LR-N11-0107, Response to Draft Request for Additional Information - License Amendment Request: Changes to Snubber Surveillance Requirements

Response to Draft Request for Additional Information - License Amendment Request: Changes to Snubber Surveillance Requirements

ML110980107
Person / Time
Site:	Salem
Issue date:	04/07/2011
From:	Fricker C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N11-0107
Download: ML110980107 (34)

Text

PSEG p.o. Box 236, Hancocks Bridge, NJ 08038-0236 OPSEG APR 07 2011 Nuclear LLC 10 CFR 50.90 LR-N11-0107 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Response to Draft Request for Additional Information - License Amendment Request: Changes to Snubber Surveillance Requirements

References:

1. Letter from Carl J. Fricker, PSEG Nuclear LLC, to U.S. Nuclear Regulatory Commission, "License Amendment Request: Changes to Snubber Surveillance Requirements," dated October 4,2010 (ADAMS Accession No. ML102780066)

2. Email from R. Ennis, USNRC to PSEG, "Salem Nuclear Generating Station, Unit Nos. 1 and 2, Draft Request for Additional Information (TAC NOS. ME4796 and ME4797)," dated February 7,2011 (ADAMS Accession No. ML110390175)

In Reference 1, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The proposed amendment would revise the Technical Specification (TS) requirements for snubbers to conform to planned revisions to the inservice inspection (lSI) program.

In Reference 2 the NRC requested additional information regarding PSEG's license amendment request. The information requested by the NRC and PSEG's responses are in Attachment 1. A markup of proposed Technical Specification page changes is provided in Attachment 2 and replaces the markup contained in Reference 1. A copy of the draft snubber program plan is provided in Attachment 3.

PSEG has determined that the information provided in this response does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted.

There are no new commitments contained in this letter. If you have any questions or require additional information, please contact Paul Duke at (856) 339-1466.

LR-N11-0107 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on __Lf....!...--_r["""',-:-Z-:-:-o_(...:....l_ __

(date)

Sincerely, Carl J. ric r Site Vice President - Salem Attachments (3) cc: W. Dean, Administrator, Region I, NRC R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector, Salem P. Mulligan, Manager IV, NJBNE L. Marabella, Corporate Commitment Tracking Coordinator H. Berrick, Salem Commitment Tracking Coordinator LR-N11-0107 Response to Draft Request for Additional Information Regarding Proposed License Amendment - Snubber Surveillance Requirements Salem Nuclear Generating Station - Units 1 and 2 NRC Docket Nos. 50-272 and 50-311 In Reference 1, PSEG Nuclear LLC PSEG) submitted an amendment request for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The proposed amendment would revise the Technical Specification (TS) requirements for snubbers to conform to planned revisions to the inservice inspection (ISI) program.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee provided that supports the proposed amendment and would like to discuss the following issues to clarify the submittal.

Background

PSEGs application dated October 4, 2010, states that for the current third 10-year ISI intervals at Salem Units 1 and 2, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.9 in lieu of the requirements contained in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, Article IWF-5000. The NRC previously authorized use of TS 3/4.7.9 in lieu of the ASME Code requirements pursuant to 10 CFR 50.55a(a)(3)(i) for the third 10-year ISI intervals for Salem Units 1 and 2.

The application states that for the Salem Unit 1 fourth 10-year ISI interval, beginning May 20, 2011, PSEG intends to adopt Subsection ISTD, of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition, in place of the current requirements. PSEG also intends to adopt Subsection ISTD of the OM Code, 2004 Edition, for the remainder of the Salem Unit 2 third 10-year ISI interval which ends November 27, 2013.

Request for Additional Information

1. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3), Surveillance requirements, states that, Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed amendment would delete the specific requirements for demonstrating snubber operability, currently in surveillance requirement (SR) 4.7.9. A reference to the program for examination, testing and service life monitoring for snubbers would be added in place of the specific requirements. The proposed changes do not provide sufficient detail necessary to adequately demonstrate snubber operability. Please propose TS changes consistent with the requirements in 10 CFR 50.36(c)(3) and provide the technical evaluation supporting these changes.

Response

To provide sufficient detail for snubber surveillance requirements, PSEG proposes to add the following description of the snubber program to the Administrative Controls section (Section 6.0) of the Technical Specifications:

LR-N11-0107 6.8.4.m 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:

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

(ii) 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.

(iii) The program shall, as allowed by 10 CFR 50.55a(b)(3)(v),

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 in lieu of Section XI of the ASME BPV Code ISI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

(iv) 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)) subject to the limitations and modifications listed therein.

Consistent with the proposed change above, PSEG also proposes to revise SR 4.7.9 to read as follows:

Each snubber shall be demonstrated OPERABLE by performance of the Snubber Testing Program for examination, testing and service life monitoring for snubbers.

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

A markup of the proposed Technical Specification page changes is provided in Attachment 2. The revised Salem ISI program for snubbers will conform to the proposed TS requirements. A comparison of the revised snubber program requirements to the current TS SR 4.7.9 requirements and justification of the changes is provided in the response to RAI 2.b below.

LR-N11-0107

2. 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TSs, the licensee shall submit a license amendment request to conform the TSs to the revised program. The licensees application states that the proposed changes to TS 3/4.7.9 are required to conform the TSs to the revised ISI program for snubbers.

However, rather than changing the specific requirements currently contained in SR 4.7.9 to conform to Subsection ISTD of the OM Code, the licensee has proposed to delete the SRs and add a reference to the program for examination, testing and service life monitoring for snubbers.

The licensees application dated October 4, 2010, provides no analysis of the specific changes to the snubber examination, testing and service life monitoring that would result from the revised ISI program. Since the licensee is not relocating TS 3/4.7.9 out of the TSs in its entirety (i.e., based on the criteria in 10 CFR 50.36(c)(2)), the NRC staff needs further information to adequately evaluate the actual change being made. The following additional information should be provided:

a) Consistent with 10 CFR 50.55a(g)(5)(ii), please identify which planned revised ISI program requirements for Salem Units 1 and 2 conflict with the current requirements in SR 4.7.9.

Response

For Salem Unit 1 fourth 10-year ISI interval, beginning May 20, 2011, and for the remainder of the Unit 2 third 10 year interval which ends November 27, 2013, PSEG intends to adopt the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Subsections ISTA and ISTD, 2004 Edition.

This is consistent with the requirements for the Snubber Testing Program in proposed TS 6.8.4.m discussed above.

Conflicts with the current requirements in SR 4.7.9 are identified in the response to RAI 2.b below.

b) Provide a detailed comparison of the changes that would result from the revised ISI program with respect to the visual inspection requirements (SR 4.7.9.a);

visual inspection acceptance criteria (SR 4.7.9.b), functional tests (SR 4.7.9.c),

hydraulic snubbers functional test acceptance criteria (SR 4.7.9.d), mechanical snubbers functional acceptance criteria (SR 4.7.9.e), snubber service life monitoring (SR 4.7.9.f), and snubber visual inspection interval requirements (Table 4.7-3). The information provided should justify why the proposed changes are sufficient to demonstrate snubber operability consistent with the requirements in 10 CFR 50.36(c)(3).

Response

A detailed comparison of the planned revised snubber ISI program requirements to the current requirements in SR 4.7.9 is provided in the table below.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.a Visual Inspection ISTD-4220(a) requires all snubbers to be Table ISTD-4252-1 is identical to TS Table considered one population for examination, or 4.7-3 for population/category sizes less than or All snubbers shall be categorized into two alternatively, to categorize them individually as equal to 150.

groups: those accessible and those accessible or inaccessible. The categories of inaccessible during reactor operation. The accessible and inaccessible snubbers shall be Use of ISTD-4200 for snubber inservice visual inspection interval for each category of considered separately for examination. examination in lieu of current TS SR 4.7.9.a snubbers shall be determined based upon the does not change the number of snubbers criteria provided in Table 4.7-3. ISTD-4220(b) requires the decision to examine required to be examined or the required the snubbers as one population or as separate examination intervals.

Note 1 to TS Table 4.7-3 states that snubber categories to be made and documented before categories may be examined separately or the scheduled examination begins and not jointly. changed during the examination.

ISTD-4252(b) requires inservice examinations to be conducted in accordance with Table ISTD-4252-1.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.b Visual Inspection Acceptance Criteria ISTD-4210 states that inservice examination 10 CFR 50.55a(b)(3)(v) allows the use of shall be a visual examination to identify subsection ISTD for inservice examination Visual inspections shall verify (1) that there are physical damage, leakage, corrosion, or requirements. Preservice and inservice no visible indications of damage or impaired degradation that may have been caused by examinations are required to be performed OPERABILITY, (2) attachments to the environmental exposure or operating using the VT-3 visual examination method foundation or supporting structure are secure, conditions; and external characteristics that described in IWA-2213.

and (3) in those locations where snubber may indicate operational readiness of the movement can be manually induced without snubber shall be examined. The revised ISI program requirements for disconnecting the snubber, that the snubber inservice examination do not differ significantly has freedom of movement and is not frozen ISTD-4231 requires that examinations shall from the visual inspection acceptance criteria up. include observations for the following and the in SR 4.7.9.b.

conditions shall be evaluated when found:

(a) loose fasteners, or members that are corroded or deformed (b) disconnected components or other conditions that might interfere with the proper restraint of movement 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.

ASME Code Section XI, Articles IWF-5200(c) and IWF-5300(c) requires integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of Subsection IWF.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.b (continued) ISTD-4240 permits snubbers classified as The revised ISI program requirements for unacceptable during inservice examination to evaluation and corrective action for inservice Snubbers which appear inoperable as a result be tested in accordance with the requirements examination are equivalent to those of current of visual inspections may be determined of ISTD-5210. Results that satisfy the SR 4.7.9.b for visual examination acceptance OPERABLE for the purpose of establishing the operational readiness test criteria of ISTD- criteria.

next visual inspection interval, providing that 5210 shall be used to accept the snubber, (1) the cause of the rejection is clearly provided the test demonstrates that the established and remedied for that particular unacceptable condition did not affect snubber and for other snubbers that may be operational readiness.

generically susceptible; and (2) the affected snubber is functionally tested in the as found ISTD-4233 requires that fluid supply or content condition and determined OPERABLE per for hydraulic snubbers shall be observed. If Specification 4.7.9d or 4.7.9e as applicable. the fluid is less than the minimum amount, the However, when the fluid port of a hydraulic installation shall be identified as unacceptable, snubber is found to be uncovered, the snubber unless a test establishes that the performance shall be declared inoperable and cannot be of the snubber is within specified limits. Tests determined OPERABLE via functional testing shall be performed in accordance with ISTD-for the purpose of establishing the next visual 5210(b) and ISTD-5210(c). The initial test shall inspection interval. All snubbers connected to start with the piston at the as-found setting and an inoperable common hydraulic fluid reservoir be performed in the extension (tension) shall be counted as inoperable snubbers. 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.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.c Functional Tests ISTD-5200 requires snubber operational The frequency of snubber testing in the revised readiness testing to be performed each fuel program is unchanged from the frequency At least once per 18 months during shutdown, cycle. Testing shall be performed during specified in current TS SR 4.7.9.c.

a representative sample of 10% of the total of normal system operation, or during system or each type of snubber in use in the plant shall plant outages. The revised program provides greater flexibility be functionally tested either in place or in a in permitting testing to be performed during bench test. ISTD-5240 states that snubber testing may modes other than shutdown. However, as begin no earlier than 60 days before a noted in Generic Letter 91-04:

scheduled refueling outage.

The staff concludes that the TS need not ISTD-5261 requires snubbers of each Defined restrict surveillances as only being Test Plan Group (DTPG) to be tested using performed during shutdown.

either: Nevertheless, safety dictates that when refueling interval surveillances are (a) the 10% testing sample plan performed during power operation, (b) the 37 testing sample plan licensees give proper regard for their effect on the safe operation of the plant. If the ISTD-5223 and ISTD-5224 permit snubbers to performance of a refueling interval be tested in their installed location or in a surveillance during plant operation would bench test. adversely affect safety, the licensee should postpone the surveillance until the unit is shut down for refueling or is in a condition or mode that is consistent with the safe conduct of that surveillance.

PSEG assesses and manages risk in accordance with 10 CFR 50.65(a)(4) prior to performing maintenance and surveillance activities both at power and during shutdown.

Activities are scheduled to minimize outage times for TS required equipment.

PSEG plans to use the 10% sample plan for Salem Units 1 and 2.

The initial sample size in the revised program is as large as the size specified in current TS 4.7.9.c.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.c (continued) ISTD-5271 requires snubbers that do not meet For testing failures, the revised program can test requirements specified in ISTD-5210 or require fewer additional tests than current TS For each type of snubber that does not meet ISTD-5230 to be evaluated to determine the SR 4.7.9.c. However, the revised program the functional test acceptance criteria of root cause of the failure. requirements for failure evaluation, corrective Specification 4.7.9d or 4.7.9e, an additional action, additional testing and service life 10% of that type of snubber shall be ISTD-5330 requires the snubbers of each monitoring provide adequate assurance of functionally tested. DTPG and failure mode group (FMG) to be snubber OPERABILITY.

tested as required. Testing is complete when the mathematical expressions of ISTD-5331 are satisfied, or all snubbers in the DTPG or FMG have been tested.

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

(a) for each DTPG N 0.1n + C(0.1n/2)

(b) for each FMG NF CF(0.1n/2)

Per ISTD-5322, additional tests are not required for an isolated failure.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.c (continued) ISTD-5311(a) requires the initial sample to Initial sample composition requirements are include as practicable representation from the less detailed in the revised program than those The representative sample selected for DTPG based on the significant features (i.e., in current TS SR 4.7.9.c. However, the functional testing shall include the various the various designs, configurations, operating revised program requirements continue to configurations, operating environments and the environments, sizes, and capacities) and ensure initial sample selection is random and range of size and capacity of snubbers. At based on the ratio of the number of snubbers representative.

least 25% of the snubbers in the of each significant feature, to the total number representative sample shall include snubbers of snubbers in the DTPG. Initial sample from the following three categories: selection shall be random.

1. The first snubber away from each As an alternative, ISTD-5311(b) requires the reactor vessel nozzle initial sample to be generally representative, as

2. Snubbers within five feet of heavy in ISTD-5311(a) but allows the sample to be equipment (valve, pump, turbine, selected from those snubbers scheduled for motor, etc.) seal replacement or other activities related to

3. Snubbers within ten feet of the service life monitoring.

discharge from a safety relief valve 4.7.9.c (continued) ISTD-5500 requires that snubbers placed in The revised program requirement is equivalent the same location as snubbers that failed the to the current TS SR 4.7.9.c requirement to In addition to the regular sample, snubbers previous inservice operational readiness test retest a replacement snubber installed in place which failed the previous functional test shall shall be retested at the time of next operational of a failed snubber. Retesting is required, be retested during the next test period. If a readiness testing unless the cause of the unless the cause of the original failure was spare snubber has been installed in place of a failure is clearly established and corrected. clearly established and corrected.

failed snubber, then both the failed snubber (if it is repaired and installed in another position) Retests in accordance with ISTD-5500 shall The revised program does not require retest and the spare snubber shall be retested. Test not be considered a part of inservice during the next test period of failed snubbers results of these snubbers may not be included operational readiness testing sample selection that are repaired and installed in another for the re-sampling. requirements. position. However, the corrective action requirements for unacceptable snubbers in ISTD-5280, including testing, provide adequate assurance of OPERABILITY for failed snubbers that are repaired and installed in another position.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.c (continued) ISTD-5271 states that snubbers that do not The revised program requirements for meet test requirements shall be evaluated to manufacturer or design deficiencies require If any snubber selected for functional testing determine the root cause of the failure. replacement or modification of all snubbers in either fails to lockup or fails to move, i.e., the FMG or additional testing until the frozen in place, the cause will be evaluated ISTD-5272 states that snubbers found mathematical expression of ISTD-5331(b) is and if caused by manufacturer or design unacceptable according to operational satisfied or all snubbers in the FMG have been deficiency all snubbers of the same design readiness test requirements should be tested. This may result in fewer snubbers subject to the same defect shall be functionally assigned to FMGs unless the failure is isolated being tested after a test failure. However, the tested. This testing requirement shall be or unexplained. FMGs shall include all revised program requirements provide independent of the requirements stated above unacceptable snubbers with the same failure adequate assurance of snubber for snubbers not meeting the functional test mode and all other snubbers with similar OPERABILITY because all potentially affected acceptance criteria. potential for similar failure. snubbers will be replaced or modified; or the acceptance limit for additional testing will be As an alternative to additional testing for met, demonstrating an acceptable level of Design or Manufacturing FMGs, ISTD-5323 reliability.

requires no additional testing when all 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.c (continued) ISTD-1800 requires that an evaluation shall be The revised ISI program requirements for performed of the system(s) or components of supported component(s) or system evaluation For the snubber(s) found inoperable, an which an unacceptable snubber is a part, for are equivalent to those of current SR 4.7.9.c.

engineering evaluation shall be performed on possible damage to the supported system or the components which are supported by the component.

snubber(s). The purpose of this engineering evaluation shall be to determine if the components 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.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.d Hydraulic Snubbers Functional Test ISTD-5210(a) and (b) require the same The revised ISI program requirements for Acceptance Criteria verification for operational readiness testing. hydraulic snubber acceptance criteria are equivalent to those of current SR 4.7.9.d.

The hydraulic snubber functional test shall verify that:

1. Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.

2. Snubber bleed, or release rate, where required, is within the specified range in compression or tension. For snubbers specifically required to not displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.e Mechanical Snubbers Functional ISTD-5210(a), (b) and (c) require the same The revised ISI program requirements for Acceptance Criteria verification for operational readiness testing. mechanical snubber acceptance criteria are equivalent to those of current SR 4.7.9.e.

The mechanical snubber functional test shall verify that:

1. The force that initiates free movement of the snubber rod in either tension or compression is less than the specified maximum drag force.

2. Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.

3. Snubber release rate, where required, is within the specified range in compression or tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

LR-N11-0107 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.9.f Snubber Service Life Monitoring ISTD-6100 requires initial snubber service life Technical Specification 6.10.2.m is not to be predicted based on manufacturer's affected by the proposed change.

A record of the service life of each snubber, recommendation or design review.

the date at which the designated service life The service life evaluation requirements in commences and the installation and ISTD-6200 requires service life to be evaluated ISTD-6100 and ISTD-6200 are equivalent to maintenance records on which the designated at least once each fuel cycle. If the evaluation the requirements in current TS SR 4.7.9.f.

service life is based shall be maintained as indicates that service life will be exceeded required by Specification 6.10.2.m. before the next scheduled system or plant outage, one of the following actions shall be Concurrent with the first inservice visual taken:

inspection and at least once per 18 months thereafter, the installation and maintenance (a) the snubber shall be replaced with a records for each snubber shall be reviewed to snubber for which the service life will verify that the indicated service life has not not be exceeded before the next been exceeded or will not be exceeded prior to scheduled system or plant outage the next scheduled snubber service life review. (b) technical justification shall be If the indicated service life will be exceeded documented for extending the service prior to the next scheduled snubber service life life to or beyond the next scheduled review, the snubber service life shall be system or plant outage reevaluated or the snubber shall be replaced (c) the snubber shall be reconditioned or reconditioned so as to extend its service life such that its service life will be beyond the date of the next scheduled service extended to or beyond the next life review. This reevaluation, replacement or scheduled system or plant outage reconditioning shall be indicated in the records.

LR-N11-0107

3. Please provide a copy of the document describing the snubber program for snubber examination and testing that is based on Subsection ISTD of the OM code.

Response

A copy of the draft snubber program plan is provided in Attachment 3. Upon implementation, the plan will be submitted in accordance with the requirements of ASME OM Code ISTA-3200.

References

1. Letter from Carl J. Fricker, PSEG Nuclear LLC, to U.S. Nuclear Regulatory Commission, "License Amendment Request: Changes to Snubber Surveillance Requirements," dated October 4, 2010 (ADAMS Accession No. ML102780066)

LR-N11-0107 Salem Generating Station NRC Docket Nos. 50-272 and 50-311 Changes to Snubber Surveillance Requirements Markup of Proposed Technical Specification Page Changes Revised Unit 1 TS Pages 3/4 7-28 3/4 7-29 3/4 7-30 3/4 7-31 3/4 7-32 6-16f Revised Unit 2 TS Pages 3/4 7-23 3/4 7-24 3/4 7-25 3/4 7-26 3/4 7-27 6-19g LR-N11-0107 INSERT "A" 6.8.4.m 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:

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

(ii) 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.

(iii) The program shall, as allowed by 10 CFR 50.55a(b)(3)(v), 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 in lieu of Section XI of the ASME BPV Code ISI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

(iv) 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)) subject to the limitations and modifications listed therein.

PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All 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).

4.7.9 ACTION

With one r more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, replace or restore the inoperable snubb (s) to OPERABLE status and perform an engineering evaluation per Specification 4:7-;.ge on the supported component or declare the supported system inoperable and follow appropriate ACTION statement for that system.

~-=~~-=~~~----~~

the Snubber Testing Program for examination, testing and service life monitoring of snubbers 4.7.9 Each snubber shall be demonstrated OPERABLE by performance of ~

augmented inservice inspection program, in addition to the regular Inservice Inspection Program requirements.

&. VtstJal InssectioR All snubbers shall be categorized into two groups: those accessible and those inaccessible -during reactor operation. The visl:lal inspection interval rof eaeR category of sA~J.I-be-OeteFmined based upon the criteria pro\4eJed-i.n

+able 4.7 3.

SALEM - UNIT 1 3/47-28 Amendment No. 297

PlANT SYSTEMS V §:!RVEIHANGE REQUIREME:m (GoAtinued)

b. Visual Inspection Acceptance Criteria

~ ~Aspectfens shall verify (1) that there are no vhible

~Ad~cations sf damage or impaired OPERABIllT¥, W attachments to the foundation or supporting structure are secure, and ~} in those locations where snubber movement can be-manual1y induced without disconnnect1ng the snubber, that the snubber has freedom sf mo¥emcnt

~ not frozen up. Snubbers wh~ppear inoperab1e as a result of visual i nspecthns may be deteFmiAed OPERAS LE for the purpose ,of establishing the next visua1 inspection ~nterval, providing that (1) the cause of the reject~oA is clearly established and remedied for that particu1ar snubber and for other snubbers that may be generically susceptible; and (2) the affected snubber is functionally tested in the a.s-!ouru! condition and determtn.e.d OPERAS l£ per Sp.ec1f1cat1on 4.'1.9d or U-.-9.e--a..s-ap~le-" Howe.v.er. when the :(1 ui d port of a hydralll1 c snubber is found to be uncovered, the snubber shall be declared inoperable and cannot be determined OPERABLE via functional testing for the purpose of establishing the ne~ visual inspection interval. ArlH snubbers connected to an inoperable common hydraulic fluid reservoir shall be counteQ~s inoperable snubbers. .'

e-.- Functi onal Tests Pages 3/4 7-30 through 3/4 7-32 have been deleted.

SALEM - ~IT 1 3/4 7-29 Amendmen t No. 93 MAY 1'1989

~~~

SYRVEILLJ~CE REQUIREMENTS (Continued)

~ addition to ~ula;' samp.!-e-,-s-nubbeu-w*Mch faH~e previous functional test shall be retested.during the next test pe.r-!~p.a*l!e~-beeR-i-nrt-a-1-led--i-fl-pl-ace of a-failed snubber~ then both the failed snubber (if it is repaired and i~~-ted--in-another position) and the spare snubber shall be

~ Test results of the5~bet'5 may net be--i:a~. .o't'. . . .t-he te-sampling.

~f-any snubb~elected for functional testing either fails to lockup or fails to move, ~ frozen in place, the cause w~~

evaluated and if caused by manufaoturer or design deficiency all snubbers of tl:le sam~-t~f!ect shaH-b-e-functionally tested. This testing requirement shall be independent of the requirements stated above for snubbers not meeting the functional test acceptance criteria.

For the snu.b.~.w:l~erable >> ~g-e.y.a.l-\ta-t-ien shall be perfoFmed on the components which are supported by ~he snubbe~'s). the pU~PQse of this engineering evaluation shall be to d~~ine if the components sup~d 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 se~~~

d-.- Hvdraulic 5Mbbers Functional Test. t.ceeptanee Cdte'd:a

!Rle hydraulie snubber funetisnal test shall verify thatH

~ Aetivation (restraining action} is achieved within the specified range of .,elo~ity or acceleration in both tension and compression.

2-.- &nub*b~-r-elea-5e raU. whe-r~ ~-tM-n the specified rangn in compres$ion or tension. For snubbers specifioally required to not d6splace under continuous load, the ability of the snu.9ber to ~ii~ 10al:1 without.

displacement shall be verified.

er Mechanical Snubbers Functional Acceptance Criteria

~ mechanical snub~r funetioaal-test shall ~£y that:

1-.- The force that ini-Mates free movement of the *-snub.bet'--r.o.d.-in-eithet'" tension Ot' compression is leIS than the specified maximum drag foreGN

~ Activation (restraining action) is achieved Within the specified~~ef ~ele~r acceleration in both tension and compression.

Amendment No, sa.

Effective Date:

May 12, 1Gi9 jtlN 5- ~

PLAN[! SYSTEMS SURVEI:IiLANCE REQUIREMENl'S (Go:nt!inued)

~ Snubber release rat!e, where requirea, ~ wi~in the speci~iea range in compression or tension.

For snubbers specifical1y~~~irea n~~

~nder SQn4a-n-u.o~ the-alH'~

the snubber to w;i,th.s..t.and 10aQ.....w.i-t.oo.u.t

~~ent shall be verified.

~ Snubber Service Life Monitorin2 A record of the service life of each snUbber~a-te

~ the designated ser~qce life commences and the installation and maintena~e-EeOar~s on wh4Gh-the design~~e life is based shall be maintained

~ed by Specification 6.10.2.m.

Concurrent with the first inservioe-v~~i~n

~d at least onoe per 1S months thereafter, ~

installation and maintenanoe reooras "for eaoh"snubber shall be reviewed to verify that the indioated ser~oe life has not been exceeded or will not! be exceeded prior to the next scheduled snubber service l~£e review. If the indicated service life will be ~*ceeQed prior to the next scheduled snubber service li~e review, the snubber s~rvice life shall be reevaluated or the snubber shall be replaced or reconditioned se as to extend its service lif4e-beyond the date of the

~chedul~e~~ce life review. This ree~aluation, replacement or reconditioni:ng shall be indicated in the records.

SAObEM ... UNI[! 1 3/4 7-31 Amendment No. 225 N.O¥--o 2-'I99S

TIIUlLE 4.7 3 s.mmSEB :v::r:SUM, ;ms.p.EC-T-I-eN-I-N!FERlJAL Number of Unaeoeptable Snubbers Colwm ~ Colwm ~ Cohtmn e4~

Population', 2 E£-erui ~ Rechloe ICategory Interval In-t-e-rva-l ~

o o

o o

Notes: J..-.... ~e~:isual insp~.terval for the population of a s~~sha.J.-l-b~R\-i.ned--ba-se-d.-upon---t.he-most :t"ecent inspeotion interval and the number of unaooeptable snubbers ~

during that in~ Snubbers-ma~a.ze4-, baseQ-\1}X)n their acoessibility during power operation, as aocessible or inaccessible. ~-es--ma.y-b~in-ed-&epa-~-y--o~

jOintly. !,l"his decision shall be made and dooumented before any inspection and used as the basis upon which to determine the n~

insp~-1'1.t.erval--f-or-tha*t-cat*egor-y-.

~ Interpolation between population or oategory sizes and the number O-~n~~-s&i-bl-e-. Wher-e--the-limit for

-unaooeptable snuSbers in COIWMS A, S, or C :i.s -determiaed by

i.nterpolation and iaoludes a fraotional value, the limit may be reduced to the next lower integ~

~ If the number of unacceptable snubbers is equal to or less than the numb~ ~, the next inspeet1on-!nte~~1 ~e twice the previous inter\'al but not greater than 48 months.

4-. l-f the number of unacceptable smmbers is equal to or less than the number in Column S but greater than the number ia Column A,

&he-nex-~~be the same as the current ia*terval ,

&r If the aumber of unaooeptable saubbers is equal to or greater than. the aumber ia Column OJ tme next inspection in~l be-two.-thirds of the current interval. Howe~ ~~

unacoeptable srwbbers is ~e-n'Umbe-r--*-in Ce;tumn C but greater than the number in Column S,* the next inte~~l shall be reduoed proportionally by interpolation, that is:

U--B I,

• Ie e-....-B W~i IT . next i~spestion-interval 10

• ourrent :Ln~

y .... RUmber o£ unaGseptable snubbers ~ during the previous inspection inter-Will B . number-4n Column B G- Il number in Column C

!.l"he provisions of Specification 4.0.2 are appliGable for all inspection intervals up to and including-48 mont~

ADMINISTRATIVE CONTROLS 6.8.4.1 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that SUrveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program, SALEM - UNIT 1 6-19f Amendment No. 299

PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMITING CONPITION FOR OPERATION 3.7.9 All 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 r more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, replace or restore the inoperable snub (s) to OPERABLE status and perform an engineering evaluation per Specification 4,.7.,.9G on the supported component or declare the supported system inoperable and follow appropriate ACTION statement for that system.

=--=~~-=--~~----~~

the Snubber Testing Program for examination, testing and service life monitoring of snubbers 4.7.9 Each snubber shall be demonstrated OPERABLE by performance of tAe-fe.I.I~

, '" . 'R-aGc:Jition to the re§ulaF-lRservioe Insp~faffI a-: Visllal Inspection All snubbers shall be oategori~d-iR-~hose aoeessible ana. .those inaccessible dllFinl reactor operation. The visual inspection interval for each category of snubbers shall be determined based upon the criteria provided in Table 4.7 3.

SALEM - UNIT 2 3/47-23 Amendment No, 279

PlAMT SYSTEMS

§OOVEILIANCE REQUIREMENTS (Continued)

b. ¥;sual Inspeet40n Acceptance Criteria Visual inspections shan verif;y (-l-}-th-at there are no visible indications of damage or impaired OPERABILITY. (2) attachments to the

!oundat10n or supporting structure are secure, and (3) in those locathlns where snubber movement can be' manually induced without disconnnecting the snubber, that the snubber has freedom of movement and is not frolen up. Snubbers which appear inoperable as a result o~

vtsua1 fnspections may be determined OPERABLE for the purpose of establishing the next visual inspection interval, providing that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers that may be generically .

~cept1ble; and (2) the affected snubber is functionally tested in t~

as found condition and determiRed OPERABLE per SpecificatioR 4.7.9d or 4.7.ge as applicable. However. when the fluid port of a hydraulic snubber is-tound to be unco¥ered, the snubber shall be declared inoperable and cannot be determined OPERABLE via functional testing for the purpose of establishinQ the next visual inspection ~nterval. ~

Sfl~bbers CQAAected to an inoperable common hydraulic fluid reservoir shall be counted as inoperable snubbers.

G. Functional Te~ts Pages 3/4 7-25 through 3/4 7-27 have been deleted.

SA LEM .. ltiIT 2 3/4 7*24 Amendmen t No. 68 MAY 11989

PLANT s¥s:rrns

~I:bbANGE REQUI-REM~ ~~)

--.._=-111.===__.......==============================-_======================

In addition to the ~egular sample, snubbers which failed the p.re.v-k-us funct iona.l-t.e.s-~e. -re.te-sted--d-u*r-ing--tbe--ne**t;-*-*te5-t period. If a sp~~e snubber has been install~d~~f-&

~1T~~f.a.-i-l-eG-snu-b*be-r--(-.i-f--i.t~re*d--a-n-d:

installed in anot-het posit-ien) and the spa~e snubber shall be retested. ~est resultb of these snubbers may not be included fer ene re-sampliRg.

If any s~er selected for functional testing eitheE' fails to lockup or fails to move, ~ frozen in place, ~

~~~~~~~~~~~~~.~~~~-~

snubbers of the same design subject to the same defect shall be func"tionally tested. This testing requirement shall be independent of the requirements stated abo¥e for snubbers not meeting the f~~nal test acceptance criteria.

~~.e-&n~OUR.d--i..nopar....abl-e..,.~-i-~~

shall be performed on the components which are ~rted by the snubber's). The purpose of this eng~neering evaluation shall be to determine if the components supported by the snubber(s) were aO'.. el:'sely affected by the inoperabUity of the sRubber(s) iR order to ensure that the supported component remains capable ei meeting the designed service.

d-.- R!f~Uc Snubb~Gtional T~st AAf:::!l!s.ancc Cdtnia

r:he hydraulic snubbe£" fu-ncUQnal teSi. shall ',etify that...;.

h- Activation (~estt'aining action) is acRie'Jcd .... itRiR the specified range of 'Jelocity or acceleration in both tension and ca~prcsnion.

3-.- Snubser eleed, or release ratr.~ uRers required, is-within the-specified ran~e in cQmpression or tension. F~

~-ecifi~ally required tEl flat displaec \mdcr CQntiRUQU-S load, the ability of the snupbe~ to withstand load without dhplacement shall be verified.

&r Mochanigal Snubb2r§ F\m£Sional Acceptance Criteria

be mechanical snubb~r funotional test shall verify that

~ ;fle force that initiates free movement of the snubber red in either tensioR or compressioR is less than the spec~fied maximum drag force.

3-.- Activation (restraining actian) is aSAie¥eQ Hit1:li-n-the speeified range af velaci~r aeseleration in b~

tension and compression.

SM.EM - UNIT 2. 3/4 7'2.5 Amendment No. 75 JUL 2 01S89

u SORVE ILIJlaNCE REQUIREMENTS (Continued) 3...- ~er release rate, where-r-equi-:r-ed'1 .is-wi-~n-the speoified-range in oompression or tension. For snubbers spe~if4~~~~t to displace under eontinuous

l:eacl-, the ability of th~,-,to--wi-hllstand--10ad,----wi-thou-t

~ shall be p. . eri£ie&.

f. Snubber Sen'ice Life Honitorinq A--reeord of the service 1ife of each sn\1bbe~, the date at wMch

~esignated sen-ice life commences and the ins~

maintenance records on which the designated Bervi-c~e ~s

~~s-~--requ-i-red.---by-speei£iC8:'tien 6-.10.2. m.

Coneurrent w-ith-the---fi-rst ;in-se:!!V;ice--Yi-s-~ i:nspectien and at least once per la.months thereafter, the installation and ma-intenanee-reeaMs for each snubber shall be reviewed ~

that the ~ndieated serviee life has not been exeeeded or w~

not be exceeded prior t~*t-..-scheduled-snubber service life

~. ~f the indieated sen-ice life will be exceeded prior to the-fle.x.e-s-cheduled snubber sen'ice life re-uew, the snubber serviee ~e sha:l~e ree ...aluated or the snubber sh-a-ll--be replaeed or reconditioned so as to extend its sen-ice life beyond the date of the nS*~d-"se~-i-ee-l-i..fe -re..<d.mf-. ~

ree~aluation, replacement or reconditioning shall be indicat-cd in the records.

3/4 7-26 Amendment No. 2B6 lffi.¥--4~

~~

SNUBBER:--¥r~SPECT!O~

Number of Unacceptable Snubbers Column ~ Column '!!fo..h Column e46 pop't11atl:i:on1.-2 Extend Repeat Reduce

,tGat-es'Si:'Y

_~ __---a.-'_-""'-';'-________ ~'''''-W/-iIIIiI" Intef.'VaJ. Interval

_____'__ '.IIoIt-___________-_.,..... _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Iatef.'Val o

G Q

0-Notes; ~ ~he next visual 1nspe~~n-inter\'al for the population of a snubber category shall be determined based-upen-Ghe-mo~t inspection interval and the number of unacoeptable snubbers &ound during ~t inteJ?Tal. Snubb~e--G&t-eS~d-, ~pon Ghei~l:tty w:t'-ing-power epe-r-a-t:4oa-, a-s-ae*ees-s-ibl-e-or

!n~ !I!he&~i&s-may-be-exam.-i-ned-&epar-a-t.el-y-Gr jointly. This decision shall be made and doeum~~any iaspection and used as the basis upon which tC,determine the n~

iaspection interval for that category.

~ Interpolation between populaticn or category sizes and the number of-unaooeptable-.. snubbers is permissible. Where the limit for unaooeptable---enubbel'S--i-n-Cel-umne At B,--sr C :is determined b-y interpola-tMm--anQ insl~-a-ct.i-on.a.J.-...va-lue-, the li~

v

~ext lower :t.nt.e~

~ If the number of unacceptable snubbers ~ to or less thaR the number i~ext iRspe~R iRterval may be twi-ee the previous inter\ql but not greater than 48 months.

4-.- If the Rumber of unacceptable snubbers is equal to or less than the Dumber 11'1 Column B bu-t-g.rea-ter than the n~-R-GoJ,uma A-,

the Rext inspection-i~er\'al shall be the same as the current interval.

5-r I-f-the-numb~e-ptable snubbers is equal to or greater than the number in Column 0, the aext iaspectioa iaterval shall

~ of the*-Gu*rrent :t.nterval. However, i-f the number e unacseptab~e GRubbers is less than the DUmber in Column C aut greater than the number in Column S,' the next inter\ral shall be reQuQed propot'tionally by interpolation, that iSI It . Ie G------B where: ~

• Bem; inspe.gt.;i.c;ra-~

to

• current inspeo*t*;i.on--.inte.r.v.a.l y ... Rumber of u:aacceptable snubbers found during the previous :t.nspection inter\ql B n~B C number in Column C The provisions of Specification 4.0.2 are applicable for all inspeotion intsr\'als up to and including-4S-months~

ADMINISTRATIVE CONTROLS 6.8.4.1 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

SALEM - UN IT 2 6-19g Amendment No. 282 LR-N11-0107 Salem Generating Station NRC Docket Nos. 50-272 and 50-311 Draft Snubber Examination and Testing Program Plan

Snubber Examination and Testing Program Plan Draft Salem Generating Station

1.0 General

1.1 In order to ensure the required operability of all safety related snubbers for both Units 1&2 during a seismic or other event, initiating dynamic loads, the inspection and testing of these snubbers shall be implemented and performed in accordance with the requirements of PSEG SH.RA-ST.ZZ-0105(Q), Snubber Examination and Testing.

1.2 The Snubber program, as defined within SH.RA-ST.ZZ-0105(Q), establishes visual examination, functional testing and service life monitoring requirements, pertaining to mechanical and hydraulic safety related snubbers.

1.3 The examination boundaries shall include the snubber assembly from pin to pin inclusive. Coordination with the ISI program owner will be required to complete the surveillance requirements for piping and structural attachments. Integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of the ASME Code Section XI, Article IWF-5200(c) and IWF-5300(c) within the ISI program.

1.4 The Snubber Program described in SH.RA-ST.ZZ-0105(Q) adheres to the requirements of the ASME OM Code, Subsection ISTD, 2004 Edition, as allowed by 10CFR50.55a(b)(3)(v) in lieu of ASME Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b).

1.5 PSEG Service Life Monitoring Procedure, ER-AA-330-011, in conjunction with SH.RA-ST.ZZ-0105(Q) provides for Snubber Service Life Monitoring for Hydraulic and Mechanical Snubbers which adheres to the requirements of ISTD-6000.

2.0 Examination, Testing and Service Life Monitoring Requirements:

2.1 Visual Examinations and Functional Testing shall be performed to the extent specified within SH.RA-ST.ZZ-0105(Q).

2.2 Snubbers are grouped into DTPGs by design type, in accordance with ISTD-5252 for testing purposes. Snubbers shall be tested using the 10% sample plan. The DTPG at Salem Station includes all Lisega hydraulic snubbers.

Unit 1 Unit 2 Snubber Design Type DTPG Includes DTPG Includes Lisega L All Sizes L All Sizes 2.3 The service life of all snubbers shall be monitored and snubbers replaced or reconditioned as required to ensure that the service life is not exceeded between Snubber Examination and Testing Program Plan Draft Salem Generating Station surveillance inspections, during a period when the snubber is required to be operable. The replacement or reconditioning shall be documented and records retained in accordance with Salem Procedures.

3.0 Examination and Testing Methods:

3.1 Visual Examinations shall be performed by qualified individuals using the VT-3 method as described in ASME Section XI, IWA-2213. Visual Examinations and Functional Testing shall be performed to verify the requirements specified within SH.RA-ST.ZZ-0105(Q), ER-AA-330-004 and ER-AA-330-010 are met in accordance with ISTD.

4.0 Examination and Testing Frequency:

4.1 Visual Examinations and Functional Testing shall be performed at the frequency specified within SH.RA-ST.ZZ-0105(Q). Salem Station currently performs accessible and inaccessible snubber visual examinations during alternating refueling outages, which results in approximately one half of the snubber population being examined during each refueling outage.

4.2 Visual (VT-3) 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.

4.3 Functional testing requirements for new installations or spares shall be equal to or more stringent than that specified within SH.RA-ST.ZZ-0105(Q).

5.0 Examination, Testing and Service Life Monitoring Evaluation:

5.1 Snubbers that do not appear to conform to the Visual Examination requirements of SH.RA-ST.ZZ-0105(Q) and ER-AA-330-004, 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 are 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 SH.RA-ST.ZZ-0105(Q) and NC.DE-TS.ZZ-3067 shall be evaluated to determine the cause of the failure and appropriate corrective action taken.

5.4 The service life of a snubber is evaluated using manufacturing input and engineering information gained through consideration of the snubber service conditions and inservice functional test results. A service life monitoring program is Snubber Examination and Testing Program Plan Draft Salem Generating Station included in SH.RA-ST.ZZ-0105(Q) and Service Life Monitoring Procedure Snubber ER-AA-330-011.

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 XI.

7.0 Scheduling

7.1 The Visual Examinations and Functional Testing schedules shall be established, tracked and maintained within SH.RA-ST.ZZ-0105(Q) by the ISI Snubber Coordinator.

7.2 The ISI Snubber Coordinator shall identify and track expanded or additional testing and/or examinations as required by SH.RA-ST.ZZ-0105(Q) and 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.

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

8.3 Records of the service life of all hydraulic and mechanical snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records will be maintained.