ML20140C350
| ML20140C350 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/20/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-86-011, NUDOCS 8601270362 | |
| Download: ML20140C350 (6) | |
Text
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i KANSAS GAS AND ELECTRIC COMPANY THE ELECT % COMPANY GLENN L MOESTER vsCE Pet siormt - seuCLtam January 20, 1986 Mr. Barold R. Denton, Director Office of mclear Reactor Regulation U.S. m clear Regulatory Commission mshington, D.C.
20555 KMINRC 86-011 Re:
Docket No. STN 50-482 Subj: Partial Exenption to ASME Section XI Requirenents for Snubber Inspection
Dear Mr. Denton:
The purpose of this letter is to request a partial exenption to the inservice inspection (ISI) requirements of ASME Section XI, Subsection IKF purcuant to the provisions of 10 CPR 50.55a(g)(6)(i).
Wolf Creek Technical Specification 4.7.8 specifies surveillance requirenents for snubbers.
Technical Specification 4.7.8 also requires corpliance with Technical Specification 4.0.5 which invokes the ISI requirements of ASME Section XI.
Kansas Gas & Electric Conpany (KG&E) has reviewed the snubber inspection requirenents of both Technical Specification 4.7.8 and AmE Section XI and han found them to require similar inspections in the areas of visual inspections and functional testing.
Therefore, the requested exenption would allow inspection and functional testing of the snubbers, as defined below, to be perforned in accordance with Technical Specification 4.7.8 in lieu of ASME Section XI.
Visual and functional testing requirements for the snubbers are n
delineated in Technical Specification 4.7.8.
The attached table Jg provides a conparison between the visual and functional testing n on.
requirements of the Technical Specification and ASME Section XI. As 88 shown by this
- table, the applicable inspection and testing g
requirenents of AME Section XI are used as guidance for the Technical Specification surveillances. Also, the visual inspections performed in
@d accordance with the Technical Specifications cover all safety related and special scope snubbers and are performed more often than Section XI Mc visual inspections. Therefore, KG&E proposes to perform all functional 3
testing in accordance with the Technical Specification, and visual M*
gg inspections from the attachment to the foundation or supporting ca s.o structure through the snubber up to and including the fastener to the conponent clanp would also be in accordance with the Technical f
Specification.
Inspection of the conponent clanp and snubber support M structure will remain under the ASME Section XI ISI program. KG&E I vi believes that this approach to snubber inspections provides a
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conparable degree of safety to that specified in AME Section XI.
201 N, Market - Wichita, Kansas - Mail Address: RO. Box 208 i Wichita, Kansas 67201 - Telephone: Area code (316) 261-6451 L
Mr. H.R. Denton Page 2 January 20, 1986 KMLNRC 86-011 Granting of this exenption will eliminate unnecessary inspections resulting in a benefit to KG&E without any increase in risk to the health and safety of the p1blic.
The exenption will allow elimination of the duplicate record keeping required by both prograns.
The resulting reduced nunber of inspections will also reduce the radiation exposure to personnel over the lifetime of the station as well as reduce the operating costs to KG&E.
In conclusion, the snubber inspection requirements of Technical Specification 4.7.8 provide adequate assurance of the operability of snubber assenblies and provide a conparable degree of safety to that specified in AME Section XI.
Therefore, exenption from A9 E Section XI inspection and testing requirements will facilitate operation of Wolf Creek Generating Station, Unit No. 1 and will not pose any undue risk to the health and safety of the public.
A check for the $150.00 a wlication fee required by 10 CFR 170.21 is being transmitted under separate cover.
l Very truly yours, dif Glenn L. Koester Vice President-Naclear Attachment cc: PO' Conner (2), w/a JCumins, w/a l
L
STATE OF KANSAS )
) SS CITY OF WICHITA )
Glenn L. Koester, of lawful age, being first duly sworn upon oath says that he is Vice President - Nuclear and an Officer of Kansas Gas and Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said Company with full Power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By Glenn L. KoesEer Vice President - Nuclear SUBSCRIBED and sworn to before me this 20th day of January
, 198 6
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/a; N6tary Public
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Mr. H.R. Denton Page 1 Janu2ry 20, 1986 KMIM C 86-011 Enclosure COMPARISON OF TECHNICAL SPECIFICATION REOUIFDENTS A!O A91E SECTION XI REOUIREMENTS FOR EXAMINATION OF SNUNF'RS ASME SECTION XI REQUIRDIENPS
'IECHNICAL SPECIFICATION 1980 EDITION THROUGH ITHi REOUIREMENTS (4.7.8)
WINTER 1981 ADDEIOA I.
Visual Examination A.
Sanple Size All safety related and special Snubbers are selected for scope snubbers. (4.7.8.b) examination that are required to be examined under INB, INC and Im during first interval
( N -2500)
B.
Inspection First inspection to be between Snubbers selected for exam-Schedule 4-10 nonths after power opera-inntion are inspected during tion. Subsequent inspection each inspection interval (10 periods, vary between 31 days years) which has three in-and 18 nonths depending upon spection periods of 40 months the nunber of inoperable snub-each ( N -2500-1).
bers found in the previous in-spection period.
(4.7.8.b) i C.
Extent of Visual inspections shall include:
%e extent of examination is per Examination (a) Shubber M -1300 and Fig. M -1300-1. %is (b) Attachment to foundations or examination includes the snubber, 4
supporting structure all non-integral supports and 4
(c) Fasteners for attachment of integral supports connected to a the snubber to the couponent building structure up to the and to the snubber anchorage.
surface of the building structure.
(4.7.8.c) 4 1
Mr. H.R. Denton Page 2 January 20, 1986
~
KMINRC 86-011 Enclosure D.
Acceptance Visual inspections shall verify Conponent support conditions which that:
are unacceptable fo continued ser-(a) there are no visible indica-vice shall include the following tions of damage or inpaired (IhF-3410) :
operability.
(a) deformations or structural de-(b) attachments to the founda-gradations of fasteners, tion or supporting structure springs, clanps, or other sup-are functional, and port itens; (c) fasteners for attachment of (b) missing, detached, or loosened the snubbers to the conponent support itens; and to the snubber anchorage (c) arc strikes, weld spatter, are functional.
(4.7.8.c) paint, scoring, roughness,or general corrosion on close tolerance machined or sliding surfaces; (d) fluid loss beyond specified limits or lack of fluid indi-cation (hydraulic snubbers only)
(e) inproper hot or cold positions (snubbers and spring supports).
II. Functional Test A.
Sanple Size (a) At least 10% of the total A representative sanple of 10% of of each type shall be the total nunber of non-exenpt snub-functionally tested either bers shall be functionally tested in-place or in a bench test; (IhF-5400 (b)).
or (b) A representative sanple of each type of snubber shall be functionally tested in accord-ance with Figure 4.7-1; or (c) An initial representative sanple of 55 snubbers shall be functionally tested.
(4.7.8.e)
B.
Inspection First refueling shutdown and at Every inspection period of 40 months Schedule least once per 18 months there-(INF-5400(b)).
after during shutdown. (4.7.8.e)
Mr. H.R. Denton Page 3 January 20, 1986 100mc 86-011 Enclosure C.
Acceptance The snubber functional test shall
'Ihe snubber inservice test shall Criteria verify that:
verify that (1) Activation (restraining (1) Activation (restraining action) is achieved within action) is achieved within the specified range in both the specified range of tension and conpression and velocity or acceleration in both tension and conpression, and HYDRAULIC SNUBBER Ir/DRAULIC SNUBBER (2) Snubber bleed rate or (2)
Snutber bleed, or re]aase release rate where re-rate, where required, is quired, is present in within the specified range both tension and compres-in conpression or tension, or sicn within the specified range, or MECHANICAL SNUBBER MBCHANICAL SNUBBER (3) Force required to initiate (3) During low velocity dis-or maintain motion of the placenents, the specified snubber is within the speci-maxinum drag or free move-fled range in both directions ment force will initiate of travel. (4.7.8.f) motion of the snubber rod in both tension and conpres-sion. (Iw-5400(b)).
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