ML20101F816

Application for Amend to License NPF-12,changing Tech Spec 3/4.7.7 to Indicate Operability of Snubbers Required for Safe Shutdown/Accident mitigation.Marked-up Tech Specs Encl

ML20101F816
Person / Time
Site:	Summer
Issue date:	12/14/1984
From:	Dixon O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8412270311
Download: ML20101F816 (10)

Text

p SOUTH CAROLINA ELECTRIC 8c GAS COMPANY POST OFF#CE 764 COLuusiA. South CAROUNA 29210 O. W. Dixom. Jm.

Nuc$e'. oFca

"'*' Ir~ ions December 14, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Generic Letter 84-13 Technical Specification Change for Snubbers

Dear Mr. Denton:

In a letter dated November 16, 1983, South Carolina Electric and Gas Company (SCE&G) requested a revision to Technical Specifications Table 3.7-4b, " Safety Related Mechanical Snubbers." On May 25, 1984, SCE&G received Generic Letter 84-13, " Technical Specification for Snubbers," which outlined the criteria for deleting Tables 3.7-4a and 3.7-4b. In response to this generic letter, SCE&G hereby requests a revision to the November 16, 1983 submittal to eliminate Tables 3.7-4a and 3.7-4b and to revise Specification 3/4.7.7 as described below and shown on the attached marked-up Technical Specification pages.

As stated in Generic Letter 84-13, the snubber listing currently found in Technical Specifications is not necessary, provided Technical Specification 3/4.7.7 specifies which snubbers are required to be operable. Technical Specification 3/4.7.7 is therefore being revised to indicate that all snubbers on systems required for safe shutdown / accident mitigation shall be operable. This includes safety and non-safety related snubbers on systems used to protect the code boundary and to ensure the structural integrity of these Systems under dynamic loads.

SCE&G has determined that a finding of no significant hazards consideration is justified because the snubbers listed in Tables 3.7-4a and 3.7-4b are now being defined in section 3.7.7 of the Technical Specifications. Therefore, the scope and requirements found in section 3/4.7.7 are not changed and SCE&G considers the amendment consistent with NRC guidance and administrative in nature.

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- Mr. Harold R.- Denton, Director

. Generic Letter 84-13 Technical Specification

_ Change.on' Snubbers

_ December 14, 1984

_Page'#2 This revision.has been reviewed and approved by the Plant Safety Review Committee and the Nuclear Safety Review Committee.- A check in the amount of four thousand dollars ($4000.00) was previously submitted with the November 16, 1983 letter.

Ver trul your ,

O. W. Dixon, r.

AMM/OWD/gj Attachments cc: V. C. Summer C. A. Price T. C. Nichols, Jr./O. W. Dixon, Jr. C. L. Ligon (NSRC)

E. H. Crews,'Jr. K. E. Nodland E. C. Roberts R. A. Stough.

W. A. Williams, Jr. G. Percival D. A. Nauman C. W. Hehl J .- P. O' Reilly J. B. Knotts, Jr.

Group Managers H. G. Shealy O. S. Bradham NPCF File

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PLANT SYSTEMS 3/4.7.7 SNUBBERS I

LIMITING CONDITION FOR OPERATION 3.7.7 $ EE MSED A" APPLICA8ILITY: M00ES 1, 2, 3 and 4. MODES 5'an'd 6 for snubbers located on

, _ systems required OPERABLE in those MODES. I ACTION:

With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber (s) to OPERA 8LE status and perform an engineering evaluation per Specification 4.7.7.g on the attached component or declare the attached I system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7.7 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.

a. Inspection Types

' As used in this specification, type of snubber shall mean snubbers of the same design and manufacturer, irrespective of capacity,

b. Visual Inspections The first inservice visual inspection of each type of snubber shall

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be performed after 4 months but within 10 months of commencing POWER OPERATION and shall include all snubbers l u b4 in T.;,; n 3.7-4. oer mto IN b ECTION 3,Y7. '

If less than two snubbers of each type are found inoperable during the first inservice visual inspection, the second inservice visual inspection shall be performed 12 months i 25% from the date of the first inspection. Otherwise, subsequent visual inspections shall be performed in accordance with the following schedule:

No. Inoperable Snubbers of each Subsequent Visual ,

type per Inspection Period Inspection Period" 0 18 months i 25%

1 12 months i 25% (

! 2 6 months i 25%

3,4 124 days i 25%

5,6,7 62 days i 25%

8 or more 31 days i 25%

The inspection interval for each type of snubber shall not be lengthened I more than one step at a time unless a generic problem has been identified and corrected; in that event the inspection interval may be lengthened one j step the first time and two steps thereafter if no inoperable snubbers of

! that type are found.

The provisions of Specification 4.0.2 are not applicable. (

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4 INSERT " A"

' All snubbers on systems required 'for safe shutdown / accident mitigation'shall be OPERABLE. This includes safety and

.non-safety related' snubbers on systems used to protect the

code boundary and to ensure the structural integrity of these systems under dynamic loads.

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l SURVEILLANCE REQUIREMENTS (Continued) '

c. Refuelino Outane Inspections

"" *3 ' At least once per 18 months an inspection shall be performed of all the snucDersui kt:d 9 T el:: ?. 'M: : f ?.'Mt attached to sections of safety systems piping that have experienced unexpected, potentially '

damaging transients as determined from a review of operational data and a visual inspection of the systems. 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: (i) manually induced snubber movement; (ii) evaluation of in place snubber piston setting; or (iii) stroking the mechanical snubber through its full range of travel. l

d. Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that there are no visible indications of damage or impaired OPERA 8ILITY and (2) attachments to the foundation or supporting structure are secure. Snubbers which '

appear' inoperable as a result of visual inspections may be determined OPERA 8LE 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 for other snubbers irrespective of type that may be generically susceptible; and (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.7.f. When a fluid port of a hydraulic snubber is found to be uncovered the snubber shall be declared inoperable and shall not be determined /

[i OPERA 8LE via functional testing unless the test is started with the i piston in the as found setting, extending the piston rod in the

' tension mode direction. All' snubbers connected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.

e. Functional Tests During the first refueling shutdown and at least once per 18 months thereafter during shutdown, a representative sample of either:

(1) At least 105 of the total of each type of snubber in use in the plant shall be functionally tested either in place or in a bench test. For each snubber of a type that does not meet the functional test acceptance criteria of Specification 4.7.7.f, an additional 10% of that type of snubber shall be functionally tested until no more failures are found or until all snubbers of that type have been functionally tested, or (2) A representative sample of each type of snubber shall be functionally tested in accordance with Figure 4.7-1, "C" is the total number of snubbers of a type found not meeting the acceptance requirements of Specification 4.7.7.f.

The cumulative number of snubbers of a type tested is denoted by "N." At the end of each day's testing, the new values of "N" and "C" (previous day's total plus current day's increments) shall be plotted on Figure 4.7-1. If at any time the point plotted falls in the " Reject" region all snubbers of that type shall be functionally tested. If at any time the point plotted falls in

( SUpeiER - UNIT 1 3/4 7-17

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DELETE PLANT SYSTEMS Table 3.7-4a

( Safety-Related Hydraulic Snubbers

• Paul-Monroe System Size (Kips)

Small Medium Large N/A N/A 1000 FW 15

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Subtotal-1 15 Subtotal-2 15 TOTAL 15 "Sn rs may be added to safety-related systems without prior License ndment to Table 3.7-4a provided that a revision to Table 3.7-4a is cluded with the next License Amendment request.

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SUPMER - UNIT 1 3/4 7-21

DELETE

'P SYSTEMS I

-Table 3.7-4b Safety-Related Mechanical Snubbers * .

Pacific-Scientific System Size (Kips)

Small Medium Large 1/2 1 3' 10 35 100 AS .1 1 CC. 2 1 3, 19 2 11 CS- 7 18 9

.DG 2 16

- EF 2 1 ,

FW 1 18 34 32 1 e M 7 2 1 )

M 8 9 4 3 RC 6 19 80 49 1 10 (

RH 1- 21 89 40 3 SF 1 6 3 SI 7 14 44 36 5

-SP 1 2 53 7 I SW 12 11 3 Subtota'l-1 16 38 153 319 180 109 4 Subtotal-2 54 652 113 TOTAL 19 "Snubbe may be added to safety-related systems without prior License 4 Ane nt to Table 3.7-4b provided that a revision to Table 3.7-4b is inc with the next License Amendment request.

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SUMER - UNIT 1 3/4,.7-22

PLANT SYSTEMS

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BASES ULTIMATE HEAT SINK (Continued)

The limitations on minimum water level and maximum temperature are based (

on providing a 30 day cooling water ' supply to safety related equi ment without i exceeding their design basis temperature and is consistent with tie j recommendations of Regulatory Guide 1.27, " Ultimate Heat Sink for Nuclear Plants", March 1974. l 3/4.7.6 CONTROL ROOM NORMAL AND EMERGENCY AIR HANDLING SYSTEM The OPERABILITY of the control room ventilation system ensures that

1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERA 8ILITY 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 ren or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50.

3/4.7.7 SNU88ERS i

, All snubbers on systems required for safe shutdown / accident mitigation shall be OPERABLE. This includes safety and non-safety related snubbers on systems used to protect the code boundary and to ensure the structural integrity of these systems under dynamic loads.

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, Snubbers are classified and grouped by design and manufacturer but not by

size. Forexample,mechanicalsnubbersutilizingthesamedesignfeaturesof the 2 kip,10 kip and 100 kip capacity manufactured by company A" are of the same type. The same design mechanical snubber manufactured by company "B" for the purposes of this specification would be of a different type, as would f

. hydraulic snubbers from either manufacturer. L The visual inspection frequency is based upon maintaining a constant level of snubber protection to systems. Therefore, the required inspection interval varies inversely with the observed snubber failures and is determined l by the number of inoperable snubbers found during an inspection. Inspections r i; performed before that interval has elapsed may be used as a new reference (

point to determine the next inspection. However, the results of such early i inspections performed before the original required time interval has elapsed l (nominal time less 25%) may not be used to lengthen the required inspection

. interval. Any inspection whose results require a shorter inspection interval will override the previous schedule. (,

SUP#iER - UNIT 1 8 3/4 7-4 i

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1 Pt. ANT SYSTEMS

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BASES SNU8BERS (Continued).

~To provide assurance of snubber functional reliability one of two sampling and acceptance criteria methods are used:

1) functionally test 10 percent of a type of snubber with an additional '

10 percent tested for each functional testing failure, or l

2) functionally test a sample size and determine sample acceptance or rejection using Figure 4.7-1.

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

The service 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 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 age and operating conditions.. These records will provide statistical bases for future consideration of snubber service life. The requirements for i

- {- the maintenance of records and the snubber service life review are not intended to affect plant operation.

Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption i is presented and, if applicable, snubber life destructive testing was performed to qualify the snubber for the applicable design conditions at either the completion of their fabrication or at a subsequent date. Snubbers so exempted shall sent$aus-4e be listed in T et:: 3.7-t: Y

• the extent of the exemptions. CSscTron 3,7.3.?-05withfootnotesindicating

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• Sufg4ER - UNIT 1 B 3/4 7-5 l

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ADMINISTRATIVE CONTROLS

1. Records of Quality Assurance activities as specified in the NRC's approved SCE&G position on Regulatory Guide 1.88, Rev. 2, October 1976.

j. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k. Records of meetings of the PSRC'and the NSRC.

pman m Sm.u 1. Records of the service lives of all hydraulic and mechanical 3.7.y snubbers m : :e :: T:M :: 2.?-t: ::: '-it including the date at which the service life commences and associated installation and maintenance records.

m. Records of secondary water sampling and water quality.

n. Records'of analysis required by the radiological environmental monitoring program.

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

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6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" o'r " alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20 each high radiation area in which the intensity of radiation is greater than 100 mres/hr but less than 1000 mres/hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)." Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area, A radiation monitoring device which continuously integrates the b.

radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been

- established and personnel have been made knowledgeable of them,

c. A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiation Work Permit.

" Health Physics personnel or personnel escorted by Health Physics personnel .

shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they otherwise comply with (

approved radiation protection procedures for entry into high radiation areas.

- SUMER - UNIT 1 6-22

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