L-2014-027, Fourth Ten-Year Inservice Inspection Interval License Amendment Request, Changes to Snubber Surveillance Requirements

Fourth Ten-Year Inservice Inspection Interval License Amendment Request, Changes to Snubber Surveillance Requirements

ML14049A284
Person / Time
Site:	Saint Lucie
Issue date:	01/30/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-027
Download: ML14049A284 (47)

Text

0FPLo January 30, 2014 L-2014-027 10 CFR 50.90 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

St. Lucie Unit 2 Docket No. 50-389 Operating License NPF-16 Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Requirements Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) is submitting a request for an amendment to the Technical Specifications (TS) for St. Lucie Unit 2 (SL2).

The proposed amendment would revise the Technical Specification (TS) surveillance requirements (SRs) for snubbers to conform to revisions to the Snubber Testing Program.

Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 contains a detailed comparison of the current TS 4.7.9 SR to the proposed Snubber Program requirements and justification of changes. Attachment 5 provides a copy of the proposed Snubber Testing Program Plan. Attachment 6 provides the revised snubber program bases description, for information only.

FPL is requesting that this be processed as a normal amendment request, with approval of the proposed amendment within one year of the submittal date. Once approved, the amendment shall be implemented within 60 days.

If you should have any questions, please contact Mr. Ken Frehafer at (772) 467-7748.

Florida Power & Ught Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-027 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Vseph Jensen Site Vice President St. Lucie Plant Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages

4. TS 4.7.9 SR Comparison to ISI Program Requirements

5. Proposed Snubber Program Plan

6. Revised Technical Specification Bases (for information only)

L-2014-027 Attachment 1 Page 1 of 7 St. Lucie Unit 2 Docket No. 50-389 Operating License No. NPF-16 ATTACHMENT 1 Description and Assessment 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90, Florida Power & Light (FPL) is submitting a license amendment request to revise Technical Specification (TS) 3/4.7.9, "Snubbers," for St. Lucie Unit 2. The proposed change would revise the TS surveillance requirements for snubbers to conform to the revised St. Lucie Unit 2 Snubber Testing Program.

2.0 DETAILED DESCRIPTION St. Lucie Unit 2 third 10-year IS[ interval ending date was August 7, 2013. The snubber surveillance program is being removed from the ISI program under the ASME,Section XI inspection requirements to comply with the ASME OM Code, Subsection ISTD requirements. Allowing for a 1 year extension to the existing interval for the snubber program transition, in accordance with ASME OM Code, Subsection ISTA-3120(d), the fourth 10-year interval for snubbers at St. Lucie Unit 2 will begin on August 8, 2014.

Currently, snubber testing and examination are performed in accordance with the requirements of TS 3/4.7.9 and FPL Third 10-Year ISI Inspection Interval Program submitted in letter L-2003-189, dated August 6, 2003 and will continue until August 7, 2014. As required by 10 CFR 50.55a(b)(3)(v)(B), FPL is revising the snubber examination and testing program in order to meet the requirements of the OM Code and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor'Nuclear Power Plants," of the ASME OM Code, 2004 Edition with 2005 and 2006 Addenda. The proposed changes to the St.

Lucie Unit 2 TS are summarized below:

Reference to Specification 4.7.9f in TS ACTION 3.7.9 would be replaced with reference to Specification 4.7.9.

TS Surveillance Requirement (SR) 4.7.9 would be revised to conform the surveillance requirements for demonstrating snubber operability to be consistent with the revised snubber examination and testing program. The current

L-2014-027 Attachment 1 Page 2 of 7 description of requirements would be replaced by a reference to the "Snubber Testing Program."

A new TS Section 6.8.4.p, "Snubber Testing Program," will be added to the Administrative Controls section (Section 6.0) of TS to provide a description of the snubber program requirements.

Mark-ups of the proposed TS pages are provided in Attachment 2. Retyped TS pages reflecting the proposed changes are provided in Attachment 3. Attachment 4 contains a detailed comparison of the current TS 4.7.9 SR to the proposed Snubber Program requirements and justification of changes. Attachment 5 provides a copy of the Snubber Testing Program Plan. Revised bases description is provided in Attachment 6 for information only.

3.0 TECHNICAL EVALUATION

Licensees are required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v)(B) to perform the ISI and testing of snubbers in accordance with the ASME OM Code and the applicable addenda, except where the NRC has granted specific written relief pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

As noted in Regulatory Issue Summary 2010-06, licensees have the option to control the ASME Code-required ISI and testing of snubbers through their TS or other licensee-controlled documents. For plants using their TS to govern ISI and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4),

licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRC - approved alternatives used in lieu of the Code requirements.

The proposed change revises the specific TS requirements for snubber examination, testing and service life monitoring with a reference to the Snubber Testing Program, thereby ensuring the TS requirements remain consistent with the revised snubber testing program.

Snubbers will continue to be demonstrated OPERABLE by performance of the Snubber Testing Program. This program will be maintained in compliance with 10 CFR 50.55a per the proposed TS section 6.8.4p. The program for inspection and testing of snubbers in accordance with ASME OM Code and the aplplicable addenda as required by 10 CFR 50.55a(g) includes an evaluation of supported components or systems when snubbers are found to be unacceptable.

L-2014-027 Attachment 1 Page 3 of 7 The proposed change to TS ACTION 3.7.9 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.9.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements Allowing for a 1 year extension of the third 10-year ISI interval, St. Lucie Unit 2 is currently nearing the beginning of the fourth 10-year interval for snubbers at St. Lucie Unit 2, which will begin on August 8, 2014.

Currently, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.9 and FPL Third 10-Year Inspection Interval Program submitted in letter L-2003-189, dated August 6, 2003.

10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b)(3), 12 months before the start of the 120-month inspection interval. If a revised ISI program for a facility conflicts with the TS for the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TS.

For the St. Lucie Unit 2 fourth 10-year interval for snubbers beginning August 8, 2014, as required by 10 CFR 50.55a(b)(3)(v)(B), FPL intends to adopt Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2004 Edition with 2005 and 2006 Addenda, to satisfy the specific surveillance requirements of TS 3/4.7.9 as previously submitted in correspondence dated August 6, 2003.

The purpose of this amendment request is to revise the specific surveillance requirements for demonstrating snubber operability in the TS since the surveillance program will be revised to include the requirements of the OM Code Subsection ISTD as described in the Snubber Testing Program. As such, the proposed changes to TS 3/4.7.9 are necessary to conform the TS to the revised snubber testing program.

4.2 Precedent The changes proposed to TS 3/4.7.9 are similar to changes submitted by Public Service Electric and Gas (PSEG) Nuclear, LLC for Salem Generating Station, Units 1 and 2 and Dominion Nuclear Connecticut (DNC), Inc for Millstone Power Station Unit 2. The applicable references for these similar changes are provided below:

L-2014-027 Attachment 1 Page 4 of 7 PSEG Letter LR-N10-0363, License Amendment Request: Changes to Snubber Surveillance Requirements [for Salem Units 1/2], dated October 4, 2010 (Accession No. MLI102780066).

PSEG Letter LR-N11-0107, Response to Draft Request for Additional Information

- License Amendment Request: Changes to Snubber Surveillance Requirements

[for Salem Units 1/2], dated April 7,2011 (Accession No. ML110980107).

PSEG Letter LR-N 11-0151, Response to Draft Request for Additional Information

- License Amendment Request: Changes to Snubber Surveillance Requirements

[for Salem Units 1/2], dated May 23, 2011 (Accession No. ML111430636)

DNC Letter 11-354, License Amendment Request to Revise Snubber Surveillance Requirements [for Millstone Power Station Unit 2], dated September 21,2011 (Accession No. ML11270A051).

DNC Letter 12-086, Response to Request for Additional Information Regarding License Amendment Request to Revise Snubber Surveillance Requirements [for Millstone Power Station Unit 2], dated February 24,2012 (Accession No. ML12062A069).

A minor difference noted between these precedent license amendment requests and the St. Lucie Unit 2 request being submitted by FPL is that the FPL request is in response to the requirement of 10 CFR 50.55a(b)(3)(v)(B) to perform the ISI and testing of snubbers in accordance with Subsection ISTD of the ASME OM Code and the applicable addenda when using the 2006 Addenda and later editions and Addenda of Section Xl of the ASME B&PV Code.

The previously referenced license amendment requests were made prior to the splitting of 10 CFR 50.55a(b)(3)(v) into parts (A) and (B) with the endorsement of the 2006 Addenda of the Section Xl Code, where 10 CFR 50.55a(b)(3)(v) permitted the optional use of OM Code Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light- Water Reactor Nuclear Power Plants," 2004 Edition, in place of the requirements for snubbers in the Boiler and Pressure Vessel Code (B&PV Code), Section Xl, Articles IWF-5200(a) and (b) and IWF-5300(a) and (b).

10 CFR 50.55a(b)(3)(v) previously required that when using this alternative, preservice and inservice examination of snubbers must be performed using the VT-3 method specified in IWA-2213.

4.3 No Significant Hazards Consideration Determination FPL requests adoption of an approved change to the plant specific Technical Specifications for St. Lucie Unit 2, to revise TS 3/4.7.9, "Snubbers."

L-2014-027 Attachment 1 Page 5 of 7 As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes would revise SR 4.7.9 to conform the TS to the revised surveillance program for snubbers. Snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g)

Snubber examination, testing and service life monitoring is not an initiator of any accident previously evaluated. Therefore, the probability of an accident previously evaluated is not significantly increased.

Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The proposed change to TS ACTION 3.7.9 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.9. The proposed change does not adversely affect plant operations, design functions or analyses that verify the capability of systems, structures, and components to perform their design functions therefore, the consequences of accidents previously evaluated are not significantly increased.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not involve any physical alteration of plant equipment. The proposed changes do not alter the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged. The methods governing plant operation and testing remain consistent with current safety analysis assumptions.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

L-2014-027 Attachment 1 Page 6 of 7

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed changes ensure snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g). Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives.

The proposed change to TS ACTION 3.7.9 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.9.

Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion 10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of the 120-month inspection interval.

If a revised ISI program for a facility conflicts with the TS of the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TS to conform the TS to the revised ISI program.

The proposed change amends the TS surveillance requirements for snubbers to conform the TS to the revised testing program for snubbers which shall meet the requirements of 10 CFR 50.55a(g) except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

L-2014-027 Attachment 1 Page 7 of 7 5.0 ENVIRONMENTAL EVALUATION The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 RER C 6.1 FPL Letter dated August 6, 2003,

Subject:

St. Lucie, Unit No. 2 Third 10-Year Inservice Inspection Interval, Inservice Inspection Program - Revision 0 (Accession No. ML032260327) 6.2 NRC Regulatory Issue Summary 2010-06, "Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)," June 1, 2010 (Accession No. ML101310338).

6.3 St. Lucie, Unit No. 2, Current Facility Operating License NPF-16, Tech Specs, Revised 12/21/2013.

L-2014-027 Attachment 2 Page 1 of 9 Proposed Technical Specification Changes Summary Revised TS Pages 3/4 7-21 3/4 7-22 3/4 7-22a 3/4 7-22b 3/4 7-23 3/4 7-24 3/4 7-25 6-15j

L-2014-027 Attachment 2 Page 2 of 9 PLANT SYSTEMS 314.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All safety-related snubbers shall be OPERABLE.

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

ACTION:

With one or more safety related snubbers inope ble, 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 OPE LE status and perform an engineering evaluation per Specification . on the supported component or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

T SURVEILLANCE REQUIREMENTS 4.7.9 Each snubber shall be demon ted OPERABLE by performance of the As bersusetrthis of the" specificationb desgn andl "type of snubbera manufacturer, shall mean irrespective of snub-capacity.

Sb. VisuallInspections

• " Snubbers are categorized as in sqssible or accessible during p- reactor operation. Each of these ca r~ies (inaccessible or accessible) may be inspected independe atccording to the schedule deemnd b al .7-2. The visual inspe c interval for each category of snubber shall be determined based u he criteria provided in Table 4.7-2 and the first inspection interval rmined using this criteria shall be based upon the previous inspectio interval as established by the requirements In effect before Amendment.

ST. LUCIE - UNIT 2 314 7-21 Amendment No. 22, 44

L-2014-027 Attachment 2 Page 3 of 9 PLANT SYSTEMS

c. Visual Inspection Acceptance Criteria Visual Inspections shag verify that (1) the snubber has no visible Indications of damage or Impaired OPERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) fast-eners for the attachment of the snubber to the component and to the ubber anchorage are functional. Snubbers which appear inoperable a result of visual inspections shall be classified as unaccept-abI nd may be reclassified acceptable for the purpose of estab-lishin

• next visual inspection interval, provided that (0 the cause o he rejection is clearly established and remedied for that particular ubber and for other snubbers irrespective of type that may be gen cally susceptible; and (ii) the affected snubber is functionally te ed in the as-found condition and determined OPERA-BLE per Specifd tion 4.7.10.e. All snubbers found connected to an inoperable cormmohydraulic fluid reservoir shall be counted as unacceptable for de mining the next inspection interval. A review and evaluation shall b rformed and documented to justify contin-ued operation with an un cceptable snubber. If continued operation cannot be justified, the sn ber shall be declared inopefable and the ACTION requirements s 11be met.

TABLE 4. -2 SNUBBER VISUAL INSPE ION INTERVAL NUMBER OF UNACCEPTABLL NUBBERS Population Column A Column Column C or Category Extend Interval Repeat Inte I Reduce Interval (Notes I and 2) (Notes 3 and 6) (Notes 4 and 6 (Notes 5 and 6) 0 0 1 80 0 0 2 100 0 1 4

• .150 0 3  :ý 8

• -200 25 3

• "400 8 183 Soo50 12 24 48

• -"750 20 40 78 1000 or greater 29 56 109\

ST. LUCIE: - UNIT 2 3/4 7-22 Amendment No. 22, .46, 51

L-2014-027 Attachment 2 Page 4 of 9 PLANT SYSTEMS SURVILANCE REQUIREMENTS (continued)

N te 1: The next visual inspection interval for a snubber population or category 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 accesslbil-

. during power operation, as accessible or inaccessible.

These c egories may be examined separately or jointly. However, the lice ee must make and document that decision before any inspection and s11l use that decision as the basis upon which to determine the next ins ction interval for that category.

Note 2: Interpolation tween population or category sizes and the number of unacceptable s bbers is permissible. Use next lower integer for the value of the Ii *for Columns A, B, or C if that integer in-cludes a fractional v e of unacceptable snubbers as determined by interpolation.

Note 3: Ifthe number of unacceptab snubbers is equal to or less than the number in Column A, the next spection interval may be twice the previous interval but not greater n 48 months.

Note 4: Ifthe number of unacceptable snubbe is equal to or less than the number in Column B but greater than th umber in Column A, the next inspection interval shall be the same as th revious interval.

Note 5: If the number of unacceptable snubbers is equa o or greater than the number in Column C, the next inspection inte I shall be two-thirds of the previous interval. However, ifthe numb of unac-ceptable snubbers is less than the number in Column ut greater than the number in Column B. the next interval shall be r uced 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 ring the previous interval and the number in Column B to the difference in the numbers in Columns 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.

ST. LUCIE - UNIT 2 3/4 7-22a Amendment No. ,51

L-2014-027 Attachment 2 Page 5 of 9 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

d. Functional Tests an During the first refueling shutdown and at least once per 18 months thereafter during shutdown, a representative sample of either:

• . ~(1) At least 10% of the total of each type of safety related snubber .

in use in the plant shall be functionally tested either in place or iC a bench test. For each snubber of a type that does not meet the "nctional test acceptance citeria of Specification 4.7.9e. an additional of that type of snubber shall be functionally tested until no more of are found or until all snubbers of that type have beenday functiotally tested or (2) A representative sample of each type of snubber hall be functionally tested in accordance with Figure 4.7-1.

a"n tmis thetalequirements acceptance number of snubbers of a type of Specification foundThe 4.7.9e. not cumulative meeting the tatnumber of snubbers of a type tested is denoted by "N". At the end ofeach day'st" ting, the newvalues of "N"and "C" (previous day's total plus current day's increments) shall be plotted on Figure 4.7-1.

Ifat any time the ps nt plotted falls in the "Reject" region, all snubbers of that typ design shall be functionally tested. Ifat any timee point plot d falls in the "Accept" region, testing of that type of snubber shasbe terminated. When the point plotted of siz lies in the e Tesaid " region, additional snubbers of that type shall be es until the int falls in the "Accept" region or the "Rejecat" ion, or all thewubbers of that type have been tested.

The representautive sample seleoteor functional testing shall include the various configurations, h rating environments, nd the range of sbte and capacity of snumbbeprf each type. The representa-tive sample should beweightedto includw more snubbers from severe service areas such as near heavy equiped t. Snubbero placed in the same location as snubbers which ailed the pevious functional test shall beicue ntenx est lot if the failur*analysis shows that failure was due to location.

S e. Functional Test Acceptance Criteria The snubber functional test shall verify that:"

I1. Activation (restraining action) is achieved within the sl cifled rangenbthtnion_ and compression" "

2. Snubber bleed, rrlaert hr equired, is present ir both tensio n and. compression, .with_._ in the specified range.\

3. Wher eurd h oc eurdt nitiate or maintain mtooftesubriwihntespecified range in both directions of travel.

L C1 - NI 2 14 - b Affen me t No. 1

L-2014-027 Attachment 2 Page 6 of 9 PLANT SYSTEMS

e. Functional Test Acceptance Criteria (continued)

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

5. Fasteners for attachment of the snubber to the component and to the snubber anchorage are secure. e v o Testing ethods may be used to measure parameters indirectly or parameters other tharhose specified ifthose results can be correlated to the ie specified p meters through established methods.

f. Function Test Failure Analysis An engineeri evaluation shall be made to esig fiimeet theall functional test eptance criteqia to deternine the cause of thep failure. The resuien of this evaluation shall be used, if applicable, in selecting the snn bers to be tested in an effort to determine the OPERABILITYofdotr snubbers irrespective of type which mayibe th subject too he same faul s ede.t e e i e For the snubbers found in ~lera ble, an engineering evaluation shall "

ibeperformed on the ompoi nts to which the inoperable snubbers are

• . attached. The purpose of thi 'ngineering evaluation shall be to

" ~determine if the components weeadversely affected by the inopera-

bility ca pableof the snubbersthe of rmeeting in designed order tos es ureice.that the component remains Ifany snubber selected for functional t ting either fails to fockup or fails to move, inn pla ' the cause will be evaluated andif caused by manuf7ac.ture o design deficiency all

• . ~snubbers of the same type subject to the sa* defect shall be

[pfunctionally tested. hstsing requirementsshllbe independent

• . ~of the requirements in Specification 4.7.9.e for s *bbers not matngtet fuctonal test acceptance criteria.

g. Functional Testing feaird and Replaced Snubbe

• ,-Snubbers which fail the visual inspection or the functiona ~st

• ,.acceptance criteria shall be repaired or replaced. Replace ~nt

• .snubesadsubr hc aerpairs which might affe the funtoa tseult shall be tested to meet the functional test c

crtei before installation in the unit. These snubbers shall have*

(. ~met the acceptance criteria subsequent to their most recent servic

( ~and the functional test must have been performed within 12 months "

I before being installed in the unlit F-U E T 3/ 7.- A e d nt o 51

L-2014-027 Attachment 2 Page 7 of 9 PLANT SYSTEMS Snube rSeal Replacement Program The sea ce life of hydraulic snubbers shall be monitored and documented Ptoensurerthat It xedo not fall

• " The aiu xpected s ilf between surveillance Inspections.

for the various seals, sea[

maeias an plctons shall be =-Jted based on engineering inorato an h el hl e replaced s the maximum exece sevc iede o xire during a perio h

i. Exemption From Visual Inspection or Functional Tests 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 the snubber for the applicable design conditions at either the completion of their fabrication or at a subsequent date.

ST. LUCIE - UNIT 2 314 7-24 Amendment No, 2. 61,k1.

L-2014-027 Attachment 2 Page 8 of 9 7

6 C 5 4

3 0 10 20 30 40 90 100 N

FIGURE 4.7-1 SAMPUNG PLAN FOR SNUBBER TEST ST. LUCIE - UNIT 2 314 7-25

L-2014-027 Attachment 2 Page 9 of 9 ADMINISTRATIVE CONTROLS (continuedi

n. Diesel Fuel Oil Testing Proaram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

(i) Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color or a water and sediment content within limits; (ii) Other properties for ASTM 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and (iii) Total particulate concentration of the fuel oil is - 10 mg/I when tested every 31 days.

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.

o. Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendation of Regulatory position c.4. b of Regulatory Guide 1.14, Revision 1, August 1975.

p. Snubber Testing Program

-This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10CFR50.55a inservice inspection (151)requirements for supports. The program shall be in accordance with the following:

1. This program shall meet 10 CFR 5Om55a(g) ISI requirements for supports.

2. The program shall meet the requirementsfor ISIof supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure (BPV)

Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(b) subject to limitations and modifications listed in 10 CFR50.55a(b) and subject to Commission approval.

3. The program shall, as required by 10 CFR 50.55a(b)(3)(v)(B), meet Subsection ISTA,'General Requirements" and Subsection ISTD."Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

4. The 120-month program updates shall be made in accordance with 10CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10CFR 50.55a(b)(3)(v)(B)) subject to the limitations and modifications listed therein.

ST. LUCIE - UNIT 2 3-15j Amendment No. 4.65, 46

L-2014-027 Attachment 3 Page 1 of 9 Word Processed TS Pages 3/4 7-21 3/4 7-22 3/4 7-22a 3/4 7-22b 3/4 7-23 3/4 7-24 3/4 7-25 6-15j

L-2014-027 Attachment 3 Page 2 of 9 PLANT SYSTEMS 314.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All safety-related snubbers shall be OPERABLE.

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

ACTION:

With one or more safety related 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 per Specification 4.7.9. on the supported component or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7.9 Each snubber shall be demonstrated OPERABLE by performance of the Snubber Test Program.

a. Exemption From Visual Inspection or Functional Tests 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 the snubber for the applicable design conditions at either the completion of their fabrication or at a subsequent date.

ST. LUCIE - UNIT 2 3M47-21 Amendment No. -2 5-4

L-2014-027 Attachment 3 Page 3 of 9 DELETED ST. LUCIE - UNIT 2 3/4 7-22 Amendment No. -24,45,64

L-2014-027 Attachment 3 Page 4 of 9 DELETED ST. LUCIE - UNIT 2 314 7-22a Amendment No. 44

L-2014-027 Attachment 3 Page 5 of 9 DELETED ST. LUCIE - UNIT 2 314 7-22b Amendment No.44

L-2014-027 Attachment 3 Page 6 of 9 DELETED ST. LUCIE - UNIT 2 3f4 7-23 Amendment No.-1

L-2014-027 Attachment 3 Page 7 of 9 DELETED ST. LUCIE - UNIT 2 3/4 7-24 Amendment No. 12, "-, 440

L-2014-027 Attachment 3 Page 8 of 9 DELETED ST. LUCIE - UNIT 2 3/4 7-25

L-2014-027 Attachment 3 Page 9 of 9 ADMINISTRATIVE CONTROLS tcontinued)

n. Diesel Fuel Oil Testing Proaram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

(i) Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color or a water and sediment content within limits; (ii) Other properties for ASTM 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and (iii) Total particulate concentration of the fuel oil is -S10 mg/I when tested every 31 days.

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.

o. Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendation of Regulatory position c.4. b of Regulatory Guide 1.14, Revision 1, August 1975.

p. Snubber Testing Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISI) requirements for supports. The program shall be in accordance with the following:

1. This program shall meet 10 CFR 50.55a(g) ISI requirements for supports.

2. The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(b) subject to limitations and modifications listed in 10 CFR 50.55a(b) and subject to Commission approval.

3. The program shall, as required by 10 CFR 50.55a(b)(3)(v)(B), meet Subsection ISTA, "General Requirements" and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

4. The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10 CFR 50.55a(b)(3)(v)(B)) subject to the limitations and modifications listed therein.

ST. LUCIE - UNIT 2 6-15j Amendment No. 4.15,544%

L-2014-027 Attachment 4 Page 1 of 11 St. Lucie Unit 2 Docket No. 50-389 Operating License No. NPF-16 ATTACHMENT 4 COMPARISION OF CURRENT TS REQUIREMENTS TO REVISED ISI SNUBBER PROGRAM ASSESSMENT

L-2014-027 Attachment 4 Page 2 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.a Inspection Types ISTD-5252 allows for DTPG's to be established The revised SNUBBER program requirements As used in this specification," i snubber" type of As used based upon differences in design, application, this sforficatios"asypSRo4sn7b9er for inspection types allow the same distinction shall mean snubbers of the same design and size, or type. for DTPG's as SR 4.7.9.a manufacturer, irrespective of capacity.

4.7.9.b Visual Inspections ISTD-4220(a) requires all snubbers to be Use of ISTD-4200 for snubber inservice Snubbers are categorized as inaccessible or considered one population for examination, or examination in lieu of current SR 4.7.9.b does accessible during reactor operation. Each of alternatively, to categorize them individually not change the number of snubbers required these categories (inaccessible or accessible). as accessible or inaccessible. The categories to be examined or the required examination may be inspected independently according to of accessible and inaccessible snubbers shall intervals.

the schedule determined by Table 4.7-2. The be considered separately for examination.

visual inspection interval for each category of ISTD-4220(b) requires the decision to examine snubber shall be determined based on the the snubbers as one population or as separate criteria provided in Table 4.7-2, and the first categories to be made and documented inspection interval determined using this before the scheduled examination begins and criteria shall be based upon the previous not changed during the examination.

inspection interval as established by the requirements in effect.

4.7.9.c Visual Inspection Acceptance Criteria ISTD-4210 states that inservice examination 10 CFR 50.55a(b)(3)(v) allows the use of Visual inspections shall verify (1) that there shall be a visual examination to identify subsection ISTD for inservice examination are no visible indications of damage or physical damage, leakage, corrosion, or requirements.

impaired OPERABILITY and (2) attachments to degradation that may have been caused by The revised Snubber program requirements the foundation or supporting structure are environmental exposure or operating will continue to examine the integrity of the functional, and (3) fasteners for the conditions; and that external characteristics attachments to the supporting structure.

that may indicate operational readiness of the anttachmeo the snubber thore the fncmponet snubber shall be examined. The revised snubber program requirements and to the snubber anchorage are functional. for inservice examination satisfy the visual

L-2014-027 Attachment 4 Page 3 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change ISTD-4231 requires that examinations shall inspection acceptance criteria in SR 4.7.9.c include observations for loose fasteners, or members that are corroded or deformed disconnected components or other conditions that might interfere with the proper restraint of movement. If observed these conditions shall be evaluated.

ISTD-4232 requires that examinations verify snubbers do not restrain thermal movement to an extent that unacceptable stresses could develop in the snubber, the pipe, or other equipment that the snubber is designed to protect or restrain.

ISTD-4233 requires that examinations verify snubbers are shall be free of defects that may be generic to particular designs as may be detected by visual examination.

4.7.9.c Visual Inspection Acceptance Criteria ISTD-4240 permits snubbers classified as The revised SNUBBER program requirements (cont) unacceptable during inservice examination to for inservice examination is equivalent to the Snubbers which appear inoperable as a result be tested in accordance with the visual inspection acceptance criteria in SR requirements of ISTD-5210. Results that 4.7.9.c unacceptable and may be reclassified satisfy the operational readiness test criteria unacceptable and may buse rfelassifd t of ISTD-5210 shall be used to accept the acceptable for the purpose of establishing the subr rvddtets eosrtsta next visual inspection interval, provided that snubber, provided the test demonstrates that (i) the cause of the rejection is clearly established and remedied for that particular operational readiness.

L-2014-027 Attachment 4 Page 4 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change snubber and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.9.e 4.7.9.c Visual Inspection Acceptance Criteria ISTD-4233 requires that fluid supply or The revised SNUBBER program requirements (cont) content for hydraulic snubbers shall be for inservice examination satisfy the visual All snubbers found connected to an observed. If the fluid is less than the inspection acceptance criteria in SR 4.7.9.c minimum amount, the installation shall be inifie asounaccep table, ss at e inoperable common hydraulic fluid reservoir as unacceptable, unless a test ouned unacepableforidentified shal aasbeunacceptable shall be counted for determining the next inspection interval. A establishes that the performance of the review and evaluation shall be performed and snubber is within specified limits. Tests shall documented to justify continued operation be performed in accordance with ISTD-with an unacceptable snubber. If continued 5210(b) and ISTD-5210(c). The initial test shall operation cannot be justified, the snubber start with the piston at the as-found setting shall be declared inoperable and the ACTION and be performed in the extension (tension) requirements of shall be met. direction, or in a mode that more closely resembles the operating and design requirements of the snubber.

ISTD-4270 requires that snubbers that do not meet examination requirements of ISTD-4230 shall be evaluated to determine the root cause of the unacceptability.

ISTD-4280 requires that unacceptable snubbers shall be adjusted, repaired, modified, or replaced.

L-2014-027 Attachment 4 Page 5 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change TABLE 4.7-2 SNUBBER VISUAL INSPECTION ISTD-4252(b) requires inservice examinations Table ISTD-4252-1 is equivalent to SR Table INTERVAL to be conducted in accordance with Table 4.7-2 for population/category population ISTD-4252-1 sizes.

4.7.9.d Functional Tests ISTD-5200 requires snubber operational The frequency of snubber testing in the During the first refueling shutdown and at readiness testing to be performed each fuel revised program is unchanged from the least once per 18 months thereafter, during cycle. Testing shall be performed during frequency specified in current TS SR 4.7.9.d.

shutdown a representative sample of either: normal system operation, or during system or The initial sample size in the revised program plant outages. is as large as the size specified in current SR (1) At least 10% of the total of each type of ISTD-5223 and ISTD-5224 permit snubbers to 4.7.9.d.

functionally tested either in place be tested in their installed location or in a The revised program provides for an bench test. bench test. expanded sample of one half the initial sample For each snubber of a type that does not meet ISTD-5261 requires snubbers of each Defined be tested for each failed snubber when using the functional test acceptance criteria of Test Plan Group (DTPG) to be tested using the 10% test plan. Although the present either:program requires an additional sample of the specification 4.7.9.e, an additional 10% of that either:

same 10% for each failed snubber this is not (a) the 10% testing sample plan s iee to e a ired in s since type of snubber shall be functionally tested euto nsft ic are found, or until all cniee ob snunti no until smore failures nofmore fues are fund, ofunctilally ISTD-5330 requires the snubbers of each DTPG the proposed program includes an increased snubbers of that type have been functionally and failure mode group (FMG) to be tested as emphasis on service life monitoring, and this required. Testing is complete when the proposed test program has been previously mathematical expressions of ISTD-5331 are approved by the regulator and is widely in use satisfied, or all snubbers in the DTPG or FMG elsewhere.

have been tested.

ISTD-5331 requires that testing shall satisfy the mathematical expressions as follows:

(a) for each DTPG

L-2014-027 Attachment 4 Page 6 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change N > O.1n + C(0.1n/2)

(b) for each FMG NF 2!CF(0.1n/2) 4.7.9.d Functional Tests (cont.) ISTD-5411 requires an initial sample of 37 The initial sample size using the 37 plan in the snubbers to be selected randomly from each revised program is as large as the size (2) A representative sample of each type of 37 plan DTPG. specified in current SR 4.7.9.e.

snubber shall be functionally tested in accordance with Figure 4.7-1, "C" is the total ISTD-5431 requires testing to satisfy the Figure ISTD-5431-1 reflects the same number of snubbers of a type found not mathematical expressions as follows: acceptance line as SR Figure 4.7-1 only it is meeting the acceptance requirements of defined in terms of N rather than C.

(a) for each DTPG Specification 4.7.9.e. The cumulative number It requires the same equation to be satisfied of snubbers of a type tested is denoted by N Ž-36.49 + 18.18C (Fig. ISTD-5431-1) to complete testing.

"N". At the end of each days testing, the new Figure ISTD-5431-1 reflects the same values of "N" and "C" (previous day's total acceptance line as SR Figure 4.7-1 only it is plus current day's increments) shall be plotted defined in terms of N rather than C.

on Figure 4.7-1. If at any time the point plotted falls in the "Reject region, all snubbers of that type design shall be functionally tested. If at any time the point plotted falls in the "Accept" region, testing of that type snubber may be terminated.

The representative sample selected for ISTD-5500 requires that snubbers placed in functional testing shall include the various the same location as snubbers that failed the Retests of failed snubber locations are configurations, operating environments, and previous inservice operational readiness test required by the revised program as in SR the range of size and capacity of snubbers of shall be retested at the time of next 4.7.9.d each type. The representative sample shall be operational readiness testing unless the cause weighted to include more snubbers from of the failure is clearly established and

L-2014-027 Attachment 4 Page 7 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change severe service areas such as near heavy corrected.

equipment. Snubbers placed in the same location as snubbers which failed the previous functional test shall be included in the next test lot if the failure analysis shows that a failure was due to location.

4.7.9.e Functional Test Acceptance Criteria ISTD-5210(a), (b) and (c) require the same The revised SNUBBER program requirements The snubber functional test shall verify that: verification for operational readiness testing. for snubber acceptance criteria are equivalent to those of current SR 4.7.9.e

1. Activation (restraining action) is achieved within the specified range in both tension and ISTD-4231 Requires Snubbers to be installed compression. so they are capable of restraining movement when activated. Examinations include

2. Snubber bleed, or release rate where fasteners and other components that might required, is present in both tension and interfere with proper restraint of movement.

compression, within the specified range.

3. Where required, the force required to initiate or maintain motion of the snubber is within the specified range in both directions of travel.

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

5. Fasteners for attachment of the snubber to ISTD-5226 States when test methods are used the component and to the snubber anchorage that either measure parameters indirectly, or are secure. measure parameters other than those Testing methods may be used to measure specified, the results shall be correlated with

L-2014-027 Attachment 4 Page 8 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change parameters indirectly or parameters other specified parameters through established than those specified if those results can be methods.

correlated to the specified parameters through established methods.

4.7.9.f Functional Test Failure Analysis ISTD-5271 states that snubbers that do not The revised SNUBBER program requirements An engineering evaluation shall be made to meet test requirements shall be evaluated to for snubber acceptance criteria are equivalent each failure to meet the functional test determine the root cause of the failure to those of current SR 4.7.9.f acceptance criteria to determine the cause of ISTD-5272 states that snubbers found the failure. The results of this evaluation shall unacceptable according to operational be used, if applicable, in selecting snubbers to readiness test requirements should be be tested in an effort to determine the assigned to FMGs unless the failure is isolated OPERABILITY of other snubbers irrespective of or unexplained. FMGs shall include all the type which may be subject to the same unacceptable snubbers with the same failure failure mode. mode and all other snubbers with similar potential for similar failure.

4.7.9.f Functional Test Failure Analysis (cont.) ISTD-1800 Requires an evaluation be The revised SNUBBER program requirements For snubbers found inoperable, an performed of the system(s) or components of for snubber acceptance criteria are equivalent engineering evaluation shall be performed on which an unacceptable snubber is a part, for to those of current SR 4.7.9.g the components to which the inoperable possible damage to the supported system or snubbers are attached. The purpose of this component.

engineering evaluation shall be to determine if the components were adversely affected by the inoperability of the snubbers in order to ensure that the component remains capable of meeting the designed service.

L-2014-027 Attachment 4 Page 9 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.f Functional Test Failure Analysis (cont.) ISTD-5271 states that snubbers that do not The revised program requirements for if any snubber selected for functional testing meet test requirements shall be evaluated to manufacturer or design deficiencies require either fails to lockup or fails to move, i.e., determine the root cause of the failure. replacement or modification of all snubbers in frozen in place, the cause will be evaluated ISTD-5272 states that snubbers found the FMG or additional testing until the and if caused by manufacturer or design unacceptable according to operational mathematical expression of ISTD-M331(b) is deficiency all snubbers of the same type readiness test requirements should be subject to the same defect shall be assigned to FMGs unless the failure is isolated tested. This may result in fewer snubbers functionally tested. This testing requirement or unexplained. FMGs shall include all being tested after a test failure. However, the shall be independent of the requirements in unacceptable snubbers with the same failure revised program requirements provide Specification 4.7.9.e for snubbers not meeting mode and all other snubbers with similar adequate assurance of snubber OPERABILITY Specfiction4.79.ebecause all potentially affected snubbers will the functional test acceptance criteria potential for similar failure.

be replaced or modified; or the acceptance As an alternative to additional testing for limit for additional testing will be met, Design or Manufacturing FMGs, ISTD-5323 demonstrating an acceptable level of requires no additional testing when all reliability snubbers in the FMGs are replaced or modified in accordance with ISTD-1600.

If replacement or modification is not performed in accordance with ISTD-5323, additional testing is required in accordance with ISTD-5324. Testing is required to continue until the acceptance limit is satisfied or all snubbers in the FMG have been tested.

4.7.9.g Functional Testing of Repaired and ISTD-1610 Requires replacement or modified The revised SNUBBER program requirements Replaced Snubbers snubber(s) to have a proven suitability for the for supported component(s) or system Snubbers which fail the visual inspection or application and environment and; evaluation are equivalent to those of current the functional test acceptance criteria shall be ISTD-5134 Requires adjusted, modified, SR 4.7.9.g.

repaired or replaced. Replacement snubbers repaired, or replacement snubbers to be

L-2014-027 Attachment 4 Page 10 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change and snubbers which have repairs which might tested to meet the requirements of ISTD-5120 affect the functional test result shall be tested prior to service.

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.

4.7.9.h Snubber Seal Replacement Program ISTA-9310 requires the maintenance of The service life evaluation requirements in The seal service life of hydraulic snubbers shall records in accordance with the Owners QIA The sethesrequirementsoinhcurrentcTsnSRbers.shhl ISTD-6100 and ISTD-6200 are equivalent to be monitored and documented to ensure that program. the requirements in current TS SR 4.7.9.h.

the seals do not fail between surveillance ISTD-6100 requires initial snubber service life inspections. The maximum expected service to be predicted based on manufacturer's life for the various seals, seal materials, and recommendation or design review.

applications shall be estimated based on ISTD-6200 and ISTD-6200(c) requires service engineering information and the seals shall be life to be evaluated at least once each fuel replaced so that the maximum expected cycle. If the evaluation indicates that service service life will not be exceeded during a life will be exceeded before the next sedul ed ste or e the period when the snubber is required to be system or plant outage, the OPERBLE.scheduled OPERABLE. snubber shall be reconditioned such that its service life will be extended to or beyond the next scheduled system or plant outage Figure 4.7-1 SAMPLING PLAN FOR SNUBBER Fig. ISTD-5431-1 The 37 Testing Sample Plan Figure ISTD-5431-1 reflects the same FUNCTIONAL TEST acceptance line as SR Figure 4.7-1 only it is

L-2014-027 Attachment 4 Page 11 of 11 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change defined in terms of N rather than C.

L-2014-027 Attachment 5 Page 1 of 6 St. Lucie Plant Snubber Testing Program Plan Revision 0 Florida Power & Light Company St. Lucie Plant 6501 S. Ocean Drive Jensen Beach, FL 34957 Page 1 of 6 Revision Date Revision Date Rev 00 Rev Page I of 6

L-2014-027 Attachment 5 Page 2 of 6 Revision Log Effective Revision Description Prepared: Date Approved: Date Date IST Snubber Engineering Coordinator Manager

+ I 4 4- 4

+ I 4 4-

+ 4 4 4 4 Rev 0 Pa~ge2of6 Rev'ison Date Revision Date Rev 0 Page2 of 6

L-2014-027 Attachment 5 Page 3 of 6 TABLE OF CONTENTS SECTION

1.0 INTRODUCTION

2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:

3.0 EXAMINATION and TESTING METHODS:

4.0 EXAMINATION and TESTING FREQUENCY:

5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:

6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:

7.0 SCHEDULING

8.0 REPORTS AND RECORDS:

Rev 00 Pageiqfd Date Revision Dale Rev Page 3 o./6

L-2014-027 Attachment 5 Page 4 of 6 INTRODUCTION:

1.1 Purpose

To provide requirements for the performance and administration of assessing the operational readiness of those quality related dynamic restraints (Snubbers) whose specific functions are required to ensure the integrity of the reactor coolant pressure boundary or any safety-related system.

1.2 Scope

The program plan was prepared to meet the requirements of the following subsections of the American Society of Mechanical Engineers (ASME) OM Code 2004 Edition with 2005 and 2006 Addenda.

" Subsection ISTA, "GeneralRequirements" ISTA contains the requirements directly applicable to inservice examination and testing including the Owner's Responsibility and Records Requirements.

" Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor NuclearPower Plants" ISTD establishes requirements for preservice and inservice examination and testing, and the service life monitoring of Dynamic Restraints (Snubbers) in light-water reactor nuclear power plants. The snubbers covered are required to support the systems and components that are required in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

1.3 Discussion

In order to ensure the required operability of all safety related and quality related snubbers for the St.

Lucie Plant during seismic or other events initiating dynamic loads, the inspection, testing and service life monitoring of these snubbers shall be implemented and performed in accordance with the requirements of the station Snubber Testing Program Requirements.

The examination boundaries for the Snubber Program shall include the snubber assembly from pin to pin inclusive. Integral and nonintegral structural attachments for snubbers, when examined, shall be examined in accordance with the requirements of the ASME Code Section XI, Article IWF-2500(a),

(b), (c) and (d). Coordination with the ISI program owner will be required to complete the surveillance and documentation requirements for these piping and structural attachments.

The Snubber Program described in OSP-73.01 and QI-10-PRfPSL-6 adheres to the requirements of the ASME OM Code, Subsection ISTD, 2004 Edition with 2005 and 2006 Addenda, as required by 10CFR50.55a(bX3 )(v)(B).

Page 4of6 Revision Date Revsion Dale Rev 00 Rev Page 4 oft6

L-2014-027 Attachment 5 Page 5 of 6 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:

2.1 Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the extent specified within OSP-73.01, QI-10-PR/PSL-6 and referenced Surveillance Test Procedures.

2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample plan per ISTD-5300. Large equipment snubbers atlached to the Steam Generators or Reactor Coolant Pumps will each comprise separate DTPG's.

2.3 The service life of all snubbers shall be monitored and evaluated, replaced, or reconditioned in accordance with OSP-73.01, QI-10-PR/PSL-6 and ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections. The replacement or reconditioning of snubbers shall be documented and records retained in accordance with St. Lucie Plant procedures.

3.0 EXAMINATION and TESTING METHODS:

3.1 Visual examinations shall be performed by individuals qualified in accordance with St. Lucie Plant procedures. These examinations are conducted to ensure the mechanical and structural condition of the snubber support location and to observe conditions that could affect functional adequacy. Visual examinations and functional testing shall be performed to verify the requirements specified within OSP-73.01 and QI-10-PR/PSL-6 are met in accordance with Subsection ISTD.

4.0 EXAMINATION and TESTING FREQUENCY:

4.1 Visual Examinations and Functional Testing shall be performed at the frequency specified within OSP-73.01, QI-10-PRIPSL-6 and ISTD-4250 and ISTD-5240. Snubbers are categorized as inaccessible or accessible during reactor operation for visual examination. Each of these categories (inaccessible and accessible) may be examined independently according to the schedule determined by Table ISTD 4252-I.

4.2 Code Case OMN-13, which allows the extension of the visual examination interval, will be implemented for snubber inspections during this interval. Code Case OMN-13 is approved for use in Regulatory Guide 1.192 (June 2003). The Visual Examinations of Table ISTD 4252-1 may be extended in accordance with Code Case OMN-13 once the prerequisites of the code case have been satisfied.

4.3 Visual Examinations shall be performed whenever new snubbers are installed, reinstallation of existing or swapped snubbers that were functionally tested, or after repairs, replacements or modifications.

4.4 Functional testing requirements for new installations or spares shall be equal to or more stringent than that specified within OSP-73.01 and QI-10-PR/PSL-6.

Rev 00 Page .5of 6 Rev'ision Date Revision Date Rev Page .5of 6

L-2014-027 Attachment 5 Page 6 of 6 5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:

5.1 Snubbers that do not appear to conform to the Visual Examination requirements of OSP-73.01 and QI-10-PRJPSL-6, shall be reported for evaluation and appropriate corrective action.

5.2 Snubbers that do not appear to conform to the visual examination acceptance requirements and arc later confirmed as operable as a result of functional testing may be declared operable for the purpose of establishing the next visual inspection interval, providing that the unacceptable condition did not affect operational readiness.

5.3 Snubbers that do not meet the operability testing acceptance criteria in OSP-73.01 and QI PR/PSL-6 shall be evaluated to detenrnine the cause of the failure and appropriate corrective action shall be taken.

5.4 The service life of a snubber is predicted using manufacturer's input and contemporary information gained through consideration of the snubber service conditions and inservice functional test results.

Service life monitoring program requirements are included in OSP-73.01 and QI-10-PR/PSL-6.

6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:

6.1 Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the ASME Code, Section X3.

7.0 SCHEDULING

7.1 The Visual Examinations, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with OSP-73.01, QI-10-PR/PSL-6 and Subsection ISTD by the Snubber Engineer.

7.2 A listing of snubbers included in this program is maintained and is controlled within the NAMS Equipment Data Base.

7.3 The Snubber Engineer shall identify and track expanded or additional testing and/or examinations as required by OSP-73.01, QI-10-PR/PSL-6 and Subsection ISTD.

8.0 REPORTS and RECORDS:

8.1 Reports and records for the Visual Examinations and Functional Testing shall be maintained for all snubbers included within the Snubber Program in accordance with QI-17-PSL-1, Quality Assurance Records.

8.2 Applicable records and reports, as required for Repair and Replacements, shall be maintained.

8.3 Records of the service life of all snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records shall also be maintained in accordance with QI-l 7-PSL-1 and QI-10-PR/PSL-6.

Rev 0 Page 6of6 Revision Date Revision Date Rev 0 Page 6 oft

L-2014-027 Attachment 6 Page 1 of 3 St. Lucie Unit 2 Docket No. 50-389 Operating License No. NPF-16 ATTACHMENT 6 REVISED TECHNICAL SPECIFICATION BASES PAGES Proposed Technical Specification Bases Changes Retyped TS Bases Pages Section 3/4 7-10 Section 3/4 7-11

L-2014-027 Attachment 6 Page 2 of 3 SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGE:

314.7 BASES ATTACHMENT 9 OF ADM-25.04 10 of 11 REVISION NO.: PLANT SYSTEMS 3 ST. LUCIE UNIT 2 314.7 CONTAINMENT SYSTEMS (continued)

BASES (continued) 314.7.9 SNUBBERS All safety related snubbers are required to be OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety related systems Is maintained during and following a seismic or other event initiating dynamic loads. Snubbers excluded from this inspection program are those installed on nonsafety related systems and then only if their failure or failure of the system on which they are installed, would have no adverse effect on any safety related system.

The snubber program has been updated for the fourth inspection interval to meet the requirements of the ASME OM Code, as required by 10 CFR 50.55a Rulemaking.

Snubbers are classified and grouped by design and manufacturer but not by size. For example, mechanical snubbers utilizing the same design features of the 2 kip. 10 kip and 100 kip capacity manufactured by company "A" are of the same type. The same design mechanical snubber manufactured by company "B", for purposes of this Specification, would be of a different type, as would hydraulic snubbers for either manufacturer.

The visual inspection frequency is based upon maintaining a constant level of snubber protection to systems. Therefore, the required Inspection interval varies inversely with the observed snubber failures and is determined by the number of inoperable snubbers found during an inspection. Inepeetiene-pa - m- w------ --------

a wpý wU-- - - -.-

point to dotOrMin. thc*... t inopoction. HWc^...r, the rcufts1 of ouch eaody inepectione Ppcformcd before the original required- tima interv.al has clapsed (rorri'a 'ioe lass 25O1 ma' not he used to lonothrAA nnrd rrotr v..

intn.-l ,Any inspection whose results require a shorter inspection interval will override the previous schedule.

To provide assurance of snubber functional reliability, ee of We ,-sampling and acceptance criteria methods from the OM Code, Subsection ISTD are used,-,

1. Functionally test 1950%of a type of cnubber with an-additional 10% teeted for acrh fu-nctional tocting failuro or

2. Functin"ally toet a cample sic and determino sample arceoptanco or roioction ucino Figure '1.7 1.

L-2014-027 Attachment 6 Page 3 of 3 SECTION No': TITLE: TECHNICAL SPECIFICATIONS PAGE:

3/4.7 BASES ATTACHMENT 9 OF ADM-25,04 11 Of 11 REVISION NO.! PLANT SYSTEMS 3 ST. LUCIE UNIT 2 3/4.7 CONTAINMENT SYSTEMS (continued)

BASES (continued) 3/4.7.9 SNUBBERS (continued)

Figurac 1.7 1 WaS~ deV:QGp~d Wcing "Wald'c GGGIUGntiil PFObabillrtY RAtio PlMAn" an doscribod OR"Qualit"; C.n... 2nd ndj...... tati.ti.. " by'.Achesn I.

Dunean.

A-4_Service life of all snubbers is evaluated via manufacturer input and information through consideration of the snubber service conditions and associated installation and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc...). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions. These -erGds-evaluationswill be documented to provide stagtstiGae-bases for future consideration of snubber service life.

314.7.10 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is 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 sources within radiation monitoring or boron measuring devices) are considered to be stored and need not be tested unless they are removed from the shield mechanism.

3/4.7.11 DELETED