ML18067A677

Proposed Tech Specs,Deleting Snubber Operability Requiements in LCO 3.20 & Snubber Testing Requirements Currently in SR 4.16

ML18067A677
Person / Time
Site:	Palisades
Issue date:	09/03/1997
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18067A676	List: ML18067A675 ML18067A677
References
NUDOCS 9709090203
Download: ML18067A677 (35)

Text

ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATIONS CHANGE REQUEST DELETION OF SNUBBER REQUIREMENTS

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970903 -PDR ADOCK 05000255 p PDR Proposed Pages 5 Pages

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PLANT TECHNICAL TABLE OF CONTENTS SECTION DESCRIPTION 3.0 LIMITING CONDITIONS FOR OPERATION (continued) 3.10 3.10.1 3.10.2 3.10.3 3.10.4 3.10.5 3.10.6 3.10.7 CONTROL ROD AND POWER DISTRIBUTION LIMITS Shutdown Margin Requirements Deleted Part-Length Control Rods Misaligned or Inoperable Rod Regulating Group Insertion Limits Shutdown Rod Limits Low Power Physics Testing 3.11 POWER DISTRIBUTION INSTRUMENTATION 3.11.1 Incore Detectors 3.11.2 Excore Power Distribution Monitoring System 3 .12 3 .13 3.14 3 .15 3 .16 B3.16 Figure 3.11-1 Axial Variation Bounding Condition MODERATOR TEMPERATURE COEFFICIENT OF REACTIVITY Deleted CONTROL ROOM VENTILATION Deleted ESF SYSTEM INITIATION INSTRUMENTATION SETTINGS Table 3.16.1 ESF System Initiation Instrument Setting Limits Basis -ESF System Instrumentation Settings 3.17 INSTRUMENTATION AND CONTROL SYSTEMS 3.17.1 Reactor Protective System Instruments Table 3.17.1 Instrument Requirements for RPS 3.17.2 Engineered Safety Features Instruments Table 3.17.2 Instrument Requirements for ESF Systems 3.17.3 Isolation Functions Instruments Table 3.17.3 Instrument Requirements Isolation Functions 3.17.4 Accident Monitoring Instruments Table 3.17.4 Instrument Requirements for Accident Monitoring 3.17.5 Alternate Shutdown System Instruments Table 3.17.5 Instruments for the Alternate Shutdown System 3.17.6 Other Safety Feature Instruments Table 3.17.6 Instruments for Other Safety Features B3.17 Basis -Instrumentation Systems 3.18 3.19 3.20 3.21 3.22 3.23 3.23.1 3.23.2 3.23.3 Table 3.23-3 Deleted IODINE REMOVAL SYSTEM Deleted Deleted Deleted POWER DISTRIBUTION LIMITS Linear Heat Rate Radial Peaking Factors Quadrant Power Tilt -Tq Power Distribution Measurement i i Uncertainty PAGE NO 3-1 3-50 3-50 3-51 3-51 3-52 3-52 3-53 3-53 3-56 3-56 3-57 3-59 3-60 3-60 3-61 3-62 3-63 3-63 B 3.16-1 3-64 3-64 3-65 3-66 3-67 3-68 3-69 3-70 3-71 3-72 3-73 3-74 3-77 B 3.17-1 3-79 3-79 3-84 3-84 3-84 3-84 3-84 3-86 3-87 3-88 Amendment No. -+/--6-9, -l-74, i:-7&,

PLANT TECHNICAL SPECIFICAT,NS TABLE OF CONTENTS DESCRIPTION SECTION 4.0 SURVEILLANCE REQUIREMENTS 4 .1 4.2 4.3 Table 4.2.1 Table 4.2.2 Table 4.2.3 OVER PRESSURE PROTECTION SYSTEM TESTS EQUIPMENT AND SAMPLING TESTS Minimum Frequencies for Sampling Tests Minimum Frequencies for Equipment Tests Ventilation Systems Tests SYSTEMS SURVEILLANCE 4.4 Table 4.3.1 Primary Coolant System Pressure Isolation Valves Deleted 4.5 4.5.1 4.5.2 4.5.3 4.5.4 4.5.5 4.5.6 4.6 4.6.l 4.6.2 4.6.3 4.6.4 4.6.5 4.7 4.7.1 4.7.2 4.7.3 CONTAINMENT TESTS Integrated Leakage Rate Tests Local Leak Detection Tests Containment Isolation Valves Surveillance for Prestressing System End Anchorage Concrete Surveillance Dome Delamination Surveillance SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEMS TESTS Safety Injection System Containment Spray System Pumps Valves Containment Air Cooling System EMERGENCY POWER SYSTEM PERIODIC TESTS Diesel Generators Station Batteries Emergency Lighting MAIN STEAM STOP VALVES AUXILIARY FEEDWATER SYSTEM REACTIVITY ANOMALIES Deleted AUGMENTED ISi PROGRAM FOR HIGH ENERGY LINES Deleted AUGMENTED ISI PROGRAM FOR STEAM GENERATORS PRIMARY SYSTEM FLOW MEASUREMENT Deleted 4.8 4.9 4.10 4.11 4.12 4.13 4.14 4.15 4.16 4.17 INSTRUMENTATION SYSTEMS TESTS Table 4.17.1 Surveillance for the RPS Table 4-17.2 Surveillance for ESF Functions Table 4-17.3 Surveillance for Isolation Functions Table 4-17.4 Surveillance for Accident Monitoring Table 4-17.5 Surveillance for Alternate Shutdown Table 4-17.6 Surveillance for Other Safety Functions 84.17 4.18 4.18. l 4.18.2 4.19 4.19.1 4.19.2 4.20 Basis -Instrumentation Systems Surveillance POWER DISTRIBUTION INSTRUMENTATION Incore Detectors Excore Monitoring System POWER DISTRIBUTION LIMITS Linear Heat Rate Radial Peaking Factors MODERATOR TEMPERATURE COEFFICIENT (MTC) ii i PAGE NO 4-1 4-6 4-7 4-9 4-11 4-14 4-16 4-18 4-19 4-19 4-19 4-19 4-21 4-2la 4-21c 4-21c 4-24 4-24 4-24 4-24 4-24 4-25 4-42 4-42 4-42 4-43 4-44 4-45 4-46 4-46 4-60 4-65 4-66 4-70 4-70 4-75 4-76 4-77 4-78 4-79 4-80 4-81 B 4.17-1 4-83 4-83 4-83 4-84 4-84 4-84 4-85 Amendment No. -+/--6-2-, -l-74, ----------------------------------

e 3.19 IODINE REMOVAL SYSTEM Basis Iodine Removal System TSP Baskets (continued)

The quantity of TSP placed in containment is designed to adjust the pH of the sump water to be between 7.0 and 8.0. The pH needs to remain< 8.0 to remain within the assumptions of the analysis for post-LOCA Hydrogen concentration in the containment.

That analysis concludes that hydrogen generation will not exceed the limits of Regulatory Guide 1.7. Weight limits: The minimum acceptable amount of TSP is that weight which will ensure a sump solution 7.0 after a LOCA, with the maximum amount of water at the minimum initial pH possible in the containment sump; a maximum acceptable amount of TSP is that weight which could cause a sump solution pH 8.0 with a minimum amount of water at a maximum initial pH. The TSP is stored in wire mesh baskets placed *inside the containment at the 590. ft. elevation.

Any quantity between 8,300 and 11,000 lb. of TSP will result in a pH in the desired range. Basis Applicability 3.19 TSP baskets support operation of the Safety Injection System, The Containment Spray System, and the SIRWT. Therefore, the TSP baskets are required to be OPERABLE when the PCS is greater than 300°F. Basis Action Statements 3.19 The listed Action is required to be completed within the specified time if the conditions of the specification are not met. If, prior to expiration of the specified completion time, the required conditions are restored, completion of the Action is not required.

Each specified completion time starts at the time it is discovered that the Action statement is applicable.

Action 3.19.1 -TSP not within limit -If it is discovered that the TSP in the containment building is not within limits, action must be taken to restore the TSP to within limits. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for restoring the TSP within limits, where possible, because 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is the same time allowed for restoration of other ECCS components.

Action 3.19.2 -Required action AND associated completion time not met -If the required action cannot be met within the associated completion time, the plant must be placed in a condition where the inoperable equipment is not required.

Twelve hours are allowed to bring the plant to HOT SHUTDOWN, and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to reach conditions where the affected equipment is not required, to avoid unusual plant transients.

Both the 12 and the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time periods start when it is discovered that Action 3.19.2 is applicable. (Next Page is 3-84) Amendment No . .f-6.S, 3-79b 3.20 3.21 3.22 3.23 3.23.l Deleted Deleted Deleted POWER DISTRIBUTION LIMITS LINEAR HEAT RATE (LHR) The LHR in the peak power fuel rod at the peak power elevation Z shall be maintained within the limits specified in the COLR. APPLICABILITY:

Power operation above 50% of RATED POWER. ACTION 1: When using the incore alarm system to monitor LHR, and with four or more coincident incore alarms, initiate within 15 minutes corrective action to reduce the LHR to within the limits and restore the incore readings to less than the alarm setpoints within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or failing this, be at less than 50% RATED POWER within the following 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ACTION 2: When using the excore monitoring system to monitor LHR and with the AO deviating from the target AO by more than 0.05, discontinue using the excore monitoring system for monitoring LHR. If the incore alarm system is inoperable, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be at 85% (or less) RATED POWER and follow the procedure in ACTION 3 below. ACTION 3: If the incore alarm system is inoperable and the excore monitoring system is not being used to monitor LHR, operation at less than or equal to 85% RATED POWER may continue provided that incore readings are recorded manually.

Readings shall be taken on a minimum of 10 individual detectors per quadrant (to include a total number of 160 detectors in a 10-hour period) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and at least every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> thereafter.

If readings indicate a local power level equal to or greater than the alarm setpoints, the action specified in ACTION I above shall be taken. Amendment No. 31-, W, 68, i:-+/--8, .f-44, 1:-&2-, -l-69-3-84 4.15 Primary System Flow Measurement Applicability Applies to the measurement of primary system flow rate with four primary coolant pumps in operation.

Objective To provide assurance that the primary system flow rate is equal to or above the flow rate required in 3.1.1.c. Specification After each refueling outage, or after plugging 10 or more steam generator tubes, a primary system flow measurement shall be made with four primary coolant pumps in operation.

This measurement shall be made within the first 31 days of rated power operation.

This surveillance program assures that the reactor coolant flow is consistent with that assumed as the basis for Specification 3.1.lc. 4.16 Deleted (Next Page is 4-75) 4-70 Amendment No. lS ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATIONS CHANGE REQUEST DELETION OF SNUBBER REQUIREMENTS Existing Pages Marked to Show Proposed Changes 11 Pages

. . SECTION 3.0 PALISADES PLANT TECHNICAL SPECIFICATIONS TABLE OF CONTENTS DESCRIPTION LIMITING CONDITIONS FOR OPERATION (continued) 3.10 3.10.1 3.10.2 3.10.3* 3.10.4 3.10.5 3.10.6 3.10.7 CONTROL ROD AND POWER DISTRIBUTION LIMITS Shutdown Margin Requirements Deleted Part-Length Control Rods Misaligned or Inoperable Rod Regulating Group Insertion Limits Shutdown Rod Limits Low Power Physics Testing 3.11 POWER DISTRIBUTION INSTRUMENTATION 3.11.1 Incore Detectors 3.11.2 Excore Power Distribution Monitoring System 3.12 3.13 3.14 3.15 3.16 B3.16 Figure 3.11-1 Axial Variation Bounding Condition MODERATOR TEMPERATURE COEFFICIENT OF REACTIVITY Deleted CONTROL ROOM VENTILATION Deleted ESF SYSTEM INITIATION INSTRUMENTATION SETTINGS Table 3.16.l ESF System Initiation Instrument Setting Limits Basis -ESF System Instrumentation Settings 3.17 INSTRUMENTATION AND CONTROL SYSTEMS 3.17.1 Reactor Protective System Instruments Table 3.17.1 Instrument Requirements for RPS 3.17.2 Engineered Safety Features Instruments Table 3.17.2 Instrument Requirements for ESF Systems 3.17.3 Isolation Functions Instruments Table 3.17.3 Instrument Requirements Isolatinn Functions 3.17.4 Accident Monitoring Instruments Table 3.17.4 Instrument Requirements for Accident Monitoring 3.17.5 Alternate Shutdown System Instruments Table 3.17.5 Instruments for the Alternate Shutdown System 3.17.6 Other Safety Feature Instruments Table 3.17.6 Instruments for Other Safety Features 83.17 Basis -Instrumentation Systems 3.18 Deleted 3.19 IODINE REMOVAL SYSTEM :

3.22 Deleted 3.23 POWER DISTRIBUTION LIMITS 3.23.1 Linear Heat Rate 3.23.2 Radial Peaking Factors 3.23.3 Quadrant Power Tilt -Tq Table 3.23-3 Power Distribution Measurement Uncertainty i i PAGE NO 3-1 3-50 3-50 3-51 3-51 3-52 3-52 3-53 3-53 3-56 3-56 3-57 3-59 3-60 3-60 3-61 3-62 3-63 3-63 B 3.16-1 3-64 3-64 3-65 3-66 3-67 3-68 3-69 3-70 3-71 3-72 3-73 3-74 3-77 B 3.17-1 3-79 3-79 3 Sl 3-84 3-86 3-87 3-88 Amendment No. -+/--6-9, -l-74,

... . PALISADES PLANT TECHNICAL SPECIFICATIONS TABLE OF CONTENTS DESCRIPTION SECTION 4.0 SURVEILLANCE REQUIREMENTS 4.1 4.2 4.3 Table 4.2.1 Table 4.2.2 Table 4.2.3 OVER PRESSURE PROTECTION SYSTEM TESTS EQUIPMENT AND SAMPLING TESTS Minimum Frequencies for Sampling Tests Minimum Frequencies for Equipment Tests Ventilation Systems Tests SYSTEMS SURVEILLANCE 4.4 Table 4.3.1 Primary Coolant System Pressure Isolation Valves Deleted 4.5 4.5.1 4.5.2 4.5.3 4.5.4 4.5.5 4.5.6 4.6 4.6.l 4.6.2 4.6.3 4.6.4 4.6.5 4.7 4.7.1 4.7.2 4.7.3 CONTAINMENT TESTS Integrated Leakage Rate Tests Local Leak Detection Tests Containment Isolation Valves Surveillance for Prestressing System End Anchorage Concrete Surveillance Dome Delamination Surveillance SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEMS TESTS Safety Injection System Containment Spray System Pumps Valves Containment Air Cooling System EMERGENCY POWER SYSTEM PERIODIC TESTS Diesel Generators Station Batteries Emergency Lighting MAIN STEAM STOP VALVES AUXILIARY FEEDWATER SYSTEM REACTIVITY ANOMALIES Deleted AUGMENTED ISI PROGRAM FOR HIGH ENERGY LINES Deleted AUGMENTED ISi PROGRAM FOR STEAM GENERATORS PRIMARY SYSTEM FLOW MEASUREMENT 4.8 4.9 4.10 4.11 4.12 4.13 4.14 4.15 4.16 4.17 lNSiRUMENTATION SYSTEMS TESTS Table 4.17.1 Surveillance for the RPS Table 4-17.2 Surveillance for ESF Functions Table 4-17.3 Surveillance for Isolation Functions Table 4-17.4 Surveillance for Accident Monitoring Table 4-17.5 Surveillance for Alternate Shutdown Table 4-17.6 Surveillance for Other Safety Functions 84.17 4.18 4.18. l 4.18.2 4.19 4.19.1 4.19.2 4.20 Basis -Instrumentation Systems Surveillance POWER DISTRIBUTION INSTRUMENTATION Incore Detectors Excore Monitoring System POWER DISTRIBUTION LIMITS Linear Heat Rate Radial Peaking Factors MODERATOR TEMPERATURE COEFFICIENT (MTC) ii i PAGE NO 4-1 4-6 4-7 4-9 4-11 4-14 4-16 4-18 4-19 4-19 4-19 4-19 4-21 4-21a 4-21c 4-21c 4-24 4-24 4-24 4-24 4-24 4-25 4-42 4-42 4-42 4-43 4-44 4-45 4-46 4-46 4-60 4-65 4-66 4-70 4-75 4-76 4-77 4-78 4*79 4-80 4-81 B 4.17-1 4-83 4-83 4-83 4-84 4-84 4-84 4-85 Amendment No. -l-6-2-, -l-74, 3.19 IODINE REMOVAL SYSTEM Basis Iodine Removal System TSP Baskets (continued)

The quantity of TSP placed in containment is designed to adjust the pH of the sump water to be between 7.0 and 8.0. The pH needs to remain< 8.0 to remain within the assumptions of the analysis for post-LOCA Hydrogen concentration in the containment.

That analysis concludes that hydrogen generation will not exceed the limits of Regulatory Guide 1.7. Weight limits: The minimum acceptable amount of TSP is that weight which will ensure a sump solution 7.0 after a LOCA, with the maximum amount of water at the minimum initial pH possible in the containment sump; a maximum acceptable amount of TSP is that weight which could cause a sump solution pH of 8.0 with a minimum amount of water at a maximum initial pH. The TSP is stored in wire mesh baskets placed inside the containment at the 590 ft. elevation.

Any quantity between 8,300 and 11,000 lb. of TSP will result in a pH in the desired range. Basis Applicability 3.19 TSP baskets support operation of the Safety Injection System, The Containment Spray System, and the SIRWT. Therefore, the TSP baskets are required to be OPERABLE when the PCS is greater than 300°F. Basis Action Statements 3.19 The listed Action is required to be completed within the specified time if the conditions of the specification are not met. If, prior to expiration of the specified completion time, the required conditions are restored, completion of the Action is not required.

Each specified completion time starts at the time it is discovered that the Action statement is applicable.

Action 3.19.l -TSP not within limit -If it is discovered that the TSP in the containment building is not within limits, action must be taken to restore the TSP to within limits. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for restoring the TSP within limits, where possible, because 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is the same time allowed for restoration of other ECCS components.

Action 3.19.2 -Required action AND associated completion time not met -If the required action cannot be met within the associated completion time, the plant must be placed in a condition where the inoperable equipment is not required.

Twelve hours are allowed to bring the plant to HOT SHUTDOWN, and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to reach conditions where the affected equipment is not required, to avoid unusual plant transients.

Both the 12 and the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time periods start when it is discovered that Action 3.19.2 is applicable.

Amendment No. +&£, 3-79b

• -I ii

.. ""* I 3.23 3.23.l

• POWER DISTRIBUTION LIMITS LINEAR HEAT RATE (LHR} *The LHR in the peak power fuel rod at the peak power elevation Z shall be maintained within the limits specified in the COLR. APPLICABILITY:

Power operation above 50% of RATED POWER. ACTION 1: When using the incore alarm system to monitor LHR, and with four or more coincident incore alarms, initiate within 15 minutes corrective action . to reduce the LHR to within the limits and restore the incore readings to less than the alarm setpoints within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or failing this, be at less than 50% RATED POWER within the following 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ACTION 2: When using the excore monitoring system to monitor LHR and with the AO deviating from the target AO by more than 0.05, discontinue using the excore monitoring system for monitoring LHR. If the incore alarm system is inoperable, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be at 85% (or less) RATED POWER and follow the procedure in ACTION 3 below. ACTION 3: If the incore alarm system is inoperable and the excore monitoring system is not being used to monitor LHR, operation at less than or equal to 85% RATED POWER may continue provided that incore readings are recorded manually.

Readings shall be taken on a minimum of 10 individual detectors per quadrant (to include a total number of 160 detectors in a IO-hour period) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and at least every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> thereafter.

If readings indicate a local power level equal to or greater than the alarm setpoints, the action specified in ACTION 1 above shall be taken. Amendment No. a:!-, W, 6-8, .f--l-8., -l-44, .f-6-2., +/--6-9 3-84

-..... . 4.15 Primary System Flow Measurement Applicability Applies to the measurement of primary system flow rate with four primary coolant pumps in operation.

Objective To provide assurance that the primary system flow rate is equal to or above the flow rate required in 3.1.1.c. Specification After each refueling outage, or after plugging 10 or more steam generator tubes, a primary system flow measurement shall be made with four primary coolant pumps in operation.

This measurement shall be made within the first 31 days of rated power operation.

This surveillance program assures that the reactor coolant flow is consistent with that assumed as the basis for Specification 3.1.lc. 4-70 Amendment No. l-i-, -l-l-8

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ATTACHMENT 3 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATIONS CHANGE REQUEST DELETION OF SNUBBER REQUIREMENTS Comparison of TS 4.16 and Code Requirements 8 Pages TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS

• 1 Current Technical Specifications Wording/Requirements TS 4.16 -Reference to Inservice Inspection Program for Snubbers TS 4.16.1 -"Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program in addition to the requirements of Specification 6.5.7. As used in this specification, 'type of snubber' shall mean snubbers of the same design and manufacturer, irrespective of capacity." TS Section 4.16.la -"Snubbers are categorized as accessible or inaccessible during reactor operation." TS 4.16.la -Visual Inspection (Guidance)

-This section contains details on inspection interval changes based upon the number of unacceptable snubbers found and the length of the previous interval.

Code Wording/Requirements and Future Differences Snubbers covered by this ISI/IST Program are ASME Code Class 1,2, and 3 components and referenced by TS Section 6.5.7, which in turn invokes ASME Section XI. The current edition of ASME Section XI-1989, Subsection IWF-5000, refers to ASME/ANSI OM-1987, Part 4 ("OMa-1988, Part 4") where snubber inservice examination and testing is concerned.

e TS 6.5.7, the Inservice Inspection and Testing Program and 10 CFR 50.55a(b)(viii) provide requirements to comply with the Code. The Code does not use "type of snubber" in the same context as the TS. The definition is not needed to implement the Code requirements.

OMa-1988 Part 4, Section 1.6 -"Snubbers may be categorized as accessible or inaccessible and may be considered separately for the purpose of examination." OMa-1988 Part 4, Section 2.3.2 contains the Code requirements for inservice examination intervals.

On 6/28/96, the NRC approved Pali sades' "Snubber Relief Request #1," allowing use of alternative inspection intervals contained in TS 4.16.1. TS 4.16.l was previously amended to revise the visual inspection requirements to be consistent with the guidance contained in GL 90-09. In addition to this TS change request, a Relief Request is enclosed asking for NRC approval to use the visual inspection interval guidance in GL 90-09 instead of the currently approved TS 4.16.l intervals, since TS 4.16 is to be deleted.

TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS

• 2 TS 4.16.lb -Visual Inspection Acceptance Criteria -This section contains general information necessary to determine snubber operability based on visual inspection.

Additionally, follow up corrective action and inspection interval adjustment is outlined for dealing with snubbers determined to be unacceptable.

TS 4.16.lb -Visual inspection shall verify that (1) the snubber has no visible indications of damage or impaired operability TS 4.16.lb -Visual inspection shall verify that (1) ..... (2) attachments to the foundation or supporting structure are functional, and (3) fasteners for the attachment of the snubber to the component and to the snubber anchorage are functional . TS 4.16.lb -nsnubbers which appear inoperable as a result of visual inspections shall be classified as unacceptable and may be reclassified acceptable 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, irrespective of type, that may be generically susceptible; and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per TS 4.16.ld or 4.16.le, as applicable." TS 4.16.lb -uAll snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval." OMa-1988 Part 4, Section 2.3.l covers snubber inservice examination in much more detail than that found in current TS. Specific requirements will be addressed in detail later in this table. OMa-1988 Part 4, Section 2.3.1.1 -uinservice examination shall be a visual examination for impaired functional ability due to physical damage, leakage, corrosion, or degradation from environmental exposure or operating conditions." OMa-1988 Part 4, Section 2.3.l.2(a)

-uVisual observation of loose fasteners, deformed members, or detection of disconnected components requires identification of the snubber installation as unacceptable." OMa-1988 Part 4, Section 2.3.4.2 -uThe snubber(s) that is found to be unacceptable as a result of inservice examination may be tested in accordance with the requirements of para. 3.2, provided that testing can resolve the unacceptable condition.

Results which satisfy the operability test criteria may be used to recategorize the snubber(s) as acceptable." OMa-1988 Part 4, Section 2.3.l.2(c)

-uif the fluid level is less than the minimum amount, the installation is to be identified as unacceptable unless a test is performed establishing that the performance of the snubber is within specified limits."

TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS TS 4.16.lb -uA review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the action requirements shall be met." Currently, TS 3.20.la provides a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a 11 owed action ti me for restoration of snubber operability before declaring the supported equipment to be inoperable.

TS 4.16.lc -Functional Tests -This section contains general information related to test interval, test sample size, general test criteria, and follow up actions associated with test failures.

TS 4.16.lc -"At least once per 18 months during a shutdown, a representative sample (10% of the total safety-related snubbers in use at the plant) shall be functionally tested either in place or in a bench test." Per Note 1 on page 4-72 of the TS, snubbers with capacity greater than 50 KIP were not to be included when defining the total number of safety-related snubbers.

TS 4 .16. le -"The test sha 11 verify the snubber has freedom of movement and is not frozen up." accordance with the guidance of GL 91-18. If a required snubber is determined to be inoperable, the supported equipment would immediately be declared inoperable, and the appropriate TS actions would be followed.

OMa-1988 Part 4, Section 3.0, "Testing Requirements," covers snubber Inservice Testing in much more detail than that found in current TS. Specific requirements will be addressed in detail later in this table. OMa-1988 Part 4, Section 3.2.2, "Inservice Operability Testing Frequency.

Testing shall take place at least every refueling outage using a sample of snubbers in the facility." OMa-1988 Part 4, Section 3.2.3.1, "The 10% Testing Sample Plan" -Based on the total number of snubbers at Palisades (29 total snubbers), this sample plan is most appropriate and will not alter the sample sizes. This total includes snubbers of all capacity; difference related to snubbers with capacity >50 KIP will be discussed later. OMa-1988 Part 4, Sections 3.2.1.2 and 3.2.6(e) -These sections discuss the use of appropriate loads (in a bench test) and the use sub-component testing such as True Test-In-Place (TTIP) methods employed on Palisades steam generator snubbers.

The NRC has reviewed and approved the use of TTIP. OMa-1988 Part 4, Section s 3.2.1.l(a)

-"the force that will initiate motion (breakaway force), the force that will maintain low velocity displacement (drag force), or both, as required by the documents of para. 1.5.2, is within specified limits, both in tension and compression;."

TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS TS 4.16.lc -uFor each snubber which did not meet the functional test acceptance criteria of Specification 4.16.l.d or 4.16.1.e, an additional 10% of the total shall be functionally tested." TS 4.16.lc -uThe representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capacity of snubbers.

Snubbers identified as especially difficult to remove or in high radiation areas during shutdown shall also be included in the sample." Per Note 1 on page 4-72 of the TS, snubbers with capacity greater than 50 KIP were not to be included when defining the total number of safety-related snubbers.

TS 4.16.lc -uin 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." . OMa-1988 Part 4, Section 3.2.3.l(b) 0 Additional Test(s) Lots -Results of Unacceptable Snubbers in the Same Test Interval." -This section makes provisions to test additional snubbers based upon the initial test sample size and the number of test failures.

Although the sample expansion required by the Code is not the same as that required by TS, the Code requirement has been found to be acceptable.

OMa-1988 Part 4, Section 3.2.3.l(a) uinitial Sample Test Lots -Representative/

Random Sampling" and Section 3.2.3.l(d) usubsequent Test Intervals

-Sample Selection Criteria" -These sections provide the same guidance as *4 . .

.. TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS

• 5 TS 4.16.lc -uif 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 design subject to the same defect shall be functionally tested. This testing requirement shall be independent of the requirements stated above for snubbers not meeting the functional test acceptance criteria." TS Page 4-72 Note I -"Snubbers of rated capacity greater than 50,000 pounds are not to be included when defining the total number of safety-related snubbers in use at the p 1 ant." TS Page 4-72 Note 2 -"Permanent or other exemptions from functional testing for individual snubbers may be granted by the Commission only if a justifiable basis for exemption is presented and/or snubber life destructive testing was performed to qualify the snubber operability for all design conditions at either the completion of their fabrication or at a subsequent date." OMa-1988 Part 4, Section 3.2.4.1 -usnubbers that do not meet the operability testing acceptance criteria in para. 3.2.l shall be evaluated to determine the cause of the failure." The 103 Testing Sample PJan Corrective Action (compared to this TS Section):

OMa-1988 Part 4, Section 3.2.5.l(a)(l)

-"all snubbers in a test failure mode group shall be replaced/modified.

The replaced/modified snubber(s) shall be reclassified as acceptable and shall be examined in accordance with para. 2.3.3.3; OR" OMa-1988 Part 4, Section 3.2.5.l(a)(2)

-"all unacceptable snubbers in the test failure mode group shall be replaced/repaired to the originally qualified condition and the number of unacceptable snubber(s) shall determine the additional testing lots in accordance with para. 3.2.3.l(b);" -OMa-1988 Part 4, Section 3.2.1.3 "Qualitative Testing" -This section provides a similar option and regulating authority approval requirement for not performing conventional functional testing.

TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS

• 6 TS 4.16.lc -usnubbers of rated capacity > 50 Kip will be functionally tested in lots comprising 25% of their total during each refueling outage." -Palisades' 16 steam generator snubbers have a capacity > 50 KIP. TS 4.16.lc -urn the event of one snubber failure out of the four tested, no additional snubbers will be tested provided the problem is non-generic.

For each additional snubber failure, however, two additional snubbers will be tested until no further snubber failures are identified or all snubbers have been tested." TS 4.16.lc -uGeneric failures will be handled as specific circumstances require." TS 4.16.lc -uFor the snubber(s) found inoperable, an engineering evaluation shall be performed on the components which are suppressed by the snubber(s).

The purpose of this engineering evaluation shall be to determine if the components suppressed by the snubber(s) were adversely affected by the inoperability of the snubber(s) in order to ensure that the suppressed component remains capable of meeting the designed service." TS 4.16.ld (1) -Hydraulic Snubbers Functional Test Acceptance Criteria -uActivation (restraining action) is achieved within the specified range of velocity in both tension and compression" OMa-1988 Part 4 gives explicit guidance on how to handle generic problems.

The generic problem is categorized per Section 3.2.4.2 uTest failure Mode Groups." Per Section 3.2.4.3, all affected or potentially affected snubbers must be included in the corrective action process outlined in Section 3.2.5.1. OMa-1988 Part 4, Section 2.3.5.5 -uAn evaluation shall be performed for possible damage to the supported system or component." OMa-1988 Part 4, Section 3.2.5.4 -uAn evaluation shall be performed to ensure that the supported component(s)/system has not been impaired due to a failed snubber." OMa-1988 Part 4, Section 3.2.1.l(b)

-uactivation is within the specified range of velocity or acceleration in both tension and compression." '*

TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS

• 1 TS 4.16.ld (2} -Hydraulic Snubbers Functional Test Acceptance Criteria -usnubber bleed, or release rate, where required, is within the specified range in compression or tension. For snubbers specifically not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified." TS 4.16.le (1) -Mechanical Snubbers Functional Test Acceptance Criteria -uThe force that initiates free movement in either tension or compression is less than the specified maximum drag force (breakaway friction)." TS 4.16.le (2) -Mechanical Snubbers Functional Test Acceptance Criteria -uActivation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression." TS 4.16.le (3) -Mechanical Snubbers Functional Test Acceptance Criteria -usnubber release rate, when required, is within the specified range in compression or tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified." OMa-1988 Part 4, Section 3.2.1.l(c)

-urelease rate, where applicable, is within the specified range in tension and compression.

For units specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be demonstrated." OMa-1988 Part 4, Section 3.2.1.l(a)

-uthe force that will initiate motion (breakaway force), the force that will maintain low velocity displacement (drag force), or both , as required by the documents of para. 1.5.2, is within specified limits, both in tension and compression." OMa-1988 Part 4, Section 3.2.1.l(b)

-uactivation is within the specified range of velocity or acceleration in both tension and compression." OMa-1988 Part 4, Section 3.2.1.l(c)

-urelease rate, where applicable, is within the specified range in tension and compression, For units specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be demonstrated." ' \

TECHNICAL SPECIFICATION CHANGE REQUEST -DELETION OF SNUBBER REQUIREMENTS ATTACHMENT 3 -COMPARISON OF TECH SPEC 4.16 and OMa-1988 REQUIREMENTS TS 4.16.lf -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." "Concurrent with the first visual inspection and at least once per 18 months thereafter, the installation and maintenance records for each safety related snubber in use in the plant shall be reviewed to verify that the service life has not been exceeded or will not be exceeded prior to the next scheduled service life review. If the indicated service life will be exceeded prior to the next scheduled 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 service life review." OMa-1988 Part 4 does not have any provisions for snubber service life monitoring.

The existing requirement for service life monitoring has been moved to the Operating Requirements Manual, which is controlled under the provisions of 10 CFR 50.59. *8

.. *./I ATTACHMENT 4 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATIONS CHANGE REQUEST DELETION OF SNUBBER REQUIREMENTS TS 4.16 Marked to Identify Related Code Paragraphs 4 Pages I. ,-of(J,.._ -19Be fltflfr '-('

/. (o 85 f 1t;t.r1' t/ t5ev-r 2 .3. I of safety-related snubbers as described If one or more unacceptable snubbers are found, the next inspection interval shall be 2/3 (-25%) of the previous interval.

If no

• unacceptable snubbers are found, the next interval may be doubled (-25%), but not to exceed 48 months. The interval extension*

provisions of Technical Specification 4.0.2 are applicable for all inspection intervals up to and including 48 months. Inspections performed before the 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 may not be used to lengthen the required inspection interval.

Any inspection whose results require a shorter inspection interval will override the previous schedule.

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!J',Jr_ 11"1" A'° t )Siu;1 IJ/Jif1£ fkss,(J.11 M'" P1tt-; nttnl5. 4-71 Amendment No. a, -t-43, 174 October 31, 1996

-.-l -. 4.16 4.16.1 INSEBVICE -ECTIOH PROGRAM FOR SHOCK SUPPRE'9fS

<Snubbersl

b. Visual Insoection Acceptance Criteria (continued)

"'"

ION /N Onfa.-1988 "70 Al.CDW oPs. w/MJoP, .s;.iuBflSI.

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41.2.3.1(d A review and evaluation shall be performed and documented justify continued operation with an unacceptable snubber. continued operation cannot be justified, the snubber shall be declared inoperable and the action nts shall be met. o1Vl ... -fl88 PtWT'/ 5f::R,-r, 3. z. z OfJ\o.-1985 PM-r {

• ro SiJ .i:W/l.i .u6 tJfN.:T -fes;' I

{fl, n 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 these snubbers may not be inclu ed the resampling.

if any snubber selected for functional testing either fails t lockup or fails to move, i.e., frozen in place, the cause will ---t.-. evaluated and, if caused by manufacturer or design deficiency, all snubbers of the same design subject to the same defect shall be functionally tested. This testing requirement shall be independent of the requirements stated above for snubbers not meetin the functional test acceptance criteria.

ermanent or o er exemptions from unctional testing for indiv dual snubbers may be granted by the Co11111ission only if a justifiable basis for exemption is presented and/or snubber life destructive testing wa performed to qualify snubber operability for all design conditions at ither the completion of their fabricatio o at a s se uent date. 4-72 Amendment No. 171 April 5, 1996

. . .. 4.16 INSEBV-INSPECTION PROGRAM FOR SHOCK sue SSORS (Snubbers) 4.16.1 c. or t e snubber(s}

ound inoperable, an engineering evaluation shall be performed on the components which are suppressed by the _

snubber(s).

The purpose of this engineering evaluation shall be seo-r. z.1.s s ef determine if the components suppressed by the snubber(s) were adversely affected by the inoperability of the snubber(s) in order to ensure that the suppressed component remains capable of me tin fNi.rr i./ Se.c:..'T1°""'

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"3.2.l. \(i.:.) he designed service. The hydraulic snubber functional test shall verify that:

P,wr'f Sa..-r. 2.. I*\ n er e , or re ease rate, w ere requ1re

• is within the specified range in compression or tension. for snubbers specifically required not to displace under continuous loa the ability of the snubber to with tand load withou shall b verifie L OM4.,-1'l'OB rAa.ir 4 s e.ac: 3. 2. \. \ The mechanical snubber functional test shall verify that: 4-73 Amendment No. , 09, .W, 171 April 5, 1996

.. 4.16 I* 4.16.1 No 1t-.1 0""1.*l'1eN>

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z. (Snubbersl A record of the service life of each snubber, the date designated service life commences and the installation and maintenance records on which the designated service life is based shall be maintained.

Concurrent with the first inservice visual inspection and at least once per 18 months thereafter, the installation and maintenance records for each safety related snubber in use in the plant shall be reviewed to verify that the indicated service life has not been . exceeded or will not be exceeded prior to the next scheduled 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 re-evaluation, replacement or reconditioning shall be indicated in the records. 4-74 Amendment No. a, 6-9, 93, 174 October 31, 1996 (

ENCLOSURE 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 SNUBBER RELIEF REQUEST REQUEST FOR APPROVAL OF ALTERNATE SNUBBER TEST PROGRAM 2 Pages

.. ' '" SNUBBER RELIEF REQUEST REQUEST FOR APPROVAL OF ALTERNATE SNUBBER TEST PROGRAM Code Classes: Various COMPONENTS:

Safety-Related Snubbers CLASS: 1, 2, and 3 FUNCTION:

Snubbers (shock suppressors) prevent the unrestrained movement of safety-related components (including piping) during an earthquake or severe transient to prevent failure of the restrained component or adjacent safety-related equipment.

TEST REQUIREMENT:

IWF-5300 (a) Inservice examinations (of snubbers) shall be performed in accordance with the first Addendum to ASME/ANSI OM-1987, Part 4 (OMa-1988) (b) Inservice examinations sample size shall be determined in accordance with subparagraph 2.3.3b of the first Addendum to ASME/ANSI OM-1987, Part 4 (OMa-1988).

ALTERNATIVE TESTING: In lieu of the schedule requirements of OMa-1988, Palisades will follow the guidance of Generic Letter 90-09 for snubber visual examinations.

The guidance of Generic Letter 90-09 has been approved for use at Palisades as documented in Docket 50-255, dated June 12, 1992 and Technical Specification Amendment Number 164, dated April 20, 1995. 1. The proposed alternative provides for 100% visual examination of the snubber population and for a decrease in the examination frequency (increase in the examination interval) in the event that no unacceptable snubbers are found. 2. If one or more unacceptable snubbers are found during visual examination, the next examination interval shall be 2/3 of the previous interval.

• . .,[ e JUSTIFICATION FOR SNUBBER RELIEF REQUEST NUMBER ONE

• BASIS FOR RELIEF: Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative provides an acceptable level of quality and safety. Subparagraph 2.3.3b of OMa-1988, Part 4 states, " ... , the examination sample size for the next required examination of the group may be reduced if justified by the owner and accepted by the regulatory authority having jurisdiction at the facility." Based on this statement, Palisades requests permission to use the guidance of Generic Letter 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions." The proposed alternative program follows the guidance of Generic Letter 90-09 to establish snubber schedule requirements.

This alternative provides the same confidence level as existing OMa-1988, Part 4 requirements and will generally allow visual examinations and corrective actions during plant outages. Occupational radiation exposure will be reduced by performing examinations during outages. ACCEPTANCE CRITERIA:

The visual examination acceptance criteria shall comply with the criteria provided in ASME/ANSI OMa-1988, Part 4 and as approved by the NRC.