BVY 13-078, Submittal of Snubber Program for the Fifth Ten-Year Inservice Inspection Interval

Submittal of Snubber Program for the Fifth Ten-Year Inservice Inspection Interval

ML13267A033
Person / Time
Site:	Vermont Yankee
Issue date:	08/28/2013
From:	Chappell C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 13-078
Download: ML13267A033 (22)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd.

Entergy Vernon, VT 05354 802-257-7711 Coley C. Chappell Licensing Manager BVY 13-078 August 28, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Submittal of Snubber Program for the Fifth Ten-Year Inservice Inspection Interval Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

Dear Sir or Madam:

In accordance with American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), Subparagraph ISTA-3200(a),

attached for your information is a copy of the Snubber Program for Vermont Yankee Nuclear Power Station (VYNPS) Fifth Ten-Year Inservice Inspection (ISI) Inteval. The VYNPS Fifth Ten-Year ISI Interval begins on September 1, 2013 and concludes on August 31, 2023.

This letter contains no new regulatory commitments.

Should you have any questions concerning this letter or require additional information, please contact me at 802-451-3374.

Sincerely, CCC/plc

Enclosures:

1. Snubber Program for the Fifth Ten-Year Interval cc list: next page

BVY 13-078 / Page 2 of 2 cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Richard V. Guzman, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 13-078 Docket 50-271 Enclosure 1 Vermont Yankee Nuclear Power Station Snubber Program for the Fifth Ten-Year Interval

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 1 of 19 VERMONT YANKEE 5 T INTERVAL SHOCK SUPPRESORS (SNUBBERS)

PROGRAM SECTION SEP-SNB-VTY-001 ENTERGY NUCLEAR ENGINEERING PROGRAMS APPLICABLE SITES ANO: IPEC: El GGNS: JAF: El 13 []

RBS: PNPS: El W3: VY:

Quality Related: YES 99 NO [

Continuous Use 0 Reference Use 13 Informational Use []

VY Program Section No. SEP-SNB-VTY-00I Revision No. 0 Page 2 of 19 REVIEW AND CONCURRENCE SHEET Program Section Vermont Yankee Shock Suppressors (Snubbers) Program Section Prepared by: Mike Griffin /Date:

Responsible lngineer/Signature Checked by: William C Pelzer / Date:

Name/Signature Concurred by: Mark LeFrancois/ / ,,.2*CC.. Date: F_,/.0 Responsible Supervisor/Signature

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 3 of 19 REVISION STATUS SHEET PROGRAM SECTION REVISION

SUMMARY

RevisionI Description 0 Revision 0 is prepared to implement the Vermont Yankee 5th Interval Shock Suppressors (Snubbers) Program Section in compliance with the requirements of 10CFR50.55a(b)(3)(v)(B), ASME OM 2004 Edition through OMb 2006 Addenda, Subsection ISTD. The Program was also renumbered from SEP-SNB-007 to SEP-SNB-VTY-001 to align with fleet numbering.

LIST OF EFFECTIVE PAGES All pages are revision 0

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 4 of 19 INSERVICE TESTING SHOCK SUPPRESSOR (SNUBBER)

PROGRAM PLAN For The 5 th Ten-Year Interval Effective September 1, 2013 Vermont Yankee Nuclear Power Station Commercial Service Date: November 29, 1972 Facility Name:

Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354-9766 Owner:

Entergy Nuclear Operations, Inc.

185 Old Ferry Road; PO Box 7002 Brattleboro, VT 05302-7002

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 5 of 19 TABLE OF CONTENTS 1.0 INTRO DUCTIO N ..................................................................................................... 6 1.1 General ................................................................................................................. 6 1.2 Com m ercial O peration Date and IST Intervals ............................................. 6 1.3 Applicable Codes ............................................................................................ 6 1.4 Purpose ................................................................................................................ 7 1.4 Scope ................................................................................................................... 7 2.0 DEFINITIO NS .................................................................................................................. 7 3.0 PRIMARY RESPO NSIBILITIES ................................................................................ 9 4.0 DETAILS ....................................................................................................................... 10

5.0 REFERENCES

AND COM M ITM ENTS ...................................................................... 14 6.0 FINAL CONDITIO NS ................................................................................................ 16 7.0 ATTACHM ENTS ............................................................................................................ 16 8.0 QA REQUIREMENTS CROSS REFERENCE ........................................................... 16

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 6 of 19

1.0 INTRODUCTION

1.1. General 1.1.1. This document is the Fifth Ten-Year Interval Program Plan (ISTA-1 310 /

ISTA-31 10) for In-service Testing (IST) of Snubbers at the Vermont Yankee Nuclear Power Station (VY). This Program Plan was prepared in accordance with the rules of 10CFR50.55a(b)(3)(v)(B), the ASME Code for Operation and Maintenance of Nuclear Power Plants, ASME OM Code 2004, through the ASME OMb Code 2006 Addenda (OM 2004 through OMb 2006 - "The Code"), Subsection ISTD.

1.1.2. To ensure system structural integrity and operability of snubbers at VY, plant Technical Specifications 3.6.E /4.6.E and TRM 4.6 require in-service inspection and testing of safety related components in accordance with 10CFR50.55a (f) and (g). These documents in turn reference the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) as the document governing in-service examinations and pre-service examinations for snubbers. To meet these requirements a program of inspection, testing and scheduled maintenance has been established.

1.2. Commercial Operation Date and IST Intervals Vermont Yankee began commercial operation on November 29, 1972, and the First Ten-Year ISI/IST Interval began on that date. The Third Interval start date was extended from November 30, 1992 to August 31, 1993 (BVY 92-133). This extension used 9 of the allowable 12 months total extension of intervals permitted by the Code.

The Third-Interval ISI/IST Program was applicable for the interval from September 1, 1993 through August 31, 2003. The 4th 10-Year ISI/IST Interval was applicable from September 1, 2003 through August 31, 2013. Therefore, the 5th 10-Year ISI/IST Interval is applicable from September 1, 2013 through August 31, 2023.

1.3. Applicable IST Codes The Fifth 10-Year Interval Snubber Program Plan complies with the OM-2004 Edition through the OMb-2006 Addenda. The Fourth 10-Year Snubber Interval Program Plan complied with ASME OM-1 998 Edition through the OMb-2000 Addenda. The Third 10-Year Interval Snubber Program Plan complied with ASME Section Xl, 1989 Edition.

The Second and First 10-Year Interval Snubber Program Plans were governed by VY T.S.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 7 of 19 1.4. Purpose 1.4.1. This document provides the VY site specific snubber details to implement the VY Technical Specification (T.S.) / Technical Requirement Manual (TRM) requirements for determining the operability of safety related, hydraulic shock suppressors (snubbers).

1.4.2. TS 3.0.8 specifically address the inoperability requirements of safety related snubbers.

1.4.3. EN-DC-333 Snubber Inspection Program provides Entergy Fleet Code general requirements including definitions, responsibilities, and general examination and test requirements.

1.5. Scope 1.5.1. Those snubbers installed to provide structural integrity for maintaining operability of safety related systems and components (ISTA-1 100) are delineated in Table 2 of this Program.

2.0 DEFINITIONS 2.1. Activation - The parameter that verifies restraining action.

2.2. Application Induced Failure - Failures resulting from environmental conditions or application of the snubber for which it is not been designed or qualified.

2.3. Bleed Rate - The rate of axial snubber movement under a specified load after activation of the snubber occurs.

2.4. Defined Test Plan Group (DTPG) - a population of snubbers selected for testing in accordance with the 10% testing sample plan.

2.5. Design or Manufacturing Failure - Failures resulting from a potential defect in manufacturing or design that gives cause to suspect other similar snubbers. This includes failures of any snubber not to withstand the environment or application for which it was designed.

2.6. Draq Force - The force required to maintain the snubber movement at a constant velocity prior to activation.

2.7. Examination - The performance of visual observation for impaired functional ability caused by physical damage, leakage, corrosion, or degradation from environmental or operating conditions.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 8 of 19 2.8. Examination Group - A composition of snubbers which have been selected to be examined.

2.9. Failure Mode Group (FMG) - A group of snubbers whose failure, or those with potential for the same failure, are similar.

2.10. Functional Test - Measurement of parameters to verify snubber performance and operational readiness.

2.11. Hydraulic Shock Suppressor (snubber) - Devices which transmit applied loads through hydraulic fluid.

2.12. Inaccessible Snubber - a snubber located in a high radiation area or where other conditions exist that would render it impractical for examination during normal plant operations without exposing personnel to undue hazards.

2.13. Isolated Failure - a failure which does not cause other snubbers to become suspect.

2.14. Lock-up Rate - the shaft velocity or acceleration at which the snubber becomes a restraint to dynamic load.

2.15. Maintenance - Replacement of parts, adjustments and similar actions that do not change the snubber design, performed to prevent deficiencies in the function of the snubber.

2.16. Maintenance, Repair, and Installation-induced Failures - Failures that result from damage during maintenance, repair, or installation activities, the nature of which causes other snubbers to be suspect.

2.17. Normal Operating Conditions - Operating conditions during reactor start-up, operating at power, hot stand-by, reactor cool down or cold shutdown.

2.18. Operating Temperature - The temperature of the environment surrounding a snubber at a designated plant location during the phase of plant operation for which a snubber is required.

2.19. Repair - Action taken to correct deficiencies in the function of the snubber.

2.20. Service Life - The period of time an item is expected to meet operational readiness requirements without maintenance.

2.21. Swing Clearance - The movement envelope within which the snubber must operate without restriction, from the cold installed position to the hot operating position.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 9 of 19 2.22. Test Temperature - The temperature of the environment surrounding the snubber at the time of the test.

2.23. Unexplained Failure - any failure for which the cause cannot be determined.

3.0 PRIMARY RESPONSIBILITIES 3.1. The Program and Component (P&C) Engineering Manager is the program owner and has the overall responsibility for the establishment, implementation and performance of the Shock Suppressor (Snubber) program.

3.2. The P&C Engineering Supervisor is responsible for designating the program coordinator.

3.3. The assigned NDE Level III is responsible for certifying personnel who perform Visual Examinations are qualified to the requirements of CEP-NDE-01 12 Certification of Visual Examination Personnel.

3.4. The Superintendent of Mechanical Maintenance is responsible for ensuring that there are adequate qualified personnel available to implement the program.

3.5. The Superintendent of Nuclear Training, Mechanical Maintenance, is responsible for assisting the Maintenance Department to develop and provide the necessary training to qualify personnel to perform snubber functional testing.

3.6. The Snubber Program Engineer is responsible for:

• The snubber program implementation oversight.

• Snubber selection to satisfy program requirements.

0 Ensuring required visual examinations and functional testing of selected snubbers are properly identified, planned and scheduled via the Work Control Process.

0 Ensuring an adequate inventory of spare snubbers is available to support snubber functional testing.

0 Verification and maintenance of examination, testing and calibration documentation.

9 Notifying the ISI Coordinator of planned snubber visual examination and functional testing.

0 Ensuring the ISI Coordinator is informed of any visual examination or functional testing failures.

• Monitoring the designated service life of each safety related snubber.

• Initiating necessary changes in the program or implementing procedures.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 10 of 19 Informing the Repair/Replacement Coordinator of snubber testing/replacement to ensure accurate reporting of repair and replacement activities per ASME Sec.

XI.

3.7. The Maintenance Supervisor, Mechanical, is responsible for ensuring assigned maintenance personnel are qualified to perform testing, refurbishment and installation of snubbers and to direct their personnel in the accomplishment of those activities.

4.0 DETAILS 4.0. GENERAL 4.0.1. Snubbers examination and testing at VY complies with the requirements of ASME OM Code 2004, through the ASME OMb Code 2006 Addenda, Subsection ISTD; Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants 4.0.2. The examination boundary includes the snubber assembly from pin to pin, inclusive (ISTD-31 10).

4.0.3. Visual inspection frequency of safety class snubbers is on a sliding scale based on the number of unacceptable snubbers found during the previous inspection in proportion to the sizes of the various populations or categories (see Table 1).

4.0.4. Plant snubbers that are not safety related are inspected & tested at a frequency listed under the component's identification number as identified in the preventative maintenance schedule.

4.0.5. Each refueling cycle a functional test is performed on 10% of all safety related snubbers. For Vermont Yankee that equates to 4 of the 38 snubbers that make up the Defined Test Plan Group (DTPG). Any functional test failure requires an additional 5% be tested until all snubbers are tested, or no additional failures are found (ISTD-5260).

4.0.6. The 10% sample is representative of all snubbers installed regardless of make, model, radiation area, or difficulty in removing. The selection is based on time since last functional test, size distribution, and service conditions.

4.0.7. As a good practice, more than 10% of the safety related snubber population will be replaced/tested/rebuilt each refueling cycle for preventive maintenance purposes. Only four are required for the 10% Testing Sample Plan. The DTPG is divided into six sample groups. Refer to Table 2 for a list of the groups and their required test dates (ISTD-5261).

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 11 of 19 4.1. TEST EQUIPMENT 4.1.1. The Grinnell Shock and Sway Suppressor (Snubber) Tester and Fill & Purge Machines shall be operated as directed by approved procedures and the vendor manual. These machines can be used to fill, purge and functionally test the three brands of hydraulic snubbers within the program scope. To ensure proper operation, these machines should be maintained on a periodic basis as determined by the Snubber Program Engineer.

4.1.2. The Snubber Tester pressure gauges shall be calibrated in accordance with the vendor manual within six months of the start of snubber functional testing.

Pressure gauge calibrations are valid for one year unless the indication accuracy is suspected in error. To ensure proper calibration record retention, the work order process shall be used when calibrating the Snubber Tester pressure gauges (ISTD-5224).

4.1.3. All remaining instrument calibrations shall be as directed by the vendor manual.

4.2. VISUAL INSPECTION 4.2.1. Snubber visual examination shall be performed in accordance with plant procedure OP 5203, Inspection and Testing of Shock Suppressors, (Latest Revision) (ISTD-1 300/I STD-1 500/ISTD-1620/ISTD-3000/I STD-4000) 4.2.2. For the purpose of visual inspection only, snubbers may be categorized into two groups: those accessible and those inaccessible during reactor operation. Each group may be inspected independently (ISTD-4220).

4.2.3. Inaccessible snubbers shall be inspected only if the period of time in which they become accessible is greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (ISTD-4220).

4.2.4. Visual inspections of safety related snubbers included in this program shall be performed and documented in accordance with an approved visual examination procedure whenever a visual inspection is conducted to:

Meet 10CFR50.55a requirements.

Document the "as-found" condition prior to removing a snubber for functional testing or maintenance.

Document the "as-left" condition following installation of a snubber for service.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 12 of 19 Note: Snubber visual Inspections will continue to be performed using the VT-3 process and qualifications, however an ANII review is not a requirement of the ASME OM Code.

4.2.5. 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:

4.2.5.1. The cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically susceptible (ISTD-4240),

4.2.5.2. The affected snubber is functionally tested in the as-found condition and determined operable (ISTD-5210).

4.2.6. When the inlet fluid port of a hydraulic snubber is found to be uncovered (i.e.,

no hydraulic fluid covering the inlet port), the snubber shall be determined inoperable unless it can be subsequently determined operable via functional testing (ISTD-4233).

4.2.6.1. In this case the functional test shall be performed with the piston in the as-found condition, extending the piston in the tension mode direction (ISTD-4233).

4.3. FUNCTIONAL TESTING 4.3.1. Refer to Table 2 to determine which snubbers shall be functionally tested in each inspection group (ISTD-5250).

4.3.2. Snubber functional testing shall be performed in accordance with plant procedure OP 5203, Inspection and Testing of Shock Suppressors, (Latest Revision) 4.3.3. The Snubber Tester shall be calibrated prior to use in accordance with associated preventative maintenance work orders and the vendor manual, VYEM 0062 (ISTA-4200).

4.3.4. The Snubber Tester operator shall be qualified to perform snubber functional testing by the Training Department, OJT training module (ISTA-1 100 / ISTA-1500).

4.3.5. A failure of any snubber found during functional testing, for Technical Specification purposes, shall require an additional 5% (quantity = 2) to be

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 13 of 19 tested until all snubbers are tested or no more failures are found. The Snubber Program Engineer shall select additional snubbers for functional testing and, if required, the selection may include other snubbers in the current inspection group (i.e., those snubbers being removed for preventive maintenance)(ISTD-5271/ ISTD-5272 / ISTD-5273 / ISTD-5321).

4.3.6. In addition to the snubbers tested in this test group, the previous test group records must be reviewed for any snubber failures that would require re-testing along with this test group (ISTD-5500).

4.3.7. Any snubber which fails visual inspection shall also require functional testing in the as-found condition. Functional test failures of these snubbers do not require testing additional snubbers. Failures here may affect the visual inspection frequency described in section 4.0 (ISTD-4252).

4.3.8. If maintenance is performed on a snubber which could affect its piston movement or lockup and bleed rates, then the snubber shall be functionally tested prior to reinstallation (ISTD-5272).

4.3.9. In addition to the regular sample, snubbers which failed the previous functional test shall be re-tested during the next test period unless the root cause for the problem has been determined and corrective actions implemented. 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 re-tested during the next test period.

Failure of these snubbers shall not require functional testing of additional snubbers (ISTD-4252).

4.3.10. If any snubber selected for as-found functional testing either fails to lockup or fails to move (frozen in place), the cause of this failure shall be evaluated. If this failure was caused by manufacturer or design deficiency, all generically susceptible snubbers of the same design subject to the same defect shall be functionally tested. Additional failures here shall not require additional functional testing (ISTD-5272).

4.3.11. For any snubber found inoperable, the Snubber Program Engineer shall initiate a Condition Report to perform and document an evaluation of the component(s) which are supported by the snubber(s). The purpose of this engineering evaluation shall be to determine if the component(s) supported by the snubber(s) were adversely affected by the inoperability of the snubber(s) in order to ensure that the supported component remains capable of meeting the designed service (ISTD-5280).

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 14 of 19 4.3.12. Corrective actions requiring repair/replacement activities shall be performed in accordance with ASME Section Xl, as applicable. Other corrective actions shall be performed in accordance with the VY Corrective Action Program (ISTA-3300).

4.4. SERVICE LIFE MONITORING 4.4.1. All snubbers under this program are expected to meet operational readiness requirements without maintenance for a period of ten (10) years. Snubber service life begins upon installation and ends when it is replaced or refurbished (ISTD-6000).

4.4.2. All snubbers under this program are replaced with a new or refurbished snubber once every nine (9) years. This ensures testing on a rotating basis to coincide with service life monitoring.

4.4.3. A record of the service life of each safety related snubber shall be maintained by the Snubber Program Engineer via Work Orders (controlled records) and maintenance history files (uncontrolled records). The snubber serial number is the method used to track the service life of a particular snubber in a given location.

4.4.4. At least once each operating cycle, the Snubber Program Engineer shall review the installation and maintenance records for each safety related snubber to verify the designated service life has not been exceeded nor will it be exceeded prior to the next snubber service life review. If service life will be exceeded before the next scheduled system or plant outage, one of the following actions shall be taken (ISTD-6200):

4.4.4.1. The snubber will be replaced with another snubber that has an expected service life exceeding the date of the next scheduled system or plant outage.

4.4.4.2. Technical justification shall be documented for extending the service life to or beyond the next scheduled system or plant outage.

4.4.4.3. The snubber shall be refurbished such that its service life will extend to or beyond the next scheduled system or plant outage.

4.4.5. New snubbers issued from Stores inventory shall have new elastomers installed prior to functional testing and installation to ensure elastomer parts are up to date at the beginning of the designated service life.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 15 of 19 4.4.6. Refurbished snubbers shall be returned to Stores inventory and issued to the designated system location prior to functional testing and system installation.

This ensures documented serial number traceability (ISTD-5227).

5.0 REFERENCES

AND COMMITMENTS 5.1. Technical Specification and Site Documents 5.1.1. TS 3.6.E and 4.6.E, Structural Integrity and Operability Testing 5.1.2. TS 3.0.8 and TRM 4.6.1, Shock Suppressors (Snubbers) 5.2. Administrative Limits 5.2.1. None 5.3. Codes, Standards and Regulations 5.3.1. Code of Federal Regulations, 10CFR50.55a(b)(3)(v)(B) 5.3.2. ASME Boiler and Pressure Vessel Code, Section Xl, Rules for Inservice Inspection of Nuclear Power Plant Components, 2007 Edition, 2008 Addenda 5.3.3. ASME OM Code-2004 Edition through OMb 2006 Addenda, Subsection ISTD, Preservice and Inservice examination and Testing of Dynamic Restraints (Snubbers) in Light Water Reactor Nuclear Power Plants.

5.4. Commitments 5.4.1. CR-VTY-2003-02110 CA-00001, Perform a Documented Reconciliation of the Snubber Testing Program.

5.4.2. CR-VTY-2003-02110 CA-00002, Prepare a Program Procedure.

5.5. Supplemental References 5.5.1. MEG-102/77, Vermont Yankee Snubbers, G.E. O'Connor to J.L. French 5.5.2. MED-257/78, Vermont Yankee Hydraulic Snubbers, T.M. Cizauskas to D.E.

Moody 5.5.3. OPVY425/87, Snubber Operability, R.L. Smith to D.A. Reid 5.5.4. OPVY541/89, Closeout Summary for Service Request 88-76, Snubber Operability During Shutdown Conditions, R.L. Smith to D.A. Reid 5.5.5. VYEM 0062, Grinnell Hydraulic Shock and Sway Suppressors (Snubbers) 5.5.6. EN-AD-103, Document Control and Records Management Activities 5.5.7. EN-LI-1 02, Corrective Action Process 5.5.8. EN-QV-102, Inspection Program 5.5.9. CEP-NDE-0903, VT-3 Examination 5.5.10. SEP-RR-VTY-001, ASME Code Section Xl Repair/Replacement Program 5.5.11. EN-WM-102 Work Implementation & Closeout

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 16 of 19 5.5.12. AP 0125, Plant Equipment 5.5.13. AP 0315, Equipment Alterations 5.5.14. OP 5203, Inspection and Testing of Shock Suppressors 5.5.15. SEP-ISI-VTY-001, Vermont Yankee Inservice Inspection Program 5.5.16. EN-DC-333, Snubber Inspection Program 6.0 FINAL CONDITIONS 6.1. None 7.0 ATTACHMENTS 7.1. Table 1, Visual Exam Table (inspection intervals) 7.2. Table 2, DTPG Snubber Inspection Program 8.0 QA REQUIREMENTS CROSS REFERENCE 8.1. None

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 17 of 19 TABLE 1 VISUAL EXAMINATION TABLE NUMBER OF UNACCEPTABLE SNUBBERS Population or Category Column A Column B Column C (Notes 1) Extended Interval Previous Interval Reduce Interval (Notes 2 & 3) (Notes 2, 4 & 5) (Notes 2, 5 & 6) 1 0 0 1 80 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 1,000 or greater 29 56 109 NOTE (1): Interpolation between population or category sizes and the number of unacceptable snubbers is permissible. The next lower integer shall be used when interpolation results in a fraction.

NOTE (2): The basic interval shall be the normal fuel cycle up to 24 months. The examination interval may be as great as twice, the same, or as small as fractions of the previous interval as required by the following Notes. The examination intervals may vary by +/- 25% of the current interval.

NOTE (3): If the number of unacceptable snubbers is equal to or less than the number in Column A, then the next examination interval may be increased to twice the previous examination interval, not to exceed 48 months. In that case, the next examination according to the previous interval may be skipped.

NOTE (4): If the number of unacceptable snubbers exceeds the number in Column A, but is equal to or less than the number in Column B, then the next visual examination shall be conducted at the same interval as the previous interval.

NOTE (5): If the number of unacceptable snubbers exceeds the number in Column B, but is equal to or less than the number in Column C, then the next examination interval shall be decreased to two thirds of the previous examination interval or, in accordance with the interpolation between Columns B and C, in proportion to the exact number of unacceptable snubbers.

NOTE (6): If the number of unacceptable snubbers exceeds the number in Column C, then the next examination interval shall be decreased to two-thirds of the previous interval.

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 18 of 19 TABLE 2 DTPG SNUBBER INSPECTION PROGRAM Code Location Sample YEAR SNUBBER ID Class Group

_________ Class 04 05 07 08 10 11 13 14 16 17 19 20 22 23 HPCI-HD103FN 2 HPCI Room 1 ET ET RHR-H185 2 RB 232'NE CR 1 ET ET RR-3 1 Drywell 1 ET ET CS-HD54A 2 Top of Torus 1 ET ET RHR-H197 (A) 2 RB 232' NE CR 1 R R RR-35 1 Drywell 1 R R RHR-H197 (B) 2 RB 232' NE CR 2 ET ET HPCI-HD103GN 2 HPCI Room 2 ET ET RHR-HD127M 2 RB 213'SE CR 2 ET ET RR-2 1 Drywell 2 ET ET CS-HD54H (A) 2 Top of Torus 2 R R MS-3 1 Drywell 2 ET R R HPCI-HD103EN 2 HPCI Room 3 R R R HPCI-HD102EN 2 HPCI Room 3 R R R MS-24 1 Drywell 3 R R R SLC-H48 1 Drywell 3 ET ET ET CS-HD90C 2 RB 213' Torus 3 ET ET ET FW-15 1 Drywell 3 ET ET ET MS-32 1 Drywell 3 ET ET ET RR-34 1 Drywell 4 R '_R R MS-15 1 Drywell 4 R R R FW-3 1 Drywell 4 R R R MS-6 1 Drywell 4 ET ET ET RHR-H183 2 RB 232' NE CR 4 ET ET ET RR-62 1 Drywell 4 ET ET ET RR-63 1 Drywell 4 ET ET ET CS-HD86C 2 Top of Torus 5 R R HPCI-HD102DN 2 HPCI Room 5 R R

VY Program Section No. SEP-SNB-VTY-001 Revision No. 0 Page 19 of 19 TABLE 2 (CONTINUED)

Code Location Sample YEAR SNUBBER ID Class Group

_______ Clas 04 05 07 08 10 11 13. 14 16 17 19 20 22 23 MS-35 1 Drywell 5 ET ET CU-2 1 Drywell 5 ET ET RHR-H98 (A) 2 RB 252' South 5 ET ET RHR-H193 2 RB 252' North 5 ET ET HPCI-H1O3B 2 HPCI Room 6 R R RHR-HD184B 2 RB 213' Torus 6 ET ET CS-HD54H (B) 2 Top of Torus 6 ET ET RHR-H98 (B) 2 RB 252' South 6 R R RHR-HD134 2 Top of Torus 6 ET ET RHR-HD127L 2 RB 213' Torus 6 ET ET NOTES:

1. Although all snubbers in a group will be replaced with a new or rebuilt unit, only the ones with an "ET" will require Examination and functional Testing to meet Technical Specification requirements.

2. The remaining snubbers "R" in that inspection group are being replaced for preventive maintenance (shelf life of rubber goods) and do not require functional testing. They may, however, be utilized for functional testing in the event of a Technical Specification functional failure and required test scope expansion.

MS-32 was mistakenly replaced instead of MS-3. Credit for a satisfactory functional test was taken for MS-32. MS-3 was functionally tested and replaced with a refurbished snubber during RFO-24 in 2004. MS-3 and MS-32 will remain in their current groups.