ML19325C701

Proposed Tech Specs Extending Interval for Performance of Visual Insp of Inaccessible Snubbers

ML19325C701
Person / Time
Site:	Byron
Issue date:	10/13/1989
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML19325C699	List: ML19325C698 ML19325C701
References
NUDOCS 8910170193
Download: ML19325C701 (5)

Text

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-f t; . ATTACHMENT 2 a.. -

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PROPOSED CHANGES TO APPENDIX A.

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13 y IICHNLCAL SPECIFICATIONL_OF FACILITY

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-OPERATING LICENSES NPF-37 ..>

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Revised Paag: :3/4.'7-22 1

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qq r h,. [ PLANT SYSTEMS:- *

'3/4.7.8: SNUBBERS:

LIMITING CONDITION FOR OPERATION P

1 ;3.7.8 'All-snubbers shall be OPERABLE. Snubbers excluded from this require-ment'are those installed on nonsafety-related systems-and then only if.their i*

failure or failure of the system on which they are installed would have no

' adverse effect on any safety related system, i

-APPLICABILITY:- MODES 1, 2, 3, and 4.' MODES 5 and 6 for snubbers located on

i. . systems required OPERABLE in those MODES. ,

ACTION:' '

With one or more snubbers inoperable, within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s-replace or restore the Linoperable snubber (s) to OPERABLE status and perform an engineering evaluation '

per Specification 4.7.8 . 9on the at+. ached component or declare. the attached:

system inoperable and folicw the appropriate ACTION statement for that system._ '

l SURVEILLANCE REQUIREMENTS-l 4.7.8 Each s.1ubber shall be demonstrated OPERABLE by performance of the s fo'llowing augmented inservice inspection program and the requirements of Specification 4.0.5.

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, Ja. Inspection Types p

As- used in'this specification, type of snubber shall mean snubbers l of the same design and manufacturer, irrespective of capacity. '

l b.. Visual Inspections

" LSnubbers are categorized as inaccessible or accessible during reactor e operation. Each of these groups (inaccessible ~and accessible) may be '

inspected independently according to the schedule below. The first .

l, inservice visual inspection of each type of snubber shall'be performed '

after 4 months but within 10 months of commencing POWER OPEF.ATION and l shall include all hydraulic and mechanical snubbers. If all snubbers p- .

of each type are found OPERABLE during the first inservice visual /

inspection, the second inservice visual inspection of that type shall be performed at the first refueling outage. Otherwise, subsequent visual inspections of a given t with the following schedule: # ype shall be performed in accordance k

-Ax- un,Y.k Cycle 3 m& be 's"PWQ

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BYRON - UNITS 1 & 2 3/4 7-22

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ATTACBMENT 3

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F ' EVALUATION OF SIGl] HCANT HAZARES_CONSIDERATILHS y

b ' Commonwealth Edison has evaluated this proposed amendment and determined that $

it involves _no significant hazards consideratien. According to 10 CFR ,

1 50.92(cF, a proposed amendment to an operating license involves no significant  ;

hazards! considerations if operation of the facility in accordance with the proposed amendment would not:

1. Involve a significant increase in the probability or consequences of an-accident previously evaluated; or

2. Create the-possibility of a new or different kind of accident from any accident previously evaluated; or

-3. Involve a significant reduction in a margin of safety.

This propc k

• amendment involves a one-time extension of Technical Specification hurveillance interval for performing the inaccessible snubbers visual inspection on Unit 1. This amendment would permit the visual inspectior to be performed during the third refueling outage rather than within 12 months ~25% from the last time the surveillances were performed.

Accident initiating events where snubbers must keep systems operable is independent of the frequency of performing visual inspection of the snubbers.

Therefore, extending the surveillance interval does not affect the probability

! of an. accident occurring. The consequences of an accident should not be l

significantly increased for several reasons. The extension to the surveillance interval is short so the probability of a seismic or_ transient event occurring that requires snubber-response is extremely small. Prior to startup after the last refueling, all. Unit 1 snubbers were determined operable as required by the Technical Specification surveillances. Since startup L containment access has been limited so damage from personnel in containment is

!~ minimized. Also, the snubbers are early in their design life of approximately 40 years so their operation is anticipated to be reliable. The Station is not aware of any seismic or transient events since the last refueling that may have made any snubbers inoperable. Therefore, there is a high degree of confidence that the snubbers should be capable of performing their intended safety function during the short surveillance extension period.

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l The extension of the snubber inspection surveillance interval does not involve

'any equipment additions or modifications at the station or cause the station to be operated in a different manner. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created.

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,< Th purpose of installed snubbers is to ensure structural integrity of the

. system following a seismic event or other event initiating dynamic. loads.

Since the probability of a seismic or transient event occurring during the 1 survelliance extension period 1s remote, anc the probability that a snubber will not function such that system integrity it impacted it sinall, the 0 . proposed Technical Specification amendment has minimal Impact on the' safe L' operation of the plant. The snubbers were determined operable following their last inspection interval and no events have occurred at the plant to suspect they may be inoperable. The possibility of a common mode failure or serious degradation in snubber performance which would affect more than one component '

or system is highly unlikely. The plant is designed to mitigate the consequences of an accident with a single failure of a component or a system.

Therefore, the proposed amendment should not significantly impact the margin

, of safety.

Therefore, based upon the above analysis, Commonwealth Edison concludes that the proposed amendment'to the Technical Specification does not involve a significant hazards consideration.-

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. . i i- ATTACHMENT'4 b Environmental Asses 11nfat P

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Commonwealth Edison.has evaluated the proposed amendment against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21. It has been determined that the proposed change meets the criteria for categorical exclusion'as provided for under 10CFR51.22(c)(9).

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Under this section a licensing action may qualify for categorical exclusion if:

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Issuance of an amendment to a license for a reactor pursuant to Part 50 of 10CFR. changes a requirement with respect to installation or use of a b facility component located within the restricted area, as defined in L :10CFR Part 20, or which changes an inspection or a surveillance

. requirement, provided that (1) amendment involves no significant hazards consideration, (11) there is no significant change in the- types or significant increase in the amounts of any effluents that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

Justification:

1. The. proposed amendment is being submitted pursuant to 10CFR50.90.

2. The proposed amendment involves a change to a surveillance requirement.

3.. The proposed amendme..c involves no significant hazards consideration as I determined pursuant to 10CFR50.92. The Significant Hazards evaluation is l

! included in the licensing submittal. .j

4. The one time surveillance extension-will not change the type or amount of I effluents. The surveillance will still be performed in same manner and L with the same plant conditions.

5. The one time surveillance extension would not cause an increase in

.- individual or cumulative radiation exposure. The surveillance activity as required by Technical Specification will still be performed in same manner and with the same plant conditions.

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