RA-22-0616, Revision to Brunswick Snubber Program Plan

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Revision to Brunswick Snubber Program Plan
ML23005A111
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 01/05/2023
From: Dewire M
Duke Energy Progress
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Office of Nuclear Reactor Regulation, Document Control Desk
References
RA-22-0616
Download: ML23005A111 (1)
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Text

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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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1.0 PURP OSE

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 Subsec tions 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 per sonnel 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/exam ination 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 exami nations, 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 t o 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 s ubmits 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 Operat ing 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 Determina tions.
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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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5.2 Snubber Program Plan

1. Each NGD site is responsible for implementation activi ties 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 H istory.
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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 Assuranc e (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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 result s 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 c riteria.
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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 sat isfying 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 s uccessfully 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 i n 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 o f 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 0BN P-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 p rogram 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 p rogram 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 t hat 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

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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 S NU-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 ide ntify 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 wil l 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 i n 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 operat ional 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

Page 21 of 30

5.8 Operational Readiness Testing (continued)

12. Degraded snubbers should be replaced with new or rebuil t 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 req uirements, which will be exempt for concurrent test interval.
2. For BNP, all hydraulic snubbers belong to a single DTPG.

BRUNSWICK NUCLEAR PLANT AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 deriv ed 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 Attachment 2, 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 F MG 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN Rev. 4

Page 26 of 30 ATTACHMENT 1 Page 1 of 1

<< Visual Examination Table >>

BRUNSWICK NUCLEAR PLANT AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 twoyear 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 AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 BP-12212 1-E11-53SS192 BP-10792 1-CO-202SS19 BP-122191-E11-53SS195 BP-10795 1-DW-203SS2 BP-126021-E11-53SS197 BP-10797 1-DW-203SS7 BP-126071-E11-53SS200 BP-15200 1-DW-203SS8 BP-126081-E11-53SS464 BP-15464 1-DW-203SS9 BP-126091-E11-53SS465 BP-15465 1-E11-1SS302 BP-153021-E11-53SS466 BP-15466 1-E11-1SS303 BP-153031-E11-54SS551 BP-15551 1-E11-2SS396 BP-153961-E11-54SS552 BP-15552 1-E11-2SS413 BP-154131-E11-60SS423 BP-15423 1-E11-3SS403 BP-154031-E11-60SS425 BP-15425 1-E11-4SS397 BP-153971-E11-60SS437 BP-15437 1-E11-4SS399 BP-153991-E11-60SS438 BP-15438 1-E11-4SS401 BP-154011-E11-60SS440 BP-15440 1-E11-5SS398 BP-153981-E11-60SS443 BP-15443 1-E11-5SS400 BP-154001-E11-60SS451 BP-15451 1-E11-5SS402 BP-154021-E11-60SS452 BP-15452 1-E11-6SS404 BP-154041-E11-60SS453 BP-15453 1-E11-37SS95 BP-106951-E11-60SS454 BP-15454 1-E11-37SS184 BP-107841-E11-187SS77 BP-10677 1-E11-50SS201 BP-152011-E41-19SS103 BP-11103 1-E11-50SS467 BP-154671-MVD-330SS105 BP-15105 1-E11-50SS468 BP-154681-SGT-10SS17 BP-1281 1-E11-51SS546 BP-15546 1-E11-51SS547 BP-15547 1-E11-51SS1188 BP-17188

BRUNSWICK NUCLEAR PLANT AD-EG-BNP-1618 SNUBBER PROGRAM PLAN 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 BP-22212 2-E11-51SS546 BP-25546 2-CO-202SS19 BP-222192-E11-51SS547 BP-25547 2-DW-203SS2 BP-226022-E11-53SS192 BP-20792 2-DW-203SS7 BP-226072-E11-53SS195 BP-20795 2-DW-203SS8 BP-226082-E11-53SS197 BP-20797 2-DW-203SS9 BP-226092-E11-53SS200 BP-25200 2-DW-203SS48 BP-226482-E11-53SS464 BP-25464 2-DW-223SS49 BP-226492-E11-53SS465 BP-25465 2-DW-223SS50 BP-226502-E11-53SS466 BP-25466 2-DW-223SS51 BP-226512-E11-54SS551 BP-25551 2-E11-1SS302 BP-253022-E11-54SS552 BP-25552 2-E11-1SS303 BP-253032-E11-60SS423 BP-25423 2-E11-2SS396 BP-253962-E11-60SS425 BP-25425 2-E11-2SS413 BP-254132-E11-60SS437 BP-25437 2-E11-3SS403 BP-254032-E11-60SS438 BP-25438 2-E11-4SS397 BP-253972-E11-60SS440 BP-25440 2-E11-4SS399 BP-253992-E11-60SS443 BP-25443 2-E11-4SS401 BP-254012-E11-60SS451 BP-25451 2-E11-5SS398 BP-253982-E11-60SS452 BP-25452 2-E11-5SS400 BP-254002-E11-60SS453 BP-25453 2-E11-5SS402 BP-254022-E11-60SS454 BP-25454 2-E11-6SS404 BP-254042-E11-188SS77 BP-21077 2-E11-37SS95 BP-206952-E11-196SS574 BP-25574 2-E11-37SS184 BP-207842-E41-19SS103 BP-21103 2-E11-50SS201 BP-252012-E51-17SS94 BP-21294 2-E11-50SS467 BP-25467 2-E11-50SS468 BP-25468

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