L-2014-227, RAI Reply for Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Requirements
| ML14212A395 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/21/2014 |
| From: | Jensen J Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2014-227 | |
| Download: ML14212A395 (17) | |
Text
0FPL. July 21, 2014L-2014-227 10 CFR 50.90 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001
Subject:
St. Lucie Unit 2 Docket No. 50-389 RAI Reply for Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Requirements
References:
- 1. FPL Letter L-2014-077 dated January 30, 2014, "Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Requirements,"
ADAMS Accession No. ML14049A284
- 2. NRC email dated July 3, 2014, "Request for Additional Information Regarding Proposed License Amendment Request Changes to Snubber Surveillance Requirements Florida Power & Light Company (FPL) St. Lucie Unit 2 Docket No. 50-389 (TAC No.
MF3470)," ADAMS Accession No. ML14172A149 In Reference I above, pursuant to 10 CFR 50.90, Florida Power & Light (FPL) submitted a Technical Specification (TS) amendment request that would revise the TS surveillance requirements (SRs) for snubbers to conform to revisions to the Snubber Testing Program.
In Reference 2 above, the NRC requested that FPL provide additional information to facilitate the staff's review of the license amendment. The attachments to this letter provide the FPL reply to the request for additional information (RAI).
Attachment I provides the FPL response to the RAIs. Attachment 2 provides conforming TS markups for RAI reply driven changes. Attachment 3 provides the conforming revision to the Snubber Testing Program.
The no significant hazards consideration determination within Reference 1 bounds the scope of this RAI reply.
If you should have any questions, please contact Mr. Ken Frehafer at (772) 467-7748.
Florida Power &Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2014-227 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, sident St. Lucie Plant JJ/KWF Attachments:
- 1. RAI Reply
- 2. Conforming Technical Specification Changes (Mark-Up)
- 3. Conforming Changes to the Proposed Snubber Program Plan cc: NRC Region II Administrator St. Lucie Plant NRC Senior Resident Inspector
L-2014-227 Attachment 1 Page 1 of 5 RAI 1 , "Description and Assessment", Section 2.0, Detailed Description, Page 1, states that St. Lucie Unit 2 third 10-year ISI interval ending date was August 7, 2013. The snubber surveillance program is being removed from the ISI program under the ASME Section Xl inspection requirements to comply with the ASME OM Code, Subsection ISTD requirements.
Allowing for a 1 year extension to the existing interval for the snubber program transition, in accordance with ASME OM Code, Subsection ISTA-3120(d), the fourth 10-year interval for snubbers at St. Lucie Unit 2 will begin on August 8, 2014. Currently, snubber testing and examination are performed in accordance with the requirements of TS 3/4.7.9 and St. Lucie Unit 2 third 10-Year ISI Interval Program submitted in letter L-2003-189, dated August 6, 2003 and will continue until August 7, 2014."
a) FPL letter L-2003-189, dated 6, 2003, regarding third 10-year ISI interval at St. Lucie Unit 2 states that St. Lucie Unit 2 third 10-year ISI program is based on ASME Section Xl 1998 Edition with Addenda through 2000. Please verify and confirm that for the snubber program for the third 10-year interval is also based on ASME Section Xl, 1998 Edition with Addenda through 2000.
b) The licensee is proposing to adopt ASME OM Code Subsection ISTD for the snubber program for the fourth 10-year ISI interval. Therefore, the one year extension of the snubber program from the end date of August 7, 2013 to August 7, 2014 for the third 10-year ISI interval cannot be based on the ASME OM Code, Subsection ISTA-3120(d).
Please provide the appropriate reasoning and section from the ASME Section Xl for extension for third 10-year ISI interval for snubber.
c) Please confirm that the one year extension for the third 10 year ISI interval is only for snubber program RAI I RESPONSE a) FPL letter L-2003-189, dated August 6, 2003, includes the submittal of the Third Inservice Inspection Interval Program for St. Lucie Unit 2 third 10-year ISI program which is based on ASME Section Xl 1998 Edition with Addenda through 2000. This Program includes a reference to the Snubber Program under paragraph 1.2.3, which states "The program for examination and testing of safety-related snubbers is addressed by St.
Lucie Plant procedures." Snubbers are functionally tested under the SL2 approved Technical Specification requirements of Section 3/4.7.9, plant procedure QI-10-PR/PSL-6 and the ASME OM Code, Subsection ISTD, 2001 Edition with Addenda through 2003, which is an acceptable alternative to ASME Section Xl 1998 Edition with Addenda through 2000 as allowed by 10 CFR 50.55a(b)(3)(v).
b) The corresponding reference under the ASME Section Xl Code for an extension of one year would be Section IWA-2430(d)(1). The reference to ASME OM Code, Subsection ISTA-3120(d) was used since the snubber program was already in accordance with the requirements of the OM Code, Subsection ISTD 2001 Edition with 2003 Addenda at the time, as well as the requirements of TS 3/4.7.9.
L-2014-227 Attachtnent 1 Page 2 of 5 c) The one year extension requested in this submittal, for the third 10 year ISI interval, is for the snubber program only.
RAI 2
In Section 3.0, "Technical Evaluation," the second paragraph states that "As noted in Regulatory Issue Summary (RIS) 2010-006, the licensees have the option to control the ASME Code-required IS[ and testing of snubbers through their TS or other licensee-control documents. For plants using their TS to govern ISI and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4),
licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRC-approved alternative used in lieu of the Code requirements."
RIS 2010-06 also states that "The TS, TRM, or other licensee-controlled documents, governing the snubber ISI and testing program, do not eliminate the 10 CFR50.55a requirements to update the program at 120-month intervals, in accordance with 10 CFR 50.55a(g)(4), or to request and receive NRC authorization for alternatives to the Code requirements, when appropriate."
a) The licensee is requested to provide details about the action taken for the snubber program at St. Lucie Unit 2 in response to RIS-2010-006 and Enforcement Guidance Memorandum (EGM) 2010-01.
b) The licensee is requested to provide detailed evaluation and compatibility of snubber examination and testing requirements of the TS 3/4.7.9, and the "Code of Record" for the third 10-year ISI interval snubber program ("Code of Record" for the third 10-year ISI interval at Turkey Point 3 & 4 is ASME Section Xl, IWF-5000, 1998 Edition with 2000 Addenda)
RAI 2 RESPONSE a) The snubber program documents at St. Lucie Unit 2 (TS 3/4.7.9 and QI-10-PR/PSL-6) were reviewed against the requirements of RIS-2010-006. RIS-2010-006 includes the statement that "10 CFR 50.55a(b)(3)(v) allows the optional use of Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code-1995 Edition through the latest edition and addenda, in lieu of ASME BPV Code, Section Xl, Articles IWF-5200(a) and (b) and IWF-5300(a) and (b) provided that TSs or licensee-controlled documents are updated to reflect these changes. If Subsection ISTD is used in lieu of Section Xl, Article IWF-5000, for snubber ISI and testing, preservice and inservice examination must be performed using the VT-3 visual examination method described in IWA-2213." Since the snubber program at St. Lucie Unit 2 met these requirements, (ASME OM Code, Subsection ISTD, 2001 Edition w 2003 Addenda and VT-3 methods used for visual examinations, as well as Technical Specification surveillance requirements TS 3/4.7.9) no further action was required in response to the RIS-2010-006.
b) A snubber program self-assessment (CR 2008-1302) was performed at St. Lucie Unit 1
& 2 during the first quarter, 2008. The assessment confirmed that the snubber program, as implemented at that time, met both the requirements of the Technical Specifications
L-2014-227 Attachment 1 Page 3 of 5 and the requirements of the ASME OM Code, Subsection ISTD, 2001 Edition w/ 2003 Addenda. Based upon the results of this assessment, the Snubber Program Owner's review of RIS-2010-006 and his knowledge of the snubber program at St. Lucie, it was concluded that the snubber program requirements were in accordance with Tech Specs and the ASME OM Code, Subsection, ISTD, which is an acceptable alternative to ASME Section Xl 1998 Edition with Addenda through 2000 as allowed by 10 CFR 50.55a(b)(3)(v). A copy of this assessment can be provided upon request.
RAI 3
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3), "Surveillance Requirements," states that, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The proposed amendment would delete the specific requirements for demonstrating snubber operability, currently in surveillance requirement (SR) 4.7.9. A reference to "SR 4.7.9, Snubber Test Program" would be added in place of the specific requirements. The proposed changes do not provide sufficient detail necessary to adequately demonstrate snubber operability. Please reference 10 CFR 50.36(c)(3) as part of the basis for this TS change RAI 3 RESPONSE The proposed TS amendment would replace the detailed requirements for demonstrating snubber operability, currently in surveillance requirements of the Technical Specification with the following: (SR) 4.7.9 "Each snubber shall be demonstrated OPERABLE by performance of the Snubber Testing Program" A new paragraph, P is also added to the Administrative Controls of the Technical Specification which confirms the Snubber Testing Program requirements are in accordance with the required surveillance requirements as stated in 10CFR 50.55a(g) and 10 CFR 50.55a(b)(3)(v)(B). This Snubber Testing Program would demonstrate snubber operability and provide an equivalent level of safety to the previously approved surveillance requirements contained in the Technical Specification. A Comparison of Current TS requirements to the Proposed OM Code Snubber Testing Program is detailed in Attachment 4 to support a review to demonstrate an equivalent level of safety. This change, to remove the detailed snubber surveillance requirements from the TS, will result in a consolidation of the snubber surveillance requirements under one program in accordance with the ASME OM Code, 2004 Edition with 2006 Addenda for the Fourth Ten-Year Inservice Interval.
RAI 4
Attachments 2 and 3, TS marked up Sections TS 4.7.9 and TS 6.8.4.p (a) Please explain the meaning of "snubber life destructive testing," in TS SR 4.7.9.a.
(b) TS Administrative Control Section 6.8.4.p, "Snubber Testing Program" (1) It would be more appropriate if the referenced regulation 10 CFR 50.55a(b)(3)(v)(B) in Sections 3 and 4 of TS 6.8.4.p are changed to 10 CFR 50.55a(b)(3)(v). This may
L-2014-227 Attachment 1 Page 4 of 5 eliminate the need for TS changes should this section be changed in the future.
Please advise if you agree.
Please change the wordings in TS 6.8.4.p, item 4, from "limitations and modifications" to "conditions" to match with the wordings in the current 10 CFR 50.55a.
RAI 4 RESPONSE a) It has been concluded that there are no snubbers in the St. Lucie Unit 2 snubber program that would require any special exemption from the snubber surveillance program as requested in TS 4.7.9.i, therefore we will delete this paragraph from the proposed Technical Specification change request.
b) (1) Agreed to change the reference from 10 CFR 50.55a(b)(3)(v)(B) to 10 CFR 50.55a(b)(3)(v).
(2) Agreed to change the wordings in TS 6.8.4.p, item 4, from "limitations and modifications" to "conditions" to match with the wordings in the current 10 CFR 50.55a.
RAI 5
a) On Page 8 of 11, third row and third column (Justification for Change) for TS SR 4.7.9.f, NRC staff believes that the referenced TS SR 4.7.9.g should be changed to TS SR 4.7.9.f RAI 5 RESPONSE a) Agreed Page 8 of 11, third row and third column (Justification for Change) that the referenced TS SR 4.7.9.g is incorrect and the correct TS SR is 4.7.9.f.
RAI 6 , St. Lucie Plant, Snubber Testing Program a) This snubber program does not specify that this is for St. Lucie Unit 1 or Unit 2. The cover sheet only states St. Lucie. Please clarify that this snubber program is for St. Lucie Unit 1 or Unit 2 or both.
b) The snubber program does not specify the fourth 10-year ISI interval.
c) The snubber program does not specify the start and end date for the fourth 10-year ISI interval.
RAI 6 RESPONSE , St. Lucie Plant, Snubber Testing Program
L-2014-227 Attachment I Page 5 of 5 a) The Snubber Testing Program Plan submitted is for St. Lucie Unit 2, and will be revised to specify Unit 2. It is FPL's intention, once the program has been approved for Unit 2 and implemented, that a similar submittal will be made to update the Snubber Program for St. Lucie Unit 1 for the remainder of the St. Lucie Unit 1 fourth interval.
b) The snubber program plan will be revised to specify the fourth 10-year interval.
c) The snubber program plan will be revised to specify the start and end date for the Fourth 10-year ISI Interval (begins August 8, 2014 ends August 7, 2024).
L-2014-227 Attachment 2 Page 1 of 4 Proposed Technical Specification Changes Summary RAI Affected TS Markups 3/4 7-21 3/4 7-24 6-15j
L-2014-227 Attachment 2 Page 2 of 4 PLANT SYSTEMS 314.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All safety-related snubbers shall be OPERABLE.
APPLICABILITY: MODES 1, 2,3 and 4. MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.
ACTION: 4..
With one or more safety related snubbers ino rable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPE iBLE status and perform an engineering evaluation per Specification 4-.7.91 on the supported component or declare the supported system inoperable and follow the appropriate ACTION statement for that system.
SURVEILLANCE REQUIREMENTS
- a. Inspection Types used in this specification. "type of snubber" shall mean snub-bers he same design and manufacturer, irrespective of capacity.
- b. Visua Ins cti Snubbers are categorize inaccessible or accessible during reactor operation. Each of the ategories (inaccessible or accessible) may be inspected indep ently according to the schedule determined by Table 4.7-2. The visual in ction interval for each category of snubber shall be determined base n the criteria provided in Table 4.7-2 and the first inspection inte determined using this criteria shall be based upon the previous inspe o n interval as established by the requirements in effect before Amendment.
ST_ LUCIE - UNIT 2 314 7-21 Amendment No. 22, 51
L-2014-227 Attachment 2 Page 3 of 4 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (.ContinuedM Subr Seal Replacement Proaqram The I service life of hydraulic snubbers shall be monitored and documented I to ensur at the seals do not fail between surveillance inspections. -
The maximun eected service life for the various seals, seal .
materials, and app tons shall be estimated based on engineering .
information and the sea hall be replaced so that the maximum expected service life does n xpire during a period when the snubber is required to be OPE E.
L Exemtion From Visual Inspection or Func al Tests Permanent or other exemptions from the surve.ogram for
- " individual snubbers may be granted by the Commission i ' tifiable .
)" basis for exemption is presented and, if applicable, snubber lif* .
P" destructive testing was performed to qualify the snubber for the .
p- applicable design conditions at either the completion of their * '
fabrication or at a subsequent date..*"
ST. LUCIE - UNIT 2 314 7-24 Amendment No- -q2, 54-, 149
L-2014-227 Attachment 2 Page 4 of 4 ADMINISTRATIVE CONTROLS Icontinued)
- n. Diesel Fuel Oil Testing Proaram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:
(i) Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:
- 1. An API gravity or an absolute specific gravity within limits,
- 2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and
- 3. A clear and bright appearance with proper color or a water and sediment content within limits; (ii) Other properties for ASTM 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and (iii) Total particulate concentration of the fuel oil is S 10 mg/I when tested every 31 days.
The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.
- o. Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the rec.ommneiratin of Reguliatuy pobtton o.4.b ot Regu*atoy Guide 1.14, Reyvimin 1, August 1975.
P.Snbb-er Tecsting Prograrem (ctASME) Boilber- and P cressur (BPhV) e Code and thnAMECode 55 forsperation andI Maqintmenanc ditspo Cxanaddend the te merica Sifet mofMechanical Engineers -n fof Nuekr upo.eram ashl (Ce) t aro*aicroaeyrfnce int1 0hCFRlowing:
sujeTh- tolm atnshand moft lt in 10 CFR 50.uiraen)sand subjcttC ommis.sio
- 3. Tfhe program shall, aets hrequired byr10 et CFR suppaob) rXt) meet Subsethion IS~bw etA "ediinera RequirCoemoents" anndSubseindISTD, "PrmerviceandScit Inservcaia Exmnationeand (4),ec 10 CFRmitatgio)(s esting BofD e na Prestrain and (nb10difcatRons.55stb) ber) ioend (incldn Liht-ater 10 Roeaor CFR 50.55a(b)(3)(n)
N subjecttoCmisn peraroPowr Plants"nac
- 4. Th 10m e r nth pr o daeshall be incr acrdance wi 10 CFR 50.55a(g) toGthera conditio enslste therein.D,"rsevc d adIsevc Eaiato n
,ST. LUCIE - UNIT 2 6-15j Amendment No. 46-, 159
L-2014-227 Attachment 3 Page 1 of 6 St. Lucie Plant Unit 2 Snubber Testing Program Plan Fourth I0-Year Interval August 8, 2014 - August 7, 2024 Revision 0 Florida Power & Light Company St. Lucie Plant 6501 S. Ocean Drive Jensen Beach, FL 34957 flev 00 Page 1 qf 6 Dole Revision Date Rev Page I of 6
L-2014-227 Attachment 3 Page 2 of 6 Revision Log Effective Revision Description Prepared: Date Approved: Date Date IST Snubber Engineering Coordinator Manager
-I- 1 1 + 4
+ 4 1 1- 4 Rev 00 Page 2of6 R'ilsion Dale Revision Date Recv Page 1 of 6
L-2014-227 Attachment 3 Page 3 of 6 TABLE OF CONTENTS SECTION
1.0 INTRODUCTION
2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:
3.0 EXAMINATION and TESTING METHODS:
4.0 EXAMINATION and TESTING FREQUENCY:
5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:
6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:
7.0 SCHEDULING
8.0 REPORTS AND RECORDS:
Rev 00 Pale 3qf6 Revison Dare Revision Date Rev Page 3 of 6
L-2014-227 Attachment 3 Page 4 of 6 INTRODUCTION:
1.1 Purpose
To provide requirements for the performance and administration of assessing the operational readiness of those quality related dynamic restraints (Snubbers) whose specific functions are required to ensure the integrity of the reactor coolant pressure boundary or any safety-related system.
1.2 Scope
The program plan was prepared to meet the requirements of the following subsections of the American Society of Mechanical Engineers (ASME) OM Code 2004 Edition with 2005 and 2006 Addenda.
- Subsection ISTA, "General Requirements" ISTA contains the requirements directly applicable to inservice examination and testing including the Owner's Responsibility and Records Requirements.
" Subsection ISTD, "Presers'ice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water ReactorNuclear Power Plants" ISTD establishes requirements for preservice and inservice examination and testing, and the service life monitoring of Dynamic Restraints (Snubbers) in light-water reactor nuclear power plants. The snubbers covered are required to support the systems and components that are required in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.
1.3 Discussion
In order to ensure the required operability of all safety related and quality related snubbers for the St.
Lucie Plant during seismic or other events initiating dynamic loads, the inspection, testing and service life monitoring of these snubbers shall be implemented and performed in accordance with the requirements of the station Snubber Testing Program Requirements.
The examination boundaries for the Snubber Program shall include the snubber assembly from pin to pin inclusive. Integral and nonintegral structural attachments for snubbers, when examined, shall be examined in accordance with the requirements of the ASME Code Section Xt, Article IWF-2500(a),
(b), (c) and (d). Coordination with the IS[ program owner will be required to complete the surveillance and documentation requirements for these piping and structural attachments.
The Snubber Program described in OSP-73.01 and QI-10-PRJPSL-6 adheres to the requirements of the ASME OM Code, Subsection ISTD, 2004 Edition with 2005 and 2006 Addenda, as required by 10CFR50.55a(b)(3)(v)(B).
Revision Date Rev 0 Page4 of 6
L-2014-227 Attachment 3 Page 5 of 6 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:
2.1 Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the extent specified within OSP-73.01, QI-10-PR/PSL-6 and referenced Surveillance Test Procedures.
2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample plan per ISTD-5300. Large equipment snubbers attached to the Steam Generators or Reactor Coolant Pumps will each comprise separate DTPG's.
2.3 The service life of all snubbers shall be monitored and evaluated, replaced, or reconditioned in accordance with OSP-73.01, QI-10-PR/PSL-6 and ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections. The replacement or reconditioning of snubbers shall be documented and records retained in accordance with St. Lucie Plant procedures.
3.0 EXAMINATION and TESTING METHODS:
3.1 Visual examinations shall be performed by individuals qualified in accordance with St. Lucie Plant procedures. These examinations are conducted to ensure the mechanical and structural condition of the snubber support location and to observe conditions that could affect functional adequacy. Visual examinations and functional testing shall be performed to verify the requirements specified within OSP-73.01 and QI-10-PR/PSL-6 are met in accordance with Subsection ISTD.
4.0 EXAMINATION and TESTING FREQUENCY:
4.1 Visual Examinations and Functional Testing shall be performed at the frequency specified within OSP-73.01, QI-10-PR/PSL-6 and ISTD-4250 and ISTD-5240. Snubbers are categorized as inaccessible or accessible during reactor operation for visual examination. Each of these categories (inaccessible and accessible) may be examined independently according to the schedule determined by Table ISTD 4252-1.
4.2 Code Case OMN-13, which allows the extension of the visual examination interval, will be implemented for snubber inspections during this interval. Code Case OMN-13 is approved for use in Regulatory Guide 1.192 (June 2003). The Visual Examinations of Table ISTD 4252-1 may be extended in accordance with Code Case OMN-13 once the prerequisites of the code case have been satisfied.
4.3 Visual Examinations shall be performed whenever new snubbers are installed, reinstallation of existing or swapped snubbers that were functionally tested, or after repairs, replacements or modifications.
4.4 Functional testing requirements for new installations or spares shall be equal to or more stringent than that specified within OSP-73.01 and QI-10-PRIPSL-6.
Rev 00 Page Sof6 Reid zion Date Revision Dare Rev Page 5 o/'6
L-2014-227 Attachment 3 Page 6 of 6 5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:
5.1 Snubbers that do not appear to conform to the Visual Examination requirements of OSP-73.01 and QI-10-PRIPSL-6, shall be reported for evaluation and appropriate corrective action.
5.2 Snubbers that do not appear to conform to the visual examination acceptance requirements and are later confirmed as operable as a result of functional testing may be declared operable for the purpose of establishing the next visual inspection interval, providing that the unacceptable condition did not affect operational readiness.
5.3 Snubbers that do not meet the operability testing acceptance criteria in OSP-73.01 and QI PR/PSL-6 shall be evaluated to determine the cause of the failure and appropriate corrective action shall be taken.
5.4 The service life of a snubber is predicted using manufacturer's input and contemporary information gained through consideration of the snubber service conditions and inservice functional test results.
Service life monitoring program requirements are included in OSP-73.01 and QI-10-PR/PSL-6.
6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:
6.1 Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the ASME Code,Section XI.
7.0 SCHEDULING
7.1 The Visual Examinations, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with OSP-73.01, QI-10-PR/PSL-6 and Subsection ISTD by the Snubber Engineer.
7.2 A listing of snubbers included in this program is maintained and is controlled within the NAMS Equipment Data Base.
7.3 The Snubber Engineer shall identify and track expanded or additional testing and/or examinations as required by OSP-73.01, QI-1O-PR/PSL-6 and Subsection ISTD.
8.0 REPORTS and RECORDS:
8.1 Reports and records for the Visual Examinations and Functional Testing shall be maintained for all snubbers included within the Snubber Program in accordance with QI-17-PSL-1, Quality Assurance Records.
8.2 Applicable records and reports, as required for Repair and Replacements, shall be maintained.
8.3 Records of the service life of all snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records shall also be maintained in accordance with QI-17-PSL-1 and QI-10-PR/PSL-6.
Revision Date Rev 0 Page 6 of 6