ML20235D484

Requests Addl Clarification Re Interpretation of Tech Specs 3.7.9 & 4.7.9 Re Operability & Testing Requirements for Snubbers

ML20235D484
Person / Time
Site:	LaSalle, 05000000
Issue date:	09/09/1986
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Holahan G Office of Nuclear Reactor Regulation
Shared Package
ML16342B348	List: IA-87-121, Discusses Inservice Test Programs Re Full Stroke Exercising of Normally Closed Swing or Tilting Disk Check Valves Per 10CFR50.55a & Section XI of ASME Code ML20235B266 ML20235B268 ML20235B295 ML20235B304 ML20235B322 ML20235B406 ML20235B470 ML20235B514 ML20235B581 ML20235B613 ML20235B673 ML20235B768 ML20235B785 ML20235B799 ML20235B859 ML20235B877 ML20235B922 ML20235C007 ML20235C967 ML20235C970 ML20235D014 ML20235D041 ML20235D091 ML20235D157 ML20235D188 ML20235D233 ML20235D400 ML20235D433 ML20235D484 ML20235D532 ML20244B491 ML20244B568 ML20244B571 ML20244B913 ML20244B937 ML20244B941 ML20244B943 ML20244C126 ML20244C271 ML20244C361 ML20244C777 ML20244C785 ML20244C833 ML20244C935 ML20244C940 ML20244C986 ML20244D413 ML20244D552 ML20244D582 ... further results
References
FOIA-87-121 NUDOCS 8707100187
Download: ML20235D484 (3)

Text

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w g ytto SD SNM MEMORANDUM FOR: Gary M. Holahan, Director, Operating Reactors Assessment Staff, NRR FROM: Charles E. Norelius, Director, Division of Reactor Projects, Region III

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE - ADDITIONAL CLARIFICATION OF SNUBBER TECHNICAL SPECIFICATION REQUIREMENTS By memorandum dated May 27, 1986 (copy attached) NRR responded to a Region III request for interpretation of Technical Specifications 3.7.9 and 4.7.9 for LaSalle dealing with operability and testing requirements for snubbers.

Region III has reviewed this memorandum and found it responsive to our request.

However, during this review several additional issues were identified for which your assistance is requested in obtaining resolution. These issues are-as follows:

a. The NRR response states that Technical Specification 4.7.9.e is explicit that the 18 month snubber functional test is to be performed during plant shutdown and that this requirement cannot be met by testing snubbers at power. Based on this response, it is Region III's understanding that snubbers which are functionally tested with the plant at power cannot be taken credit for when determining the number of snubbers to be tested per the sample plan requirements applicable during shutdown. Further, it is Region III's understanding that testing of only those snubbers associated with that portion of a shared system for the shutdown unit may be taken credit for in the sample plan.

b. The NRR response states that the allowable outage time for snubbers is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If this time limit is exceeded the associated systems must be considered inoperable and action requirements for those systems must be met. However, the action requirements for associated systems are not applicable if for surveillance testing, snubbers are sequentially removed one at a time and replaced or all snubbers are simultaneously removed and replaced as a group at the same time, so long as the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time limit is not exceeded. Based on this response it is Region III's understanding that an associated system need not be declared inoperable provided that ,

no single snubber is removed for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> continuously, and that it is acceptable for licensees to remove and replace snubbers in strict or i

8707100187 870701 PDR FOIA WILLIAM 87-121 PDR

Gary M. Holahan 2 SEP S 1988 overlapping sequence provided that no individual snubber is removed for a period of time in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Additionally, we understand that the above described snubber removal position is applicable to multiple systems simultaneously. That this may create a total cumulative time for combined snubber removal, from single or nultiple systems, in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is acceptable.

c. The action statement for TS 3.7.9 requires that inoperable snubbers must be replaced or restored to operability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and an engineering evaluation performed on the attached component to determine the impact of the inoperable snubber on that component, or the attached system must be declared inoperable. Region III has the following understanding of this requirement:

1. For an inoperable snubber, that snubber must be replaced or restored to operability and the required engineering evaluation completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the associated system is not to be declared '

inoperable. If an evaluation is not completed in the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time frame demonstrating no adverse impacts on the associated system due to the inoperable snubber, or if the evaluation shows adverse' impacts associated with the inoperable snubber, the associated system must be considered inoperable until such time as a satisfactory evaluation is completed or remedial actions for the adverse impacts are completed as appropriate.

2. If an inoperable snubber is not repaired or replaced in the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time frame required by the action statement such that the associated system is declared inoperable, the referenced engineering evaluation 4-must be completed as a condition cf operability for the associated system.

3. If a snubber or group of snubbers is removed solely for TS 4.7.9e functional testing, the tests are satisfactorily completed, and the snubber (s) is reinstalled in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, no engineering evaluation is required as the snubber (s) have been demonstrated not to be inoperable and no adverse impact accrued to the associated system.

If, however, a snubber, demonstrated operable by testing, is removed for said tests in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> such that the associated system is declared inoperable, an engineering analysis must be performed addressing the lack of seismic restraint for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before the associated system may be declared operable.

By this memorandum NRR concurrence is requested for the positions adopted by Region III as described above. If any of these positions is at variance with the positions maintained by NRR, the NRR position is requested. Your cooperation in this matter is appreciated. As LaSalle Unit 2 is scheduled to l

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Gary M. Holahan 3 SEP 9 1985 enter a refueling outage in December 1986 your response on these matters is requested no later than November 31, 1986. If you have any questions on these matters, please contact W.- Guldemond (FTS 388-5574) of my !.taff.

MM s. -w

' Charles.E. Norelius, Director Division of Reactor Safety

Attachment:

Memo C. Norelius fm H. Denton dtd 5/27/85 cc w/ attachment:

A. Bournia, NRR  !

M. J. Jordan, SRI i l

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