dated May 3, 1984 (JPN-84-27) regarding Hydraulic and Mechanical Snubbers.
-b.
NRC letter dated November 20, 1980 from Mr. D. G. Eisenhut to all power. reactor licensees,
Subject:
Technical Specification Revisions for Snubber Surveillance.
.6.
JAF FSAR
'7.
JAF SER g
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