ML16250A546

Response to Request for Additional Information Regarding Proposed License Amendment Concerning Snubber Technical Specification Requirements

ML16250A546
Person / Time
Site:	Limerick
Issue date:	09/06/2016
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16251A060	List: ML16250A546 ML16250A549
References
Download: ML16250A546 (38)

Text

Exelon Generation September 6, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Response to Request for Additional Information Regarding Proposed License Amendment concerning Snubber Technical Specification Requirements for Limerick Generating Station, Units 1 and 2

References:

1)

~etter from D. P. Helker (Exelon Generation Company, LLC), to the U.S.

Nuclear Regulatory Commission, "Request for License Amendment to Revise Limerick Generating Station Snubber Surveillance Requirements," dated March 29, 2016 (ADAMS Accession No. ML16090A286).

2) E-mail correspondence from R. Ennis (U.S. Nuclear Regulatory Commission) to S. J. Hanson (Exelon Generation Company, LLC),

"Draft Request for Additional Information Regarding Proposed License Amendment concerning Snubber Surveillance Requirements for Limerick Generating Station, Units 1 and 2," dated August 8, 2016 (ADAMS Accession No. ML16221A612).

By application dated March 29, 2016, Exelon Generation Company, LLC (Exelon),

submitted a license amendment request (LAR) for Limerick Generating Station (LGS),

Units 1 and 2 (Reference 1 ). The proposed amendment would revise the Technical Specification (TS) requirements for snubbers.

In the Reference 2 e-mail correspondence, the U.S. Nuclear Regulatory Commission (NRC) requested additional information (RAI). Attachment 1 contains Exelon's response to the NRC RAI. Attachment 2 provides a copy of the revised marked up TS pages that reflect the proposed change in response to the RAI. The remaining TS markups submitted in Reference 1 remain unchanged. Attachment 3 provides a copy of the revised TS 4. 7.4 Surveillance Requirements Comparison to ASME OM Code Subsection ISTD that reflects the proposed change in response to the RAI. Attachment 4 contains a copy of the revised Snubber Program Document that reflects the change in response to the RAI.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information LGS - Snubbers LAR September 6, 2016 Page 2 On August 8, 2016, Exelon indicated that a clarification call to discuss the draft RAI was not needed and a written response would be provided by September 6, 2016.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the U.S. NRC in Reference 1. The additional information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments in this response.

If you have any questions concerning this response, please contact Stephanie J. Hanson at 61 0-765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of September 2016.

Respectfully, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Response to Request for Additional Information Regarding Proposed License Amendment concerning Snubber Technical Specification Requirements for Limerick Generating Station, Units 1 and 2

2. Revised markup of Proposed Technical Specifications Pages 3/4 7-12 and 6-14d

3. Revised TS 4.7.4 Surveillance Requirements Comparison to ASME OM Code Subsection ISTD

4. Revised Snubber Program Document cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, Pennsylvania Bureau of Radiation Protection

ATTACHMENT 1 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 Docket Nos. 50-352 and 50-353 Response to Request for Additional Information Regarding Proposed License Amendment concerning Snubber Technical Specification Requirements for Limerick Generating Station, Units 1and2

Response to Request for Additional Information LGS - Snubber LAR Docket Nos. 50-352 and 50-353 Page 1of4 By application dated March 29, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Limerick Generating Station (LGS), Units 1 and 2. The proposed amendment would revise the Technical Specification (TS) requirements for snubbers.

The NRC staff has determined that additional information is needed to complete its review. The specific requests for additional information (RAI) questions are restated below along with Exelon's response.

Question 1 (EPNB-RAl-1): to the application, "Markup of Technical Specifications Pages," Page No. 3/4 7-12, provides a note stating "The information from Technical Specifications Section 4.7.4.d has been relocated to the Technical Requirements Manual (TRM) Snubbers Section. Technical Specifications Sections 4.7.4.a through 4.7.4.i have been intentionally omitted."

a. The snubber program provided in the Attachment 5 is based on the requirements of the ASME OM Code. The ASME OM Code paragraph ISTD-1750 provides Transient Dynamic Events requirements similar to the TS Section 4.7.4.d. Please explain the reason for relocating requirements of TS Section 4.7.4.d to the TRM instead of the proposed Snubber Program.

b. The current wording about Sections 4.7.4.a through 4.7.4.i being intentionally omitted provides no information regarding TS page configuration control. Consistent with other previous TS page deletions, it is suggested that the markup for page 3/4 7-12 state that "TECHNICAL SPECIFICATION PAGES 3/4 7-13 THROUGH 7-16 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED."

Response

a. The ASME OM Code paragraph ISTD-1750 does provide Transient Dynamic Events requirements similar to the TS Section 4.7.4.d., but does not specify a time allowance for the visual inspection of accessible and non-accessible systems following the event.

Additionally, ISTD -1750 does not specify acceptance methods of verifying freedom of motion of inspected snubbers, which is provided in TS Section 4.7.4.d. Relocating the TS Section 4. 7.4.d. requirements into the TRM preserves the necessary level of regulatory direction.

b. LGS TS page 3/4 7-12 has been revised to incorporate the suggested change. Attachment 2 contains the revised marked up TS page that reflects the proposed change.

Question 2 (EPNB-RAl-2): to the application, "Markup of Technical Specification Pages," Page No. 6-14d, shows newly added TS Administrative Control Section 6.8.4.k, "Snubber Program," Item bas follows:

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

Response to Request for Additional Information LGS - Snubber LAR Docket Nos. 50-352 and 50-353 Page 2 of 4 reference in 1 O CFR 50.55a, subject to its limitations and modifications. and subject to Commission approval.

Consistent with the current regulations at 1 O CFR 50.55a(b)(2) and 1 O CFR 50.55a(b)(3), the wording "limitations and modifications," in Item b cited above, should be changed to "conditions."

Response

LGS TS page 6-14d has been revised to incorporate the change. Attachment 2 contains the revised marked up TS page that reflects the proposed change.

Question 3 CEPNB-RAl-3) to the application provides the detail for 11TS 4.7.4 Surveillance Requirements Comparison to ASME OM Code Subsection ISTD.

11 In the comparison table, under the third column, third paragraph, "Justification for Change," TS 4.7.4.e (page 4 of 9), states that "The revised program provides greater flexibility in permitting testing to be performed during modes other than shutdown. However, as noted in Generic Letter (GL) 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."

The frequency of inservice examination and testing is specified in the applicable ASME OM Code, Subsection ISTD. Please clarify the use of GL 91-04 for justification of this change."

Response

LGS assesses and manages risk in accordance with 1 O CFR 50.65(a)(4) prior to performing maintenance and surveillance activities both at power and during shutdown. Activities are scheduled to minimize outage times for TS required equipment. Attachment 4 to the application, Page 4 of 9 pertaining to TS 4.7.4e has been revised to replace the reference to GL 91-04 with 1 O CFR 50.65(a)(4). Attachment 3 contains the revised comparison table showing the change on page 4 of 9.

Question 4 (EPNB-RAl-4) to the application, Page 2 of 9, TS 4.7.4c, third column, second paragraph references TS 4.5.M.1.b. Please explain the meaning of the referenced TS 4.5.M.1.b, because the current Limerick Units 1 and 2 TSs do not contain TS 4.5.M.1.b.

Response to Request for Additional Information LGS - Snubber LAR Docket Nos. 50-352 and 50-353

Response

Page 3 of 4 to the application, Page 2 of 9, pertaining to TS 4.7.4c has been revised to reference the correct LGS TS Section (TS 4.7.4c). Attachment 3 contains the revised comparison table showing the change on page 2 of 9.

Question 5 {EPNB-RAl-5) to the application, "Snubber Program Document," page 1-1, sixth paragraph states, in part, that The Fourth Interval Snubber Program is divided into three inspection periods as determined by calendar years within the intervals." Please explain the reason for dividing the fourth interval into three periods for snubber examination and testing under the Snubber Program at LGS.

Response: to the application, "Snubber Program Document," page vi, page 1-1, fifth and sixth paragraphs and page 1-2 have been revised to remove references to "inspection periods" and Table 1.1-1 has been deleted to align with the requirements of ISTA-3120. Attachment 4 contains the revised Snubber Program Document that reflects the change, which is pending issuance.

Question 6 {EPNB-RAl-6) to the application, "Snubber Program Document," Section 3.1 states, in part, The LGS Class 1, 2 and 3 nonexempt snubbers are those which do not meet the exemption criteria of Paragraph IWF-1230 of ASME Section XI."

Please explain whether the licensee has used the criteria of ASME Section XI, IWF-1230 to exempt snubbers while developing the listings of snubbers provided in Attachments A and 8 of.

Response

LGS has not used the criteria of ASME Section XI, IWF-1230 to exempt snubbers while developing the listings of snubbers provided in Attachments A and B of Attachment 5. All snubbers listed in Attachments A and B were classified as TS snubbers and none were exempted in the transition from TS to ISTD.

Question 7 {EPNB-RAl-7) to the application, "Snubber Program Document," Section 3.2.1, fourth paragraph states "Procedure ER-AA-330-004, "Visual Examination of Snubbers, 11 implements the visual examination program for program snubbers. Procedures ER-AA-330-010, "Snubber Functional Testing," and ER-AA-330-11, "Snubber Service Life Monitoring Program," and LGS surveillance test procedures ST-1-103-300-X and ST-1103-990-X are used to implement the functional testing and service life monitoring requirements for the program snubbers.

Please provide the difference between Procedures ER-AA-330-01 O and ER-AA-330-11, and LGS surveillance test procedures ST-1-103-300-X and ST-1-103-990-X.

Response to Request for Additional Information LGS - Snubber LAA Docket Nos. 50-352 and 50-353

Response

Page 4 of 4 The procedures ST-1-103-300-X and ST-1-103-990-X implement the requirements contained in procedures ER-AA-330-01 O and ER-AA-330-011 which provide the instructions and requirements on how to perform snubber functional testing and service life monitoring. The procedures ST-1-1 03-300-X and ST-1-1 03-990-X list and document those snubbers that are functionally tested and replaced for service life.

Question 8 (EPNB-RAl-8): to the application, "Snubber Program Document," Tables 4.1-1and4.1-2 provide the frequency for snubber examinations as "Various." Please explain the meaning of a "Various" frequency.

Response

The frequency for snubber examinations as "Various" in Tables 4.1-1 and 4.1-2 are for Visual examinations, as specified in ISTD-4200. ISTD provides allowance to change the inspection interval based upon the number of unacceptable visual inspections as provided in Table ISTD-4252-1. Therefore, the frequency of snubber visual inspections could be adjusted per Table I STD-4252-1.

ATTACHMENT 2 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 Docket Nos. 50-352 and 50-353 Response to Request for Additional Information Regarding Proposed License Amendment concerning Snubber Technical Specification Requirements for Limerick Generating Station, Units 1 and 2 Revised Markup of Technical Specifications Pages Unit 1 TS Pages 3/4 7-12 6-14d Unit 2 TS Pages 3/4 7-12 6-14d

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that there are no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are secure, and (3) fasteners for attachment of the snubber to the component and to the snubber anchorage are secure.

Snubbers which appear inoperable as a result of visual inspections shall

• be classified as unacceptable and may be reclassified acceptable for the purpose of establ i shi Ag the FJC)(t visual i Aspecti OFI interval, providing that. (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type on that system that may be generically susceptible, and/or (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.4f.

For those snubbers common to more than one system, the OPERABILITY of such snubbers shall be considered in assessing the surveillance schedule for each of the related systems.

A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber.

If continued operation cannot be justified, the snubber shall be declared inoperable and the ACTION requirements shall be met.

Transient Event Inspection An inspection shall be performed of all snubbers attached to sections of systems that have experienced unexpected, potentially damaging transients, as determined from a review of operational data or a visual inspection of the systems, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for accessible systems and 6 months for i naccessi bl e systems foll mvi ng this determination.

+A-addition to satisfying the visual inspection acceptance criteria, freedom of motion of mechanical snubbers shall be verified using at least one of the foll mr'i ng. ( 1) manual 1 y induced snubber mo'v'ement, or ( 2) evaluation of in place snubber piston setting; or (3) stroking the mechaAica1 sAubber through its full range of travel. ~

THE INFORMATION FROM TECHNICAL SPECIFICATIONS SECTION 4.7.4.d HAS BEEN RELOCATED TO THE TECHNICAL REQUIREMENTS MANUAL (TRM) SNUBBERS SECTION. TECHNICAL SPECIFICATIONS PAGES 3/4 7-13 THROUGH 7-16 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.

LIMERICK - UNIT 1 3/4 7-12 Amendment No. 51

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

i.

Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications," of the following:

a.

Actions to restore battery cells with float voltage< 2.13 volts, and

b.

Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

j.

Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies.

The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

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

b.

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

Revision 0.

c.

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

INSERT:

k. Snubber Program This program conforms to the examination, testing, and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISi) requirements for supports. The program shall be in accordance with the following:

a. This program shall meet 10 CFR 50.55a 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, subject to its conditions, and subject to Commission approval.

c. The program shall, as allowed by 10 CFR 50.55a, meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and lnservice 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.

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

LIMERICK - UNIT 1 6-14d Amendment No. -14, 186

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

-e-;-

Visual Inspection Acceptance Criteria Visual inspections shall verify (1) that there are no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are secure, and (3) fasteners for attachment of the snubber to the component and to the snubber anchorage are secure.

Snubbers which appear inoperable as a result of visual inspections shall

• be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the Arnt visual inspection interval, provi di Ag that. (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type on that system that may be generically susceptible; and/or (2) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.4f.

For those snubbers common to more than one system, the OPERABILITY of such snubbers shall be considered in assessing the surveillance schedule for each of the related systems. A review and evaluation shall be performed and documented to justify continued operation ~vith an unacceptable snubber.

If continued operation cannot be justified, the snubber shall be declared inoperable and the ACTIONS requirements shall be met.

Transient Event Inspection An inspection shall be performed of all snubbers attached to sections of systems that have experienced unexpected, potentially damaging transients, as determined from a review of operational data or a visual inspection of the systems, vvithin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for accessible systems and 6 months for i naccessi bl e systems foll mvi ng this determination.

.f.n---a.edi ti on to satisfying the visual inspection acceptance criteria, freedom of motion of mechanical snubbers shall be verified using at least one of the follm1ing:

(1) manually induced snubber movement, or (2) evaluation of in place snubber piston setting; or (3) stroking the mechanical snubber through its full range of travel.

THE INFORMATION FROM TECHNICAL SPECIFICATIONS SECTION 4.7.4.d HAS BEEN RELOCATED TO THE TECHNICAL REQUIREMENTS MANUAL (TRM) SNUBBERS SECTION. TECHNICAL SPECIFICATIONS PAGES 3/4 7-13 THROUGH 7-16 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.

LIMERICK - UNIT 2 3/4 7-12 Amendment No. 15

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

i.

Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications," of the following:

a.

Actions to restore battery cells with float voltage< 2.13 volts, and

b.

Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

j.

Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies.

The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

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

b.

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

Revision 0.

c.

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

INSERT:

k. Snubber Program This program conforms to the examination, testing, and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISi) requirements for supports. The program shall be in accordance with the following:

a. This program shall meet 10 CFR 50.55a 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 (ASM E)

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, subject to its conditions, and subject to Commission approval.

c. The program shall, as allowed by 10 CFR 50.55a, meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and lnservice 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.

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

LIMERICK - UNIT 2 6-14d Amendment No. ~' 147

ATTACHMENT 3 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 Docket Nos. 50-352 and 50-353 Response to Request for Additional Information Regarding Proposed License Amendment concerning Snubber Technical Specification Requirements for Limerick Generating Station, Units 1 and 2 Revised TS 4.7.4 Surveillance Requirements Comparison to ASME OM Code Subsection ISTD

Response to RAI LGS Snubber LAR LGS Snubber TS vs. OM Code ISTD Comparison Page 1of9 Limerick Generating Station Technical Specification ASME OM Code 2004 Edition through 2006 Justification for Change (TS)

Addenda - Subsection ISTD 3.7.4 LIMITING CONDITION FOR OPERATION Not Applicable Site operating conditions are not APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and specified in the OM code.

3. OPERATIONAL CONDITIONS 4 and 5 for snubbers located on systems required OPERABLE in those OPERATIONAL CONDITIONS.

3.7.4 LIMITING CONDITION FOR OPERATION ISTD-4280 lnservice Examination Corrective Subsection ISTD does not set a ACTION: With one or more snubbers inoperable on Action. Unacceptable snubbers shall be timeframe to replace or restore any system, 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 adjusted, repaired, modified, or replaced.

inoperable snubbers. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable snubber(s) to OPERABLE status and Additional action regarding the examination allowance to replace or restore the perform an engineering evaluation per Specification interval shall be taken as indicated in Table inoperable snubber to OPERABLE 4.7.4g on the attached component or declare the ISTD-4252-1.

status will be retained in the TS 3.7.4 attached system inoperable and follow the ACTION statement.

appropriate ACTION statement for that system.

4.7.4 SURVEILLANCE REQUIREMENTS ASME OM Code -Subsection ISTD -

LGS Snubber Program will be the Each snubber shall be demonstrated OPERABLE by Preservice and lnservice Examination and inspection program used to ensure performance of the following augmented inservice Testing of Dynamic Restraints (Snubbers) in operability for snubbersby following inspection program and the requirements of Light-Water Reactor Nuclear Power Plant.

the ASME OM Code Subsection ISTD.

Specification 4.0.5.

4.7.4a Inspection Types While ISTD does not have a generic definition Refer to TS 4.7.4b Visual As used in this specification, type of snubber shall like this, ISTD-4220(a) defines for visual Inspections, and TS 4.7.4e mean snubbers of the same design and manufacturer, exams what your grouping/definition can be Functional Testing sections irrespective of capacity.

for visuals and ISTD-5250 describes the below.

requirements for Defined Test Plan Groups for selecting /scheduling functional tests.

4.7.4b Visual Inspections ISTD-4220(a) requires all snubbers to be Table ISTD-4252-1 is equivalent to Snubbers are categorized as inaccessible or accessible considered one population for examination, TS Table 4.7.4-1 for all during reactor operation. Each of these categories or they may be categorized as accessible and population/category sizes; (inaccessible and accessible) may be inspected inaccessible.

therefore, use of ISTD-4200 for independently according to the schedule determined snubber inservice examination in by Table 4.7.4-1. The visual inspection interval for ISTD-4220(b) requires the decision to lieu of currentTS 4.7.4b does not each type of snubber shall be determined based upon examine the snubbers as one population or change the number of snubbers the criteria provided in Table 4.7.4-1 and the first as separate categories shall be made and required to be examined or the inspection interval determined using this criteria shall documented before the scheduled required examination intervals.

be based upon the previous inspection interval as examination begins and shall not be changed established by the requirements in effect before during the examination.

amendment no. 51.

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

Response to RAI LGS Snubber LAR LGS Snubber TS vs. OM Code ISTD Comparison Page 2of9 Limerick Generating Station Technical Specification ASME OM Code 2004 Edition through 2006 Justification for Change (TS)

Addenda - Subsection ISTD 4.7.4c Visual Inspection Acceptance Criteria ISTD-4210 states that inservice examination 10 CFR S0.5Sa(b)(3)(v)(B) allows the Visual inspections shall verify (1) that there are no shall be a visual examination to identify use of Subsection ISTD for inservice visible indications of damage or impaired physical damage, leakage, corrosion, or examination requirements.

OPERABILITY, (2) attachments to the foundation or degradation that may have been caused by Preservice and inservice supporting structure are secure, and (3) fasteners for environmental exposure or operating examinations are required to be attachment of the snubber to the component and to conditions; and external characteristics that performed using the VT -3 visual the snubber anchorage are secure.

may indicate operational readiness of the examination method described in snubber shall be examined.

ASME Section XI, IWA-2213.

ISTD-4231 requires that examinations shall The revised ISi program include observations for the following and requirements for inservice the conditions shall be evaluated when examination do not differ found:

significantly from the visual (a) loose fasteners, or members that are inspection acceptance criteria in TS I

corroded or deformed 4.7.4c.

(b) disconnected components or other conditions that might interfere with the Examination of the snubber from pin proper restraint of movement.

to-pin in accordance with ASME OM Code Subsection ISTD and the ISTD-4232 requires that examinations verify attachments to the component or snubbers do not restrain thermal movement structure will be examined in to an extent that unacceptable stresses could accordance with ASME Section XI, develop in the snubber, the pipe, or other Subsection IWF. This will encompass equipment that the XI, snubber is designed to that which was examined in protect or restrain. There should be no accordance with the LGS TS.

indication of binding, misalignment or deformation of 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 XI, IWF-1300 and Figure IWF-1300-1 (f) requires integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of Subsection IWF.

Response to RAI LGS Snubber LAR LGS Snubber TS vs. OM Code ISTD Comparison Page 3 of 9 Limerick Generating Station Technical Specification ASME OM Code 2004 Edition through 2006 Justification for Change (TS)

Addenda - Subsection ISTD 4.7.4c Visual Inspection Acceptance Criteria ISTD-4240 permits snubbers classified as The revised ISi program (continued) unacceptable during inservice examination to requirements for evaluation and Snubbers which appear inoperable as a result of visual be tested in accordance with the corrective action for inservice inspections shall be classified as unacceptable and requirements of ISTD-5210. Results that examination are equivalent to those may be reclassified acceptable for the purpose of satisfy the operational readiness test criteria of current TS 4.7.4c for visual establishing the next visual inspection interval, of ISTD-5210 shall be used to accept the examination acceptance criteria and providing that: (1) the cause of the rejection is clearly snubber, provided the test demonstrates that meet the requirements of ISTD.

established and remedied for that particular snubber the unacceptable condition did not affect and for other snubbers irrespective of type on that operational readiness.

system that may be generically susceptible; and/or (2) the affected snubber is functionally tested in the as ISTD-4233 requires that fluid supply or found condition and determined OPERABLE per content for hydraulic snubbers shall be Specifications 4.7.4f. For those snubbers common to observed. If the fluid is less than the more than one system, the OPERABILITY of such minimum amount, the installation shall be snubbers shall be considered in assessing the identified as unacceptable, unless a test surveillance schedule for each of the related systems.

establishes that the performance of the A review and evaluation shall be performed and snubber is within specified limits. Tests shall documented to justify continued operation with an be performed in accordance with ISTD-5210.

unacceptable snubber. If continued operation cannot The initial test shall start with the piston at be justified, the snubber shall be declared inoperable the as-found setting and be performed in the and the ACTION requirements shall be met.

extension (tension) direction, or in a mode that more closely resembles the operating and design requirements of the snubber.

ISTD-4270 requires that snubbers that do not meet examination requirements of ISTD-4230 shall be evaluated to determine the root cause of the unacceptability.

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

ISTD-1800 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. 7.4d Transient Event Inspection ISTD-1750 Transient Dynamic Event. If there The revised ISi program An inspection shall be performed of all snubbers is an unanticipated transient event that may requirements for evaluation and attached to sections of systems that have experienced have effected a snubber's operability, the corrective action for inservice unexpected, potentially damaging transients, as snubber and system shall be reviewed and examination are equivalent to those determined from a review of operational data or a any required corrective action should be of current TS 4.7.4d for Transient visual inspection of the systems, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for performed. These actions shall be Event Inspection and meet the accessible systems and 6 months for inaccessible independent of the requirements of ISTD-requirements of ISTD. Specification systems following this determination. In addition to 4100, ISTD-4200, ISTD-5100, and ISTD-5200.

4.7.4d requirement of performing a satisfying the visual inspection acceptance criteria, Transient Event Inspection will be freedom-of-motion of mechanical snubbers shall be removed and incorporated into the verified using at least one of the following: (1)

Technical Requirements Manual.

manually induced snubber movement; or (2) evaluation of in-place snubber piston setting; or (3) stroking the mechanical snubber through its full range of travel.

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Addenda - Subsection ISTD

4. 7.4e Functional Tests ISTD-5252 Defined Test Plan Group (DTPG)

The frequency of snubber testing in At least once per 24 months a representative sample Alternatives. Except as required by ISTD-the revised program is slightly of each type of snubber shall be tested using the 5253, the total snubber population may be changed from the frequency following sample plans. The sample plan(s) shall be considered one DTPG, or alternatively, specified in current TS 4.7.4e.

selected for each type prior to the test period and differences in design, application, size, or cannot be changed during the test period. The NRC type may be considered in establishing The TS requirement of 13.3% is Regional Administrator shall be notified in writing of DTPGs.

changed to a 10% requirement in the sample plan(s) selected for each type prior to the the revised program of a snubber test period or the sample plan(s) used in the prior test ISTD-5200 requires snubber operational population.

period shall be implemented:

readiness testing to be performed each fuel cycle. Testing shall be performed during The revised program provides

1) At least 13.3% of the total population of a snubber normal system operation, or during system or greater flexibility in permitting type shall be functionally tested. For each snubber of plant outages.

testing to be performed during that type that does not meet the functional test modes other than shutdown.

acceptance criteria of Specification 4.7.4f., an ISTD-5240 states that snubber testing may additional sample of at least 1/2 the size of the initial begin no earlier than 60 days before a Limerick assesses and manages risk sample shall be tested until the total number tested is scheduled refueling outage.

in accordance with equal to the initial sample multiplied by the factor, 10CFRS0.65(a)(4) prior to l+C/2, where C is the total number of unacceptable ISTD-5261 requires snubbers of each DTPG to performing maintenance and snubbers or until all the snubbers of that type have be tested using either:

surveillance activities both at been tested; or power and during shutdown.

(a) the 10% testing sample plan Activities are scheduled to minimize

2) A representative sample of 37 snubbers of a (b) the 37 testing sample plan outage times for TS required snubber type shall be functionally tested in equipment.

accordance with Figure 4.7.4-1. "C" is the total ISTD-5223 and ISTD-5224 permit snubbers to number of snubbers of that type found not meeting be tested in their installed location or in a the acceptance requirements of Specification 4.7.4f.

bench test.

The cumulative number of snubbers of the type tested is denoted by "N". If at any time the point plotted falls ISTD-5271 requires snubbers that do not in the "Accept" region, testing of snubbers of that type meet test requirements specified in ISTD-may be terminated. When the point plotted lies in the 5210 or ISTD-5230 to be evaluated to "Continue Testing" region, additional snubbers of that determine the root cause of the failure.

type shall be tested until the point falls in the "Accept" region, or afl the snubbers of that type have been ISTD-5330 requires the snubbers of each tested.

DTPG and Failure Mode Group (FMG) to be tested as required. Testing is complete when the mathematical expressions of ISTD-5331 are satisfied, or all snubbers in the DTPG or FMG have been tested.

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

(a) for each DTPG N ~ O.ln + C(0.1 n/2)

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

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

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Addenda - Subsection ISTD 4.7.4e Functional Tests (continued)

ISTD-5311(a) requires the initial sample to Since the snubbers of a DTPG are of The representative sample selected for the function include as practicable representation from the same design, configuration, and test sample plans shall be randomly selected from the the DTPG based on the significant features operating environment, and only a snubbers of each type and reviewed before beginning (i.e., the various designs, configurations, few snubbers are of different size the testing. The review shall ensure as far as practical operating environments, sizes, and and capacity, the representative that they are representative of the various capacities) and based on the ratio of the sample would only vary slightly.

configurations, operating environments, range of size, number of snubbers of each significant and capacity of snubbers of that type. Snubbers feature, to the total number of snubbers in Initial sample composition placed in the same locations as snubbers which failed the DTPG. Initial sample selection shall be requirements are similar in the in the previous functional test period shall be retested random.

revised program than those in at the time of the next functional test period but shall current TS 4.7.4e. The revised not be included in the sample plan, and failure of this As an alternative, ISTD-5311 (b) requires the program requirements continue to functional test shall not be the sole cause for initial sample to be generally representative, ensure initial sample selection is increasing the sample size under the sample plan.

as in ISTD-5311(a) but allows the sample to random and representative.

Testing equipment failure during functional testing be selected from those snubbers scheduled may invalidate the day's testing and allow that day's for seal replacement or other activities testing to resume anew at a later time provided all related to service life monitoring.

snubbers tested with the failed equipment during the day of equipment failure are retested.

ISTD-5500 requires that snubbers placed in the same location as snubbers that failed the previous inservice operational readiness test shall be retested at the time of next operational readiness testing unless the cause of the failure is clearly established and corrected. Retests in accordance with ISTD-5500 shall not be considered a part of inservice operational readiness testing sample selection requirements.

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Addenda - Subsection ISTD

4. 7.4e Functional Tests (continued)

ISTD-5271 states that snubbers that do not The revised program requirements If during the functional testing, additional testing is meet test requirements shall be evaluated to for manufacturer or design required due to failure of snubbers, the unacceptable determine the root cause of the failure.

deficiencies require replacement or snubbers may be categorized into modification of all snubbers in the failure mode group(s). A failure mode group shall ISTD-5272 states that snubbers found FMG or additional testing until the include all unacceptable snubbers that have a given unacceptable according to operational mathematical expression of ISTD-failure mode and all other snubbers subject to the readiness test requirements should be 5331(b) is satisfied or all snubbers in same failure mode. Once a failure mode group has assigned to FMGs unless the failure is the FMG have been tested. This may been established, it can be separated for continued isolated or unexplained. FMGs shall include result in fewer snubbers being testing apart from the general population of snubbers. all unacceptable snubbers with the same tested after a test failure. However, However, all unacceptable snubbers in the failure failure mode and all other snubbers with the revised program requirements mode group shall be counted as one unacceptable similar potential for similar failure.

provide adequate assurance of snubber for additional testing in the general snubber OPERABILITY because all population. Testing in the failure mode group shall be As an alternative to additional testing for potentially affected snubbers will be based on the number of unacceptable snubbers and design or manufacturing FMGs, ISTD-5323 replaced or modified; or the shall continue in accordance with the sample plan requires no additional testing when all acceptance limit for additional selected for the type or until all snubbers in the failure snubbers in the FMGs are replaced or testing will be met, demonstrating mode group have been tested. Any additional modified in accordance with ISTD-1600. If an acceptable level of reliability.

unacceptable snubbers found in the failure mode replacement or modification is not group shall be counted for continued testing only for performed in accordance with ISTD-5323, that test failure mode group. In the event that a additional testing is required in accordance snubber(s) becomes included in more than one test with ISTD-5324. Testing is required to failure mode group, it shall be counted in each failure continue until the acceptance limit is satisfied mode group and shall be subject to the corrective or all snubbers in the FMG have been tested.

action of each test failure mode group.

4.7.4f Functional Test Acceptance Criteria ISTD-5210 Test Parameters The revised snubber program The snubber functional test shall verify that:

requirements for hydraulic, a) Activation is within the specified range of mechanical PSA snubbers, and

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

acceptance criteria are equivalent to those of current TS 4. 7.4f.

2) Snubber bleed, or release rate where required, is b) Release rate is within the specified range present in both tension and compression, within the in tension and in compression. For units specified range (hydraulic snubbers only);

specifically required not to displace under continuous load, ability of the snubber to

3) For mechanical snubbers, the force required to withstand load without displacement.

initiate or maintain motion of the snubber is within the specified range in both directions of travel; and c) For mechanical snubbers, drag force is within specified limits, in tension and in

4) For snubbers specifically required not to displace compression.

under continuous load, the ability of the snubber to withstand load without displacement.

Testing methods may be used to measure parameters indirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods.

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Addenda

• Subsection ISTD

4. 7.4g Functional Test Failure Analysis ISTD-5271 states that snubbers that do not The revised snubber program An engineering evaluation shall be made of each meet test requirements shall be evaluated to requirements for functional test failure to meet the functional test acceptance criteria determine the root cause of the failure.

failure analysis are equivalent to to determine the cause of the failure. The results of those of current TS 4. 7.4g.

this evaluation shall be used, if applicable, in selecting ISTD-1800 requires evaluation of system(s) snubbers to be tested in an effort to determine the which a failed snubber was attached to, for OPERABILITY of other snubbers irrespective of type possible damage.

which may be subject to the same failure mode.

For the snubbers found inoperable, an engineering evaluation shall be performed on the components to which the inoperable snubbers are attached. The purpose of this engineering evaluation shall be to determine if the components to which the inoperable snubbers are attached were adversely affected by the inoperability of the snubbers in order to ensure that the component remains capable of meeting the designed service.

4. 7.4h Functional Testing of Repaired and Replaced ISTD-5500 requires that snubbers placed in The revised program requirement is Snubbers the same location as snubbers that failed the equivalent to the current TS 4.7.4h Snubbers which fail the visual inspection or the previous inservice operational readiness test requirement to retest a replacement functional test acceptance criteria shall be repaired or shall be retested at the time of next snubber installed in place of a failed replaced. Replacement snubbers and snubbers which operational readiness testing unless the snubber. Retesting is required, have repairs which might affect the functional test cause of the failure is clearly established and unless the cause of the original result shall be tested to meet the functional test corrected. Retests in accordance with ISTD-failure was clearly established and criteria before installation in the unit. Mechanical 5500 shall not be considered a part of corrected. The revised program does snubbers shall have met the inservice operational readiness testing not require retest during the next acceptance criteria subsequent to their most recent sample selection requirements.

test period of failed snubbers that service, and the freedom-of-motion test must have are repaired and installed in another been performed within 12 months before being position. However, the corrective installed in the unit.

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

Response to RAI LGS Snubber LAR LGS Snubber TS vs. OM Code ISTD Comparison Page 8 of 9 Limerick Generating Station Technical Specification ASME OM Code 2004 Edition through 2006 Justification for Change (TS)

Addenda - Subsection ISTD 4.7.4i Snubber Service Life Replacement Program ISTD-6100 requires initial snubber service life The service life evaluation The service life of all snubbers shall be monitored to to be predicted based on manufacturer's requirements in ISTD-6100, ISTD-ensure that the service life is not exceeded between recommendation or design review.

6200 and ISTD-6300 are equivalent surveillance inspections. The maximum expected to the requirements in current TS service life for various seals, springs, and other critical ISTD-6200 requires service life to be 4.7.4i.

parts shall be extended or shortened based on evaluated at least once each fuel cycle. If the monitored test results and failure history. Critical parts evaluation indicates that service life will be LGS TS 6.10.3 states that records of shall be replaced so that the maximum service life will exceeded before the next scheduled system inservice inspections performed not be exceeded during a period when the snubber is or plant outage, one of the following actions pursuant to these Technical required to be OPERABLE. The parts replacements shall be taken:

Specifications shall be retained for shall be documented and the documentation shall be the duration of the Facility retained in accordance with Specification 6.10.3.

(a) the snubber shall be replaced with a Operating License. This requirement snubber for which the service life will not be remains unchanged.

exceeded before the next scheduled system or plant outage (b) technical justification shall be documented for extending the service life to or beyond the next scheduled system or plant outage (c) the snubber shall be reconditioned such that its service life will be extended to or beyond the next scheduled system or plant outage ISTD-6300 requires causes for any examination or testing failures shall be determined and considered in establishing or reestablishing service life.

Response to RAI LGS Snubber LAR LGS Snubber TS vs. OM Code ISTD Comparison Page 9of9 Limerick Generating Station Technical Specification ASME OM Code 2004 Edition through 2006 Justification for Change

{TS)

Addenda - Subsection ISTD Table 4.7.4-1 SNUBBER VISUAL INSPECTION ISTD-4220(a) requires all snubbers to be Table ISTD-4252-1 is equivalent to INTERVAL considered one population for examination, TS Table 4.7.4-1 for all Note 1: The next visual inspection interval for a or they may be categorized as accessible and population/category sizes; snubber population or category size shall be inaccessible.

therefore, use of ISTD in lieu of determined based upon the previous inspection current TS is equivalent for the site.

interval and the number of unacceptable snubbers ISTD-4220(b) requires the decision to found during that interval. Snubbers may be examine the snubbers as one population or categorized, based upon their accessibility during as separate categories shall be made and power operation, as accessible or inaccessible. These documented before the scheduled categories may be examined separately or jointly.

examination begins and shall not be changed However, the licensee must make and document that during the examination.

decision before any inspection and shall use that decision as the basis upon which to determine the ISTD-4252(b) requires inservice examinations next inspection interval for that category.

to be conducted in accordance with Table ISTD-4252-1 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 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 Columns B and C.

Note 6: The provisions of Specification 4.0.2 are applicable for all inspection intervals up to and including 48 months.

ATTACHMENT 4 Limerick Generating Station, Units 1and2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 Docket Nos. 50-352 and 50-353 Response to Request for Additional Information Regarding Proposed License Amendment concerning Snubber Technical Specification Requirements for Limerick Generating Station, Units 1 and 2 Revised Snubber Program Document

Exelon Generation Company Limerick Generating Station Units l & 2 Snubber Program Snubber Program Document Fourth Ten-Year Snubber Interval Document: LGS-525537-02-RP07, Rev 0 Prepared By Prepared For amec r:

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foster wheeler Amee Foster Wheeler, Inc.

One Energy Center 40 Shuman Blvd., Suite 340 Naperville, IL 60563 e

Exelon Generation Company Limerick Generating Station 3146 Sanatoga Road Pottstown. Pennsylvania 19464

1 GS-525537-02*Rfl07, Rev 0 Snubber Program Document* 4"' lntervnl REVISION APPROVAL SHEET TITLE:

Snubber Program Document Lnnerick Generating Station. Units I & 2 INTERVAL: Limerick ISJ - Fourth Ten-Vear Snubber Interval ASME CODE OF' RECORD: ASME OM Code, 2004 &Urion through the 2006 Addenda DOCUMENT: __

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LGS-525!i:\\7*02-RP07, Rev 0 Snubber Progrum Docum(?nt-41h Interval Pnge ii REVISION APPROVAL SHEET TITLE; Snubber Program Document Limerick Generating Station, Units l & 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~-5~2~55~3~7-~0~2-_R~P0~7~~

REVISION: _o_

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LGS-525537-02-RP07, Rev 0 Page iii Snubber Program Document* 4tb Jntervul REVISION CONTROL SHEET Each time this document is revised, the following table should be completed to provide a detailed record of 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 he retrieved.

REVISION DAT£ REVISION

SUMMARY

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

Prepared: M. King Re~ iewed; S. Coleman Approved: D. Lamond Note:

1. This Snubber Progrnm Document (Sechons I - 6 inclusive) is controlled by the Limerick Generating Station. Engineering Programs Group.

amec fo* ter wheeler

LGS-525517 *02-RP07. Rev 0 Snubber Progrum Dm:umcnt - 4 111 lntervul REVISION

SUMMARY

SECTION EFFECTIVE PAGES Preface i to *Vi 1.0 1-1 to 1-8 2.0 2-1 to 2-4 3.0 3-1 to 3-5 4.0 4-1 lo 4-5 5.0 5-1 to 5-2 6.0 6-1 to 6-2 Page iv REVISION OAT£ 0

03/03/16 0

03/03/16 0

03/03/16 0

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LGS*52.55J7-02~RP07, Rev 0 Snubber Prugram Document.. 41h Interval Page v TABLE OF CONTENTS SECTION DESCRIPTlON PAGE LO INTRODUCTION AND BACKGROUND................................................................................ 1-1 I. I lntroductmn

1.2 Background

t.. l First Interval Snubber Program 1.4 Second Interval Snubber Program 1.5 Third Interval Snubber Program 1.6 Fourth lntervaJ Snubber Program

1. 7 Code of Federal Regu lalions I OCFR~0.55a Requirements 1.8 ASME OM Code Cases 1.9 Relief Requests 2.0 B.ASIS 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 Detai Is 2.5 Technical Approach and Positions l.O SNUBBER PLAN......,....... ~***i.ftfl;#t********~............................ Al.. fllP****~***,***********.... ****************"*****,..,.,........,........... 3-1

3. I Nonexempt Code Class Snubbers J.2 Snubber General Requirements

~J Visual Examination, Functional Testing. and Service Life Monitoring Program 3.4 Visual Examination. Functiomd Test1ng, and Service Life Monitoring Results 3.5 Reports/Records 4.0 SNUBBER

SUMMARY

TABLE................................................................................................. 4-1 4.1 Snubber Program Summary Table

.5.0 RELIEF REQUESTS FROM ASME OM CODE........................................................................ 5-1

6.0 REFERENCES

...................., **.*** _4,,.......,..............,....... ~ *.*******.******** t........ :f.....,_..........,...................................

_......... ~6-l

6. I NRC References 6.2 Industry References 6.3 Licensee References 6.4 License Renewal References I Commitments ATIACHMENTS Ai Unit I Snubber Details B.

Unit 2 Snubber Details amec foster wheeler

LGS-525537-02-RP07, Rev 0 Snubber Program Do~ument - 4th Interval TABLES TABLE OF CONTENTS (Continued)

DESCRIPTION Page vi PAGE 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................................................................................... 4-3 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-525537-02-RPO?, Rev 0 Page 1-1 Snubber Program Document-4th Interval

1.0 INTRODUCTION AND BACKGROUND

1.1 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 iftheir 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 snubbers, 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 ofNuclear Power Plants (ASME OM Code) requirements.

The Fourth Inservice Inspection (ISI) Interval is effective from February 1, 2017 through January 31, 2027 for LGS Units 1 and 2. With the update to the ISI Program for the Fourth ISi Interval for Class 1, 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, 10CFR50.55a(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 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.

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LGS*525517-02*RP07, Rev 0 Snubber Program Document - 4th Interval Page 1-J I,2

Background

The Philadelphia Electric Company (PECO)t now known commercially a.s Exelon Generation Company (EGC), LLC, obtained Construction Permits to build LGS Units I and 2 on June 19, 1974,. for Unit I, CPPR-I06,. and for Unit 2, CPPR-f07. The Docket Numbers assigned to LGS.50-352 for Unit I and 50-353 for Unit 2, After satisfactory plant construction and pre-operational lcsting was completed, PECO was granted a full-power operating license for Unit 1, NPF-39. and subsequently commenced commercial operation on February I, 1986; the full-power operating license for Unit 2, NPF-85. was granted and commercinl operation commenced on January 8, J 990.

LGS's piping systems and associated components were designed and fabncated to be inspectt!d and lt:sced in accordance with the requirements of ASME Section XL Although this planl was specifically designed to meet the inspection and testing requirements of ASME Section XI. literal complinnce may not be feasible or practical within the limns of the current plant design. Certain limitations are likely to occur due to conditions such as accessibility, geometnc configuration, and/or metallurgical characteristics. For some inspection categories. an alternate component may he 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 requesc will be submiued in accordance with I OCFR50.55a.

1.3 First 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 inspectmn interval.

The ISi Program was required to comply with the latest Edition and Addenda of ASME Section XI incorporated by reference m 10CFR50.55a twelve months prior to the start of the int~rval per HJCFR50.55a(g)(4)(i). Based on this datet the latest Edition and Addenda of ASME Section XI referenced in t OCFR50.55a(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 i. By letter dared 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-npproved version of ASME Section XJ (i.e., 1986 Edition, No Addenda). The voluntary upgrade was initiated to allow LGS Unit I to use the same ASME Section XI Edition ns that required for LGS Unit 2. Similarly. the version of IOCFR50.55a in effect twelve months prior to the issuance of the LGS Unit 2 operating license was ASME Section XI, 1986 Edition. No Addenda. This alignment of applicable Code Editions wns developed to provide a uniform set of requirements for bolh units at LGS, and to preclude any confusion that could result from the use of different requirements forench unit LGS Technical Specifications (TS), Section 3/4 7.4 (TS 3/4.7.4) included comprehensive programs for visual examination ond function al resting of all program snubbers. The program scope encompassed nil program snubbers. LGS TS 3/4.7.4 also included requirements for visual examination of program snubbers per ASME Section XI.

Because IOCFR50.55a did not address snubber testing. the snubber testing requirements of ASME Section XJ, IWF-5000 were not imposed on LGS per TS ~/4.7.4.

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LGS-525.ci'17 -02 ~RP07, Rev 0 Snubber Pr~ram DocuRK?nl

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" Interval Page t-4 The First ISi Interval for LOS Unit I was scheduled lo end on February l, 1996.

However. by letter dated April 6, 1995. PECO nolified the NRC that the inspection intervn1 would be extended until March r, 1996. lo accommodate the sixth refueling outage (Li 1 R06) schedule. Addhionnlly. by leuer duted January 5. 1996, PECO notified the NRC that the inspection tnterval would~ further extended until February I, 1997. to accommodate the preparation and implementation of ASME Sectjon Xl Code pressure tests that were now required ns a result of the NRC's conditional approval of Reli~f Request RR-I 3.

Therefore. the Unit I First ISi lntervnl began on February I, l 986 and ended on January 31, 1997. This one-year extension hns not been recovered to dnte for LGS Unit 1.

The LGS Unit 2 First Inspection Interval began on January 81 1990 nnd ended on January 71 2000. ISi and Repair and Replacement Programs were developed to implement the requirements of the ASME B&PV Code, Secuon XI, 1986 EditionJ No Addenda.

l.4 Second Interval Snubber Program Pursuant to 10CFR50.55a(g). licensees were required to update their ISi Programs to meet lhe requirements of ASME Section XI once every ten years or inspeclmn mterval.

The ISi Program was required to comply with the latest Edition nnd Addenda of ASME Section XI incorporated by reference in IOCFR50.55a twelve months prior to the start of the interval per 10CFR50.55o(g)(4)(ti).

As stated obove, the end of the LOS Unit 1 First ISi Interval was Janunry 31, 1997 and the end of the LGS Unit 2 First ISJ Interval was January 7 ~ 2000. In order to avoid the inherent misalignment or the LOS ASME Section XI Programs. LGS obtained approval from the NRC to begin the LOS Unit 1 ond Common Second ISi 1nterval7 as normally scheduled, using the existing Code requirements (i.e., First ISi Interval requirements). as described in ASME Section Xl, 1986 Edition. No Addenda. Then, in approximately three (3) to four (4) years following the stan of the LGS Unit 1 Second ISi lnterval, 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 nnd Addenda of the ASME Section Xly which was the Code of Record in effect 12 months prior to the start of LGS Unit 2 Second JSI Interval (i.e., 1989 Edition, No Addenda).

ASME Section XI. 1989 Edition, No Addenda. Ankle IWF-5000, lnservice £nspection Requirements for Snubbers, required inservice examinations and rests to be perfonned in accordance with Part4 of ASME/ANSI OMA-1988 Addenda to ASMEIANSJ OM-1987, ASME OM Code. Visual inspections shall use the VT*~ visual examination method described in Parc1graph IWA-2213 and shall include in(egral and non-integral attachments. Relief Request RR-04, authorized per NRC SER dated February 14, 2002.

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

Concurrently, the LGS Second Interval Snubber Program was developed in accordance wuh the requirements of the LOS TS J/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 pennit the use of ASME/ANS[ QM.. J990, Subsection ISTD, Inservice Testing of Dynamic amec foster wheeler

LGS*52.'i5J7.. 02*RP07, Re\\/ 0 Snubber Program Document.. 4' 11 Interval Pnge 1*5 Restraints (Snubber.,) in Light-Water Rt!accor Power Plants m lieu of Pan 4 of ASME/ANSI OMa-1988 Addenda to ASME/ANSI OM-1987. The program described in LGS TS ::l/4.7.4 was comprehensive and met ASME Section Xt IWF*5000 requirements for visual examination and functional testing of program snubbers~ The details of the LOS Snubber Program and examination and tesring requirements were Jocnted in AUG..

13 of th~ ISi Specifications.

As an nhcmative to the full ten-year interval duration requirements of Paragraphs lWA*2430(b) and (d} and Paragraph lWA.. 2432 for the Unit 2 Second Interval ISi Program nod the Unit 2 First Interval CISI Program, LGS has previously approved Re1i~f Request I.JR..() I that modified the interval dates of the Unit 2 Second Interval fSI Program nnd the Unit 2 First Interval CISI Program. This permitted the subsequent ISi nnd CISI Programs to share u common inspechon interval start and end delte and to 1 mplement common Code Editions for Class I, 2, 3, MC, and CC components.

As such, the Second ISi lnrcrvnl was effective from February I. 1997 through Januory 31, 2007 for LGS Unit I and from Jnnuary 8. 2000 throul!h January 31, 2007 for LGS Unit 2.

The LGS Snubber Program was governed by the requirements of T'S 314. 7.4 per Relief Request RR*04.

t.5 Third Interval Snubber Program Pursuant to JOCFR50.55a(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 m IOCFR50.55a twelve months prior to the start of the interval per 10CFR50.55u(g)(4}(ii)~ As discussed in Section J.4 above, the stan of the Third ISi Interval wns on February I. 2007 for LGS Units I nnd 2. Based on this date. the latest Edition and Addenda of ASME.Section XJ referenced in 1 OCFR50.55a{b)(2) twelve months prior lo the start of the Third ISi Interval was the 2001 Edition through the 2003 Addenda.

Concurrently, the LOS Third Interval Snubber Program was developed in accordance with the requirements of 1 OCFR50.55a and the ASME Section XI Paragraphs IWF-5200(a) and (b) and IWF-5300(a) and (b), and required VT-3 Visunl Examinations and Inservice Tests (functional tests) of snuhbers to be perfonned in accordance with the ASME Operation and Maintenance of NucJear Power PJnnts (OM) Code, Standard

.ASMEIANSI OM, Part 4. Relief Request IJR-05, authorized per NRC SER dated March 11, 2008, requested relief from the visunl examination nnd functional testing requirements of Paragraphs IWF... 5200(n), IWF~5300(a), JWF-5200(b). and IWF.. 5300(b).

The purpose of this relief request was to justify replacing the visual examination and functionnl testing requirements of Paragraphs IWF.. 5200(a) and (b) and IWF-5300(a) und (b) and the frequency required by 0Ma.. J988 Addenda to the ASMEJANSI OM-1987 Edition. Part 4, with the requirements of TS 314.7.4.. Per 10CFR50.55a(b)(3)(v). visual examinations shail be performed using the VT-1 visual examination method described in Paragraph IW A-2213. The details of che LOS Snubber Program and examination and testing requiremenls were located in AUG-13 of the ISJ Augmented Inspection Program.

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LGS-525517*02-RP07, Hev 0 Snubber Program Document.. 4 11' Interval Pnge 1~6 The LGS Third lSI Interval was effective from February I, 2007 through January 31, 2017 for Units J and 2.

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

1.6 Fourth Interval Snubber Program Pursunnl to IOCFR505.5a(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 Xl incorporated by reference in I OCFR50.55a twelve months pnor to the start of the Fourth ISi Interval per 10CFR50.55a(g)(4)(ii). As discussed ;n Section 1.5 nbove, the start of the Fourth ISi Interval will be on February J. 2017, for LOS Units I and 2. Based on this date1 the latest Edition and Addenda of ASME Section XI referenced in IOCFR50.55a(b)(2) twelve months prior to the start of the Fourth ISi Interval wns the 2007 Edition through the 2008 Addenda.

Concurrently, the LGS Fourth Interval Snubber Program Document was developed in accordance with the requiremems of I OCFR..'50.55a and lhe ASME OM Code, 2004 Edition through the 2006 Addenda. subject to the limitations nnd modifications contained within Paragraph (b) of the regulation. These limitations and modifications nre 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 end safety evaluations (SE's),

nnd ul&lizes 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 IOCFR50.55a(b)(3)(v)(B).

l. 7 Code of Federal Regulations I OCFR50.55a Requirements There are certain paragraphs in 10CFR5055a that list the limitations, modifications, and/or clarifications to the implementation requirements of ASME OM Code. Subsection

!STD. These Paragraphs in 10CFRSO.S5a that are applicable to LOS are detailed in Table J.7-J.

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LGS-525~B7-Q2.. RP07. Rev 0 Snubber Program Document* 4 11* Jntervul Pnge 1-7 TABLE 1.7-1 CODE OF FEDERAL REGULATIONS 10CFR50.S5a REQUIREMENTS 10CFR50.55a Paragraphs 1 OCFR50.55a(b)(l )(v)(B) l OCFR50.55a(b)(6)

Limitations, Modifications, and Clarification.Iii

{Snubber) OM cond11wn: Snubbers /STD. An1cle IWF-5000, "lnservice Inspection Requirements for Snubbers, of the ASME BPV Code,Section XI, must be used when performing inservice inspection exammations and tests of ~nubbers at nuclear power plnnts, except as conditioned in paragraphs (b)(3)(v)(B) of this section.

(B) Snubbers: Semnd provmon: Licensees must comply with the provisions for examining and les.ting snubbers in Subsection ISTD of the ASME OM Code and make appropnate changes to their technical specifications or licensee-controlled documents when usmg the 2006 Addenda nnd later Editions and Addenda of Section XI of the ASME BPV Code.

(Snubber) Conditums on Opemtwn and Maintenance of Nut.fear Power Plants Code C1ues: Licensees may apply the ASME Operation and Mainlenance Code Cases listed in Regulatory Guide 1.192 without prior NRC approval subject to the following:

(i) OM Code Case condition: Applying Code Cases: 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 Cc1de Case condition: ApplJi11g d~fferent revlsians Cude Case.~: lf a licensee has previously applied a Code Case and a later version of the Code Case is incorporated by reference in paragraph (a) of this sectiont the licensee may continue to apply. to lhe end of lhe current 120-month intervnft the previous version of the Code Case as authorized or may upply the Inter version of the Code Case. including any NRC-specified conditions placed on its use. Licensees who choose to continue use of the Code Case dunng subsequent 120-month lSI program intervals will be required to implement the latest version incorporated by reference into 1 OCFR..'i0.5Sa as listed in Tables l and 2 of Regulatory Guide 1. I 92.

(iii) OM Cade Ca.fe rnndition: Applying annulled Code Case.i:

Application of an annulled Code Case is prohibited unless a licensee previously applied the listed Code Case pnor to it being listed us annulled in Regulatory Guide 1.192. If a licensee has applied a lisled Code Case that is iater listed as annulled in Regulatory Guide I.192.

the Jicensee may continue to apply the Code Case to the end of the current 120-month interval.

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LGS-525517-02-RP07, Rev 0 Snubber Program Document* 4*fi lnlervnl Page 1-8 1.8 ASM E OM Codt: Cases Per toCFR50.55a(b)(6), ASME OM Code Cases thnt have been determined to be suitoble for use in the Snubber Program by the NRC are hsted in Regulatory Guide 1.192, 0 0peration and Maintenance Code Case Acceptability, ASME OM Code:* The approved Code Cases in Regulatory Guide 1.192, which are bemg utilized by LOS. are included in Section 2.L I. The most recent version of a given Code Cnse incorporated in the revision of Regulatory Guide 1.192 referenced in I OCFR50.55a(b)(6)(i) at lhe time it is applied within the Snubber Program shall be used. As this guide is revised, newly approved Code Cases may be nssessed for phm implementation at LGS per Paragrnph ISTA-3200(e) and proposed for use in revisions lo the Snubber Program Document.

The use of other Code Coses (than those listed in Regulatory Guide 1.192) mny be nuthorized by the Director of the Office of Nuclear Reactor Regulation upon request pursuant to 10CFR50.55a(z). Code Cases not npproved for use in Regulatory Guide 1.192. which are being utilized by LGS through associaL~d relief requests, ure included in Section 5.0.

1.9 Relief Requests In accordance with 10CFR50.55a. when n licensee either proposes alternatives to ASME OM Code requiremenls which provide an ncceptable level of qunlhy and safety.

determines compJiunce 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 testin!?

are impractical,. the licensee shall notify the NRC and submit informatmn to support the determination.

The submittal of this information will be referred to in this document as a urelief request." Relief requests for the Fourth Interval Snubber Program document are included in Section 5.0 of this document. The texl 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 J OCFR50.55a(l)( 1 ), 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 nre consjdered impractical per I OCFR5055a(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 detennines is authonzed by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideracion 10 the burden upon the licensee thot could result if the requirements were imposed on rhe facility.'*

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