View source for B12250, Forwards Reviews for Isap Topics 1.24, Tech Spec Surveillance for Hydraulic Snubbers, 1.25, Tech Spec Surveillance for Mechanical Snubbers & 1.46, Inservice Testing for Diesel Generator Auxiliaries

{{Adams
| number = ML20215N638
| issue date = 10/24/1986
| title = Forwards Reviews for Isap Topics 1.24, Tech Spec Surveillance for Hydraulic Snubbers, 1.25, Tech Spec Surveillance for Mechanical Snubbers & 1.46, Inservice Testing for Diesel Generator Auxiliaries
| author name = Opeka J
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = Grimes C
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B12250, NUDOCS 8611070107
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}

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{{#Wiki_filter:, e CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N, CONNECTICUT P O. BOX 270  HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 October 24,1986 Docket No. 50-213 B12250 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==References:==
(1)  3. F. Opeka letter to C. I. Grimes, dated May 17,1985.
(2)  H. L. Thompson letter to J. F. Opeka, dated July 31,1985.
Gentlemen:
Haddam Neck Plant Integrated Safety Assessment Program In Reference (1), Connecticut Yankee Atomic Power Company (CYAPCO) provided a proposed scope for the Integrated Safety Assessment Program (ISAP) review of the Haddam Neck Plant. In Reference (2), the Staff formally issued the results of the ISAP screening review process, establishing the scope of ISAP for Haddam Neck and initiating issue-specific evaluations. Reference (1) also indicated that for each issue or topic included in ISAP, CYAPCO would provide a discussion of the safety objective and an evaluation of the plant design with respect to the issue being addressed to identify specific items to be considered in the integrated assessment. In accordance with this commitment, reviews for the following ISAP topics are attached:
: 1)     ISAP Topic No. 1.24 - " Technical Specification Surveillance for Hydraulic Snubbers"
: 2)     ISAP Topic No. 1.25 - " Technical Specification Surveillance for Mechanical Snubbers"
: 3)     ISAP Topic No.1.46 "lST for Diesel Generator Auxiliaries" If you have any questions concerning the attached reviews, please contact us.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY
                                                           < b {At4/A.-
J. F. OpeVa           O                              [
Senior Vice President                               fl   i 8611070107 861024 PDR      ADOCK 05000213 p                       PDR

Docket No. 50-213 B12250 Haddam Neck ISAP Topic No.1.24 Technical Specification Surveillance for Hydraulic Snubbers October 1986

Haddam Neck ISAP Topic No.1.24 TS Surveillance for Hydraulic Snubbers I. Introduction Snubbers are designed to prevent unrestrained loads to piping and equipment as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown.              The consequence of an inoperable snubber is an increase in the probability of structural damage to piping as a result of a seismic or other event initiating dynamic loads. It is therefore required that all hydraulic snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
II. Review Criteria Generic Letter 84-13, " Technical Specifications for Snubbers" III. Related Topics / Interfaces ISAP Topic No.1.25 "TS Surveillance for Mechanical Snubbers" IV. Evaluation Due to the importance of snubber operation at all times, all safety-related hydraulic snubbers are visually inspected for overall integrity and operability. The inspections include verification of proper orientation, adequate hydraulic fluid level, and proper attachment of snubber to piping and structures.
The inspection frequency is based upon maintaining a constant level of snubber protection. Thus the required inspection interval varies inversely with the observed snubber failures. The number of inoperable snubbers found during a required inspection determines the time interval for the next required 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.
These surveillance requirements will be superseded by implementation of the Standard Technical Specifications (STS). The STS will implement the guidance provided in Generic Letter 84-13.
V. Conclusion Pending conversion to Standard Technical Specifications, which will include snubber surveillance, CYAPCO considers this topic closed.

e VI. References
                     '1. W. G. Counsil' letter to                  D.' L. Ziemann, "Haddam Neck Plant '-
Proposed Changes to Technical Specifications," dated February 27, 1979.
: 2.   .
W. G. Counsil letter to D. .M. Crutchfield, "Haddam Neck Plant -
Technical Specifications for Snubber Surveillance," dated January 12, 1982.
: 3. D. L. Ziemann letter to W. G. Counsil, " Technical Specifications Amendment #31 for the Haddam Neck Plant - Snubber Surveillance,"                                 '
dated March 2,1979.
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                                                                                  ' Haddam Neck ISAP Topic No.1.25 TS Surveillance for Mechanical Snubbers
: 1. Introduction Snubbers are de:!gned to prevent unrestrained loads to piping and equipment as might occur during an earthquake or severe trans;ent, while allowing normal thermal motion during startup and shutdown.                The consequence of an inoperable snubber is an increase in the probability of structural damage to piping as a result of a seismic or other event initiating dynamic loads. It is therefore required that all mechanical snubbers required to protect the primary coolant system or any other safety system or component be operable during reactor operation.
II. Review Criteria I&E Bulletin No. 31-01," Surveillance of Mechanical Snubbers" Ill. Related Tcpics/IMerfaces l                                                              ISAP Topic No.1.24 "TS Surveillance for Hydraulic Snubbers" IV. Evaluation Due to the importance of their operation at all times, mechanical snubbers i
are routinely inspected for their structural integrity as part of the inservice inspection program at Haddam Neck. Additionally, surveillance
;                                                              requirements for- mechanical snubbers include periodic visual and l
functior.al tests as outlined in the Standard Technical Specifications.
L V. Conclusion                                                                    I Pending conversion to Standard Technical Specifications, which will include snubber surveillance, CYAPCO considers this ISAP topic closed.
VI. - References
: 1. B. H. Grier to W. G. Counsil,"I&E Bulletin No. 81-01,' Surveillance of Mechanical Snubbers,"' dated January 27,1981.
: 2. W. G. Counsil letter to B. H. Grier, "Haddam Neck Plant - I&E Bulletin No. 81-01, Mechanical Snubbers," dated February 19,1981.

Docket No. 50-213 B12250 i
Haddam Neck ISAP Topic No.1.46
                      'f IST for Diesel Generator Auxillaries October 1936

      ~
Haddam. Neck ISAP Topic No.1.46                                                      ,
In-service Testing for Diesel Generator Auxillaries
 ;        I.        Introduction In-service - Testing (IST) Programs are necessary for certain plant
,                   components to ensure their reliable operation per ASME Code Section XI.
4 II.        Review Criterna f                  'l.       ASME Code, Section XI,1980 Edition
: 2.        10 CFR 50.55a " Codes and Standards" III.        Related Topics / Interfaces
: l.       ISAP Topic No.1.44 " Diesel Generator Reliability"
: 2.     'ISAP Topic No. 1.45 "151 Update to 1980 Code" 4
IV. Evaluation Reference (1) provided the results of the NRC Staff reviews of the IST Programs for the Haddam Neck Plant and granted relief, in part, from certain requirements of Section XI of the ASME Boiler and Pressure Vessel i
Code. The Staff requested, as documented in IE Inspection Report 50-213/83-08, that Connecticut Yankee Atomic Power Company (CYAPCO) i                   review the emergency diesel generator auxiliary systems to:
4                   o        identify applicable pumps and valves in these systems, o        determine the feasibility of conducting meaningful readiness tests in d
accordance with the code, and o        amend the IST Program accordingly.
CYAPCO outlined its response to this request in Reference (3), stating our conclusion that the testing programs we currently have' in place are adequate to ensure diesel generator reliability.                     During the Staff's evaluation of the proposed updated ISI Program (Reference (4)), questions were raised regarding the following systems:
: 1.       Pressurizer Relief / Reactor Coolant ~
  ;                 2.      Safety Injection 1                  3.       Residual Heat Removal
: 4.      Chemical and Volume Control
: 5.       Main Steam
: 6.      Feedwater
: 7.      Containment Isolation                                                                                '
: 8.      Service Water Informally, the Staff also stated they would be pursuing implementation of
  ,                 the diesel generator auxiliaries into the IST Program per ASME Code i-                 Section XI.
j

, e .s 6 On May 8,1986, CYAPCO met with the Staff on the ISI program and again implementation of an IST Program for the diesel generator auxillaries was discussed. A formal request for this was then forwarded by Reference (5).
Hence, CYAPCO is preparing to implement certain testing requirements for the diesel generator auxiliaries consistent with Millstone Unit No. 2 Implementation (See Reference (6)). However, a formal commitment for placing the diesel generator auxiliary systems into the'IST Program has not yet been made.
V. Conclusions CYAPCO is presently evaluating incorporation of the diesel generator auxiliary systems into the IST Program.
         ' VI. References
: 1. D.' M. Crutchfield letter to W. G. Counsil, "Haddam Neck Plant - In-service Testing Program,"~ dated December 29,1983.
: 2.   .W. G. Counsil letter to D. M. Crutchfield, "Haddam Neck Plant - In-service Inspection and Testing Program," dated April 9,1984.
: 3. W. G. Counsil letter to 3. A. Zwolinski, "Haddam Neck Plant - In-service Testing Program - Emergency Diesel Generator Auxillaries,"
dated January 31,1985.
: 4. F. M. Akstulewicz letter to 3. F. Opeka, " Request for Additional Information on In-service Testing Program", dated March 5,1986.
: 5. . C. I. Grimes letter . to 3. F. Opeka, "In-service Testing of the Emergency Diesel Generator Auxiliary Systems," dated August ~ 15, 1986.
: 6. ' A. C. Thadani letter to 3. F. Opeka," Millstone Nuclear Power Station, Unit No. 2, Inservice Testing of Emergency Diesel Generator Auxiliary Systems," dated December 31,1985.}}