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{{#Wiki_filter:ATTACHMENT11.4'I'iable-erabilit1JHAsystem,subsystem,train,component'rdeviceshallbeoperableorhaveoperabilitywhenitiscapableofperformingitsspecifiedfunction(s).Implicitinthisdefinitionshallbetheassumptionthatallnecessaryattendantinstrumentation,controls,normaloremergencyelectricalpowersources(subjecttolSection3.0.2),coolingorsealwater;lubrication,supports,orotherauxiliaryequipmentthatarerequiredforthesystem,subsystem,train,componentordevicetoperformitsfunction(s)arealsocapableofperformingtheirrelatedsupportfunction(s).Amendment4g1-laPROPOSED88070500i888062iPDRADQCN,05000240PPDR
{{#Wiki_filter:ATTACHMENT 1 1.4                 erabilit        1J
~4 ATTACHMENT21.ClarificationoftheJuly24,1987responsetoNRCStaffestion54reardinSGsnubbers.TheSGsnubbersarenotrequiredtobefunctionallytested,sincesnubberlockupisnotacrediblefailuremode.However,extensivemaintenanceisperformedonthesesnubbersinordertocomplywiththe"snubbersealservicelifemonitoring"TechnicalSpecification4.14.1.f.ThatmaintenanceisdescribedinProcedureM-40.7,whichprovidesinstructionsforremoval,inspection,maintenance,test,andreinstallationofAnker-Holthsnubbersonthesteamgenerators.Theseactivitiesincludedisassembly,cleaning,replacement.ofallsealsandreplacementofhydraulicfluid.Followingtherebuildingofthesnubber,ahydrostatictestisperformedoneachsnubbertoverifypressureintegrityandsealinstallation.Theseactivitiesareperformedatamaximumofa10yearintervalsoastoensuresnubbersealservicelifeisnotexceeded..TheresultsofthismaintenancearerecordedintheplantrecordsinaccordancewithproposedTechnicalSpecification6.10.2.m.All16steamgeneratorsnubbershavebeen.rebuilttwiceeachsinceplantstartup.2.ResonsetoNRCStaffestiononMechanicalSnubbersTheStandardTechnicalSpecificationsstatethatmechanicalsnubberfunctionaltestacceptancecriteriainclude:"Dragforceshallnothaveincreasedmorethan50%sincethelastfunctionaltest."Inlieuofthis,RG&EprovidesthefollowingmeansofmonitoringsnubberdragforcesintheGinnaStationSnubberInspectionandTestProgram.Theprogramrequiresfunctionaltestresultstobereviewedtodetermineacceptabilityofresults.Ifdragforce.isnotgreaterthan1%ofsnubbernormaldesignload,thesnubbermaybeinstalledinanylocation.Ifsnubberdragforceisbetween1-oand5%,thesnubberacceptabilityisbasedonatablecorrelatingsnubbersizewithpipesize.Overa5%dragisconsideredunacceptable.However,anysnubberwithadragforcegreaterthan2%isconsidereddegradedandisrequiredtoberepairedorr'eplacedasapreventivemaintenancemeasure.Thus,RG&Econsidersthattheidentificationofpotentialdegradationrelativetorequiredsnubberfunctionisconservativelyevaluatedandmonitoredinourpresentprogram.
                                                                'I'iable-H A system, subsystem, train, component'r device shall be operable or have operability when it is capable of performing its specified function(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal or emergency electrical power sources (subject to l
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Section 3.0.2), cooling or seal water; lubrication, supports, or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).
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Amendment 4g                    1-la                    PROPOSED 88070500i8 88062i PDR    ADQCN, 05000240 P                  PDR
 
~ 4 ATTACHMENT 2
: 1. Clarification of the July        24, 1987 response      to NRC  Staff estion  54  re ardin  SG  snubbers.
The  SG  snubbers are not required to be functionally tested,   since snubber lockup is not a credible failure mode. However, extensive maintenance is performed on these snubbers in order to comply with the "snubber seal service life monitoring" Technical Specification 4.14.1.f.
That maintenance is described in Procedure M-40.7, which provides instructions for removal, inspection, maintenance,     test, and reinstallation of Anker-Holth snubbers on the steam generators.                 These activities include disassembly, cleaning, replacement . of all seals and replacement      of hydraulic fluid.             Following the rebuilding of the snubber, a hydrostatic test is performed on each snubber to verify pressure integrity and seal installation. These activities are performed at a maximum of a 10 year interval so as to ensure snubber seal service life is not exceeded.. The results of this maintenance are recorded in the plant records in accordance with proposed Technical Specification 6.10.2.m. All 16 steam generator snubbers have been .rebuilt twice each since plant startup.
: 2. Res onse  to NRC  Staff    estion on Mechanical Snubbers The    Standard    Technical Specifications state that mechanical snubber functional test acceptance criteria include: "Drag force shall not have increased more than 50% since the last functional test."               In lieu of this, RG&E provides the following        means  of  monitoring snubber drag forces in the Ginna        Station  Snubber    Inspection and Test Program.       The program requires            functional    test results to be reviewed to            determine    acceptability of results. If drag      force. is not greater    than  1% of snubber normal design load, the snubber may          be    installed  in any location. If snubber drag force is between 1-o and 5%, the snubber acceptability is based on a table correlating snubber size with pipe size. Over a 5% drag is considered unacceptable.     However, any snubber with a drag force greater than 2% is considered degraded and is required to be repaired or r'eplaced as a preventive maintenance measure. Thus, RG&E considers that the identification of potential degradation relative to required snubber function is conservatively evaluated and monitored in our present program.
 
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Latest revision as of 20:44, 29 October 2019

Corrected Proposed Tech Spec 1.4, Operable-Operability, Adding Word Support After Word Lubrication for Clarification
ML17251A145
Person / Time
Site: Ginna Constellation icon.png
Issue date: 06/21/1988
From:
ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17251A136 List:
References
NUDOCS 8807050018
Download: ML17251A145 (4)


Text

ATTACHMENT 1 1.4 erabilit 1J

'I'iable-H A system, subsystem, train, component'r device shall be operable or have operability when it is capable of performing its specified function(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal or emergency electrical power sources (subject to l

Section 3.0.2), cooling or seal water; lubrication, supports, or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).

Amendment 4g 1-la PROPOSED 88070500i8 88062i PDR ADQCN, 05000240 P PDR

~ 4 ATTACHMENT 2

1. Clarification of the July 24, 1987 response to NRC Staff estion 54 re ardin SG snubbers.

The SG snubbers are not required to be functionally tested, since snubber lockup is not a credible failure mode. However, extensive maintenance is performed on these snubbers in order to comply with the "snubber seal service life monitoring" Technical Specification 4.14.1.f.

That maintenance is described in Procedure M-40.7, which provides instructions for removal, inspection, maintenance, test, and reinstallation of Anker-Holth snubbers on the steam generators. These activities include disassembly, cleaning, replacement . of all seals and replacement of hydraulic fluid. Following the rebuilding of the snubber, a hydrostatic test is performed on each snubber to verify pressure integrity and seal installation. These activities are performed at a maximum of a 10 year interval so as to ensure snubber seal service life is not exceeded.. The results of this maintenance are recorded in the plant records in accordance with proposed Technical Specification 6.10.2.m. All 16 steam generator snubbers have been .rebuilt twice each since plant startup.

2. Res onse to NRC Staff estion on Mechanical Snubbers The Standard Technical Specifications state that mechanical snubber functional test acceptance criteria include: "Drag force shall not have increased more than 50% since the last functional test." In lieu of this, RG&E provides the following means of monitoring snubber drag forces in the Ginna Station Snubber Inspection and Test Program. The program requires functional test results to be reviewed to determine acceptability of results. If drag force. is not greater than 1% of snubber normal design load, the snubber may be installed in any location. If snubber drag force is between 1-o and 5%, the snubber acceptability is based on a table correlating snubber size with pipe size. Over a 5% drag is considered unacceptable. However, any snubber with a drag force greater than 2% is considered degraded and is required to be repaired or r'eplaced as a preventive maintenance measure. Thus, RG&E considers that the identification of potential degradation relative to required snubber function is conservatively evaluated and monitored in our present program.

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