ML20077M358

Proposed Tech Specs Deleting Tables 3.7-4a & B Re Safety Related Hydraulic Snubbers & Adding Table 4.7-2 Re Snubber Visual Insp Interval

ML20077M358
Person / Time
Site:	Mcguire, McGuire
Issue date:	08/08/1991
From:	DUKE POWER CO.
To:
Shared Package
ML20077M354	List: ML20077M350 ML20077M358
References
NUDOCS 9108130309
Download: ML20077M358 (14)

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Attachment I Proposed Technical Specification Changes 9108130309 910808 (ADOC.K 0500036y-ptn<

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LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQU SECTION  :

3/4.7.5 _PAGE STANDBY NUCLEAR SERVICE WATER P0ND....................... 3/4 7-12 3/4.7.0 CONTROL AREA VENTILATION SYSTEM.......................... 3/4 7-13 3/4.7.7 t AUXILIARY BUILDING FILTERED VENTILATION EXHAUST 3/4 7-16 SYSTE 3/4.7.8 SNUBBERS.............

................................... 3/4 7-18

-TABW 2. 7-42 SAFETY-RELATED1YDRAtttIC SNUB 8ERS-(tfNITS+AN04h. 3/4-7 ..

.) -TABbE4 TA ttc sl. th4b--S 7-2 SWu AFETY- R ELAT EO-ME C HAN I C A LM,.MUBB E RS -( UN I T5+AN 6 6EK vis a u w.srec riost w is ec.vM. . . . . -. 1/4 + 26 ~

FIGURE 4.7-1 . 4a SAMPLING PLAN FOR SNUBBER FUNCTIONAL TEST 3/4 7-29...........

3/4.7.9 SEALED SOURCE CONTAMINATION..... ...

.. .... ............ 3/4 7-30 3/4.7.10 Deleted 3/4.7.11 Deleted 3/4/7.12 AREA TEMPERATURE MONITORING....... ...........

... .. .. 3/4 7-42 TABLE 3.7-6 AREA TEMPERATURE MONITORIG. . . ......... ...... .... 3/4 7-43 3/4.7.13 GROUNDWATER LEVEL................... ........ ...... . . 3/4 7-44 TABLE 3.7-7 AUXILIARY BUILDING GROUNDWATER LEVEL. MONITORS... ... 3/4 7-45 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES 0perating............................... . ......... .... 3/4 8-1 TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE.............. ....... 3/4 8-8

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.___McGuire - Units 1 and 2

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e PLANT SYSTEMS 3/4.7.8 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.8 All snubbers shall be OPERABLE. The only snabbers excluded from the requirements are those installed on non-safety-related systems and then only if the failure or the failure of the system on which they are installed would not have an adverse effect on any safety-related system.

APPLICABILITY: MODES 1, 2, 3, and 4. MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.

ACTION:

1 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 j inoperable snubber (s) to OPERABLE status and perform an engineering evaluation '

per Specification 4.7.8g. on the attached component or declare the attached l

system inoperable and follow the appropriate ACTION statement for that system.  !

SURVEILLANCE REQUIREMENTS 4.7.8 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.

a. Inspection Types As used in this specification, type of snubber shall mean snubbers of the same design and manuf acturer, irrespective of capacity,

b. Visual Inspections Snubbers are categorized as inaccessible or accessible during reactor operation and may be treated independently, l':  ;'_

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first inservice visual inspection of each type of snubber s be p ed after 4 months but within 10 months of co .. 0WER OPERATION a 11 include all snubbers. If 1 an two snubbers l of each type are noperable dur 1rst inservice visual inspection, the second in ual inspection shall be performed 12 months 25% from h eo 'rst inspection. Othe mise, subsequent v' . spections shall be p d in accordance with i g schedule:

the f McGUIRE - UNITS 1 and 2 3/4 7-18 Amendment No. (Unit 1)

( AmendmentNo.$}(Unit 2)

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) noperable Snubbers of Each Time Until Subse- .

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4 Typ e nd During Inspection Visual 1s, e ton *#

nths 2 25%

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12 months 1 25%

6 months 1 25%

$ /e 3,4 124 days 1 25%

" 5,6,7 62 days 1 25%

more t 25%

c. Refueling Outage Inspections At each refueling, the systems which have the potential for a severe dynamic event, specifically, the main steam system (upstream of the main steam isolation valves) the main steam safety and power operated relief valves and piping, auxiliary feedwater system, main steam supply to the auxiliary feedwater pump turbine, and the letdown and

- charging portion of the CVCS system shall be inspected to determine if there has been a severe dynamic event. In case of a severe dynamic event, mechanical snubbers in that system which experienced the event shall be inspected during the refueling outage to assure that tha mechanical snubbers have freedom of movement and are not frozen p up. The inspection shall consist of verifying freedom of motion (j using one of the following: (1) manually induced snubber movement; (2) evaluation of in place snubber piston setting; (3) stroking the mechanical snubber through its full range of travel. If one or more mechanical snubbers are found to be frozen up during this inspection, those snubbers shall bt replaced or repaired before returning to power. The requirements of Specification 4.7.8b. are independendent of the requirements of this specification.

d. Visual Inspection Acccatance Criteria Visual inspections shall verify: (1) that there are no visible indications of damage or impaired OPERABILITY, and (2) attachments to the foundation or supporting structure are secure. Snubbers Ld which appear jnontrgble as a result of visual inspections (meyMre -

,#. de+emmed;4Pemetf]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; he inspectio e each type of snubb et aned more than one step at a time u roblem has been identified and corrected- e inspection m be length,ened one ste time and two steps thereafter if no inopera 5 of type are found.

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McGUIRE - UNITS 1 and 2 3/4 7-19

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l PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

d. Visual Insoection Acceptance Criteria (Continued) and (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specification 4.7.8f. W t_

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e. Functional Tests During the first refueling shutdown and at least once per refueling thereafter, a representative sample of snubbers shall be tested using one of the following sample plans. The large bore steam generator hydraulic snubbers shall be treated as a separate population for func-tional test purposes. A 10% random sample from previously untested snubbers shall be tested at least once per refueling outage until the entire population has been tested. This testing cycle shall then begin anew. For each large bore steam generator hydraulic snubber that does not meet the functional test acceptance criteria, at least 10% of the remaining population of untested snubbers for that testing cycle shall be tested. The sample plan shall be sel_ected prior to the test period and cannot be changed during the test period. The NRC shall be notified of the sample plan selected prior to the test period.

1) At least 10% of the snubbers required by Specification 3.7.8 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 4.7.8f. , an additional 10% of the snubbers shall be functionally tested until no more failures are found or until all snubbers have been functionally tested; or

2) A representative sample of the snubbers required by Specifica-tion 3.7.8 shall be functionally tested in accordance with Figure 4.7-1. "C" is the total number of snubbers found not meeting the acceptance requirements of Specification 4.7.8f (failures). The cumulative number of snuobers tested is denoted by "N." Test results shall be plotted sequentially in the order of sample assignment (i.e., eacn snubber shall be plotted by its order in the random sample assignments, not by the order of testing). If at any time the point plotted f alls in the " Accept" region, testing of snubbers may be terminated. When tne point plotted lies in the " Continue Testing" region, additional snubbers sha!1 be tested until the point f alls in the " Accept" region, or all the snubbers required by Specification 3.7.8 have been tested.

Testing equipment failure during functional testing may invalidate that day's testing and allow that day's testing to resume anew at a later time, providing all snubbers tested with the failed equipmer during the day of equipment failure are retested; or

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McGUIRE - UNITS 1 and 2 3/4 7-20 Amendaient No. (Unit 1)

An,endment No., (Unit 2)

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g, cWy hN PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

e. Functional Tests (Continued)

3) An initial representative sample of fif ty five (55) snubbers small be functionally tested. For each snubber which does not meet the functional test acceptance criteria, another sample of at least one-nalf the size of the initial sample shall be tested until the total numbe'r tested is equal to the initial sample size multiplied by the f actor,1 + C/2, where "C" is the numeer of snubbers found which do not meet the functional test acceptance criteria. This can be plotted using an " Accept" line which follows i the equation N = 55(1 + C/2). Each snubber snould be plotted as soon as it is tested. If the point plotted falls on or below the " Accept" line, testing may be discontinued. If the coint plotted falls above the " Accept" line, testing must continue unless all snubbers have been tested.

The representative samples for the functional test sample plans shall be randomly selected from the snubbers required by Specifi-cation 3.7.8 and reviewed before beginning the testing. The review shall ensure as far as practical that they are representative of the various configurations, operating environments, range of sizes, and capacities. Snubbers placed in the same locations as snubbers which failed the previous functional test shall be ratested at the tise of p the next functional test but shall not be included in the saccle plan. If during the functional testing, additional sampling is d 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.

f. Functional Test Acceptance Criteria The snubber functional test shall verify that:

1) Activation (restraining action) is achieved within the specified range in both tension and compression, except that inertia dependent, acceleration limiting mechanical snubbers may be tested to verify only that activation takes place in both directions of travel;

2) Snubber bleed, or release rate where required, is present in both tension and compression, within the specified range;

3) Where required, the force required to initiate or saintain motion of the snubber is within the specified range in both direction of travel; and

4) For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement.

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.

McGUIRE - UNITS 1 and 2 3/4 7-21 Amendment No. 99 (Unit 1)

Amendment No. 31 (Unit 2)

f hQ OOf7 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

g. Functional fest Failure Analysis An engineering evaluation ' '11 be made of eacn failure to meet t~e functional test acceo w ce t iteria to determine the cause of the failure. The results of this evaluation shall be used, if applicable, in selecting snubbers to be tested in an effort to determine the OPERABILITY of other snubbers irresoective of tjpe which may be subject to the same failure mode.

For the snubbers found inocerable, 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 designea service.

If any snubber selected for functional testing 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 evaluated in a manner to ensure their OPERABILITY. This testing requirement shall be independent of the reovirements stated in Specification 4.7.Se.

for snubbers not meeting the functional test acceptance criteria.

h. Functional Testing of Reoaired and Reolaced Snubbers Snubbers which fail the visual inspection or the functional test acceptance criteria shall be repaired or replaced. Reolacement snubbers and snubbers which have repairs which might affect the functional test result shall be tested to meet the functional test criteria before installation in the unit. Mechanical snubbers snall have met the acceptance criteria subsequent to their most recent service, and freedom-of-motion test must have been performed within 12 months before being installed in the unit.

i. Snubber Seal Replacement Program The seal service life of hydraulic snubbers shall be monitored to ensure that the service life is not exceeded between surveillance inspections. Tha expected service life for the various seals, seal terials, and applications shall be determined and established

t. d on engineering information and the seals shall be replaced so that the expected service life will not be exceeded during a period when the snubber is required to be OPERABLE. The seal replacements shall be documented and th? LMcumentation shall be retained in accordance with Specification 6.10.2.

McGUIRE - UNITS 1 and 2 3/4 7-22 Amendment No. 86(Unit 1) 9 Amendment No. 67(Unit 2) k

o INSERT A Each of these categories (inaccessible and accessible) may be inspected independently according to the schedule detemined by Table 4.7-2. The visual inspection interval for each category of snubber shall be detemined based upon the criteria provided in Table 4.7-2 and tne first inspection interval detemined using this criteria shall be based upon the previous inspection interval as established by the requirements in effect before amendment (*).

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T A lt M*1 SNUB 8ER VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTA81.E $ NUB 8ERS Population Column A column a Column C or Category Extend Interval Repeat Interval Reduce Interval (Notes 1 and 2) (Notes 3 and 6) (Notes 4 and 6) (Notes 5 and 6) 1 0 0 1 M 0 0 2 100 0 1 4 150 0 3 8 200 2 5 13 300 5 12 25 400 8 18 36 500 12 24 48 750 20 40 78 1000 or greater 29 56 109 7

Note 1: The next visual inspection interval for a snubber population or cate-I gory size shall be determined based upon the previous inspection

! interval and the number of unacceptable snubbers found during that interval. Snubbers may be categorized, based upon their accessibilt:y during power operation, as accessible or inaccessible. These categor-1es may be examined separately or jointly. However, the licensee must make and document that decision before any inspection and snall l

use that decision as the basis upon which to detensine the next inspection interval for that category.

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-Note 2: Interpolation between population or category s.'zes and the number of unacceptable snubbers is permissible. Use next lower integer for the value of the limit for Columns A. B. or C if that integer includes d fractional value of unacceptable snubbers as determined by inter-polation.

Note 3: If the number of unacceptable snubbers is equa to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.

1 Note 4: If the number of unacceptable snubbers is equal to or less than the number in Column B but greater that the number in Column A, the next inspection interval shall be the same as the previous interval.

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quu66EfL VISUAL INSE'TN ifd TEAVAL Note 5: If the numeer of unacceptable soubbers is equal to or greater than the number in Column C, the next inspection interval shall be tw-thirds of the previous interval. However, if the number of unacceptable snubbers is less than the nwnber in Column C but greater than the number in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable snubbers found during the previous interval and the number in Column B to the difference in the numbers in Coluans B and C.

Note 6: The provisions of Specification 4.0.2 are applicable for all inspec-tion intervals up to and including 48 months.

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INSERT C 1 Classified SS Jnacceptable and may be reclassified 1

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INSERT D A hydraulic-snubber found with the fluid port uncovered and all hydraulic snubbers found connected to an inoperable common reservoir.1 shall be classified as-unacceptable and may be reclass:fied acceptable by functionally testing each snubber with the piston in the as-found setting, extending the piston rod in the tension direction.

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I ATTACHh1ENT 2 Duke Power Company hicGuire Nuclear Station, Units 1 and 2 Justification for Proposed Changes and Evaluation of No Significant Hazards Consideration JUSTIFICATION FOR PROPOSED CHANGE The proposed amendment in this submittal includes changes to Section 4.7.8 of the hicGuire Nuclear Station Technical Specincations, Snubbers, based on guidance

- provided by Generic Letter 90-09 dated December 11, 1990. Attachment I provides L

proposel revisions to hicGuire Technical Specifications 4.7.8 b and 4.7.8 d. The proposed revisions would replace the current snubber visual inspection schedule with a new snubber visual inspection schedule, Table 4.7-2 of Attachment 1.

The current schedule for visual inspections is based on the number of inoperable snubbers found during the previous visual inspection, irrespective of the size of the snubber population. Since hicGuire Nuclear Station has a large snubber population, this visual inspection schedule has proven to be excessively restrictive. Complying with the visual examination schedule has resulted in the spending of a significant amount of resources and subjecting plant personnel to unnecessary radiological exposure. This new schedule would maintain the same confidence level that the snubbers will operate

< within the specified acceptance levels and generally will allow visual inspections and corrective actions to be performed during plant outages.

l This amendment, ifimplemented, would reduce future occupational radiation exposure and would be highly cost effective. Such action is consistent with the Commission's policy statement on Technical Specification improvements.

t Upon approval of this amendment request, the current snubber visual inspection

! schedules will be recalculated by taking the number of inoperable snubbers found in the previous visual inspection and applying the criteria in Table 4.7-2. The start date for this newly calculated surveillance interval will remain the date of the last visual inspection.

With the addition of new Table 4.7-2, an administrative change to the TS Index is requested. Also, the current TS Index shows 2 Tables (3.7-4a & 3.7-4b) that were deleted in a previous TS atnendment. These Tables should be deleted from the Index.

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NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION This proposed amendment would incorporate the guidance contained in the NRC's Generic Letter 90-09, dated December 11, 1990. The Generic Letter provided guidance for replacing the current snubber visual inspection schedule with an alternate snubber visual inspection schedule which maintains the same confidence level.

This proposed amendment has been developed based on the Generic Letter guidance.

10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or l (2) Create the possibility of a new "fferent kind of accident l from any accident previously euuated; or 1

(3) Involve a significant reduction in a margin of safety.

The proposed amendment does not involve an increase in the probability or

consequences of any previously evaluated accident. This amendment provides an alternate schedule for the visual inspection of snubbers which maintrins the same confidence level in the snubbers ability to operate within a specified acceptance level.

The accident analyses are therefore unaffected by this proposal.

The proposed amendment does not create the possibility of a new or different kind of L accident from any accident previously evaluated since the snubbers ability to operate within a specified acceptance level has not been changed.

The proposed amendment does not involve a significant reduction in a margin of safety.

This amendment provides an alternate schedule for the visual inspection of snubbers which maintains the same confidence level in the snubbers ability to operate within a specified acceptance level. The margin of safety is therefore unaffected by this proposal.

For the above reasons, Duke Power concludes that this proposed amendment does not involve any Significant Hazards Consideration.

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' The proposed TS change has been reviewed against the criteria of 10 CFR 51.22(c)(9) for environmental considerations. The proposed change does not involve any significant hazards consideration, nor increase the types or amounts of effluents that may be released offsite, nor increase the individual or cumulative occupational radiation exposure. Based on this, the proposed Technical Specification change meets the criteria given in 10 CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.