ML20247N357

Amends 76 & 64 to Licenses NPF-10 & NPF-15,respectively, Revising Tech Specs to Allow one-time Extension of Surveillance Interval for Channel Calibr of Pressurizer Level Instruments Used for Remote Shutdown Monitoring

ML20247N357
Person / Time
Site:	San Onofre
Issue date:	08/30/1989
From:	Knighton G Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247N362	List: ML20247N357 ML20247N373 ML20247N385
References
NUDOCS 8909260203
Download: ML20247N357 (22)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION g

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SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-361 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 76 License No. NPF-10 1.

The Nuclear Regulatory Comission (the Comission) has found that:

A.

The applications for amendment to the license for San Onofre Nuclear Generating Station, Unit 2 the facility) filed by Southern California Edison Company SCE)onbehalfofitself and San Diego Gas and Electric Company, the City of Riverside, California and the City of Anaheim, California (licensees) dated May 19, 1988 and March 10, 1989 comply with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Comission; C.

There is reasonable assurance... (1) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public; and i

E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied.

i 8909260203 890830 DR ADOCK 05000361 p

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2.

Accordingly, the license is amended by changes to the Technical Speci-fications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of facility Operating License No. NPF-10 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 76, are hereby incorporated in the license. SCE shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the'date of its issuance and must be fully implemented no later than 30 days from the date of issuance.

FOR THE NUCLE R REGULATORY COMMISSION George W. K.

hton, Director Project Di ectorate V Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 30, 1989

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ATTACHMENT TO LICENSE AMENDMENT NO. 76 1

FACILITY OPERATING LICENSE NO. NPF-10 OpCKETNO.50-361 l

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Revise Appendix A Technical Specificat'ons by removing the pages identified below and inserting the enclosed pages. The revised pages are identified by L

ame.ndment number and contain marginal lines indicating the area of change.

Also enclosed are the following overleaf pages to the amended pages.

AMENDMENT PAGE OVERLEAF PAGE 3/4 3-50 3/4 3-49 3/4 3-54 3/4 7 --

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• PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) l No. Inoperable Snubbers Subsequent Visual per Inspection Period Inspection Period *y 0

18 months i 25%##

1 12 months i 25%

-R 2

6 months 25%

3,4 124 days i 25%

5,6,7 62 days t 25%

8 or more 31 days i 25%-

The snubbers may be categorized into two grot.ps:

Those accessible and those inaccessible during reactor operation.

Each group may be inspected independently.in accordance with the above schedule.

c.

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, and (3) fasteners for attachment of the snubber to (a) the component or pipe and (b) the snubber anchorage are secure.

Snubbers which appear inoperable as a result of visual inspections may be determined OPERABLE 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 that may be generically 5,usceptible; and (2) the affected snubbe.- is functionally tested in the as found condition and determined OPERABLE per Specification 4.7.6.e or 4.7.6.f, as applicable.

However, when a fluid port of a hydraulic snubber is found to be uncovered, the snubber shall be determined inoperable and cannot te 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.

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

1. The provisions of Specification 4.0.2 are not applicable.

1. 1. 20 months i 25% for inspections conducted during the Cycle 4 refueling outage.

1. 1. 1. 14 months 125% for inspections conducted during the Cycle 4 refueling outage.

1 SAN ONOFRE-UNIT 2 3/4 7-17 AMENDMENT NO. 76

PLANT SYSTEMS l

SURVEILLANCE REQUIREMENTS (Continued) d.

Functional Tests At least once per refueling interval during shutdown, a representative l

sample of at least 15% 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 of a type that does not meet the functional test acceptance criteria of Specification 4.7.6.e or 4.7.6.f, an additional 15% of that type of snubber shall be functionally tested until no more failures are found or until all snubbers of that type have been functionally tested.

The representative sample selected for functional testing shall include-the various configurations, operating environments and the range of size and capacity of snubbers.

At least 25% of the snubbers in the representative sample shall include snubbers from the following three categories:

1.

The first snubber away from each reactor vessel nozzle 2.

Snubbers within 5 feet of heavy equipment (valve, pump, turbine motor,etc.)

3.

Snubbers within 10 feet of the discharge from a safety relief valve.

Snubbers that are especially difficult to remove or in high radiatici zones during shutdown shall also be included in the representative sample.*

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 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 those snubbers may not be included for the re-sampling.

• Permanent or other exemptions from functional testing for individual snubbers in these caterories may be granted by the Commission only if justifiable basis for exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their fabrication or at a subsequent date.

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SAN ONOFRE-UNIT 2 3/4 7-18 AMENDMENT NO. 76 i

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) e.

Hydraulic Snubbers Functional Test Acceptance Criteria

• The hydraulic snubber functional test;shall verify that:

1.

Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.

2.

Snubber bleed or release rate, where required, is within the specified range in compression or tension.

For snubbers specifically required to not displace under continuous load, the ability of the snubber to withstand load without displacement-shall be verified.

f.

Mechanical Snubbers Functional Test Acceptance Criteria

• The mechanical snubber functional test shall verify that:

1.

The force required to initiate or maintain motion of the snubber is within the specified range in both directions of travel.

2.

Activation (restraining action) is achieved within the specified range of belocity or acceleration in both tension and compression.

3.

Snubber release rate, where required, is within the specified range in compression or tension.

For snubbers specifically required not to displace under centinuous load, the ability of the snubber to withstand load without displacement shall he verified, 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 failure.

The results of this evaluation shall be used, if applicable, in selecting snubbers to be tested in an effort to determine 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 snubber are attached. The purpose of this engineering evaluation shall be to l

determine if the components to which the inoperable snubbers were attached were adversely affected by the inoperability of the snubbers in order to ensure that the component remains capable of meeting the designed service.

• 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.

SAN ONOFRE-UNIT 2 3/4 7-19 AMENDMENT NO. 33 L _ ____

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

If any snubber selected for functional testing either fails to lockup or fails to move, i.e., frozen in place, the cause will be evaluated and if caused by manufacturer or design deficiency all snubbers of the same type subject to the same defect shall be functionally tested.

This testing requirement shall be independent of the requirements stated in Specification 4.7.6.e. or 4.7.6.f. for snubbers not meeting the functional test acceptance criteria.

h.

Functional Testing of Repaired and Replaced Snubbers Snubbers which fail the visual inspection or the functional test acceptance criteria shall be repaired or replaced.

Replacement snubbers and snubbers which have repairs which might affect the functional test result shall be tested to meet the functional test criteria before installation in the unit.

These snubbers shall have met the acceptace criteria subsequent to their most recent service, and the functional test must have been performed within 12 month before being installed in the unit.

i.

Snubber Service Life Monitoring A record of the service life of each snubbar, the date at which the designated service life commences and the instal-lation and maintenance records on which the designated service life is based shall be maintained as required by Specification 6.10.21.

y Concurrent with the first inservice visual inspection and et least once per refueling interval thereafter, the installation l

r and maintenance records for each snubber shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber service life review.

If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

This reevaluation, replacement or reconditioning shall be indicated in the records.

j.

Transient Event Inspections An inspection shall be performed of all hydraulic and mechanical snubbers attached to sections of safety systems that have experienced unexpected, potentially damaging transients as determined from a review of operational data and a visual inspection of the systems within 6 months following a determination that such an event has occurred.

In addition to satisfying the visual inspection acceptance criteria, freedom of motion of mechanical snubbers shall be verified using one of the following:

(1) manually induced snubber movement; (ii) evaluation of in place snubber piston setting; (iii) stroking the mechanical snubber through its full range of travel.

SAN ONOFRE-UNIT 2 3/4 7-20 AMENDMENT NO. 76

O PLANT SYSTEMS

• BASES-3/4.7.6 SNUBBERS All sn'ubbers are required OPERABLE 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 nonsafety related systems and then only if their failure or failure of the system on which they f

are installed, would have no adverse effect on any safety related system.

For visual inspection snubbers are categorized into two (2) groups, those accessible and those inaccessible during reactor operation.

For functional testing, snubbers are categorized into types by design and manufacturer, irre-spective of capacity.

For example, Pacific Scientific snubbers are divided into four types corresponding to different design features:

PSA 1/4 and 1/2 are one type; PSA 1, 3, and 10 are another; PSA 6 is arother; and PSA 35 and 100 are a fourth type.

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 riuring an inspection.

Inspections performed before that interval has elapsed may be used as a new reference point to deter-mine the next inspection.

However, the results of such early inspections per-formed before the original required time interval has elapsed (ncminal 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.

Amendment No. 76 allows a one time extension of the inspection period during Cycle 4 operation while the NRC develops generic guidance applicable to 24 month operating cycles.

To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested during plant shut-downs at refueling intervals.

l Hydraulic snubbers and mechanical snubbers may each be treated as a different entity for the above surveillance programs.

SAN ONOFRE-UNIT 2 B 3/4 7-5 AMENDMENT N0. 76

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PLANT SYSTEMS BASES SNUBBERS (Continued)

The service life of a snubber is evaluated 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, etc.).

The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions.

These records will provide statistical bases for future consideration of snubber service life.

The requirements for the maintenance of records and the snubber service life review are not intended to affect plant operation.

3/4.7.7 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, 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 radiation monitoring or boren measuring devices) are considered to be stored and need not be tested unless they are removed from the shield mechanism.

3/4.L8 FIRE SUPPRESSION SY5TEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is,available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located.

The fire suppression system consists 'of the water system, spray and/or sprinklers, and fire hose stations.

The collective capability 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 restoreo 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 alternate means of fire fighting than if the inoperable equipment l

is the primary means of fire suppression.

The surveillance requirements provide assurance that the minimum OPERABILI1Y requirements of the fire suppression systems are met.

SAN ON0FRE-UNIT 2 8 3/4 7-6 1

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NUCLEAR REGULATORY COMMISSION g~,,( ;

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SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY

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THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-362 SAN ON0FRE NUCLEAR GENERATING STATION, UNIT NO. 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 64 License No. NPF-15 1.

The Nuclear Regulatory Comission (the Comission) ha.; found that:

A.

The application for amendment to the license for San Onotre Nuclear Generating Station, Unit 3 (the facility) filed by Southern California Edison Company (SCE) on behalf of itself and San Diego Gas and Electric Company, the City of Riverside, California and the City of Anaheim, California (licensees) dated May 19, 1988, complies with the standards and re of the Atomic Energy Act of 1954, as amended (the Act)quirements

,and the Commission's regulations set forth in 10 CFR Chapter 1; B.

The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commitsion's regulations and all applicable requirements have been satisfied.

l 2.

Accordingly, the license is amended by changes to the Technical Speci-fications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-15 is hereby amended to read as follows:

(2).TechnicalSpecifications j

~

The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 64, are hereby incorporated in the license. SCE shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance and must be fully implemented no later than 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

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s th W George W Kn) hton, Director Project Directorate V Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 30, 1989 l

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ATTACHMENT TO LICENSE AMENDMENT NO. 64 FACILITY OPERATING LICENSE NO. NPF-15 DOCKET NO. 50-362

~ Revise Appendix A Technical Specifications by removing the pages identified below and inserting the enclosed pages. The revised pages are identified by amendment number and contain marginal lines indicating the. area of. change.

Also enclosed are the following overleaf pages to the amended pages.

AMENDMENT PAGE OVERLEAF PAGE 3/4 7-17 3/4 7-18 3/4 7-21 3/4 7-22 B 3/4 7-5 B 3/4 7-6

i PLANT SYSTEMS 3/4.7.6 SNUBBERS l

LIMITING CONDITION FOR OPERATION f

3.7.6 All snubbers shall be OPERABLE.

The only snubbers excluded from this requirement are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed, would hive no adverse effect on any safety related system.

j APPLICABILITY: MODFS 1, 2, 3 and 4.

(MODES 5 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 perfcrm an engineering evaluation per Specification 4.7.6.g on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7.6 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program.

1 a.

Inspection Types As used in this specification, type of snubber shall mean snubbers of the same design and manufacturer, irrespective of capacity.

b.

Visual Inspections The first inservice visual inspection of snubbers shall be performed after 4 months but within 10 months of commencing POWER OPERATION and shall include all snubbers.

If less than two snubbers are found inoperable during the first inservice visual inspection, the second inservice visual inspection shall be performed 12 months i 25% from the date of the first inspection.

Otherwise, subsequent visual inspections shall be performed in accordance with the following schedule:

No. Inoperable Snubbers Subsequent Visual,

per Inspection Period Inspection Period

• 18monthsi25%h",

0 1

12 months i 25%

2 6 months i 2E%

3,4 124 days i 25%

5,6,7 62 days i 25%

8 or more 31 days i 25%

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

1. The provisions of Specification 4.0.2 are not applicable.

1. 1. 20 months 25% for inspections conducted during the Cycle 4 refueling outage.

1. 1. 1. 14 months i 25% for inspections conducted during the Cycle 4 refueling outage.

SAN ONOFRE-UNIT 3 3/4 7-17 AMENDMENT NO. 64

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PLANT SYSTEMS

~ SURVEILLANCE REQUIREMENTS'(Continued)

The snubbers may be categorized into two groups:

Those accessible and those inaccessible during reactor operation.

Each group may be inspected independently in accordance with the above schedule.

Visual Inspection Acceptance Criteria, c.

Visual inspections shall verify (1) that there are no visible indica-g tions of damage or impaired OPERABILITY, and (2) attachments to the j-'

foundation or supporting structure are secure, and (3) fasteners for attachment of the snubber.to (a) the component or pipe and (b) the snubber anchorage are secure.

Snubbers which appear inoperable as a result of visual inspections may be determined OPERABLE for the pur-pose of establishing the.next visual inspection interval, provided that (1) the cause of the rejection is clearly established and re-medied for that particular snubber and for other snubbers that may be l

generically susceptible; and (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifi-cation 4.7.6.e or 4.7.6.f, as applicable.

However, when a 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.

d.

Functional Tests

• At least once per refueling interval during shutdown, a representative sample of at least 15% 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 of a type of that does not meet the functional test acceptance criteria of Specification 4.7.6.e or 4.7.6.f, an additional 15% of that type of snubber shall be functionally tested l

until no more failures are found or until all snubbers of that type have been functionally tested.

The representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capacity of snubbers.

At least 25% of the snubbers in the representative sample shall include snubbers from the following three categories:

1.

The first snubber away from each reactor vessel nozzle i

2.

Snubbers within 5 feet of heavy equipment (valve, pump, turbine i

rnotor, etc. )

j 3.

Snubbers within 10 feet of the discharge from safety relief

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valve.

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• Permanent or other exemptions from functional testing for individual snubbers i

in these categories may be granted by the Commission only if justifiable

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basis for exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their fabrication or at a subsequent date.

SAN ONOFRE-UNIT 3 3/4 7-18 AMENDMENT NO. 64 1

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• PLANT SYSTEMS 5

l SURVEILLANCE REQUIREMENTS (Continued) i.--

Snubber Service Life Monitoring A record of the service life of each snubber, the date at which the

-designated service life commences and the installation and maintenance records on which the designated service life is based shall be maintained as required by Specification 6.10.2.1.

Concurrent with the first inservice visual inspection and at least 1

once per refueling interval thereafter, the installation and maintenance records' for each snubber shall be reviewed to verify that the indicated service life has not:been excee'ded or will not be exceeded prior to the next scheduled snubber service life review.

If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as i

to extend its service life beyond the date of the next scheduled service life review. This reevaluation, replacement or recor.ditioning shall be indicated in the records.

j.

Transient Event Inspections An inspection shall be performed of all hydraulic and mechanical snubbers attached to sections of safety systems that have experienced unexpected, potentially damaging transients as determined from a review of operational data and a visual inspection of the systems within 6 months following a determination that such an event has occurred.

In addition to satisfying the visual inspection acceptance criteria, freedom of motion of mechanical snubbers shall be verified using one of the following:

(i) manually induced snubber movement; (ii) evaluation of in place snubber piston setting; (iii) stroking the mechanical snubber through its full range of travel.

SAN ONOFRE-UNIT 3 3/4 7-21 AMENDMENT NO. 64

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SAN ONOFRE-UNIT 3 3/4 7-22 AMENDMENT NO. 22 i

. PLANT, SYSTEMS BASES 3/4.7.6 SNUBBERS All snubbers'are required OPERABLE 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 nonsafety 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.

For visual inspection. snubbers are categorized into two (2) groups, those accessible and those inaccessible during reactor operation.

For functional testing, snubbers are categorized.into types by design and manufacturer, irrespective of capacity.

For example, Pacific Scientific snubbers are divided into four types corresponding to different design features:

PSA 1/4 and 1/2 are one type; PSA 1, 3, and 10 are another; PSA 6 is another; and PSA 35 anc 100 are a fourth type.

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 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.

Amendment No. 64 allows a one time extension of the inspection period during Cycle 4 operation while the NRC develops generic guidance applicable to 24 month operating cycles.

To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested during plant i

shutdowns at refueling intervals.

l Hydraulic snubbers and mechanical snubbers may each be treated as a dif-ferent entity for the above surveillance programs.

i SAN ONOFRE-UNIT 3 B 3/4 7-5 AMENDMENT N0. 64

l-PLANT SYSTEMS J

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BASES j

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SNUBBERS (Continued)

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l The service life of a snubber is evaluated via manufacturer input and information through consideration of the snubber service conditions and associated installation and maintenance records (newly 6ta11ed snubber, seal re'placed, spring replaced,'in high radiation area, in high.emperature area, etc.). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions.

These records will p ovide statistical bases for future consideration of snubber service life. The requirements for the maintenance'of records and the snubber service life review are not intended to affect plant operation.

3/4.7.7 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, with surveillance requirements commensurate with the probability of damage to l

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 l

sources within radiation. monitoring or boron measuring devices) are considered to be stored and need not be tested unless they are removed from the shield mechanism.

3,f,4.7.8 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located.

The fire suppression system consists of the water system, spray and/or sprinklers, and fire hose stations.

The collective capability 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 l

inoperable, alternate backup fire fighting equipment is required to be made l-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 alternate means of fire fighting than if the inoperable equipment is the primary means of fire suppression.

l The surveillance requirements provide assurance that the minimum OPERABILITY requirements of the fire suppression systems are met.

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SAN ONOFRE-UNIT 3 B 3/4 7-6