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CW ~J p-t NUCLEAR REGULATORY CO.'4 MISSIONS j
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D:ccmber 24, 1975 Docket N d 0-219 Jersey Central Power & Light Company ATTN:
Mr. I. R. Finf rock, Jr.
Vice President - Generation Madison Avenue at Punch Bowl Road Morristoun, New Jersey 07960 Gentlemen:
1 RE: OYSTER CREEK UNIT 1 By letter dated July 8, 1975, we transmitted to you model technical specifications relating to hydraulic snubbers and requested that you submit an application to amend your Technical Specificctions to incorporate these model technical specification.s.
You did this by your letter dated September 12, 1975, and-supplcraented by letter dated October 20, 1975.
Your letters provided coraents on the model technical specificatiens; houcver, you indicated that the model technical specifications were generally acceptabic to you.
As a result of coments that we roccived from licensees and further consideration by ourselves, we have revised the model technical specifications to provide some relaxation an.1 clarification of the requirements.
The revisions. consist of:
(1) deleting the requi rcuen t for periodic disassembly and inspection of snobbers, (2) provisions for installing additional safety related snubbers without prior UnC approval; and, in order to clarify the intent of the specifications, (3) specifying that the visual inspection of snubbers should include the fluid reservoir, fluid connections, and any linkage connections to associated piping, and anchors, (4) identification of all safety related snubbers rather than non-safety related snubbers, and (5) enlarging the scope of' Table 3.6.1 in the model technical specifications to identify safety related snubbers that are (a) in high radiation areas, (b) especially difficult to remove, (c) inaccessible during normal operation, and (d) accessible during normal operation.
A copy of the revised model technical specifications and bases are enclosed.
In order that we may proceed with amending your license to incorporate these technical specification changes we request that you submit an amendment to your September 12, 1975, application for. license amendment to reficct the enclos revised model technical specifications and to identify the safety related onubbers and their accessibility as required by Tabic 3.6.1 of the revised model technical specifications.
The rationale that yo.u use for characterizing a snubber as "especially difficult to remove" or " inaccessible during normal 6
l operation" should be stated in your' submittal.
Sincerely, Q
a George Lear, Chief l
Operating Reactors Branch #3 Division of Reactor Licensing bqh I
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9604220221 960213 PDR FOIA DEKOK95-258 PDR
v spr 2-December 24, 1975 J:rscy C:ntr:21 PowIr 4 Light C3.
cc:
ite llonorable W. M. Mason G. F. Trowbridge, Esquire Mayor, Lact) Township Shaw, Pittman, Potts and Trowbridge P. O. Box 475 08731 Forked River, New Jersey Barr Building 910 17th Street, N. W.
Washington, D. C.
20006 lionorabic hh. F. Ilyland Attorney General Jersey Central Power 6 Light Company State of New Jersey AT1N: Mr. Thomas M. Crimmins, Jr.
State llouse Annex Safety and Licensing thnager Trenton, New Jersey 08601 GPU Service Corpo.ation 260 Cherry 11111 Road Parsippany, New Jersey 07054 Anthony'Z. Roisman, Esquirc Itoistaan, Kessler and Cashdan 1712 N Street, N. W.
Washington, D. C.
20036 Paul Rosenberg, Esquire Danici Itappoport, Esquire 2323 S. Broad Street Trenton, New Jersey 08010 lionorabic Joseph W. Ferraro, Jr.
Deputy Attorney General State of New Jersey
- j 101 Commerce Street - Room 208 Newark, New Jersey 07102 George F. Kugler, Jr.
Attorney General State of Xcw Jersey State llouse Annex Trenton, New Jersey 08625 Ocean County Librart 15 llooper Arenue Toms River, New Jersey 08753 9
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'LIhlTINd' CONDITION FOR OPERATION SURVETLLANCE REQUIREMENT 4.6.I Hydraulic Snubbers 3.6.1 llydraulic Snubbers 1.
During all modes of operation
'Ihe following surveillance requireme'nts except Cold Shutdown and Refuel, apply to all hydraulic snubbers listed all hydraulic snubbers listed in in Tabic 3.6.1.
Table 3.6.1 shall be operable except as noted in 3.6.I.2 through 1.
All hydraulic snubbers whose seal 3.6.I.4 below.
araterial has been demonstrated by operating experience, lab testing 2.
From and after the tire that or analysis to be compatibic a hydraulic snubber is determined with the operating environment to be inoperabic, continued shall be visually inspected.
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reactor operation is permissible inspection shall include, but not only during the succeeding 72 necessarily limited to, inspection hours unicss the snubber is sooner of the hydraulic fluid reservoir, made operable, fluid connecti6ns, and linkage connections to the piping and 3.
If the reqdirements of 3.6.I.1 anchor to verify snubber operabili and 3.6.1.2 cannot be met, an in accordance with the following orderly shutdown shall be initiated schedule:
and the reactor shall be in a cold shutdown condition within Number of Snubbers Next Required 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Found Inoperabic Inspection During Inspection Interval i
4.
If a hydraulic snubber is determined or During Inspection to be inoperable while the recctor Interval is in the shutdown or refuel mode, the snubber shall be made operabic 0
18 nionths 1 25t
. prior to reactor startup.
1 12 months + 255 2
6 months [255 5.
Snubbers may be added to safety 3,4 124 deys
+ 2 5',
related systems without prior 5,6,7 62 days
.1 25% l License Amendment to Tabic 3.6.1 18 31 days 1 25i 1 provided that safety' evaluations, documentation and reporting arc The required inspection interval provided in accordance with 10 shall not be lengthened more tha:
CFR 50.59 and that a revision to one step at a time.
Table 3.6.1 is included with a subsequent License Amendment Snubbers may be categori:cd in request.
two groups, " accessible" or
" inaccessible" based on their accessibility for inspection during reactor operation.
These two groups may be inspecte '
independently according to the above schedule.
2.
All hydraulic snubbors whose see materials are other than ethyler l propylene or other material that '
has been demonstrated to bc compatibic with the operating environment shall be visually ins'pected far operability every 31 days.
,. LIMITING. CONDITION FOR OPERNI l-SURVEILLANCE JUIREMENT
~ ilydrabr e Snubbers (cont'd) 4,6.I
. 3.
The initial inspection shall be performed within 6 months from the date of issuance of these specifi-cations. For-the purpose of enterii lf".*,
thegedule in Specificatio'n'
-g 4.6;I:1,, it shall be assumed that ej.,
%s the facility had been on a 6 month inspection interval.
4.
Once each refueling cycle, a repre-
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entative sampic of 10 snubbers or approximately 10% of the snubbers, w?tichever is less, shall be functionally tested for operabilit:
including verification of proper piston movement, lock up and biced For each unit and subsequent unit found inoperabic, an addition-10% or ten snubbers shall be so tested until no more failures are found or all units have been teste l
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BASES:
3.6.I and 4.6.I llydraulic Snubbers 1
w3mibbers are designed to prevent unrestrained pipa notion under dyncmic loads as 1
cight occur during an carthquake or severc transient, while allcring nor.:s1 therral taotion during startup and shutdu. n.
The conscquence of an inoperabic snul. der is cn increase in tre probability of stn:cturni da: age to p;iping as a result of a scismic or other event initiating dynamic lot.ds.
It is therefore required that cil hydraulic snubbers required to protect the prinsry ecolant systcc or any other safety system er component be operabic during reactor operation.
Because 'the snubber protection is required only durina relatively low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for repairs or replacenents.
In case a shutdown is 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 a cold shutdos.~. condition will pcrait an orderly shutdoun censistent with standard operating procedure:.
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Sinco plant startup should not cerr.ence with kncuingly defective safety rc)ated equipment, Specification 3.6.I.4 prohibits stcru.p with inoperabic snubbers.
All safety related hydraulic snubbers arc visually inspected for overall integrity and operability.
The inspectica vill include verification of proper orientation.
adequate hydraulic fluid )cyc1 and proper attachment of snubber to piping end structures.
The inspection frequency is based upon naintaining a constant 3cyc1 of snebber
- protection.
Thus the rec.uired ins;>cetion inten c1 varies inversely uith the observed snubber failures.
The nm.ber of inapm.bic snubbers Idand ?.arina.a required inspection det ermihes tha time interval for the next required inrpection.
Inspections per/orned before that interval has elapsed r.2y be used as a nc.. refercace point te deternine the next inspection.
1;a. ever, the resu3 ts of SUch early inspectio.a perforr c d t>efore the original required tine interval has clapsed (nominal tine Jess 2%) n;y not bc l
used to lengthen the required inspection intcry.1.
Any inspection whose results require a shorter inspection interval will override the prcvious schedule.
1 Experience at operating facilitics has shown that the required surveillance progran should assure an acceptab)c level of snubber perforaanee provided thit the seal materials arc'compatibic with the operating environacnt.
Snubbers containing seal natcrial which has not been demonstrated by operating experience, lab tests or analysis to be compatible.with the operating environ.icnt should be inspected nore frequently (cycry conth) until material compatibility is confirmed or an appropriate changecut is comp 1'eted.
Examination of defective snubbers at reactor facilitics and material tests perforced nt several laboratories (Seference 1) has shoun that millabic gun polyurethr.no deteriorates rapidly under the temperature end noisture conditions present in many snubber locations.
Although tolded polyarethanc c~xhibits greater resistance to those conditions, it also nay be unsuitabic for applicat. ion in the higher temperature environments.
Data are not currently'availabic to precisely define en upper temperature liuit for the colded polyurethane.
Lab tests and in-plant experience indicate that scal natcrials 'are 'availablel prinarfly~6thylene propy)cne f
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BASES:'
.3.6.1 and 4.6.1
' Hydraulic Snubbers (cont'd)
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compounds, which should give satisfactory performance under the.most severe conditions expected in reactor installations.
To further increase the assurance of snubber reliability, functional tests should be performed once each refueling cycle.
These tests will include stroking of the s nubbers to verify proper piston movement, lock-up and biced. Ten percent or' t en snubbers, whichever is less, represents an adequate sample. for such tests.
Observed failures on these sampics should require. testing of additional units.
Those snubbers designated in Table 3.6.1 as being in high radiation areas or e specially difficult to remove need not be sc1ceted for functional tests provided cperability was previously verified.
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'(1). - Report 11. - R. Erickson,- Bergen 'l'aterson to K. R. Go11ct, NRC, October 7, 1974
' Subj ect: Hydraulic Shock Sway Arrestors m
e Tcble 3.6.1 SAFETY RELATED IIYDRAULIC SNUBBERS Snubber No.
Location Elevation Snubber'in liigh Snubbers Snubbers Snubbers Radiation Area Especially Inaccessible Accessible During Shutdown Difficult to During Normal During Normal Remove Operation Operation x
1 Main Steam Line 953'
-O x
2 Main Steam Lin~e 950' X
3 RilR 964' 4
RIIR 964' etc.
Recirculatory 922' x
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