ML20207D242

Proposed Tech Specs Deleting Snubber Tables & Correcting Typos

ML20207D242
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/23/1986
From:	PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20207D165	List: ML20207D160 ML20207D189 ML20207D242
References
TAC-64439, NUDOCS 8612300357
Download: ML20207D242 (9)

Text

- - - - - - -

i ATTACHMENT 2 PROPOSED CHANGES b'

8612300357 861223 PDR ADOCK 05000267 P PDR

6 Fort St. Vrain #1

. Technical Specifications T '

Amendment No.

Page 4.3-7 i

Specification LC0 4.3.10 - Shock Suppressors (Snubbers) -

Limitine Condition for Operation t

a) The reactor shall not be operated at power unless all i

?

] l shock suppressors (snubbers) supporting Class I piping  !

l systems are operable except as noted in b) through d)

[

of this LCO.  !

i l l b) With one or more snubbers removed from service in a 4 ,

Class I system or subsystem, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace

.l or restore the snubber (s) to operable status. If one

l or more snubber (s) is found inoperable, within 72 l l hours replace or restore the inoperable snubber (s) and .

i perform an engineering evaluation per 5pecification SR I 5.3.8.c) on the supported component or declare the

supported system inoperable and follow the appropriate f action statement for that system.

1 c) If the requirements of a) and b) of this LCO cannot be j met, an orderly shutdown shall be initiated and the  ;

reactor sht11 be in a low power condition within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

i d) If a shock suppressor is determined to be inoperable ,

j while the reactor is in the shutdown or refueling i mode, the suppressor shall be made operable or replaced prior to reactor operation at power.

I l l

I i <

l I

i i

i

- Fort St. Vrain #1 Technical Specifications !

Amendment No. I Page 4.3-8 I 1

S

-s I l Basis for Specification LCO 4.3.10 Shock suppressors (snubbers) are designed to prevent unrestrained pipe motion under dyqamic loads, as ,might occur during an earthquake, while allowing normal thermal motion during startup and shutdown. The consequence of an inoperable snubber is an increase in the probability of structural damage to piping resulting from the dynamic loads produced by a seismic event. It is therefore {

recessary that all snubbers required to protect the Class I systems, subsystems, or components be operable '

during reactor power operation.

Because snubber protaction is required only during 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 repair or replacement. 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 low power condition will permit an orderly power reduction consistent with standard operating procedures. Since reactor operation at power should not be conducted with defective safety-related equipment, reactor power operation is prohibited with inoperable snubbers, except as stated above.

s k

, . - . . . - _ . ._ . , . . .....k,__._._.___ . _ _ . _ _ _ _ . . _ _ _ . _ _ _ _ . _ _

Fort St. Vrain #1

' Technical Specifications knendment No.

Page 5.3-9 activity level decreases to less than 10% of the limit of LCO 4.3.8, at which time weekly sas.pling may be resumed.

Basis for Specification SR 5.3.7 The specification surveillar.ce interval is adequate to monitor the activity of the secondary coolant.

Specification SR 5.3.8 - Shock Suppressors (Snubbers)

Surveillance The following surveillence requirements apply to all Class I piping. system shock suppressors (snubbers):

a) Visual Inspections The first in-service visual inspection of snubbers shall be performed within six months from issuance of l this Technical Specification (Amendment 39). For the purpose of entering the schedule described in this section, it shall be assumed that the facility had been on a six-month inspection interval.

l l

- -.- , - - ..m.,-- - - - - -- ~ , ,

Fort St..Vrain #1

. Technical Specifications Amendment No.

Page 5.3-10 The first in-service visual inspection of snubbers l shall include all Class I piping system snubbers. If less than two snubbers are found inoperable during the first in-service visual . inspection, the second in-service visual inspection shall be performed 12 months plus or minus 25% from the date of the first inspection. Otherwise, subsequent visual inspections shall be performed in accordance with the following schedule:

Number of Inoperable Snubbers per Inspection Subsequent Visual Period Inspection Period

• 0 18 Months plus or minus 25%

1 12 Months plus or minus 25%

2 6 Months plus or minus 25%

3, 4 124 Days plus or minus 25%

5,6,7 62 Days plus or minus 25%

8 or more 31 Days plus or minus 25%

• The inspection interval shall not be lengthened more than one step at a time.

b) Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that there are no visible indications of damage or impaired operability, (2) attachments to the . foundation or supporting structure are secure, and (3) in those locations where snubber movement can be manually induced without disconnecting the snubber, that the snubber has i freedom of movement and is not seized. Snubbers which appear inoperable as a result of visual i

l

Fort St. Vrain #1

, Tcchnical Sp:cifications Amendment No.

Page 5.3-11 inspections may be determined operable for the purpose of establishing the next visual inspection interval, providing that (1) the cause of .the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible, and (2) the affected snubber is functionally tested in the as-found condition and l determined operable per Sections 5.3.8.d) and 5.3.8.e). However, when the fluid port of a hydraulic snubber is found to be uncovered, the snubber shall be determined inoperable and cannot be determined OPERABLE via functional testing for the purpose of establishing the next visual inspection interval. All snubbers connected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.

c) Functional Tests At least once per 18 months (not to exceed 22 1/2 months),a representative sample of each type of snubber shall be tested using one of the following sample plans: The sample plan (s) shall be selected prior to the test period and cannot be changed during the test period. The NRC Regional Administrator shall be notified in writing of the sample plan (s) selected for each type of snubber prior to the test period or the sample plan (s) used in the prior test period shall be implemented:

1) At least 10% of the total of the type of snubber shall be functionally tested either in place or in a bench test. For each snubber of that type that does not meet the functional test acceptance criteria of Specification SR 5.3.8.d) or SR 5.3.8.e), an additional 10% of that type of i

I

Fort St. Vrain #1 Technical Specificaticns Amendment N3.

Page 5.3-15 f) Examption From Visual Inspection or Functional Tests Permanent or other exemptions from the survefilance prograe. for individual snubbers may be granted by the l Commission if a justifiable basis for exemption is l presented. #

I g) Record Keeping Record keeping shall consist of:

1) A hi storical record for each snubber shall be maintained.

2) Concurrent with the first in-service visual inspection and at least once per refueling cycle thereafter, the historical records for each l snubber shall be reviewed to determine any trends that may adversely affect service life.

3) The maximum expected service life for the various seals, seal materials, and applications shall be determined and established based on engineering information and the seals shall be replaced so that the maximum expected service life will not be exceeded during a period when the snubber is required to be OPERABLE. This monitoring program shall be fully implemented within 22 1/2 months  !

from the issuance of this Technical Specification (Amendment 39).

I ATTACHMENT 3 SIGNIFICANT HAZARDS CONSIDERATION L

f e

SIGNIFICANT HAZARDS CONSIDERATION I. Evaluation

~

The proposed changes to LC0 4.3.10 and SR 5.3.8 pertain to celeting the snubber tables from the Technical Specifictions and correcting typographical errors. This change is administrative and will have no effect on the ability of a shock suppessor to provide structural integrity of a safety related system during and following a seismic or other event initiating dynamic loads.

4.3.10.b has been changed to clarify the difference in requirements for intentionally removing a snubber from service and discovering an inoperable snubber. In the first case, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allows time for repair / replacement of snubbers during power operation, and no Engineering- Evaluation is required since the time period the snubber (s) are out of service is known.

If a snubber is found inoperable, the time it has been in this condition is in question. This requires an Engineering Evaluation to determine if any plant evolutions / transients which had occured (since operability was last verified) affected the associated piping / equipment.

II. CONCLUSION Based on the above evaluation, it is concluded that operation of Fort St. Vrain in accordance with the proposed changes will not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) increase the possibility of a new or different kind of accident from any accident previously evaluates, or (3) involve a significant reduction in any margin of safety. Therefore, this change will not increase the risk to the health and safety of the public nor does it involve any significant hazards consideration.

>