ML20101T444

Proposed Tech Specs,Revising Hydraulic & Mechanical Snubber Surveillance Program,Including Changes to Visual & Functional Tests of safety-related Snubbers & Maint of Equipment & Surveillance Records

ML20101T444
Person / Time
Site:	Davis Besse
Issue date:	01/30/1985
From:	TOLEDO EDISON CO.
To:
Shared Package
ML20101T425	List: ML20101T424 ML20101T444
References
TAC-11311, TAC-11312, NUDOCS 8502060169
Download: ML20101T444 (8)

Text

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PLANT SYSTEMS 3/4.7.7 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.7 All safety related snubbers shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4. (MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

a. With one or more snubbers inoperable: 1. within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or rentore the inoperable snubber (s) to OPERABLE status, or 2. verify system operability with the snubber (s) inoperable by engineering evaluation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

3. declare the supported subsystem inoperable and follow the appropriate ACTION statement for that system.

and, for snubbers which have failed either the visual or functional test:

b. Perform an engineering evaluation within 90 days to deter-mine if any safety-related system or component has been adversely affected by the inoperability of the snubber and if the snubber mode of failure has imparted a significant effect or degradation on the supported component or system.1 The provisions of Technical Specification 3.0.4 are not applicable for the component or system.

SURVEILLANCE REOUTREMENTS 4.7.7 Each snubber 2 shall be demonstrated OPERABLE by the requirements of the following surveillance programs and pursuant to require-ments of Specification 4.0.5.

4.7.7.1 Visual Inspection Program lEngineering evaluation is not required when a snubber is removed for surveillance testing provided it is returned to OPERABLE status within the requirements of action statement a.

2 Safety related snubbers are listed in the latest revision of applicable surveillance test-procedure (s). Snubbers may be added to, or removed from, safety-related systems and their assigned groups without prior Licensing Amendment.

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8502060169 850130 PDR ADOCK 05000346 -i P PM DAVIS-BESSE, UNIT 1 3/4 7-20

PLANT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)

a. General Reouirements At least once per inspection interval, each group of snubbers in use in the Plant shall be vistally inspected in i

accordance with Specification 4.7.7.1.b and 4.7.7.1.c.

Visual inspections may be performed wita binoculars, or other visual support devices, for thore snubbers that are difficult to access and where requir:d to keep exposure as low as reasonably achievable. Response to failures shall be in accordance with Specification 4.7.7.1.d.

b. Inspection Interval and Sample Criteria-The inspection interval and sample criteria may be applied on the basis of snubber groups. The snubber groups may be established based on physical characteristics and accessi-bility. Inaccessible snubbers are defined as those locat-ed: (a) inside containment, (b) in high radiation exposure zones, or (c) in areas where accessibility is limited by physical constraints such as the need for scaffolding.

Visual inspections for a group shall be performed in accordance with the following schedule:

. Snubbers are divided into four (4) groups: " Accessible" -

Group 1 and " Inaccessible" - Group II for either hydraulic or mechanical.

No. of Inoperable Snubbers Within a Group Subsequent Group Visual Per Inspection Interval Inspection Interval 3, 4, 5 0 18 months 1 12 months 2 6 months 3, 4 124 days 5,6,7 62 days 8 or more 31 days The inspections for a group shall include 100 percent of snubbers in that group.

3 The inspection interval shall not be lengthened more than one step at a time, and 4 The provisions of Specification 4.0.2 are not applicable.

5A11 the time intervals are +25%, except that the inspection of inaccessible snubbers, may be deferred to the next shutdown when plant conditions allow 5 days for inspection.

DAVIS-BESSE, UNIT 1 3/4 7-21

-PLANT SYSTEMS SURVEILLANCE REOUTREMENTS (Continued)

c. Acceptance Criteria A snubber shall be considered OPERABLE as a result of a visual inspection if: (1) there are no visible indications of damage or inoperability, and (2) attachments to the foundation or supporting structure are secure,

d. Response to Failures For each snubber unit which does not meet the visual inspection acceptance criteria of Specification 4.7.7.1.c:

Determine the snubber OPERABLE by functionally testing the snubber per Specification 4.7.7.2, unless the (hydraulic) snubber was determined inoperable because the fluid port was found uncovered; QR

1. Perform the ACTION specified in 3.7.7a; and

2. Perform an engineering evaluation as specified in 3.7.7.b.;

and

3. Increase the frequency of group. inspection as de-scribed in Specification 4.7.7.1.b, unless the cause of the rejection is clearly established and remedied ~

for that particular snubber and for other snubbers that may be generically susceptible.

4.7.7.2 Functional Test Program

a. General Requirements At least once per inspection interval a representative sample of each group of snubber in use in the Plant shall

.be functionally tested in accordance with Specifications 4.7.7.2.b and 4.7.7.2.c. Response to the failures shall be in accordance with Specification 4.7.7.2.d.

For all snubbers, _ functional testing shall consist of either bench testing or inplace testing.

b. Inspection Interval and Sample Criteria The snubbers may be categorized into groups based on physical characteristics. Snubbers are divided into four (4) groups: " Accessible" - Group 1 and " Inaccessible" -

. Group II 'for either hydraulic or mechanical. Each group

. may be tested independently from the standpoint of per-forming additional tests if failures are discovered.

DAVIS-BESSE, UNIT 1 3/4 7-22

PLANT SYSTEMS j SURVEILLANCE REQUIREMENTS (Continued)

The inspection interval for functional testing shall be g 18 months.

Snubbers which are scheduled for removal for seal mainte-nance may be included in the test. sample prior to any i maintenance on the snubber.

The representative sample shall consist of at least 13 percent (rounded off to next highest integer) of each group of

• snubbers in use in the Plant. The selection process shall ensure that all snubbers, regardlessa of their accessibili-ty classification, are functionally tested at least once every ten inspection intervals.

c. Acceptance Criteria <

For hydraulic snubbers (either inplace testing or bench testing), the test shall verify that:

1. Snubber piston will allow the hydraulic fluid to

" bypass" from one side of the piston to the other to assure unrestrained action is achieved within the specified range of velocity or acceleration in both tension and compression.

2. When the snubber is subjected to a movement which creates a load condition that exceeds the specified range of velocity or acceleration, the hydraulic fluid is trapped in one end of the snubber causing suppres-  !

sion of that movement

3. Snubber release rate or bleed rate, where required, occurs in compression and tension.

For mechanical _ snubber in place and bench testing, the test shall_ verify that:

1. The force that-initiates free movement of the snubber rod in either tension or compression is less than the

- specified maximum drag force.

2. Activation (restraining action) is achieved in both tension and compression.

t sPermanent or other exemptions from functional testing for' individual-

, snubbers in these categories may be granted by the Commission only if l a justifiable basis for exemption is presented.

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! DAVIS-BESSE, UNIT 1 3/4 7-23 l

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

', d. Response to Failures

. For each inoperable snubber per Specification 4.7.7.2.c:

1. Perform the ACTIONS specified in 3.7.7a and 3.7.7b; and

2. Within the specified inspection interval, functionally test an additional sample of at least 10 percent of the snubber units from the group that the inoperable snubber unit is in.

The functional testing of an additional sample of at least 10 percent from the inoperable snubber's group is required for each snubber unit determined to be inoperable in subsequent functional tests, or until all snubbers in that group have been tested; and

3. The cause of snubber failure will be evaluated and, if caused by a manufacturing or design deficiency, all snubbers of the same or similar design subject to the same defect shall be functionally tested within i 90 days from determining snubber inoperability. This testing requirement shall be independent of the requirements in 4.7.7.2.d(2) above.

DAVIS-BESSE, UNIT 1 3/4 7-24

5 PLANT SYSTEMS RARER PLANT SYSTEMS 3/4/7.7 SNUBBERS BASES All safety-related snubbers are required OPERABLE to ensure that the structural integrity of the reactor coolant system and all other safety-related. systems is maintained during and following a seismic event.

Snubbers excluded from this inspection program are those installed on safety-related cystema for loads other than seismic or 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 during a seismic event.

Inoperable is defined as:

1. For visual test

a. The fluid no longer is supplied to the valve block, or

b. Mounting pins are disengaged from the snubber.

. c. Attachment to foundation or supporting structure is not secure.

2. For functional test

a. The snubber (excluding end anchors, i.e., pin-to pin) does not meet specified test criteria. _

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 c determined by the number of inoperable snubbers found during an inspec-tion. Inspections 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 inspections performed before the original required

. time interval has elapsed (nominal time less 25%) may not be used to lengthen the required inspection interval. Any inspection whose results 1 require a shorter inspection interval will override the previous schedule. .

When'the cause of the' rejection of a snubber is clearly established and remedied for that snubber and for any other snubbers that may be generi-

> cally susceptible, and verified by functional testing, that snubber may be

, exempted from 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 snubber by visual

. inspection,,or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.

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s DAVIS-BESSE, UNIT 1 B 3/4 7-Sa c =

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' PLANT SYSTEMS nAnrn

. When a snubber is found inoperable through a visual or functional test, an engineering evaluation is performed, in addition to the determination of the snubber mode of failure, in order to determine if any safety-related component or system has been adversely affected by the inoperability of the snubber. The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a sign.ficant effect or degrada-e tion on the supported component or system.

To provide assurance of en bber functional reliability, a representative sample of the installed snubbers will be functionally tested at 18 month intervals. Observed failures of these sample snubbers shall require functional testing of additional units. When a snubber is found to be inoperable due to failure to lock up or failure to move (i.e., frozen in place), the cause will be evaluated for further action or testing.

In cases where the cause of failure has been identified, additional snubbers that have a high probability for the same type of failure or are being used in the same application that caused the failure shall be tested. This requirement increases the probability of locating inoperable snubbers without testing 100% of the snubbers.

Hydraulic snubbers and mechanical snubbers may each be treated as a different entity for the above surveillance programs.

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s DAVIS-BESSE, UNIT 1 B 3/4 7-5b

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, ADMTMISTRATIVE CONTROLS

e. Records of changes made to Operating Procedures.

f. Records of radioactive shipments.

3 3 Records of sealed source and fission detector leak tests

- and results. ,

h. Records of annual physical inventory of all sealed source material of record.

6.10.2 - The following records shall be retained for the duration of the Facility Operating License:

a. Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

^ b. Records of new and irradiated fuel inventory, fuel trans-fers and assembly burnup histories.

c. Records of radiation exposure for all individuals entering radiation control areas.

d. Records of gaseous and liquid radioactive material released to the environs. -

.- e. Records of transient of operational cycles for those m facility components identified in Table 5.7-1.

f. -Records of reactor tests and experiments.

3 Records of training and qualification,for current members of the plant staff. )

,~ b. Records of in-service inspections performed pursuant to these Technical Specifications.

i. Records of Quality Assurance activities required by the QA Manual. . .,.

j. Records of reviews performed for changes made to procedures

- / .or equipment or reviews of tests and experiments pursuant 1 x to 10 CFR 50.59. ,

k. Records of meetings of the SRB and the CNRB.

D 1. - acords for Environmental Qualification which are covered under the provisions of paragraph 6.13.

m. Records of the service lives of all safety.related hydrau-lic and mechanical snubbers including the date at which the service life commences and associated installation and maintenance records.

'" r DAVIS-RESSE, UNIT 1 6-19 Amendment No. 8, 12 Order dtd. Oct. 24,.1980

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