ML17261A862

Proposed Tech Specs Re Limiting Condition for Operation for Snubbers & Inservice Insp of High Energy Piping Outside Containment

ML17261A862
Person / Time
Site:	Ginna
Issue date:	02/16/1989
From:	ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17261A861	List: ML17261A860 ML17261A862
References
NUDOCS 8903010221
Download: ML17261A862 (20)

Text

ATTACHMENT A Revise the Technical Specification pages as follows: Remove Page 1-la Pages 3.13-1 through 3.13-7 Pages 4.2-1 through 4.2-2 Pages 4.14-1 through 4.14-5 Insert Page 1-1a Page 3.13-1 Pages 4.2-1 through 4.2-3 Pages 4.14-1 through 4.14-8 Page 6.10-3 85'030i022i 89'0216 PDR AGOCK 05000244 P PDC<<4' 1.4 erable-erabilit A system, subsystem, train, component or 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 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 gg 1-la Iil-Proposed II Py C II II ,I I l ,I'f I 3'3 Snubbers Limitin Condition for 0 eration 3.13.1 With RCS conditions above cold shutdown, all safety-related snubbers shall be operable.This specification does not apply to those snubbers installed on non safety-related.

systems if the snubber failure, and.a resulting failure of the supported non safety-related system shown to be caused by that snubber failure, would have no adverse effect on any safety-related system.Action 3.13.2 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 perform an engineering evaluation per Specification 4.14.1e on the supported component or declare the supported system inoperable and follow the appropriate action statement for Basis that system.Snubbers are required to be 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 may be replaced by rigid structural supports (bumpers)provided an analysis is performed to demonstrate that appropriate acceptance criteria are satisfied for design basis seismic and pipe break events and provided that the bumpers are inspected periodically in a manner appropriate for rigid structural supports.J 3~1 3 1 Proposed 4.2 Inservice Ins ection A licabilit Applies to the inservice inspection of Quality Groups A, B, and C Components, High Energy Piping Outside of Containment, Snubbers and Steam Generator tubes.It also applies to inservice pump.and valve testing.4.2.1 To provide assurance of the continuing structural and operational integrity of the structures, components and systems in accordance with the requirements of 10 CFR 50.55a(g).

S ecification The inservice inspection program for Quality Groups A, B, and C Components, High Energy Piping Outside of Containment, Snubbers and Steam Generator tubes shall be in accordance with Appendix B of the Ginna Station Quality Assurance Manual.This inservice pump and valve testing program shall be in accordance with Appendix C of the Ginna Station Quality Assurance Manual.These inservice inspection programs shall define the specific requirements of the edition and.Addenda of the ASME Boiler and Pressure Vessel Code,Section XI, which are applicable for the forty month period of the ten year inspection interval.The programs'en year inspection interval shall be based on the following commencing dates.Amendment No.4.2-1 Proposed 4.2.1,1 The inspection interval for Quality Group A components shall be ten year intervals of service commencing on January 1, 1970.4.2.1.2 The inspection intervals for Quality Group B and C Components shall be ten year intervals of service commencing with May 1, 1973, January 1, 1980, 1990 and 2000, respectively.

4.2.1.3 The inspection intervals for the High Energy Piping Outside of Containment shall be ten year intervals of service commencing May 1, 1973, January 1, 1980, 1990 and 2000, respectively.

The inspection program during each third of the first inspection interval provides for examination of all welds at design basis break locations and one-third of all welds at locations where a weld failure would result in unacceptable consequences.

During each succeeding inspection interval, the program shall provide for an examination of each 1 I of the design basis break location'elds,'nd each of the welds at locations where a weld, failure would result in unacceptable consequences.

4.2.1.4 The inspection intervals for Steam Generator Tubes shall be specified in the"Inservice Inspection Program" for the applicable forty month period commencing with May 1, 1973.Amendment No.$4.2-2 Proposed.

4.2.1,5 Inservice Inspection of ASME Code Class 1, Class 2 and Class 3 components (Quality Groups A, B, and C)shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

4.2.1.6 The inspection interval for the Inservice Pump and Valve Testing Program shall be ten year intervals commencing with January 1, 1981, 1990 and 2000.4.2.1.7 The inspection intervals for Snubbers shall be as defined in Specification 4.14.Basis The inservice inspection program provides assurance for the continued structural integrity of the structures, components and systems of Ginna Station.The programs comply with the ASME Boiler and Vessel Code Section XI"Rulesfor Inservice Inspection of Nuclear Power Plant Components" as practicable, with due consideration to the design and physical access of the'tructures, components and systems as manufactured and constructed.

This compliance will constitute an acceptable basis for satisfying the requirements of General Design Criterion 32, Appendix A of 10 CFR Part 50 and the requirements of Section 50.55a, paragraph g of 10 CFR Part 50.4.2-3 Proposed 4~14, SNUBBER SURVEILLANCE RE UIREMENTS:

4.14.1 Each snubber required by Specification 3.13 to be operable shall be demonstrated operable by performance of the following inservice inspection program and the requirements of Specification 4.2.a.Visual Ins ections The visual inspection period for snubbers under this program shall be based on the results of the previous inspections.

Subsequent visual inspections shall be performed in accordance with the following schedule: No.Inoperable Snubbers of Each Type*Found Durin Ins ection Time Until Subsequent Visual Ins ection**0 1 2 3,4 5,6,7 8 or more 18 months 12 months 6 months 124 days 62 days 31 days+25'25'25'o+25'o+25'25'o" Type of snubber, as used in this specification, shall mean snubbers of the same design and manufacturer, irrespective of capacity.**The inspection interval for each type of snubber shall not be lengthened more than one step at a time unless a generic problem has been identified and corrected; in that event the inspection interval may be lengthened one step the first time and two steps thereafter if no inoperable snubbers of that type are found.4.14-1 Proposed Snubbers may be further categorized into two groups: those accessible and those inaccessible during reactor operation.

Each group may be inspected independently in accordance with the above schedule.b.Visual Ins ection Acce tance Criteria Visual'nspections shall verify: (1)that there are no visible indications of damage or impaired operability, and (2)that the attachments to the foundation or supporting structure 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 other snubbers, irrespective of type, that may be generically susceptible; or (2)the affected snubber is functionally tested in the as-found condition and determined operable per Specification 4.14.1.d.When a fluid port of a hydraulic snubber is found to be uncovered the snubber shall be declared inoperable and shall not be declared inoperable and shall not.be determined operable'ia functional testing unless the test is started with the piston'in the as-found'setting, extending the piston rod in the tension mode direction.

All snubbers connected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.4.14-2 Proposed c.Functional Tests At least once per 18 months during shutdown, a representative sample (at least 10-o of the snubbers required by Specification 3.13)shall be functionally tested either in place or in a bench test.For each snubber that does not meet the functional test acceptance criteria of Specification 4.14.1.d, an additional 10-o of the snubbers shall be functionally tested until no more failures are found or until all snubbers have been functionally tested.The representative sample selected for functional testing shall, as far as practical, include the various configurations, operating environments, range of sizes and capacities of snubbers.In addition to the regular sample, snubbers placed in the same locations as snubbers which failed the previous functional test shall be retested at the time of the next functional test.Additionally, if a failed snubber has been repaired and reinstalled in another location, that failed snubber shall also be retested.These snubbers shall not be included in the regular sample.4.14-3 Proposed.

If during the functional testing, additional sampling is required due to failure of only one type of snubber, the functional testing results shall be reviewed at that time to determine if additional samples should be limited to the type of snubber which has failed, the functional testing.Steam Generator snubbers are excluded from the functional testing requirements until the first refueling outage following completion of the SG snubber replacement program.d.Functional Test Acce tance Criteria The snubber functional test shall verify that: 1)Activation (restraining action)is achieved within the specified range in both tension and compression; 2)Snubber bleed, or release rate where required, is present in both tension and compression, within the fl i specified range;3)Where required, the force required to initiate or lt maintain motion of the snubber is within the specified range in both directions of travel;and 4)For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement is verified.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.4.14-4 Proposed.

~P"I I e.Functional Test Failure Anal sis An analysis shall be made of each failure to meet the functional test acceptance criteria to determine the cause of the failure.The results of this analysis 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 specific case of a snubber selected for functional testing which either fails to activate 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 or evaluated in a manner to ensure their operability.

Any testing performed as part of this requirement shall be independent of the requirements stated in Specification 4.14.1.c for snubbers not meeting the functional test acceptance criteria.For any snubbers found inoperable, an engineering evaluation shall be performed on the components to which the inoperable snubbers are attached.The purpose of this engineering evaluation shall be to determine if the components to which the inoperable snubbers are attached were adversely affected by the inoperability of the snubbers in order to ensure that the component remains capable of meeting the designed service.4.14-5 Proposed Ir f l I 1 J

~~f.Snubber Seal Service Life Monitorin The seal service life of hydraulic snubbers shall be monitored and seals replaced as required to ensure that the service life is not exceeded between surveillance inspections during a period when the snubber is required to be operable.The seal replacements shall be documented and the documentation shall be retained in accordance with Technical Specification 6.10.2.Basis Snubbers are provided 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.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 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-o)may not be used to lengthen the required inspection interval.Any inspection whose results require a shorter inspection interval will override the previous schedule.4.14-6 Proposed When the cause of the rejection of a snubber is clearly established and remedied for that snubber and for any other snubbers that may be generically susceptible, and verified by inservice functional testing, that snubber may be exempted from being counted as inoperable.

Generically susceptible snubbers are those which are of a specific make or model and have the same design features directly related to the snubber rejected or are those which are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.

When a snubber is found, inoperable, an engineering evaluation of the supported component is performed in order to determine if any safety-related component or system has been adversely affected by the inoperability of the snubber.This evaluation is in addition to the determination of the snubber mode of failure.The engineering evaluation shall determine whether or not the snubber failure has imparted.a significant effect on or caused degradation of the supported component or system, to ensure they remain capable of meeting the designed service.4.14-7 Proposed ll EI I To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested during plant shutdowns at less than or equal to 18 month intervals.

Observed failures of these sample snubbers shall require functional testing of additional units.Hydraulic snubbers and.mechanical snubbers may each be treated as a different entity for the above surveillance programs.The service life of a snubber is evaluated via manufacturer input and engineering information through consideration of the snubber service conditions and functional design requirements.

The only snubber components with service lives not expected to exceed plant life are seals and o-rings fabricated from certain seal materials.

Therefore, a seal replacement program is required to monitor snubber seal and o-ring service life to assure snubber operability is not degraded due to exceeding component service life.4.14-8 Proposed m.Records of the service lives of all hydraulic and mechanical snubbers listed in the Xnservice Xnspection Program including the date at which the service life commences and associated installation and maintenance records.6.10-3 Proposed r t