Text

Snubber Program Plan for the Fourth Ten-Year Inservice Testing Interval
	ML15343A344
Person / Time
Site:	Columbia
Issue date:	12/09/2015
From:	Gregoire D; Energy Northwest
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GO2-15-166
	Download: ML15343A344 (8)
	v • d • e

ENERGY DW Regulatory Affairs and Performance Improvement

Pn Box 968, PE2O Ni;HIHIf5T Richland, WA 99352-0968 Ph. 509-377-861 6 F. 509.377.4098 dwgregoire@ energy-northwest.com G02-1 5-166 u.a Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SNUBBER PROGRAM PLAN FOR THE FOURTH TEN-YEAR INSERVICE TESTING INTERVAL

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),

Energy Northwest is submitting for your information a copy of the Snubber Program Plan Fourth 1 0-Year Inservice Testing Interval for Columbia Generating Station (Columbia). The Snubber Program fourth ten-year interval begins on December 13, 2015.

The program was developed to satisfy the snubbers preservice and inservice testing and examination requirements of the ASME OM Code 2004 Edition through 2006 Addenda.

No new regulatory commitments are being made in this submittal.

Respectfu I ly, DW Gregoire Manager, Regulatory Affairs and Performance Improvement

Enclosure:

As stated cc:

NRC RIV Administrator NRC NRR Project Manager NRC Senior Resident Inspector

- 988C CD Sonoda

- BPA

- 1399 (w/o enclosure)

WA Horin

- Winston & Strawn (w/o enclosure)

December 9, 2015

Snubber Program Plan 4th 10-YEAR INTERVAL Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 SNUBBER PROGRAM PLAN FOURTH 10-YEAR INSERVICE TESTING INTERVAL (13 DEC 2015 through 12 DEC 2024)

CODE OF RECORD:

ASME OM CODE 2004 Edition, 2005 and 2006 Addendum ENERGY NORTHWEST COLUMBIA GENERATING STATION 76 North Power Plant Loop Richland, WA 99354 USNRC DOCKET NO. 50-397 FACILITY OPERATING LICENSE NO. NPF-21 COMMERCIAL OPERATION DATE: DECEMBER 13, 1984

Snubber Program Plan 4th TEN YEAR INTERVAL Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 DESCRIPTION OF CHANGES Justification (required for major revision)

New Snubber Program Plan (AR 258889258889

Page(s)

Description (including summary, reason, initiating document, if applicable)

Snubber Program Plan 4th TEN YEAR INTERVAL Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 TABLE OF CONTENTS Page

1.0 INTRODUCTION

................................................................................................................................ 1 1.1 PURPOSE........................................................................................................................................... 1 1.2 SCOPE................................................................................................................................................ 1 1.3 DISCUSSION...................................................................................................................................... 2 2.0 VISUAL EXAMINATIONS.................................................................................................................. 2 3.0 FUNCTIONAL TESTING................................................................................................................... 3 4.0 SERVICE LIFE MONITORING.......................................................................................................... 4 5.0 REPAIR, REPLACEMENT AND MODIFICATION REQUIREMENTS........................................... 4 6.0 SCHEDULING.................................................................................................................................... 4 7.0 QUALITY ASSURANCE.................................................................................................................... 4

Snubber Program Plan 4th 10-Year Interval Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 1

1.0 INTRODUCTION

1.1 PURPOSE This document provides the general requirements, as set forth in the ASME OM Code, Subsection ISTD, for the performance and administration of assessing the operational readiness of those dynamic restraints (Snubbers) whose specific functions are required to ensure the integrity of the reactor coolant pressure boundary or any safety-related system.

These requirements include Visual Examinations, Functional Testing and Service Life Monitoring. This document references plant procedures and surveillances that implement specific requirements of the Snubber Program at Columbia.

1.2 SCOPE Columbias Snubber Program Plan complies with the requirements of 10 CFR Part 50.55a(b)(3) and Part 50.55a(b)(3)(v)(B). The ASME OM Code 2004 Edition, 2005 and 2006 Addenda was incorporated by reference into 10 CFR 50.55a(b)(3) by rulemaking effective on July 21, 2011 and has been adopted by Columbia as the Code of Record for the Fourth 10-year Inservice Testing Interval for which this program plan is applicable.

Columbias Snubber Program Plan meets the requirements of the following subsections of the ASME OM Code.

Subsection ISTA, General Requirements ISTA contains General Requirements directly applicable to inservice examination and testing of certain pumps, valves and dynamic restraints (snubbers). This section establishes such things as general Owner Responsibilities, Definitions and Record Requirements.

Subsection ISTD, Preservice and Inservice Examination and Testing of dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants ISTD establishes specific requirements for preservice and inservice examination, testing, and service life monitoring of snubbers.

The scope of the Snubber Program are those ASME Code Class 1, 2 and 3 snubbers used in systems that perform a specific function in shutting down a reactor to the safe shutdown condition, maintaining the safe shutdown condition, mitigating the consequences of an accident, or ensuring the integrity of the reactor coolant pressure boundary.

Snubber Program Plan 4th 10-Year Interval Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 2

1.3 DISCUSSION In order to ensure the required operational readiness of all snubbers that impact safety related systems at Columbia during seismic or other events that initiate dynamic loads, the Examination, Testing and Service Life Monitoring of these snubbers shall be implemented and performed in accordance with the requirements of ASME OM CODE, Subsection ISTD as described in site procedure SWP-PRG-03 Snubber Program and implemented per Plant Surveillance Procedures.

Specific snubber, snubber location, testing results and service life monitoring activities are maintained within SnubbWorks, a data management module that is part of the software package IDDEAL Software Suite used at Columbia.

2.0 VISUAL EXAMINATIONS The Snubber Program examination boundary includes the snubber assembly from pin to pin, inclusive (ISTD-3110).

Preservice examinations shall be performed on all snubbers placed in new or modified systems after placing the systems in service as required by ISTD-4100. Preservice examinations are required on all replacement snubbers installed as part of service life monitoring or corrective actions, such that they meet the applicable requirements of ISTD-4100, ISTD-4200, and ISTD-5200.

Inservice examinations shall be performed on a set frequency and results shall be evaluated to determine the snubbers operational readiness (ISTD-4200).

An examination checklist shall be used to identify physical damage, leakage, corrosion, or degradation that may have been caused by environmental exposure, operating conditions or human performance errors (ISTD-4210).

For inservice examinations, snubbers are categorized as accessible or inaccessible (ISTD-4220) to distinguish which snubbers can be examined during normal plant operation and which cannot such that personnel safety is maintained.

Snubber Program Plan 4th 10-Year Interval Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 3

Snubbers that are found unacceptable during inservice examination may be tested in accordance with the requirements of ISTD-5210 and declared acceptable, provided the test demonstrates that the unacceptable condition did not affect operational readiness (ISTD-4240).

Inservice examination intervals begin at the end of the previous examination interval (end of last outage), and conclude at the end of the next refueling outage per ISTD-4252.

Visual examination frequencies have been established in accordance with Table ISTD 4252-1, with all snubbers being categorized as one population.

Code Case OMN-13, which allows the extension of the visual examination interval, will be implemented during the 4th 10-year Interval. Code Case OMN-13 is approved for use in Regulatory Guide 1.192 (published Oct 2014). Once the prerequisites of the code case are satisfied visual examination frequency may be extended to once every 10 years.

Visual examinations are performed per the applicable requirements of ISTD-4100 following reinstallation of repaired, replaced or modified snubbers. Upon reinstallation snubbers that have been removed for functional testing only shall also be visually examined.

3.0 FUNCTIONAL TESTING Columbia will use the 10% Testing Sample Plan as described in ISTD-5300 to functionally test snubbers during every refueling outage.

Columbias snubber population consists of all Basic-PSA mechanical snubbers and is separated into Design Test Plan Groups (DTPG) by snubber size and applications in accordance with ISTD-5252.

DTPG Population Description Sample Plan 1

PSA-100s inside Primary Containment 10%

2 PSA-35s inside Primary Containment 10%

3 PSA-35s inside Heater Bay 10%

4 PSA-35s inside Reactor Bldg.

10%

5 All remaining PSA sizes.

10%

Snubber functional testing is performed in accordance with SWP-PRG-03 and plant Surveillance Procedures. Snubbers that do not meet the applicable acceptance criteria shall be

Snubber Program Plan 4th 10-Year Interval Columbia Generating Station LBD-IST-SNUBBER-4 Revision 0 4

evaluated to determine the cause of the failure and appropriate corrective action taken. Failure evaluations may be performed per guidance in SWP-PRG-03 and Failure Mode Grouping (FMG) should be applied in accordance with ISTD-5320, as applicable.

When additional testing samples are required due to an unacceptable snubber, the sample size shall be at least one-half the size of the initial sample from that DTPG in accordance with ISTD-5312. Additional testing is performed in accordance with ISTD-5320.

Retesting of snubbers during the next testing interval due to unacceptable snubbers in the previous test interval shall be performed in accordance with ISTD-5500.

4.0 SERVICE LIFE MONITORING The service life of all snubbers shall be monitored. Initial snubber service life shall be predicted based on manufacturers recommendation or design review. Snubbers shall be replaced or reconditioned as required to ensure that the service life is not exceeded before the next scheduled system or plant outage. Service life evaluations for each snubber shall be performed at least once each fuel cycle and service life verified to be adequate or increased or decreased, as needed. The Snubber Service Life Monitoring Program is described in SWP-PRG-03.

5.0 REPAIR, REPLACEMENT AND MODIFICATION REQUIREMENTS Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified in plant procedure PPI-PPM-1.3.30 Repair, Replacement and Alteration of ASME Items.

6.0 SCHEDULING The Visual Examinations, Functional Testing schedules and Service Life Monitoring activities shall be established, tracked and maintained in accordance with SWP-PRG-03 and per the requirements of Subsection ISTD by the Snubber Program Owner.

7.0 QUALITY ASSURANCE Columbia Generating Stations Snubber Program activities will be conducted in accordance with the Energy Northwest's Operational Quality Assurance Program Description (OQAPD).