ML11270A051

Connecticut, Inc., License Amendment Request to Revise Snubber Surveillance Requirements

ML11270A051
Person / Time
Site:	Millstone
Issue date:	09/21/2011
From:	Price J Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
11-354
Download: ML11270A051 (56)

Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, Virginia 23060om inio Web Address: www.dom.com September 21, 2011 U.S. Nuclear Regulatory Commission Serial No.11-354 Attention: Document Control Desk NSSL/MLC RO Washington, DC 20555 Docket No.

50-336 License No.

DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 LICENSE AMENDMENT REQUEST TO REVISE SNUBBER SURVEILLANCE REQUIREMENTS In accordance with the provisions of 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) is submitting a license amendment request to revise Technical Specification (TS) 3/4.7.8, "Snubbers," for Millstone Power Station Unit 2 (MPS2). The proposed change would revise the TS surveillance requirements for snubbers to conform to the revised MPS2 inservice inspection (ISI) program. to this letter describes the proposed changes and provides justification for the changes. Attachment 2 provides the marked-up TS pages.

Marked-up TS Bases pages are provided in Attachment 3 for information only. contains a detailed comparison of the current surveillance requirements in TS 4.7.8 to the revised ISI program requirements and justification of the changes. Attachment 5 provides a copy of the MPS2 snubber program.

The proposed amendment does not involve a Significant Hazards Consideration under the standards set forth in 10 CFR 50.92.

The Facility Safety Review Committee has reviewed and concurred with the determinations herein.

Issuance of this amendment is requested by September 21, 2012. Once approved, the amendment will be implemented within 60 days.

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the State of Connecticut.

Serial No: 11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers Page 2 of 3 Should you have any questions in regard to this submittal, please contact Ms.

Wanda Craft at (804) 273-4687.

Sincerely, VICKI L. HULL J. A Notary Public Vic Pre ident - Nuclear Engineering Commonwealth of Virginia 140542 My Commission Expires May 31, 2014 COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. Alan Price, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this

• _ay

,of`,4ý,4 2011.

My Commission Expires:

3

/

ýNotarý Public Attachments:

1. Evaluation of Proposed License Amendment

2. Marked-Up Technical Specification Pages

3. Marked-Up Technical Specification Bases Pages

4. Comparison of Current TS Requirements to Revised ISI Program Requirements

5. U2-24-SNUB-BAP01, Snubber Examination, Testing, and Service Life.

Monitoring Program Plan Commitments made in this letter: None

Serial No: 11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission Region I Regional Administrator 475 Allendale Road King of Prussia, PA 19406-1415 C. J. Sanders NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08B3 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.11-354 Docket No. 50-336 ATTACHMENT 1 EVALUATION OF PROPOSED LICENSE AMENDMENT DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 1 of 7 EVALUATION OF PROPOSED LICENSE AMENDMENT

1.0 INTRODUCTION

In accordance with the provisions of 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) is submitting a license amendment request to revise Technical Specification (TS) 3/4.7.8, "Snubbers," for Millstone Power Station Unit 2 (MPS2).

The proposed change would revise the TS surveillance requirements for snubbers to conform to the revised MPS2 inservice inspection (ISI) program.

2.0 PROPOSED CHANGE

S The proposed changes to the MPS2 TSs are summarized below:

" Reference to Specification 4.7.8.d in TS ACTION 3.7.8 would be replaced with reference to Specification 4.7.8.

" TS Surveillance Requirement (SR) 4.7.8 would be revised to remove specific surveillance requirements for demonstrating snubber operability. The current requirements would be replaced by a reference to the "Snubber Examination, Testing, and Service Life Monitoring Program."

" A new TS Section 6.28, "Snubber Examination, Testing, and Service Life Monitoring Program," would be added to the Administrative Controls section (Section 6.0) of the TSs to provide a description of the snubber program.

Mark-ups of the proposed TS pages are provided in Attachment 2. TS Bases markups are provided in Attachment 3 for information only. A comparison of the current SR 4.7.8 requirements to the revised ISI program requirements and justification of the changes are provided in Attachment 4. Attachment 5 contains the Snubber Examination, Testing, and Service Life Monitoring Program. Implementation of this program will occur coincident with implementation of the approved license amendment.

3.0 BACKGROUND

MPS2 is currently in the fourth 10-year ISI interval. The fourth 10-year ISI interval at MPS2 began on April 1, 2010 (References 8.1 and 8.2). Currently, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.8 and the requirements contained in American Society of Mechanical Engineers

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 2 of 7 (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code),

2004 Edition. Conformance to both the TSs and the Code is currently required.

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

For MPS2, the examination and testing of snubbers is performed in accordance with the optional criteria of 10 CFR 50.55a(b)(3)(v). This permits the 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 (BPV Code), Section Xl, Articles IWF-5200(a) and (b) and IWF-5300(a) and (b). 10 CFR 50.55a(b)(3)(v) also requires that when using this alternative, preservice and inservice examination of snubbers must be performed using the VT-3 method specified in IWA-2213.

The purpose of this amendment request is to remove the specific surveillance requirements for demonstrating snubber operability from the TS since the ISI program has been revised to include the requirements of the OM Code Subsection ISTD in the Snubber Examination, Testing and Service Life Monitoring Program. As such, the proposed changes to TS 3/4.7.8 are necessary to conform the TSs to the revised ISI program.

4.0 TECHNICAL ANALYSIS

Licensees are required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v) to perform the ISI and testing of snubbers in accordance with ASME BPV Code, Section Xl or the 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). 10 CFR 50.55a(a)(3) states that licensees may use alternatives to the requirements of 10 CFR 50.55a(g) when authorized by the NRC if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

As noted in Regulatory Issue Summary 2010-06 (Reference 8.3), licensees have the option to control the ASME Code-required ISI and testing of snubbers through their TSs. For plants using their TSs 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

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 3 of 7 TSs, the licensee shall apply to the Commission for amendment of the TSs to conform the TSs to the revised program. 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 TSs remain consistent with the new code of record or NRC-approved alternatives used in lieu of the Code requirernents. The TSs governing the snubber ISI and testing program do not eliminate the 10 CFR 50.55a requirements to update the program at 120-month intervals, in accordance with 10 CFR 50.55a(g)(4), or requirements to request and receive NRC authorization for alternatives to the Code requirements, when appropriate.

The proposed change replaces the specific TS requirements for snubber examination, testing and service life monitoring with a reference to the Snubber Examination, Testing and Service Life Monitoring Program, thereby ensuring the TSs are consistent with the ISI program.

Snubbers will continue to be demonstrated OPERABLE by performance of the Snubber Examination, Testing and Service Life Monitoring Program. This program will be required to be maintained in compliance with 10 CFR 50.55a per the new proposed TS 6.28. The program for ISI and testing of snubbers in accordance with ASME BPV Code, Section Xl or the OM Code and the applicable addenda as required by 10 CFR 50.55a(g) is required to include evaluation of supported components/systems when snubbers are found to be unacceptable.

The proposed change to TS ACTION 3.7.8 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.8.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The NRC has provided standards for determining whether a significant hazards consideration (SHC) exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated; or 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.

DNC has evaluated whether or not a significant hazards consideration is involved with the proposed change. A discussion of these standards as they relate to this change request is provided below.

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 4 of 7 Criterion 1 Will operation of the facility in accordance with 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 4.7.8 to conform the TSs to the revised ISI program for snubbers. Snubber examination, testing and service life monitoring will continue to 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).

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 3.7.8 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.8. Therefore, 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. The consequences of accidents previously evaluated are not significantly increased.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Criterion 2 Will operation of the facility in accordance with this 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 change 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.

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 5 of 7 Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

Criterion 3 Will operation of the facility in accordance with this proposed change involve a significant reduction in the 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) 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). 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 3.7.8 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.8.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Conclusion Based on the above, DNC concludes that the proposed changes do not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

5.2 Applicable Regulatory Requirements/Criteria 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 TSs of the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TSs to conform the TSs to the revised ISI program.

The proposed change amends the TS surveillance requirements to conform the TS to the revised ISI 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).

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 6 of 7 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.

6.0 ENVIRONMENTAL CONSIDERATION

DNC has determined that the proposed amendment would change requirements with respect to installation or use of a facility component located within the restricted area, as defined by 10 CFR 20, or an inspection or surveillance requirement. DNC has evaluated the proposed amendment and has determined that it 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 off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment 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 to be prepared in connection with the proposed amendment.

7.0 PRECEDENTS The changes to TS 3/4.7.8 are similar to changes submitted by Public Service Electric and Gas (PSEG) Nuclear, LLC for Salem Generating Station, Units 1 and 2. The applicable references for these changes are provided below:

7.1 PSEG Letter LR-N10-0363, License Amendment Request: Changes to Snubber Surveillance Requirements [for Salem Units 1/2], dated October 4, 2010 (Accession No. ML102780066).

7.2 PSEG Letter LR-N 11-0107, 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).

7.3 PSEG Letter LR-N1 1-0151, 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 ML111430636)

Serial No.11-354 Docket No. 50-336 Revision to TS 3/4.7.8, Snubbers, Page 7 of 7 Three minor differences were noted between DNC's license amendment request and the request submitted by PSEG. These differences are summarized below:

" MPS2 SR 4.7.8 includes a surveillance requirement (i.e., 4.7.8.a) entitled "Inspection Types." This requirement is not contained in the Salem Units 1/2 TSs.

In accordance with MPS2 SR 4.7.8.d, for each snubber that does not meet the test acceptance criteria, an additional 5% of that type of snubber shall be tested. For Salem Units 1/2 SR 4.7.9.c, an additional 10% is required. As noted in Attachment 4 of this submittal, the revised ISI program requirement for testing failures of MPS2 snubbers is equivalent to those of the current TS.

For Salem Units 1/2, SR 4.7.9.c requires retest, during the next test period, of failed snubbers that are repaired and installed in another position. MPS2 SR 4.7.8.d does not contain this requirement and it is not required by ISTD-5500.

8.0 REFERENCES

8.1 Millstone Power Station Unit 2, Fourth 10-Year Interval Inservice Inspection Program and Associated Proposed Alternatives and Relief Requests, July 29, 2010 (Accession No. ML102580204).

8.2 Millstone Power Station Unit 2, Fourth 10-Year Interval Inservice Inspection Program, August 5, 2010 (Accession No. ML102220527).

8.3 NRC Regulatory Issue Summary 2010-06, "Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)," June 1, 2010 (Accession No. ML101310338).

Serial No.11-354 Docket No. 50-336 ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

PLANT SYSTEMS 3/4.7.8 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.8 All snubbers shall be OPERABLE. The only snubbers excluded from the requirements 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.

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 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 4.7.84 on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for the system.

SURVEILLANCE REQUIREMENTS Snubber Examination, Testing, and Service Life Monitoring Program Each snubber shall be demonstrated OPERABLE by performance of the g

4.7.8 augmenica inscr;icc inspocuon program ana inc rc~uircmcnts CT inc insor.' icc inspccuon Program.i 1-a-

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J snuttcrs are catcgor-zcd as ;nacccssitl or accossmiti during rceactor opcration.

Each of thcsc cotcgorics (inacccssiblc and acccssiblc) may bc inspcctcd in~dcpcndcntly according to thc schcdulc dctcrmincd by Tablc 1.7 3. Thc visual inspcction intcr,'al for cach typc of snuibbcr shall bc dctcrrniincd bascd upon thc critcria providcd in T;ablc 1.7 3 and thc first inspcction intcrval dctcrmincd Using this critcria shall bec bascd upon thc prcvious inspcction intcr~aI as established by thc rcguircmcents in cffcct bcfcarc Amcndmcent 1-60.

Visual inspcctions shall vcrib' that (1) thc snubbcr-has no ;'isiblc indications ot damage or impairoed OPERXBILITY*, (2) attachmcnts to the foundation or supporinig structurce arc functional, and (3) fastonors for-thc _attach~mcnt ofth snubbor-to thc componcnt and to the snubber-anchor-agc arc funcetional. Snubbcrs which apcrio

-able as a rosgult of visual inspcctions shall bc classificd as unfacccptablc10 anmaeb classificd acccptablc for thc puqzosc of establishing thc ncxt visual inspcctionfl intcrOal, prov~idcd that (1) thc causc ofthc roejection is clcarly, cstablishcd and r-emcdied fo-1r t-hat-p-art4icular-Snubber-and feRr-othcr snubbc;rs c

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-UNIT 2 3/47-21 MILLSTONE Amendment No. 44, 44-, 5-2, 96,44-98, 1-60, *,04

March 21, 200-0

ýT TD1Tz'TT AbJTGCE REQUI1R*FMENTSg that may bc gcncricalily susccptible; and (2) the affcctcd snubbcr is fufnctionally tcstcd in the as found condition and dctcincd OPER. BLE. pcr Specific.tion 4.7.8.c or 4.7.8.f, as applicabic. All snubbcrs9 foutnd conncctcd to an inoapcrablc common hydr.aulic fluid rcscr..ir shall bc countcd as u.naccptablc for detcn..ining thc nc.xt inspcction intcr.al. A rcvic--1 an c.al shall bce pcrfoarcd and documcntcd to justify, continued operation 'with an unacccptable snubbcr. if continuced opcration cannot bc justificd, thc snubbcr shall be dcclarcd 0c zrv lc and the ;;u+f"4, mrcquircmcnis Snuil.c met.

swabbef4;est At lcast oncee per eighteen (18) months dur-ing shutdown, arpentive sample (10; of the total of each type of snubber, mnechanical and hydraulic, in uisc in the plant) shall be tested either-in place or-in a benceh test. For-each snutbber-thast doeps not meet the test aecpnc crteia of Specification 4.7.8. or I 78f, -As applicable, an additioanal 5% f-thaet type of snubbcr shall be tcsted.

Testing shall continue until no additional inoperable snubbers arc fo~und 'within -a

-V THIS PAGE INTENTIONALLY LEFT BLANK sample or until all snubbers have bcen testcd. Thne representative sample scicctca forp testing shall include the various configurations, and the range of sizean Yaac~

of snutbbers.-

Snubbers identified as "Especially Difficult to Rcmove" or in "H igh Radiation Zones During Shutdo'wn" shall also be included in the representative samaple.1 in addition to the regular sample, in locations 'where snubbers had failed h preios test due to opcr-ationial or environmental conditions (exceessive vibration,

'water -hammer, high r-adiationi, extremfe heat or-humidity, etc.), the snubbers curently ~nstalled in these lcations shall be tested during the next test pcriod.

Test results of these snubbers may net be included for the resampling. All r-oplaeoffiew saiu-bbers-s;hall have been tested prior. to* ;et+*11*+;,

t I

Permanent or-other-exemptionts from funcetional testinig for-individual snubbers in these categories may be gr-anted by the Commission only, if a justifiable basis foar eepini preese ed.

Amendment No. 4-4-, 44, -52, 96, 44-8, 435,460,2-44 MILLSTONE - UNIT 2 3/4 7-22

August-R7,l1999, if any snubbor selecced for testing zither fails to lock up or-fails to Move (i.e.,

frozen in place), the ceausca wlill bc elvaluated and if eauscd by manufactur-er-design deficiency, all snubbers of the same design subject to the same defect shall be tested regardless of location or difficuK'y or-rcmoval. This testing rcquircemcnt shall bc indcpcndcnt of the r-equircemcnts stated above for-snubbcrs noet mcctinig thc test accptnc critra For thc snubber(s) found inopcrablc, an cngineering evaluation shall bc per-foffld on the components which are suppoi~ed by the snubber-(s). The pupposc of this eniering evaluation shall be to dctefmine if the eomponcnts suppoaied by the snubber-p (s) were adv~er-sely affceted by the inoper-ability of the snubber (s) int order-to ensure that the suppon~ed component r-emains eapable of mneeting the designed sen~ieet THIS PAGE INTENTIONALLY LEFT BLANK T"he hydraulc snubber functional test shall ver.ify. that:

4-.

Aefvftian(restraining aetion) is aehieved within the speeified range of

-vJoeity or acceler-ation in both ftension and eompressin Snubber bleed, or-release rate, where required, is within the specificd ranige azrrsin or tznscn-F-

meiimia snoe-Iantea I-s~

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The mechanical snubber-tunetional test Shall vcrif-' that:

4-.

The force that initiates frFee movement of the snubber-rod in either-tension or ompesion is less than the specified maximumn dr-ag foarce.

1Xetivution (restraining action) is achieved within the specified r-ange ot.

.Joeeity or-aceeler-ation in both tension and compressiont.

t-A reeord of the serniee life of eaceh sntut sc.ic life commences and the installat designated sermiee life is based shall be Assurance Program Topicl Repot.

~ber, he d ion and-fn ai e at which the desigrnal ntenance records on w, as rqired by Qutalit' hieh the f

41-lat t

SMechanical snubber-functional test accep installation of sniubber-testing equipment tance criter-ia shall become effee Nve UPOR UT fief ater-T an Amendment No. 96, 48, 460, 239 MILLSTONE - UNIT 2 3/4 7-22a

jue 16, 992 tUREILLNC.tE QUtEMEtT (C.ntinued)

Coneunoent with the firs9t inget-viee N'iqual inspeetian and at. lea~t enee por1 months ther-eafter, the inistallation and mnaintenanee reeards foar eaeh snubber 9hai be rz~iewe'd to w'rify, that the indieated gen~iee iifc hag not been exeeded or "wiii not be eoxocoded prier to the next sehedetled snubber sen~iee life review. If the indieeted gen'iee life wiAl be eoxocoded prior. to the next seheduled gen'iee lifc Irv.icy' Othe Sniubber gcrIc life

.hall be reevaluated or the snubber shall bo-.

rolao or reeonditioned so as to extend ifU gcr.'ie life beyand the date of the next seheduled ger.'iee life ro~iew. Thig reeNvaluation, replaeement or r-eeonditiorning shall be indieated in the reeard-s-THIS PAGE INTENTIONALLY LEFT BLANKI Amendment No. 96, 44-8, 4-60 AV4ILLSTONE - UNIT 2 3/4 7-22b

lFor Information Onlyl September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-23 Amendment No. 118

I For Information Onlyl September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-24 Amendment No. 118

I For Information Only September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-25 Amendment No. 118

I For Information Only September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-26 Amendment No. 118

I For Information Only September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-27 Amendment No. 118

I For Information Only September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-28 Amendment No. 118

I For information Only September 1, 1987 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-29 Amendment No. 118

For Information Only THIS PAGE INTENTIONALLY LEFT BLANK September 1, 1987 MILLSTONE - UNIT 2 3/4 7-30 Amendment No. 118

For Information OnlyA August 2, 1984 THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 2 3/4 7-31 Amendment No. 96

SNUBBER VISUAL INSPECTION INTERVALA NITM.4RET? ON UJNA C-CEPTA1IT.SNIRU Ca H0zrn Popultdeion OF-Getegwey (Notes 1-and-2-)

Extend interva (Naes e3-amitd*

Repeat intef4 (Nates 4 and-6*

Reduce Intena 4-9

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4-5-4

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44 Note-2L

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~Nefe-6!

Th nxtviua ispctonfo asnbbr oplaio o cteor iz~e shall be determined based-pntepeiu isectiont interval -and the1 umbe of unaceptable snubbers fon uigthat inten'al. Snubbers mayh categried bae poFhi i+.,,..,.,,.YU, iU W

1 4 hi

,U 1

11

• ,.L,,.,+,,,..,.,...L~

t,,

u1-

.LjIp

,Yi,1" nJ yt~iL Wd~nn T'=*'*"~~on aq' aees

i deemie by; intemolation.

efr-ean is twice the prvou nervlbt insetot gretertan 18r moths.etea

'f-telanumnber fLaeepa snuberses eq alnoorls thante n umerinCoumr bu t

greate thanle the nmber in er Coum Ar the nalexat isetiohne ra sh~allAA be the sam ffas ithgepreiu inteldst rval. 6i.-u fuaeetbesubsa if the number of unaeeept!abl nbesi q to or-greate than the number-in Column C, the next inispection initerval shallb betotid ftepeiu nevl oeeif the number of unaeeptaie snubbers iso r

less than the number in Column C u nefr+tmtemme-i bu veater Column e

next interval sall be educed popodio.lly by iterpolaion,.tha is,.th prev~ious interval shall be reducedyafctrta is onie third_ of the ratio of th.e difrneiewe the number-of untacceptable snubbers found durn thAe prvosneval and the number in Column B to the diffcr-ence in the numfbers in. I1 I

1 +

I I° A*

• 1 "me nro,rzvmins ci-Srmciiimntin IALI2 are anrriicntizi for all insneetion irnicrvais un" to ann ineluing 4M montins.

r-~--------

I-

.September-18, 2008 ADMINISTRATIVE CONTROLS 6.27 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM (Continued)

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of Surveillance Requirement 4.0.2 are applicable to the frequencies for assessing CRE habitability and determining CRE unfiltered inleakage as required by paragraph c.

6.28 Snubber Examination, Testing, and Service Life Monitoring Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR50.55a inservice inspection (ISI) requirements for supports. The program shall be in accordance with the following:

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

b. 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 Vessel (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 its limitations and modifications, and subject to Commission approval.

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

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

Amendment No. 94&

MILLSTONE - UNIT 2 6-33

Serial No.11-354 Docket No. 50-336 ATTACHMENT 3 MARKED-UP TECHNICAL SPECIFICATION BASES PAGES For Information Only DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

r For Information Only PLANT SYSTEMS BASES 3/4.7.7 DELETED

_r 3/4.7.8 SNUBBERS All snubbers are required 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.

A list of indkidvidal sanubbers with dctaiicd infe~atien of snubbeF location and size and ot system afcted shall be available at the plant in aeeordanco with Section 50.71(e) of 10 GFR Pa1

50. The aeeessibility of each snubber shall be determined and approvo~d by the Plant Operations Rcvcw omm~cc Th dccn~natonshall be based upon the existing r-adiation leovob and the expeeted time to pcrfcm a visual inzco in aeh snubbemeloation as well as other-faefers a~sseiated with aeeessibility during pln o aiens (e.g., tcmperaturc, atmespher-e, location, ete.), and the

..... n.

nR:daIn fA..--

-R-I-44 1y Guide 8.8 and 8..10. The addition or-deletion of an hydrautlie or meehanie snubber shall be made in accoerdancc with Seetion 50.59 of 10 CFR Pa~

The Nvisual inspeetien frcgeueney is based uipon mainiig a istant levcel of snubbcr pr-eteetion to systems. Ther-eferc, the required intspeetion intcn'A] vAr-ie inyersely with h obacr.'cd snubber-failurc3 and ig determinced by the number. of nloper-able snUbber-found dur-ing ani~ctiet. inspeetions perfeomed befierc that interval has elapsed mfay, be used as a ncw r.rcfc.w--ncft point to detemiine the next inspeetion. HolweNvcr, the results of stieh ear-!) inspeetions per-fcnmd before the original required time interval has elapsed (noeminal timce less 25%) may not be used to lenethen the reauired insigeetion interval. Anyv insncction whose results reauire a-i i

i sheAer insigeetten mtnfena! will override the iprevioug seheduic.

MILLSTONE - UNIT 2 B 3/4 7-5 Amendment No. +4, 5, 96, 4-16, 2Q02,

I For Information Only March 31, 2000 PLANT SYSTEMS BASES When the cause of the r-ejectiont ofa snubber-is clear-ly established and r-emfedied for that snubb-er -And for-any other snubbers that ma" be generically susceptible, that snufbber mafy be exmpted from being counted as inoeper-able. Generically susceptible sniubber-s arc those which are of a specific make or-model and have the same design features dir-ectly related to r-ejection of the snubber by visual inspection, or-arc simnilar-ly located or-exposed to the same environmffentlW conditions such as temoper-ature, radiation, and vibration.

When a snubber is foeund inoper-able, an engnerig evaluation is perfoFmed, in addition to the determinetion of the snubber. mode of failure, in order-to dete'-fffine. if any safety r-elated componient or system has been adversely affected by the inoper-ability of the snubber.

The engineering ev~aluation shall detennine whether-or not the snubber-mode of failure has imnpar~ed a significant effect or-degr-adationt ont the suppod~ed compontent or-system.

To proavide assur-ance of snubber r-eliability, a repr-esentative sample of the installed snubber-s wi ll be tested dur-ing plant shutdowns at eighteen (18) month intcr.'als. Obsred, failures of these sample snubbers shall require testing of additional units.

H' dr-aulic snubbers and mtechanical! snubber-s may each be treated as a different entity, for the above sur.'eillanec programs.

The ser~ice life of a snubber is ev~aluiated v~ia manufacturer input and infonnationi through.

consider-ation of the snubber sen'iee conditions and associated installation and mnainitenance records (niewly installed snubber-, seal replaced, spr-ing r-eplaced, in high r-adiation area, in high temperature areat, etc.... ). The r-equirement to monitor the snubber-scn~ice life is included to enisur-e that the snubbers per-iodically, undergo a per-fonnanee ev~aluation in v~iew of their agean operating conditions. These records will provide statistical bases for futiure contsiderationo snubber-ser~icc life. The r-equirements for the maintcnancc of recor-ds and the snubber scr.'ice life rev~iew are notf intended to affect plant operation. 3/4.7.9 DELETED MILLSTONE - UNIT 2 B 3/4 7-6 Amendment No. 4-t-, 5, 96,

"-1-8, 4--94, 244

Serial No.11-354 Docket No. 50-336 ATTACHMENT 4 COMPARISON OF CURRENT TS REQUIREMENTS TO REVISED ISI PROGRAM REQUIREMENTS DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.11-354 Docket No. 50-336, Page 1 of 10 Millstone Power Station Unit 2 (MPS2)

Comparison of Current TS Requirements to Revised ISI Program Requirements Current TS Surveillance Revised ISI Program Requirement Justification for Change Requirement 4.7.8.a Inspection Types ISTD-5252 states that the total snubber population At MPS2, snubbers are grouped into DTPGs may be considered one Defined Test Plan Group by design type in accordance with ISTD-5252.

As used in this specification, "type of (DTPG), or alternatively, differences in design, Specifically, hydraulic snubbers are considered snubber" shall mean snubbers of the application, size, or type may be considered in one DTPG while mechanical snubbers are same design and manufacturer, establishing DTPGs. See exception in ISTD-5253.

another DTPG. This snubber grouping is the irrespective of capacity.

same as that required by Surveillance Requirement (SR) 4.7.8.a.

4.7.8.b Visual Inspection Snubbers are categorized as ISTD-4220(a) requires all snubbers to be categorized Table ISTD-4252-1 is identical to Table 4.7-3 inaccessible or accessible during as one population for examination, or alternatively, to for population/category sizes less than or equal reactor operation. Each of these categorize them individually as accessible or to 300.

categories (inaccessible and inaccessible. The categories of accessible and accessible) may be inspected inaccessible snubbers shall be considered separately Use of ISTD-4200 for snubber inservice independently according to the for examination, examination in lieu of current SR 4.7.8.b does schedule determined by Table 4.7-3.

not change the number of snubbers required to The visual inspection interval for each ISTD-4220(b) requires the decision to examine the be examined or the required examination type of snubber shall be determined snubbers as one population or as separate categories intervals..

based upon the criteria provided in shall be made and documented before the scheduled Table 4.7-3 and the first inspection examination begins and shall not be changed during interval determined using this criteria the examination.

shall be based upon the previous inspection interval as established by ISTD-4252(b) requires inservice examinations to be the requirements in effect before conducted in accordance with Table ISTD-4252-1.

Amendment 160.-

Note 1 to TS Table 4.7-3 states that snubber categories may be examined separately or jointly.

Serial No.11-354 Docket No. 50-336, Page 2 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.8.c Visual Inspection Acceptance Criteria Visual inspections shall 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) fasteners for the attachment of the snubber to the component and to the snubber anchorage are functional.

ISTD-4210 states that inservice examination shall be a visual examination to identify physical damage, leakage, corrosion, or degradation that may have been caused by environmental exposure or operating conditions; and external characteristics that may indicate operational readiness of the snubber shall be examined.

ISTD-4231 requires that examinations shall include observations for the following and the 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 shall be free of defects that may be generic to particular designs as may be detected by visual examination.

ASME Code Section Xl, 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.

10 CFR 50.55a(b)(3)(v) allows the use of subsection ISTD for inservice examination requirements. Preservice and inservice examinations are required to be performed using the VT-3 visual examination method described in IWA-2213.

The revised inservice inspection (ISI) program requirements for inservice examination do not differ significantly from the visual inspection acceptance criteria in SR 4.7.8.c.

Serial No.11-354 Docket No. 50-336, Page 3 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance

____,______________________,j Revised iSIProgram Requirement Justification for Chane Requirement Rv, S

C 4.7.8.c (continued)

Snubbers which appear inoperable as a result of visual inspections shall be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specification 4.7.8.e or 4.7.8.f, as applicable. All snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the ACTION requirements shall be met ISTD-4240 permits snubbers classified as unacceptable during inservice examination to be tested in accordance with the requirements of ISTD-5210. Results that satisfy the operational readiness test criteria of ISTD-5210 shall be used to accept the snubber, provided the test demonstrates that the unacceptable condition did not affect operational readiness.

ISTD-4233 requires that fluid supply or content for hydraulic snubbers shall be observed. If the fluid is less than the minimum amount, the installation shall be identified as unacceptable, unless a test establishes that the performance of the snubber is within specified limits. Tests shall be performed in accordance with ISTD-5210(b) and ISTD-5210(c). The initial test shall start with the piston at the as-found setting and be performed in the extension (tension) 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.

Additional action regarding the examination interval shall be taken as indicated in Table ISTD-4252-1.

The revised ISI program requirements for evaluation and corrective action for inservice examination are equivalent to those of current SR 4.7.8.c for visual examination acceptance criteria.

Serial No.11-354 Docket No. 50-336, Page 4 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance Revised ISI Program Requirement Justification for Change Requirement 4.7.8.d Snubber Tests At least once per eighteen (18) months during shutdown, a representative sample (10% of the total of each type of snubber, mechanical and hydraulic, in use in the plant) shall be tested either in place or in a bench test.

ISTD-5200 requires snubber operational readiness testing to be performed each fuel cycle. Tests are required to be in accordance with a specified sampling plan. Testing shall be performed during normal system operation, or during system or plant outages.

ISTD-5240 states that snubber testing may begin no earlier than 60 days before a scheduled refueling outage.

ISTD-5261 requires snubbers of each Defined Test Plan Group (DTPG) to be tested using either:

(a) the 10% testing sample plan (b) the 37 testing sample plan ISTD-5223 and ISTD-5224 permit snubbers to be tested in their installed location or in a bench test.

The frequency of snubber testing in the revised program is unchanged from the frequency specified in current SR 4.7.8.d.

The revised program provides greater flexibility in permitting testing to be performed during modes other than shutdown. However, as noted in Generic Letter 91-04:

The staff concludes that the TS need not restrict surveillances as only being performed during shutdown. Nevertheless, safety dictates that when refueling interval surveillances are performed during power operation, licensees give proper regard for their effect on the safe operation of the plant. If the performance of a refueling interval surveillance during plant operation would 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.

DNC 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.

DNC plans to use the 10% sample plan for MPS2.

The initial sample size in the revised program is as large as the size specified in SR 4.7.8.d.

Serial No.11-354 Docket No. 50-336, Page 5 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS SurveillanceI eureent T

u inRevised ISI Program Requirement Justification for Change Requirement 4.7.8.d (continued)

For each snubber that does not meet the test acceptance criteria of Specification 4.7.8.e or 4.7.8.f, as applicable, an additional 5% of that type of snubber shall be tested.

Testing shall continue until no additional inoperable snubbers are found within a sample or until all snubbers have been tested.

ISTD-5271 requires snubbers that do not meet test requirements specified in ISTD-5210 or ISTD-5230 to be evaluated to determine the root cause of the failure.

ISTD-5312 requires that additional samples required by ISTD-5320 shall be at least one-half the size of the initial sample from that DTPG.

ISTD-5330 requires the snubbers of each DTPG and failure mode group (FMG) to be 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(O.1n/2)

(b) for each FMG NF 2! CF(O.1 n/2)

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

The revised ISI program requirement for testing failures is equivalent to those of the current SR 4.7.8.d

Serial No.11-354 Docket No. 50-336, Page 6 of 10 Millstone Power Station Unit 2 of Current TS Requirements to Revised ISI Program Requirements (Continued)

Comparison Current TS Surveillance Rquirement TRevised ISI Program Requirement Justification for Change Requirement 4.7.8.d (continued)

ISTD-531 1(a) requires the initial sample to include The revised program requirement for sample as practicable representation from the DTPG based composition is equivalent to the current SR The representative sample selected for on the significant features (i.e., the various designs, 4.7.8.d. The revised program requirements testing shall include the various configurations, operating environments, sizes, and continue to ensure initial sample selection is configurations, and the range of size and capacities) and based on the ratio of the number of random and representative.

capacity of snubbers. Snubbers identified snubbers of each significant feature, to the total as "Especially Difficult to Remove" or in number of snubbers in the DTPG. Initial sample "High Radiation Zones During Shutdown" selection shall be random.

shall also be included in the representative sample.

As an alternative, ISTD-531 1(b) requires the initial sample to be generally representative, as in ISTD-5311 (a) but allows the sample to be selected from those snubbers scheduled for seal replacement or other activities related to service life monitoring.

4.7.8.d (continued)

ISTD-5500 requires that snubbers placed in the The revised program requirement is equivalent same location as snubbers that failed the previous to the current SR 4.7.8.d requirement to retest In addition to the regular sample, in inservice operational readiness test shall be retested a replacement snubber installed in place of a locations where snubbers had failed the at the time of next operational readiness testing failed snubber. Retesting is required, unless previous test due to operational or unless the cause of the failure is clearly established the cause of the original failure was clearly environmental conditions (excessive and corrected.

established and corrected.

vibration, water hammer, high radiation, extreme heat or humidity, etc.), the Retests in accordance with ISTD-5500 shall not be snubbers currently installed in these considered a part of inservice operational readiness locations shall be tested during the next testing sample selection requirements of ISTD-5200, test period. Test results of these ISTD-5300, or ISTD-5400.

snubbers may not be included for the resampling. All replacement snubbers shall have been tested prior to installation.

Serial No.11-354 Docket No. 50-336, Page 7 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change 4.7.8.d (continued)

ISTD-5271 states that snubbers that do not meet test The revised program requirements for requirements specified in ISTD-5210 or ISTD-5230 manufacturer or design deficiencies require If any snubber selected for testing shall be evaluated to determine the root cause of the replacement or modification of all snubbers in either fails to lock-up or fails to move failure.

the FMG or additional testing until the (i.e., frozen in place), the cause will be mathematical expression of ISTD-5331(b) is evaluated and if caused by ISTD-5272 states that snubbers found unacceptable satisfied or all snubbers in the FMG have been manufacturer design deficiency, all according to operational readiness test requirements tested. This may result in fewer snubbers snubbers of the same design subject to should be assigned to FMGs unless the failure is being tested after a test failure. However, the the same defect shall be tested isolated or unexplained. FMGs shall include all revised program requirements provide regardless of location or difficulty or unacceptable snubbers with the same failure mode adequate assurance of snubber removal. This testing requirement shall and all other snubbers with similar potential for similar OPERABILITY because all potentially affected be independent of the requirements failure.

snubbers will be replaced or modified; or the stated above for snubbers not meeting acceptance limit for additional testing will be the test acceptance criteria.

As an alternative to additional testing for Design or met, demonstrating an acceptable level of Manufacturing FMGs, ISTD-5323 requires no reliability.

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 mathematical expression of ISTD-5331(b) is satisfied or all snubbers in the FMG have been tested.

Serial No.11-354 Docket No. 50-336, Page 8 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance Rquirement TRevised ISI Program Requirement Justification for Change Requirement i,

4.7.8.d (continued)

ISTD-1 800 requires that an evaluation shall be The revised ISI program requirements for performed of the system(s) or components of which an supported component(s) or system evaluation For the snubber(s) found inoperable, unacceptable snubber is a part, for possible damage are equivalent to those of current SR 4.7.8.d an engineering evaluation shall be to the supported system or component.

performed on the components which are supported by the 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.

4.7.8.e Hydraulic Snubbers ISTD-5210, Test Parameters. Snubber operational The revised ISI program requirements for Functional Test Acceptance readiness tests shall verify the following:

hydraulic snubber acceptance criteria are Criteria equivalent to those of current SR 4.7.8.e.

The hydraulic snubber functional test (a) activation is within the specified range of velocity or shall verify that:

acceleration in tension and in compression.

1.

Activation (restraining action)

(b) release rate, when applicable is within the is achieved within the specified specified range in tension and in compression.

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.

Serial No.11-354 Docket No. 50-336, Page 9 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance Revised ISl Program Requirement Justification for Change Requirement 4.7.8.f Mechanical Snubbers ISTD-5210, Test Parameters. Snubber operational The revised ISI program requirements for Functional Test Acceptance readiness tests shall verify the following:

mechanical snubber acceptance criteria are Criteria equivalent to those of current SR 4.7.8.f.

(a) activation is within the specified range of velocity or The mechanical snubber functional test acceleration in tension and in compression.

shall verify that:

(c) for mechanical snubbers, drag force is within

1. The force that initiates free specified limits, in tension and in compression.

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.

Serial No.11-354 Docket No. 50-336, Page 10 of 10 Millstone Power Station Unit 2 Comparison of Current TS Requirements to Revised ISI Program Requirements (Continued)

Current TS Surveillance Revised ISI Program Requirement Justification for Change Requirement 4.7.8.g Snubber Service Life Monitoring A record of the service life of each snubber, the date at which the designated service life commences and the installation and maintenance records on which the designated service life is based shall be maintained as required by Quality Assurance Program Topical Report.

Concurrent with the first inservice visual inspection and at least once per 18 months thereafter, the installation and maintenance records for each snubber shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber service life review. If the indicated service life will be exceeded prior to the next scheduled service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review. This reevaluation, replacement or reconditioning shall be indicated in the records.

ISTD-6100 requires initial snubber service life to be predicted based on manufacturer's recommendation or design review.

ISTD-6200 requires service life to be evaluated at least once each fuel cycle, and increased or decreased, if warranted. If the evaluation indicates that service life will be exceeded before the next scheduled system or plant outage, one of the following actions shall be taken:

(a) the snubber shall be replaced with a snubber for which the service life will not be exceeded before the next scheduled system or plant outage (b) technical justification shall be documented for extending the service life to or beyond the next scheduled system or plant outage (c) the snubber shall be reconditioned such that its service life will be extended to or beyond the next scheduled system or plant outage The service life evaluation requirements in ISTD-6100 and ISTD-6200 are equivalent to the requirements in current SR 4.7.8.g.

Serial No.11-354 Docket No. 50-336, Page 1 of 10 ATTACHMENT 5 U2-24-SNUB-BAP01 SNUBBER EXAMINATION, TESTING, AND SERVICE LIFE MONITORING PROGRAM PLAN DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

U2-24-SNUB-BAPO1 Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 Millstone Power Station Unit 2 U2-24-SNUB-BAPO1 Snubber Examination, Testing, and Service Life Monitoring Program Plan Revision 0 Commercial Service Date December 26, 1975 Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 Rope Ferry Road Waterford, CT 06385 APPROVALS:

See ER-MPIST-106 Attachment 1 for approval signatures Revision Date 07/21/Il Rev 0 Page 1 Revision Date 07121111 Rev 0 Page I "

U2-24-SNUB-BAPO1 Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 Revision Log Effective Revision Description Prepared:

Date Approved:

Date Date IST Snubber Engineering Coordinator Manager Original 08/08/11 08/15/11 Revision Date 07/21/11 Rev 0 Page 2 Revision Date 07121111 Rev 0 Page 2

U2-24-SNUB-BAPOI Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 TABLE OF CONTENTS SECTION

1.0 INTRODUCTION

1.1 Purpose 1.2 Scope 1.3 Discussion 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:

2.1 Snubber Inservice Testing Plan Description 2.2 DTPG Description 2.3 Service Life Monitoring 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:

9.0 ATTACHMENTS

Revision Date 07/21/11 Rev 0 Page 3

U2-24-SNUB-BAPOI Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 INTRODUCTION:

1.1 Purpose

To provide requirements for the performance and administration of assessing the operational readiness of those dynamic restraints (Snubbers) whose specific functions are required to perform one of the following three functions or, to ensure the integrity of the reactor coolant pressure boundary.

Shutdown the reactor to the safe shutdown condition Maintain the reactor in the safe shutdown condition Mitigate the consequences of an accident

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.

Subsection ISTA, "General Requirements" 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 Nuclear Power Plants" ISTD establishes preservice and inservice examination and testing, and the service life 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 snubbers for Unit 2 during a seismic or other events, initiating dynamic loads, the inspection, testing, and the service life monitoring of these snubbers shall be implemented and performed in accordance with the requirements of SP-21149, Snubber Visual Inspection Surveillance and SP 21174 Snubber Functional Testing Surveillance.

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.

The Snubber Program described in SP 21149 and SP 21174 adhere 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).

2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:

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Millstone Power Station Unit 2 2.1 Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the extent specified within SP 21149 and SP 21174.

2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) by design type, in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample plan per ISTD-5300. The snubbers attached to the Steam Generators are listed as a separate DTPG as required by ISTD-5253.

DTPGs at Millstone Station Unit 2 include all hydraulic snubbers as DTPG "A", all mechanical snubbers as DTPG "B", and all Steam Generator snubbers as DTPG "C". The individual snubbers included in the each specific DTPG are listed in Attachment 9.1, 9.2, and 9.3 of this plan and in SP 21149.

2.4 The service life of all snubbers shall be monitored and snubbers replaced, reconditioned or evaluated in accordance with SP 21174 and ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections. The replacement or reconditioning shall be documented and records retained in accordance with Millstone 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 Examinationsand Functional Testing shall be performed to verify the requirements specified within SP 21149, SP 21174 and ER-AA-NDT-VT-603 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 SP 21149 and SP 21174. Millstone Unit 2 currently performs accessible and inaccessible snubber visual examinations as one group with the frequency shown in Table ISTD 4252-1.

4.2 The Visual Examinations of Table ISTD 4252-1may be extended in accordance with Code Case OMN13 once the prerequisites of the code case have been met.

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 SP 21174.

5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:

5.1 Snubbers that do not appear to conform to the Visual Examination requirements of SP 21149, 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 SP 21174 shall be evaluated to determine the cause of the failure and appropriate corrective action taken.

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Millstone Power Station Unit 2 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 included in SP 21174.

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, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with SP 21149, SP 21174, and ISTD by the IST Snubber Coordinator.

7.2 The IST Snubber Coordinator shall identify and track expanded or additional testing and/or examinations as required by SP 21149, SP 21174 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.

9.0 ATTACHMENTS

9.1 DPTG A (Hydraulic Snubber Test Group) 9.2 DPTG B (Mechanical Snubber Test Group) 9.3 DPTG C (Steam Generator Snubber Test Group)

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Millstone Power Station Unit 2 Hanger ID Number 312015A 312015B 312016A 312016B 312017 312018 312019 401008 401024 402009 402022 402056A 402056B 402083 402100 402113A 402113B 402115A 402115B 403068 403090 405388 410004A 410004B 410012 410014 410015 410017 410019 410021 410022 410027 410028 410029 410031A 410031B 410061 System MS MS MS MS MS MS MS CS HPSI LPSI LPSI CS CS CS SIT SDC SDC SDC SDC SFP SFP MS SIT SIT SIT SIT SIT SIT SIT SIT SIT SIT SIT SIT SIT SIT SDC ATTACHMENT 9.1 DPTG A (Hydraulic Snubber Test Group)

Manufacturer Size Grinnell 4x5 Grinnell 4x5 Grinnell 4x5 Grinnell 4x5 Grinnell 10x5 Grinnell 10x5 Grinnell 8x5 Grinnell 1.5x5 Grinnell 2.5x5 Grinnell 1.5x5 Grinnell 2.5x5 Grinnell 1.5x5 Grinnell 1.5x5 Grinnell 1.5x5 Grinnell 2.5x5 Grinnell 3.25x5 Grinnell 3.25x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 1.5x5 Grinnell 1.5x5 Grinnell 2.5x5 Grinnell 3.25x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 3.25x5 Grinnell 2.5x5 Grinnell 3.25x5 Grinnell 6x5 Grinnell 6x5 Grinnell 2.5x5 Grinnell 2.5x5 Grinnell 2.5x5 Revision Date 07/21/11 Rev 0 Page 7

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Millstone Power Station Unit 2 ATTACHMENT 9.1 (cont)

DPTG A (Hydraulic Snubber Test Group)

System Manufacturer Size Hanger ID Number 410065A 410065B 410067 410083 410086A 410086B 410086C 410103 411030A 411030B 412002 412003 412004 412013 412015 412016A 412016B 412018 413009 41301 IA 4130111B 413018B 413019A 413019B 413022A 413022B 413024A 413024B 413025A 413025B 413028 413029A 413029B 413030A 413030B 413031 413032A SIT SIT SIT SIT SIT SIT SIT SIT FW FW MS MS MS FW FW MS MS FW MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS MS Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Lisega Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell Grinnell 2.5x5 2.5x5 2.5x5 2.5x5 5x5 3.25x5 3.25x5 3.25x5 5x5 5x5 309253 5x5 6x10 3.25x5 3.25x5 6x5 6x5 3.25x5 2.5x5 4x5 4x5 8x5 4x5 4x5 4x5 4x5 5x5 5x5 4x5 4x5 2.5x5 2.5x5 2.5x5 3.25x5 3.25x5 6x5 8x5 Revision Date 07/21/li Rev 0 Page 8 Revision Date 07121111 Rev 0 Page 8

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Millstone Power Station Unit 2 Hanger ED Number 413032B 413041 413046A 413046B 413081 413082A 413082B 413172 413179 413181 413192A 413192B 413199A 413199B 416014A 416014B 416020 416025 416027 427075 427097A 427097B 505166A 505166B 510017 510018 512001 513023A 513023B 513032 60025 60026 ATTACHMENT 9.1 (cont)

DPTG A (Hydraulic Snubber Test Group)

System Manufacturer Size MS Grinnell 8x5 MS Grinnell 6xl0.

MS Grinnell 3.25xl0 MS Grinnell 3.25x10 MS Grinnell 1.5x5 MS Grinnell 1.5x5 MS Grinnell 1.5x5 FW Grinnell 3.25x5 FW Grinnell 4x5 FW Grinnell 2.5x5 FW Grinnell 3.25x5 FW Grinnell 3.25x5 FW Grinnell 2.5x5 FW Grinnell 2.5x5 CS Grinnell 1.5x5 CS Grinnell 1.5x5 CS Grinnell 2.5x5 CS Grinnell 2.5x5 CS Grinnell 2.5x5 SW Grinnell 2.5x5 SW Grinnell 2.5x5 SW Grinnell 2.5x5 RBCCW Grinnell 1.5x5 RBCCW Grinnell 1.5x5 SIT Grinnell 3.25x5 SIT Grinnell 3.25x5 MS Anvil PSA-1 MS Grinnell 1.5x5 MS Grinnell 1.5x5 MS Grinnell 6x5 FW Grinnell 3.25x5 FW Grinnell 6x5 Revision Date 07/21/11 Rev 0 Page 9

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Millstone Power Station Unit 2 Hanger ID Number 302092 310022 401014 401016A 401016B 401018 401019A 401019B 404020A 404020B 408009 408010 408021A 408021B 408022 408029 410007 410037A 410037B 410040 410040A 410046 410049 410054 410059 410062A 410062B 410092 411045A 411045B 413064A 413064B 413132A 413132B 413135A 413135B 414001A System LPSI SIT LPSI LPSI LPSI HPSI HPSI HPSI 14PSI HIPSI RCS RCS RCS RCS RCS RCS SIT RCS RCS RCS RCS RCS RCS RCS RCS SDC SDC SIT FW FW MS MS MS MS MS MS RCS ATTACHMENT 9.2 DPTG B (Mechanical Snubber Test Group)

Manufacturer Size PSA PSA-I PSA PSA-I PSA PSA-1 PSA PSA-I PSA PSA-I PSA PSA-3 PSA PSA-I PSA PSA-I PSA PSA-I PSA PSA-1/4 PSA PSA-3 PSA PSA-3 PSA PSA-1 PSA PSA-1 PSA PSA-1 PSA PSA-I PSA PSA-1 PSA PSA-I PSA PSA-1 PSA PSA-1 PSA PSA-1 PSA PSA-3 PSA PSA-1 PSA PSA-3 PSA PSA-1 PSA PSA-3 PSA PSA-3 PSA PSA-1 PSA PSA-1 PSA PSA-1 PSA PSA-3 PSA PSA-3 PSA PSA-3 PSA PSA-3 PSA PSA-1 PSA PSA-1 PSA PSA-1 Revision Date 07/21/11 Rev 0 Page 10 Revision Date 07121111 Rev 0 Page 10

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Millstone Power Station Unit 2 Hanger ID Number 414001 B 414002A 414002B 414006A 414006B 414009A 414009B 414016A 414016B 41402 1A 41402 1B 414029A 414029B 414029C 414029D 414032A 414032B 414033A 414033B 414035 414040 414041 414044 416016A 416016B 416021 416022 416032A 416032B 427103 427106 427115A 427115B 450058A 450058B 491375D 501023A ATTACHMENT 9.2 (cont)

DPTG B (Mechanical Snubber Test Group)

System Manufacturer Size RCS PSA PSA-1 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-3 RCS PSA PSA-1 RCS PSA PSA-1 RCS PSA PSA-1 RCS PSA PSA-I RCS PSA PSA-1 RCS PSA PSA-1 RCS PSA PSA-1 RCS PSA PSA-I RCS PSA PSA-1 RCS PSA PSA-1 CS PSA PSA-1/4 CS PSA PSA-1/4 CS PSA PSA-1/2 CS PSA PSA-1/4 CS PSA PSA-1 CS PSA PSA-I SW PSA PSA-3 SW PSA PSA-35 SW PSA PSA-3 SW PSA PSA-3 RBCCW PSA PSA-1/2 RBCCW PSA PSA-1/2 CVCS PSA PSA-1/4 CS PSA PSA-1 Revision Date 07/21/11 Rev 0 Page 11

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Millstone Power Station Unit 2 Hanger ID Number 501023B 501024 502024A 502024B 502026A 502026B 502035 507002A 507002B 510004 512002 512003 513008 513036 513040 513041 513042 514001 527071A 527071B 527072A 527072B 60017 60240 60606 70080 70087 70100 491356G DP-023 491389K DP-034 491369G DP-038 60390 DP-086 491354G DP-107 491354C DP-109 491357E DP-125A 491357E DP-125B 491437G DP-152 System CS CS SDC SDC LPSI LPSI LPSI SIT SIT SIT MS MS MS MS MS MS MS RCS SW SW SW SW FW RHV RCS CVCS RWST HPSI MS CVCS CVCS MS MS MS MS MS CVCS ATTACHMENT 9.2 (cont)

DPTG B (Mechanical Snubber Test Group)

Manufacturer Size PSA PSA-1L PSA PSA-1 PSA PSA-3 PSA PSA-3 PSA PSA-1/2 PSA PSA-1/2 PSA PSA-3 PSA PSA-3 PSA PSA-3 PSA PSA-1 PSA PSA-1/2 PSA PSA-1/2 PSA PSA-1 PSA PSA-1 PSA PSA-1 PSA PSA-I PSA PSA-I PSA PSA-10 PSA PSA-3 PSA PSA-3 PSA PSA-3 PSA PSA-3 PSA PSA-10 PSA PSA-1/2 PSA PSA-3 PSA PSA-1/4 PSA PSA-1 PSA PSA-1/4 PSA PSA-1/4 PSA PSA-1 PSA PSA-1/4 PSA PSA-1 PSA PSA-1 PSA PSA-1/4 PSA PSA-1/4 PSA PSA-1/4 PSA PSA-1/4 Revision Date 07/21/11 Rev 0 Page 12

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Millstone Power Station Unit 2 ATTACHMENT 9.2 (cont)

DPTG B (Mechanical Snubber Test Group)

Hanger ID Number 491358E DP-190 70037 DP-208 70038 DP-215 491361D DP-253 491232K DP-307 491424A DP-41 1 491389M DP-501 491280A DP-537 60365 DP-633 491277B DP-781 60375 DP-816 System MS MS MS MS MS CVCS CVCS HPSI MS HPSI MS Manufacturer PSA PSA PSA PSA PSA PSA PSA PSA PSA PSA PSA Size PSA-1/4 PSA-1 PSA-1 PSA-1/4 PSA-1 PSA-1/4 PSA-1/2 PSA-1/2 PSA-1 PSA-1 PSA-1 Revision Date 07/21/11 Rev 0 Page 13 Revision Date 07121111 Rev 0 Page 13

I' "

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Millstone Power Station Unit 2 Hanger ID Number SGI---SS1 SGI---SS2 SGI---SS3 SG1---SS4 SG1---SS5 SG1---SS6 SGI---SS7 SGI---SS8 SG2---SS1 SG2---SS2 SG2---SS3 SG2---SS4 SG2---SS5 SG2---SS6 SG2---SS7 SG2---SS8 ATTACHMENT 9.3 DPTG C (Steam Generator Snubber Test Group)

System Manufacturer Size SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 10x5 SG Grinnell 1Ox5 SG Grinnell 10x5 SG Grinnell 10x5 Revision Date 07/21/li Rev 0 Page 14 Revision Date 07121111 Rev 0 Page 14