RNP-RA/14-0061, Submittal of Snubber Examination and Testing Program

Submittal of Snubber Examination and Testing Program

ML14163A089
Person / Time
Site:	Robinson
Issue date:	05/29/2014
From:	Peavyhouse S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/14-0061
Download: ML14163A089 (31)

Text

Sharon W Peavyhouse

~DUKE H. B. Robinson Steam Electric Plant Unit 2 ENERGY Dir - Nc Org Effectiveness Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0: 843 857 1584 F: 843 857 1319 Sharon.Peavyhouse(4duke-energycom Serial: RNP-RA/14-0061 ASME OM Code ISTA-3200(a)

MAY 2 9 2014 Attn: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-26 1/RENEWED LICENSE NO. DPR-23 SUBMITTAL OF SNUBBER EXAMINATION AND TESTING PROGRAM FOR H. B.

ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 Ladies and Gentlemen:

Per the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM)

Code, Subsection ISTA-3200(a), Administrative Requirements, Duke Energy Progress, Inc. hereby submits the H. B. Robinson Steam Electric Plant, Unit No. 2 Shock Suppressor(Snubber)

Examination and Testing ProgramManual (TMM-006), Revision 16, to the Nuclear Regulatory Commission for information. Should you have any questions regarding this matter, please contact Mr. Richard Hightower, Manager - Nuclear Regulatory Affairs at (843) 857-1329.

This document contains no new Regulatory Commitments.

Sincerely, Sharon W. eeavyhouse Director - Nuc Org Effectiveness SWP/jmw Attachment c: V. McCree, NRC, Region II Ms. Martha C. Barillas, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP2

-Act -7

United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/14-0061 30 Pages (Including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT (HBRSEP), UNIT NO. 2 TMM-006 - Shock Suppressor (Snubber) Examination and Testing Program. Revision 16

R Progres EReference "sr EUse H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 6 PART 1 TMM-006 SHOCK SUPPRESSOR (SNUBBER) EXAMINATION AND TESTING PROGRAM REVISION 16 I TMM-006 Rev. 16 Page 1 of 29

SUMMARY

OF CHANGES PRR 514720, CR 573237 Step/Section REVISION COMMENTS Entire Re-written in its entirety to comply with RNP's Fifth 10-Year Interval Code Procedure (OM Code) Update. Revised to implement Revised to implement Technical Specification LCO 3.0.8 in August 2013 (PRR 514720, CR 573237)

Entire Reformatted Headings to Writers Guide criteria. (Editorial)

Procedure Corrected all cross referenced steps to be auto cross referenced (Editorial)

Old 2.3 Replaced CM-216 reference with superseding procedures CM-M-GNRL-SNBR-001, 008, & 009 (Editorial)

Old 2.4 Replaced CM-401 with superseding procedures CM-M-GNRL-SNBR-002

& CM-M-SG-SNBR-002 (PRR 584245) (Editorial)

Old 2.5, 2.6, Deleted references to CM-402, CM-404, CM-408, & CM-409 as 2.9, 2.10 requested by Tech reviewer. (Editorial)

Old 2.8 Replaced CM-406 with superseding procedure CM-M-SG-SNBR-001.

(PRR 584161) (Editorial)

Old 2.16 & 5.1 Deleted information for PLP-037 IPTE does not apply to this procedure.

(Editorial)

Old 2.20 Deleted CAP-NGGC-0201 because it is a program procedure. (Editorial) 2.0 Rearranged section to place procedures at the end of the section.

(Editorial) 2.7 Added reference to AR 508610, Snubber Program Self Assessment (Editorial) 2.13 Replaced CM-405 with CM-M-GNRL-SNBR-004 (PRR 572779)

(Editorial) 2.14 through Added references to maintenance procedures. (Editorial) 2.18 2.25 Added EGR-NGGC-0213 reference (Editorial) 3.0 Renumbered and reordered Definitions Section and added OM Code ISTD definitions (Editorial) 4.1 Change Supv-Equip Performance to Supv-Component Support Eng. as requested by Tech reviewer. (Editorial) 4.2 Changed "ISI Specialist" to "ISI Program Manager" 6.5.1.2 Table Reformatted Snubber / calculation list picture to a table format.

(Editorial) 6.2 Replaced TMM-015 with superseding procedure EGR-NGGC-0211 (Editorial) 9.3.8.4.a.2), Changed Grinnell to "Anvil and Grinnell" 3), and 4)

TMM-006 Rev. 16 Page 2 of 29

TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ...................................................................................................... 4

2.0 REFERENCES

................................................................................................. 4 3.0 DEFINITIO NS ................................................................................................... 7 4.0 RESPONSIBILITIES ........................................................................................ 9 5.0 PREREQUISITES ............................................................................................ 9 6.0 PRECAUTIONS AND LIM ITATIO NS ............................................................ 10 7.0 SPECIAL TOO LS AND EQ UIPM ENT ............................................................. 14 8.0 ACCEPTANCE CRITERIA .............................................................................. 14 9.0 INSTRUCTIONS ............................................................................................. 15 10.0 RECO RDS .......................................................................................................... 27 11.0 ATTACHM ENTS ............................................................................................ 27 11.1 VISUAL EXAM INATIO N FLOW CHART ................................................... 28 11.2 FUNCTIO NAL TESTING FLOW CHART .................................................. 29 I TMM-006 Rev. 16 1 Page 3 of 29

1.0 PURPOSE 1.1 The purpose of this procedure is to describe the Snubber Visual Examination and Functional Testing and Seal Life Monitoring Program at the Robinson Nuclear Plant. This program provides a method of assuring compliance with the ASME OM Code, 2004 Edition through the 2006 Addenda "Code for Operation and Maintenance of Nuclear Power Plants", and PLP-025, "In-Service Inspection Programs", ASME Section Xl (Boiler and Pressure Vessel Code), 2007 Edition, 2008 Addenda, "Rules for Inspection of Nuclear Power Plant Components".

1.2 Visual examinations, functional testing and service life monitoring requirements are contained in Subsection ISTD of the ASME OM Code, 2004 Edition through 2006 Addenda.

1.3 The scope of the Snubber Visual Examination, Functional Testing and Service Life Monitoring Program at the Robinson Nuclear Project includes, as a minimum, dynamic restraints (snubber) used in systems that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident, or to ensure the integrity of the reactor coolant pressure boundary. The scope includes safety related snubbers as listed in step 6.5.1.3.

1.4 Non-Safety Related snubbers are not addressed by the ASME Section Xl or OM Code requirements and therefore, considered an Augmented Non-Safety Scope.

In keeping with good engineering practice, to provide assurance of structural reliability, these snubbers are periodically inspected under an Augmented Scope in accordance with PM-142, "Non-Safety Related Shock and Sway Suppressor Visual Inspection" as required.

2.0 REFERENCES

2.1 ASME OM Code, 2004 Edition through the 2006 Addenda, "Code for Operation and Maintenance of Nuclear Power Plants 2.2 ASME Section Xl, 2007 Edition, 2008 Addenda, Boiler and Pressure Vessel Code, "Rules for Inservice Inspection of Nuclear Power Plant Components" 2.3 Technical Specification 3.0.8, Snubbers 2.4 Technical Specification 5.5.8, Inservice Testing 2.5 CR 98-01668, Snubber Program Self Assessment 2.6 Assessment Number 15259, Snubber Self Assessment 2.7 AR 508610, Snubber Program Self Assessment TMM-006 Rev. 16 Page f2

2.8 Evaluation of Operating Characteristics of Safety Related Hydraulic Shock Suppressors at H.B. Robinson Unit No. 2, dated July 3, 1979, filed under Outline of Equipment File No. 2-G-1 (bases for small bore hydraulic suppressor functional test acceptance criteria, Number 13 through 26, 28, 29, 30, and 35).

2.9 Vendor Manual 727-702-17, Technical Instruction Manual for Hydraulic Shock Suppressors (bases for functional test acceptance criteria for large bore Anker-Holth/Paul Monroe Suppressors, Number 1-12) 2.10 Vendor Manual 728-626-26, Mechanical Shock Arrestors (bases for functional test acceptance criteria for Pacific Scientific Arrestors, Number 31, 32, 33, 34, and 36) 2.11 EC 51344 R1, Removal of Snubbers 31 and 32.

2.12 ADM-NGGC-0101, Maintenance Rule Program 2.13 CM-M-GNRL-SNBR-001, Grinnell or Anvil Hydraulic Snubber Removal and Reinstallation 2.14 CM-M-GNRL-SNBR-004, 500K Anker Holth Shock and Sway Suppressor Maintenance 2.15 CM-M-GNRL-SNBR-008, Bergen-Paterson Hydraulic Snubber Removal and Reinstallation 2.16 CM-M-GNRL-SNBR-009, Pacific Scientific Mechanical Snubber Removal and Reinstallation 2.17 CM-M-SG-SNBR-001, SG Snubber Fluid System Pressure TEST 2.18 CM-M-SG-SNBR-002, Steam Generator Hydraulic Snubbers Removal and Reinstallation 2.19 EST-032, Visual Examination of Hydraulic and Mechanical Shock Suppressors 2.20 EST-033, Functional Testing of Hydraulic and Mechanical Shock Suppressors Snubbers) 2.21 PLP-025, Inservice Inspection Programs 2.22 PM-142, Non-Safety Related Shock and Sway Suppressor Visual Inspection 2.23 EGR-NGGC-0008, Engineering Programs 2.24 EGR-NGGC-021 1, ASME Section Xl Repair/Replacement Program 2.25 EGR-NGGC-0213, Snubber Program TMM-006 Rev. 16 Page 5 of29

2.26 NGGM-PM-001 1, Nuclear NDE Manual 2.27 NDEP-A, Nuclear NDE Program and Personnel Process 2.28 NDEP-0613, VT-3 Visual Examination of Nuclear Power Plant Components 2.29 ESR 9700613, Service Life For Small Bore Snubbers 2.30 Lake Engineering Report Number LEC-304-R1, "Seal Life Evaluation of Anker-Holth Snubbers, H.B. Robinson Station", dated 8/30/00 (performed during RFO-19)

I TMM-006 I Rev. 16 Page 6 of 29

3.0 DEFINITIONS 3.1 Acceptable - A snubber that is capable of performing its specified function(s) by meeting the requirements of Subsection ISTD.

3.2 Accessible - Snubbers that can be readily examined or tested during normal plant operations without exposing plant personnel to undue hazards or radiological dose.

3.3 Activation - The change of condition from passive to active, in which the snubber resists rapid displacement of the attached pipe or component. This is sometimes referred to as lock-up rate when discussing hydraulic snubbers.

3.4 Application-Induced Failure - Failures resulting from environmental conditions or applications of the snubber for which it has not been qualified.

3.5 Defined Test Plan Group (DTPG) - A population of snubbers from which samples are selected for testing in accordance with the 10% or 37 testing sample plan.

3.6 Design or Manufacturing Failure - Failures resulting from a potential defect in manufacturing or design that give cause to suspect other similar snubbers.

3.7 Diagnostic Testing - Testing to determine the case or mechanism associated with failure, degradation or performance anomaly of a snubber.

3.8 Drag Force - The force that will sustain low velocity snubber movement without activation throughout the working range of the snubber stroke.

3.9 Failure Mode Group (FMG) - A group of snubbers that have failed and those other snubbers that have similar potential for similar failure.

3.10 Functional Failure - Snubber that does not satisfy the operational readiness test acceptance criteria.

3.11 Functional Testing - Performing the ISTD required operational readiness testing to ensure performance parameters meet specified criteria.

3.12 Inaccessible Snubbers - 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 or radiological dose.

ITMM-006 Rev. 16 1 Page 7 of29

3.13 Maintenance, Repair and Installation-Induced Failures - Failures that result from damage during maintenance, repair, or installation activities, the nature that causes other snubbers to be suspect.

3.14 Normal Operating Conditions - Operating conditions during reactor start-up, operating at power, hot standby, reactor cooldown and cold shutdown.

3.15 Operating Temperature - The temperature of the environment surrounding a snubber at its installed plant location during the phase of operation for which the snubber is required.

3.16 Operational Readiness Testing - Measurement of the parameters that verify snubber operational readiness.

3.17 Release Rate - The rate of the axial snubber movement under a specified load after activation of the snubber takes place. This is sometimes referred to as bleed rate with hydraulic snubbers.

3.18 Replacement Snubber - Any snubber other than the snubber immediately previously installed at a given location.

3.19 Service Life - The period of time an item is expected to meet the operational readiness requirements without maintenance or replacement.

3.20 Service Life Population - Those snubbers for which the same service life has been established.

3.21 Shock Suppressor, Suppressor Snubber - Hydraulic and mechanical dynamic restraints designed for use on piping systems or equipment which allow unrestrained thermal growth, but provide controlled restraint during dynamic or cyclic disturbances.

3.22 Swing Clearance - The movement envelope within which the snubber must operate without restriction, from the cold installed position to the hot operating position.

3.23 Test Temperature - The temperature of the snubber, snubber fluid, AND the environment surrounding the snubber at the time of testing.

I TMM-006 Rev. 16 Page 8 of 29 1

3.24 Transient Dynamic Event Failure - Inability of a snubber to perform its intended function due to an unanticipated transient dynamic event.

3.25 Unacceptable Snubbers - Snubbers that do not meet the examination or testing requirements of subsection ISTD.

3.26 Unexplained Failure - Failure for which the cause has not been determined.

4.0 RESPONSIBILITIES 4.1 Supervisor - Component Support Engineering The Supervisor - Component Support Engineering is responsible for compliance with this procedure.

4.2 ISI Program Manger The ISI Program Manager is responsible for review of the completed ISI visual examinations specified in this procedure for ASME Section XI credit.

4.3 Snubber Program Manager The Snubber Program Manager is responsible for the performance of the visual examinations and functional testing specified in this procedure.

5.0 PREREQUISITES N/A TMM-006 Rev. 16 Page 9 of29

6.0 PRECAUTIONS AND LIMITATIONS 6.1 Visual examinations shall be performed in order to meet the requirements set forth in Subsection ISTD-4200, and shall be documented per EST-032, Visual Examination of Hydraulic and Mechanical Shock Suppressors.

6.2 Functional testing shall be performed to meet the requirements of Subsection ISTD-5200, and shall be documented per EST-033, Functional Testing of Hydraulic and Mechanical Shock Suppressors (Snubbers).

6.3 Service life monitoring shall be performed and evaluated at least once per cycle per Subsection ISTD 6200, in accordance with EST-032, Visual Examination Of Hydraulic And Mechanical Shock Suppressors (Snubbers).

6.4 The visual examination boundary shall include snubber assembly from pin to pin, inclusive. Any concerns detected outside of the ISTD examination boundary should also be documented and evaluated.

6.5 Visual examinations on safety related snubbers shall be performed by a VT-3 (Level II or Ill) Examiner, certified in accordance with NDEP-A, Nuclear NDE Program and Personnel Process or approved Vendor Program. VT-3 Certification documentation shall be attached to the associated EST for record retention.

I TMM-006 Rev. 16 1 Page 10of 29I

6.5.1 Prior to performing EST-032, the personnel performing the visual examination shall be provided with the current revision of snubber related calculations that include snubber "as-built" drawings.

1. The current revision shall be verified as current via the Document Management System.

2. The calculations for the snubbers can be located in the following packages:

Snubber Number Calculation Number Snubber Number Calculation Number 1-12 RNP-C/SPPT-1530 24 CH-4-SN-24 13 RNP-C/SPPT-1297 25 CH-4-SN-25 14 RNP-C/SPPT-1298 26 RC-6-218 15 RC-4-241 (SN) 28 FW-6A-1 007 16 RC-4-241 (SN) 29 FW-6B-44 17 SI-20-1043 30 MS-4-SN-30 18 SI-20-1031 33 AFW-45 19 SI-20-1023 34 AFW-46 20 SI-20-1023 35 83038-M-05-F 21 SI-20-18 36 RNP-C/SPPT-1726 22 SI-20-18 23 CH-4-SN-23 TMM-006 Rev. 16 Page 11 of 29

6.5.1 Continued

3. The following safety related snubbers are included in the program:

Snub. OEM/Location in Plant Rating Cylinder Bore Stroke No. (1000 (inches) (inches) pounds) 1-4 Enertech - Steam Generator "A" 470 12 5 5-8 Enertech - Steam Generator "B" 470 12 5 9-12 Enertech - Steam Generator "C" 470 12 5 13 Anvil/Grinnell - CVC-387 3 1 1/2 5 14 Anvil/Grinnell - CVC-387 3 1 1/2 5 15 Bergen-Paterson - Pressurizer Relief Line 20 3.25 6 16 Bergen-Paterson - Pressurizer Relief Line 20 3.25 6 17 Anvil/Grinnell - RHR Pump "A" Suction Line 12.5 2 11/2 5 18 Anvil/Grinnell - RHR Pump "B" Suction Line 12.5 2 1/2 5 19 Anvil/Grinnell - Upstream of RHR-752B 12.5 2 1/2 5 20 Anvil/Grinnell - Upstream of RHR-752B 12.5 2 1/2 5 21 Anvil/Grinnell - Upstream of SI-862A 12.5 2 1/2 5 22 Anvil/Grinnell - Upstream of SI-862A 12.5 2 1/2 5 23 Anvil/Grinnell - Charging Line Loop 2 Cold Leg 12.5 2 1/2 5 24 Anvil/Grinnell - Charging Line Loop 2 Cold Leg 12.5 2 1/2 5 25 Anvil/Grinnell - Auxiliary Spray Line 12.5 2 1/2 5 26 Anvil/Grinnell - Letdown Line to Non-regenerative HX 3 1 1/2 5 28 Anvil/Grinnell - Feedwater Line "A" 12.5 2 1/2 5 29 Anvil/Grinnell - Feedwater Line "B" 12.5 2 1/2 5 30 Anvil/Grinnell - No. 2 Steam Supply to Aux. Feedwater 3 1 1/2 5 Pump 33 Pacific Scientific - FCV-1424 0.650 --- 2.5 34 Pacific Scientific - FCV-1425 0.650 --- 2.5 35 Anvil/Grinnell - Letdown Line to Letdown Orifice 3 1 1/2 5 36 Pacific Scientific - SI-850D 0.650 --- 2.5 TMM-006 Rev. 16 Page 12 of 29

6.6 Snubber repair and replacement shall be performed in compliance with EGR-NGGC-021 1. Examples of compliance with EGR-NGGC-0211 would include repair and replacement of load pins and studs, mounting brackets, pipe clamps, snubbers, and any other hardware.

6.7 Any maintenance or testing performed by the OEM/vendor shall be documented with the associated EST, including personnel certification, test procedures and calibration sheets and test results, when applicable.

6.8 A file for trending snubber reliability concerns shall be maintained in the Program IQ System Health Report for Snubbers.

6.9 Any examination findings which result in a functional failure, as defined in ADM-NGGC-0101, Maintenance Rule Program, should be addressed per the guidelines in ADM-NGGC-0101.

6.10 The snubbers that will undergo functional testing in EST-033, "Functional Testing of Hydraulic and Mechanical Shock Suppressors", shall be selected and documented in EST-033 prior to the performance of EST-032. This is to ensure the functional test population is chosen prior to performing visual examinations.

6.11 References 2.8, 2.9, and 2.10 are utilized for the bases for functional testing acceptance criteria. Snubbers shall not be adjusted, maintained, or repaired before a visual examination or test specifically to meet the examination or test requirements. Examination and testing must be performed in the as-found condition regarding the parameters to be tested to the fullest extent possible.

6.12 Snubbers that are maintained or repaired by removing or adjusting a snubber part that can affect the results of tests shall undergo functional testing per EST-033 and visual examination per EST-032 before returning to service. The examination and testing shall ensure that the parameters that may have been affected are verified to be acceptable by suitable examination and testing.

6.13 Replacement or modified snubbers shall have proven suitability for the application and environment, and undergo examination and testing per written procedures prior to use.

6.14 In some instances system analysis may allow for the subsequent deletion of snubbers from locations where a snubber has been found to be unacceptable by examination or testing. Such snubbers must still be counted as unacceptable for the purposes of determining additional testing within the DTPG, FMG considerations, and recalculation of examination intervals.

ITMM-006 Rev. 16 Page 13of 29

7.0 SPECIAL TOOLS AND EQUIPMENT N/A 8.0 ACCEPTANCE CRITERIA 8.1 Any examination findings which result in a functional failure, as defined in ADM-NGGC-0101, Maintenance Rule Program, should be addressed per the guidelines in ADM-NGGC-0101.

8.2 References 2.8, 2.9, and 2.10 are utilized for the bases for functional testing acceptance criteria.

ITMM-006 I Rev. 16 - Page 14 of 29

9.0 INSTRUCTIONS 9.1 Snubber Visual Examination 9.1.1 Snubbers may be categorized as one population, or they may be categorized in two groups, "accessible" and "inaccessible", based on their accessibility for examination during reactor operation. These two groups may be examined independently. The decision to categorize the snubbers as one population or as separate populations may be made during or after the examination. If combining separate accessible and inaccessible populations into one population, the shorter interval shall be used for subsequent examination.

9.1.2 Refer to Attachment 11.1, Visual Examination Flow Chart, for a flow chart of the visual examination process. All snubbers shall be visually examined as required in EST-032 in accordance with the following schedule:

NOTE: The normal (initial) visual examination interval is every fuel cycle which begins at the end of a refueling outage and concludes at the end of the next refueling outage. The interval shall be adjusted as required based on the following table.

Snubbers determined to be unacceptable based on the visual examination acceptance criteria at any time during the interval shall be counted in determining the subsequent examination interval.

Number of Uinacceptable Snusbbers Column A Column B Column C Population or for Extended lfr Interval Same fof Interval Cateaory Interval as Previous Reduiction to 'A

[Note (1)] (Notes (2). (3)] Motes (2A. (W). (5)l(Notes (2). (S). (6)]

1 0 0 1 50 0 0 2 too 0 1 4 ISO 0 3 8 200 2 5 13 3100 5 12 2.5 400 8 18 36 SO0 12 24 48 750 20 40 78

> 1000 29 56 109 NOTES, (1) Interpolation between poputation or category sizes armdthe number of unacceptable snubbers Is permissible, The next tower inteter shanl be used when Interpolation results In a fraction.

(2) The basic interval shall be the normal fuel cycle up to 24 months. The examtnatin interval may be as great as tivice, the same, or as small as fractions of the previous Interval as reqtired by the following Notes, The examination interval may vary t25% of the current interval.

(3) If the number of unecceptable snubbers Is eMal to or less than the numbe7 in Column A. then the next examination Interval may be Increased to twice the previous examination Interval. not to exceed 48 months. In that case, the nest examination ac.cording to the previous interval may be skipped.

(4) it the number of unacceptablo snubbers exceefds the number In Column A, but is eqill to or less than the number in Column B, then the next visual examination shall be conducted at the same interval as the previous interval.

(5) If the number of unacceptable snubbers exceeds the number In Column 8. but Is equal to or less than the number in Column C, then the next examination interval shall be decreased to two-thirds Of the previous examination Interval or, In accordance with the Interpolation betiween Cotumns B and C. in propertion to the exact number or unaaceptable snubbers.

(6) If the number of unacceptable snubbers exceeds the number in Column C, then the next examination interval shall be decreased to two-thirds of the previous Interval.

I TMM-006 Rev. 16 Page 15 of 29

9.1.3 Snubbers shall be visually examined on the required schedule and evaluated to determine the following:

1. Inservice examination shall be a visual examination to identify physical damage, leakage, corrosion, or degradation that may have been caused by environmental exposure or operating conditions. External characteristics that may indicate operational readiness of the snubber shall be examined. An examination checklist (EST-032) shall be used.

2. Restrained movement: Snubbers shall be installed so they are capable of restraining movement when activated. Examinations shall include observations for the following:

a. Loose fasteners, or members that are corroded or deformed,

b. Disconnected components or other conditions that might interfere with the proper restraint of movement.

3. Thermal movement: Snubber installations shall not restrain thermal movement to an extent that unacceptable stresses could develop in the snubber, the pipe, or other equipment the snubber is designed to protect or restrain. This requirement is satisfied if no indication of binding, misalignment, or deformation of the snubber is observed.

4. Design-specific Characteristics: Snubbers shall be free of defects that may be generic to particular designs as may be detected by visual examination. For example, fluid supply or content for hydraulic snubbers shall be observed. An observation that the fluid level is equal or greater than the minimum specified amount that is sufficient for actuation at its operating extension is considered to satisfy this requirement. If the fluid level is less than the minimum specified amount, the installation shall be identified as unacceptable, unless a test establishes that the performance of the snubber is within specified limits.

5. In those locations where snubber movement can be manually induced without disconnecting the snubber, ensure that the snubber has freedom of movement.

6. Fluid level (hydraulic units): Reservoir content is equal to or greater than the minimum specified fluid level. If the level is below the minimum specified level, operational readiness may be proven by acceptable functional test results.

7. Piston (hydraulic) and stroke (mechanical) settings: Verify piston and stroke settings are within specified ranges.

TMM-006 Rev. 16 Page 16 of 29 1

9.1.3 continued

8. Snubbers that do not meet the examination requirements shall be evaluated to determine the cause of unacceptability.

9. An unacceptable snubber shall be adjusted, repaired, modified or replaced, unless engineering analysis determines it can be permanently removed.

9.2 Snubber Functional Testing 9.2.1 Refer to Attachment 11.2, Functional Testing Flow Chart, for a flow chart of the functional testing process.

9.2.2 Snubbers shall be tested for operational readiness during each fuel cycle. Tests are required to be in accordance with a specified sampling plan. Testing shall be performed during normal system operation, or during system or plant outages, but no earlier than 60 days prior to the scheduled (start of refueling) outage. For each snubber determined unacceptable by operational readiness testing, additional snubbers shall be tested as determined by the type of failure and the corrective action plan.

9.2.3 DTPG Alternative: Except as required by ISTD-5253, the total snubber population may be considered one DTPG, or alternatively, differences in design, application, size or type may be considered in establishing DTPGs.

Robinson has divided its snubber population into three DTPGs.

9.2.4 Additional DTPG Requirement for Pressurized Water Reactors: Snubbers attached to the steam generator (SG Snubbers 1-12) and snubbers attached to the reactor coolant pump (none at Robinson) shall be at least one, separate DTPG.

9.2.5 Plan Selection: A test plan shall be selected for each DTPG before the scheduled testing begins.

9.2.6 Plan Application: The test plan selected for a DTPG shall be used throughout the refueling outage tests for that DTPG and any failure mode group (FMG) that is derived from it.

9.2.7 Snubbers in More Than One FMG: When a snubber is assigned to more than one FMG, it shall be counted in each of those FMGs and shall be included in corrective action for each of those FMGs.

9.2.8 FMG Sample Composition: When samples from an FMG are required, they shall be selected randomly from untested snubbers in the FMG.

9.2.9 Continued Testing: For unacceptable snubbers, the additional testing shall continue in the DTPG or FMG per ISTD-5330.

TMM-006 Rev. 16 Page 17 of 29

9.3 Sample Plan 9.3.1 Once each fuel cycle (beginning no earlier than 60 days prior to the scheduled refueling outage) test 10% of the safety-related snubbers in accordance with EST-033, Functional Testing of Hydraulic and Mechanical Suppressors (Snubbers), for proper operation.

1. Testing will be conducted for each defined test plan group (DTPG) using the following, as applicable, where at least 10% of the total of each group/type of snubber population (fractional numbers will be rounded up) shall be functionally tested either in-place or in a bench test.

a. The representative sample selected for the initial functional test will be randomly selected from the DTPG and reviewed before beginning the testing. This review will ensure as far as practical, that they are representative of the various designs, configurations, operating environments, range of size, and capacity of snubbers.

b. Alternatively the test sample selection may be selected from snubbers concurrently scheduled for seal life replacement or other service life monitoring reasons and shall be generally on a rotational basis coinciding with the service life activities.

2. All snubbers subject to the functional test requirements are as detailed:

NOTE: Due to their large size, testing of the control unit only is satisfactory for Steam Generator Snubbers 1 through 12. Snubbers 1 through 12 are in groups of four (1-4, 5-8, and 9-12), and each group (bank) has a common control unit. Each time a control unit is tested it is representative of four snubbers. Steam Generator snubbers are tested on a rotational basis with one bank required for routine EST testing each refueling outage.

a. Steam Generator (hydraulic) Snubbers (Routine testing of one bank required each cycle):

No. 1 through 4 - "A" Steam Generator Bank No. 5 through 8 - "B" Steam Generator Bank No. 9 through 12 - "C" Steam Generator Bank ITMM-006 I Rev. 16 1 Page 18 of 291

9.3.1.2 Continued

b. Safety-related Hydraulic Piping Snubbers (Routine testing of two snubbers required each cycle):

No. 13 - At Valve CVC-387, "B" RCP Bay No. 14 - At Valve CVC-387, "B" RCP Bay No. 15 - Discharge of Pressurizer Relief Valve No. 16 - Discharge of Pressurizer Relief Valve No. 17 - "A" RHR Pump Suction No. 18 - "B" RHR Pump Suction No. 19 - Upstream of Valve RHR-752B in RHR Pump Room No. 20 - Upstream of Valve RHR-752B in RHR Pump Room No. 21 - Upstream of Valve SI-862A in RHR Pump Room No. 22 - Upstream of Valve SI-862A in RHR Pump Room No. 23 - Charging Line Loop 2 Cold Leg No. 24 - Charging Line Loop 2 Cold Leg No. 25 - Auxiliary Spray No. 26 - Letdown Line to Nonregenerative Heat Exchanger No. 28 - "A" Feedwater Line No. 29 - "B" Feedwater Line No. 30 - No. 2 Steam Supply Line to Aux. Feedwater Pump No. 35 - RCS Letdown Relief Valves

c. Safety-related Mechanical piping snubbers (Routine testing of one snubber required each cycle):

No. 33 - Valve AFW-1424 Inlet, Aux. Feedwater Pump Room No. 34 - Valve AFW-1425 Inlet, Aux. Feedwater Pump Room No. 36 - Valve SI-850D, Containment First Level ITMM-006 Rev. 16 Page 19 of 29

9.3.2 Functional Operability Test Acceptance Criteria

1. The snubber functional test shall verify, as applicable, that:

a. The force that will initiate motion (breakaway force), the force that will maintain low velocity displacement (drag force), or both as required per procedural requirements are within specified limits both in tension and compression.

b. Activation (lock-up) is within the specified range of velocity or acceleration in both tension and compression.

c. Release (bleed) rate is within the specified range in tension and compression. For units specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be demonstrated.

2. Snubbers shall be tested at a load sufficient to verify the operating parameters specified in 9.3.2.1. Test methods shall not alter the condition of the snubber to the extent that the results do not represent the as-found snubber condition.

3. Qualitative testing may be used in lieu of quantitative testing in meeting the requirements of 9.3.2.1 provided sufficient data, based upon service history or life cycle testing is available to justify the ability of the parameter in question to be within specifications over the life of the snubber (e.g., demonstration that activation takes place without measurement of the activation level). A test report verifying that the parameter was within specifications shall be available for each snubber exempted from an in-service quantitative functional test requirement.

4. When snubber size, test equipment limitations, or inaccessibility prevents use of bench or in place snubber test methods, snubber sub-components that control the parameters to be verified shall be examined and tested in accordance with approved test methods. Re-assembly shall be in accordance with approved procedures.

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

b. Correlation of Indirect Measurements: When test methods are used that either measure parameters indirectly, or measure parameters other than those specified, the results shall be correlated with specified parameters through established methods.

I TMM-006 I Rev. 16 1 Page 20 of 29

9.3.2 continued

5. Snubbers that fail the functional test acceptance criteria shall be repaired or replaced. Snubbers that have repairs shall be tested to meet the functional test criteria before installation.

9.3.3 Functional Test Failure Analysis

1. Snubbers that do not meet the acceptance criteria for functional testing shall be evaluated to determine the cause of the failure to determine corrective actions.

a. Hydraulic snubbers typically fail due to loss of fluid, which results in no restraining action. This is referred to as failing soft.

Snubbers may also fail due to loss of bleed capacity. This will only be evident if the snubber has been activated.

b. Sometimes the cause of an inoperable snubber condition can be determined by external examination, such as a loose tubing connection or the existence of paint on moving parts. Visual examinations and measurements, coupled with the knowledge of snubber operational details, are usually sufficient to determine the cause of the failure.

c. However, in some cases, the snubber will require disassembly to determine the cause of failure and whether a part broke from an overload or fatigue, or broke in tension or compression, etc.

Additional investigation is usually required to determine what caused this defect to develop. Such root causes may be improper maintenance, improper design or operation under excessive vibration from the attached component.

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

3. For each snubber of an initial sample group/type that does not meet the functional test acceptance criteria, an additional sample of at least one-half the size of the initial sample lot shall be tested.

ITMM-006 I Rev. 16 1 Page 21 of29 1

9.3.4 Additional Samples / Failure Mode Groups

1. After determination by an engineering evaluation, that a snubber is unacceptable/unsatisfactory an additional sample of at least one-half the size of the initial sample lot shall be tested.

2. The unacceptable/unsatisfactory snubber may be categorized into an examination / testing failure mode group (FMG). A failure mode group shall include all unacceptable snubbers that have a given failure and all other snubbers evaluated to be subject to the same failure (except snubbers in a separate examination category). The failure mode groups shall be separate and distinct for each examination and testing work scope.

The following failure mode groups shall be used:

a. Unexplained

b. Design or manufacturing and Application-Induced

c. Design or manufacturing and Maintenance, repair, or installation and Application-Induced

d. Transient Dynamic Event

3. Once a failure mode group has been established, any snubber(s) identified in that failure mode group may be separated for continued examination / testing from the original work scope. The new defined and independent failure mode group will remain until the applicable corrective action has been completed.

4. In the event a snubber(s) is included in more than one failure mode group, it shall be counted in each, and subject to the schedule, subsequent schedule and corrective action of each test failure mode group.

5. Unexplained Failure: All unacceptable snubbers in this failure mode group shall be replaced/repaired to an acceptable condition and additional samples tested as determined in 9.3.4.8 below.

TMM-006 I Rev. 16 1 Page 22 of 29

9.3.4 continued

6. Design or Manufacturing and Application-Induced Failure Mode: The following corrective actions shall apply:

a. All snubbers in the failure mode group shall be replaced or modified. The replacement/modified snubbers shall be reclassified as acceptable and the applicable reexamination performed; OR

b. All unacceptable snubbers in the failure mode group shall be replaced or repaired to an acceptable condition and the environment or applications shall be made compatible with the design parameters for all snubbers in this FMG.

c. No additional testing is required provided the above corrective actions have been taken.

7. Design or Manufacturing: Maintenance, Repair, or Installation; and Application-Induced Failure Mode: When the corrective actions of 9.3.4.5.a or b. above are not applicable, or are not taken, then additional samples in the FMG shall be taken until the mathematical formula of 9.3.6.1 is satisfied or all the snubbers in the FMG have been tested.

8. Transient Dynamic Event Failure Mode Group: Although additional samples of this FMG are not required, the operational readiness of all snubbers in this FMG shall be evaluated by stroking or testing. All operationally ready snubbers in this FMG shall be eligible for selection and testing for other appropriate FMGs and the DTPG.

9. When an unacceptable/unsatisfactory snubber has not been assigned to an FMG, the additional sample shall be taken from the DTPG. As practical, the additional sample shall include the following:

a. Snubbers of the same manufacturer's design

b. Snubbers from the same system including those snubbers immediately adjacent to the unacceptable snubbers

c. Other piping systems having the same operating conditions such as temperature, humidity, vibration and radiation

d. Snubbers which are previously untested ITMM-006 Rev. 16 Page 23 9

9.3.4 continued

10. Deletions of Unacceptable Snubbers: Snubbers may be deleted based on analysis of the affected piping system. When an unacceptable snubber is deleted, the deleted snubber shall continue to be considered in its respective examination population, examination category, or failure mode group for determining the corrective action.

9.3.5 Transient Dynamic Event

1. If a transient dynamic event (e.g. water hammer, steam hammer, etc.) is determined to have occurred, that may have affected snubber operability, then the affected snubbers and systems shall be reviewed and any appropriate actions taken. Any actions taken shall be considered independent of the in-service visual examination inspection plan.

2. Potential actions included visual examination of the snubbers and freedom of motion verification by one of the following:

a. Manually induced snubber movement, or

b. Evaluation of in-place snubber piston settings, or

c. Stroking the snubber through its full range of travel, or

d. Functional testing of the snubber.

3. Any unacceptable/unsatisfactory or degraded snubber condition reported on the applicable inspection / test report sheet, or any identified anomaly resulting from this supplemental scope, shall have an evaluation performed by Engineering. This evaluation shall be performed to determine the type and cause of the visual examination discrepancy, effect on the operability of the snubber and related component(s) and any required corrective actions.

ITMM-006 I Rev. 16 Page 24 of 29

9.3.6 Test Plan Completion

1. Testing shall be considered complete when the mathematical expressions below are satisfied for each DTPG or FMG or all snubbers in the DTPG or FMG have been tested.

a. For each DTPG N> 0.1n + C(O.1n12)

Where:

N = total number of snubbers tested that were selected from the DTPG n = number of snubbers in the DTPG C = total number of unacceptable snubbers found in the DTPG (excluding those counted for FMG tests)

b. For each FMG Nf > Cf (O.ln2)

Where:

N f = All snubbers selected and tested from the FMG after the FMG was established from the DTPG.

C f = Total number of unacceptable snubbers in the FMG, plus those found in the DTPG and used to establish the FMG.

n = Number of snubbers in the DTPG ITMM-006 Rev. 16 Page 25 of 29

9.4 Snubber Service Life 9.4.1 The service life of the snubbers at Robinson is addressed and documented in EST-032.

9.4.2 Service life shall be evaluated at least once each cycle, and increased or decreased, as warranted based on the requirements of ISTD-6200. The service life values are based on actual seal life examinations, vendor recommendations, calculations based on actual snubber conditions and locations and plant snubber testing and experience.

9.4.3 If evaluation indicates that service life will be exceeded prior to the next scheduled system or plant outage:

1. The snubber shall be replaced with a snubber for which service life will not be exceeded before the next scheduled system or plant outage

2. Technical justification shall be documented for extending the service life to or beyond the next scheduled system or plant outage

3. Snubber shall be reconditioned such that its service life will be extended to or beyond the next scheduled system or plant outage.

9.4.4 Cause Determination: Causes for any examination or testing failures shall be determined and considered in establishing or reestablishing service life.

TMM-006 Rev. 16 Page 26 of 29 1

9.5 Snubber Maintenance 9.5.1 Snubber repair or refurbishment is accomplished in accordance with the procedures listed in Section 2.0.

9.5.2 It has been determined by Robinson Nuclear Project Engineering and Maintenance that removal, reinstallation and minor maintenance is considered skill of the craft, and requires no specific snubber maintenance qualification.

Minor maintenance does not include snubber cylinder or control valve disassembly, seal replacement and reassembly.

1. Small bore snubbers are replaced with units from stock instead of major repair.

2. Large bore (Steam Generator) snubbers are refurbished by an approved and qualified vendor with Owner-approved procedures.

9.5.3 Repair and replacement parts shall be addressed as required by EGR-NGGC-0211 for load pins and studs, mounting brackets, pipe clamps and snubbers.

9.5.4 Snubbers that undergo maintenance or repair by removing or adjusting a snubber's part that can affect the results of tests shall undergo functional testing (EST-033) and visual examination (EST-032) before returning the snubber to service.

10.0 RECORDS 11.0 ATTACHMENTS 11.1 Visual Examination Flow Chart 11.2 Functional Testing Flow Chart I TMM-006 Rev. 16 Page 27 of 29

ATTACHMENT 11.1 Page 1 of 1 VISUAL EXAMINATION FLOW CHART TMM-006 Rev. 16 Page 28 of 29]

ATTACHMENT 11.2 Page 1 of 1 FUNCTIONAL TESTING FLOW CHART REPAIR/REPLACE SNUBBER WITHIN 12 OR 72 HOURS OF FINDING INOPERABLE FUNCTIONAL TEST OR *-=

AS REQUIRED* =-- . Perform Analysis Within 12 (multiple trains

• [ affeM-dl or-or 2 Hours (single train EROMVIUL REFER TO TECH SPEC 3.0.8 IF affected) on Supported Component EXAM NOT REPLACED IN 12 OR 72 - #

S HOURS ERT TO TECil SPEC REFER 3.0.8 TMM-006 Rev. 16 Page 29 of 29