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| document type = CONTRACTED REPORT - RTA,QUICK LOOK,ETC. (PERIODIC, TEXT-PROCUREMENT & CONTRACTS
| document type = CONTRACTED REPORT - RTA,QUICK LOOK,ETC. (PERIODIC, TEXT-PROCUREMENT & CONTRACTS
| page count = 14
| page count = 14
| project = TAC:43606
| stage = Other
}}
}}


Latest revision as of 01:45, 14 December 2021

Technical Evaluation Rept on Proposed Tech Spec Changes for Inservice Surveillance of Safety-Related Hydraulic Snubbers at Rancho Seco Nuclear Generating Station,Unit 1
ML20136C554
Person / Time
Site: Rancho Seco
Issue date: 05/15/1985
From: Chan P
LAWRENCE LIVERMORE NATIONAL LABORATORY
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20136C517 List:
References
CON-FIN-B-8559, CON-FIN-B-8562 TAC-43606, UCID-20454, NUDOCS 8601030361
Download: ML20136C554 (14)
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. .. TECHNICAL EVALUATION REPORT ON THE PROPOSED TECHNICAL SPECIFICATI00 CHANGES FOR THE INSERVICE SURVEILLANCE OF SAFETY -RELATED HYDRAULIC SNUBBERS AT THE RANCHO SECO I s. NUCI.2AR .GENEP.ATING STATION, UNIT.1

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DISCLAIMER , 

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                                                             . This decsaient was prepared as an accomet of work sponsored by an asency of the United States Geeernment. Neither the United States Government nor the University of Califormis nor any of their employees, makes any warranty, espress or implied, or
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                                                             . etherwise, does w ascessarily constitute er imply its endorsement. recomsmendation, er favoring by the United States Government or the University of Califerais. The elpes and opinions of authors espressed bereia de not necessarily state er reflect these of the United States Government er the University of Califer'nia, and shall not be used for advertising er predact endorsement perpenes.
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I i i ABSTRACT. 

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This report documents the technical evaluation of the proposed Technical Specification changes to Limiting Conditions for Operation, . Surveillance Standards, and Bases for safety-related. hydraulic snubbers at l the Rancho Seco Nuclear Generating Station, Unit 1. t The evaluation is to determine whether the proposed Technical Specifications are in conformance , with the model Standard Technical Specification set forth by the NRC. A check list, Appendix A of this report, compares the licensee's' submittal with , the NRC requirements. l t FOREWORD [ t Actions, Technical Specifications for Hydraulic and Mechanical Snu  ! being conducted for the U. S. Nuclear Regulatcry Commission, Region V, by Lawrence Livermore National Laboratory. i The U. S. Nuclear Regulatory Commission funded the work under B&R No. 95-19-20-10, FIN No. B-8562 and FIN No. B-8559. , L k s i r 

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TABLE OF CONTENTS
                                                                                                                                                            ' Pan I. INTRODUCTION .               .      .       .     .    .        .      .             .         .

A. Description of the Proposed Action 

                                                                                                                        .    ..        .        .    .           1 B.           Background Information               .    .
                                                                                                                       .       .       .        .    .           1 C.        -Scope of Review .
                                                                                          .             .        .     .       .      .         .  '.           1 4                                                               ..    .    .        .      .             .        .

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                                                                                                                       .       .      .         .   .           2
             'II. EVALUATION              .   .      .       .   ..     .        .      .  .

A. Limiting Conditions for Operation (LCO) . 

                                                                                                                 .    .        .      .        .    .           2 B.                                                                                                  .       .       .        .    .           2 Surveillance "tandards - Snubbers-                        .             .        .

C. Bases . . . . . 

                                                                                                                      .      .        .        .   .            3
                                                                                                                              .      .         .   .            3 III. CONCLUSION             .    .      .

f . . . . . . . . . . . . 4 REFERENCES . . . . . . . . . . 4 

                                                                                                                                    .        .    .            5 APPENDIX A           ..    .      .      .      .    .        .      .             .        .     .       .       .        .    .            7 1

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_ _ ._ _ . _~ _ -. i TECHNICAL EVALUATIO REPORT ON THE PROPOSED TECHNICAL SPECIFICATION CHANGES FOR THE INSERVICE SURVEILLANCE OF SAFETY-RELATED HYDRAULIC SNUBBERS AT THE RANCHO SECO NUCLEAR GENERATING STATION, UNIT 1 (Docket No. 50-312) i Paul M. A. Chan ( Lawrence Livermore National Laboratory, Nevada i

1. INTRODUCTION I

i A. Description of the Proposed Action } i This Technical Evaluation Report (TER) addresses Sacramento Municipal , Utility District's (SMUD), the licensee, compliance with the require-- ments contained in th'e generic letter of November 20,=1980 [Ref. 11, from Darrel G. Eisenhut, Director, Division of Licensing, to all power reactor licensees Station, Unit 1. except SEP, for the Rancho Seco Nuclear Generating The generic letter contained model Standard Technical Specifications for the inservice surveillance requirements for snubbers. B. Background Information l The operability of ' snubbers is required to provide assurance that the t structural integrity of the reactor coolant system and all other safety-J related systems are maintained during and following a seismic or other event initiating dynamic loads. The operability is verified by an inservice inspection and testing program specified in the plant's Tech-nical. Specifications (TS). Recent. operating-experience has indicated the need for changes, clarifications, and improvements in the inservice surveillance requirements for hydraulic snubbers and to include similar requirements for mechanical snubbers. By letter dated November 20, '1980 [Ref.1], the NRC requested. that ' all power reactor licensees, except SEP licensees, incorporate the revised l model NRC Standard Technical Specifications (STS) into the plant speci- 

                                         .fic Technical Specifications for hydraulic and mechanical snubbers.
.A similar request was sent'to the SEP licensees in a letter dated March 23, -1981. [Ref.1]..

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-The NRC model STS require that a visual inspection frequency be based upon maintaining related systems. a constant level of. snubber protection to the safety-I Additionally, in order to provide assurance that the
                                                                                          ~

j hydraulic and mechanical snubbers function reliably, a representative sample of the plant's installed snubbers will be functionally tested 

                                         .at least once per 18 months during plant shutdowns. The required.

sampling provides a confidence level nf 95% that 90% of the plant specific snubbers will~ be operable within acceptable limits. t I 

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i C. . Scone of Review 4 I i i Tha review consisted of evaluating the licensee's submittals [Refs. 2, 3, and 8] and conparing them with the Limiting Conditions for Operation  ! (LCO), Surveillance Standards, and Sases outlined in the N2C review 2 criteria. Appendix A of this report documents the comparison in the i form of a checklist. The check list describes the requirements with ' a 'YES' or 'N0' column that is marked to indicate conformance or i nonconformance. When a 'N0' is marked, the ' Deviation and Resolution,' { or ' Proposed Resolution' is described. A ' Resolution' requires no  ! further licensse action and provides the explanation. A ' Proposed Resolution' requires further licensee action and describes the action needed to rescive the deviation. Also found in the check list are 

                           ' Remarks' which are used for additional clarification.                                                         .

The review criteria that were applied in determining the accepta-bility of the inservice surveillance standards for the operability } of the safecy-related snubbers are contained in the following:  ! (1) Generic letter from D. G. Eisenhut to all Power Reactor Licensees (except SEP licensees) dated November 20, 1980, with enclosed Standard Technical Specifications (STS) Snubber } Surveillance Requirements. (Criteria also applicable to SEP ( Licensees based on March 23, 1981 NRC letter.) (Ref. 1]. f (2) Technical Spe.cifications and Bases for Snubbers as incorporated f in the McGuire Units 1 and 2 plant Technical Specifications: [ TS 3/4.7.8 [Ref. 4]. 1 t (3) Technical Specifications and Bases for Snubbers as incorporated in the Byron plant Technical Specifications: TS 3/4.7.8 [Ref. 5]. (4) NRC memorandus, L. Engle (Lead PM) to G. C. Lainas, AD/OR, DL, j ' " General Guidance (Region I thru V) for MPA Items B-17 and B-22, j Hydraulic and Mechancial Snubbers, Respectively. for Technical t Specification Surveillance Requirements," dated March 2,1983 [Ref. 6]. [* t An inspection trip was made to verify the accessibility and inaccessi-bility of various_ snubbers (Ref. 7]. II. EVALUKTION  ! i A. Lindting Conditions for Operation (LCO)  ! A review of the LCO in the licensee's proposed TS finds they are in I; conformance with those stated in the review criteria. Specifically. 1 they list the modes of applicability that all snubbers listed shall be operable and action req.irements when one or more . snubbers are found. inoperable. An engineering evaluation will be made to deter-  ! mine the mode of failure and if any safety-related system or compo-  ! nent was adversely affected by the inoperable snubber. ', t i Y 

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B. Surveillance Standards - Snubbers The licensee's proposed Technical Specifications Surveillance Standards establish that each snubber identified in the LCO will be demon-strated operanle by an inservice inspection program. The inservice inspection tasting. program consists of visual inspections and. functional As the number of inoperable snubbers increase, the frequency of visual inspections also increase (shorter time interval between inspection periods). A 10% sample of each type of snubber will be functionally tested at least once per refueling interval. For each snubber which fails the functional test, an additional 10% test samp-ling of the. failure type is required. Snubbers are randomly selected for functional testing from the licensee's Technical Specifications, Table 3.12-1, " Safety-Related Hydraulic Snubbers." The table also categorizes snubbers as Accessible (A) or Inaccessible (I). Reviews are set up to assure that the snubbers selected are typical of what they represent. . Rules are established for selecting additional' test i samples to replace units that failed the tests, Some of the snubbers'in Table 3.12-1 are~ located in high radiation . areas, and therefore, functional testing of these snubbers is sub-ject to the facility ALARA program. According to the licensee, functional testing of other snubbers on this list cannot be accom-plished within the safety guidelines established by OSHA or otherwise involve significant physical risks to personnel safety [Ref. 3]. These two classes of snubbers are listed in the licensee's Technical Specifications, Table 4.14-1, " Designated Safety'Related Hydraulic Snubbers Functionally Tested Only As Required by the Snubber Seal Replacement Program" (SRP). The SRP monitors the service life his-tory of the snubber seals and requires that approximately 20% of the snubbers receive replacement seals at each fuel outage. This exceeds the initial sample size specified for the balance of the safety-related snubbers, but is not subject to expansion unless a generic problem with a specific brand or model of snubber is identified. The Surveillance Standards. define acceptance criteria for both the visual inspections and functional testing as well as other specific requirements of each (visual and functional). A monitoring and record keeping. program is established. A review of these proposed Surveillance Standards finds they are in conformance with those defined in.the review criteria. C. Bases A review of the Technical Specifications Bases for sntbbers finds that an adequate presented. and clear explanat, ion of the Surveillance Standards are 

           'are defined. The visual inspection and functional testing requirements An engineering evaluation is required to determine if a system has been adversely affected by an inoperable snubber (s). Snub-bers in high radiation areas will be subjected to additional mainten-ance ander the SRP.        A monitoring and record keeping program is estab-lished reviewed.to  ensure   that the snubbers' performance is periodically

III. CONCLUSION Based upon the proposed Technical Specification changes sub=1tted by the Sacramento Municipal Utility District fer the Rancho Seco Nuclear Gen 2 rating Station, Unit 1, the following is concluded: A. The proposed TS on Snubber Surveillance are clear and adequate. B. The changes proposed reflect the plant specific requirements of Rancho Seco. C. The proposed TS meet cr exceed the requirements of the nodel NRC Standard Technical Specifications. Accordingly, it is recommended that the NRC accept the -Proposed Amendment No. 75, Revision 2, submitted by S! IUD, which demonstrates that the imple-mentation of the proposed TS on Snubber Surveillance will meet or exceed the standard set by the NRC. - - I l

REFERENCES 1. NRC letter (D. G. Eisenhut) to all Power Reactor Licensees (except SEP Licensees) dated November 20, 1980 and March 23, 1981 for the SEP Licensees. 2. SMUD letter (J. J. Mattimoe) to the NRC (D. G. Eisenhut), dated April 7, 1981. 3. SMUD letter (R. J. Rodriquez) to the NRC (J. F. Stolz), dated November 14, 1983. 4 Technical Specifications, and Bases for Snubbers as incorporated in the McGuire Units 1 and 2 plant Technical Specifications (TS 3/4.7.8). 5. Technical Specifications and Bases for Snubber's as incorporated in the Byron plant Technical Specifications (TS 3/4.7.8).. 6. NRC memorandum, Leon B. Engle to Gus C. Lainas, dated March 2,1983. 7. Plant trip and meeting, R. Colombo and B. Thomas (SMUD), M. Padovan (NRC), J. Selan and R. White (LLNL), dated September 15, 1983. 8. SMUD9,letter April (R. 1985. J. Rodriquez) to the NRC '(H. L. Thompson, Jr.), dated 9. NRC letter (D. G. Eisenhut) to all Power Reactor Licensees (except SEP Licensees), dated May 3, 1984. F P

APPENDIX A SNUBBER SURVEILLANCE RANCHO SECO NUCLEAR GENERATING STATION, UNIT 1 Data Comparison of Licensee Proposed Technical Specification Changes Versus NRC Model Standard Technical Specifications REFERENCES': 1. SMUD letter April.7, (J. 1981. J. Mattimoe) to the NRC, (D. G. Eisenhut), dated 2. Licensee meeting; R. Colombo and B. Thomas (SMUD), M. Padovan (NRC), and J. Selon and R. White (LLNL), dated September 15, 1983.

3. '

SMUD letter November (R. J. Rodriquez) to the NRC ('J. E.' Stolz), dated 14, 1983; 4. SMUD9,letter April (R. 1985. J. Rodriquez) to the NRC (H. L. Thompson, Jr. ), dated I. YES NO LIMITING CONDITIONS FOR OPERATION A. All snubbers listed required to be operable. X B. Mechanical / hydraulic types designated in separate tables. X Remarks: Mechanical snubbers are not utilized. C. Modes' of applicability include modes 1-4 and modes 5, cold shutdown, and 6, refueling. X D. Inoperable snubbers replaced or operability restored within 72 hours and X E. Engineering evaluation conducted on the supported components within 72 hours eg; X F. Follow appropriate action statements for the supported system. X Remarks: To be consistent with the format of the plant's existing TS, the licensee uses the word " specification" rather than " action" per the STS. t 

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

YES NO G. 

    -          Snubbers may be added .co Table 3.12-1 without prior license
              -amendment                          ~

request, etc. (as in STS cable footnotes). How-ever, snubbers may not be added to this table without NRC approval, because of special provisions applicable to Table 4.14-1. X H. Modifications to the table in the "high radiation zone colut:n"- may be made without prior license amendment request, etc. (as in STS table footnotes). N/A Remarks _: Licensee's submittal does not have the "high radiation zone column." II. SURVEILLANCE STANDARDS A. Each snubber demonstrated operable by an augmented - inservice inspection program schedule and 1 X-Deviation: The licensee do4s not explicitly refer to the inservice inspection program as " augmented." Resolutio2: The visual inspection and functional testing i requirements are both based on increases in , the number of failures. For the visual inspec-tions, as the number of fsilures increase, the frequency of, inspections also increase. Also, l as the number of snubbers fail the functional test, an additional sample of each snubber type is tested until no more fail or all are tested. Finally, snubbers in high radiation areas are subjected to the Seal Replacement Program. Based on these provisional requirements, the licensee's inservice inspection program is , considered " augmented" and is therefore  ; acceptable.  ! B. The requirements of Specification 4.0.5 or equivalent are referenced. - I i Deviation: The licensee does not reference the require-ments of Specification 4.0.5 or equivalent. ) Resolution:  ! Snubber surveillance at Rancho Seco is inde-  ! pendent of their existing inservice inspection program.  ! P I I i l 

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            . n YES        NO C. Visual Inspection
1. First inspection interval defined (not applicable for N/A reactors in operation > 2 yrs).

2. Second interval defined (12 months + 25%) if less than two snubbers are found inoperable in first interval (not applicable for reactors in operation > 2 yrs). __ N/A

3. Subsequent inspection intervals defined. X
4. Inspection intervals ~ not lengthened more than one step at a time and provisions of Specification X 4.0.2 or equivalent are not applicable.

Renarks: The proposed TS is the equivalent to STS Specification 4.0.2. s

5. Snubbers categorized into accessible / inaccessible groups and inspected independently. X D. Visual inspection acceptance criteria 1.

No visible indicatior of damage / impaired operability. X

2. Attachments secure. X 3.

Manual inducement for freedom of movement. X 4 Inoperable snubber determined operable, provided a. Cause of rejection is established and remedied for that snubber and others generically susceptible, and

b. Functionally tested in as found condition and determined operable. X
5. Open fluid ports cause for inoperability. X Deviation: The liceusee has added the prov'ision that a snubber (uncovered fluid port) may be declared operable via a functional test if the test is started with the piston in the as-found setting r.nd extending the piston in the tension mode.

Resolution: This provision is consistent with the TS for McGuire and Byron in the review criteria and is therefore acceptable. 

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! YES NO t 6. Common fluid reservoirs addressed for inoperability (not applicable if common reservoir not used). X L Remarks: Common reservoir is not used at Rancho . l Seco, Unit 1. ' i

E. Functional Tests  !

1., once per 18 months during plant shutdown.  ! I E

2. 10% of each type tested in place or in a bench test. I
                                                                                                 ?
3. <

10% additional of that type for each snubber failing test. . X 

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4. 25% of sample selected from Lan 3 ' defined areas.
                                                                                                \

I I Deviation:  ! The snubberi selected for the functional ( tests were not specifically selected from i the three defined areas per the STS. I Resolution: The licensee used wording consistent with  ! the TS for McGuire and Byron in the review [ criteria that as far as practical the selec- ) tion will be representative of the various ', configurations, environments, sizes, and capabilities and is therefore acceptable. [ 5. Snubbers identified as "especially difficult to remove" or in "high radiation zones during shutdown" and l included in test samples.  : I  ! Remarks: The licensee does not identify snubbers as "especially difficult to remove" or in "high

radiation zones during shutdown," in Table l 3.12-1. Those snubbers, however, where it  !

j i is deemed that functional testing would  ; j result in significant radiation exposure or i significant physical risk to safety, are l listed in Table 4.14-1 and are subject to "j functional testing as prescribed by the Seal Replacement problems. Programs or as a result of generic l i i I i 

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{. . YES- NO

6. Footnote statement regarding permanent or other exemptions . . . . may be granted, etc., included. X
7. Retesting of previous failed snubbers and replacements.

X

8. Testing of all snubbers where any one failed and was determined generic.

X

9. Inoperable snubbers require engineering evaluation performed on supported components. X F. Hydraulic snubbers functional test acceptance criteria
1. Activation (restraining action) is achieved within specifications of velocity and acceleration in both compression / tension.

X

2. Snubber bleed rate within specified'tange. X
3. ' Snubbers required to r.ot displace are verified. X G.

Mechanical snubbers functional test acceptance criteria. 

                               -1.

Force for free movement is < specified max drag force. Drag force has not increased >50%. N/A

2. Activation (restraining action) is achieved within specifications of velocity and acceleration in both compression / tension.

N/A 3. Snubber release rate within specified range. N/A

4. Snubbers required to not-displace are verified. N/A H.

Snubber service life monitoring. 1. Records of service life maintained. X III. BASES ' A. Adequate explanation in Bases of the surveillance X standards for snubbers. 

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