ML20090H270

Proposed Tech Specs Re Tables 3/4.7.9 on Snubbers,Deletion of Tables 4.7.9a,4.7.9b & 4.7.9c from Limiting Condition for Operation 3.7.9,ref to Tables & Deletion of Ref to SI-162

ML20090H270
Person / Time
Site:	Sequoyah
Issue date:	10/24/1983
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20090H239	List: ML20090H233 ML20090H270
References
NUDOCS 8310280040
Download: ML20090H270 (13)

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r ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 TVA-SQN-TS-49 i

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

g. Functional Test Failure - Attached Component 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 visual 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 before being installed in the unit.

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" Snubber Service Life Proaram The seal service life of hydraulic snubbers shall be monitored to ensure that the seals do not fail between surveillance inspections.

The maximum expected service life for the'various seals, seal -

materials, and applications shall"be~ estimated based on engineering information, and the seals shall be replaced so that the maximum expected service. life does not expire during a period when the snubber is required to be operabvle. The seal replacements shall be documented and the documentation shall be retained in accordance wth 6.10.2.n. ,5 Mechanical snubber drag force increases greater than 50 percent of previously measured values shall be evaluated as an indication of ^

impending failure of the snubber. These evaluations and any associated corrective action, shall be documented, and the i-l documentation shall be retained in accordance with 6.10.2.n.

j. Exemotion From Visual Insoection or Functional Tests Permanent or other exemptions form 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.

SEQUOYAH - UNIT 1 3/4 7-25

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SEQUOYAH - UNIT 1 3/4 7-26

. .- . .N PLANT SYSTEMS '

BASES

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SNUBBERS-(Continued) -

that may be generically susceptible and operability verified by inservice func-tional testing, if applicable, that snubber may be exempted from being counted as inoperable. Generically susceptible snubbers are those which are of a specific make or model and have the same design features directly related to rejection of the snubber, or are similarly located or exposed to the same environmental conditions such as temperature, radiation, and vibration.

Inspection groups may be established based on design features and installed

. conditions which may be expected to be generic. Each of these inspection

-groups are inspected and tested separately unless an engineering analysis

-indicates the inspection group is improperly constituted. All suspect snub-bers are subject to inspection and testing regardless of inspection groupings.

To further increase the assurance of snubber reliability, functional tests shall be performed during each refueling outage. These tests will include stroking of the snubbers to verify proper movement, activation, and bleed or release. The performance of hydraulic snubbers generally depends on a clean, deaerated fluid contained within variable pressure chambers, flowing at closely t

controlled rates. Since these characteristics are subject to change with expo-sure to the reactor environment, time, and other factors, their performance within -the specified range should be verified. Mechanical snubbers which depend upon overcoming the inertia of a mass and the braking action of a capstan spring contained within the snubber for limiting the acceleration of the attached compo-nent. (within the load rating of the snubber) are not subject to changes in per-

, formance in the same manher as hydraulic snubbers. 'Pending the development of information regarding the change during the servite of the snubber of the acceleration / resistance relationship and the optimum method for detecting this -

change, these mechanical snubbers may be tested to verify that when subjected to a large change in velocity ths resistance to movement increases greatly.

The performance change information is to be developed in order to establish g test methods to be used during and after the first refueling outage.

Ten percent of the total population of approximately 700 snubbers is an -

adequate sample for functional tests. The initial sample is to be proportioned ,

among the groups in order to obtain a representative sample. Observed failures of more than two snubbers in the initial lot will require an engineering analysis and testing of additional snubbers selected from snubbers likely to have the same defect. A thorough inspection of the snubber threaded attach-L ments to the pipe or components and the anchorage will be made in conjunction L

with all required functional tests.

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, SEQUOYAH - UNIT 1- B 3/4 7-6

PLANT SYSTEMS - ..

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1 3/4.7.9 SNUBBERS (cont'd) l i

A list of individual snubbers with detailed-information of snubber location and size shall be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Plant Operations Review Committee.

The determination shall be based upon the existing radiation levels and the expected time to perform a -

visual inspection in each snubber location as well as otner factors associated with accessibility during plant operations (e.g., temperature, atmosphere, location etc.), and the reccmmendations of Regulatory Guide 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

3/4.7.10 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak testing, plutonium.

including alpha emitters, based on 10 CFR 70.39(c) limits for This limitation will ensure that leakage from byproduct, source, and special nuclear material sources will not exceed allowable intake values.

Sealed sources are classified into three groups according to their use, with ~

! surveillance requirements commensurate with the probability of damage to a source in that group. Those sources which are frequently handled are required .

to be tested more often than those which are not. Sealed sources which are l continuously enclosed within a shielded mechanism (i.e., sealed sources within radiation monitoring or boron measuring devices) are considered to be stored 4 and need not be tested unless they are removed from the shielded mecnanism.

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SEQUOYAH UNIT 1 B 3/4 7-6a t

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ADMINISTRATIVE CONTROLS 6.10.2 The following records shall be retained for the duration of the Unit

.0perating License:

a. Records and drawing changes reflecting unit design modifications made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories. -

c. Records of radiation exposure for all individuals entering radiation control areas.

d. Records of gaseous and liquid radioactive material released to the environs.

e. Records of transient or operational cycles for those unit components identified in Table 5.7-1.

f. Records of reactor tests and experiments.

g. Records of training and qualification for current members of the unit staff.

h. Records of in-service inspections performed pursuant to these Technical Specifications, i.

Records of Quality Assurance activities required by the Operational Quality Assurance Manual,

j. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

, k. Records of meetings of the PORC, RARC, and the NSRB. -

1. Records of analyses required by the radiological environmental monitoring program.

m. Records of secondary water sampling and water quality. '

n. Records of the service life monitoring of all safety related hydraulic and mechanical snubbers, required by T/S 3.7.9, including the

, maintenance performed to renew the service life.

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Records for Environmental Qualification which are covered under the t

provisions of Paragraph 2.c.(12)(6) of License No. DPR-77.

! 6.11 RADIATION PROTECTION PROGRAM '

Procedures for personnel radiation protection shall be prepared consistent ,

with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

I-SEQUOYAH - UNIT 1 6-23 E

PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All safety related snubbers shall be OPERABLE.

I APPLICABILITY: MODES 1, 2, 3 and 4.

(MODES 5 and 6 for snubbers located on systems or partial systems required OPERABLE in those MODES.)

ACTION:

With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the -

inoperable snubber (s) to OPERABLE status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE R'EQUIREMENTS

4. 7.'9 Each safety related snubber shall be dem

. performance of the following augmented inserviconstrated OPERABLE e inspection byand the program requirements of Specification 4.0.5. i.

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a. Inspection Groups The snubbers may be categorized into two major groups based on whether operation.

the snubbers are accessible or inaccessible during reactor These major groups may be further subdivided into subgroups based on design, environment, or other features which may be expected to affect the OPERABILITY of the snubbers within the subgroup.

Each subgroup or group may be inspected independently in accordance with 4.7.9.b through 4.7.9.h. ,

b. Visual Inspection Schedule The first inservice visual inspection of snubbers shall be performed after 4 months but within 10 months of commencing POWER OPERATION and shall include all snubbers on safety related systems. If less than two (2) snubbers are found inoperable during the first inservice SEQUOYAH - UNIT 2 3/4 7-21

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) >

g. Functional Test Failu're - Attached Component 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 visual 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 before being installed in the unit.

i. ' Snubber Service Life Program The seal service life of hydraulic snubbers shall be monitored to ensure that the seals do not fail between surveillance inspections.

The maximum expected service life for the'various seals, seal materials, and applicn ions shall be' estimated based on engineering information, and tbc seals shall be replaced so that the maximum -

expected service. life does not expire during a period when the snubber is required to be operabvle. The seal replacements shall be documented and the documentation shall be retained in accordance wth 6.10.2.n.

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Mechanical snubber drag force increases greater than 50 percent of previously measured values shall be evaluated as an indication of '

impending failure of the snubber. These evaluations and any associated corrective action, shall be documented, and the documentation shall be retained in accordance with 6.10.2.n.

j. Exemption From Visual Inspection or Functional Tests ~

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Permanent or other exemptions form 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 snebber operability for the applicable design conditions at either the completion of their fabrication or at a subsequent date.

SEQUOYAH - UNIT 2 3/4 7-25 i

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. .- . . '- PLANT SYSTEMS BASES 3/4.7.9 SNUBBERS (cont'd)

A list of individual snubbers with detailed ~information of snubber location and size shall be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Plant Operations Review Committee. The determination shall be i

based upon.the existing radiation levels and the expected time to perform a visual inspection in each snubber location as well as other factors associated with accessibility during plant operations (e.g., temparature, atmosphere, location etc.), and the recommendations of Regulatory Guide 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in j accordance with Section 50.59 of 10 CFR Part 50. j 3/4.7.10 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak testing, including alpha emitters, based on 10 CFR 70.39(c) limits for plutonium.

This limitation will ensure that leakage from byproduct, source, and special nuclear material sources will not exceed allowable intake values.

Sealed sources are classified into three groups according to their use, with surveillance requirements commensurate with the probability of damage to a source in that group. Those sources which are frequently handled are required to be tested more often than those which are not. Sealed sources which are continuously enclosed within a shielded mechanism (i.e., sealed tources within i

radiation monitoring or baron measuring devices) are considered to be stored  :

l and need not be tested unless they are removed from the shielded mechanism.

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! SEQUOYAH UNIT 2 B 3/4 7-6a u

ADMINISTRATIVE CONTROLS 6.10.2 (Continued)

m. Records of secondary water sampling and water quality.

n. Records of the service life monitoring of all safety related hydraulic and mechanical snubbers, required by T/S 3.7.9, including the maintenance performed to renew the service life.

6.11 RADIATION PROTECTION PROGRAM

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Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal' required by paragraph 20.203(c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Special (Radiation)

Work Permit *. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or mare of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device -

may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

! c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate moaitoring device. This individual

! shall be responsible for providing positive control over the activities L within the area and shall perform control over the activities within the area and shall perform periodic radiation surveillance.at the

l. frequency specified by the facility Health Physicist in the Special l (Radiation) Work Permit.

6.12.2 The requirements of 6.12.1, above, shall also apply to each high ~

radiation area in which the intensity of radiation is greater than 1000 mrem /hr.

In addition, locked doors shall be provided to prevent unauthorized entry into '

such areas and the keys shall be maintained under the administrative control of the Shift Engineer on duty and/or the Her.lth Physicist.

• Health Pnysics personnel or personnel escorted by Health Physics personnel in accordance with approved emergency procedures, shall be exempt from the SWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

SEQUOYAH - UNIT 2 6-29

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. ENCLOSURE 2 JUSTIFICATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGE TVA-SQN-TS-49 SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 The proposed technical specifications delete Tables 4.7.9a, 4.7.9b, and 4.7.9c from the limiting condition for operation (LCO) 3.7.9, as well as the references made to those tables, and delete the reference to SI-162.

The proposed changes will still provide the required level of snubber protection and surveillance.

As stated in the BASES, page BV3/4 7-6a, a list of individual snubbers with detailed information of snubber location and size will be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The ac?essibility of each snubber will be determined and approved by the Plant Op(rations Review Committee. The determination will be based upon the existing radiation levels and the expected time to perform a visual inspection in each snubber location as well as other factors associated

- with accessibility during plant operations (e.g. , temperature, atmosphere, location, etc.), and the recommendations of Regulatory Guide 8.8 and 8.10.

The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

The proposed change was evaluated pursuant to 10 CFR Part 50.92 and no significant hazards considerations (SHC) are involved. The SHC determination is attached.

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ATTACHMENT SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The proposed technical specification requires the safety-r' elated snubbers to be surveillance plant OPERABLE, instruction.

but the list of snubbers will now reside in the appropriate Safety-related snubbers will then be handled in the same manner as other safety-related equipment required by technical specifications. Surveillance requirements will be met using the appropriate plant surveillance instruction, and compliance with the requirements will be documented in accordance with 10 CFR part 50 section 50.71(c). Changes to the snubbers will be handled pursuant to 10 CFR part 50 section 50.59.

. The proposed technical specification change does not reduce the number of snubbers required to be OPERABLE nor does it reduce the surveillance requirements on those snubbers. The physical plant and equipment will not be impacted by the proposed change. We have, therefore, determined that no accident probability is increased for either new or previously analyzed accidents or malfunctions. No snubber requirements are changed so the margin of safety is not reduced.

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