Text

Request for Amendment to Revise Oyster Creek Nuclear Generating Station Under Snubber Surveillance Requirements
	ML14127A435
Person / Time
Site:	Oyster Creek
Issue date:	04/30/2014
From:	Jim Barstow; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-14-046
	Download: ML14127A435 (59)
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~ Exelon Generation 10 CFR 50.90 RA-14-046 April 30, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-1 6 NRC Docket No. 50-219

Subject:

Request for Amendment to Revise Oyster Creek Nuclear Generating Station Snubber Surveillance Requirements In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-1 6 for Oyster Creek Nuclear Generating Station (OCNGS).

The proposed changes will revise OCNGS snubber surveillance requirements contained in TS.

EGC has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92.

The proposed changes have been reviewed by the OCNGS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. provides an evaluation of the proposed changes, including a detailed description, technical and regulatory evaluations, and an environmental consideration. Attachment 2 provides the existing TS pages marked up to show the proposed changes. The marked up TS Bases page is provided for information only in Attachment 3. Attachment 4 contains a detailed comparison of the current TS 4.5.M Surveillance Requirements to the proposed ISI program requirements and justification for changes. Attachment 5 provides a copy of the proposed Snubber Inspection Program.

There are no regulatory commitments contained in this submittal.

Aoc)

U.S. Nuclear Regulatory Commission April 30, 2014 Page 2 EGC requests approval of the proposed license amendment by April 30, 2015, with the amendment being implemented within 60 days of issuance.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the State of New Jersey of this application for license amendment by transmitting a copy of this letter and its attachments to the designated state official.

Should you have any questions regarding this submittal, please contact Ms. Stephanie J.

Hanson at (610) 765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3 0 th day of April 2014.

Respectfully, JameYBarstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Technical Specifications Pages

3. Markup of Technical Specification Bases Page (For Information Only)

4. TS 4.5.M Surveillance Requirements Comparison to ASME OM Code Subsection ISTD

5. Proposed Snubber Inspection Program cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, OCNGS USNRC Project Manager, OCNGS Manager, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

ATTACHMENT I Evaluation of Proposed Changes Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219

Subject:

Request for Amendment to Revise Oyster Creek Nuclear Generating Station, Snubber Surveillance Requirements 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedents 4.3 No Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

License Amendment Request Revise Snubber Surveillance Requirements Page 1 of 5 Evaluation of Proposed Change Docket No. 50-219 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No..DPR-16 for Oyster Creek Nuclear Generating Station (OCNGS). The proposed changes will revise the TS surveillance requirements for snubbers to conform to the revised OCNGS Snubber Inspection Program.

2.0 DETAILED DESCRIPTION OCNGS is currently in the fifth 10-year Inservice Inspection (ISI) interval, and is using the American Society of Mechanical Engineers (ASME)Section XI Code, 2007 Edition with the 2008 Addenda. The fifth 10-year ISI interval at OCNGS began on January 15, 2013. Currently, snubber inspection and testing are performed in accordance with the specific requirements of TS 4.5.M.

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

For OCNGS, the inspection and testing of snubbers is performed in accordance with plant TS. OCNGS intends to adopt Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2004 Edition through the 2006 Addenda, in place of the requirements for snubbers in the plant TS.

The purpose of this amendment request is to remove the specific surveillance requirements for demonstrating snubber operability from the TS since the inspection program has been revised to include the requirements of the OM Code Subsection ISTD in the Snubber Inspection Program. The proposed changes to TS 4.5.M are necessary to conform the Technical Specifications to the revised inspection program for snubbers.

The proposed changes to the OCNGS TS are summarized below:

1. TS Section 4.5.M would be revised to remove specific surveillance requirements for demonstrating snubber operability. The current requirements would be replaced by a reference to the "Snubber Inspection Program."

2. The "Snubber Inspection Program," as described in TS Section 4.5.M will provide a description of the snubber program requirements. provides the existing TS pages marked up to show the proposed changes. The marked up TS Bases page is provided for information only in Attachment 3. A comparison of the current TS 4.5.M requirements to the revised snubber program requirements and justification of the changes are provided in Attachment 4. Attachment 5 contains a copy of the proposed Snubber Inspection Program.

License Amendment Request Revise Snubber Surveillance Requirements Page 2 of 5 Evaluation of Proposed Change Docket No. 50-219

3.0 TECHNICAL EVALUATION

Licensees are required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v) to perform the inspection and testing of snubbers in accordance with ASME B&PV Code,Section XI 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(b)(3)(v)(B) states that licensees shall comply with the provisions for examining and testing snubbers in Subsection ISTD of the ASME OM Code and make appropriate changes to their Technical Specifications or licensee-controlled documents when using the 2006 Addenda or later editions and addenda of Section XI of the ASME B&PV Code. OCNGS is currently using the 2007 Edition with the 2008 Addenda of the Section XI ASME Code.

The proposed changes replace the specific TS requirements for snubber examination, testing and service life monitoring with a reference to the Snubber Inspection Program, thereby ensuring the TS remain consistent with the Snubber Inspection Program.

Snubbers will continue to be demonstrated OPERABLE by performance of the Snubber Inspection Program. This program will be required to be maintained in compliance with 10 CFR 50.55a per the proposed new TS Section. The program for inspection and testing of snubbers in accordance with ASME B&PV Code,Section XI 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.

4.0 REGULATORY EVALUATION

4.1 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.

10 CFR 50.55a(b)(3)(v)(B) states that licensees shall comply with the provisions for examining and testing snubbers in Subsection ISTD of the ASME OM Code and make appropriate changes to their Technical Specifications or licensee-controlled documents when using the 2006 Addenda or later editions and addenda of Section XI of the ASME B&PV Code.

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

The proposed changes amend the TS surveillance requirements to conform the TS to the revised inspection 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).

License Amendment Request Revise Snubber Surveillance Requirements Page 3 of 5 Evaluation of Proposed Change Docket No. 50-219 4.2 Precedents The proposed changes to TS 4.5.M are similar to changes submitted by Public Service Enterprise Group (PSEG) Nuclear, LLC for Salem Generating Station, Units 1 and 2 and Dominion Nuclear Connecticut (DNC), Inc for Millstone Power Station. The applicable references for these changes are provided below:

1. Letter from R. E. Ennis (U.S. Nuclear Regulatory Commission) to T. Joyce (PSEG Nuclear, LLC), "Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Issuance of Amendments RE:

Technical Specification Requirements for Snubbers (TAC Nos. ME4796 AND ME4797)," dated August 25, 2011.

2. Letter from J. Kim (U.S. Nuclear Regulatory Commission) to D. A. Heacock (Dominion Nuclear),

"Millstone Power Station, Unit 2 - Issuance of Amendment RE: Snubber Surveillance Requirements (TAC No. ME7221)," dated June 28, 2012.

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-1 6 Oyster Creek Nuclear Generating Station (OCNGS). The proposed changes would revise the TS surveillance requirements for snubbers to conform to the revised OCNGS inservice inspection (ISI program).

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

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

Response: No The proposed changes would revise TS 4.5.M to conform the TS to the revised Snubber Inspection Program. Snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g). Snubber examination, testing and service life monitoring is not an initiator of any accident previously evaluated. Therefore, the probability of an accident previously evaluated is not significantly increased.

Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The proposed changes do not adversely affect plant operations, design functions or analyses that verify the capability of systems, structures, and components to perform their design functions. Therefore, the consequences of accidents previously evaluated are not significantly increased.

License Amendment Request Revise Snubber Surveillance Requirements Page 4 of 5 Evaluation of Proposed Change Docket No. 50-219 Based on the above, these proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

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

Therefore, it is concluded that these proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No The proposed changes ensure snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g). Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives.

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

4.4 Conclusions 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements; (ii) changes to recordkeeping, reporting, or administrative procedures or requirements; (iii) changes to the licensee's or permit holder's name, phone number, business or e-mail address; (iv) changes to the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager; or (v) changes to the format of the license or permit or otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR

License Amendment Request Revise Snubber Surveillance Requirements Evaluation of Proposed Change Docket No. 50-219 Page 5 of 5 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. 10 CFR 50.55a, "Codes and standards."

2. American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2004 Edition through the 2006 Addenda.

3. American Society of Mechanical Engineers (ASME) Section Xl, B&PV Code for Operation and Maintenance of Nuclear Power Plants 2007 Edition with the 2008 Addenda.

ATTACHMENT 2 Markup of Technical Specifications Pages Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219 REVISED TECHNICAL SPECIFICATIONS PAGES TS Pa-qes 4.5-6 4.5-7 4.5-8 4.5-9 4.5-17 4.5-18

Leakage at Instrument fittings and valves Venting an unisolated instrument or instrument line Flushing or draining an instrument Installation of a new instrument or instrument line L.

Suppression Chamber Surveillance

1. At the frequency specified in the Surveillance Frequency Control Program, the suppression chamber water level and temperature and pressure suppression system pressure shall be checked.

2. A visual inspection of the suppression chamber interior, including water line regions, shall be made at the frequency specified in the Surveillance Frequency Control Program.

3. Whenever heat from relief valve operation is being added to the suppression pool, the pool temperature shall be continually monitored and also observed until the heat addition is terminated.

4. Whenever operation of a relief valve is indicated and the suppression pool temperature reaches 160°F or above while the reactor primary coolant system pressure is greater than 180 psig, an external visual examination of the suppression chamber shall be made before resuming normal power operation.

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Shock Suppressors (Snubbers)

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1. Each snubber shall be demonstrated OPERABLE by performance of the oU-1 in znjpouo 1r;-!o*;

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a. Vicual inspootlc~i Cnubboro are catoexizd as 'A89961318bl Or aseessiblo duAR9n ronoto OPOF6410.

rEach-Atth 4-11 to81990118 (IRS019688ibII Ond scoocaiblo) muW be a Repeated Midepep~ndot scc~diR@ to tho cohodulo dotemRrngd by Table 4.61. The 4AGUIoa inupootoRi !nt9r~ul for 080h ty~pe of snubbor shallb zotorminod based upon tho oritori proy'dod in Table 14A 1, JINSERT ý OYSTER CREEK 4.5-6 Amendment No.: 412, 4 86, 21 6-M

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(2) afttahments 4o tho oundation OF SUPPOIrtig otructur Bro fUncton~l; and (3) fastonser for. tha attAhmiwiant oftho anbar. to tho oam~pcnont and to the R onubbr aROh-l-,G A rNi Snubboro whioh appear Inoperablo ac a aeoult of ý.1ousI incpcc~ens ha bos oAcu-esiicd efi WR8oaPtablo and may be roolnaslfied as aezaptablo (fr the purpooc 8f S"abi*ching the ROMt YIG~aI inSPectio IeNtal, preliding ftha (1) the eauce of tho rejooion *9 oloary ooa~bllohod and reimedlead-for that PSrtlcMISr onubbor and for othor snubbor lR0*opeti9 6f t"p 4h6t maOY bG goeRiceally ouccaptiblo; and (2) the &#"aotd BnubberI to unctRonlly tooted-in t-ho Qs foui-nd -eand-itlon and d-etorminead OPERA66Le por SPoo8flcatio 4.6.M.d Or 4.6t.o~. A m.1oe: and OOIaluatio OhOll be por~orrnod and documontod to Juotify cantinuod operation WMt On unacamptoblo c.,ubbor-. $9If cntnud opootlon cannot bo juctifld, the Gnubber Ghall be deelerod mnoporablo and !he ACTION requiromonts ahe be Met o;

Functional ToceW At bo9W ones ey"r 21 months, a wepmeeFntote sample (410% of tho totW of 880h typo-of Gonubboralf in uco I the plant) shall be functionally tosted SithoFR Pin8-placA or8n bnc.', toot For. each anubber that dec no R!Moot t-he function-aal t66t noaptancs crIteria of Spooflfatlon 4.6.M.1.d o 4:6.M.o, OR ad-d-itional 40% of that typo of 6nubber Shall be fuenctioally tOWte.

Ac used In 11 ths peeiffioat~,

"yp Of Onubbor Shall meanR onubboro of the same design and m~anufacturr, mooshanca! Or h"Faulc The rOP8GRIonAfrYo sample colootod fer fuRnctonal tooting shall Include the

aroUS confgur~ations, opSeMRtig oreRnmeAntSR and the rane Of OWz and capacity of Gnubboro. At leaot 26% of #he snubboro in the FeprecontAth isamalo sihall Inaludop anubbera #Fro the foI'n8,:In throoa estntoooas I

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unbb tcwthn 6 foot ef hoayy cguipmont (yalvo, pump,

3. Gnuibbor within' 109 foot oft the diocharue from a safet: relio OYSTER CREEK 4.5-7 Amendment No.: 4824 6

In addition to the rOgulOr cOrplO, snubbrsG whish fWelld a provices funelispal too! 9ha! be retested dUring th9 Rodt tso perici. It a spree snubbe We on n~~d IA plaea Of a We~d cnubber, then be*h the Woied (1if it Fo rpeirod and lInsalled 'A OAnther positiOn) and the roplasemont sn~ubbrhllbreeed hreutfrmtoigotoo For any enubber that falls to lockup OF fals to MOVO, 1,o., froze 'n ploes, the souse vill -bie opal-ated. 'f lloused by rMAHOnufaOFue oF design defilcen~ olo hall be tokon to noro that all unubbors of the samo doSIGA are net subjectl to-the cearno dofoct d-Hy;*oulle Snubboro Fwunctlo'o Tost Agecptanes GrlOMM m

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.v-sposfif ed range Of Volseh~y Or ocoolorotln In both tor-A1on anvd-GRONub blood, Or release raft, WhOIor requlred, is VWFItn the OpOOMed Frang In cOmFPression OF teASIOn. For snubbor cpeeolflally roqu!rod to net disp~ee und-er Fninous load, the abilkty of the snubbors to withstand load witou dloolasament shall be Yerffi"d 07 tMcohanical Snubboro Functional Toot Aczootanse Critera The meshenisal onubbor funcVORIco 4964 Ohall

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The drag Wesc 4o masintain mo~memnt of the snubber red i aithor tensien OF cOmFpression 19 '866 than the spooMfOd maximum drag ferco.

Ae Y~e (FWPn ostloni Is ashieyod within the spnocietd range of voleslty Or 8acoloratlOn !n both tension and Snubber rolecOS rate, WhOFO requiped, 'a withini the opcefiod Grang In cOFFIPreselon or Wt~ona.

For snubbors spoceelcly required not to displess undOF continRuGo load, the abiliy o the snubber to withsand lead without dioplacomont shall be verlaga I

OYSTER CREEK 4.5-8 Amendment No.: 432,4,L2

f, Sk tubbsr MorMPA I i. Uanitrn M9 ecFd of the aer.13 li8 Wf 986h MnUMSr 049 dino Bt W:hic ho docignatod oor.1~ It sermmoncw aci t- -

-Ir.thlen and wIisir.3neRe Fesoide 9R w~e the dosIgnAtod oor..1c IWo is baed shall be maitained on roqid by Speelffintion 6.40,2.A, Coneurrent Wth the fiWs Incer.1ce viual hInpooton and at l@66t Ocic POr 24 montdhe thorapler-, the lnsto!5atOn And RIMRSaltonnc rocrds (Fc oa09h GnubbOr 8hall bo ro~r1ewd to ye*f th-t &&.o 3-n1-4Ate j-c

&- ho-- n-t been e*99oicd OF Will neot be oi~eodod ptorF to the next seheduod c~ubbor cPArtlie9Wesw-low. If-h tho

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d 9P lndotierife w14 H be e;seed H pro to "h Rnet asheduled sciubbepAr e Wo~aDe rc~ew, the ciubb6F corelAs Wie shall be Fe &Mont-aod-or. the enubbe-shall be moplecod Or rocandhieocd so as to o9tend kt oor9iA9 life beyond the doew of the next sehcduled 9cAr~cies go m;4w. ThI0Fe rm

.~latin, replacWOmon Or rocondltlcIng shall he indicated in the record.

6Serico life Shall Pot at on'. tima affect rmantor. ovoannons.

N.

Secondary Containment Isolation Valves

1. Each secondary containment isolation valve shall be demonstrated operable prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator by cycling the valve through at least one complete cycle of full travel. Following maintenance, repair or replacement work on the control or power circuit for the valves, the affected component shall be tested to assure it will perform its intended function in the circuit.

2. At the frequency specified In the Surveillance Frequency Control Program, all valves shall be tested for automatic closure by an isolation signal.

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awnber of mweeeptable sabberg funwd during that hntrml. Um~bb.m may be eategprizeth bard uipn their sa;eaibility during p we paine jaintly. Hoewcyvo, th; deeisies on how to eftvgerize the 3nubben mmt be mad: and daeumcntd befor an" iiupeetion ad sLhll use tha~t dLzision :

the bamis Von ;vhieh t; detzrmine the nfte inspe;tiin intiefv a! for tAMt intrpeIatien betwee~n papuation et eatcr iz An the rmumkr of meeeeptable sanubbr i rM e~. UZ-on1--t8 31-wer integar for the valuie ef the limit for Gelurmw A, 8, erCG if that inftegr ineludes a fivetienal val~e ef

jtablcW 3nubbers as dcthrmined by interpelefin if th; "ember ef uneptable xMubbcr is equtMI !ar less than the number in CGiluni A, the next icmpeefien inter.'aI may b: twic: theprviu

~c~;lbut net greater thmn 48 mznthw.

If the nwnber efu ;;eptab smubbr is equl teo r les the~n the wnumbe; in Ccluxn B) but grotor than the number in CGlumn A, th; n:et inzpefien

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OYSTER CREEK 4.5-17

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ic inform!l. ffewevr, if th

numiber of unscccptnble swabbmr is lzn thUn th; mrnber; in Czlurn C but greater Oma the umibcr in C-zium B, tL; next interval shal11 be rzzlused prepertfinahly by intrpolatin, thmt is, the pie oieua.ftk~yel shlli be rcduved by a "ostr tha is one tiri ofth relis ;fthe iFare"---bt th; number cf unnoczj~bl; sntubbers fcun during the pra.ieto interva-l and th: onuber in Cclumn 1 to the diffe:;nee in the awabers in CGIumn El and G:

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INSERT 1:

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:

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 (B&PV) 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 XI of the ASME B&PV 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.

OYSTER CREEK 4.5-18 Amendment No.: 18.,1,86

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ATTACHMENT 3 Markup of Technical Specifications Bases Page (For Information Only)

Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219 REVISED TECHNICAL SPECIFICATIONS BASES PAGE TS Bases Page 4.5-14

ThoS enubor InoSpootlo fgSo ia based HPA tho nuMbr 8oF G#

AncaPItno Gcnubbof $61 f* ad duARin the pro~eue lnepoeetiAn the toal population OF categor; 912o 1Fo 9Ach enberpe, and 11ho prew.ous !reapoolon intoral. A onubbor. -a caneldorod unAcaOPtblo If W it folio to#loy h aeIpV no litR la of the u

Iopoo MIlon Wnubbero maey I tg d based upon thoe!

acees3Ibi~ity during 88Fpo:orepoRoto.

poaSOWcbleGlWW orinoaohla. :MARA eategorloc maOy 1§ V8oopaItl; Or joitl. Ho.ceor, that deI lcV musIt be mlade sand m

bolora any Inpetion and used as the basi upon which to detJrmino the next Inspoln lnt*oril l far that I$

nineI#ued operalion cannot ol bue t

I!1id th San unIeIepIabo*

nubbIr, t1o W

Rubbr hOhll be deolorod inoporablo and the epplileAbleo aotion roguiremonts Fmot. To doermi-~no the n~

Viu

._ile intoryeI, the onlbbor may!be roolaeified as acaoptablo If it can be dornnoFtrtodth 11§o onubbor Ic Opeablo i Ito 49 Beo1und condition by the prfcrmenca of a AMunotInl toot6 eand If It satisfies the aeoaptanee cr"ier for ional tooting The no4 W.ioal lnepeotln Wnerawa may be twico, the came, or reducad by as Faucs as tWe thrd ef the proy1ouo inopoction intRal.p T7hie intorwoI dopende On tho nlumfber ef unaczaeptab e.,ubboro found In proportin to the size of the population or catogo; fer onch typo of Snubber Fincludod Ini the pmre.iuo inepection. Table 4.6 1 cot6a-bllohes the length of the noet Icual Inopoeeln intowol To furter increSe-8 th14 BesuaRnee Of enUbbor reliability, functional toWSW Shiuld be peFformed onee eacei refueling eyolo. Thocae toots will lncludo stroking oW the cnUbbero to %-a*f proper pioton mo'.eMOnt, leek up and blood. Ton percent rOProconts 8n adogueAt GaMPle $Fo ouch tse.

Obcor~scd-fInauraee o 4thooo eemoleB rOOuir WMoInA of additional unite.

After the containment oxygen concentration has been reduced to meet the specification initially, the containment atmosphere is maintained above atmospheric pressure by the primary containment inerting system. This system supplies nitrogen makeup to the containment so that the very slight leakage from the containment is replaced by nitrogen, further reducing the oxygen concentration. In addition, the oxygen concentration is continuously recorded and high oxygen concentration is annunciated. Therefore, a periodic check of oxygen concentration is adequate.

This system also provides the capability for determining if there is gross leakage from the containment.

The drywell exterior was coated with Firebar D prior to concrete pouring during construction.

The Firebar D separated the drywell steel plate from the concrete. After installation, the drywell liner was heated and expanded to compress the Firebar D to supply a gap between the steel drywell and the concrete. The gap prevents contact of the drywell wall with the concrete which might cause excessive local stresses during drywell expansion in a loss-of-coolant accident.

The surveillance program is being conducted to demonstrate that the Firebar D will maintain its integrity and not deteriorate throughout plant life. The surveillance frequency is adequate to detect any deterioration tendency of the material.(8)

The "Snubber Inspection Program" manages the requirement for demonstrating snubber operability (examination, testing and service life monitoring) as reflected in TS Section 4.5.M thereby ensuring the TS remains consistent with the ISI program. The program for ISI testing of snubbers in accordance with ASME 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 to be inoperable.

OYSTER CREEK 4.5-14 Amendment No.: 482,496,2494M <-=

ATTACHMENT 4 TS 4.5.M SR Comparison to ISI Program Requirements Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219

OCNGS Snubber TS vs. OM Code Subsection ISTD Oyster Crook Technical ASME OM Code 2004 Edition through Justification for Chango

'S kecifcan (TS) 2O66(Addenda - Subsact~o ISTD 4.5.M Shock Suppressors While ISTD does not have a generic Refer to TS 4.5.M.1.a Visual (Snubbers) definition like this, ISTD-4220(a) defines Inspection, and TS 4.5.M.c As used in this specification, for visual exams what your Functional Testing sections

'type of snubber" shall mean grouping/definition can be for visuals and below.

snubbers of the same design ISTD-5250 describes the requirements and manufacturer, irrespective of for Defined Test Plan Groups for

capacity, selecting/scheduling functional tests.

4.5.M.1 ASME OM Code - Subsection ISTD -

The Oyster Creek Snubber Each snubber shall be Preservice and Inservice Examination Inspection Program will be the demonstrated OPERABLE by and Testing of Dynamic Restraints inspection program used to performance of the following (Snubbers) in Light-Water Reactor ensure operability for snubbers inspection program:

Nuclear Power Plants.

by following the ASME OM Code Subsection ISTD.

4.5.M.1.a Visual Inspection ISTD-4220(a) requires all snubbers to be Table ISTD-4252-1 is Snubbers are categorized as considered one population for equivalent to TS Table 4.5-1 for inaccessible or accessible during examination, or they may be categorized population/category sizes less reactor operation. Each of the as accessible and inaccessible, than 150. Oyster Creek's categories (inaccessible and snubber population/category accessible) may be inspected ISTD-4220(b) requires the decision to sizes are less than 150.

independently according to the examine the snubbers as one population therefore use of ISTD-4200 for schedule determined by Table or as separate categories shall be made snubber inservice examination 4.5-1. The visual inspection and documented before the scheduled in lieu of current TS 4.5.M.1.a interval for each type of snubber examination begins and shall not be does not change the number of shall be determined based upon changed during the examination.

snubbers required to be the criteria provided in Table 4.5-examined or the required

1.

ISTD-4252(b) requires inservice examination intervals.

examinations to be conducted in accordance with Table ISTD-4252-1.

4.5.M.1.b Visual Inspection ISTD-421 0 states that inservice 10 CFR 50.55a(b)(3)(v) allows Acceptance Criteria examination shall be a visual the use of Subsection ISTD for Visual inspections shall verify examination to identify physical damage, inservice examination that:

leakage, corrosion, or degradation that requirements. Preservice and may have been caused by environmental inservice examinations are (1) that there are no visible exposure or operating conditions; and required to be performed using indications of damage or external characteristics that may indicate the VT-3 visual examination impaired OPERABILITY; operational readiness of the snubber method described in ASME shall be examined.

Section Xl, IWA-2213.

(2) attachments to the foundation or supporting ISTD-4231 requires that examinations The revised ISI program structure are functional; and shall include observations for the requirements for inservice following and the conditions shall be examination do not differ (3) fasteners for the attachment evaluated when found:

significantly from the visual of the snubber to the component (a) loose fasteners, or members that are inspection acceptance criteria and to the snubber anchorage corroded or deformed in TS 4.5.M.1.b.

are functional.

(b) disconnected components or other conditions that might interfere with the Examination of the snubber proper restraint of movement from pin-to-pin in accordance with ASME OM Code 1

Oyster Creek Technical ASME OM Code 2004 Edition through Justification for Change Specification (TS) 200. Addenda - $ubsection iSTD ISTD-4232 requires that examinations Subsection ISTD and the verify snubbers do not restrain thermal attachments to the component movement to an extent that unacceptable or structure will be examined in stresses could develop in the snubber, accordance with ASME Section the pipe, or other equipment that the Xl, Subsection IWF. This will snubber is designed to protect or encompass that which was restrain. There should be no indication of examined in accordance with binding, misalignment or deformation of the Oyster Creek TS.

the snubber.

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 Section Xl, IWF-1300 and Figure IWF-1 300-1 (f) requires integral and non-integral attachments for snubbers shall be examined in accordance with the requirements of Subsection IWF.

4.5.M.1.b Visual Inspection ISTD-4240 permits snubbers classified The revised ISI program Acceptance Criteria as unacceptable during inservice requirements for evaluation and Snubbers which appear examination to be tested in accordance corrective action for inservice inoperable as a result of visual with the requirements of ISTD-5210.

examination are equivalent to inspections shall be classified as Results that satisfy the operational those of current TS 4.5.M.1.b unacceptable and may be readiness test criteria of ISTD-5210 shall for visual examination reclassified as acceptable for the be used to accept the snubber, provided acceptance criteria and meet purpose of establishing the next the test demonstrates that the the requirements of ISTD.

visual inspection interval, unacceptable condition did not affect providing that:

operational readiness.

(1) the cause of the rejection is ISTD-4233 requires that fluid supply or clearly established and remedied content for hydraulic snubbers shall be for that particular snubber and observed. If the fluid is less than the for other snubbers irrespective of minimum amount, the installation shall be type that may be generically identified as unacceptable, unless a test susceptible; and establishes that the performance of the snubber is within specified limits. Tests (2) the affected snubber is shall be performed in accordance with functionally tested in the as-ISTD-521 0. The initial test shall start with found condition and determined the piston at the as-found setting and be OPERABLE per Specification performed in the extension (tension) 4.5.M.d or 4.5.M.e. A review and direction, or in a mode that more closely evaluation shall be performed resembles the operating and design and documented to justify requirements of the snubber.

continued operation with an unacceptable snubber. If ISTD-4270 requires that snubbers that continued operation cannot be do not meet examination requirements of justified, the snubber shall be ISTD-4230 shall be evaluated to declared inoperable and the determine the root cause of the ACTION requirements shall be unacceptability.

2

Oyster Creek Technical ASME OM Code, 2004 Edition through Justification for Change Specification (TS) 200*6. Addenda - Subsection, ISTD met.

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

ISTD-1 800 requires that an evaluation shall be performed of the system(s) or components of which an unacceptable snubber is a part, for possible damage to the supported system or component.

4.5.M.c Functional Testing At least once every 24 months, a representative sample (10% of the total of each type of snubber in use in the plant) shall be functionally tested either in place or in a bench test.

For each snubber that does not meet the functional test acceptance criteria of Specification 4.5.M.d or 4.5.M.e, an additional 10% of that type of snubber shall be functionally tested. As used in this specification, type of snubber shall mean snubbers of the same design and manufacturer, mechanical or hydraulic.

ISTD-5252 Defined Test Plan Group (DTPG) Alternatives. Except as required by ISTD-5253, the total snubber population may be considered one DTPG, or alternatively, differences in design, application, size, or type may be considered in establishing DTPGs.

ISTD-5200 requires snubber operational readiness testing to be performed each fuel cycle. 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 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.

ISTD-5271 requires snubbers that do not meet test requirements specified in ISTD-521 0 or ISTD-5230 to be evaluated to determine the root cause of the failure.

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 testinq shall The frequency of snubber testing in the revised program is unchanged from the frequency specified in current TS 4.5.M.c.

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."

Oyster Creek 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 3

Oyster Creek Technical ASME OM Code 2004 Edition through Justification for Change Specification (TS) 2006 Addenda -. Subsection ISTD satisfy the mathematical expressions as minimize outage times for TS follows:

required equipment.

(a) for each DTPG Oyster Creek plans to use the N > 0.1n + C(0.1n/2) 10% sample plan. The initial (b) for each FMG sample size in the revised NF > CF(O.1 n/2) program is as large as the size specified in current TS 4.5.M.c.

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

4.5.M.c Functional Tests ISTD-531 1(a) requires the initial sample Since the snubbers of a DTPG (continued) to include as practicable representation are of the same design, The representative sample from the DTPG based on the significant configuration, and operating selected for functional testing features (i.e., the various designs, environment, and only a few shall include the various configurations, operating environments, snubbers are of different size configurations, operating sizes, and capacities) and based on the and capacity, the environments and the range of ratio of the number of snubbers of each representative sample would size and capacity of snubbers.

significant feature, to the total number only vary slightly.

At least 25% of the snubbers in of snubbers in the DTPG. Initial sample the representative sample shall selection shall be random.

Initial sample composition include snubbers from the requirements are less detailed following three categories:

As an alternative, ISTD-531 1(b) requires in the revised program than the initial sample to be generally those in current TS 4.5.M.c.

1. The first snubber away from representative, as in ISTD-531 1(a) but However, the revised program each reactor vessel nozzle allows the sample to be selected from requirements continue to those snubbers scheduled for seal ensure initial sample selection

2. Snubbers within five feet of replacement or other activities related to is random and representative.

heavy equipment (valve, pump, service life monitoring.

turbine, motor, etc.)

3. Snubbers within ten feet of the discharge from a safety relief valve 4.5.M.c Functional Tests ISTD-5500 requires that snubbers placed The revised program (continued) in the same location as snubbers that requirement is equivalent to the In addition to the regular sample, failed the previous inservice operational current TS 4.5.M.c requirement snubbers which failed the readiness test shall be retested at the to retest a replacement snubber previous functional test shall be time of next operational readiness testing installed in place of a failed retested during the next test unless the cause of the failure is clearly snubber. Retesting is required, period. If a spare snubber has established and corrected. Retests in unless the cause of the original been installed in place of a failed accordance with ISTD-5500 shall failure was clearly established snubber, then both the failed not be considered a part of inservice and corrected. The revised snubber (if it is repaired and operational readiness testing sample program does not require retest installed in another position) selection requirements.

during the next test period of and the spare snubber shall be failed snubbers that are retested. The results from testing repaired and installed in of these snubbers are not another position. However, the included for determining corrective action requirements additional sampling for unacceptable snubbers in 4

Oyster Creek Technical ASME OM Code 2004 Edition through Justification for Change Specification (TS) 2006 Addenda &- Subsection ISTD requirements.

ISTD-5280, including testing, provide adequate assurance of OPERABILITY for failed snubbers that are repaired and installed in another position.

4.5.M.c Functional Tests ISTD-5271 states that snubbers that do The revised program (continued) not meet test requirements shall be requirements for manufacturer For any snubber that fails to evaluated to determine the root cause of or design deficiencies require lockup or fails to move, i.e.,

the failure.

replacement or modification of frozen in place, the cause will be all snubbers in the FMG or evaluated. If caused by ISTD-5272 states that snubbers found additional testing until the manufacturer or design unacceptable according to operational mathematical expression of deficiency, actions shall be taken readiness test requirements should be ISTD-5331(b) is satisfied or all to ensure that all snubbers of the assigned to FMGs unless the failure is snubbers in the FMG have same design are not subject to isolated or unexplained. FMGs shall been tested. This may result in the same defect.

include all unacceptable snubbers with fewer snubbers being tested the same failure mode and all other after a test failure. However, snubbers with similar potential for similar the revised program failure.

requirements provide adequate assurance of snubber As an alternative to additional testing for OPERABILITY because all design or manufacturing FMGs, ISTD-potentially affected snubbers 5323 requires no additional testing when will be replaced or modified; or all snubbers in the FMGs are replaced or the acceptance limit for modified in accordance with ISTD-1600.

additional testing will be met, If replacement or modification is not demonstrating an acceptable performed in accordance with ISTD-level of reliability.

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.

4.5.M.1.d Hydraulic Snubbers ISTD-5210 Test Parameters The revised ISI program Functional Test Acceptance requirements for hydraulic Criteria a) Activation is within the specified snubber acceptance criteria are The hydraulic snubber functional range of velocity or acceleration in equivalent to those of current test shall verify that:

tension and in compression.

TS 4.5.M.1.d.

1. Activation (restraining action) b) Release rate is within the specified Oyster Creek does not have is achieved within the specified range in tension and in compression.

any snubbers specifically range of velocity or acceleration required to not displace under in both tension and continuous load.

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 snubbers to withstand load without 5

Oyster Creek Technical ASME OM Code 2004 Edition through Justification for Change Speocification (TS) 2006. Addenda - Subs ection ISTD displacement shall be verified.

4.5.M.1.e Mechanical ISTD-5210 Test Parameters The revised ISl program Snubbers Functional requirements for mechanical Test Acceptance Criteria a) Activation is within the specified snubber acceptance criteria are

1. The drag force to maintain range of velocity or acceleration in equivalent to those of current movement of the snubber rod in tension and in compression.

TS 4.5.M.1.e.

either tension or compression is b) Release rate is within the specified less than the specified maximum range in tension and in compression.

Oyster Creek does not have drag force.

c) For mechanical snubbers, drag force any snubbers specifically is within specified limits, in tension required to not displace under

2. Activation (restraining action) and in compression.

continuous load.

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.

4.5.M.f Snubber Service Life ISTD-6100 requires initial snubber The service life evaluation Monitoring service life to be predicted based on requirements in ISTD-6100, A record of the service life of manufacturer's recommendation or ISTD-6200 and ISTD-6300 are each snubber, the date at which design review, equivalent to the requirements the designated service life in current TS 4.5.M.f.

commences and the installation ISTD-6200 requires service life to be and maintenance records on evaluated at least once each fuel cycle. If Oyster Creek TS 6.10.2.1 which the designated service life the evaluation indicates that service life states that records of inservice is based shall be maintained as will be exceeded before the next inspections performed pursuant required by TS 6.10.2.1.

scheduled system or plant outage, one of to these Technical the following actions shall be taken:

Specifications shall be retained Concurrent with the first for the duration of the Facility inservice visual inspection and at (a) the snubber shall be replaced with a Operating License. This least once per 24 months snubber for which the service life will not requirement remains thereafter, the installation and be exceeded before the next unchanged.

maintenance records for each scheduled system or plant outage snubber shall be reviewed to verify that the indicated service (b) technical justification shall be life has not been exceeded or documented for extending the service will not be exceeded prior to the life to or beyond the next scheduled next scheduled snubber service system or plant outage life review. If the indicated service life will be exceeded (c) the snubber shall be reconditioned 6

Oyster Creek Technical ASME OM C-ode 2004 Edition through Justification for Change Specification (TS) 2006 Addenda - Subsection ISTD prior to the next scheduled such that its service life will be snubber service life review, the extended to or beyond the next snubber service life shall be re-scheduled system or plant outage evaluated or the snubber shall be replaced or reconditioned so ISTD-6300 requires causes for any as to extend its service life examination or testing failures shall be beyond the date of the next determined and considered in scheduled service life review, establishing or reestablishing service life.

This re-evaluation, replacement or reconditioning shall be indicated in the records. Service life shall not at any time affect reactor operations.

TS Table 4.5-1 Snubber Visual Inspection Interval Note 1: The next visual inspection interval for a snubber population or category size shall be determined based upon the previous inspection interval and the number of unacceptable snubbers found during that interval. Snubbers may be categorized, based upon their accessibility during power operation, as accessible or inaccessible. These categories may be examined separately or jointly. However, the decision on how to categorize the snubbers must be made and documented before any inspection and shall use that decision as the basis upon which to determine the next inspection interval for that category.

Note 2: Interpolation between population or category sizes and the number of unacceptable snubbers is permissible. Use next lower integer for the value of the limit for Columns A, B, or C if that integer includes a fractional value of unacceptable snubbers as determined by interpolation.

Note 3: If the number of unacceptable snubbers is equal ISTD-4220(a) requires all snubbers to be considered one population for examination, or they may be categorized as accessible and inaccessible.

ISTD-4220(b) requires the decision to examine the snubbers as one population or as separate categories shall be made and documented before the scheduled examination begins and shall not be changed during the examination.

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

Table ISTD-4252-1 is equivalent to TS Table 4.5-1 for population/category sizes less than 150. Oyster Creek's snubber population/category sizes are less than 150; therefore use of ISTD in lieu of TS is equivalent for the site.

7

Oyster Creek Technical ASME OM Code 21004 Edition through Justification for Change Specification (TS) 2006 Addenda - Subsection ISTD, to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.

Note 4: If the number of unacceptable snubbers is equal to or less than the number in Column B but greater than the number in Column A, the next inspection interval shall be the same as the previous interval.

Note 5: If the number of unacceptable snubbers is equal to or greater than the number in Column C, the next inspection interval shall be two-thirds of the previous interval. However, if the number of unacceptable snubbers is less than the number in Column C but greater than the number in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable snubbers found during the previous interval and the number in Column B to the difference in the numbers in Column B and C.

Note 6: Each inspection interval shall be subject to the limitation of Technical Specification 1.24.

Notes I Assumptions I

References:

1. Code of Record for this comparison: ASME OM Code 2004 Edition through the 2006 Addenda.

2. Oyster Creek snubber population consists of 2 defined test plan groups (DTPG) - Mechanical (Inaccessible) and Hydraulic (Accessible) snubbers.

8

ATTACHMENT 5 Proposed Snubber Inspection Program Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219

ER-OC-330-5004 Revision 0 Page 1 of 32 Exelon Generation Company, LLC Oyster Creek Generating Station 5 th Interval Snubber Inspection Program Snubber Administrative Program Document Fifth Ten-Year Inspection Interval AES Document:

OC-472623-RP06 Prepared By Prepared For 1

AUTOMATED 1

ENGINEERING jSERVICES CORP.

Exelon.

Exelon Generation Company, LLC Oyster Creek Generation Station Route 9, Lacy Township Forked River, NJ 08731 Automated Engineering Services One Energy Center 40 Shuman Blvd., Suite 340 Naperville, IL 60563

- 1 Automated Enginring Serces Corp

ER-OC-330-5004 Revision 0 Page 2 of 32 REVISION APPROVAL SHEET TITLE:

Snubber Inspection Program Fifth Ten-Year Inspection Interval Oyster Creek Generating Station AES DOCUMENT:

OC-472623-RP06 REVISION:

0 PROGRAM ACCEPTANCE REVIEWED:

APPROVED:

Greg Harttraft Greg Harttraft Programs Engineer (ISI)

John Clark

/

/ 11/22/13 11/22/13 John Clark Manager, Programs Each time this document is revised, the Revision Approval Sheet will be signed and the following Revision Control Sheet should be completed to provide a detailed record of the revision history. The signatures above apply only to the changes made in the revision noted. If historical signatures are required, Oyster Creek Generating Station archives should be retrieved.

ZA Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 3 of 32 REVISION CONTROL SHEET Major changes should be outlined within the table below. Minor editorial and formatting revisions are not required to be logged.

REVISION DATE REVISION

SUMMARY

0 11/22/13 Initial issuance. (This Snubber Administrative Program Document was developed by Automated Engineering Services as part of the Fifth Interval ISI Program update.)

Note:

1. This Snubber Administrative Program Document (Sections 1 - 6 inclusive) is controlled by the Oyster Creek Generating Station Engineering Programs Group.

' 2 Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 4 of 32 REVISION

SUMMARY

SECTION EFFECTIVE PAGES REVISION DATE Preface 1-7 0

11/22/13 1.0 8-14 0

11/22/13 2.0 15-25 0

11/22/13 3.0 26-30 0

11/22/13 4.0 31-34 0

11/22/13 5.0 35-36 0

11/22/13 6.0 37-38 0

11/22/13 z

Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 5 of 32 TABLE OF CONTENTS SECTION DESCRIPTION PAGE

1.0 INTRODUCTION AND BACKGROUND

8 1.1 Introduction

1.2 Background

1.3 Fourth Interval Snubber Inspection Program 1.4 Fifth Interval Snubber Inspection Program 1.5 Code of Federal Regulations 10CFR50.55a Requirements 1.6 Code Cases 1.7 Relief Requests 2.0 BASIS FOR SNUBBER INSPECTION PROGRAM..................................................

15 2.1 ASME OM Code Examination and Testing Requirements 2.2 Augmented Examination and Testing Requirements 2.3 Snubber Scope 2.4 Snubber Drawings and Details 2.5 Technical Approach and Positions 3.0 SN U B B E R PLA N....................................................................................................................

23 3.1 Nonexempt ISI Class Supports 3.2 Snubber General Requirements 3.3 Visual Examination, Functional Testing, and Service Life Monitoring Program 3.4 Visual Examination, Functional Testing, and Service Life Monitoring Results 3.5 Reports/Records 4.0 SNUBBER SUM M ARY TABLE.......................................................................................

30 4.1 Snubber Inspection Summary Table 5.0 RELIEF REQUESTS FROM ASME OM CODE.............................................................

32 6.0 R E FE R E N C E S..................................................................................................................

34 6.1 NRC References 6.2 Industry References 6.3 Licensee References 6.4 License Renewal References ZRiL*

Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 6 of 32 TABLE OF CONTENTS (Continued)

TABLES DESCRIPTION PAGE 1.5-1 CODE OF FEDERAL REGULATIONS 10CFR50.55a REQUIREMENTS............... 12 2.4-1 SN U BBER D ETA ILS.................................................................................................

17 2.5-1 TECHNICAL APPROACH AND POSITIONS INDEX.............................................

22 4.1-1 SNUBBER INSPECTION

SUMMARY

TABLE........................................................

30 4.1-2 SNUBBER INSPECTION

SUMMARY

TABLE PROGRAM NOTES.......................

31 5.0-1 RELIEF REQUEST INDEX.........................................................................................

33 z AIAutomated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 7 of 32

1.0 INTRODUCTION AND BACKGROUND

1.1 Introduction This Snubber Administrative Program Document establishes and defines the Snubber Inspection Program requirements. The primary purpose of this Snubber Inspection Program is to maintain the operational readiness of all Safety Related (Class 1, 2, and 3) and Non-Safety Related snubbers by periodically examining, testing, and monitoring service life to fulfill applicable plant operating commitments, American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI (ASME Section XI), and ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) requirements.

The Fifth Inservice Inspection (ISI) Interval is effective from January 15, 2013 through January 14, 2023 for Oyster Creek Generating Station (OCGS). With the update to the ISI Program for the Fifth ISI Interval for ISI Class 1, 2, and 3 components, including their supports, Exelon Generation Company, LLC (Exelon) has elected to update the Snubber Inspection Program documentation at this time. The ASME OM Code of Record for the Fifth Interval Snubber Inspection Program is the 2004 Edition through the 2006 Addenda.

Per 10CFR50.55a(b)(3)(v)(B), OCGS will use Subsection ISTD of the ASME OM Code 2004 Edition through the 2006 Addenda for the Fifth Interval Snubber Inspection Program. This is a change from the previous intervals when OCGS was committed to using Technical Specifications for the inspection of Snubbers.

Paragraph ISTA-3120(d) of ASME OM Code allows an inspection interval to be extended or decreased by as much as one year, and Paragraph ISTA-3120(e) allows an inspection interval to be extended when a unit is out of service continuously for six months or more. The extension may be taken for a period of time not to exceed the duration of the outage.

J, Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 8 of 32

1.2 Background

The construction permit for OCGS was issued on December 15, 1964. The Reactor Primary System (i.e., Reactor Vessel, Reactor Recirculating Piping, Isolation Condensers and all piping, pumps, and valves up to the first isolation valve with the exception of the Feedwater System where the break is at the second isolation valve) was fabricated, inspected and tested in accordance with the ASME Boiler and Pressure Vessel Code,Section I, Power Boilers, 1962 Edition and addenda plus the Nuclear Code Cases applicable on December 11, 1963.

1.3 Fourth Interval Snubber Inspection Program The OCGS Fourth Interval Snubber Inspection Program was developed in accordance with the requirements of OCGS Technical Specifications (TS) 3.5.A.8 and 4.5.M in lieu of the requirements of ASME Section XI, 1995 Edition through the 1996 Addenda per Relief Request R-38. The TS snubber visual examination program inspects safety related snubbers and incorporates the alternate snubber visual examination requirements delineated in Nuclear Regulatory Commission (NRC) Generic Letter (GL) 90-09, "Alternate Requirements for Snubber Visual Inspection Intervals and Corrective Actions." GL 90-09 was accepted by the NRC in the Safety Evaluation Report (SER) dated September 6, 1998. The general requirements of ASME Section XI, Subsection IWA for examination methods and personnel qualifications still applied.

At the end of the Fourth ISI Interval and in preparation for the Fifth ISI Interval, OCGS sent Relief Request R-41 to the NRC to request a three month extension from the original end date. This relief request was approved by the NRC and the changes allowed OCGS to extend from the original Fourth ISI Interval to beyond one year.

Therefore, the OCGS Fourth ISI Interval was effective from October 14, 2002 through January 14, 2013.

1.4 Fifth Interval Snubber Inspection Program Pursuant to 10CFR50.55a(g), licensees are required to update their ISI Programs to meet the requirements of ASME Section XI once every ten years or inspection interval. The ISI Program is required to comply with the latest Edition and Addenda of ASME Section XI incorporated by reference in I OCFR50.55a twelve months prior to the start of the interval per 10CFR50.55a(g)(4)(ii). Based on this date, the latest Edition and Addenda of ASME Section XI referenced in 10CFR50.55a(b)(2) twelve months prior to the start of the Fifth ISI Interval was the 2007 Edition with the 2008 Addenda.

212LU Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 9 of 32 Concurrently, the OCGS Fifth Interval Snubber Administrative Program Document was developed in accordance with the requirements of 10CFR50.55a and the ASME OM Code, 2004 Edition through the 2006 Addenda, subject to the limitations and modifications contained within Paragraph (b) of the regulation.

These limitations and modifications are detailed in Table 1.5-1 of this section.

This Fifth Interval Snubber Administrative Program Document addresses Subsection ISTA, Subsection ISTD, approved ASME Code Cases, approved alternatives through relief requests and SER's, and utilizes the inspection requirements as defined therein.

The OCGS Fifth ISI Interval is effective from January 15, 2013 through January 14, 2023. However, OCGS operations are planned to cease by the end of 2019 as previously announced.

1.5 Code of Federal Regulations 10CFR50.55a Requirements There are certain Paragraphs in I 0CFR50.55a that list the limitations, modifications, and/or clarifications to the implementation requirements of ASME OM Code, Subsection ISTD. These Paragraphs in 10CFR50.55a that are applicable to OCGS are detailed in Table 1.5-1.

LZ'A M-L Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 10 of 32 TABLE 1.5-1 CODE OF FEDERAL REGULATIONS 10CFR50.55a REQUIREMENTS 10CFR50.55a Paragraphs Limitations, Modifications, and Clarifications I OCFR50.55a(b)(3)(v)(B)

(ISI) Subsection ISTD: Article IWF-5000, "Inservice Inspection Requirements for Snubbers," of the ASME B&PV Code,Section XI, must be used when performing inservice inspection examinations and tests of snubbers at nuclear power plants, except as conditioned in Paragraph (b)(3)(v)(B) of this section. (B) Licensees shall comply with the provisions for examining and testing snubbers in Subsection ISTD of the ASME OM Code and make appropriate changes to their technical specifications or licensee-controlled documents when using the 2006 Addenda and later editions and addenda of Section XI of the ASME B&PV Code.

10CFR50.55a(b)(6)

Operation and Maintenance of Nuclear Power Plants Code Cases: Licensees may apply the ASME Operation and Maintenance Nuclear Power Plants Code Cases listed in Regulatory Guide 1.192 without prior NRC approval subject to the following:

(i) When a licensee initially applies a listed Code Case, the licensee shall apply the most recent version of that Code Case incorporated by reference in this paragraph.

(ii) If a licensee has previously applied a Code Case and a later version of the Code Case is incorporated by reference in this paragraph, the licensee may continue to apply, to the end of the current 120-month interval, the previous version of the Code Case as authorized or may apply the later version of the Code Case, including any NRC-specified conditions placed on its use.

(iii) Application of an annulled Code Case is prohibited unless a licensee previously applied the listed Code Case prior to it being listed as annulled in Regulatory Guide 1.192.

If a licensee has applied a listed Code Case that is later listed as annulled in Regulatory Guide 1.192, the licensee may continue to apply the Code Case to the end of the current 120-month interval.

A*'1 Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 11 of 32 1.6 Code Cases Per 10CFR50.55a(b)(6), ASME Code Cases that have been determined to be suitable for use in the Snubber Inspection Program by the NRC are listed in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code". The approved Code Cases in Regulatory Guide 1.192, which are being utilized by OCGS, are included in Section 2.1.1. The most recent version of a given Code Case incorporated in the revision of Regulatory Guide 1.192 referenced in IOCFR50.55a(b)(6)(i) at the time it is applied within the Snubber Inspection Program shall be used. The latest version of Regulatory Guide 1.192 incorporated into this document is Revision 0. As this guide is revised, newly approved Code Cases will be assessed for plan implementation at OCGS per Paragraph ISTA-3200(e) and proposed for use in revisions to the Snubber Administrative Program Document.

The use of other Code Cases (than those listed in Regulatory Guide 1.192) may be authorized by the Director of the Office of Nuclear Reactor Regulation upon request pursuant to 10CFR50.55a(a)(3). Code Cases not approved for use in Regulatory Guide 1.192, which are being utilized by OCGS through associated relief requests, are included in Section 5.0.

1.7 Relief Requests In accordance with 10CFR50.55a, when a licensee either proposes alternatives to ASME OM Code requirements which provide an acceptable level of quality and safety, determines compliance with ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or determines that specific ASME OM Code requirements for inservice inspection or testing are impractical, the licensee shall notify the NRC and submit information to support the determination.

The submittal of this information will be referred to in this document as a "Relief Request". Relief Requests for the Fifth Interval Snubber Inspection Program document. The text of the Relief Requests contained in Section 5.0 will demonstrate one of the following: the proposed alternatives provide an acceptable level of quality and safety per 10CFR50.55a(a)(3)(i), compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety per 10CFR50.55a(a)(3)(ii), or the code requirements are considered impractical per 10CFR50.55a(g)(5)(iii).

Per 10CFR50.55a Paragraphs (a)(3) and (g)(6)(i), the Director of the Office of Nuclear Reactor Regulation will evaluate relief requests and "may grant such relief and may impose such alternative requirements as it determines is authorized A'.-

Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 12 of 32 by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility".

ANNL Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 13 of 32 2.0 BASIS FOR SNUBBER INSPECTION PROGRAM 2.1 ASME OM Code Examination and Testing Requirements As required by the 10CFR50.55a, this Program was developed in accordance with the requirements detailed in the 2004 Edition through the 2006 Addenda of the ASME OM Code, Subsection ISTD, approved ASME Code Cases, and approved alternatives through relief requests and Safety Evaluations (SE's).

2.1.1 ASME OM Code Cases As referenced by 10CFR50.55a(b)(6) and allowed by NRC Regulatory Guide 1.192, the following Code Cases can be incorporated into the OCGS Snubber Inspection Program if they meet the requirements of Paragraph ISTA-3130(b) and (c).

OMN-13 Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants. Regulatory Guide 1.192.

Additional Code Cases invoked in the future shall be in accordance with those approved for use in the latest published revision of Regulatory Guide 1.192 or 10CFR50.55a at that time.

2.2 Augmented Examination and Testing Requirements Augmented examination and testing requirements are those examinations and tests that are performed above and beyond the requirements of ASME OM Code.

These examinations and tests are those that will be performed in addition to the requirements of ASME OM Code on a routine basis during the Fifth Interval Snubber Inspection Program. There are currently no augmented examinations and tests performed by OCGS that are not specifically addressed by the ASME OM Code.

2.3 Snubber Scope This OCGS Snubber Inspection Program applies to the snubber functional testing and visual examinations, and service life monitoring from pin connection to pin connection, and is conducted in accordance with the ASME OM Code. This program includes all snubbers necessary to protect the primary coolant pressure boundary and any other safety system or components that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident (i.e., all safety-related snubbers.)

SIL Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 14 of 32 2.4 Snubber Drawings and Details OCGS has two (2) types of snubbers (Mechanical and Hydraulic). Drawings for these snubbers can be found in the vendor manuals VM-OC-0026 for Pacific Scientific Mechanical Snubbers, and VM-OC-0006 for Hydraulic Shock and Sway Arrestors.

This section of the document includes information with regard to the actual snubber population and the different types, models, and sizes of snubbers utilized by OCGS. A complete listing of all the OCGS ASME OM Code snubbers within the scope of the visual examination and functional testing requirements is provided in the program database and in Table 2.4-1.

SAutomated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 15 of 32 TYPE POSITION SYSTEM /

LOCATION PIMS ID ALT I.D.#

DESCRIPTION NUMBER (GP #)

MECHANICAL N-1-1 NORTH STEAM DRYWELL 27' 411-MS-1-S7 0029\\B MECHANICAL N-1-2 NORTH STEAM DRYWELL 27' 411-MS-1-S6 0029\\A MECHANICAL N-1-3 NORTH STEAM DRYWELL 48' 411-0027 MS-l-S5 MECHANICAL N-1-4 NORTH STEAM DRYWELL 49' 411-0026 MS-1-S4 MECHANICAL N-i-5 NORTH STEAM DRYWELL 48' 411-0024 MS-I-S3 MECHANICAL N-1-6 NORTH STEAM DRYWELL 49' 411-0023 MS-I-S2 MECHANICAL N-1-7 NORTH STEAM DRYWELL 55' 411-0022 MS-I-Si MECHANICAL S-I-I SOUTH STEAM DRYWELL 26' 411-MS-I-S14 0009\\B MECHANICAL S-1-2 SOUTH STEAM DRYWELL 26' 411-MS-I-S13 0009\\A MECHANICAL S-1-3 SOUTH STEAM DRYWELL 48' 411-0007 MS-i-S 12 MECHANICAL S-1-4 SOUTH STEAM DRYWELL 49' 411-0006 MS-I-Si1 MECHANICAL S-1-5 SOUTH STEAM DRYWELL 48' 411-0004 MS-i-S10 MECHANICAL S-1-6 SOUTH STEAM DRYWELL 49' 411-0003 MS-I-S9 MECHANICAL S-1-7 SOUTH STEAM DRYWELL 55' 411-0002 MS-1-S8 MECHANICAL N-2-1 NORTH FEED DRYWELL 30' 422-RF-2-S6 0027\\A MECHANICAL N-2-2 NORTH FEED DRYWELL 30' 422-RF-2-S6A 0027\\B MECHANICAL N-2-3 NORTH FEED DRYWELL 51' 422-0025 RF-2-S5 MECHANICAL N-2-4 NORTH FEED DRYWELL 47' 422-0024 RF-2-S5A MECHANICAL N-2-5 NORTH FEED DRYWELL 48' 422-0021 RF-2-S4 MECHANICAL N-2-7 NORTH FEED DRYWELL 48' 422-0017 RF-2-S1 MECHANICAL N-2-8 NORTH FEED DRYWELL 47' 422-0018 RF-2-S2 MECHANICAL S-2-1 SOUTH FEED DRYWELL 30' 422-RF-2-S 11 001 2\\A MECHANICAL S-2-2 SOUTH FEED DRYWELL 30' 422-RF-2-S12 0012\\1B MECHANICAL S-2-3 SOUTH FEED DRYWELL 51' 422-0010 RF-2-S9 MECHANICAL S-2-4 SOUTH FEED DRYWELL 47' 422-0009 RF-2-S 10 MECHANICAL S-2-5 SOUTH FEED DRYWELL 48' 422-0006 RF-2-S4A MECHANICAL S-2-7 SOUTH FEED DRYWELL 48' 422-0002 RF-2-S8 MECHANICAL S-2-8 SOUTH FEED DRYWELL 48' 422-0003 RF-2-S7 MECHANICAL N-14-1 ISO CONDENSER DRYWELL 58' 211-0002 NE-2-S1 MECHANICAL N-14-2 ISO CONDENSER DRYWELL 67' 211-0004 NE-2-S3A MECHANICAL N-14-3 ISO CONDENSER DRYWELL 85' 211-NE-2-S3 0005\\B MECHANICAL N-14-4 ISO CONDENSER DRYWELL 85' 211-NE-2-S2 0005\\A MECHANICAL N-14-5 ISO CONDENSER DRYWELL 62' 211-0022 NE-2-S4 MECHANICAL N-14-6 ISO CONDENSER DRYWELL 67' 211-0023 NE-2-S5 MECHANICAL N-14-7 ISO CONDENSER DRYWELL 85' 211-NE-2-S6 0025\\A 9 M Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 16 of 32 TYPE POSITION SYSTEM /

LOCATION PIMS ID ALT I.D.#

DESCRIPTION NUMBER (GP#N MECHANICAL N-14-8 ISO CONDENSER DRYWELL 85' 211-NE-2-S7 0025\\13 MECHANICAL N-14-9 ISO CONDENSER DRYWELL 89' 211-NE-5-S1 0058\\A MECHANICAL N-14-10 ISO CONDENSER DRYWELL 88' 211-NE-5-S2 0058\\1B MECHANICAL N-14-11 ISO CONDENSER DRYWELL 88' 211-NE-5-S3 0039\\A MECHANICAL N-14-12 ISO CONDENSER DRYWELL 85' 211-NE-5-S4 0039\\1B MECHANICAL 16-1 CLEANUP DRYWELL 60' 215-ND-I-SI 00 14\\A MECHANICAL 16-2 CLEANUP DRYWELL 60' 215-ND-I-S2 0014\\13 MECHANICAL 16-3 CLEANUP DRYWELL 60' 215-ND-10-SI 0004\\A MECHANICAL 16-4 CLEANUP DRYWELL 60' 215-ND-10-$2 0004\\1 MECHANICAL 17-1 S/D COOLING DRYWELL 58' 214-NU-2-SI 0019\\A MECHANICAL 17-2 S/D COOLING DRYWELL 58' 214-NU-2-S2 0019\\1B MECHANICAL 17-3 S/D COOLING DRYWELL 48' 214-0002 NU-1-S1 MECHANICAL 17-4 S/D COOLING DRYWELL 49' 214-0004 NU-1-$2 MECHANICAL 17-5 S/D COOLING DRYWELL 42' 214-NU-1-$3 0006\\A MECHANICAL 17-6 S/D COOLING DRYWELL 42' 214-NU-1-S4 0006\\13 MECHANICAL N-20-1 N CORE SPRAY DRYWELL 61' 212-NZ-3-S2A 0005\\A MECHANICAL N-20-2 N CORE SPRAY DRYWELL 61' 212-NZ-3-S2B 0005\\1B MECHANICAL N-20-3 N CORE SPRAY DRYWELL 65' 212-0002 NZ-3-S3 MECHANICAL N-20-4 N CORE SPRAY DRYWELL 67' 212-0001 NZ-3-S4 MECHANICAL S-20-2 S CORE SPRAY DRYWELL 98' 212-0051 NZ-3-S8 MECHANICAL 75-26 AUG FUEL POOL RX BLDG 84' 251-0053 NN-1-$27 MECHANICAL N-E-1 EMRV NORTH DRYWELL 47' 212-0163 SV-1-S1 MECHANICAL N-E-2 EMRV NORTH DRYWELL 47' 212-0165 SV-1-S2 MECHANICAL S-E-1 EMRV SOUTH DRYWELL 47' 212-0155 SV-1-S3 MECHANICAL S-E-2 EMRV SOUTH DRYWELL 44' 212-0158 SV-1-S4 MECHANICAL S-E-3 EMRV SOUTH DRYWELL 51' 212-0159 SV-1-S5 MECHANICAL A-1 A RECIRC DRYWELL 30' 223-NG-A-S3 0009\\A MECHANICAL A-2 A RECIRC DRYWELL 30' 223-NG-A-S4 0009\\B MECHANICAL A-3 A RECIRC DRYWELL 15' 223-NG-A-5 1

010\\A IL Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 17 of 32 TYPE POSITION SYSTEM /

LOCATION PIMS ID ALT I.D.#

DESCRIPTION NUMBER (GP #)

MECHANICAL A-4 A RECIRC DRYWELL 15' 223-NG-A-S6 0010\\1B MECHANICAL B-i B RECIRC DRYWELL 30' 223-NG-B-S3 0020\\A MECHANICAL B-2 B RECIRC DRYWELL 30' 223-NG-B-S4 0020\\B MECHANICAL B-3 B RECIRC DRYWELL 15' 223-NG-B-S5 0021\\A MECHANICAL B-4 B RECIRC DRYWELL 15' 223-NG-B-S6 002 1 \\B MECHANICAL C-1 C RECIRC DRYWELL 30' 223-NG-C-S3 003 1 \\A MECHANICAL C-2 C RECIRC DRYWELL 30' 223-NG-C-S4 003 1\\13 MECHANICAL C-3 C RECIRC DRYWELL 15' 223-NG-C-S5 0032\\A MECHANICAL C-4 C RECIRC DRYWELL 15' 223-NG-C-S6 0032\\1B MECHANICAL D-1 D RECIRC DRYWELL 30' 223-NG-D-S3 0042\\A MECHANICAL D-2 D RECIRC DRYWELL 30' 223-NG-D-S4 0042\\B MECHANICAL D-3 D RECIRC DRYWELL 15' 223-NG-D-S5 0043\\A MECHANICAL D-4 D RECIRC DRYWELL 15' 223-NG-D-S6 0043\\1B MECHANICAL E-1 E RECIRC DRYWELL 30' 223-NG-E-S3 0053\\A MECHANICAL E-2 E RECIRC DRYWELL 30' 223-NG-E-S4 0053\\1B MECHANICAL E-3 E RECIRC DRYWELL 15' 223-NG-E-S5 0054\\A MECHANICAL E-4 E RECIRC DRYWELL 15' 223-NG-E-S6 0054\\B MECHANICAL SDVI S D VOLUME RX BLDG 25' 225-0046 NC-i MECHANICAL 51/23 CORE SPRAY 2 RX BLDG 59' 212-0070 NZ-2-S15A MECHANICAL 51/24 CORE SPRAY 2 RX BLDG 59' 212-0071 NZ-2-S15B HYDRAULIC

-19/6 CONT. SPRAY RX BLDG 19' 241-NQZ-I-S12 0114\\B HYDRAULIC

-19/7 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S11 0 1 14\\A HYDRAULIC

-19/8 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S1O 0109\\B HYDRAULIC

-19/9 CONT. SPRAY RX BLDG 19' 241-NQZ-I-S9 0109\\A HYDRAULIC

-19/10 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S8 0106\\B 2alll Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 18 of 32 TYPE POSITION SYSTEM /

LOCATION PIMS ID ALT I.D.#

DESCRIPTION NUMBER (GP #)

HYDRAULIC

-19/11 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S7 01 06\\A HYDRAULIC

-19/12 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S6 0100\\B HYDRAULIC

-19/13 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S5 01 00\\A HYDRAULIC

-19/14 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S4 0098\\1B HYDRAULIC

-19/15 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S3 0098\\A HYDRAULIC

-19/16 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S2 0094\\B HYDRAULIC

-19/17 CONT. SPRAY RX BLDG 19' 241-NQZ-1-S1 0094\\A HYDRAULIC

-19/18 CORE SPRAY RX BLDG 19' 212-0025 NZ-2-S1 HYDRAULIC

-19/19 CORE SPRAY RX BLDG 19' 212-0023 NZ-2-S2 HYDRAULIC 15/1 A FEEDWATER FEED PUMP RM 422-1017 RF-1-SI HYDRAULIC 15/2 B FEEDWATER FEED PUMP RM 422-1018 RF-1-S2 HYDRAULIC 17/1 C FEEDWATER FEED PUMP RM 422-1019 RF-I-S3 HYDRAULIC 20/1 CORE SPRAY RX BLDG 20' 212-0021 NZ-2-S3 HYDRAULIC 20/2 CORE SPRAY RX BLDG 20' 212-0020 NZ-2-S4 HYDRAULIC 20/5 CORE SPRAY RX BLDG 20' 212-0086 NZ-2-S1O HYDRAULIC 20/6 CORE SPRAY RX BLDG 20' 212-0085 NZ-2-S 11 HYDRAULIC 23/1 CORE SPRAY RX BLDG 23' 212-0074 NZ-2-S13 HYDRAULIC 23/2 CORE SPRAY RX BLDG 23' 212-0078 NZ-2-S12 HYDRAULIC 23/3 CONT. SPRAY RX BLDG 23' 241-0032 NQ-2-S14 HYDRAULIC 23/4 CONT. SPRAY RX BLDG 23' 241-0035 NQ-2-S13 HYDRAULIC 23/5 CONT. SPRAY RX BLDG 23' 241-0034 NQ-2-S12 HYDRAULIC 23/6 CONT. SPRAY RX BLDG 23' 241-0037 NQ-2-S1 1 HYDRAULIC 23/7 CONT. SPRAY RX BLDG 23' 241-0039 NQ-2-SIO HYDRAULIC 51/5 CORE SPRAY RX BLDG 51' 212-0015 NZ-2-S5 HYDRAULIC 51/6 CORE SPRAY RX BLDG 51' 212-0040 NZ-2-S9 HYDRAULIC 51/7 CORE SPRAY RX BLDG 51' 212-0013 NZ-2-S6 HYDRAULIC 51/8 CORE SPRAY RX BLDG 51' 212-0011 NZ-2-S7 HYDRAULIC 51/9 CORE SPRAY RX BLDG 51' 212-0009 NZ-2-S8 HYDRAULIC 51/10 CORE SPRAY RX BLDG 51' 212-0007 NZ-3-S1 HYDRAULIC 51/11 S/D COOLING RX BLDG 51' 214-0025 NU-2-S5 HYDRAULIC 51/12 S/D COOLING RX BLDG 51' 214-0024 NU-2-S5A HYDRAULIC 51/14 S/D COOLING RX BLDG 51' 214-0027 NU-2-S9 HYDRAULIC 51/15 S/D COOLING RX BLDG 51' 214-0035 NU-2-S10 HYDRAULIC 51/20 S/D COOLING RX BLDG 51' 214-0008 NU-1-S5 HYDRAULIC 51/21 CORE SPRAY RX BLDG 51' 212-0068 NZ-2-S14 HYDRAULIC 51/22 CORE SPRAY R.X BLDG 51' 212-0065 NZ-2-S15 HYDRAULIC 75/1 CORE SPRAY RX BLDG 75' 212-0062 NZ-2-S17 HYDRAULIC 75/2 CORE SPRAY RX BLDG 75' 212-0063 NZ-2-S16 Uk~

Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 19 of 32 TYPE POSITION SYSTEM /

LOCATION PIMS ID ALT I.D.#

DESCRIPTION NUMBER (GP #)

HYDRAULIC 75/3 CORE SPRAY RX BLDG 75' 212-0058 NZ-3-S5 HYDRAULIC 75/4 CORE SPRAY RX BLDG 75' 212-0060 NZ-2-S18 HYDRAULIC 75/5 CORE SPRAY RX BLDG 75' 212-0055 NZ-3-S6 HYDRAULIC 75/7 ISO CONDENSER RX BLDG 75' 211-0127 NONE HYDRAULIC 75/8 ISO CONDENSER RX BLDG 75' 211-0006 NE-2-S 15 HYDRAULIC 75/9 ISO CONDENSER RX BLDG 75' 211-0041 NE-5-S6 HYDRAULIC 75/10 ISO CONDENSER RX BLDG 75' 211-0015 NE-2-S9 HYDRAULIC 75/11 ISO CONDENSER RX BLDG 75' 211-0016 NE-2-S8 HYDRAULIC 75/12 ISO CONDENSER RX BLDG 75' 211-0014 NE-2-S10 HYDRAULIC 75/13 ISO CONDENSER RX BLDG 75' 211-0028 NE-2-S20 HYDRAULIC 75/14 ISO CONDENSER RX BLDG 75' 211-0128 NONE HYDRAULIC 75/15 ISO CONDENSER RX BLDG 75' 211-0030 NE-2-S19 HYDRAULIC 75/16 ISO CONDENSER RX BLDG 75' 211-0065 NE-1-S1 HYDRAULIC 75/17 ISO CONDENSER RX BLDG 75' 211-0019 NE-2-S13 HYDRAULIC 75/18 ISO CONDENSER RX BLDG 75' 211-0020 NE-2-S14 HYDRAULIC 75/19 ISO CONDENSER RX BLDG 75' 211-0012 NE-2-S1 1 HYDRAULIC 75/20 ISO CONDENSER RX BLDG 75' 211-0010 NE-2-S12 HYDRAULIC 75/21 ISO CONDENSER RX BLDG 75' 211-0032 NE-2-S21 HYDRAULIC 75/22 ISO CONDENSER RX BLDG 75' 211-0034 NE-2-S 18 HYDRAULIC 75/23 ISO CONDENSER RX BLDG 75' 211-0047 NE-1-S8 HYDRAULIC 75/24 ISO CONDENSER RX BLDG 75' 211-0046 NE-I-S7 HYDRAULIC 75/25 ISO CONDENSER RX BLDG 75' 211-0036 NE-2-$17 HYDRAULIC 95/1 ISO CONDENSER RX BLDG 95' 211-0066 NE-1-S5 HYDRAULIC 95/2 ISO CONDENSER RX BLDG 95' 211-0070 NE-1-$3 HYDRAULIC 95/3 ISO CONDENSER RX BLDG 95' 211-0071 NE-1-S3A HYDRAULIC 95/4 ISO CONDENSER RX BLDG 95' 211-0073 NE-1-S4 HYDRAULIC 95/5 ISO CONDENSER RX BLDG 95' 211-0050 NE-1-S12A HYDRAULIC 95/6 ISO CONDENSER RX BLDG 95' 211-0048 NE-i-S12 HYDRAULIC 95/7 ISO CONDENSER RX BLDG 95' 211-0052 NE-I-S9 HYDRAULIC 95/8 ISO CONDENSER RX BLDG 95' 211-0053 NE-I-S10 HYDRAULIC 95/9 ISO CONDENSER RX BLDG 95' 211-0055 NE-I-S 11 2.5 Technical Approach and Positions When the requirements of ASME OM Code are not easily interpreted, OCGS has the option to review general licensing/regulatory requirements and industry practice to determine a practical method of implementing the Code requirements. The Technical Approach and Position (TAP) documents contained in this section have been provided to clarify OCGS's implementation of ASME OM Code requirements.

Currently OCGS does not have any TAP's, however, an index which is used to summarize each technical approach and position is included in Table 2.5-1.

/l Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 20 of 32 TABLE 2.5-1 TECHNICAL APPROACH AND POSITIONS INDEX Position Number 15T-XX (Program) Description of Technical Approach and Position U

Note 1: Technical Approach and Position Status Options: Active - Current Snubber Inspection Program Technical Approach and Position is being utilized at OCGS; Deleted - Technical Approach and Position is no longer being utilized at OCGS.

Note 2: The revision listed is the latest revision of the subject technical approach and position. The date noted in the second column is the date of the Snubber Administrative Program Document revision when the Technical Approach and Position was incorporated into the document.

U!m Automated Engineering Sernces Corp

ER-OC-330-5004 Revision 0 Page 21 of 32 3.0 SNUBBER PLAN The OCGS Snubber Plan includes equipment dynamic restraints (snubbers) as defined in ASME OM Code 2004 Edition through the 2006 Addenda, Paragraph ISTA-2000.

Procedures ER-AA-330-004 "Visual Examination of Snubbers", ER-AA-330-010 "Snubber Functional Testing", and ER-AA-330-011 "Snubber Service Life Monitoring",

implement the ASME OM Code Snubber Plan.

3.1 Nonexempt ISI Class Supports The OCGS ISI Class 1, 2, and 3 nonexempt supports are those which do not meet the exemption criteria of Paragraph IWF-1230 of ASME Section XI. A summary of the OCGS ASME Section XI nonexempt supports is included in Section 7.0 of the ISI Program Plan.

3.1.1 Identification of ISI Class 1, 2, and 3 Nonexempt Supports ISI Class 1, 2, and 3 supports are identified on the ISI Isometric and Component Sketches listed in Section 2.4, Table 2.4.1 of the OCGS ISI Program Plan. Supports are identified by controlled OCGS individual support detail drawings.

3.2 Snubber General Requirements 3.2.1 As allowed by 10CFR50.55a(b)(3)(v)(B), OCGS will use Subsection ISTD, "Inservice Testing of Dynamic Restraints (Snubbers) In Light Water Reactor Power Plants," ASME Operation and Maintenance of Nuclear Power Plants Code (ASME OM Code), 2004 Edition through the 2006 Addenda, to meet the visual examination, functional testing, and service life monitoring requirements for safety-related and non safety-related snubbers. This approach is consistent with ASME Section XI, Paragraph IWF-1220, which excludes inservice inspection of snubbers and defers to the ASME OM Code for examination, testing, and monitoring requirements.

Procedure ER-AA-330-004 implements the visual inspection program for safety-related and non safety-related snubbers. Procedures ER-AA-330-010, ER-AA-330-01 1, and station surveillance test procedures are used to implement the functional testing and service life monitoring requirements for safety-related and non safety-related snubbers.

The ASME OM Code specifies the functional testing and visual examination, and service life monitoring requirements for snubbers in the ASME OM Code, Subsection ISTD. ASME Section XI also has Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 22 of 32 inspection requirements for supports that apply to snubbers, as well as to other supports. This Snubber Plan is in place to provide a link between the functional testing and visual examination of the snubbers performed at OCGS per the ASME OM Code and the ASME Section XI visual examination requirements.

The general requirements of ASME Section XI, Subsection IWA, such as examination methods, personnel qualifications, etc., will still apply.

Additionally, examination of integral and non-integral attachments, all repairs, replacements, records and reports will be performed in accordance with ASME Section XI.

3.3 Visual Examination, Functional Testing, and Service Life Monitoring Program 3.3.1 The visual examination of all snubbers included in this program shall be performed in accordance with procedures ER-AA-330-004 and ER-AA-335-016. The required examination schedule is determined by Paragraph ISTD-4252 and Table ISTD-4252-1 of the ASME OM Code.

Visual Examinations shall be performed by individuals qualified in accordance with OCGS procedures.

The ASME Section XI visual examination boundary of a support containing a snubber is defined in Figure IWF-1300-1(f). This boundary does not include the snubber pin-to-pin and does not include the connections to the snubber assembly (pins) per Paragraph IWF-1300(h).

This results in the remaining ASME Section XI requirements for VT-3 visual examinations of the snubber attachment hardware including bolting and clamps. The ASME Section XI ISI Program uses Subsection IWF to define the inspection requirements for all ISI Class 1, 2, and 3 supports, regardless of type. The ISI Program maintains the Code Class snubbers in the support populations subject to inspection per Subsection IWF. This is done to facilitate scheduling, preparation including insulation removal, and inspection requirements of the snubber attachment hardware (e.g.,

bolting and clamps).

It should be noted that the examination of snubber welded attachments will be performed in accordance with the ASME Section XI Subsections IWB, IWC, and IWD welded attachment examination requirements (e.g.,

Examination Categories B-K, C-C, and D-A).

3.3.2 The functional testing of snubbers shall be performed in accordance with procedure ER-AA-330-010. Functional testing shall be scheduled every fuel cycle in accordance with the ASME OM Code. Snubbers are grouped I/*

Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 23 of 32 into Defined Test Plan Groups (DTPG's) by design type, in accordance with Paragraph ISTD-5252 for testing purposes. Snubbers at OCGS will be tested using the 10% sample plan. (See Section 3.3.2.2 below for Testing Sample Plan options.)

Functional testing of snubbers can be performed as a sampling of the entire snubber population per Article ISTD-5000.

3.3.2.1 Defined Test Plan Group (DTPG)

The DTPGs shall include all snubbers except replacement snubbers and snubbers repaired or adjusted as a result of not meeting the examination acceptance requirements of Subarticle ISTD-4200.

These snubbers shall be exempt for the concurrent test interval.

Except as required by Paragraph ISTD-5253, the total snubber population may be considered one DTPG, or alternatively, differences in design, application, size, or type may be considered in establishing DTPG's.

The snubbers at Oyster Creek will be split into two (2) DTPG's =

Mechanical Snubbers (Inaccessible) and Hydraulic Snubbers (Accessible).

3.3.2.2 Testing Sample Plans The snubbers of each DTPG shall be tested using the following:

(a) the 10% testing sample plan Nonmandatory Appendix D includes a comparison of sample plans. Snubber testing plans are presented in flow chart form in Nonmandatory Appendix E. A test plan shall be selected for each DTPG before the scheduled testing begins.

3.3.3 Service life monitoring of snubbers shall be performed in accordance with Article ISTD-6000 with the use of Nonmandatory Appendix F providing supplemental guidance. Additional implementation requirements for Service Life Monitoring are described in procedure ER-AA-330-01 1.

Snubbers shall be replaced or reconditioned as required to ensure that the service life is not exceeded between 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 ASME OM Code, ASME Section XI and OCGS procedures.

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Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 24 of 32 If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be re-evaluated 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.

3.4 Visual Examination, Functional Testing, and Service Life Monitoring Results 3.4.1 The results of the visual examinations and the functional tests will be evaluated using the criteria of the ASME OM Code and plant procedures.

ASME Section XI provisions may be used for supplemental guidance.

Snubbers that do not appear to conform to the Visual Examination requirements of procedure ER-AA-330-004, shall be reported for evaluation and appropriate corrective action.

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.

Snubbers that do not meet the operability testing acceptance criteria shall be evaluated to determine the cause of the failure and appropriate corrective action taken.

The service life of all snubbers is evaluated using manufacturing input and engineering information gained through consideration of the snubber service conditions and inservice functional test results.

3.5 Reports/Records 3.5.1 The visual examination and functional testing results will be recorded and kept in accordance with ASME OM Code and plant procedures. Repair and replacement records and reports will be kept in accordance with ASME Section XI.

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.

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Automated Engineefing Services Corp

ER-OC-330-5004 Revision 0 Page 25 of 32 4.0 SNUBBER

SUMMARY

TABLE 4.1 Snubber Inspection Summary Table 10CFR50.55a(b)(3)(v)(B) "Codes and Standards" allows usage of ASME OM Code, Subsection ISTD.

The following Table 4.1-1 provides a summary of the ASME OM Code, Subsection ISTD, Snubber visual examinations and functional testing for the Fifth Snubber Interval at OCGS.

The format of the Snubber Inspection Summary Table is as depicted below and provides the following information:

ASME OM Code OM Subarticle Subarticle Exam Totals Frequency Relief Notes Subsection (with Number Number Requirements Request/

Subsection Description TAP Description)

Number (1)

(2)

(3)

(4)

(5)

(6)

(7).

(8)

(1)

ASME OM Code Subsection:

Provides the applicable ASME OM Code subsection number and a description as obtained from Subsection ISTD. Only applicable subsections to OCGS are identified.

(2)

OM Subarticle Number:

Provides the subarticle number as identified in Subsection ISTD. Only those subarticle numbers applicable to OCGS are identified.

(3)

Subarticle Number

Description:

Provides the subarticle description as identified in Subsection ISTD. Identifies the methods selected to be performed at OCGS.

(4)

Examination Requirements:

Provides the visual examination and functional testing methods required by Subsection ISTD.

,'Oft Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 26 of 32 (5)

Totals:

Provides the total number of snubbers that pertain to that subarticle of Subsection ISTD. Note that the total number of snubbers are subject to change after completion of plant modifications and design changes.

(6)

Frequency:

Provides the frequency for visual examinations and functional testing as addressed in Subsection ISTD and approved ASME OM Code Cases.

(7)

Relief Requests/TAP Number:

Provides a listing of Relief Request/TAP Numbers to specific snubber components. Relief requests and TAP Numbers that generically apply to all components, or an entire class are not listed. If a Relief Request/TAP Number is identified, see the corresponding relief request in Section 5.0 or the TAP Number in Section 2.5.

(8)

Notes:

Provides a listing of program notes applicable to the Subsection ISTD subarticle number. If a program note number is identified, see the corresponding program note in Table 4.1-2.

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Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 27 of 32 TABLE 4.1-1 SNUBBER INSPECTION

SUMMARY

TABLE ASME OM Code OM Subarticle Subarticle Number Description Exam Totals Frequency Relief Request/

Notes Subsection (with Number Requirements TAP Number Subsection Description)

ISTD ISTD-4220 Accessible Snubbers - Hydraulic Visual, VT-3 74 Every Cycle 1

Snubber 1

3 Examinations Inaccessible Snubbers - Mechanical Visual, VT-3 84 Every Refuel I

I Outage 3

ISTD ISTD-5240 10% Functional Test Plan - Hydraulic Functional Testing 74 Every Cycle 2

Snubber Type Snubbers (Accessible)

Testing 10% Functional Test Plan - Mechanical Functional Testing 84 Every Refuel 2

Type Snubbers (Inaccessible)

Outage AA Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 28 of 32 TABLE 4.1-2 SNUBBER INSPECTION

SUMMARY

TABLE PROGRAM NOTES Note #

Note Summary II I

Examinations performed per Code Case OMN-13, "Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants."

2 Per the ASME OM Code, Subsection ISTD, 2004 Edition through the 2006 Addenda, Paragraph ISTD-5240 "Test Frequency."

3 Per the ASME OM Code, Subsection ISTD, 2004 Edition through the 2006 Addenda, Paragraph ISTD-4250 "Inservice Examination Intervals."

AWI Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 29 of 32 5.0 RELIEF REQUESTS FROM ASME OM Code This section contains relief requests written per 10CFR50.55a(a)(3)(i) for situations where alternatives to ASME requirements provide an acceptable level of quality and safety; per 10CFR50.55a(a)(3)(ii) for situations where compliance with ASME requirements results in a hardship or an unusual difficulty without a compensating increase in the level of quality and safety; and per 10CFR50.55a(g)(5)(iii) for situations where ASME requirements are considered impractical.

The following NRC guidance was utilized to determine the correct 10CFR50.55a paragraph citing for OCGS relief requests. IOCFR50.55a(a)(3)(i) and 10CFR50.55a(a)(3)(ii) provide alternatives to the requirements of ASME, while 1 OCFR50.55a(g)(5)(iii) recognizes situational impracticalities.

10CFR50.55a(a)(3')(i:

1 0CFR50.55a(a)(3)(ii):

Cited in relief requests when alternatives to the ASME requirements which provide an acceptable level of quality and safety are proposed.

Cited in relief requests when compliance with the ASME requirements is deemed to be a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Cited in relief requests when conformance with ASME requirements is deemed impractical.

An index for OCGS relief requests is included in Table 5.0-1. The "15R-XX" relief requests are applicable to Snubbers.

The following relief requests are subject to change throughout the inspection interval (e.g., NRC approval, withdrawal). Changes to NRC approved alternatives (other than withdrawal) require NRC approval.

A1l Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 30 of 32 TABLE 5.0-1 RELIEF REQUEST INDEX Relief Revision Status2 (Program) Description/

Request Date3 Approval Summary' 15R-XX Note 1: The NRC grants relief requests pursuant to 10CFR50.55a(g)(6)(i) when Code requirements cannot be met and proposed alternatives do not meet the criteria of 10CFR50.55(a)(3). The NRC authorizes relief requests pursuant to 10CFR50.55a(a)(3)(i) if the proposed alternatives would provide an acceptable level of quality and safety or under 10CFR50.55a(a)(3)(ii) if compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of safety.

Note 2: This column represents the status of the latest revision. Relief Request Status Options: Authorized -

Approved for use in an NRC SE (See Note 1); Granted - Approved for use in an NRC SE (See Note 1);

Authorized Conditionally - Approved for use in an NRC SE which imposes certain conditions; Denied -

Use denied in an NRC SE; Expired - Approval for relief has expired; Withdrawn - Relief has been withdrawn by OCGS; Not Required - The NRC has deemed the relief unnecessary in an SE or RAI; Cancelled - Relief has been cancelled by OCGS prior to issue; Submitted - Relief has been submitted to the NRC by the station and is awaiting approval; Pending - Relief has been awaiting station and Corporate review and submittal to the NRC.

Note 3: The revision listed is the latest revision of the subject relief request. The date this revision became effective is the date of the approving SE which is listed in the fourth column of the table. The date noted in the second column is the date of the Snubber Administrative Program Document revision when the relief request was incorporated into the document.

L,.Zu Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 31 of 32

6.0 REFERENCES

The references used to develop this Snubber Administrative Program Document include:

6.1 NRC References 6.1.1 Code of Federal Regulations, Title 10, Energy.

- Part 50, Paragraph 50.55a, "Codes and Standards."

- Part 50, Paragraph 2, "Definitions," the definition of "Reactor Coolant Pressure Boundary."

6.1.2 Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code."

6.2 Industry References 6.2.1 ASME Boiler and Pressure Vessel Code,Section XI, Division 1, "Inservice Inspection of Nuclear Power Plant Components," the 2007 Edition through the 2008 Addenda. (51h ISI Interval).

6.2.2 ASME Boiler and Pressure Vessel Code,Section III, Division 1, "Rules For Construction of Nuclear Power Plant Components," the 2007 Edition through the 2008 Addenda.

6.2.3 ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants," the 2004 Edition through the 2006 Addenda (Subsection ISTD).

6.3 Licensee References 6.3.1 Oyster Creek Generating Station, Updated Final Safety Analysis Report (UFSAR).

6.3.2 Oyster Creek Generating Station, Technical Specifications (TS).

6.3.3 Oyster Creek Generating Station, Operational Quality Assurance Plan (QAP).

6.3.4 Oyster Creek Generating Station ISI Program Plan (ER-OC-330-5001),

Fifth Ten-Year Inservice Inspection Interval.

6.3.5 Oyster Creek Generating Station ISI Classification Basis Document (ER-OC-330-5002), Fifth Ten-Year Inservice Inspection Interval.

6.3.6 Oyster Creek Generating Station ISI Selection Document (ER-OC-330-5003), Fifth Ten-Year Inservice Inspection Interval.

6.3.7 Oyster Creek Generating Station License Renewal Application, July 2005.

6.3.8 Procedure ER-AA-330, "Conduct of Inservice Inspection Activities."

6.3.9 Procedure ER-AA-330-003, "Inservice Inspection of Section XI Component Supports."

6.3.10 Procedure ER-AA-330-004, "Visual Examination of Snubbers."

6.3.11 Procedure ER-AA-330-009, "ASME Section XI Repair/Replacement Program."

OAu Automated Engineering Services Corp

ER-OC-330-5004 Revision 0 Page 32 of 32 6.3.12 Procedure ER-AA-330-010, "Snubber Functional Testing."

6.3.13 Procedure ER-AA-330-01 1, "Snubber Service Life Monitoring Program."

6.3.14 Procedure ER-AA-335-016, "VT-3 Visual Examination of Component Supports, Attachments, and Interiors of Reactor Vessels."

6.3.15 Procedure EP-0 11, "Methodology for Assigning and Maintaining the Quality Classification of Components."

6.4 License Renewal References 6.4.1 None.

21 Automated Engineering Services Corp

v t e Letter Sequence Request
TAC:MF4124, (Approved, Closed)
Initiation Request Acceptance Administration Questions 16 September 2014 Answers Results Approval Other:
MONTHYEAR2014-06-16 [Table View]

RA-14-046, Request for Amendment to Revise Oyster Creek Nuclear Generating Station Under Snubber Surveillance Requirements

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RA-14-046, Request for Amendment to Revise Oyster Creek Nuclear Generating Station Under Snubber Surveillance Requirements

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