ML20063G307

Proposed Tech Specs SR 4.7.9.i, Snubber Service Life Program, Reflecting Wording from Westinghouse Sts,Rev 4a

ML20063G307
Person / Time
Site:	Sequoyah
Issue date:	02/07/1994
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20063G305	List: ML20063G304 ML20063G307
References
NUDOCS 9402150413
Download: ML20063G307 (13)

Text

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4 e ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-93-11)

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• 1 PLANT SYSTEMS t i

. SURVEILLANCE: REQUIREMENTS (Continued)  ! '!

c. k Visual Inspection Performance'and Evaluation i Visual inspections shall verify (1) that there.are no visible indications of damage or impaired OPERABILTY, (2) bolts attaching the snubber to the foundation or supporting structure are secure, and (3) snubbers. attached -!

to sections of safety-relateu systems that have experienced unexpected potentially damaging transients since the last inspection period shall be  :

evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm' operability. jp j j

Snubbers which appear. inoperable as a result visual inspections may.be  :

determined OPERABLE for the purpose of est ishing the next visual ,,,6 m.

inspection interval, providing that (1) t e cause of'the rejection is.

clearly established and remedied for th particular snubber and for ,

other snubbers that may be generically usceptible; and (2) the affected  !

snubber is functionally testedlAf Aplirdblglin the as-found condition  :

and determined OPERABLE per Specification: 4. 7.9.e. Hydraulic snubbers with inoperable single or common fluid reservoirs which have uncovered fluid ports shall t;e declared inoperable.j hen by auli snu ers wch Kav un ver d fl dp ts e tes d, t tests hall e  ;

pe ormed y- '

y, st rti g w'th t pi on a the

-foun settin and xten ng th pis n d t ex nsio mod direc on. ,

Also, snubbers.which hiva been made inoperable as the result.of unexpected transients, isolated ce age or other such random events, when the provisions of 4.7.9.g and 4.7.9.h lieve been. met and any other appropriate corrective E a action implemented, shall not be counted in determining the next visual inspection interval,

d. Functional Test Schedule, Lot Size, and Comoosition During each refueling outage, a representative sample of'10% of the total of the safety related snubbers in use in the. plant shall-be functionally tested either in place or in a bench test. "

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SEQUOYAH-- UNIT 1 3/4 7-22 Amendment No.12,153 1

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.j q PLANT S STEMS .,

SURVEILLANCE REQUIREMENTS -(Continued)

f. Functional Test Failure Analysis and. Additional Test Lots (Continued)

If more than two snubbers do not meet the functional. test acceptance 1 criteria, an additional lot equal to one-half the original lot size-shall.

be functionally tested for each failed snubber in excess of the two  :

allowed failures. An engineering evaluation shall be made of each failure to meet the functional test acceptance criteria to determine the cause of the failure. The result of this analysis shall be used, if 1 applicable, in selecting snubbers to be tested in the subsequent lot inL  !

an effort to determine the operability of other snubbers which may be subject to the-same failure mode. (Selection of snubbers for future testing may also be based on the failure analysis.) Testing shall continue until not more than one additional inoperable snubber is found within a subsequent required lot or all snubbers of the original inspec-tion group have been tested, or all suspect snubbers identified by the failure analysis have been tested, as applicable.

The discovery of loose or missing attachment fasteners will be evaluated '

to determine whether the cause may be localized or generic. The result  ;

of the evaluation will be used to select other suspect snubbers for  ;

verifying the attachment fasteners, as applicable.

Snubbers shall not be subjected to prior maintenance specifically for the purpose of meeting functional test requirements. '16

g. Functional Test Failure - Attached Component Analysis For snubber (s) found inoperable, an engineering evaluation shall be performed on the components which are restrained by the snubber (s). The purpose of this engineering evaluation shall be to determine if the  :

components restrained'by the snubber (s) were adversely affected by the 1 inoperability of the snubber (s), and in order to ensure th'at the restrained component remains capable of meeting the designed service.

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h. Functional Testing of Repaired and Spare Snubbers Snubbers which fail the visual inspection or the functional test acceptance 1 criteria shall be repaired or replaced. Replacement snubbers and snubbers {

which have repairs which might affect the functional test results shall '

be tested to meet the functional test criteria before installation in the unit. These snubbers shall'have met the acceptance criteria subsequent  ;

to their most recent service, and the functional test must have been performed within 12 months before being installed in the unit.

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i. Snubber Service Life Program I

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hen. The al s vice l' of hyd ulic s _

ers sha be monit ed to'ensu L Ato (# M ct t t th eals not fai etween urveillar e inspect' s. The m imum p re ipscr/ expec d serv' e life f the v ious seal , seal ma ials, and plica- j ti s shal e estim ed bas on engin ring inf .ation, an he seal '

p,all b eplaced so that ie maximu expected tvice lif oes notj MAR 251982 1 SEQUOYAH - UNIT 1 3/4 7 Amendment No. 12 l 1

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I PLANT. SYSTEMS- '

SURVEILLANCE REQUIREMENTS (Continued)

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i. 34u'bber SefvT'e c Life Sco' gram (Con iued) .

7)ccagng / expi during eriod whe e snubber i required to operable. he replac. nts shall documented d the docum ation shal e retained accordane with 6.10.2 . Mechanica snubber dra orce  ;

incre es greater 1an 50 perce of previous measured v es shall ,

ev uated as a indication o impending fa' ure of the s ber. Th e valuation nd any asso ted correcti action shal e docume ed and the doc . ntation sha be retained ' accordance h 6.10.2 .

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j. Exemption From Visual Inspection or Functional Tests'

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Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and if applicable snubber life destructive testing was performed to qualify snubber operability for the applicable design ~

conditions at either the completion of their fabrication or at a subsequent date.

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i June 20, 1985 SEQUOYAH - UNIT 1 3/4 7-25 Amendment No. 39 i t

... i PLANT SYSTEMS ,

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. SURVEILLANCE REQUIREMENTS (Continued) c.

Visual Inspection Performance and Evaluation Visual inspections shall verify (1) that there are no visible indications of damage or impaired OPERABILITY, (2) bolts attachin .

(3) snubbers attached to sections of. safety related and sys have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, .to confirm operability. '

Snubbers which appear inoperable as a result of visual inspections may be determined OPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible:.

and (2) the affected snubber is functionally testedvitEpuetibleff asur<

in the tion as-found condition and determined OPERABLE per Specifica-4.7.9.e.

Hydraulic snubbers with inoperable single or common fluid reservoirs which have uncovered fluid ports shall be declared

_porinoperable.

s at teste I When ydrauli snubbers nich hay uncovere fluid the tes s shall perform p' ton the -found - tting a extendi thebypis star ng with he n rod i

_xten on mo direct' n. the .. ,

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R143 SEQUOYAH - UNIT 2 3/4 7-22 1

Amendment No. 2, 143 SEP 101*1 .

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r' PLANT SYSTEMS

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SURVEILLANCE REQUIREMENTS (Continued) *

g. -Functional Test Failure - Attached Cemponent Analysis For snubbers (s) found inoperable, an engineering evaluation shall be '

performed on the components which are restrained by the snubber (s).

The purpose of this engineering evaluation shall be to determine if ,

the components restrained by the snubber (s) were adversely affected by '

the inoperability of the snubbers (s), and in order to ensure that the.

restrained component remains capable of meeting the designed service. .

h. Functional Testing of Repaired and Spare Snubbers Snubbers which fail the visuai inspection or the functional test' acceptance criteria shall be repaired or replaced. Replacement snubbers and snubbers which have repairs which might affect the  :

functional test results shall be tested to meet the funtional test criteria before installation in the unit. These snubbers shall have met the acceptance criteria subsequent to their most recent service, and the functional test must have been performed within 12 months i before being installed in the unit.

i. Snubber Service Life Program

' The seal s vice l' 'e of hyd eulic sr abers si il be mon' ored to .

e ure et the >als do t fail 'etween s' . veillance nspections he m- imum e ected st vice li . for tho 'arious sr s, seal Ogurry e4No ma ials, nd appli ations chall be e- imated b<. d on engi ring-g g fg g,ra forma 'on, and ,e seale ohall be eplaced s hat the m .imum expe -ed servie_ lire d s not ey .re durin.

1. 1. 5*"# " 'k snes er is r uired be operE e. The period wi' i the-

• al replacer _nts shall e R104 /

mocumenter' and the ecumenta son shall .e retained a accordan 'wth

,f 6.10.2 M ianical anubber.d og force i reases gre'.er than~5 ercent of '

previou y measur 4 values s .il be evalu med as an 'adication "

impe ing failt of the s sober. Thec_ evsluatic.s and any-a ciated cc.rective ar on, shall > document , and the a ocumentak' n shall be retained ir accordanc with 6.10 '.n.

j. Exemption irom Visual Inspection or Functional Tests' ,

Permanent or other exemptions f orm the surveillance program for.

individual snubbers may be granted by the Commission if a justifiable-basis for exemption is presented and if applicable snubber life destructive testing was pe,'forned to qualify snubber operability for the applicable design conditions at either the completion of their '

fabrication or at a subsequent aate. -

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l SEQUOYAH - UNIT 2 3/4 7-l.5 Amendment No. 31. 104 May 5, 1989 i h

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Insert A The service life of hydraulle and mechanical snubbers shall be monitored to ensure that the service-life is not exceeded between' surveillance inspections. The maximum expected service'. life for various seals,.

springs, and-other critical parts shall be determined and~ established .

based on engineering information and shall be extended or shortened based _

on monitored. test results~and failure history. Critical parts shall be replaced so that'the maximum service life will not be exceeded-during a period when the snubber is. required to be OPERABLE. The-parts-~

replacements shall be documented and the documentation shall be retained in accordance with Specification 6.10.2.n. .

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ENCLOSURE 2 i

PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS.-50-327 AND 50-328 (TVA-SQN-TS-93-11)

DESCRIPTION AND JUSTIFICATION FOR REVISIONS TO TS 3/4.7.9 - SNUBBERS I

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Derrhtion_nLEhange TVA proposes to modify the Sequoyah Nuclear Plant (SQN) Units 1 and 2 -i technical specifications (TSs) to replace wording in Surveillance Requirement (SR) 4.7.9.1, " Snubber Service Life Program," with that from , _;

the Westinghouse Electric Corporation Standard TS, Revision ha. In addition,_the text contained in SR 4.7.9.c, " Snubber Visual Inspection Performance and Evaluation," which is inconsistent with Generic Letter (GL) 90-09, will be deleted.

Reason _ fat _Ebange Although NRC's approval of TS Change 91-06, " Snubber Visual Inspection Frequency," was obtained NRC subsequently noted that some of the wording  ;

was not consistent with GL 90-09. TVA was requested to consider NRC's .;

comments and include these changes during the next snubber TS change.

Based upon that request, TVA has proposed this revision to SR 4.7.9.c.

The change to SR 4.7.9.i is proposed because the present Snubber Service '

Life Program is overly prescriptive and is not consistent with the NRC-approved Westinghouse Standard TS, Revision Aa. As stated in NRC Inspection Report 327, 328/86-67, the majority of utilities in Region II i have eliminated requirements to perform engineering evaluations when drcg forces are determined to have increased 50 percent or greater over the.

previously measured value. Repiccement of the current-text with that provided in Westinghouse Standard TS, Revision 4a, allows SQN to be consistent with other utilities' Snubber Service Life Programs.

Jus 1111catinn_hr_ Change The proposed change to SR 4.7.9.c is consistent with the guidance in GL 90-09. Specifically, GL 90-09 does not allow the option of "if applicable" currently allowed by SR 4.7.9.c for performance of an "as-found" functional test. In addition, prescriptive test guidance does i not exist in GL 90-09 for hydraulic snubbers, which have uncovered fluid  !

ports. ,

TVA is proposing to replace the present TS wording in SR 4.7.9.i with that provided in the Westinghouse Standard TS, Revision 4a. This will eliminate the need to perform an engineering evaluation for drag-force increases of 50 percent or greater of the~previously measured value. l This 50 percent requirement to perfonn an engineering evaluation is ,

considered as an unnecessary expense where snubbers have a relatively ,

small drag force measured at the last test. During future testing, small increases in drag' forces could be measured but may be 50 percent greater i than the previous value. When-compared with the rated load of the snubber, it still may be well within the acceptable range.. The'new verbage requires that a trending program be provided to predict snubber-failure. SQN has defined " failure" as any measured drag force of 5  ;

percent or greater of rated load (with some exceptions for lower-rated i snubbers). When a drag force of 4 percent or greater is measured, an engineering evaluation is to be performed. This established program will j provide for predicting snubber f ailure.  ;

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Envirnamental I n. L Pact Evaluation The proposed change request does not involve an unreviewed environmental' question because operation of SQN Units 1 and 2 in accordance with this-change would not:

1. Result in.a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as .

modified by the staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or decisions of the Atomic Safety and-Licensing Board.

2. Result in a significant change in effluents.or power levels..

3. Result in matters not previously reviewed in the licensing basis.for

[ SQN that may have a significant environmental impact.

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J. Enclosure 3

' PROPOSED TECIINICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS l'AND 2 DOCKET NOS._50-327 AND 50-328 (TVA-SQN-TS-93-11)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION s

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'Significant Hazards Evaluation i

IVA has evaluated the proposed technical specification (TS) change and' I has determined that it does not represent a significant hazards ,

consideration based on criteria established in 10 CFR 50.92(c).

Operation of Sequoyah Nuclear Plant (SQN) in accordance with the proposed amendment will not:

1. Involve a significant increase in the probability or consequences.of ,

an accident previously evaluated. /l TVA proposes to delete the current TS requirement to perform an evaluation of snubber test data when there is a greater than  :

50 percent increase in drag force for mechanical snubbers. The 50 percent evaluation requirement is considered unnecessary where. .!

snubbers have small drag forces during their previous test.- During  ;

subsequent testing, small increases in drag forces (when compared-with the rated land of the snubber) may exceed 50 percent-of the . ,

previous test value. The relative change in drag force is small when compared with the overall rating of the snubber; however, under the I

current TS, an engineering evaluation for impending failure will still be required. Eliminating the current evaluation requirement from SQN's TSs will reduce the burden associated with performing '

unnecessary evaluations. The proposed change is consistent with the '

standard TS (Revision Aa), and a Snubber Service Life Prograo '

continues to exist at SQN. Therefore, there is no increase.in the probability or consequences of an accident previously evaluated.

In addition, the testing language associated with Visual Inspection Performance and Evaluation has been deleted to provide-consis'.ency ,

with Generic Letter 90-09. It should be noted that SQN tests its '

hydraulic snubbers in either direction as necessary. This is~more ,

conservative than the present TS requirement; therefore, this change '

does not involve a significant increase in the probability or-consequences of an accident previously evaluated.  ;

2. Create the possibility of a new or different kind of accident from i any previously analyzed.

1 The two proposed changes involve deleting a requirement to perform l unnecessary analyses and a potentially nonconservative testing 1) requirement. These changes do not alter _any plant. operation,  ;

maintenance requirements, or system design or function.- Therefore, a y new or different kind of accident is not created by:this-proposed. il change.

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

The proposed changes to the visual inspection and the service life section will-not modify the plant or revise'its mode of operation or the present safety analysis. The trending criteria to be utilized r provide adequate assurance that. snubber impending failure will be predicted in a timely manner. The deleted sections will not change the requirement to test and trend test data for snubbers to predict failure; therefore, there is not a reduction in any margin of safety.

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