ML20215F435
| ML20215F435 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 06/05/1987 |
| From: | DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20215F424 | List: |
| References | |
| NUDOCS 8706220381 | |
| Download: ML20215F435 (27) | |
Text
ATTACHMENT I PROPOSED TECHNICAL SPECIFICATION REVISION AND DESCRIPTION'0F AMENDMENT REQUEST l
'8706220381 870605 PDR ADOCK 05000369 P PDR
Description of Amendment Request
'The proposed revision to the McGuire T.S. would:
- 1) Delete snubber Tables 3.'7-4a and 3.7-4b from the T.S.
- 2) Add . the following statement to Section 4.7.8.e Functional Testing.
The large bore steam generator hydraulic snubbers shall be tested as a separate population for functional test purposes. A 10% random sample from previously untested snubbers shall be tested at least once per refueling outage with continued testing based on failure evaluation. Once the whole population has been' subjected to functional testing, the testing sequence shall begin anew by random selection based on the total population.
- 3) Modify T.S. 3.7.8 which currently reads, "All snubbers listed in Tables 3.7-4a;and 3.7-4b shall be operable." to read "All snubbers shall be operable. The only snubbers excluded from the requirements are those installed'on non-safety related systems and then only if the failure of the system on which they are installed would not have an adverse effect on any_
safety related system."
- 4) Delete the reference to Tables 3.7-4a and 3.7-4b in Section 4.7.8.b second paragraph and delete the reference to Tables 3.7-4a and 3.7-4b in Section 6.10.2.k Administrative Controls. "
- 5) Revise the Bases of T.S. 3/4.7.8 Snubbers to delete the requirement to list exempted snubbers in Tables 3.7-4a and 3.7-4b.
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PLANT SYSTEMS 3/4.7.8 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.8 All snubbers lis+=a ia .:: .. L :. .m n '- shall be OPERABLE..W. Inset a++nc.ked y APPLICABILITY: MODES 1, 2, 3, and 4. MODES S and 6 for snubbers located on systems required OPERABLE in those MODES.
ACTION:
With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber (s) to OPERABLE status and perform an engineering evaluation per Specification 4.7.8g. on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.
SURVEILLANCE REQUIREMENTS 4.7.8 Each snubber shall be demonstrated OPERABLE by perform.ance of the following augmented inservice inspection program and the requirements of Specification 4.0.5. .-
of the same design and manufacturer, irrespective of capacity,
- b. Visual Inspections Snubbers are categorized as inaccessible or accessible during reactor .
I operation and may be treated independently. The accessibility of each snubber shall be determined and approved by the Station Health f Physicist or qualified designee prior to performing each visual {
inspection. The determination shall be based upon the then existing radiation levels in each snubber location and the expected time to perform the visual inspection and shall be in accordance with the recommendations of Regulatory Guides 8.8 and 8.10.
The first inservice visual inspection of each type of snubber shall be performed after 4 months but within 10 months of commencing POWER 4- T_:,1;. N and OPERATION and shall include all snubbers.listan M If less than two snuobers of each type are found inoperable
~ during the first inservice visual inspection, the second inservice l i
visual inspection shall be performed 12 months t 25% from the date of the first inspection. Otherwise, subsequent visual inspections shall be performed in accordance with the following schedule:
I
.McGUIRE - UNITS 1 and 2 3/4 7-18
The only snubbers excluded from the requirements are those installed on non-safety related systems and then only if the failure or the failure of the system on which they are installed would not have an adverse effect on any safety related system.
0**
kr.Zn$m ab ,0agoc3rS 0h PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
No. Inoper.able Snubbers of Each Time Until Subsequent Type Found During Inspection Visual Inspection *# i 0 18 months 1 25%
1 12 months i 25%
2 6 months 1 25%
3,4 124 days t 25%
5,6,7 62 days t 25%
8 or more 31 days t 25%
- c. Refuelino Outage Inspections At each refueling, the systems which have the potential for a severe dynamic event, specifically, the main steam system (upstream of the main steam isolation valves) the main steam safety and power-operated relief valves and piping, auxiliary feedwater system, main steam supply to the auxiliary feedwater pump turbine, and the letdown and charging portion of the CVCS system shall be inspected to determine if there has been a severe dynamic event. In case of a severe dyr.amic event, mechanical snubbers in that system which experienced the ,
event shall be inspected during the refueling outage to assure that the mechanical snubbers have freedom of movement and are not frozen up. The inspection shall consist of verifying freedom of motion using one of the following: (1) manually induced snubber movement; (2) evaluation of in-place snubber piston setting; (3) stroking the mechanical snubber through its full range of travel. If one or more mechanical snubbers are found to be frozen up during this inspection, those snubbers shall be replaced or repaired before returning to power. The requirements of-Specification 4.7.8b. are independendent of the requirements of this specification,
- d. Visual Inspection Acceptance Criteria Visual inspections shall verify: (1) that there are no visible indications of damage or impaired OPERABILITY, and (2) attachments to the foundation or supporting structure are secure. Snubbers which appear inoperable as a result of visual inspections may be determined OPERA 8LE for the purpose of establishing the next visual inspection interval, provided that: (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible;
- The inspection interval for each type of snubber shall not be lengethened more than one step at a time unless a generic problem has been identified and corrected; in that event the inspection interval may be length _ened one j step the first time and two steps thereafter if no inoperable snubbers of j that type are found. l
- The provisions of Specification 4.0.2 are not applicable.
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McGUIRE - UNITS 1 and 2 3/4 7-19
PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
- d. Visual Inspection Acceptance Criteria (Continued) and (2) the affected snubber is functionally tested in the as found When a condition and determined OPERABLE per Specification 4.7.8f.
fluid port of a hydraulic snubber is found to be uncovered the snubber shall be declared inoperable and shall not be determined OPERABLE via functional testing unless the test is started with the piston in the as-found setting, extending the piston rod in the tension mode direction. All snubbers connected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.
- e. Functional Tests During the first refueling shutdown and at least once per refueling thereafter, a representative sample of snubbers shall be tested using one of the following sample plans. The sample plan shall be selected prio- to the test period and cannot be changed during the test period. The NRC shall be notified of the sample plan selected. -
prior to the test period. -X nw.,f. cd4Qd
- 1) At least 10% of the snubbers required by Specification 3.7.8 shall be functionally tested either in place or in a bench test. For each snubber that does not meet the functional test Oe acceptance criteria of Specification 4.7.8f., an additional 10%
of the snubbers shall be functionally tested until no more failures are found or until all snubbers have been functionally tested; or
- 2) A representative sample of the snubbers required by Specifica-tion 3.7.8 shall be functionally tested in accordance with Figure 4.7-1. "C" is the total number of snubbers found not meeting the acceptance requirements of Specification 4.7.8f '
(failures). The cumulative number of snubbers tested is (
denoted by "N." Test results shall be plotted sequentially in )
l the order of sample assignment (i.e., each snubber shall be (
plotted by its order in the random sample assignments, not by the order of testing). If at any time the point plotted falls (
) l l
l in the " Accept" region, testing of snubbers may be terminated.
When the point plotted lies in the " Continue Testing" region, ) l j
additional snubbers shall be tested until the point falls in the \/ l
" Accept" region, or all the snubbers required by Specifica- \ l Testing equipment failure during tion 3.7.8 have been tested. l functional testing may invalidate that day's testing and allow '
that day's testing to resume anew at a later time, providing all snubbers tested with the failed equipment during the day of equipment failure are retested; or 3)
An initial representative sample of fifty-five (55) snubbers shall be functionally tested. For each snubber which does not meet the functional test acceptance criteria, another sample of 3/4 7-20 Amendment No. 46 (Unit 1)
McGUIRE - UNITS 1 and 2 Amendment No. 27 (Unit 2)
The large bore steam generator hydraulic snubbers shall be tested as a separate population for functional test purposes. A 10% random sample from previously untested snubbers shall be tested at least once per refueling outage with continued testing based on failure evaluation. Once the whole population has been subjected to functional testing, the testing sequence shall begin anew by random selection based on the total population.
f
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- [dr Ebnyt uN1 fyys.str $
PLANT SYSTEMS .
SURVEILLANCEREQUIREhENTS(Continued) .
- e. Functional Tests (Continued) at least one-half the size of the initial sample shall ce testeo until the total numoer tested is equal to the initial samole si:e multiplied by the f actor,1 + C/2, wnere "C" is the numoer of snubbers found which do not meet the functional test acceptance criteria. This plan be plotted using an " Accept" line whicn follows the equation N = 55(1 + C/2). Each snubber should be plotted as soon as it is tested. If the point plotted falls on or below the " Accept" line, testing may be discontinued. If the coint plotted falls above the "Accoot" line, testing must continue ,
unless all snubbers have been tested.
The representative samples for the functional test sample plans shall be randomly selected from the snubbers required by Specifi-cation 3.7.8 and reviewed before beginning the testing. The review shall ensure as far as practical that they are representative of the various configurations, operating environments, range of sizes, and .
capaci ties. Snubbers placed in the same locations as snubbers which '
failed the previous functional test shall be retested at the time of.
the next functional test but shall not be included in the sample plan. If during the functional testing, additional sampling is required due to failure of only one type of snubber, the functional testing results shall be reviewed at that time to determine if additional samples should be limited to the type of snuDber which has failed the functional testing.
- f. Functional Test Acceptance Criteria The snubber functional test shall verify that:
- 1) Activation (restraining action) is achieved within tne specified range in both tension and compression, except that inertia dependent, acceleration limiting mechanical snuceers may be tested to verify only that activation takes place in both directions of travel;
- 2) Snubber bleed, or release rate where required, is present in both tension and compression, within the specified range;
- 3) Where required, the force required to initiate or maintain motion of the snubber is within the specified range in cath direction of travel; and
- 4) For snubbers specifically required not to displace under continuous load, the ability of the snuober to withstand load j without displacement.
Testing methods may be used to measure parameters indirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods, g, Functional Test Failure Analysis An engineering evaluation shall be made of each failure to meet the functional test acceptance criteria to determine the cause of the Amendment No. 1 (Unit 2) 3/4 7-21 Amendment No. 20 (Unit 1)
McGUIRE - UNITS 1 and 2 4/13/83
1, Ehr]5/Nr/w hfffJd 5 h l
l l
PLANT SYSTEMS .
SURVEILLANCE REQUIREMENTS (Continued) f l
- g. Functional Test Failure Analysis (Continued) ,
l I
failure. The results of this evaluation shall be used, if l l
applicable, in selecting snubbers to be tested in an effort to
' deterisine the OPERABILITY of other snubbers irrespective of type which may be subject to the same failure mode.
For the snubbers found inoperable, an engineering evaluation shall be performed on the components to which the inoperable snubbers are attached. The purpose of this engineering evaluation shall be to determine if the components to which the inoperable snubbers are attached were adversely affected by the inoperability of the snubbers in order to ensure that the component remains capable of meeting the j designed service. j l
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If any snubber selected for functional testing eith6r fails to ]
activate or fails to move, i.e., frozen-in-place, the cause will be ~ l evaluated and, if caused by manufacturer or design deficiency, all l snubbers of the same type subject to the same defect shall be evaluated j in a manner to ensure their OPERABILITY. This testing requirement {
shall be independent of the requirements stated in Spacification 4.7.8e. , j for snubbers not meeting the functional test acceptance criteria.
- h. Functional Testing of Repaired and Replaced Snubbers 1
Snubbers which fail the visual inspection or the functional test j acceptance criteria shall be repaired or replaced. Replacement j snobbers and snubbers which have repairs which might affect the {
j functional test result shall be tested to meet the functional test i criteria before installation in the unit. Mechanical snubbers shall !
have met the acceptance criteria subsequent to their most recent 1 service, and freedom-of-motion test must have been performed within 12 months before being installed in the unit.
I
- i. Snubber Seal Replacement Program f
I The seal service life of hydraulic snubbers shall be monitored to '
ensure that the service life is not exceeded between surveillance inspections. The expected service life for the various seals, seal materials, and applications shall be determined and established i j
based on engineering information and the seals shall be replaced so that the expected service life will not be exceeded during a period {
when the snubber is required to be OPERABLE. The seal replacements ;
j shall be documented and *.he documentation shall be retained in accordance with Specification 6.10.2. J l
l McGUIRE - UNITS 1 and 2 3/4 7-22 ;
Delvle Po .c u
ANT SYSTEMS TABLE 3.7-da.
SAFETY-RELATED HYORAULIC SNUBBERS
- ITT-GRINNELL MEDIUM SIZE RGE SIZE SMALL SIZE (45,500 lbs. to (1,250 lbs. or Less (10,350 lbs. to 27,300 lbs) 68,200 lbs)
SYSTEM **
TO 3,000 lbs)
UNIT 1 1 0 5
AS 1 1 43 88 4 0 CA 60 .
KC -
0 0 1
KD 0 0 3
KF 1 0 2
KR 0 0 8
LD 0 0 42 #
NB 5 8 58 NC 8 0 3
ND 0 0 6
NF 13 0 58 NI 0 24 NM 1 0 16 NS j 3 0 102 NV 10 8 0 f RN e added or deleted without prior License Ame ent to Table 3.7-ta
- Snubbers may next License provided t t a revision to Table 3.7-4a is included with t In lieu of any other report required by ecification 6.9 . . ,
Amendment equest. Special 5 days prior to the deletion of any listed snubber, at least hall dance with Report be prepared and submitted to the Commission in ace Speci ication 6.9.2 evaluating the safety significance of the pro osed snu er removal. l e
- A isting of individual snubbers and more detailed information shal vailable for NRC review at the McGuire Nuclear Station.
2,755,000 lb. also exempt fro Plus 8_ steam gen. -- Paul-Monroe, Hyd. Size functional testing.
outTg 1 -ma 9 1/4 7-91 u i]ee
DeO Sg C7
)
ANT SYSTEMS ]
l TABLE 3.7-4a (Continued) j SAFETY-RELATED HYDRAULIC SNUBBERS
- ITT-GRINNELL SMALL SIZE- MEDIUM SIZE LARG SIZE (1,250 lbs. or Less (10,350 lbs. to (45 00 lbs. to TO 3,000 lbs) 27,300 lbs) 6 ,200 lbs)
SYSTEM **
RV 15 0 0 4 68 29 ,
2 0 0 VE 0 0
( VN 3 0 .
l VQ 1 4 0 0 VX -
3 0 0 WL 0 e YA 1 0 6 0 0 YC 2 0 0 i
ZD 587 217 38 Subtotal (Unit 1) l l
UNIT 2 1 0 CA 1 6 0 CF 1 2 0 FW 3 0 0 KC 3 0 0 i
N8 i 0 0 8 NC
- Snubbers may added or deleted without prior License Amendmen to Table 3.7-4a provided tha a revision to Table 3.7-4a is included with the ne License Amendment quest. In lieu of any other report required by Specif ation 6.9.1, at least days prior to the deletion of any listed snubber, a Spe al Report all be prepared and submitted to the Commission in accordanc with Specif cation 6.9.2 evaluating the safety significance of the proposed snub r removal.
- A isting of individual snubbers and more detailed information shall be ailable for NRC review at the McGuire Nuclear Station.
Plus 8 steam gen. -- Paul-Monroe, Hyd. Size 2,755,000 lb. also exempt from ionctional testing.
J/ * <c McGUIRE - UN115 1 ano 2
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- Ds/4 gn V
ANT SYSTEMS' TABLE 3.7-4a (Continued)
~
. SAFETY-RELATED HYDRAULIC SNUBBERS
- SMALL SIZE MEDIUM SIZE L GE SIZE (1,250 lbs. or Less (10,350 lbs. to 5,500 Lbs. to TO 3,000 lbs) 27,300 lbs) 68,200 lbs)
SYSTEM **
NO 5 1 0 NI 6 1 0 i NS 2 0 0 NV 4 0 0 SM 0 40 10 3 0 0 SV 41 51 18 Subtotal (Unit 2)
TOTAL FOR UNITS 1 & 2 628 268 5_6 l
- Snubbers may be added o deleted without prior Lic se Amendment to Table 3.7-Aa provided that a revis n to Table 3.7-4a is include with the next License Amendment recuest. n lieu of any other report requi d by Specification 6.9.1, at least 15 days p or to the deletion of any listed s bber, a Special -
Report shall be epared and submitted to the Commission in accordance with
.2 evaluating the safety significance of he proposed Specification 6 snubber remov .
- A listing o individual snubbers and more detailed informatio shall be available or NRC review at the McGuire Nuclear Station.
f McGUIRE - UNITS 1 and 2 3/4 7-25
]
.04/b Sq.<
cr PLANT SYSTEMS .
_ TABLE 3.7-4b SAFETY-RELATED MECHANICAL SNUBBERS" PACIFIC SCIENTIFIC SMALL SIZE _
MEDIUM SIZE LARG" IZE (350 lbs. or Less (1,487 lbs, to (50 00 lbs. to SYSTEMA
- TO 600 lbs) _,
15,000 lbs) 1 .000 lbs)
UNIT 1 AS 0 2 0 98 92 31 0 BW 6 2 0 2 18 0 CA s CF \ 5 0 FW KC
\1 15 23 9 1 1
2 0 KF 2\ '
NB 30 \ 3 0 NC 24 'y 50 1 ND 6
\ 'y 12 3
1 0
NF NI O 25 0 NM 20 3 0 NV 43 35, 0 0 2 0 RF ,
RN 2 9 l'
' 1 13 11 s, 0 RV SA 0 8 \, O SM 0 10 N. B
- Snu ers may be added or deleted without prior License Amendment 9 Table 3. 7-4b pr vided that a revision to Table 3.7-4b is included with the next ' License mendment request. In lieu of any other report required by Soecific' ion 6.9.1, at least 15 days prior to the deletion of any listed snubber, a Specia -
Report shall be prepared and submitted to the Commission in accordance with Sp aification 6.9.2 evaluating the safety significance of the proposed \\
snubber removal.
- A listing of individual snubbers and more detailed information shall be available for NRC review at the McGuire Nuclear Station.
Amendment No. 1 (Unit 2)
McGUIRE - UNITS 1 and 2 3/4 7-26 Amendment No. 20 (Unit 1) 4/13/83
5 1 l
AtJbk kJ '
PLANT SYSTEMS TABLE 3.7-4b-(Continued)
.3AFETY-RELATED MECHANICAL SNUBBERS
- PACIFIC SCIENTIFIC SMALL SIZE MEDIUM SIZE LARG SIZE (350 Lbs. or Less (1,487 Lbs. to (50 00 lbs. to SYSTEM ** TO 600 lbs) 15,000 lbs) 1 .000 Lbs) 0 3 0 SV 1 3 0 VE 30 1 0 VI 0 2 0 VQ 2 0 0 WG 8 0 WL 2 0 0 WS 1 0 YC 282 23 Subtotal (Unit l') 326 UNIT 2 67 55 0 BB 9 59 0 CA 13 80 8 CF 0 4 1 FW 66 81 0 KC 3 0 ,
KD 5 0 KF 2 0 2 0 LD 1 0 NB 5 95 2 l NC 100 41 0 ND 29
- Snub rs may be added or deleted without prior License Amendment o Table 3.7-4b pro ided that a revision to Table 3.7-4b is included with the next icense A ndment request. In lieu of any other report required by Specific tion 6.9.1, t least 15 days prior to the deletion of any listed snubber, a Speci ith Report shall be prepared and submitted to the Commission in accordance I Specification 6.9.2 evaluating the safety significance of the proposed snubber removal.
- A listing of individual snubbers and more detailed information shall be available for NRC review at the McGuire Nuclear Station.
Amendment No.10(Unit 2) 3/4 7-27 Amendment No. 29(Unit 1)
McGUIRE - UNITS 1 and 2
OW$c $ag PLANT SYSTEMS c7' TABLE 3.7-4b (Continued)
. SAFETY-RELATED MECHANICAL SNUB 8ERS*
PACIFIC SCIENTIFIC SMALL SIZE MEDIUM SIZE LARGE IZE (350 Lbs. or Less (1,487 Lbs. to (50 00 Lbs. to TO 600 lbs) 15,000 lbs) 12 ,000 lbs) ,
SYSTEM **
NF 2 2 0 )
56 55 3 1 NI NM 42 11 0 NR 10 8 0 NV 170 69 0 .
RF 1 3 0 RN 28 3 1 9 8 0 RV .
12 0 SA SM 2 24 30 0 1 0 e SV 1 3 0 TE 4
3 2 0 VE 1 2 0 VG 1 0 VI 0 4 0 VN
/ 3 0 i VQ 1 0 0 VS VX 2 1 0 l 15 7 0 WL 0 2 O WN ,
675 674 45 Subtotal (Un 2) 956 65 TOTAL for ITS 1 and 2 1,001 ~
1 i
- Snu ers may be added or deleted without prior License Amendment to Table 3.7-Ab p vided that a revision to Tabier 3.7-4b is included with the next L ense mendment request. In. lieu of any other report required by Specificat'on 6.9.1, i j
at least 15 days prior to:the deletion of any listed snubber, a Special eport shall be prepared and.suomitted to the Commission in accordance with Spec fic-ation 6.9.2 evaluating the safety significance of the proposed snubber re va' ;
j
- A listing of individual snubbers and more detailed information shall be '
available for NRC review at the McGuire Nuclear Station.
Amendment No.10(Unit 2)
McGUIRE - UNITS 1 and 2 3/4 7-28 Amendment No. 29(Unit 1)
Ebr Inkem '
o, Su ,p m s 0,,
PLANT SYSTEMS 10 9
8 7
6 C 5 4
CONTINUE TESTING , [
- G j
1 r
/ ACCEPT l
l 0
s 70 80 90 100 20 30 40 50 60 10 l
N
(
FIGURE 4.7-1 SAMPLE PLAN 2) FOX SNUBLER TUNCTIONAL TEST 3/4 7-29 Amendment No. 46 (Unit 1) .
McGUIRE - UNITS 1 and 2 Amendment No. 27 (Unit 2) f
_x.
kr E [o m s O rfoSc S hn ADMINISTRATIVE CONTROLS 6.10 RECORD RETENT16h In addition to the applicable record retention requirements of Title 10, Code of Federal. Regulations, the following records shall be retained for at least the minimum period indicated. 4 I
6.10.1 The following records shall be retained for at least 5 years: )!
- a. Records and logs of unit' operation covering time interval at each power level-l
- b. Re' cords and logs of principal maintenance activities, inspections, ]
repair and replacement of principal items of equipment related,to j nuclear safety;
- c. All REPORTABLE EVENTS;
- d. Records' of surveillance activities; inspections and calibrations '
required by these Technical Specifications;
- e. Records of changes made to the procedures required by Specifi-cation 6.8.1; j
- f. Records of radioactive shipments; f
- g. Records of sealed source and fission detector leak tests and results; and
- 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 Unit Operating License:
i
- a. Records and drawing changes reflecting unit design modifications J made to systems and equipment described in the Final Safety Analysis Report; l
- b. Records of new and irradiated fuel inventory, fuel transfers, and j j
assembly burnup histories; i
- 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 or operational cycles for those unit components identified in Table 5.7-1;
- f. Records of reactor tests and experiments; 6-22 Amendment No.13 (Unit 2)
McGUIRE -_ UNITS 1 and 2
_ Amendment No 17 (Unit 1) _
ADMINISTRATIVE CONIROLS RECORD RETENTION (Continued)
- g. Records of training and qualification for current members of the unit staff;
- h. Records of inservice inspections performed pursuant to these Technical Specifications;
- i. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59; j.
i Records of meetings of the NSRB and reports required by Specification 6.5.1.12; ,
Records of the service lives of all snubbers 1 4a k.
N including the date at which the service 11te commences and associated installation and maintenance records;
- 1. Records of secondary water sampling and water quality; and .
- m. Records of analyses required by the Radiological Environmental Monitoring Program that would permit evaluation of the accuracy of the analysis at a later date. This should include procedures effective at specified times and QA records showing that these procedures were followed.
6.10.3 Records of quality assurance activities required by the QA Manual shall be retained for a period of time required by ANSI N45.2.9-1974.
6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
6.12 HIGH RADIATION AREA
/
6.12.1 In lieu of the " control device" or " alarm signal" required by \
paragraph 20.203(c)(2) of 10 CFR 20, each high radiation area, as defined in ?
10 CFR Part 20, in which the intensity of radiation is equal to or less than 1000 mrem /hr at 45 CM (18 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as (
a high radiation area and entrance thereto shall be controlled Individuals' by requiring qualified in radiation issuance of a Radiation Work Permit (RWP).
protection procedures (e.g., Health Physics Technician) or personnel contin- (
uously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mrem /hr provided they are otherwise following plant radiation protection procedures for entry into high ,
radiation areas.
6-23 Amendment No.52 (Unit 1)
McGUIRE - UNITS 1 and 2 Amendment No.33 (Unit 2)
l BASES 3/4.7.8_ SNUBBERS ,
All snubbers are required OPERABLE to ensure that the structural l integM t.y of the Reactor Coolant System and all other safety-related systems j is maintained during and following a seismic or other event initiating dynamic l loads. Snubbers excluded from this inspection program are those installed on I nonsafety-related systems and then only if their failure or failure of the i system on which they are installed, would have no adverse effect on any safety- l I related system. i l
Snubbers are classified and grouped by design and manufacturer but not by j size. For example, mechanical snubbers utilizing the same design features of i the 2 kip, 10 kip, and 100 kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured Company "B" for the purposes of this specification would be of a different type, as would ,
J
. hydraulic snubbers from either manufacturer.
The visual inspection frequency is based upon maintaining a constant level of snubber protection to systems. Therefore, the required inspection j interval varies inversely with the observed snubber failures and is determined j by the number of inoperable snubbers found during an inspection. Inspections '" j performed before that interval has elapsed may be used as a new reference 1 point to determine the next inspection. However, the results of such early j .
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 require a shorter inspection interval will override the previous schedule.
To provide assurance of snubber functional reliability one of the three sampling and acceptance criteria methods are used:
- 1. Functionally test 10% of a type of snubber with an additional 10%
tested for each functional testing failure, or
- 2. Functionally test a sample size and determine sample acceptance or continue testing
- using Figure 4.7-1, or [
r unctionally test a representative sample size and determine sample 3.
acceptance or rejection using the stated equation.
Figure 4.7-1 was developed using "Wald's Sequential Probability Ratio Plan" as described in " Quality Control and Industrial Statistics" by Acheson J. Duncan.
Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and, if applicable, snubber life destructive testing was performed to qualify the snubber for the applicable design conditions at either the completion of their f ?brication or at a subsecuent date./ Snuboer< cn --: p;;s shall continue iv 6 l-!;ted in Tahlec 't h': .0 ^ 7"+o with footn,otes indicating the evtaat Of t6 exemp,tions.
/
- 1f testing continues to between 100-200 snubbers (or 1-2 weeks) and still the (
accept region has not been reached, then the actual % of population quality )
(C/N) should be used to prepare for extended or 100% testing. <\
B 3/4 7-5 Amendment No.46 (Unit 1)
McGuire - UNITS 1 ana 2 Amendment No.27 (Unit 2) e-____-_-_-
$r .Ibkrma-kel kr,wS<S 0f BASES SNUBBERS (Continued).
The service life of a snubber is established via manufacturer input and information through consideration of the snubber service conditions and ,
associated installation and maintenance records (newly installed snubber : seal replaced, spring replaced, in high radiation area, in high temperature area, i etc. . .). The requirement to monitor the snubber service life is included to ,
ensure that the snubbers periodically undergo a performance evaluation in view l of their age and operating conditions. .These records will provide statistical bases for future consideration of snubber service life. The requirements for the maintenince of records and the snubber service life review not intended to a % ct plant operation.
3/4.7.9 SEALED SOURCE CONTAMINATION !
The limitations on removable contamination for sources requiring leak testing,-including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium. This limitation will ensure that leakage from Byproduct, Source, and Special Nuclear Material sources will not exceed allowable intake values.
Sealed sources are classified into three groups according to their use, j with Surveillance Requirements commensurate with the probability of damage to a source in that group. Those sources which are frequently handled are required to be tested more often than those which are not. Sealed sources which are continuously enclosed within a shielded mechanism (i.e., sealed sources within g
radiation monitoring or boron measuring devices) are considered to be stored and need not be tested unless they are removed from the shielded mechanism.
3/4.7.10 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the Fire Suppression Systems ensures that adeauate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety-related equipment is i located. The Fire Suppression System consists of the water system, spray, and/or sprinklers, Halon, and fire hose stations. The collective capaoility of the Fire Suppression Systems is adequate to minimize potential damage to safety-related equipment and is a major element in the facility fire protection program.
In the event that portions of the Fire Suppression Systems are inoperable, alternate backup fire-fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service.
When the inoperable fire-fighting equipment is intended for use as a backup means of fire suppression, a longer period of time is allowed to provide an I alternate means of fire fighting than if the inoperable equipment is the primary means of fire suppression. For McGuire Nuclaar Station pumps A and B serve as a backup for each other. Pump C is located separately with independ-ent dedicated power supply.
McGuire - UNITS 1 and 2 B 3/4 7-6 Amendment No.55(Unit 1)
Amendment No.36(Unit 2) I
ATTACHMENT 2 JUSTIFICATION FOR PROPOSED CHANGE AND ANALYSIS'0F SIGNIFICANT HAZARDS CONSIDERATION l
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Justification For Proposed Technical Specification Revision And Analysis of Significant Hazards Consideration By letter dated May 3,1984, NRC issued Generic Letter 84-13 (GL 84-13), Technical Specification For Snubbers transmitting the conclusion that snubber listings (tables) within the T.S. are not necessary provided the snubber T.S. is modified to specify which snubbers are required to be operable. It was also stated that record keeping requirements of the snubber T.S. are not altered by such a .
revision. Paragraph 4.9.7.f of the snubber T.S. requires that the plant records l contain a record of the service life, installation date, etc. of each snubber.
Any changes in quantities, types, or locations would be a change to the facility and would be subject to the provisions of 10CFR Part 50.59 and, of course, these changes would have to be reflected in the records required by paragraph 4.9.7.f.
Duke proposes to revise the McGuire T.S. as described in the following discussions.
First'as provided in GL 84-13, Duke proposes to revise the snubber T.S. to exclude Tables 3.7-4a and 3.7-4b. As the snubber T.S. is currently written, a number of license amendments have been required to add, delete, or modify the snubber tables within the T.S. Duke agrees with the NRC that this requirement is an "
administrative burden and should not be required provided the snubber T.S. be modified to specify which snubbers are required to be operable. A snubber listing is presently maintained at McGuire in addition to the snubber listing in the T.S.
in accordance with T.S. 6.10.2.k. Although the snubber tables would not be in the T.S. , any changes would be subject to the provisions of 10CFR Part 50.59 and would be reflected in the records required by T.S. 6.10.2.k.
As required by 10CFR 50.91, this analysis is provided concerning whether the proposed amendment involves significant hazards considerations as defined by 10CFR 50.92. Standards for determination that a proposed amendment involves no significant hazards considerations are if operation of the facility in accordance with the proposed amendment would not; 1) involve a significant increase in the probability or consequences of an accident previously evaluated or; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.
The proposed revision does not involve a significant hazards consideration because operation of McGuire Units One and Two in accordance with this revision would not:
- 1) involve a significant increase in the probability or consequences of an accident previously evaluated. This revision eliminates the need to submit numerous license amendments to revise snubber tables 3.7-4a and 3.7-4b when snubbers are added, deleted, or modified at McGuire. The limitations, restrictions, and surveillances presently included in the T.S. would not be affected as a result of this proposed revision. There is no change to the actual systems or design of the systems as installed with respect to snubbers i as a result of this proposed revision. The program by which snubbers are '
added, deleted, or modified will not change as a result of the proposed revision. Therefore, this change cannot increase the probability or consequences of an accident previously evaluated.
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- 2) create the possibility of a new or different kind of accident from any accident previously evaluated. It has been determined that a new or different kind of accident will not be possible due to this change. The elimination of the administrative requirement to maintain snubber tables in the T.S. does not cres,te the possibility of a new or different kind of accident. The limitations, restrictions, and surveillances presently included in the T.S. would not be affected as a result of the proposed change. The program by which snubbers are added, deleted, or modified will nat change as a result of proposed revision.
- 3) involve a significant reduction in a margin of safety. Existing administrative and maintenance procedures involved in the documentation and maintenance of soubbers along with the requirements of the existing T.S.
governing snubbers preserve the margin of safety. Elimination of the requirement to include the snubber tables in the T.S. will not reduce the margin of safety.
Therefore, based on the above considerations Duke considers this proposed revision does not involve a significant hazards consideration.
The second proposed change, as a result of deleting snubber tables 3.7-4a and -
3.7-4b from the snubber T.S., the footnote on Tables 4.7-4a and 4.7-4b that reads,
"#Plus 9 steam gen.--Paul-Monroe, Hyd. Size 2,755,000 lb. also exempt from functional testing", would be deleted. This previous exemption granted by the NRC would no longer be applicable. The Paul Monroe hydraulic snubbers have previously been exempted from functional testing. Because these snubbers are so different from other snubbers at the station, due to having ten times greater load bearing capabilities that require specialized testing, Duke proposes to treat the large bore steam generator hydraulic snubbers as a separate population for functional test purposes. A 10% random sample from previously untested snubbers would be tested at least once per refueling outage with continued testing based on failure evaluation. Once the whole population has been subjected to functional testing, the testing sequence would begin anew by random selection based on the total population. The addition of the testing requirement world provide additional confidence in the large bore steam generator hydraulic snubbers which are currently exempted from this testing. Furthermore, this testing frequency is conservative in the fact that by being treated as a separate population, the large bore steam generator hydraulic snubbers would be tested more frequently than if they were tested as part of the existing population. The more frequent testing would provide a higher level of confidence in the large bore steam generator hydraulic snubber testing quality also.
As required by 10CFR 50.91, this analysis is provided concerning whether the proposed amendment involves significant hazards considerations as defined by 10CFR 50.92. Standards for determination that a proposed amendment involves no significant hazards considerations are if operation of the facility in accordance with the proposed amendment would not; 1) involve a significant increase in the probability or consequences of an accident previously evaluated or; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.
Page'3-The proposed' revision does not involve a significant hazards consideration because operation of McGuire Units One and Two in accordance with this revision would not:
- 1) involve a significant increase in the probability or consequences of an accident previously evaluated. This revision imposes the requirement to begin testing of the large bore steam generator hydraulic snubbers. The j removal / replacement and testing of the snubbers would be performed in '
accordance with appropriate approved procedures by qualified personnel.
There would be no change to the actual systems or design'of the systems as installed as a result of the proposed revision. The program by which snubbers are added, deleted, or modified would not change as a result of the i proposed revision. The limitations, restrictions, and surveillances presently included in the snubber T.S. would not be affected as a result of the proposed revision.
- 2) create the possibilits/ of a new or different kind of accident from any accident previously evaluated. It has been determined that a new or different kind of accident will not be possible due to the proposed revision. '
The addition of the limitations, restrictions, and surveillance requiring the testing of the large bore steam generator hydraulic snubbers does not create ,,,
the possibility of a new or different kind of accident.. The current snubber T.S. limitations, restrictions, and surveillance would not change as a result of the proposed revision. The new testing would be performed in accordance with approved procedures and the removal / replacement of the snubbers would be performed in accordance with approved procedure. There would be no change to the actual systems or design of the systeme'as installed. The program governing the addition, deletion, and modification of snubbers would not be affected by the proposed revision.
- 3) involve a significant reduction in a margin of safety. Existing limitations, restrictions, and surveillances required for snubbers will not be affected by the revision in that there would not be a decrease in the aforementioned.
Additional limitations and restrictions will be incurred with the addition of the surveillance requirement to test large bore steam generator hydraulic snubbers. The additional testing will increase the level of confidence in the snubbers and provide a conservative testing program for the snubbers.
Therefore, there will not be a reduction in a margin of safety.
Therefore based on the above considerations, Duke considers this proposed revision does not involve a significant hazards consideration.
The third proposed change, as per GL 84-13 would specify which snubbers are required to be operable. Duke proposes to revise the T.S. to specify that all snubbers shall be operable with the exception of snubbers installed on non-safety related systems and then only if the failure of the system on which they are installed would not have an adverse effect on any safety related system.
Currently, the existing T.S. requires all snubbers to be operable to ensure that the structural integrity of the Reactor Coolant system and all other safety related structures are 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
Page 4 failure of the system on which they are installed, would have no adverse effect on any safety related system. The proposed revision will more clearly specify the aforementioned in lieu of_the absence of the snubber tables which is essentially the same as the current snubber T.S.
As required by 10CFR 50.91, this analysis is provided concerning whether the proposed amendment involves significant hazards considerations as defined by 10CFR 10.92. Standards for determination that a proposed amendment involves no significant hazards consideration are if operation of the facility in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated or; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.
This proposed revision does not involve a significant hazards consideration because operation of McGuire Units one and Two in accordance with this revision would not:
- 1) involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed revision would not affect the limitations, restrictions, and surveillances presently included in the snubber T.S. There would be no change to the actual system or design of the systems as a result of the proposed revision. The program by which snubbers are added, deleted, or modified would not change as a result of the proposed revision. The same snubbers now required to be operable by the current T.S. would continue to be required operable by the proposed revision to the T.S. Therefore, this change cannot increase the probability or consequences of an accident previously evaluated.
- 2) create the possibility of a new or different kind of accident from any accident previously evaluated. It has also been determined that a new or different kind of accident will not be possible due to this proposed revision. The snubbers required to be operable in the existing snubber T.S.
snubber tables 3.7-4a and 3.7-4b would be required to be operable by the proposed change. The non-safety related snubbers that currently are required to be operable because their inoperability would affect a safety related system would be required to be operable under the proposed revision. The addition to the T.S. to require all snubbers to be operable with the exception of snubbers installed on non-safety related systems and then only if the failure of the system on which they are installed would not have an adverse affect on any safety related system is essentially the same requirement as specified by the existing T.S. This proposed revision would not affect the possibility of a new or different kind of accident from any accident previously evaluated.
- 3) involve a significant reduction in a margin of safety. Existing restrictions, limitations, and requirements of the snubber T.S. would not be affected by the proposed revision; thus, the margin of safety would not be reduced.
Therefore, based on the above considerations, Duke considers this proposed ,
revision does not involve a significant hazards consideration.
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Page 5 The fourth change to the McGuire T.S. , provided the deletion of snubber Tables 3.7-4a and 3.7-4b is approved, are two references to the tables in the T.S. that would require deleting. The two references are as follows:
In T.S. 4.7.8.b, second paragraph the T.S. states that the first inservice visual inspection of each type of snubber shall be performed after four months but within ten months of commencing Power Operation and shall include all snubbers listed in Tables 3.7-4a and 3.7-4b. The proposed revision would delete the reference to Tables 3.7-4a and 3.7-4b and would state, the first inservice visual inspection of each type of snubber shall be performed after four months but within ten months of commencing Power Operations and shall include all snubbers. The deletion of the reference to the tables is purely an administrative change resulting from the deletion of snubber Tables 3.7-4a and 3.7-4b from the T.S.
In T.S. 6.10.2.k, Administrative Controls, snubber Tables 3.7-4a and 3.7-4b are referenced regarding requirements to maintain records of service life. The T.S.
currently states that records of the service lives of all snubbers listed in Tables 3.7-4a and 3.7-4b including the date at which the service life commences and associated installation and maintenance records shall be retained for the duration of the Unit Operating License. The proposed revision would require that records of all snubbers including the date at which the service life commences and" associated installation and maintenance records shall be retained for the duration of the unit Operating License. The deletion of the reference to the snubber tables is purely an administrative change resulting from the deletion of the snubber tables from the T.S.
As required by 10CFR 50.91, this analysis is provided concerning whether the proposed amendment involves significant hazards considerations as defined by 10CFR 50.92. Standards for determination that a proposed amendment involves no significant hazards considerations are if operation of the facility in accordance with the proposed amendment would not; 1) involve a significant increase in the probability or consequences of an accident previously evaluated or; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.
The proposed revision does not involve a significant hazards consideration because l operation of McGuire Units One and Two in accordance with this revision would not: '
- 1) involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed revision merely eliminates reference to the snubber tables in both changes. The restrictions, limitations, and surveillances would not be affected as a result of this proposed revision. Neither the inspection requirements nor the record keeping requirement will be affected by the proposed revision. Therefore, this change cannot increase the probability or consequences of an accident previously evaluated.
- 2) create the possibility of a new or different kind of accident from any previously evaluated. It has been determined that a new or different kind of accident will not be possible due to this change because the change merely eliminates the references to the snubber tables and in no way affects the intent of the T.S. Therefore, this change cannot increase the probability or consequences of an accident.
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- 3) involve a significant reduction in a margin of ufety, The administrative requirements to retain records of the service lives of snubbers cannot reduce !
the margin of safety 3 The reference to the snubber tables being deleted does ]
not affect this. administrative requirement. There will not be a reduction or j change to the inspection of snubbers as a result of deleting the reference to l the snubber tables. Therefore, the proposed change to delete the reference l to the snubber tables 3.7-4a and 3.7-4b does not reduce the margin of safety. )
I Therefore, based on the above considerations, Duke considers the proposed revisna j does not involve a significant hazards consideration. ;
i The fifth and final change included in the proposed revisions to the snubber T.S. {
I is a revision to the T.S. Bases, Section 3/4.7.8. The deletion of the snubber l Tables 3.7-4a and 3.7-4b would require the deletion of the following statement l from the Bases referencing the tables:
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Snubbers so. exempted shall continue to be listed in Tables 3.7-4a and 3.7-4b with footnotes indicating the extent of the exemptions.
The only exemption that was included in the snubber tables was the exemption from " .
functional testing of large bore steam generator hydraulic snubbers. As l previously discussed in this amendment submittal, Duke proposes to forego this exemption and begin testing of the aforementioned snubbers. Therefore, the statement for exempted snubbers would not be required in the Bases.- Since the Bases is a summary of the reasons for the specifications in T.S. Sections 3.0 and 4.0, and in accordance with 10CFR 50.36 are not a part of the T.S. a significant hazards consideration discussion is not applicable.
It should also be noted that the proposed revisions in this amendment submittal are very similar to those of Duke's Catawba T.S. which were licensed to exclude the snubber tables.
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