RA-22-0616, Revision to Brunswick Snubber Program Plan
| ML23005A111 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/05/2023 |
| From: | Dewire M Duke Energy Progress |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RA-22-0616 | |
| Download: ML23005A111 (1) | |
Text
e.f_-, DUKE
~ ENERGY January 5, 2023 Serial: RA-22-0616 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Revision to Brunswick Snubber Program Plan Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461
Reference:
Letter from Bryan B. Wooten (Duke Energy) to U.S. Nuclear Regulatory Commission, Snubber Program Plan for Fifth 10-Year Interval lnservice Testing Program, dated January 10, 2018, ADAMS Accession Number ML18010A579.
Ladies and Gentlemen:
In accordance with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Subsection ISTA-3200(a),
"Administrative Requirements," on January 10, 2018, Duke Energy Progress, LLC (Duke Energy), provided an information copy of AD-EG-BNP-1618, Brunswick Nuclear Plant Snubber Program Plan, Revision O (i.e., Reference). The program was developed to satisfy the snubber preservice and inservice testing and examination requirements of the ASME OM Code, 2004 Edition through 2006 Addenda, and is applicable to the fifth 10-year interval for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.
AD-EG-BNP-1618 was revised on December 8, 2022, adopting ASME OM Code Case OMN-13. The revised plan is enclosed, for information only.
This document contains no regulatory commitments.
Please refer any questions regarding this submittal to Mr. Stephen Yodersmith, Brunswick Regulatory Affairs, at (910) 832-2568.
Ma k R. DeWire Manager - Nuclear Support Services Brunswick Steam Electric Plant
U.S. Nuclear Regulatory Commission Page 2 of 2
Enclosure:
AD-EG-BNP-1618, Brunswick Nuclear Plant Snubber Program Plan, Revision 4 cc (with Enclosure):
Ms. Laura Dudes, NRC Regional Administrator, Region II Mr. Luke Haeg, NRC Project Manager Mr. Gale Smith, NRC Senior Resident Inspector Chair - North Carolina Utilities Commission Mr. Donald Kinney, NC Department of Labor, Boiler Safety Bureau Chief
RA-22-0616 Enclosure AD-EG-BNP-1618, Brunswick Nuclear Plant Snubber Program Plan, Revision 4
Information Use BRUNSWICK UNIT 0 ADMINISTRATIVE PROCEDURE AD-EG-BNP-1618 BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN REVISION 4
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 2 of 30 REVISION
SUMMARY
PRR 2447318 DESCRIPTION Editorial changes to Section 1.0 Step 1.
Added snubber definition Section 3.0 Step 9.
Revised Section 4.1 Step 11 from "Performs" to "Assists with."
Revised Section 4.1 Step 14 to reference program document.
Deleted previous Step 4.1.15, 4.1.17.
Revied newly numbered Section 4.1 Step 17 and Section 4.1 Step 18.
Added Section 4.1 Step 23.
Revised header for Section 4.2, Section 4.3, and Section 4.4 from "Plant" to "Site."
Added reference to AD-OP-ALL-0105 to Section 4.3 Step 1.
Added "as required by code rulemaking" to Section 4.4 Step 3.
Revised Section 5.1 Step 1.
Revised Section 5.2 Step 1.
Deleted Step 5.2.3.
Revised newly numbered Section 5.2 Step 3 and Section 5.2 Step 5.
Added Section 5.4 Step 3 to describe OM Code visual inspections.
Revised Section 5.6 Step 2, Section 5.6 Step 4, Section 5.6 Step 5, Section 5.6 Step 6, and Section 5.6 Step 8.
Added Section 5.6 Step 11.d for unacceptable snubbers.
Revised Section 5.6 Step 12 to provide guidance for snubbers that do not meet visual examination acceptance criteria.
Deleted previous Section 5.6 Step 14.
Added Section 5.6 Step 14 and Section 5.6 Step 15from OMN-13.
Revised Section 5.6 Step 16.
Revised Section 5.7 Step 1 and Section 5.7 Step 2.
Added Section 5.14 Step 3, to reference requirements of 0OI-01.06 and 0PT-19.6.3.
Deleted Note prior to Section 7.1, updated references and added Section 7.2 Procedure 3, and Section 7.3 Miscellaneous Document 12.
Revision by C. Sexton
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 3 of 30 TABLE OF CONTENTS SECTION.......................................................................................................................... PAGE 1.0 PURPOSE..................................................................................................................... 5 2.0 SCOPE.......................................................................................................................... 5 3.0 DEFINITIONS................................................................................................................ 6 4.0 RESPONSIBILITIES...................................................................................................... 7 5.0 INSTRUCTIONS.......................................................................................................... 10 5.1 General........................................................................................................................ 10 5.2 Snubber Program Plan................................................................................................ 11 5.3 IDDEAL Software Suite............................................................................................... 12 5.4 Test and Examination Scheduling............................................................................... 12 5.5 Snubber Categorization............................................................................................... 13 5.6 Visual Examination...................................................................................................... 13 5.7 Service Life Monitoring................................................................................................ 18 5.8 Operational Readiness Testing................................................................................... 19 5.9 Defined Test Plan Group (DTPG)................................................................................ 21 5.10 Testing Sample Plans.................................................................................................. 22 5.11 Sample Expansion....................................................................................................... 22 5.12 Snubber Replacement................................................................................................. 23 5.13 Snubber Deletion......................................................................................................... 23 5.14 Transient Dynamic Events........................................................................................... 23 6.0 RECORDS................................................................................................................... 24
7.0 REFERENCES
............................................................................................................ 24 ATTACHMENTS 1
Visual Examination Table............................................................................................ 26 2
37 Test Plan................................................................................................................ 27
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 4 of 30 TABLE OF CONTENTS (continued)
SECTION.......................................................................................................................... PAGE ATTACHMENTS 3
Fluid Level Trending and Corrective Actions............................................................... 28 4
Snubbers with 12-Hour LCO Completion Times.......................................................... 29
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 5 of 30 1.0 PURPOSE
- 1.
The purpose of the Snubber Program Plan is to define methods used to develop, administer, and implement the Snubber Program at Brunswick Nuclear Plant (BNP) Units 1 and 2. This document provides a systematic approach for implementing visual examinations, operability testing, and service life monitoring for snubber population at BNP, as well as general guidelines for executing program responsibilities, corrective actions, and record keeping, for compliance with regulatory requirements.
2.0 SCOPE
- 1.
NRC endorses ASME Code for Operation and Maintenance of Nuclear Power Plants for inspection and testing of snubbers, as stipulated in 10CFR50.55a and NUREG-1482. Specifically, ASME OM Code Subsections ISTA and ISTD govern the snubber examination and testing activities for BNP. This is effective for the fifth 10-year IST interval for Units 1 & 2, which has a start date of December 22, 2017 and expiration date of December 22, 2027.
- 1.
This program envelopes scope described in ASME OM Code, 2004 edition through 2006 addenda, Subsection ISTA, Article ISTA-1100, which is defined as the following:
- a.
Snubbers used in systems that perform a specific function in shutting down a reactor to the safe shutdown condition.
- b.
Snubbers used to maintain the safe shutdown condition.
- c.
Snubbers employed to mitigate the consequences of an accident.
- d.
Snubbers used to ensure the integrity of reactor coolant pressure boundary.
- 2.
BNP Snubber Program Plan also applies to all snubbers except those installed on Non-Safety Related systems, which may be excluded provided their failure or failure of system on which they are installed would not have an adverse effect on any Safety Related system.
- 3.
In keeping with good engineering practice and to provide reasonable assurance of structural reliability, any remaining snubbers not identified above (i.e.,
Non-Safety Related) may be included and inspected/monitored as part of BNP Snubber Program.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 6 of 30 3.0 DEFINITIONS
- 1.
Acceptable: A snubber that has been examined or tested and is shown to meet examination or testing acceptance criteria.
- 2.
Accessible: Snubbers that can be readily examined or tested during normal plant operations without exposing plant personnel to undue hazards or dose, or placing operating equipment at risk.
- 3.
Defined Test Plan Group (DTPG): A population of snubbers selected for testing in accordance with the snubber testing sample plan.
- 4.
Degraded: Any snubber that has an examination or testing parameter that is approaching, but has not exceeded the limits of the acceptance criteria.
- 5.
Failure Mode Group (FMG): A group of snubbers that have failed and those other snubbers that have similar potential for similar failure.
- 6.
Inaccessible: Snubbers that are located in environments which make it impractical for the snubbers to be examined under normal plant operations without exposing plant personnel to undue hazards (e.g., radiation or extreme heat) or putting plant equipment at risk.
- 7.
Safety-Significant Snubbers: Snubbers designated as Non-Safety Related but determined that their failure or the failure of the system on which they are installed would have an adverse effect on any safety-related system.
- 8.
Service Life: The period of time a snubber is expected to meet the operational readiness requirements without maintenance.
- 9.
Snubber: Dynamic restraints that are utilized to allow slow, constant movement of an attached component while providing rigid restraint against rapid motion due to dynamic loads.
- 10.
Test Campaign: The series of actions required to complete the testing of DTPG samples for a specific cycle.
- 11.
Transient Dynamic Event: An unexpected or potentially damaging occurrence, which was determined from reviews of operating data or during a visual inspection/examination such as a water/steam hammer, earthquake or similar event.
- 12.
Unacceptable: Snubbers that do not meet examination or testing acceptance criteria.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 7 of 30 4.0 RESPONSIBILITIES NOTE The general roles and responsibilities for the execution of Nuclear Generation Department (NGD) Engineering Programs are outlined in AD-EG-ALL-1006, Conduct of Fleet Programs Engineering, and AD-EG-ALL-1618, Snubber Program Plan.
Specific activities and responsibilities for those organizations and individuals that are involved with the implementation of the Snubber Program at BNP are outlined below.
4.1 Fleet Engineering Programs - Snubber Program Manager
- 1.
Ensures that Snubber Programs are effectively managed and implemented to meet regulatory, process, and procedure requirements.
- 2.
Provides governance and oversight of the Snubber Program as well as set strategic and technical direction.
- 3.
Maintains qualifications in accordance with the Program Managers respective ESP Program in which they are enrolled. No additional qualifications specific to the Snubber Program Manager position exist at either the Fleet or Site levels.
- 4.
Establishes, prepares, and maintains snubber testing and examination Program Plans, implementing procedures, and schedules.
- 5.
Assigns examination and testing requirements for snubbers, as identified in the BNP Snubber Program Plan.
- 6.
Maintains the IDDEAL Software Suite Database (SnubbWorks) for snubbers.
- 7.
Coordinates the performance of scheduled and non-scheduled snubber examination and testing activities, preventive maintenance and condition monitoring activities.
- 8.
Selects and identifies snubbers for examination, testing, and service life activities.
- 9.
Reviews test and examination results for acceptability.
- 10.
Evaluates results of examinations and tests which fail to meet acceptance criteria.
- 11.
Assists with operability evaluations for snubbers, as required.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 8 of 30 4.1 Fleet Engineering Programs - Snubber Program Manager (continued)
- 12.
Generates corrective actions:
- a.
Action Requests (ARs)
- b.
Nuclear Condition Reports (NCRs)
- c.
Work Requests (WRs) in support of Program activities
- 13.
Determines the extent of additional examinations, tests, or repairs which may be required following the discovery of an unacceptable snubber condition.
- 14.
Establishes, monitors, and tracks the service life of installed snubbers and maintains the controlled listing in program document SNU-BNP-1618-01, BNP Installed Snubber Listing.
- 15.
Provides pertinent information to the implementing work groups.
- 16.
Identifies the applicable procedures required to satisfy the examination or testing requirements, per the BNP Snubber Program Plan.
- 17.
Identifies and submits the required snubber work scope to the On-Line work management, Outage work management, and/or Planning work groups.
- 18.
Manages the snubber work scope, including content, additions, deletions, expansions, and corrections.
- 19.
Compares current recorded results with the prior or expected results to determine snubber continued service and/or corrective actions.
- 20.
Identifies Licensing or Code requirements which cannot be achieved due to impracticality or hardship and initiates actions (i.e., Relief Request) necessary to notify the Nuclear Regulatory Commission (NRC).
- 21.
Establishes industry contacts with ASME OM Code committee representatives, peers at other nuclear utilities, and outside consultants to ensure that the Snubber Program effectively utilizes external Operating Experience (OE).
- 22.
Reviews plant design changes and revises the BNP Snubber Program Plan, as required.
- 23.
Assists with Operability Evaluations for snubbers as required.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 9 of 30 4.2 Site Maintenance
- 1.
Ensures that snubber functional testing is performed in accordance with the applicable station procedures.
- 2.
Records the results of the snubber tests, examinations, and as-found or as-left conditions of the snubber, in accordance with the appropriate station procedures.
- 3.
Reports findings on the appropriate data sheet(s) and notifies the Snubber Program Manager.
- 4.
Repairs, rebuilds, or replaces snubbers, as required by the Snubber Program.
4.3 Site Design Engineering
- 1.
Performs operability evaluations on piping systems or components per AD-OP-ALL-0105, Operability Determinations.
- 2.
Notifies Snubber Program Manager of plant design changes that may impact the Snubber Program.
4.4 Site Regulatory Affairs
- 1.
Provides licensing support of the Snubber Program.
- 2.
Processes relief requests.
- 3.
Submits Snubber Program Plan documents to Regulatory Authorities as required by code or rulemaking.
4.5 Qualified Snubber Inspector / Qualified Snubber Maintenance Technician /
Qualified QC Mechanical Inspector / Certified Nondestructive Examination (NDE)
VT-3 Examiners
- 1.
Record the as found or as left conditions of the snubber in accordance with the appropriate station procedures.
- 2.
Reports findings on the appropriate data sheet(s) and notifies the Snubber Program Manager.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 10 of 30 5.0 INSTRUCTIONS 5.1 General
- 1.
For the purposes of this procedure, Snubber Program Manager refers to a designee or other person assigned to fulfill responsibilities described in Section 4.1.
- 2.
ASME OM Code requirements are identified and administered by the implementation of this document.
- 3.
This document (i.e., BNP Snubber Program Plan) contains the overall details and implementation requirements for examination, testing, and service life monitoring of snubbers. The plan details the appropriate snubber categorization, the examination and test plan(s) required to be performed each refueling cycle, and service life monitoring of all plant installed snubbers.
- 4.
During the 10-year interval between required program updates, the BNP Snubber Program Plan may periodically be subject to revision. Reasons for revision include, but are not limited to:
- a.
Incorporation of Relief Requests
- b.
Incorporation of Code Cases
- c.
NRC Regulatory Guides, Notices, and Bulletins
- d.
Augmented examinations
- e.
Organizational/Responsibility changes
- f.
Plant License changes
- g.
Snubber replacements
- h.
Snubber Service Life Monitoring updates
- i.
Modifications to the plant that impact the Snubber Program
- 5.
Generation and revision to BNP Snubber Program Plan are made in accordance with applicable corporate and site procedures.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 11 of 30 5.2 Snubber Program Plan
- 1.
Each NGD site is responsible for implementation activities of the Snubber Program Plan, herein referred to as the Program. Snubber Program Plans may use Controlled Supporting Documents or controlled Program Documents (Type PGMD) to provide supplemental information.
- 2.
BNP Snubber Program Plan is developed and maintained in accordance with AD-DC-ALL-0201, Development and Maintenance of Controlled Procedure Manual Procedures.
- 3.
On a periodic basis the BNP Snubber Program Plan may be revised as applicable to update pertinent information. All updates will be documented in the BNP Snubber Program Plan Revision History.
- 4.
10-Year Updates:
- a.
Once every 10 years, the site Snubber Program Plan requires updating to the code edition and addenda as specified in 10CFR50.55a.
- b.
The site Snubber Program Plan shall be filed with the regulatory authorities having jurisdiction as required by ASME OM, Subsection ISTA-3200, and/or 10 CFR 50.55a requirements. The Plan filing shall have a cover sheet providing the information requested by ISTA-9220.
- 5.
Changes to program testing or inspection methodologies may require BNP Snubber Program Plan to be re-submitted to regulatory authorities. Changes that may require resubmittal include code revision updates, utilization of code cases or regulatory relief, revised test sample plans, or any changes that significantly alter the plan implementation from existing commitments. Routine periodic revisions to address items such as organizational changes or editorial items (updated references, correct typographical errors, formatting, etc.) do not require resubmittal but may be submitted as a courtesy notification.
- 6.
Snubbers which have a 12-hour replacement window in accordance with LCO 3.0.8b and Technical Requirements Manual 3.21, Required Compensatory Measure B2, are listed in Attachment 4, Snubbers with 12-Hour LCO Completion Times.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 12 of 30 5.3 IDDEAL Software Suite
- 1.
IDDEAL Software Suite is a non-QA software program that is governed in accordance with AD-IT-ALL-0002, Software Quality Assurance (SQA) Program Administration.
- 2.
IDDEAL Software is used to:
- a.
Store component information, examination and testing history, and examination and testing schedules.
- b.
Administer and implement Inservice Inspection (ISI), Inservice Testing (IST), Snubber, and Balance of Plant (BOP) Programs.
- 3.
SnubbWorks (one of the IDDEAL applications) is a Microsoft Access based computer program used as a tool to manage Snubber Program information. This software program is used to organize pertinent data and records to assist with snubber examination, testing, and service life monitoring purposes. Information contained in SnubbWorks is not QA, but can be used to produce documents or lists which, when verified, can be used as QA records.
- 4.
Examination and test reports may be generated by SnubbWorks software to document examination and test results, unless otherwise directed by the Site Implementing Procedures.
5.4 Test and Examination Scheduling
- 1.
Test and examination scheduling routinely coincides with refueling outages.
Performing testing and examinations during refueling outages allows for improved accessibility, environmental conditions conducive for examination methods, and reduced exposure (ALARA).
- 2.
Examinations and functional testing may be performed during plant operation or during refueling outages, as conditions allow. Functional testing for test plan credit may begin no earlier than 60 days prior to scheduled start of a refueling outage.
- 3.
OM Code required Inservice visual examination activities at BNP are scheduled via predefined model work orders. The associated PMID-RQ's are listed in 0PT-19.6.0A, Visual Inspection of Accessible Hydraulic Snubbers, and 0PT-19.6.0B, Visual Inspection of Inaccessible Hydraulic Snubbers.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 13 of 30 5.5 Snubber Categorization
- 1.
Snubbers at BNP are considered a single population (for each unit) for examination intervals outlined in ASME OM Code, Subsection ISTD, Table 4252-1 (See Attachment 1, Visual Examination Table). In accordance with ASME OM Code, Article ISTD-4220, snubbers are categorized as accessible or inaccessible for workload reduction during outages.
- a.
Decision to examine all snubbers as a single population or as separate populations may be made during or after the examination.
- b.
When recombining categories into one population, shorter interval of categories will be used.
- c.
Categorization is in accordance with ASME OM Code, Article ISTD-4220.
5.6 Visual Examination
- 1.
Visual examination will be performed in accordance with ASME OM Code, Subsection ISTD, to verify that no visible indications of damage or impaired functionality exist and attachments to foundation or support structure are secure.
- 2.
Visual examination activities for snubbers will be conducted in accordance with BNP Procedure 0PT-19.6.0A, Visual Inspection of Accessible Hydraulic Snubbers, 0PT-19.6.0B, Visual Inspection of Inaccessible Hydraulic Snubbers, 0CM-SUP505, Bergen-Paterson Hydraulic Shock and Sway Arrestor Removal, Installation, and Maintenance, or 0PT-19.6.3, Inspection of Safety-Related Snubbers Which Have Experienced An Unusual Shock, as applicable, which meets requirements outlined in ASME OM Code, Subsection ISTD.
- 3.
Accessible snubbers are visually examined under 0PT-19.6.0A, Visual Inspection of Accessible Hydraulic Snubbers. The snubbers under this periodic test procedure are divided into multiple groups organized primarily by system and loop. These examinations are performed online during system windows.
- 4.
Snubber groups 21 and 22 are located in high dose areas during plant operation.
Snubber group 4 is located in an area of highly sensitive instrumentation during plant operation. Although accessible for online, these groups may be scheduled during refueling outages at the discretion of Operations and Work Management.
- 5.
Inaccessible snubbers are visually examined under 0PT-19.6.0B, Visual Inspection of Inaccessible Hydraulic Snubbers. The snubbers under this periodic test procedure are divided into two groups for the purpose of the visual inspections based on Drywell elevation.
- 6.
Specific snubbers on the Reactor Recirculation system are inspected every outage for fluid level per the recommendations of calculation 0SNUB-0007, Lower Elevations Drywell Snubber Seal Life.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 14 of 30 5.6 Visual Examination (continued)
- 7.
All snubber groups are tracked by ST PMs to ensure schedule requirements are met.
- 8.
Visual examination of as-found conditions will be performed prior to conducting any maintenance, stroking, or testing, and prior to disconnecting or removing any snubber, to determine presence of visible damage or impaired functional ability due to physical damage, leakage, corrosion, or degradation from environmental exposure or operating conditions, and to document position of snubber with respect to compression/extension. Additional discussion of fluid level is provided in Attachment 3, Fluid Level Trending and Corrective Actions.
- 9.
Snubbers with unacceptable visual examination results may be evaluated by performing operational readiness testing (i.e., functional testing) in as-found condition. In accordance with ASME OM Code, Article ISTD-4240, snubbers satisfying operational readiness testing acceptance criteria may be reclassified as acceptable visual examinations.
- 10.
Hydraulic snubbers found with fluid port uncovered, and all hydraulic snubbers found connected to a non-functional common reservoir, will be classified as unacceptable unless a functional test establishes that the performance of the snubber satisfies operational readiness test acceptance criteria.
- 11.
In accordance with ASME OM Code, Subsection ISTD, Articles 4270 and 4280, Snubber Program Manager (or designated individual knowledgeable in snubber operability requirements) will perform an evaluation for any snubber identified as not meeting acceptance criteria.
- a.
An evaluation will be performed to determine type and cause of visual examination discrepancy and effect on operability of snubber and related components.
- b.
If an unacceptable condition is determined to be generic, then additional examinations may be required, or a Work Request may be generated to correct any discrepancies found, as appropriate.
- c.
For any snubber determined to be unacceptable or unsatisfactory, Snubber Program Manager or designee will initiate a NCR.
- d.
Unacceptable snubbers shall be adjusted, repaired, modified, or replaced.
- 12.
All snubbers identified during the period that do not meet the visual examination acceptance criteria shall be considered as "Unacceptable" when determining the length of the following period in accordance with Table ISTD-4242-1. This includes snubbers identified outside of the scheduled examination process.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 15 of 30 5.6 Visual Examination (continued)
- 13.
An augmented scope is invoked in cases where a visual examination is to be performed as a supplemental scope, outside of program requirements.
- 14.
Verification of satisfying OMN-13 Prerequisites:
- a.
ISTD-4251 states that the initial examination interval of snubbers shall begin no sooner than 2 months after attaining 5% reactor power operation and shall be completed by the end of the first refueling outage. This prerequisite is considered met since at the time of OMN-13 adoption Unit 1 is in its 25th fuel cycle and Unit 2 in its 26th fuel cycle.
ISTD-4252 deals with subsequent examination intervals. These intervals begin at the end of the previous examination interval and conclude at the end of the next refueling outage. It states that the duration of examination intervals following completion of the second refueling outage shall be in accordance with Table ISTD-4252-1.
The maximum interval of two cycles (48 months) was successfully utilized for the intervals which encompassed Cycles 23/24 for Unit 1 and 24/25 for Unit 2. For Unit 1 and Unit 2, zero snubbers were identified during the interval as being unacceptable in accordance with the Visual Examination Acceptance Criteria. This is well within the Table ISTD-4252-1 Column B interpolated allowable limit of 22 unacceptable snubbers for Unit 1 (population of 475) and 24 unacceptable snubbers for Unit 2 (population of 501). Therefore it is acceptable to extend the interval in accordance with OMN-13 for this prerequisite.
- b.
OMN-13 paragraph 3.1 through 3.6 requirements are as follows.
(1)
OMN-13 paragraph 3.1 states: "Examinations per paras.
ISTD-4210, ISTD-4220, ISTD-4230, and ISTD-4240 shall include examination for indications of degradation and severe operating environments." All snubber examinations were or are performed using procedures NDEP-0613, 0PT-19.6.0A, 0PT-19.6.0B, 0PT-19.6.3 or 0CM-SUP505 which have included such indications in the examination attributes.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 16 of 30 5.6 Visual Examination (continued)
(2)
OMN-13 paragraph 3.2 states: "All snubbers shall be examined in accordance with the requirements of paras. ISTD-4210, ISTD-4220, ISTD-4230, and ISTD-4240 and para. 3.1 of this Code Case prior to conducting any maintenance, stroking, or testing, and prior to removal, for any reason, from their installed location."
Snubber removal and maintenance has primarily been performed using 0CM-SUP505. This procedure requires the prerequisite examination as described in the referenced paragraphs.
Throughout the prior interval 0BNP-TR-008, Inservice Inspection/Testing Guideline, has also required a visual examination prior to snubber removal or performance of a maintenance activity. Early in the prior interval, prior to 0CM-SUP505 being revised to include visual examination as part of its scope when the program was updated from an ASME Section XI program to an ASME OM Code program, visual examinations prior to maintenance were performed as VT-3 examinations in accordance with NDEP-0613 and documented in the implementing work order. These examinations also met the requirements of the ISTD paras. referenced above. In some cases during the prior interval, the condition requiring maintenance was identified during a VT-3 examination on a separate work order from the one performing the maintenance. However, the examination was performed prior to the maintenance, therefore, this prerequisite is met for those activities.
(3)
OMN-13 paragraph 3.3 states: "Fluid level in hydraulic snubber reservoirs shall be sufficient to ensure that the snubber is acceptable for continued service to the next examination interval."
Procedures 0PT-19.6.0A, 0PT-19.6.0B, 0PT-19.6.3 and 0CM-SUP505 include requirements for verifying snubber fluid levels are within acceptable limits. Following update of the program to the ASME OM Code, Attachment 3, Fluid Level Trending and Corrective Actions, of this procedure (AD-EG-BNP-1618) has provided guidance for fluid level trending and corrective actions when fluid levels are found below nominal levels. During the early part of the prior interval, when the program was performed in accordance with ASME Section XI, this guidance was contained in 0ENP-16.15, Administrative Procedure of the Snubber Program.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 17 of 30 5.6 Visual Examination (continued)
(4)
OMN-13 paragraph 3.4 requires that inservice test data be evaluated for indications and anomalies indicative of progressive degradation and to also identify severe operating environments not previously identified. This occurs during required Operational Readiness Testing and is considered within the Service Life Monitoring activities as described in Section 5.7 and Section 5.8 of this document (AD-EG-BNP-1618). Results are documented using PMID-RQs 2164-01 (Unit 1) and 2165-01 (Unit 2). During the early part of the prior interval, when the Program was performed in accordance with ASME Section XI, this evaluation was required in 0ENP-16.15.
(5)
OMN-13 paragraph 3.5 states: "Snubbers and snubber parts shall be examined for indications of degradation and severe operating environments during disassembly (e.g., during failure evaluation, refurbishment)." BNP has refurbished snubbers in accordance with 0CM-SUP506 for the duration of the prior interval. During refurbishment, degraded parts are identified and replaced. These indications provide data to inform evaluations of Service Life as described in Section 5.7 of this document (AD-EG-BNP-1618) and Section 5.1.2.3 of 0ENP-16.15 (during the early part of the prior interval when the Program was performed in accordance with ASME Section XI). This type of examination is also considered as part of failure evaluations required in accordance with Section 5.8.
(6)
OMN-13 paragraph 3.6 states: "The service life evaluation required by para. 2.1 of this Code Case shall include any transient dynamic event and actions taken under ISTD-1750." For the duration of the prior interval 0PT-19.6.3 has been in place to direct examination on snubbers that have experienced a potentially damaging transient event. As described in Section 5.7, Section 5.8, and Section 5.14, of this document (AD-EG-BNP-1618) all examinations performed in response to a dynamic event and any failures identified are accounted for within the scope of Service Life Monitoring activities.
- 15.
The start date for adoption of the OMN-13 Code Case is the date of issuance for revision 4 of this procedure, AD-EG-BNP-1618. From that date, unless the period is truncated in accordance with OMN-13, 3.7(b) each snubber shall be examined within 10 years of that snubber's most recent previous examination on an ongoing basis. Should such truncation be required this procedure (AD-EG-BNP-1618) shall be revised to document the required inspection interval.
- 16.
Snubber visual examination boundaries shall include the snubber assembly from pin to pin, inclusive.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 18 of 30 5.7 Service Life Monitoring NOTE BNP Snubber Program Plan includes a Service Life Monitoring component which addresses requirements outlined in ASME OM Code, Article ISTD-6000.
- 1.
An estimated service life has been established for each installed snubber within program scope and documented in SNU-BNP-1618-01, BNP Installed Snubber Listing.
- a.
Snubber service life will be reviewed by Snubber Program Manager at least once each fuel cycle.
- b.
Snubbers that will reach end of service life during the upcoming cycle will be identified for replacement or refurbishment.
- 2.
Previously established service life durations for installed snubbers will be evaluated prior to each fuel cycle for continued applicability. Snubber listing SNU-BNP-1618-01 will be periodically updated to reflect evaluation results (updates generally occur on an annual basis), and evaluation methodology /
basis for conclusions will be clearly documented in outage summary reports (PMID-RQ 2164-01 (Unit 1) or 2165-01 (Unit 2), or other QA documentation.
- a.
For hydraulic snubbers, estimated seal life is generally governing factor for overall service life. Seal life is based on Original Equipment Manufacturer (OEM) recommendations, actual experience, and/or seal life studies.
- b.
Historical data should be reviewed to identify any trends regarding service life values.
- 3.
If service life of any snubbers will be exceeded prior to next scheduled system or plant outage, one of the following actions will be taken:
- a.
Snubbers will be replaced with a snubber for which service life will not be exceeded before next scheduled system or plant outage.
- b.
Technical justification will be documented for extending service life to or beyond next scheduled system or plant outage.
- c.
Snubbers will be reconditioned such that service life will be extended to or beyond next scheduled system or plant outage.
- 4.
Each outage summary report will address service life for all applicable snubbers, including those scheduled for replacement / service life extension and those whose service life will not be exceeded prior to either the next refueling outage or next scheduled maintenance activity.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 19 of 30 5.7 Service Life Monitoring (continued)
- 5.
If testing is conducted specifically for service life monitoring purposes, the results of such testing do not require testing of additional snubbers.
5.8 Operational Readiness Testing
- 1.
Safety Related snubber population will be tested for operational readiness during each fuel cycle, to verify that:
- a.
Activation (restraining action) is achieved within specified range in both tension and compression.
- b.
Snubber bleed or release rate, where required, is present in both tension and compression, within specified range.
- c.
Where required, force required to initiate or maintain motion of snubber is within specified range in both directions of travel.
- d.
For snubbers specifically required not to displace under continuous load, ability of snubber to withstand load without displacement.
- 2.
Non-Safety Related snubbers may be tested at discretion of Snubber Program Manager.
- 3.
Operational readiness testing will be performed in accordance with testing sample plans defined in Section 5.9.
- 4.
Test scheduling will be established in accordance with Section 5.4. In accordance with ASME OM Code, Article ISTD-5240, snubber testing may begin no earlier than 60 days before a scheduled refueling outage.
- 5.
Snubbers will be tested in their as-found condition regarding parameters to be tested to fullest extent practicable.
- a.
Test methods will not alter condition of a snubber to extent that results do not represent as-found snubber condition.
- b.
Pipe snubbers will be removed from field installation and bench tested in accordance with BNP Procedure 0PT-19.6.1.
- c.
Snubbers will not be subjected to prior preventive or corrective maintenance (i.e., pre-conditioning) specifically for purpose of meeting applicable examination or testing requirements. Verification of freedom of motion upon snubber removal is not considered to be pre-conditioning.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 20 of 30 5.8 Operational Readiness Testing (continued)
- 6.
Snubbers that are maintained or repaired by removing/adjusting a part that can affect results of applicable tests required by this program, will be examined/tested before returning to service. Applicable installation requirements will also be met. Requirements selected will ensure that affected parameters are verified to be acceptable through examination/testing.
- 7.
Applicable site maintenance procedures will govern removal and reinstallation of plant installed snubbers. BNP Procedure 0CM-SUP505, Bergen-Paterson Hydraulic Shock and Sway Arrestor Removal, Installation, and Maintenance, is the governing procedure for all snubber removal/restoration activities.
- 8.
Each snubber will have an as-found visual examination performed prior to removal activities and an as-left visual examination following reinstallation.
- 9.
For each Safety Related snubber determined to be unacceptable by operational readiness testing, additional snubbers will be tested in accordance with ASME OM Code, Article ISTD-5270. Number of additional snubbers tested is dependent upon testing sample plan being utilized.
- a.
Unacceptable (i.e., failed) snubbers will be evaluated and documented in accordance with Corrective Action Program (NCR).
(1)
The evaluation shall include review of information related to other unacceptable snubbers found during that test campaign.
- b.
An engineering evaluation will be performed on System, Structure, or Component (SSC) to which unacceptable snubbers are attached.
(1)
Engineering evaluation is performed to determine whether SSC to which inoperable snubbers are attached was adversely affected by inoperability of snubbers, to ensure that SSC remains capable of meeting designed service.
- 10.
If a snubber selected for functional testing either fails to activate or fails to move (i.e., frozen-in-place), cause will be evaluated and, if caused by manufacturer or design deficiency, all snubbers of same type and subject to same defect will be evaluated to ensure functionality.
- 11.
For Non-Safety Related snubbers determined to be unacceptable by operational readiness testing, additional tests may be required to address extent of condition and service life concerns in accordance with Corrective Action Program.
Requirement for additional testing will be determined by Snubber Program Manager.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 21 of 30 5.8 Operational Readiness Testing (continued)
- 12.
Degraded snubbers should be replaced with new or rebuilt snubbers as a preventive maintenance action. Scope expansion is not required for degraded snubbers unless deemed necessary to address extent of condition concerns.
Additional snubbers may be tested or replaced at discretion of Snubber Program Manager, based on cause of degradation and potential impact on service life assumptions. Information gathered from degraded snubbers will be considered in service life monitoring program, as applicable.
- 13.
Unacceptable snubbers shall be adjusted, repaired, modified, or replaced.
- 14.
Test equipment failure during functional testing may invalidate all testing performed during respective day, unless it can be determined exactly when failure occurred and which snubbers were affected. Failed testing equipment will be repaired or replaced.
- 15.
Initial test performed for an inservice snubber test will be maintained as as-found test of record. If multiple tests are performed for any reason, all test results will be saved and documented. Copies of all tests will be included with test procedure records, and reason for performing multiple tests will be documented.
Snubber Program Manager may provide additional comments or justification as an attachment to procedure, as required.
- 16.
Test results will be reviewed for adverse trends, to help establish service life for specific snubbers or locations.
- 17.
Snubbers placed in same locations as snubbers which failed previous functional test will be retested at time of next scheduled functional test, unless cause of failure is clearly established and corrected. Such snubbers will not be considered as part of functional testing sample. Failures found by these retests shall not require additional testing in accordance with Section 5.11, Sample Expansion, but shall be evaluated for appropriate corrective action.
- 18.
Each snubber in a parallel or multiple-snubber installation will be identified and counted individually.
- 19.
Fractional sample sizes will be rounded up to next integer.
5.9 Defined Test Plan Group (DTPG)
- 1.
DTPGs will include all Safety Related or Safety Significant snubbers, with exception of replacement snubbers and snubbers repaired/adjusted as a result of not meeting acceptance requirements, which will be exempt for concurrent test interval.
- 2.
For BNP, all hydraulic snubbers belong to a single DTPG.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 22 of 30 5.10 Testing Sample Plans
- 1.
Safety Related snubbers in each DTPG at BNP will be tested in accordance with one of the below listed testing plans in accordance with ASME OM Code, Subsection ISTD.
- a.
37 Test Plan.
- b.
10% Test Plan.
NOTE If test plan selection is changed after Plan submittal to Regulatory Authorities, it may be necessary that revised BNP Snubber Program Plan be re-submitted.
- 2.
BNP currently utilizes the 37 Test Plan. Initial sample selection will be random, as described in ASME OM Code, Articles ISTD-5311 & 5411.
- 3.
Test plan will be selected for each DTPG before scheduled testing begins and will be used throughout refueling outage campaign for that DTPG and any Failure Mode Group (FMG) that is derived from it.
- 4.
For unacceptable snubber(s), additional testing will continue within DTPG or FMG, as described in Section 5.11.
5.11 Sample Expansion
- 1.
After determination that a snubber is unacceptable, an additional test plan sample will be established. Additional test sample size will be as required per ASME OM Code, Article ISTD-5270.
- a.
37 Test Plan supplemental samples will consist of either 18 or 19 randomly selected snubbers, based on number of unacceptable snubbers and numerical expression provided in ASME OM Code, Article ISTD-5431, per ASME OM Code, Article ISTD-5412 (See, 37 Test Plan).
- b.
10% Test Plan supplemental samples will consist of an additional population of at least one-half size of initial sample from that DTPG population, per ASME OM Code, Article ISTD-5312.
- 2.
In addition to required test plan sample expansion, a FMG test population may be established. In accordance with ASME OM Code, Articles ISTD-5272 & 5273, unacceptable snubbers may be categorized into a FMG containing all unacceptable snubbers with a given failure cause and all other snubbers vulnerable to same cause.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 23 of 30 5.12 Snubber Replacement
- 1.
Snubber replacement will be performed in accordance with BNP Procedure 0CM-SUP505.
- 2.
Any replacement or modified snubbers will have a proven suitability for application and environment.
- 3.
Replacement or modified snubbers will be examined and tested prior to placing them into service. Test results from the manufacturer for new snubbers or from the rebuild vendor may be utilized.
5.13 Snubber Deletion
- 1.
Snubbers may be deleted from plant, based on analysis performed for affected piping system. When an unacceptable snubber is subsequently deleted prior to completion of the test campaign, deleted snubber will still be considered in its respective examination population, examination category, or FMG for determining corrective action.
- 2.
Number of deleted snubbers failing/passing tests or examinations prior to being deleted will be used in determining examination/testing frequencies.
5.14 Transient Dynamic Events
- 1.
During each outage, systems having potential to experience a severe dynamic event will be reviewed to determine whether a severe dynamic event has occurred.
- 2.
If an unanticipated dynamic event (e.g., water hammer, steam hammer, beyond Design Basis Event (DBE), etc.) occurs that may affect snubber operability, then affected snubbers and systems will be reviewed and any appropriate corrective action taken. Event information, scope of review, and actions taken will be documented in Corrective Action Program (NCR).
- a.
Program Manager will notify System Engineer and/or Design Engineering to define extent of evaluation for affected system.
- b.
Snubbers within affected region will be examined, stroked, or tested as deemed appropriate to address concern.
- c.
In many cases, condition monitoring stroke testing which has been planned/completed may sufficiently address concern.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 24 of 30 5.14 Transient Dynamic Events (continued)
- 3.
As part of 0OI-01.06, Post Trip Review, performed following a planned or unplanned Unit trip, Operations is required to notify the Engineering Duty Manager to evaluate the need for visual walkdowns and snubber inspections in accordance with 0PT-19.6.3, Inspection of Safety-Related Snubbers Which Have Experienced an Unusual Shock, on any systems affected by an unanticipated transient dynamic event during the trip.
6.0 RECORDS
- 1.
Records of inspections, tests, repairs, evaluations, and outage summaries will be maintained within an appropriate Work Order or periodic test procedure. Work Orders and/or PMID histories are searchable in the Nuclear Asset Suite (NAS) application.
- 2.
No records generated from this procedure.
7.0 REFERENCES
7.1 Commitments None 7.2 Procedures
- 1.
0CM-SUP505, Bergen-Paterson Hydraulic Shock and Sway Arrestor Removal, Installation and Maintenance
- 2.
0CM-SUP506, Rebuild of Bergen-Paterson Hydraulic Shock and Sway Arrestors
- 3.
0OI-01.06, Post Trip Review
- 4.
0PT-19.6.0A, Visual Inspection of Accessible Hydraulic Snubbers
- 5.
0PT-19.6.0B, Visual Inspection of Inaccessible Hydraulic Snubbers
- 6.
0PT-19.6.1, Snubber Functional Testing
- 7.
0PT-19.6.3, Inspection of Safety-Related Snubbers Which Have Experienced An Unusual Shock
- 8.
AD-DC-ALL-0201, Development and Maintenance of Controlled Procedure Manual Procedures
- 9.
AD-DC-ALL-0301, Development and Maintenance of Controlled Supporting Documents
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 25 of 30 7.2 Procedures (continued)
- 10.
AD-EG-ALL-1000, Conduct of Engineering
- 11.
AD-EG-ALL-1006, Conduct of Fleet Programs Engineering
- 12.
AD-EG-ALL-1202, Preventive Maintenance and Surveillance Testing Administration
- 13.
AD-EG-ALL-1450, Preconditioning of Structures, Systems, and Components
- 14.
AD-EG-ALL-1618, Snubber Program Plan
- 15.
AD-IT-ALL-0002, Software Quality Assurance (SQA) Program Administration 7.3 Miscellaneous Documents
- 1.
0BNP-TR-008, Inservice Inspection/Testing Guideline
- 2.
0SNUB-0006, Lower Elevation Drywell and Balance of Plant Snubber Seal Life
- 3.
0SNUB-0007, Lower Elevations Drywell Snubber Seal Life
- 4.
ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants
- 5.
Code of Federal Regulations: 10CFR50.55a, Codes and Standards
- 6.
INPO EPG-07, Engineering Program Guide - Snubbers
- 7.
NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants - Inservice Testing of Pumps and Valves and Inservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants
- 8.
Regulatory Guide 1.192, Operation and Maintenance Code Case Applicability, ASME OM Code
- 9.
Regulatory Guide 1.193, ASME Code Cases Not Approved for Use
- 10.
SNU-BNP-1618-01, BNP Installed Snubber Listing
- 11.
UFSAR, Section 3.9.3 & 5.2.4
- 12.
Unit 1 (Unit 2), Technical Requirements Manual. Section 3.21
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 26 of 30 ATTACHMENT 1 Page 1 of 1
<< Visual Examination Table >>
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 27 of 30 ATTACHMENT 2 Page 1 of 1
<< 37 Test Plan >>
37 Test Plan Mathematical Expression Testing satisfies the mathematical expressions as follows:
(a) For each DTPG:
N 36.49 + 18.18C (Fig. ISTD-5431-1) where:
N = total number of snubbers tested that were selected from the DTPG C = total number of unacceptable snubbers found in the DTPG (excluding those counted in FMG tests), plus one for each applicable FMG requiring additional tests in accordance with ISTD-5424 (b) For each FMG requiring additional tests:
NF 18.18Cf where:
NF = all snubbers selected and tested after the FMG was established from DTPG CF = total number of unacceptable snubbers in the FMG, plus those found in the DTPG and used to establish the FMG
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 28 of 30 ATTACHMENT 3 Page 1 of 1
<< Fluid Level Trending and Corrective Actions >>
- 1.
The current practice of replacing snubbers pulled for service life or for functional testing precludes any meaningful trending of functional test data. However, fluid levels recorded during visual examination provide a parameter for monitoring snubber fluid leakage and indirectly the sealing capability of snubber seals.
- 2.
Snubbers identified during visual examinations with leakage or a total indicated fluid level of less than 5-3/4 inch on 6 inch stroke snubbers require a review of previous examination data to investigate adverse trending.
- 3.
Corrective actions will be dependent upon the magnitude of reduction in fluid level over previous examinations.
- a.
Accessible snubbers identified with evidence of active leakage should be re-examined at approximately two-year intervals if not replaced.
- b.
Inaccessible snubbers identified with active leaks and not replaced will be scheduled for examination during the next refueling outage.
- c.
If corrective action is addition of snubber fluid, a visual examination will be performed for trending purposes.
- 4.
Any safety-related snubber with a total indicated fluid level of less than 3.25 inch for 6 inch stroke snubbers or a total indicated fluid of less than the thermal movement for 2 inch stroke snubbers will be pulled and functionally tested per 0PT-19.6.1, Snubber Functional Testing for operability.
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 29 of 30 ATTACHMENT 4 Page 1 of 2
<< Snubbers with 12-Hour LCO Completion Times >>
The following list identifies those snubbers which have a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> completion time in accordance with LCO 3.0.8b and TRM 3.21 Required Compensatory Measure B2:
Unit 1 Snubbers Component Drawing Component Drawing 1-CO-202SS12 1-CO-202SS19 1-DW-203SS2 1-DW-203SS7 1-DW-203SS8 1-DW-203SS9 1-E11-1SS302 1-E11-1SS303 1-E11-2SS396 1-E11-2SS413 1-E11-3SS403 1-E11-4SS397 1-E11-4SS399 1-E11-4SS401 1-E11-5SS398 1-E11-5SS400 1-E11-5SS402 1-E11-6SS404 1-E11-37SS95 1-E11-37SS184 1-E11-50SS201 1-E11-50SS467 1-E11-50SS468 1-E11-51SS546 1-E11-51SS547 1-E11-51SS1188 BP-12212 BP-12219 BP-12602 BP-12607 BP-12608 BP-12609 BP-15302 BP-15303 BP-15396 BP-15413 BP-15403 BP-15397 BP-15399 BP-15401 BP-15398 BP-15400 BP-15402 BP-15404 BP-10695 BP-10784 BP-15201 BP-15467 BP-15468 BP-15546 BP-15547 BP-17188 1-E11-53SS192 1-E11-53SS195 1-E11-53SS197 1-E11-53SS200 1-E11-53SS464 1-E11-53SS465 1-E11-53SS466 1-E11-54SS551 1-E11-54SS552 1-E11-60SS423 1-E11-60SS425 1-E11-60SS437 1-E11-60SS438 1-E11-60SS440 1-E11-60SS443 1-E11-60SS451 1-E11-60SS452 1-E11-60SS453 1-E11-60SS454 1-E11-187SS77 1-E41-19SS103 1-MVD-330SS105 1-SGT-10SS17 BP-10792 BP-10795 BP-10797 BP-15200 BP-15464 BP-15465 BP-15466 BP-15551 BP-15552 BP-15423 BP-15425 BP-15437 BP-15438 BP-15440 BP-15443 BP-15451 BP-15452 BP-15453 BP-15454 BP-10677 BP-11103 BP-15105 BP-1281
BRUNSWICK NUCLEAR PLANT SNUBBER PROGRAM PLAN AD-EG-BNP-1618 Rev. 4 Page 30 of 30 ATTACHMENT 4 Page 2 of 2
<< Snubbers with 12-Hour LCO Completion Times >>
Unit 2 Snubbers Component Drawing Component Drawing 2-CO-202SS12 2-CO-202SS19 2-DW-203SS2 2-DW-203SS7 2-DW-203SS8 2-DW-203SS9 2-DW-203SS48 2-DW-223SS49 2-DW-223SS50 2-DW-223SS51 2-E11-1SS302 2-E11-1SS303 2-E11-2SS396 2-E11-2SS413 2-E11-3SS403 2-E11-4SS397 2-E11-4SS399 2-E11-4SS401 2-E11-5SS398 2-E11-5SS400 2-E11-5SS402 2-E11-6SS404 2-E11-37SS95 2-E11-37SS184 2-E11-50SS201 2-E11-50SS467 2-E11-50SS468 BP-22212 BP-22219 BP-22602 BP-22607 BP-22608 BP-22609 BP-22648 BP-22649 BP-22650 BP-22651 BP-25302 BP-25303 BP-25396 BP-25413 BP-25403 BP-25397 BP-25399 BP-25401 BP-25398 BP-25400 BP-25402 BP-25404 BP-20695 BP-20784 BP-25201 BP-25467 BP-25468 2-E11-51SS546 2-E11-51SS547 2-E11-53SS192 2-E11-53SS195 2-E11-53SS197 2-E11-53SS200 2-E11-53SS464 2-E11-53SS465 2-E11-53SS466 2-E11-54SS551 2-E11-54SS552 2-E11-60SS423 2-E11-60SS425 2-E11-60SS437 2-E11-60SS438 2-E11-60SS440 2-E11-60SS443 2-E11-60SS451 2-E11-60SS452 2-E11-60SS453 2-E11-60SS454 2-E11-188SS77 2-E11-196SS574 2-E41-19SS103 2-E51-17SS94 BP-25546 BP-25547 BP-20792 BP-20795 BP-20797 BP-25200 BP-25464 BP-25465 BP-25466 BP-25551 BP-25552 BP-25423 BP-25425 BP-25437 BP-25438 BP-25440 BP-25443 BP-25451 BP-25452 BP-25453 BP-25454 BP-21077 BP-25574 BP-21103 BP-21294