Text

LGS-525537-02-RP07, Revision 0, Snubber Program Document, Fourth Ten-Year Snubber Interval. Part 1 of 2
	ML16089A302
Person / Time
Site:	Limerick
Issue date:	03/04/2016
From:	Mark King; Amec Foster Wheeler
To:	; Exelon Generation Co, Office of Nuclear Reactor Regulation
Shared Package
ML16090A286	List: ML16089A302; ML16089A325;
References
	LGS-525537-02-RP07, Rev 0
	Download: ML16089A302 (33)
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Exelon Generation Company Limerick Generating Station Units 1 & 2 Snubber Program Snubber Program Document Fourth Ten-Year Snubber Interval Document: LGS-525537 RP07, Rev 0 Prepared By Prepared For amec foster wheeler Exelon .

Amee Foster Wheeler, Inc. Exelon Generation Company One Energy Center Limerick Generating Station 40 Shuman Blvd., Suite 340 3146 Sanatoga Road Naperville, IL 60563 Pottstown, Pennsylvania 19464

I.GS-525537-02-RP07, Rc\1 0 Page i Snubber rrogram Document - 411' Interval REVISION APPROVAL SHEET TITLE: Snubber Program Document Limerick Generating Station, Units J & 2 INTERVAL: Limerick ISi - Fourth Ten-Year Snubber Interval ASME CODE OF RECORD: ASME OM Code, 2004 Edition through the 2006 Addenda DOCUMENT:~--=L~G=S~-5=25~5=3~7-~02~-RP==-0~7~~ REVISION: 0 PREPARED TRANSMITTAL PREPARED: ~=:::S:;l6-::=-=-L------1' 3 j3 I/{&,

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j Amee Foster Wheeler P grams Engineer REVIEWED:

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Amee Foster Wheeler Sr. Programs Engineer APPROVED: ~tJ/-.--C--

~W. Lam~

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"S""S*/t, Amee Foster Wheeler Engineering Programs Director EXELON GENERATION CQMPANY ACCEPTANCE amec faster wheeler ~

LGS-525537-02-RPO?, Rev 0 Page ii Snubber Program Document - 4*b Interval REVISION APPROVAL SHEET TITLE: Snubber Program Document Limerick Generating Station, Units 1 & 2 INTERVAL: Limerick IS I - Fourth Ten-Year Snubber lnte.rval ASME CODE OF RECORD: ASME OM Code, 2004 Edition through the 2006 Addenda DOCUMENT:~---L~G=S~ - 5=2=55~3~7-~0~2-~R~P0~7~~ REVISION: ___o PROGRAM ACCEPTANCE REVIEWED:

Gary~yder

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Snubber Program Engineer REVIEWED: __tt.c-----'~"---~---------'I 3/2s-f:i.01'°

_......;..-rJ1._,Gk Programs Engineer APPROVED: ~ (t:1.::i. 1\~'~

Programs Manager amec foster wheeler

LGS-525537-02-RP07, Rev 0 Page iii Snubber Program Document* 4*h Interval REVISION CONTROL SHEET Each time this document is revised, the following table should be completed to provide a detailed record or the revision history. The major changes should be outlined within the table. Editorial and formatting revisions are not required to be logged. The signatures above apply only to the changes made in the revisions noted. If historical signatures are required, Limerick Generating Station archives will need to be retrieved.

REVISION DATE REVISION

SUMMARY

0 03/03/16 Initial issuance. (This Snubber Program Document was developed by Amee Foster Wheeler as part of the Fourth Interval ISi Program update.)

Prepared: M. King Re\-iewed; S. Coleman Approved: D. Lamond Note: 1. This Snubber Program Document (Sections 1 - 6 inclusive) is controlled by the Limerick Generating Station. Engineering Programs Group.

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LGS-52..'i.517-02-RPO?, Rev 0 Page iv Snubber Progrum Document - 4111 lntervul REVISION

SUMMARY

SECTION EFFECTIVE PAGES REVISION DATE Preface i lo vi 0 03/03/16 1.0 1-1 to 1-8 0 03/03/16 2.0 2-1 to2-4 0 03/03/16 3.0 3-1 to 3-5 0 03/03/16 4.0 4-1 lo 4-5 0 03/03/16 5.0 5-1 to 5-2 0 03/03/16 6.0 6-1 to 6-2 0 03/03/16 amec foster wheeler ~

LGS-525537-02-RP07, Rev 0 Pngev Snubber Program Document

41h Interval TABLE OF CONTENTS SECTION DESCRIPTION PAGE

1.0 INTRODUCTION AND BACKGROUND

.................................................................................. 1-1 1.1 Introduction 1.2 Background 1..1 First Interval Snubber Program I.4 Second Interval Snubber Program I.5 Third Interval Snubber Program 1.6 Founh Interval Snubber Program 1.7 Code of Federal Regulations IOCFR50.55a Requirements 1.8 ASME OM Code Cases 1.9 Relief Requests 2.0 BASIS FOR SNUBBER PROGRAM ................. ......................................................................... 2-1 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 SNUBBER PLAN ......................................................................................................................... 3-1 3.1 Nonexempt Code Class Snubbers 3.2 Snubber General Requirements 3.J 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

SUMMARY

TABLE ................................................................................................. 4-1

4. I Snubber Program Summary Table 5.0 RELIEF REQUESTS FROM ASME OM CODE ........................................................................ 5-1

6.0 REFERENCES

.............................................................................................................................. 6-1 6.1 NRC References 6.2 Industry References 6.3 Licensee References 6.4 License Renewal References I Commitments ATTACHMENTS A. Unit I Snubber Details B. Unit 2 Snubber Details amec foster wheeler

LGS-525537-02-RP07, Rev 0 Page vi Snubber Program Document - 4th Interval TABLE OF CONTENTS (Continued)

TABLES DESCRIPTION PAGE I. 1-1 UNITS I AND 2 FOURTH SNUBBER PROGRAM INTERVAUPERIOD/OUTAGE MATRIX ....................................................................................................................................... 1-2 1.7-1 CODE OF FEDERAL REGULATIONS 10CFR50.55a REQUIREMENTS ............................... 1-7 2.5-1 TECHNICAL APPROACH AND POSITIONS INDEX ............................................................. 2-4 4.1-1 UNIT 1 SNUBBER

SUMMARY

TABLE ................................................................................. ..4-J 4.1-2 UNIT 2 SNUBBER

SUMMARY

TABLE ................................................................................... 4-4 4.1-3 SNUBBER

SUMMARY

TABLE PROGRAM NOTES ............................................................. .4-5 5.0-1 RELIEF REQUEST INDEX ................................................................................ ......................... 5-2 amec foster wheeler

LGS-5255J7-02-RP07, Rev 0 Page 1-1 S1mbber Program Document - 4111 Interval

1.0 INTRODUCTION AND BACKGROUND

I. I Introduction Snubbers are installed on safety related and non-safety related systems at Limerick Generating Station (LGS) Units 1 and 2 to ensure the continued structural integrity of the reactor coolant system and other safety related systems following a seismic or other event initiating dynamic loads. As such, assurance of the ability of these snubbers to perform as designed through visual examination and functional testing is imperative. Snubbers installed on non-safety related systems may be included if their failure or failure of the system on which they are installed would have an adverse effect on any safety related system. These non-safety related snuhbers, along with all safety related snubbers, will be referred to as "program snubbers" throughout this document.

This Snubber Program Document establishes and defines the Snubber Program requirements. The primary purpose of this Snubber Program is to maintain the operational readiness of all program snubbers (installed on Class 1, 2, 3, and non-class piping) 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 Fourth lnservice Inspection (ISi) Interval is effective from February I, 2017 through January 31, 2027 for LGS Units I and 2. With the update to the ISi Program for the Fourth ISi Interval for Class I, 2, and 3 components, including their supports. LGS has elected to update the Snubber Program documentation at this time. The ASME OM Code of Record for the Fourth Interval Snubber Program is the 2004 Edition through the 2006 Addenda.

Per Code of Federal Regulations, Title 10, Part 50, Section .55a, Codes and standards.

10CFR50..5.5a{b)(3)(v)(B), LGS will use Subsection ISTD of the ASME OM Code 2004 Edition through the 2006 Addenda for the Fourth Interval Snubber Program. This is a change from the previous intervals when LGS was committed to using Technical Specifications for the inspection of program snuhbers.

Paragraph ISTA-3 I20(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 nol to exceed the duration of the outage. See Table 1.1 ~I for intervals, periods, and extensions that apply to LGS's Fourth Interval Snubber Program.

The Fourth Interval Snubber Program is divided into three inspection periods as determined by calendar years within the intervals. Table 1.1-1 identifies the period start and end dates for the Fourth Interval Snubber Program. In accordance with Paragraph ISTA-3120(d), the inspection periods specified in these Tables may be decreased or extended by as much as 1 year to enable inspections to coincide with LGS's refueling outages.

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LGS-525537-02-RP07, Rev 0 Pa£c 1-2 Snubber Program Document - 41J1 Interval TABLE 1.1-1 UNITS 1 AND 2 FOURTH SNUBBER PROGRAM INTERVAUPERIOD/OUTAGE MATRIX UNITI Period Interval Period Unit2 Outage Projected Outage Start Date To End Date Start Date to Start Date To End Date Projected Outage Outage Number Start Date or End Date Start Date or Number Outaee Duration Outaee Duration Li1Rl7 Scheduled I Scheduled Li2Rl4 3/18 1SI 151 4/17 LilR18 Scheduled 2/1/17 to 1/31/21 4m (Unit 1) 2/l/17to 1/31/20 Scheduled Li2Rl5 3/20 211117 to l/31/2i 3 4/19 LilR19 Scheduled 21111 21111 Scheduled Li2Rl6 3/22 2/1/21 to 1/31/24 2/1/20 lo 1/31/23 4/21 4lh (Unit 2)

LilR20 Scheduled Scheduled Li2R17 3/24 3rd 211117 to l /3 l /27 2' 3 3n1 4/23 LilR21 Scheduled 2/1/24 to 1/31127 2/1123 to 1/31/27 Scheduled Li2Rl8 3/26 4125 Note I: The LGS Unit I and Common First Period was extended by one year and the Second Period was reduced by one year as permitted by Paragraph IW A-2430(c)(3) in order to coincide with the Unit 2 refueling outage schedule.

Note 2: The LGS Unit 2 Second Period was reduced by one year and the Third Period was extended by one year as permitted by Paragraph IWA-2430(c)(3) in order Lo coincide with the Unit I and Common refueling outage schedule.

Note 3: The LGS Units 1 and 2 Snubber Program aligns with the intervals. periods, and extensions that apply to LGSs Fourth Interval ISi Program.

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LGS-5255J7-02-RP07, Rev 0 Page 1-J Snubber Program Document - 4th Interval 1.2 Background The Philadelphia Electric Company (PECO), now known commercially as Exelon Generation Company (EOC), LLC, obtained Construction Permits lo build LOS Units I and 2 on June 19, 1974, for Unit I, CPPR-106, and for Unit 2, CPPR-107. The Docket Numbers assigned to LOS 50-352 for Unit I and 50-353 for Unit 2. After satisfactory plant construction and pre-operational testing was completed, PECO was granted a full-power operating license for Unit I, NPF-39, and subsequently commenced commercial operation on February I, 1986~ the full-power operating license for Unit 2, NPF-85. was granted and commercial operation commenced on January 8, 1990.

LOS's piping systems and associated components were designed and fabricated to be inspected and tested in accordance with the requirements of ASME Section XI. Although this plant was specifically designed to meet the inspection and testing requirements of ASME Section XI, literal compliance may not be feasible or practical within the limits of the current plant design. Certain limitations are likely to occur due to conditions such as accessibility, geometric configuration, and/or metallurgical characteristics. For some inspection categories. an alternate component may be selected for examination and the code statistical and distribution requirements can still be maintained. If ASME Section XI required examination criteria cannot be met, a relief request will be submitted in accordance with IOCFR50.55a.

1.3 First Interval Snubber Program Pursuant to 10CFR50.55a(g), licensees were required to update their ISi Programs to meet the requirements of ASME Section XI once every ten years or inspection interval.

The ISi Program was required to comply with the latest Edition and Addenda of ASME Section XI incorporated by reference in 10CFR50.55a twelve months prior to the start of the interval per 10CFR50.55a(g)(4)(i). Based on this date, the latest Edition and Addenda of ASME Section XI referenced in IOCFR50.55a(b)(2) twelve months prior to the issuance of the LOS Unit I operating license was ASME Section XI, 1980 Edition, including Addenda through Winter 198 l. By letter dated January 24, 1992, PECO notified the Nuclear Regulatory Commission (NRC) that the LOS Unit I and Common ISi and Repair and Replacement Programs had been voluntarily upgraded to meet the requirements of the latest NRC-approved version of ASME Section XI (i.e., 1986 Edition, No Addenda). The voluntary upgrade was initiated to allow LGS Unit I to use the same ASME Section XI Edition as that required for LOS Unit 2. Similarly, the version of IOCFR50.55a in effect twelve months prior to the issuance of the LOS Unit 2 operating license was ASME Section XI, 1986 Edition. No Addenda. This alignment of applicable Code Editions was developed to provide a uniform set of requirements for both units at LOS, and to preclude any confusion that could result from the use of different requirements for each unit.

LOS Technical Specifications (TS), Section 3/4.7.4 (TS 3/4.7.4) included comprehensive programs for visual examination and functional testing of all program snubbers. The program scope encompassed alJ program snubbers. LOS TS 3/4.7.4 also included requirements for visual examination of program snubbers per ASME Section XI.

Because JOCFR50.55a did not address snubber testing, the snubber testing requirements of ASME Section XI, IWF-5000 were not imposed on LOS per TS 3/4.7.4.

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LGS-525.5J7-02-RP07, Re\> 0 Page 1-4 Snubber Pr~rom Document - 4111 Interval The First ISi Interval for LGS Unit I was scheduled to end on February I, 1996.

However. by letter dated April 6, 1995. PECO notified the NRC that the inspection interval would be extended until March I, 1996. to accommodate the sixth refueling outage (Li I R06) schedule. Additionally, by letter dated January 5. 1996, PECO notified the NRC that the inspection interval would ~ further extended until February I, 1997, to accommodate the preparation and implementation of ASME Section XI Code pressure tests that were now required as a result of the NRC's conditional approval of Relief Request RR-13.

Therefore, the Unit I First ISi Interval began on February I, 1986 and ended on January 31, 1997. This one-year extension has not been recovered to date for LGS Unit I.

The LGS Unit 2 First Inspection Interval began on January 8, 1990 and ended on January 7, 2000. ISi and Repair and Replacement Programs were developed to implement the requirements of the ASME B&PV Code,Section XI, 1986 Edition, No Addenda.

1.4 Second Interval Snubber Program Pursuant to IOCFR50.55a(g), licensees were required to update their ISi Programs to meet the requirements of ASME Section XI once every ten years or inspection interval.

The ISi Program was required to comply with the latest Edition and Addenda of ASME Section XI incorporated by reference in IOCFR50.55a twelve months prior to the start of the interval per IOCFR50.55a(g)(4)(ii).

As stated above, the end of the LGS Unit I First ISi Interval was January 31, 1997 and the end of the LGS Unit 2 First ISi Interval was January 7, 2000. In order to avoid the inherent misalignment of the LGS ASME Section XI Programs. LGS obtained approval from the NRC to begin the LGS Unit 1 and Common Second ISi Interval, as normally scheduled, using the existing Code requirements (i.e., First ISi Interval requirements). as described in ASME Section XI, 1986 Edition, No Addenda. Then, in approximately three (3) to four (4) years following the start of the LGS Unit 1 Second ISi Interval, when LGS Unit 2 completed its First ISi Interval, both Unit I and Unit 2 ISi Programs were simultaneously updated to the latest approved Edition and Addenda of the ASME Section XI, which was the Code of Record in effect 12 months prior to the start of LGS Unit 2 Second ISi Interval (i.e., 1989 Edition, No Addenda).

ASME Section XI, 1989 Edition, No Addenda, Article IWF-5000, lnservice Inspection Requirements for Snubbers, required inservice examinations and tests to be perfonned in accordance with Part4 of ASMFJANSI OMA-1988 Addenda to ASMFJANSI OM-1987, ASME OM Code. Visual inspections shall use the VT-3 visual examination method described in Paragraph IWA-2213 and shall include integral and non-integral attachments. Relief Request RR-04, authorized per NRC SER dated February 14, 2002.

requested relief from the visual examination and functional testing of Paragraphs IWF-2000 and IWF-5000 for snubber assemblies from the pin-connection to the pin-connection.

Concurrently, the LGS Second Interval Snubber Program was developed in accordance with the requirements of the LOS TS 3/4. 7.4 as described in AUG-13 of the ISi Specifications. Licensing Change Request 91-04-0 amended LGS TS 3/4. 7.4 to permit the use of ASME/ANSI OM-1990, Subsection ISTD, lnservice Testing of Dynamic c

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LGS-52S537-02-RP07. Rev 0 Page 1-5 Snubber Program Document - 41h Interval Restraints (Snubbers) in Light-Water Reactor Power Plants in lieu of Part 4 of ASME/ANSI OMa-1988 Addenda to ASMFJANSI OM-1987. The program described in LGS TS 3/4.7.4 was comprehensive and met ASME Section XI. IWF-5000 requirements for visual examination and functional testing of program snubbers. The details of the LGS Snubber Program and examination and testing requirements were located in AUG-13 of the ISi Specifications.

As an alternative to the full ten-year interval duration requirements of Paragraphs IW A-2430(b) and (d) and Paragraph IW A-2432 for the Unit 2 Second Interval ISi Program and the Unit 2 First Interval CISI Program, LGS has previously approved Relief Request 13R-O I that modified the interval dates of the Unit 2 Second Interval ISi Program and the Unit 2 First Interval CISI Program. This permitted the subsequent ISi and CISI Programs to share a common inspection interval start and end date and to implement common Code Editions for Class I, 2, 3, MC, and CC components.

As such, the Second ISi Interval was effective from February I, 1997 through January JI, 2007 for LGS Unit I and from January 8. 2000 through January 31, 2007 for LGS Unit 2.

The LGS Snubber Program was governed by the requirements of TS 3/4. 7.4 per Relief Request RR-04.

1.5 Third Interval Snubber Program Pursuant to IOCFR50.55a(g), licensees were required to update their ISi Programs to meet the requirements of ASME Section XI once every ten years or inspection interval.

The ISi Program was required to comply with the latest Edition and Addenda of ASME Section XI incorporated by reference in IOCFR50.55a twelve months prior to the start of the interval per IOCFR50.55a(g)(4)(ii). As discussed in Section 1.4 above, the stan of the Third ISi Interval was on February I. 2007 for LGS Units I and 2. 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 Third ISi Interval was the 2001 Edition through the 2003 Addenda.

Concurrently, the LGS Third Interval Snubber Program was developed in accordance with the requirements of IOCFR50.55a and the ASME Section XI Paragraphs IWF-5200(a) and (b) and IWF-5300(a) and (b), and required VT-3 Visual Examinations and lnservice Tests (functional tests) of snubbers to be performed in accordance with the ASME Operation and Maintenance of Nuclear Power Plants (OM) Code, Standard ASME/ANSI OM, Part 4. Relief Request 13R-05, authorized per NRC SER dated March I I, 2008, requested relief from the visual examination and functional testing requirements of Paragraphs IWF-5200(n), IWF-5300(a), IWF-5200(b). and IWF-5300(b).

The purpose of this relief request was to justify replacing the visual examination and functional testing requirements of Paragraphs IWF-5200(a) and (b) and IWF-5300(a) and (b) and the frequency required by OMa-1988 Addenda to the ASMFJANSI OM-1987 Edition, Part 4, with the requirements of TS 3/4.7.4. Per IOCFR50.55a(b)(3)(v), visual examinations shall be performed using the VT-J visual examination method described in Paragraph IWA-2213. The details of the LGS Snubber Program and examination and testing requirements were located in AUG-13 of the ISi Augmented Inspection Program.

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LGS-!'i2S!'iJ7-02-RP07, Rev 0 Page 1-6 Snubber Program Document

4111 Interval The LGS Third ISi Interval was effective from February 1, 2007 through January 31, 2017 for Units I and 2.

The LGS Snubber Program was governed by the requirements of TS 3/4. 7.4 per Relief Request 13R-05.

1.6 Fourth Interval Snubber Program Pursuant to IOCFR50.55a(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 10CFR50.55a twelve months prior to the start of the Fourth ISi Interval per 10CFR50.55a(g)(4)(ii). As discussed in Section 1.5 above, the start of the Fourth ISi Interval will be on February I. 2017, for LGS Units 1 and 2. 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 Fourth ISi Interval was the 2007 Edition through the 2008 Addenda.

Concurrently, the LGS Fourth Interval Snubber 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 1.7-1 of this section. The Fourth Interval Snubber Program and this Snubber Program Document addresses Subsection JSTA, Subsection ISTD, approved ASME OM Code Cases, approved alternatives through relief requests and safety evaluations (SE's),

and utilizes the inspection requirements as defined therein.

The LGS Fourth ISi Interval is effective from February 1, 2017, through January 31, 2027.

The LGS Snubber Program is governed by the requirements of the ASME OM Code, 2004 Edition through the 2006 Addenda per JOCFR50.55a(b)(3)(v)(B).

1.7 Code of Federal Regulations 10CFR50.55a Requirements There are certain paragraphs in 10CFR50.55a 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 LGS are detailed in Table 1.7-1.

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LGS-5255'.l7-02-RP07, Rev 0 Page 1-7 Snubber Program Document - 4111 lntervul TABLE 1.7-1 CODE OF FEDERAL REGULATIONS 10CFR50.55a REQUIREMENTS 10CFRS0.55a Paragraphs Limitations, Modifications, and Clarifications IOCFR50.55a(b)(3)(v)(B) (Snubber) OM condition: Snubbers /STD. Article IWF-5000, "lnservice Inspection Requirements for Snubbers," of the ASME BPV Code,Section XI, must be used when performing inservice inspection examinations and tests of snubbers at nuclear power plants, except as conditioned in paragraphs (b)(3)(v)(8) of this section.

(8) Snubbers: Second provi.'iion: Licensees must 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 BPV Code.

JOCFR50.55a(b)(6) (Snubber) Conditiom on Operation and Maintenance of Nuclear Power Plants Code Cases: Licensees may apply the ASME Operation and Maintenance Code Cases listed in Regulatory Guide 1.192 without prior NRC approval subject to the following:

(i) OM Code Case condition: Applying Code Case.r: When a licensee initially applies a listed Code Case, the licensee must apply the most recent version of that Code Case incorporated by reference in paragraph (a) of this section.

(ii) OM Code Case condition: ApplyiJJg different revi.r;ions Code Cases: If a licensee has previously applied a Code Cnse and a later version of the Code Case is incorporated by reference in paragraph (a) of this section, 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. Licensees who choose to continue use of the Code Case during subsequent 120-month ISi program intervals will be required to implement the latest version incorporated by reference into 10CFR50.5Sa as listed in Tables I and 2 of Regulatory Guide 1.192.

(iii) OM Code Case condition: Applying annulled Code Cases:

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.

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LGS-525517-02-RPO?, Rev 0 Page 1-8 Snubber Program Document - 4*h Interval 1.8 ASME OM Code Cases Per IOCFR50.S.Sa(h)(6), ASME OM Code Cases that have been determined to be suitable for use in the Snubber Program by the NRC are listed in Regulatory Guide I .192, "Operation and Maintenance Code Case Acceptability, ASME OM Code." The approved Code Cases in Regulatory Guide 1.192, which are being utilized by LGS, 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 Program shall be used. As this guide is revised, newly approved Code Cases may he assessed for plan implementation at LGS per Paragraph ISTA-3200(e) and proposed for use in revisions to the Snubber Program Document.

The use of other Code Cases (than those listed in Regulatory Guide I. 192) may be authorized by the Director of the Office of Nuclear Reactor Regulation upon request pursuant to IOCFR50.55a(z). Code Cases not approved for use in Regulatory Guide 1.192. which are being utilized by LGS through associated relief requests, are included in Section 5.0.

1.9 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 Fourth Interval Snubber Program document are included in Section 5.0 of this 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 l OCFR50.55a(z)(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 IOCFR50.55a(z)(2), or the code requirements are considered impractical per 10CFR50.55a(g)(5)(iii).

Per IOCFR50.55a Paragraphs (z) 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 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."

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LGS-525537-02-RP07, Rev 0 Page 2-1 Snubber Program Document - 4111 Interval 2.0 BASIS FOR SNUBBEI{ PROGRAM 2.1 ASME OM Code Examination and Testing Requirements As required by the IOCFR50.55a, this Program was developed in accordance with the requirements detailed in the 2004 Edition through the 2006 Addenda of the ASME OM Code, Subsection ISTA, Subsection ISTD, approved ASME OM Code Cases, and approved alternatives through relief requests and Safety Evaluations (SE's).

2.1.1 ASME OM Code Cases As referenced by JOCFR50.55a(b)(6) and allowed by NRC Regulatory Guide 1.192, Revision I, being the latest incorporated into this Snubber Program Document. the following Code Cases can be incorporated into the LGS Snubber 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 perfon11ed in addition to the requirements of ASME OM Code on a routine basis during the Fourth Interval Snubber Program. There are currently no augmented examinations and tests perfonned by LGS that are not specifically addressed by the ASME OM Code.

2.3 Snubber Scope This LGS Snubber Program applies to the snubber visual examinations, functional testing, 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 maintaini ng the safe shutdown condition, or in mitigating the consequences of an accident (i.e .. all program snubbers.)

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LGS-525537-02-RPO?, Rev 0 Page 2-2 Snubber Program Document - 4lh Interval 2.4 Snubber Drawings and Details LOS has three (3) varying types of snubbers: Mechanical PSA snubbers. Hydraulic snubbers, and Mechanical PSB snubbers (compensating struts). Vendor manuals and drawings for Pacific Scientific Mechanical Snubbers (PSA/PSB) and for Lisega Hydraulic Snubbers are controlled through the LGS controlled document database.

This section of the document includes information with regard to the actual snubber population and the different types, models, and sizes of program snubbers utilized by LOS. A complete listing of all the LGS ASME OM Code program snubbers within the scope of the visual examination. functional testing, and service life monitoring requirements is provided in the Snubber Program database, site procedures, and in Attachments A and B of this document.

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LGS-525537-02-RP07, Rev 0 Page 2-3 Snubber Program Document - 4*b Interval 2.5 Technical Approach and Positions When the requirements of ASME OM Code are nol easily interpreted, LGS 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 LGS's implementation of ASME OM Code requirements. An index, which is used to summarize each TAP, is included in Table 2.5-1.

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LGS-5255J7-02-RP07, Rev 0 Page 2-4 Snubber Program Document

4111 Interval TABLE2.S-1 TECHNICAL APPROACH AND POSITIONS INDEX Position Revision Status' (Program) Description of Technical Approach Number Date1 and Position 14T-XXS Note I: Snubber Program Technical Approach nnd Position Status Options: Active - Current Technical Approach lllld Position is being utilized al LGS; Dele1ed -Technical Approach and Position 1s no longer being utilized al LGS.

Note 2: The revision listed is the latest revision or the subject Technical Approach and Position. The date noted in the second column 1s the date of the Snubber Program Document revision when the Technical Approach and Position was incorporated into the document.

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LGS-525537-02-RPO?, Rev 0 Page 3-1 Snubber Program Document - 41h Interval 3.0 SNUBBER PLAN The LGS 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 Code Class Snubbers The LGS Class I, 2, and 3 nonexempt snubbers are those which do not meet the exemption criteria of Paragraph IWF-1230 of ASME Section XI. A summary of the LGS ASME Section XI nonexempt snubbers is included in Section 4.0 of this document.

3.1.1 Identification of Class I, 2, and 3 Nonexempt Snubbers Class 1, 2. and 3 snubbers are identified on the ISi Isometric and Component Drawings listed in Section 2.4, Tables 2.4.I, 2.4-2, 2.4-3, 2.4-4, 2.4-5, and 2.4-6 of the LGS ISi Program Plan. The Class I and 2 Isometric Drawings are identified with a special prefix of "FIG" for Unit 1 and "XI for Unit 2 (e.g.,

FIG-01-01 or Xl-DCA-204-1). Snubbers are identified by controlled LGS individual support detail drawings.

3.2 Snubber General Requirements 3.2.1 As allowed by 10CFR50.55a(b)(3)(v)(B), LGS will use Subsection ISTD, "lnservice Testing of Dynamic Restraints (Snubbers) In Light Water Reactor Power Plants," ASME OM Code, 2004 Edition through the 2006 Addenda, to meet the visual examination, functional testing, and service life monitoring requirements for program 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 visual examination, functional testing, and service life monitoring requirements.

At LGS Units l and 2, all snubbers were procured and installed to the quality standards of safety related snubbers. As such, it is LGS's pJnn to continue to maintain all snubbers to quality standards.

Example: the mechanical and hydraulic snubber functional testing sample shall consist of 37 and/or I 0% of each Defined Test Plan Group (DTPG) taken from the program snubber population. Any failure within these test sample plan groups require an expansion sample per the applicable Subsection ISTD requirements.

Procedure ER-AA-330-004, "Visual Examination of Snubbers," implements the visual examination program for program snubbers. Procedures ER-AA-330-0JO, "Snubber Functional Testing," ER-AA-330-011. "Snubber Service Life Monitoring Program," and LGS surveillance test procedures ST-1-103-300-X and ST-1-103-990-X are used to implement the functional testing and service life monitoring requirements for program snubbers.

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LGS-5255J7-02-RP07, Rev 0 Page J-2 Snubber Progrom Document - 4111 Interval The ASME OM Code specifies the visual examination, functional testing, and service life monitoring requirements for snubbers in the ASME OM Code, Subsection ISTD. ASME Section XI also has 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 visual e:itamination and functional testing of the snubbers performed at LOS per the ASME OM Code and the ASME Section XI visual examination requirements.

The general requirements of ASME Section XI, Subsection IW A, 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-'.B5-0l 6.

The required examination schedule is determined by Paragraph ISTD-4252 and Table JSTD-4252-1 of the ASME OM Code. This visual examination is to verify: a) no indications of damage or impaired operability; b) attachments to foundations or supporting structure are functional, and c) fasteners for the snubber attachment to the component and to the anchorage are functional.

Visual examinations shall be performed by individuals qualified in accordance with LOS procedures.

The ASME Section XI visual examination boundary of a support containing a snubber is defined in Figure IWF-1300-l(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, also referred to as "pin-out". The ASME Section XI ISi Program uses Subsection IWF to define the inspection requirements for all Class I, 2, and 3 supports, regardless of type. The ISi Program maintains the Code Class snubbers in the support populations subject to inspection per Article IWF-2000. This is done to facilitate scheduling, preparation including insulation removal. and inspection requirements of the snubber attachment hardware (e.g., bolting and clamps). The examination and testing of the snubber body and extension, also referred to as "pin-in", will be performed in accordance with the ASME OM Code Snubber Program.

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).

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LGS-52'i537-02-RP07, Rev 0 Page 3-3 Snubber Program Document - 4111 Interval 3.3.2 The functional testing of snubbers included in this program 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 into DTPG's by design type. in accordance with Paragraph ISTD-5252 for testing purposes. Snubbers at LGS will be tested using the 37 testing sample plan for mechanical PSA snubbers and a 10% testing sample plan for hydraulic snubbers and mechanical PSB snubbers. (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. t Defined Test Pinn Group The DTPGs shall includ~ nil 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 LGS will be split into three (3) DTPG's - DTPGI Mechanical PSA Snubbers (Accessible and Inaccessible), DTPG2 Hydraulic Snubbers (Accessible and Inaccessible), and DTPG3 Mechanical PSB snubbers (compensating struts) (Accessible and Inaccessible).

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

(a) the 10% testing sample plan (LGS's sample plan for hydraulic snubbers and mechanical PSB snubbers)

(b) the 37 testing sample plan (LGS's sample plan for mechanical PSA snubbers)

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 The service life of all snubbers included in this program shall be monitored to ensure that the service life is not exceeded between examination/testing intervals.

The maximum expected service life for various seals. springs. and other critical parts shall be extended or reduced based on monitored test results and failure history. Critical parts shall be replaced so that the maximum service life will not be exceeded during a period when the snubber is required to be operable.

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l..GS-52.S5J7-02-RP07, Rev 0 Page 3-4 Snubber Program Document - 4*h Interval 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-330-011.

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 Section XI and site procedures.

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 site 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 the ASME OM Code and site procedures. Repair and replacement records and reports will be kept in accordance with ASME Section XI and site procedures.

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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LGS-525517-02-RPO?, Rev 0 Pa!!e 3-5 Snubber Program Document - 4111 Interval Details of examinations and tests conducted under this program need not be included in the ASME Section XI Summary Report and Form NJS-1. An abstract of examinations completed may be provided in the Summary Report.

Form NIS-2 shall be included in the Summary Report for any ASME Section XI repairs or replacements performed on the snubbers within the scope of this program.

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LGS-525537-02-RPO?, Rev 0 Page 4-1 S11ubbcr Program Document* 4*h Interval 4.0 SNUBBER

SUMMARY

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

Subsection JSTD.

The following Tables 4.1-1 and 4.1.2 provide a summary of the ASME OM Code, Subsection ISTD, Snubber visual examinations and functional testing for the Fourth Snubber Interval at LGS.

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

ASMEOMCode 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)

(I) ASME OM Code Subsection (with Subsection Description):

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

(2) OM Subarticle Number:

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

(3) Subarticle Number

Description:

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

(4) Examination Requirements:

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

(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.

amec foster wheeler

LGS-525537-02-RPO?, Rev 0 Page 4-2 Snubber Program Document - 41h Interval (6) Freguency:

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

(7) Relief Reguest/ TAP Number:

Provides a listing of Relief Request/ TAP Numbers to speci fie 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 lo the Subsection ISTD subarticle number.

If a program note number is identified, see the corresponding program note in Table 4.1-3.

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LGS-525537-02 RP07, Re1. 0 Page 4-3 Snubber Program Document - 4lh Interval TABLE4.1-1 UNIT 1 SNUBBER

SUMMARY

TABLE ASMEOMCode OM Subarticle Number Description Exam Totals Frequency Relier Request/ Notes Subsection (with Subarticle Requirements TAP Number Subsectilm Number Description)

!STD ISTD-4200 Accessible and Inaccessible Snubbers - Visual , VT-3 1049 Various I Snubber Mechanical PSA, Hydraulic, and Examinations Mechanical PSB (1 oooulation) lSTD lSTD-5200 (DTPG I) 37 Functional Test Plan - Functional 850 Every 2 Snubber Mechanical Type PSA Snubbers (Accessible/ Testing Refueling Testing Inaccessible) Oula~c (DTPG2) 10% Functional Test Plan - Functional 193 Every 2 Hydraulic Type Lisega Snubbers (Accessible/ Testing Refueling Inaccessible) Outage (DTPG3) 10% Functional Test Plan - Functional 6 Every 2 Mechanical Type PSB Snubbers (Inaccessible) Testing Refueling Outage amec foster wheeler

LGS-525537-02-RP07. Re"' 0 Pagl! 4-4 Snubber Program Document

4th Interval TABLE4.1-2 UNIT 2 SNUBBER

SUMMARY

TABLE ASMEOMCode OM Subarticle Number Description Exam Totals Frequency Relief Request/ Notes Subsection (with Subarticle Requirements TAP Number Subsection Number Descriotion)

ISTD ISTD-4200 Accessible and Inaccessible Snubbers - Visual. VT-3 649 Various I Snubber Mechanical PSA, Hydraulic, and Examinations Mechanical PSB (I population)

ISTD ISTD-5200 (DTPG I) 37 Functional Test Plan - Functional 513 Every 2 Snubber Mechanical Type PSA Snubbers {Accessible/ Testing Refueling Testing Inaccessible) Outa2e (0TPG2) I 0% Functional Test Plan - Functional 126 Every 2 Hydraulic Type Lisega Snubbcrs (Accessible/ Testing Refueling 1naccessible) Outa2c (DTPG3) 10% Functional Test Plan - Functional 10 Every 2 Mechanical Type PSB Snubbers {Accessible/ Testing Refueling Inaccessible) Outage amec foster wheeler 1$

LGS-525537-02-RPO?, Re" 0 Page 4-5 Snubber Program Document - 4t11 Interval TABLE4.1-3 SNUBBER

SUMMARY

TABLE PROGRAM NOTES Note# Note Summary 1 Per the ASME OM Code, Subsection ISTD. 2004 Edition throu2h the 2006 Addenda, Para2raph ISTD-4250 "Jnservice Examina1ion Jnlervals."

2 Per the ASME OM Code, Subsec1ion ISTD, 2004 Edition lhrough the 2006 Addenda, Paragraph ISTD-5240 "Test Frequency."

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LGS-.52.5.537-02-RP07, Rev 0 Page 5-1 Snubber Program Document - 4th Interval 5.0 RELIEF REQUESTS FROM ASME SECTION XI This section contains relief requests written per IOCFR50.S5a(z)( I) for situations where alternatives to ASME Section XI requirements provide an acceptable level of quality and safety; per IOCFR50.55a(z)(2) for situations where compliance with ASME Section XI requirements results in a hardship or an unusual difficulty without a compensating increase in the level or quality and safety: and per IOCFR50.55a(g)(5)(iii) for situations where ASME Section XI requirements are considered impractical.

The following NRC guidance was utilized to determine the correct IOCFR50.55a Paragraph citing for LGS relief requests. IOCFR50.55a(z)(I) and IOCFR50.55a(z)(2) provide alternatives to the requirements of ASME OM Code. while IOCFR50.55a(g)(5)(iii) recognizes situational impracticalities.

10CFRSO.S5a(z)(l): Cited in relief requests when alternatives to the ASME Section XI requirements which provide an acceptable level of quality and safety nre proposed. Examples are relief requests which propose alternative non-destructive examination (NOE) methods and/or examination frequency.

10CFRS0.55a(z)(2): Cited in relief requests when compliance with the ASME Section XI requirements is deemed to be a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of hardship and/or unusual difficulty include.

but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimal increases in examination coverage.

10CFRSO.S5a(g)(5)(iiil: Cited in relief requests when conformance with ASME Section XI requirements is deemed impractical. Examples of impractical requirements are situations where the component would have to be redesigned, or replaced to enable the required inspection to be performed.

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.

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LGS-525517-02-RPO?, Rev 0 Page 5-2 Snubber Program Document - 411t Interval Table S.0-1 Relier Request Index Relief Revision Stotus2 (Program) Description/

Request Date Approval Summary 1 14R-XXS Note I: The NRC grants relief requests pursuant to IOCFR50.:'i5a(g)(6)(i) when Code requirements cannot be met and proposed alternatives do not meet the criteria of IOCFR50,55(z). The NRC authorizes relief requests pursuant lo IOCFR50.5:'ia(z)( l) if the proposed ahematives would provide an acceptable level of quality and safety or under IOCFR50.55a(z)(2) if compliance with the specified requirements would result tn hardship or unusual difficulties without a compensating increase in the level of safety. Requests for relief under IOCFR50.5:'ia(g)(5)(iii) are not to be submitted to the NRC for evaluation prior lo the licensee perfonning the ASME Section XI Code-required examination. The NRC may also impose ahemative requirements as il determines.

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

Authorized Conditionally - Approved for use in an NRC SE which imposes certain conditions: Granted Conditionally -Approved for use in an NRC SE which imposes certain conditions; Expired -Approval for relief has expired; Withdrawn - Relief has been withdrawn by the station; Not Required - The NRC has deemed the relief unnecessary in an SE or RAI; Pending - Relief has been submitted to the NRC by the station and is awaiting approval.

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LGS-:'i255J7-02-RP07, Rev 0 Page 6-1 Snubber Program Document - 4*h Interval

6.0 REFERENCES

The references used to develop this Snubber Program Document include:

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

- Part 50. Pnragrnph 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. I ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants," the 2004 Edition through the 2006 Addenda (Subsection ISTA and ISTD). (4'11 Snubber Interval).

6.2.2 ASME Boiler and Pressure Vessel Code,Section XI, Division I, "Inservice Inspection of Nuclear Power Plant Components," the 2007 Edition through the 2008 Addenda. (41h ISi Interval).

6.3 Licensee References 6.3.1 Limerick Generating Station Units I and 2. Updated Final Safety Analysis Report (UFSAR).

6.3.2 Limerick Generating Station Units I and 2, Technical Specifications (TS).

6.3.3 Limerick Generating Station Units 1 and 2, ISi Program Plan (ER-LG-330-1001), Fourth Ten-Year In service Inspection Interval.

6.3.4 Limerick Generating Station Units I and 2, ISi Augmented Inspection Program (ER-LG-330-1002).

6.3.5 Limerick Generating Station Units I and 2, ISi Classification Basis Document (ER-LG-330-1003), Fourth Ten-Year lnservice Inspection Interval.

6.3.6 Limerick Generating Station Units I and 2, Component and Classification Document (ER-LG-330-1004), Fourth Ten-Year Inservice Inspection Interval.

6.3.7 Limerick Generating Station Units I and 2, ISi Selection Document (ER-LG-330-1005). Fourth Ten-Year Inservice Inspection Interval.

6.3.8 Limerick Generating Station Units 1 and 2, License Renewal Application, October 2014.

6.3.9 Procedure ER-AA-330, "Conduct of lnservice Inspection Activities."

6.3.10 Procedure ER-AA-330-003, "lnservice Inspection of Section XI Component Supports."

6.J.11 Procedure ER-AA-330-004, "Visual Examination of Snubbers."

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

6.3.13 Procedure ER-AA-330-010, "Snubber Functional Testing."

6.3.14 Procedure ER-AA-330-011, "Snubber Service Life Monitoring Program."

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

6.3.16 Procedure EP-011. "Methodology for Assigning and Maintaining the Quality Classification of Components."

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LGS-5255J7-02-RP07, Rev 0 Page 6-2 Snubber Program Document - 4111 Interval 6.4 License Renewal

Reference:

i. /Commitments 6.4.1 None.

[

amec foster wheeler

Exelon Generation Company Limerick Generating Station Units 1 & 2 Snubber Program Snubber Program Document Fourth Ten-Year Snubber Interval Document: LGS-525537 RP07, Rev 0 Prepared By Prepared For amec foster wheeler Exelon .

Amee Foster Wheeler, Inc. Exelon Generation Company One Energy Center Limerick Generating Station 40 Shuman Blvd., Suite 340 3146 Sanatoga Road Naperville, IL 60563 Pottstown, Pennsylvania 19464

I.GS-525537-02-RP07, Rc\1 0 Page i Snubber rrogram Document - 411' Interval REVISION APPROVAL SHEET TITLE: Snubber Program Document Limerick Generating Station, Units J & 2 INTERVAL: Limerick ISi - Fourth Ten-Year Snubber Interval ASME CODE OF RECORD: ASME OM Code, 2004 Edition through the 2006 Addenda DOCUMENT:~--=L~G=S~-5=25~5=3~7-~02~-RP==-0~7~~ REVISION: 0 PREPARED TRANSMITTAL PREPARED: ~=:::S:;l6-::=-=-L------1' 3 j3 I/{&,

itaf~R.Ki

j Amee Foster Wheeler P grams Engineer REVIEWED:

Step . Col n

~

Amee Foster Wheeler Sr. Programs Engineer APPROVED: ~tJ/-.--C--

~W. Lam~

/ ______

"S""S*/t, Amee Foster Wheeler Engineering Programs Director EXELON GENERATION CQMPANY ACCEPTANCE amec faster wheeler ~

LGS-525537-02-RPO?, Rev 0 Page ii Snubber Program Document - 4*b Interval REVISION APPROVAL SHEET TITLE: Snubber Program Document Limerick Generating Station, Units 1 & 2 INTERVAL: Limerick IS I - Fourth Ten-Year Snubber lnte.rval ASME CODE OF RECORD: ASME OM Code, 2004 Edition through the 2006 Addenda DOCUMENT:~---L~G=S~ - 5=2=55~3~7-~0~2-~R~P0~7~~ REVISION: ___o PROGRAM ACCEPTANCE REVIEWED:

Gary~yder

~

Snubber Program Engineer REVIEWED: __tt.c-----'~"---~---------'I 3/2s-f:i.01'°

_......;..-rJ1._,Gk Programs Engineer APPROVED: ~ (t:1.::i. 1\~'~

Programs Manager amec foster wheeler

LGS-525537-02-RP07, Rev 0 Page iii Snubber Program Document* 4*h Interval REVISION CONTROL SHEET Each time this document is revised, the following table should be completed to provide a detailed record or the revision history. The major changes should be outlined within the table. Editorial and formatting revisions are not required to be logged. The signatures above apply only to the changes made in the revisions noted. If historical signatures are required, Limerick Generating Station archives will need to be retrieved.

REVISION DATE REVISION

SUMMARY

0 03/03/16 Initial issuance. (This Snubber Program Document was developed by Amee Foster Wheeler as part of the Fourth Interval ISi Program update.)

Prepared: M. King Re\-iewed; S. Coleman Approved: D. Lamond Note: 1. This Snubber Program Document (Sections 1 - 6 inclusive) is controlled by the Limerick Generating Station. Engineering Programs Group.

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LGS-52..'i.517-02-RPO?, Rev 0 Page iv Snubber Progrum Document - 4111 lntervul REVISION

SUMMARY

SECTION EFFECTIVE PAGES REVISION DATE Preface i lo vi 0 03/03/16 1.0 1-1 to 1-8 0 03/03/16 2.0 2-1 to2-4 0 03/03/16 3.0 3-1 to 3-5 0 03/03/16 4.0 4-1 lo 4-5 0 03/03/16 5.0 5-1 to 5-2 0 03/03/16 6.0 6-1 to 6-2 0 03/03/16 amec foster wheeler ~

LGS-525537-02-RP07, Rev 0 Pngev Snubber Program Document

41h Interval TABLE OF CONTENTS SECTION DESCRIPTION PAGE