ML20095G182

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Amend 73 to License NPF-38,revising TS by Modifying Snubber Surveillance Requirements for Facility
ML20095G182
Person / Time
Site: Waterford 
Issue date: 04/17/1992
From: Larkins J
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20095G187 List:
References
NUDOCS 9204280437
Download: ML20095G182 (9)


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'o UNITED STATES

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NUCLE AR REGULATORY COMMISSION

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W ASHINGTON, O C. 20555 y

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HJTERGY OPERAT10NS. I TK,

4 DOCKET NO. Su-3P2 WTERFORD STEAM E!.[:TRM ST ATJ0'L UNJ1 3 AMENn4ENT TO FACli'TY ODEG TIN'; LICENSE i

Amendment No. 73 l

License No. hPF-38 l-The Nuclear Reguiatory Commission (the Cer iss'an) has found that:

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A.

The application for amendment by Entergy Operations, Inc. (the i

licensec) dated January 6, 1992, complies with the standards and i

requirements of the Atomic Energy Act of 1954, as amended (the Act),

and the Commission's rules and regulations set forth in 10 CFR Lhapter I; i

S.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commi s s io r,;

4 C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health cad safety of the public, and (ii) that sutb activities will be i

conducted in compliance with the Commission's regulations; 0.

The is' ince of thit amendment will not be ir.imical to the common defe-

.) security or to the health and safety of the public; and E.

The issuance of this amendrent is in accordance with 10 CFR Part 51 of the Com-'ission's regul.tions and all applicable requirements have i

been satisfied.

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Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of facility Operating License No. NPF-38 is hereby amended to read as follows:

(2) Technical Soecifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 73, and the Environmental Proter. tion Plan contained ii, Appendix 0, are hereby incorporated in the license.

The licensee shall operate tne facility in 'accordance with the Technical Specifications and the Environmentai Protection Plan.

3.

This license amendment is effective as of its date of issuance.

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FOR THE NUCLEAR REGULATORY COMMISSION s

e i,/',<< h 4 W John T. Larkins, Director Project Directorate IV-1 Division of Reactor Projects lil/IV/V

' tice of Nuclear Reactor Regulation

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Attachment:

Changes to the Technical Spet i ficatioris Date of Issuance:

April 17, 1992 4

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ATT ACHMENT TO LICENSE AMENDMENT 'ric 73 TO FACillTY OPLRATING LICENSE NO. NPF-38 DOCKET NO. 50-;.o2 Replace the following pages of the Appendix A Technical Specifications with the attached pages.

The revised pages are identified by Amendment number and contain vertical lines indicating the areas of change.

REMOVE PACES

. INS.ERT PAGES 3/4 7-21 3/4 7-21 3/4 7-21a 3/4 7-21b 3/4 7-22 3/4 7-22 B 3/4 7-5

.C 3/4 7-5 B 3/4 7-6 8 3/4 7-6 k

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L PLANT SYSTEMS 3/4.7.8 SNU9BERS l-i LIMITING CONDITION FOR r'"?ATION j

l 3.7.8 All hydraulic and mechanical snubbers shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

MODES 5 and 6 for snubbers located on systems required OPERABLE in those OPERATIONAL MODES.

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ACTION:

With one or more snubbers inoperable on any system, within_72 hours replace er i

restore the inoperable snubber (s) to OPERABLE status and perform-an engineering -

j evaluation per Specificatinn 4.7.89. on the. attached component or declare the i

attached' system inoperable and follow the ar repriate ACTION statement for that l

system.

SURVELLIANCE REQUIREMENTS l

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4.7.8 Each snubber shall be demonstrated OPERABLE by performance of the1 following. augmented inservice inspection program and the requirements of l'

Specificttion 4.0.5.

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a.

Inspection Types l

As used in this specification, " type of snubber" shall mean snubbers i

of the same design and manufacturer, irrespective of capacity.

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b.

Visual Inspections I

i-Snubbers are categorized as inaccessible or:accest.ible during reactor operation.

Each of these categories (inaccessible and accessible)-

i may be inspected independently according to the.schedulo determined j

by Table 4.7-2._ The visual jnspect#on_ interval-for-each type of snubber--shall be determined ~ based upon the criteria provided-in

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Table 4.7-2 and-the first inspection interval.oetermined_using this criteria shall be-based upon-the crevious inspection ~ interval as established by.the requirements in~effect befcre amendment-t=

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1, W/.TERF00_ LUNIT 3 3/4 7-21 AMENDMENT NO. 2, 73

TABLE 4.7-2 SNUBBER VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval (Notes 1 & 2)

(Notes 3 & 6)

Jotes 4 & 6)

(Notes 5 & 6) 1 0

0 1

80 0

0 2

100 0

1 4

150 0

3 8

200 2

5 13 300 5

12 25 400 8

18 36 500 12 24 46 750 20 40 78 1000 or greater 29 56 109 Note 1:

The next visual incpectiJn interval for a snubber population or category size shall be determined based upon the previous inspection interval and the number of unacceptaMe snubbers found during that interval.

Snubbers may be categorized, based upon their accessibility during power operation, as acc6ssible or inaccessible.

These categories may be examined separately or jointly.

However, the licensee must make and doc aent that decision before any inspection and shall ase that decision as the? Mis upon which to determine the next inspection interval for tha'

'ltegory.

Note 2:

Interpolation between population or category s'.es and the number of unacceptable snubbu 3 is permissible.

Use ri m lower integer for the value of the limit for Columns A, B, or C if that integer includes a ft1:tional value of unacceptable snubbers as determined by interpolation.

Note 3:

If the number of unacceptable snubbers is equal to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.

WATERFORD - UNIT 3 3/4 7-21a AMENDMENT NO. 73

TABLE 4.7-2 (Continued)

SNUBBER VISUAL INSPECTION INTERVAL Note 4:

If the number of unacceptable snubbers is equal to or less than the number in Column 8 but greater than the number in Column A, the next inspection interval shall be the same as-the previous interval.

Note 5:

If the number of unacceptable snubbers is equal to or greater than tne number in Column C, the next inspection interval shall be two-thirds of the previous interval.

However, if the number of unacceptable snubters is less than the number in-Column C but greater than the number in Column B, the next interval shall be reduced proportionally by interp';1ation, that is, the previous interval shall be reduced-by a factor that is one-third of the-ratio of the difference between the number of unacceptable snubbers found during the previous interval had the number in Column B to the difference in the numbers in Columns B and C.

Note 6:

The provisions of Specification 4.0.2 are applicable for all inspec-tion intervals up to and including 48 months.

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WATERFORD - UNIT 3 3/4 7-21b AMENDMENT NO.73 j

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c.

Visual Inspection Acceptance Criteria Visual inspections shall verify that (1) the snubber has no visible.

indications of damage or impaired 0?ERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) fasteners for the attachmer.t of the snubber to the component and to the snubber anchoragt are functional.

Snubbers which appear inoperable as a resuh of visual inspections shall bt' classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) the cause of rejec-tion is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that asy be generically susceptible; and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specifica-tion 4.7.8f.

All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval.

A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber.

If continued operation cannot be justified, the snubber shall be declared inoperable and the ACTION requirements shall be met.

d.

Transient Ever.t Inspection An inspection shall be performed of all hydraulic and mechanical snubbers attached tn sectio,s of systems that have experienced unexpected, potentially damaging transients as' determined from a-review v! operational data and a visual inspection of the systems within 6 months _following such an event.

In addition to satisfying-the visual inspection acceptance criteria, freedom-of-motion of mechanical snubbers shall be verified using at least one of the following:

(1) manually induced snuboer. movement; or (2) evaluation of in place snubber piston settirg; or (3) stroking the mechanical snubber through its full range of travel, a

1 WATERFOP.D - UNIT 3 3/4 7-22 AMENOMENT NO. 2, 73

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PLANT SYSTEMS BASES CONTROLLEO VENTILATION AREA SYSTEM (Continued)

Operation of the system with the heaters on for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> continuous over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

Obtaining and analyzing charcoal samples after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (since the last sample and analysis) ensures that the adsorber maintains the efficiency assumed in-the safety analyses and is consistent with Regulatory Guide 1.52.

3/4.7.8 SNUBBERS All snubbers are required OPERABLE to ensure that tne 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.

4 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.

Snubbers are classified and grouped by design and manufacturer but not by size.

For example, mechanical snubbers utilizing the same design features of the 2-kip, 10-kip, and 100-kip capacity manufactured by Company "A" are of the same type.

The same design mechanical snubbers manufactured by Company "B" for the purposes of this Technical Specification would be of a different type, as would hydraulic snubbers from either manufacturer.

A list of individual snubbers with detailed information of snubber location and size and of system affected shall be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. -The accessibility of each snubber shall be determined and approved by the Plant Operations Review Committee.

The determination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each snubber locatiun as well as other factors associated with accessibility during plant operations (e.g.,

temperature, atmosphere, location, etc.), and the recommendations uf Regulatory Guides 8.8 and 8.10.

The addition or deletion of any hydraulic or mechu.ical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

Guidance for visual inspection is provided in NRC Generic Letter 90-09. A-visual inspection is the observation of the condition of installed snubbers to identify those.that are damaged, degraded, or inoperable as caused by physical means, leakage," corrosion, or environmental exposure.

The functional testing program provides a 95 percent confidence level that 90 to 100 percent of the snubbers will operate within the specified acceptance limits.

The performance of visual examinrtions is a separate process that complements the functional testing program and provides additional confidence in snubber operability.

WATERFORD - UNIT 3 B 3/4 7-5 Amendment No. 73

PLANT SYSTEMS BASES SNUB 8ERS (Continued)

The visual inspection schedule (as determined by Table 4.7-2) is based on the number of. unacceptable snubbers found during the previous inspection in proportion to the sizes of the various snubber populationi, or categories.

A snubber is considered unacceptable if it fails the acceptance criteria of the visual inspection.

The inspection interval is based on a fuel cycle of up to 24 months and may be as long as two cycles, or 48 months for plants with other fuel cycles, depending on the number of unacceptable snubbers found during the previous visual inspection.

The acceptance criteria are to be used in the visual inspection to determine OPERABILITY of the snubbers.

For example, if a fluid port of a hydraulic snubber is found to be uncovere!..

he snubber shall be declared inoperable and shall not be determined OPERABLt via functional testing.

s To provide assurance of snubber functional reliability one of three functional testing methods are used with the stated acceptance criteria:

1.

Functionally test 10% of a type of snubber with an additional 10%

tested for each functional testing failure, or 2.

Functionally test a sample size and determine sample acceptance or rejection using Figure 4.7-1, or 3.

Functionally test a representative sample size and determine sample acceptance or rejection using the stated equation.

Figure 4.7-1 was developed using "Wald's Sequential Probability Ratio Plan" as described in " Quality Control and Industrial Statistics" by Acheson J.

Duncan.

Permanent or other exemptions from the surveillance program for individual snubbers may be Granted by the Commission if a justifiabis basis for exemption is presented and, if applicable, snubber life destructive testing was performed to qualify the snubbers for the applicable design conditions at either the completion of their fabrication or at a subsequent date.

Snubbers so exempted shall be listed in the list of individual snubbers indicating the extent of the exemptions.

The serviN life of a snubber is established via manufacturer input and information through consideration of the snubber service conditions and associated installation and maintenance records (newly installed inubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc.).

The requ.vtiment to monitor the snubber service life is included to ensure that the

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snubbers periodically undergo a performance ovaluation in view of their age and operating conditions.

These records will provide statistical bases for future consideration of snubber service life.

WATERFORD - UNIT 3 8 3/4 7-6 knendnient No. 73

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