ML20206J823
| ML20206J823 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/15/1988 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20206J820 | List: |
| References | |
| NUDOCS 8811290131 | |
| Download: ML20206J823 (22) | |
Text
_ -
ATTACIMENT 1 PROPOSED CHANGES TO APPENDIX A TECHNICAL SPICITICATION FOR OUAD CLIIgs lTATION UNIIS_1 AND 2 FACILITY QPERATIHQ_, LICENSES _DPR-29 AND DPR-30 REYISED_PMES:
iv (DPR-29) 3.6/4.6-5b (DPR-29) 3.6/4.6-6 (DPR-29) 3.6/4.6-7 (DPR-29) 3.6/4.6-14 (DPR-29) 3.6/4.6-14a (DPR-29) 3.6/4.6-15 (DPR-29) 3.6/4.6-15a (DPR-29) Deleted 3.6/4.6-15b (DPR-29) Deleted 3.6/4.6-15c (DPR-29) Deleted 3.6/4.6-15d (DPR-29) Deleted 0.6/4.6-15e (DPR-29) Deleted 3.6/4.6-15f (DPR-29) Deleted i
3.6/4.6-159 (DPR-29) Deleted i
REVISED _EAGES:
IV (DPR-30) 3.6/4.6-5b (DPR-30) 3.6/4.6-6 (DPR-30) 3.6/4.6-7 (OPR-30) 3.6/4.6-14 (DPR-30) l 3.6/4.6-14a (DPR-30) 3.6/4.6-15 (DPR-30) 3.6/4.6-15a (DPR-29) Deleted 1
3.6/4.6-15b (DPR-29) Deleted 3.6/4.6-15c (DPR-29) Deleted 3.6/4.6-15d (DPR-29) Deleted 3.6/4.6-15e (DPR-29) Deleted a
a I
5063K 8811290131 881115 POR ADOCK 05000254 P
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QUAD CITZES OPR-29 TECHNICAL SPECIFICATIONS APPENDIX A LIS' 0F TABLES Number Title Page 3.1-1 Reactor Protection System (Scram)
Instrumentation Requirements-Refuel Mode 3.1/4.1-8 3.1-2 Reactor Protection System (Scram) Instrumentation Requirements-Startup/ Hot Standby Mode 3.1/4.1-9 3.1-3 Reactor Protection System (Scram) Instrumentation Requirements-Run Mode 3.1/4.1-10 3.1-4 Notes for Tables 3.1-1, 3.1-2, and 3.1-3 3.1/4.1-11 4.1-1 Scram Instrumentation and Logic Systems Functional Test-Minimal Functional Test frequencies for Safety Instrumentation, Logic Systems and Control Circuits 3.1/4.1-12 4.1-2 Scram Instrument Calibration-Minimum Calibration Frequencies for Reactor Protection Instrument Channels 3.1/4.1-14 3.2-1 Instrumentation that Initiates Primary Containment Isolation Functions 3.2/4.2-11 3.2-2 Instrumentation that Initiates or Controls the Core and Containment Cooling Systems 3.2/4.2-12 3.2-3 Instrumentation that Initiates Rod Block 3.2/4.2-14 3.2-4 Postaccident Monitoring Instrumertation Requirements 3.2/4.2-15 M -5 Radioactive Liquid Effluent Monitoring Instrumentation 3.2/4.2-15b 3.2-6 Radioactive Gaseous Effluent Monitoring Instrumentation 3.2/4.2-15e 4.2-1 Minimum Test and Calibration Frequency for Core and Containment Cooling Systems Instrumentation, Rod Blocks and Isolation 3.2/4.2-16 4.2-2 Postaccident Monitoring Instrumentalon Surveillance Requirements 3.2/4.2-18 4.2-3 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements 3.2/4.2-19 4.2-4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 3.2/4.2-20 4.6-1 Inservice Inspection Requirements for Quad-Cities 3.6/4.6-1f 4.6-2 Revised Withdrawl Schedule 3.6/4.6-21A 3.7-1 Primary Containment Isolation 3.7/4.7-20 3.7-2 Primary Containment Leakage Test Penetrations 3.7/4.7-23 4.8-1 Radioactive Gaseous Waste Sampling and Analysis Program 3.8/4.8-20 1423H
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QUAD-CETIES DPR-29 I.
Shock Suppressors (Snubbers)
I.
Shock Suppressors (Snubbers)
The following surveillance
[
requirements apply to all. snubbers on 1 safety related piping systems.
I.
During all modes of operation 1.
Visual inspections shall be except Shutdown and Refuel, all performed in accordance with the snubbers on safety related following schedule utilizing the piping systems shall be operable accepte ce criteria given by except as noted in 3.6.I.2 Specification 4.6.I.2.
following.
I 2.
From and after the time that a Number of Snubbers snubber is determined to be Found Inoperable Next inoperable, continued reactor During Inspection Required operation is permissible during or During Inspec-Inspection the succeeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> only if tion Interval Interval the snubber is sooner made operable.
0 18 months
+25%
3.
If the requirements of 3.6.I.1 and 3.6.I.2 cannot be met, an 1
12 months orderly shutdown shall be
+25%
initiated and the reactor shall be in a cold shutdown condition 2
6 months within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
325%
4.
If a snubber is determined to be 3,4 124 days l
inoperable while the reactor is 225%
in the Shutdown or Refuel mode, i
the snubber shall be made 5,6,7 62 days i
operable prior to reactor g25%
l startup.
i 28 31 days 325%
The required inspection leierval
~
sbs11 nct be lengthened more i
than one step at a time.
l Snubbers may be categorized in two groups, ' accessible' or t
' Inaccessible' based on their accessibility for inspection during reactor operation.
These 3
two groups may be inspected independently according to the i
above schedule.
i l
l 117ss 3.6/4.6-56 Amendment No.
QUAD-CITIES OPR-29 Snubber service life monitoring shall be followed by the snubber surveillance inspection records and maintenance history records.
The:above r.acord retention method shall be used
~to prevent the snubbers from exceeding a service life.
2.
Visual inspections shall verify:
/
a.
There are no visible indications of damage or impaired operability, and b.
Attachments to the foundation or supporting structure are secure.
3.
Once each refueling cycle a representative sample of 10% 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 that does not meet the functional test criteria, an additional 10%
of that type of snubber shall be functionally tested.
~~
4.
The mechanical snubber functional tests shall verify:
a.
That the breakaway force that initiates free movement of the snubber rod in either tension or compression is less thtn the specified maximum force.
b.
That the activation (restraining action) is achieved within the specified range of acceleration in both tension and compression.
11788 3.6/4.6-6 Amendment No.
e-
QUAD-CITIES DPR-29 5.
When a snubber is deemed inoperable, a review shall be conducted to determine the mode of failure and to decide if an engineering-evaluation should be performed.
If the engineering evaluation is deemed neces-sary, it will determine whether or not the snubber mode of failure has imparted a significant effect or degradation on the supported component or system.
6.
If any snubber selected for l
functional testing either falls to lockup or fails to move.
i.e., frozen in place, the cause will be evaluated and if determined to be generically deficient all snubbers of the same design, subject to the same defect shall be functionally tested.
7.
In addition to the regular sample, snubbers which failed the previous functional test shall be retested durtoo the next test period.
If a spare snubber has kaen installed in place of a failed snubber, then both the failed snubber (if it is repaired and installed in another position) and the spare snubber shall be retested.
Test results of these snubbers may not be included for the I
resampling.
t l
11788 3.6/4.6-7 Amendment No.
QUAD-CZTIES DPR-29 I. Snubbers All snubbers are required OPERABLE to ensure that the
- tural 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.
Snubbers excluded from this inspection program are those installed on non-safety-related systems and then only 1f their failure or failure of the system on which they are installed, would have no adverse effect on any safety-related system.
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 by the number of inoperable snubbers found during an inspection.
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 257.) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.
Snubber service life monttoring will be followed by the existing snubber survelliance inspection records and maintenance history records.
The above record retention method should be used to prevent the mechanical snubbers from exceeding a service life of 40 years.
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 generically susceptible, and verified by inservice 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.
To provide assurance of snubber reliability, a representative sample of the installed snubbers will be functionally tested during plant shutdowns at refueling cycle intervals.
Functional testing of the mechanical snubber will i
i consist of verification that the force that initiates free movement of the snubber in either tension or compression is less than the maximum breakaway friction force and verification that the activation (restraining action) is achieveo wtthin the specified range of acceleration in both tension and l
compression.
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l 11788 3.6/4.6-14 Amendment No.
l t
QUAD-CfTZES OPR-29 When a snubber is found inoperabic, a review shall be performed to determine the snubber mode of failure.
Results of the review shall be used to determine if an engineering evaluation of the safety-related system or component is necessary;.The. engineering evaluation shall determine whether or not the snubber.' mode of failure has imparted a significant effect or degradation on the support component or system.
Observed failures of these sample snubbers shall require functional testing of additional units.
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I 11785 3.6/4.6-14a Amendment No.
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QUAD CITIES OPR-30 TECHNICAL SPECIFICATIONS APPEN0lX A LIST OF TABLES Number Title Page 3.1-1 Reactor Protection Systen (Scram)
Instrumentatlon Requ'.rMants-Refuel Mode 3.1/4.1-8 3.1 2 Reactor Protection Sn tem (Scram) Instrt. mentation Requirements-StartucMat Standby Mode 3.1/4.1-9
' 1-3 Reactor Protection.6vitem (Scram) Instrumentation Requirements-Run Mde 3.1/4.1-10 3.1-4 Notes for Tab es 3,1-1, 3.1-2, and 3.1-3 3.1/4.1-11 4.1-1 Scram Instrumentation ar.d Logic Systems Functional Test-Minimal Fuactional Test Frequencies for Safety Instrumentation. Logic Systems, and Contro Circuits 3.1/4.1-12 4.1-2 Scram Instrurstnt Calibration-Minimum Calibration Frequencies for Reactor Protection Instrument Channels 3.1/4.1-14 3.2-1 Instrumentation that Initiates Primary Containment Isolation functions 3.2/4.2-11 3.2-2 Instrumentation that Initiates or Controls the Core and Containment Cooling Systems 3.2/4.2-12 3.2-3 Instrumentation that Initiates Rod Block 3.2/4.2-14 l
3.2-4 Postaccident Monitoring Instrumentation Requirements 3.2/4.2-15 3.2-5 Radioactive Liquid Effluent Monitoring Instrumentation 3.2/4.2-15b 3.?-6 Radioactive Gaseous Effluent Monitoring i
Instrumentation 3.2/4.2-15c 4.2-1 Minimum Test and Calibration Frequency for Core and Containment Cooling Systems Instrumentation, Rod Blocks 3
and isolation 3.2/4.2
'.6 4.2-2 Postaccident Monitcring Instrumentalon Surveillance l
Requirements 3.2/4.2-1b 4.2-3 Radioactive Liquid Effluent Monitoring Instrumentation i
Surveillance Requirements 3.2/4.2-19 4.2-4 Radioactive Gasecus Eff!uent Monitoring Instrumentation Surveillance Requirements 3.2/4.2-20 i
4.6-1 Intervice Inspection Raquirements for Quad-Cities 1.6/4.6-IT 4.6-2 Revised Withdrawl Schedule
.. /4.6-21A 3.7-1 Primary Containment Isolation 3.7/4.7 20 3.7-2 Primary Containment Le4Aage Test Penetrations 3.7/4.7-23 4.8-1 Radioactive Gaseous Waste 4
$ampling and Analysis Program 3.8/4.8-20 1423H Iv
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F, QUAD-CITIES DPR-30 I.
55ock Suppressors (Snubbers)
I.
Shock Suppressors (Snubbers)
The following surve
- e requirements apply to all snubbers on safety related piping' systems.
1.
During all modes of cperation 1.
Visual inspections shall be except Shutdown and Refuel, all performed in accordance with the snubbers on safety related following schedule utilizing the pipt'g systems shall be operable acceptance criteria given by except as noted in 3.6.I.2 l
Specification 4.6.I.2.
l following.
2.
From and after the time that a Number of Snubbers snubber is determined to be Found Inoperable Next inoperable, continued reactor During Inspection Required operation is permissible during or Ouring Inspec-Inspection the succeeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> only if tion Interval Interval the snubber is sooner made cperable.
0 18 months 125%
.s.
If the requirements of 3.6.I.1 and 3.6.I.2 cannot be met, an 1
12 months orderly shutdown shall be 125%
initiated and the reactor shall be in a cold shutdown condition 2
6 months within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
125%
4.
If c snubber is determiaed to be 3,4 124 days inoperable while the reactor is 125%
in the Shutdown or Refuel mode, the snubber shall be made 5,6,7 62 days operable prior to reactor 125%
startup.
18 31 days 125%
The required inspection interval shall not be lengthened more than one step at a time.
Snubbers may be categorized in two groups, ' accessible' or
' inaccessible' based on their accessibility for inspection during reactor operation. These two groups may be inspected Independently according to the above schedule.
11783 3.6/4.6-Sb Amendment No.-
~
QUAD-CITIES
' OPR-30 Snubber service life monitoring shall be followed by the snubber surveillance inspection records and maintenance history records.
The above record i
retention method shall be used to prevent the snubbers from exceeding a service life.
2.
Visual inspections shall verify:
i a.
There are no visible I
indications of damage or impaired operability, and b.
Attachments to the foundation or supporting structure are secure.
3.
Once each refueling cycle a representative sample of 10% of the total of each type of snubber in use in the plant i
shall be functionally tested l
either in place or in a bench test.
For each snubber that does not meet the functional test criteria, an additional 10%
of that type of snubber shall be functionally tested.
4.
The mechanical snubber functional tests shall verify:
a.
That the breakaway force that initiates free movement of the snubber rod in either tension or compression is less than the speelflad maximum force, b.
That the activation (restraining action) is achieved within the specified range of acceleration in both tension and compression.
9 11788 3.6/4.6-6 Amendment No.
@AD-CITIES DPR-30 5.
When a snubber is deemed inoperable, a review shall be conducted to determine the mode of fa'. lure and to decide if an engineering evaluation should be performed.
If the engineering evaluation is deemed neces-sary, it will determine whether or not the snubber mode of failure has imparted a significant effect or degradation on the supported component or system, 6.
If any snubber selected for functional testing either fails to lockup or falls to move, i.e., frozen in place, the cause will be evaluated and if determined to be generically officient all snub 5ers of the same design, subject to the same defect shall be functionally tested.
7.
In addition to the regular sample, snubbers which failed the previous functional test shall be retested during the next test period.
If a spare snubber has been installed in L
place of a failed snubber, then both the failed snubber (if it is repaired and installed in another position) and the spare snubber shall be ratested.
Test results of these snubbers may not be included for the i
resampilng.
l l
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l 11788 3.6/4.6-7 Amendment No.
l l
QUAD-CfTIES OPR-30 I. Snubbers All snubbers are required OPERABl.i to ensure that the 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.
Snubbers excluded from this inspection program are.those installed on non-safety-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.
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 ietermined by the number of inoperable snubbers found during an inspection.
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 257.) may not be used to lengthen the required inspection interval.
Any inspection whose results require a shorter inspection interval will override the previous schedule.
Snubber service life monitoring will be followed by the existing snubber surveillance inspection records and maintenance history records.
The above record retention method should be used to prevent the mechanical snubbers from exceeding a service life of 40 years.
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 generically susceptible, and verified by inservice functional testing, ; bat 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 ir,ubber by visual inspection, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.
To provide assurance of snubber reliability, a representative sample of the installed snubbers will be functionally tested during plant shutdowns at refueling cycle intervals.
Functional testing of the mechanical snubber will consist of verification that the force that initiates free movement of the snubber in either tension or compression is less than the maximum breakaway friction force and verification that the activation (restraining action) is
~
achieved within the specified range of acceleratier,in both tension and compression.
11788 3.6/4.6-14 Amendment No.
s-QUAD-CITZES OPR-30 When a snubber is found inoperable, a review shall be performed to determine the snubber mode of failure.
Results of the review shall be used to determine if an engineering evaluation of the safety-related system or component is necessary.
The engineering evaluation shall determine whether or not~the snubber mode of failure.has imparted a significant effect or degradation on the support component or system.
Observed failures of these sample snubbers shall require functional testing of additional units.
9 11788 3.6/4.6-14a Amendment No.
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ATTACIMENT_2 SUlelARLOLCllAtlGES A total of forty-six (46) changes to the Quad Cities Station Units 1 and 2 Technical Speelfications have been identified (twenty-four (24) for Unit 1 and twenty-two (22) for Unit 2) and are listed below as follows:
1.
P ag e._1y,_Li sLoL 2nld e s_4_.DIR - 21a nd_10 (a) Under "List of Tahta ",
'41-t= Item 3.6-1, Safety Related Shock Suppressors (Snubbers), 3.6/4.6-15.
This change reflects the recommendations of Generic Letter 84-13 by deleting the snubber tables from the List of Tables in the Technical Specifications.
2.
Page 1 1Liis_5h,_DPR-29 and_3Q (a) Limiting Conditions for Operation (LCO),
3.6.I.1.
- Delet,e "listed in Table 3.6-1" and replace with "on safety related piping systems", so the sentence now reads, "During all modes....on safety related piping systems....in 3.6.I.2 following."
This change deletes the reference to the snubber table from the Technical Specifications.
(b)
LCO, 3.6.I.1. - Replace "3.6.1.1" and "3.6.1.2" with "3.6.I.1" and "3.6.1.2".
This change corrects an existing typographical error and is considered to be an administrative change.
(c)
LCO, 3.6.I.5. - Delete in its entirety.
As a result of removing the snubber tables from the Technical Specification, no reference is needed regarding how snubbe, additions may be added to the tables.
(d) Surveillance Requirements (SR), 4.6.I. - Delete "listed in Table 3.6-1" and trolace with "on safety related piping systems", so the sentence now reads "The following....to all snubbers on safety related piping systems."
This change teruits from the deletion of the snubber tables from the Technical Speelfications.
(e) SR 4.6.I.1.
- Replace "4.6.1.2." with "4.6.1.2.".
This change corrects an existing typographical error.
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' 3.
P_ age 3.6/4.6-6 DPR-29_and_1Q (a)
SR 4.6.I.2.c. - Delete Item c.
In its entirety.
This change reflects the fact that hydraulic snubbers are no longer utilized at Quad Citles Station.
(b) SR 4.6.I.4. - Delete Item in its entirety as Quad Cities Station no longer utilizes hydraulic anubbers.
(c) SR 4.6.I.5. - Renumber Technical Specification "4.6.I.S." to "4.6.I.4."
This change is a result of the deletion of a previous Item (Item 3(a)) and is an administrative change.
4.
Eage 3.6/4.6-7. DER-29 and 3D (a) SR 4.6.I.6. - Renumber "4.6.I.6."
to "4.6.I.5."
This change is a result of the change identified in Item 3(a) and is an administrative change.
(b)
SR 4. 6. I. 7. - Renumbe r "4. 6. I. 7. " to 4. 6. I. 6. ".
This change is a result of the change identified in Item 3(a) and is an administrative enange.
(c)
SR 4.6.I.8. - Renumber "4.6.I.8." to 4.6.I.7.".
This change is a result of the change identified in Item 3(a) and is an administrative change.
5.
En g e_1._ftLi tft-14, _ DER: 21_ an d_3 Q (a) Bases - Third paragraph, third line, delete "the hydraulic snubber from exceeding e service life of 10 years and".
This change deletes reference and requirements for hydraulic anubbers from the Bases to the Technical Speelfications.
(b) rifth paragrapi, third line - Delete "Hydraulle snubber functional testing... lock up and bleed".
This change deletes reference and requirements for hydraulle snubbers from the Bases to the Technical Specifications.
-3 (c) rifth paragraph, seventh line - Delete period and the next sentence which begins with "the remaining portions of the functional test consisting of" insert "and", delete "will not be done.", so the sentence now reads, "runctional Testing of the mechanical snubber.... friction force and verification that....in both tension and compression."
This change deletes reference and requirements for hydraulle snubbers from the Bases to the Technical Specifications.
(d) rifth paragraph, tenth line - Delete the sentence "This is due to the lack of competitive marketable test equipment available for Station use.
This change deletes reference and requirements for hydraulle snubbers from the Bases to the Technical Specifications.
6.
Page_id/_416:14 a,_ DER:21_and_JD (a) Third paragraph - Delete the sentence "Hydraulle snubbers and mechanical snubbers may be each treated as a different entity for the above surveillance program."
This sentence is no longer needed as Quad Cities Station does ns use hydraulle snubbers.
7.
Eage 3. 6 /4.1-15,_EEIL-21_and_30 Delete page containing Table 3.6-1 to reflect recommendations of Generic Letter 84-13.
8.
Eage_1._6 Lid -lhai_ DER-2Lond_J Q Delete page containing Table 3.6 1 to reflect recommendations of Generic Letter 84-13.
9.
Page_116L4 d=15h._DTR-ZLond._30 Delete page containing Table 3.6-1 to reflect recommendations of Generic Letter 84-13.
10.
Page_2.fl.i ts:15m_ Dth 2 Lond_30 Delete page continining Table 3.6-1 tt, reflect recommendations of Generic Letter 84-13.
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. 11.
Enge 3.6/4.6-15d. DPR-29 and 30 Delete page containing Table 3.6-1 to reflect recomendations of Generic Letter 84-13.
12.
EAge 3.6/4.6-15c. DPR-29,_Qnly Delete page contcIning tem.: 1.6-1 to reflect recomendations of Generic Letter 84-13.
13.
hge 3.6-15e. DPR-30_ODly Reissue page as page 3.6-15 to reflect changes identified in Items 7 through 11.
14.
Enge_.L 6L(26-15 k DER-29_Qaly Delete page containing Table 3.6-1 to reflect recommendations of Generic Letter 84-13.
15.
Eage 3.6-15g. DPR-29_Only Reissue page as page 3.6-15 to reflect changes identified in Items 7 through 12 and Item 14.
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ATIACIMENT_3 DESCRIEII0tLDLERDEQSED RiENDMINT_REQUIST There are three types of chenges associated with the proposed license snendment. The first is a result of the recommendations of Generic Letter 84-13; the second change removes references to hydraulle snubbers while the last type of change portains to the correction of typographical errors and renumbering of Technical Specifications.
Commonwealth Edison proposes to amend Operating Licenses DPR-29 and DPR-30 for Quad Cities Station to conform with the requirements of Generic Letter 84-13 which allows the deletion of Snubber Tables from the Technical Specifications.
The proposed Technical Specification change does not represent a significant change in acceptance criteria or safety margins.
This Technical Specification change for thJ deletion of Snubber Table 3.6-1 and Hydraulic Snubber test requirements will not decrease the safety margin of the integrity of the piping systems because no decreate in snubber functional and visual testing sequirements is proposed.
The proposed Technical Specification change is in response to an NRC reassessment which concludes that such Technical Specification listings are not necessary, provided that the Technical Specification is modified to specify what snubbers are required to be operable. This will be accomplished by changing the Technical Specification references to Table 3.6-1 to a statement that specifies "all snubbers on safety-related piping systems".
The record of installed safety related snubbers will be meinteined within the control of Ouad Cities Administrative procedure 6 in urder to comply with the surveillance requirements of paragraph 4.6.I.1.
The test requirements for hydraulle snubbers are no longer needed by the St.ation since the total population of snubbers on safety-related piping systems consist of mechanical snubbers. Therefore, the proposed Technical Specification change will delete all references to hydraulic snubbers due to the inapplicability of this type of snubber to the station's current as-built condition of safety-related systems. This change is considered to be administrative in nature.
Similarly, several typographical errors have been corrected and some specifications have been renumbered as a result of the deletion of the hydraulle snubbers from the Technical Specifications.
These changes are also a6ministrative changes.
These changes have been reviewed by Commonwealth Edison and we believe that they do not present a Significant Hasards Consideration.
The basis for our determination is documented as follows:
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- BASIS _E0fLNQ_ElGNIf_IfANT_HAZARDLCCtlEIDERATION Commonwealth Edison has evaluated this proposed snendment and determined that it involves no significant hasards consideration.
In I
accordance with the criterla of 10 CTR 50.92(c), a proposed amendment to an operating license involves no significant hasards consideration if operation of the facility, in accordance with the proposed snendment, would note 1)
Involve a significant increase in the probability or consequences of an accident prevlously evaluated because:
(a) The intent of the testing of snubbers has not changed. The current functional and visual testing of snubbers will not be affected. The proposed change transfers the official record of installed safety-1 related snubbers from the Technical Specifications to the control of Quad Cities Administrative procedures. All references to the tablo in the Technical Specification text has been revised to a reference which states "all snubbers on safety-related piping system".
i The proposed change will also remove all references to hydraulle snubbers. The intent of snubber testing will not be affected because the station does not have hydraulic anubbers installed on safety-related piping systems. This change is considered to be an administrative change to the Technical Specifications.
Therefore these changes do not significantly increase the probability or consequences of previously evaluated accidents.
(b) The other changes to the Technical Speelfications, which include the renumbering of other inter-related portions of the Technical Specifications (which were affected by the proposed change) and the l
correction of ty90 graphical errors, are considered to be administrative in nature.
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2)
Create the possibility of a new or different kind of accident from any accident previously evaluated because:
I (a) This proposed unendment does not change the methods or amount of snubbers tested, and since the snubber listing will be documented and controlled in a separate administrative procedure, the snubber l
integrity will still be maintained.
Also, since the station does l
l not have hydraulle snubbers installed on safety-related systemn, the removal of all references to this type of snubber will not impact the intent of snubber testing. Therefore, this does not create the I
possibility of a new or different kind of accident than previously e*raluated, i
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(b) The other types of changes noted in the proposed unendment are administrative in nature.
3)
Involve a significant reduction in the margin of safety because (a) The proposed Technical Specification change does not change the intent, methods, or quantity of the snubbers to be tested sAnce the change only removes the snubber tabular listing. Also, since the station does not have hydraulic snubbers installed on safety-related systems, the removal of all references to this type of snubber will not impact the intent of snubber testing.
So therefore, the margin of safety will not be adversely affected.
(b) These changes are administrative and therefore do not impact the margin of safety.
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l Therefore, rince the proposed license amendment satisfles the criteria specified in 10 CFR 50.92, Commonwealth Edison has determined that a no significant hasards consideration exist for these items. We further request their approval in accordance with the provisions of 10 CFR 50.91(a)(4).
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