View source for RC-13-0048, License Amendment Request - LAR 12-06014 Changes to Snubber Surveillance Requirements

{{Adams
| number = ML13095A107
| issue date = 04/02/2013
| title = License Amendment Request - LAR 12-06014 Changes to Snubber Surveillance Requirements
| author name = Gatlin T
| author affiliation = South Carolina Electric &amp; Gas Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000395
| license number = NPF-012
| contact person = 
| case reference number = RC-13-0048
| document type = Letter type:RC, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 47
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Thomas D. Gatlin Vice President,Nuclear Operations 803.345.4342 A SCANA COMPANY April 2, 2013 RC-1 3-0048 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

==Subject:==
VIRGIL C. SUMMER NUCLEAR STATION UNIT I (VCSNS)
DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST - LAR 12-06014 CHANGES TO SNUBBER SURVEILLANCE REQUIREMENTS Pursuant to 10CFR50.90, South Carolina Electric & Gas Company (SCE&G), acting for itself and as an agent for South Carolina Public Service Authority, is hereby submits the following request for an amendment to the Technical Specifications (TS) for Virgil C.
Summer Nuclear Station Unit 1 (VCSNS).
The proposed amendment would revise the TS surveillance requirements (SRs) for snubbers to conform to planned revisions of the snubber inservice inspection (ISI) program. provides a description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 contains a detailed comparison of the current TS 4.7.7 SR to the proposed ISI program requirements and justification of changes. Attachment 5 provides a copy of the proposed Snubber Program Plan.
Approval of the proposed amendment is requested by April 4, 2014. The start of the fourth Inservice Inspection Interval will begin January 2014. Once approved, the amendment shall be implemented within 60 days. There are no new or revised commitments associated with this proposed change.
Virgil C.Summer Station . Post Office Box 88. Jenkinsville, SC - 29065 - F(803) 345-5209

Document Control Desk CR-12-06014 RC-13-0048 Page 2 of 2 In accordance with 10CFR50.91, a copy of this application is being provided to the designated South Carolina Official.
The proposed change has been reviewed and approved by both the VCSNS Plant Safety Review Committee and the VCSNS Nuclear Safety Review Committee.
If you should have any questions, please contact Mr. Bruce L. Thompson at (803) 931-5042.
I declare under penalty of perjury that the foregoing is true and correct.
                                                             . Gatln "
Executed On                    Th6mqor JMG/TDG/bq Attachments:
: 1.      Description and Assessment
: 2.      Proposed Technical Specification Changes (Mark-Up)
: 3.      Revised Technical Specification Pages
: 4.      TS 4.7.7 SR Comparison to ISI Program Requirements
: 5.      Proposed Snubber Program Plan
: 6.      List of Regulatory Commitments cc:    K. B. Marsh                               S. E. Jenkins S. A. Byrne                               Paulette Ledbetter J. B. Archie                              NRC Resident Inspector N. S. Carns                               K. M. Sutton J. H. Hamilton                            NSRC J. W. Williams                            RTS (CR-12-06014)
W. M. Cherry                              File    (813.20)
V. M. McCree                              PRSF (RC-13-0048)
E. A. Brown

Document Control Desk CR-12-06014 RC-13-0048 Page 1 of 7 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 1 Description and Assessment 1.0     

==SUMMARY==
DESCRIPTION In accordance with the provisions of 10 CFR 50.90, South Carolina Electric & Gas (SCE&G) is submitting a license amendment request to revise Technical Specification (TS) 3/4.7.7, "Snubbers," for Virgil C. Summer Nuclear Station (VCSNS). The proposed change would revise the TS surveillance requirements for snubbers to conform to the revised VCSNS Snubber Testing Program.
2.0     DETAILED DESCRIPTION VCSNS is currently nearing the completion of the third 10-year Inservice Inspection (ISI) interval. The fourth 10-year ISI interval at VCSNS begins on January 1, 2014.
Currently, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.7 as authorized in NRC correspondence under TAC No. MC4323 (Accession No. ML051290198) dated May 10, 2005. As required by 10 CFR 50.55a(b)(3)(v)(B), SCE&G intends to adopt Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2004 Edition with 2005 and 2006 Addenda. The proposed changes to the VCSNS TS are summarized below:
Reference to Specification 4.7.7.g in TS ACTION 3.7.7 would be replaced with reference to Specification 4.7.7.
TS Surveillance Requirement (SR) 4.7.7 would be revised to remove specific surveillance requirements for demonstrating snubber operability. The current requirements would be replaced by a reference to the "Snubber Testing Program."

Document Control Desk CR-12-06014 RC-1 3-0048 Page 2 of 7 Add a new TS Section 6.8.4.n, "Snubber Testing Program," to the Administrative Controls section (Section 6.0) of TS to provide a description of the snubber program requirements.
Mark-ups of the proposed TS pages are provided in Attachment 2. A comparison of the current SR 4.7.7 requirements to the revised snubber program requirements and justification of the changes are provided in Attachment 4. Attachment 5 contains the Snubber Testing Plan.

==3.0      TECHNICAL EVALUATION==

Licensees are required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v)(B) to perform the ISI and testing of snubbers in accordance with the ASME OM Code and the applicable addenda, except where the NRC has granted specific written relief pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).
As noted in Regulatory Issue Summary 2010-06, licensees have the option to control the ASME Code-required ISI and testing of snubbers through their TS. For plants using their TS to govern ISI and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4), licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRC-approved alternatives used in lieu of the Code requirements.
The proposed change replaces the specific TS requirements for snubber examination, testing and service life monitoring with a reference to the Snubber Testing Program, thereby ensuring the TS remain consistent with the ISI program.
Snubbers will continue to be demonstrated OPERABLE by performance of the Snubber Testing Program. This program will be maintained in compliance with 10 CFR 50.55a per the proposed section TS 6.8.4.n. The program for ISI and testing of snubbers in accordance with ASME OM Code and the applicable addenda as required by 10 CFR 50.55a(g) is required to include evaluation of supported components/systems when snubbers are found to be unacceptable.
The proposed change to TS ACTION 3.7.7 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.7.

Document Control Desk CR-12-06014 RC-13-0048 Page 3 of 7

==4.0   REGULATORY EVALUATION==

4.1     Applicable Regulatory Requirements VCSNS is currently nearing the completion of the third 10-year ISI interval. The fourth 10-year ISI interval at VCSNS begins on January 1, 2014. Currently, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.7. Relief was authorized pursuant to 50.55a(a)(3)(i), for the third 10-year inservice inspection interval at VCSNS under TAC No. MC4323 (Accession No. ML051290198) dated May 10, 2005.
10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b)(3), 12 months before the start of the 120-month inspection interval. If a revised ISI program for a facility conflicts with the TS for the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TS.
For the VCSNS fourth 10-year ISI interval beginning January 1, 2014, as required by 10 CFR 50.55a(b)(3)(v)(B), SCE&G intends to adopt Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2004 Edition with 2005 and 2006 Addenda, in place of the specific requirements of TS 3/4.7.7 as previously authorized in NRC relief correspondence dated May 10, 2005.
The purpose of this amendment request is to remove the specific surveillance requirements for demonstrating snubber operability from the TS since the ISI program will be revised to include the requirements of the OM Code Subsection ISTD in the Snubber Testing Program. As such, the proposed changes to TS 3/4.7.7 are necessary to conform the TS to the revised ISI program.
4.2     Precedence The changes proposed to TS 3/4.7.7 are similar to changes submitted by Public Service Electric and Gas (PSEG) Nuclear, LLC for Salem Generating Station, Units 1 and 2 and Dominion Nuclear Connecticut (DNC), Inc for Millstone Power Station Unit 2. The applicable references for these similar changes are provided below:
4.2.1 PSEG Letter LR-N10-0363, License Amendment Request:
Changes to Snubber Surveillance Requirements [for Salem Units 1/2],
dated October 4, 2010 (Accession No. ML102780066).
4.2.2 PSEG Letter LR-N11-0107, Response to Draft Request for Additional Information - License Amendment Request: Changes to

Document Control Desk CR-12-06014 RC-13-0048 Page 4 of 7 Snubber Surveillance Requirements [for Salem Units 1/2], dated April 7, 2011 (Accession No. ML110980107).
4.2.3 PSEG Letter LR-N11-0151, Response to Draft Request for Additional Information - License Amendment Request: Changes to Snubber Surveillance Requirements [for Salem Units 1/2], dated May 23, 2011 (Accession No. ML111430636) 4.2.4 DNC Letter 11-354, License Amendment Request to Revise Snubber Surveillance Requirements [for Millstone Power Station Unit 2],
dated September 21, 2011 (Accession No. ML11270A051).
4.2.5 DNC Letter 12-086, Response to Request for Additional Information Regarding License Amendment Request to Revise Snubber Surveillance Requirements [for Millstone Power Station Unit 2], dated February 24, 2012 (Accession No. ML12062A069).
A minor difference is noted between these precedent license amendment requests and the VCSNS request. The SCE&G request is in response to the requirement of 10 CFR 50.55a(b)(3)(v)(B) to perform the ISI and testing of snubbers. Testing will be in accordance with Subsection ISTD of the ASME OM Code and the applicable addenda when using the 2006 Addenda and later editions and Addenda of Section Xl of the ASME Boiler and Pressure Vessel (B&PV) Code.
The previously referenced license amendment requests were made prior to the splitting of 10 CFR 50.55a(b)(3)(v) into parts (A) and (B) with the endorsement of the 2006 Addenda of the Section Xl Code. 10 CFR 50.55a(b)(3)(v)(A) permitted the optional use of OM Code Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," 2004 Edition, in place of the requirements for snubbers in the B&PV Code, Section Xl, Articles IWF-5200(a) and (b), and IWF-5300(a) and (b). 10 CFR 50.55a(b)(3)(v) previously required that when using this alternative, preservice and inservice examination of snubbers must be performed using the VT-3 method specified in IWA-2213.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 5 of 7 4.3    No Significant Hazards Consideration Determination SCE&G requests adoption of an approved change to the plant specific Technical Specifications for VCSNS Unit 1, to revise TS 3/4.7.7, "Snubbers".
As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes would revise SR 4.7.7 to conform the TS to the revised ISI program for snubbers. Snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g). Snubber examination, testing and service life monitoring is not an initiator of any accident previously evaluated. Therefore, the probability of an accident previously evaluated is not significantly increased.
Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The proposed change to TS ACTION 3.7.7 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.7. The proposed change does not adversely affect plant operations, design functions or analyses that verify the capability of systems, structures, and components to perform their design functions. Therefore, the consequences of accidents previously evaluated are not significantly increased.
Based on the above, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes do not involve any physical alteration of plant equipment. The proposed changes do not alter the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged. The methods governing plant operation and testing remain consistent with current safety analysis assumptions.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 6 of 7 Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed changes ensure snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g). Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives.
The proposed change to TS ACTION 3.7.7 for inoperable snubbers is administrative in nature and is required for consistency with the proposed change to SR 4.7.7.
Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, SCE&G concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4      Conclusion 10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of the 120-month inspection interval.
If a revised ISI program for a facility conflicts with the TS of the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TS to conform the TS to the revised ISI program.
The proposed change amends the TS surveillance requirements to conform the TS to the revised ISI program for snubbers which shall meet the requirements of 10 CFR 50.55a(g) except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be

Document Control Desk CR-1 2-06014 RC-1 3-0048 Page 7 of 7 conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0      ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

==6.0      REFERENCES==

6.1      NRC Letter dated May 10, 2005, Virgil C. Summer Nuclear Station, Unit No. 1 - Request for Relief No. RR-111-01 Regarding Snubber Visual Examination and Functional Testing (TAC No. MC4323) (Accession No. ML0511290198) 6.2      NRC Regulatory Issue Summary 2010-06, "Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)," June 1, 2010 (Accession No. ML101310338).
6.3     Virgil C. Summer, Unit 1, Current Facility Operating License NPF-12, Tech Specs, Revised 12/21/2012 (Accession No. ML052870422)

Document Control Desk CR-12-06014 RC-13-0048 Page 1 of 10 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 2 Proposed Technical Specification Changes (Mark-Up)
SCE&G - EXPLANATION OF CHANGES Paqe        Affected             Description of Change          Reason for Change Section 3/4 7-16       3/4.7.7     Change to Surveillance Requirements 10 CFR 50.55a(g)(5)(ii) 3/4 7-17        4.7.7      Change to Surveillance Requirements 10 CFR 50.55a(g)(5)(ii) 3/4 7-18        4.7.7      Change to Surveillance Requirements 10 CFR 50.55a(g)(5)(ii) 3/4 7-19        4.7.7      Change to Surveillance Requirements 10 CFR 50.55a(g)(5)(ii)
.3/4 7-20    Figure 4.7-1   Deleted                             10 CFR 50.55a(g)(5)(ii) 3/4 7-21    Table 1.7-2    Deleted                             10 CFR 50.55a(g)(5)(ii) 6-12i         6.8.4      New Page &Subsection                10 CFR 50.55a(g)(5)(ii)
B 3/4 7-4f     3/4.7.7     Bases                               10 CFR 50.55a(g)(5)(ii)
B 3/4 7-5      3/4.7.7     Bases                               10 CFR 50.55a(g)(5)(ii)

Document Control Desk CR-12-06014 RC-1 3-0048 Page 2 of 10 PLANT SYSTMS LIMITING CONDITION FOR OPERATION 3.7.7 All snubbers on Systems required for safe shutdsUlaccident mitigation shall be OPERABLE. ThMs includes safety and non-safety related snubbers on ystems used to protect the code boundary and to ensure the structural integ-        0-rity of these systems under dnatnic loads.                                           0)
APPLICABIITI:     03OES 1, 2, 3 and 4. HMOES 5 and 6 for snubbers located on systems required OPERABLE In those HODES.
E-ACTION:
With one or more snubbers inoperable, within 72 hours replace or restore the inoperable snubber(s) to OPERABLE statUs and perform an engitneering evaluation per Specification 4.7.7-g-on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.      .oC)
SUMVEILLANCE REQUIREMENTS 4.7.7   Each snubber shall be   .demonstratedOPERABLE &#xfd;r. e hi,--_*.,"
e 4- .....
vim ... ....         ..    . . . ... .... .
SUMMER  - UNIT I                      3/4 7-16                  Amendment No. fy 3 A a G "!

Document Control Desk CR-12-06014 RC-1 3-0048 Page 3 of 10
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                                                           . on a     onal 1O%   oft iW      oi sml3i shele be funadotaly                Ountno more hlures aeo fownd or re daldltwo oaeen        -tesiod.        or (2) A @prsnWdsamiple                        o funciana teste In acoftoore with Rgwo 4.;                       1$~fte toa iwmbrofl                  cia tyefundrinloo"meeting th                11 miotno r,     -       of 4.7.7.". The cumuu*tve number of mnuibrs of a typ.                   Is
                                   *W. AttheWoeancih daysteIsftn.Uisetw vaueus of                             OC' day* ta Anwrent pbt              thy' horeleaf) *idmbe pldolledo 4.7 . Ifat anye     *no            pont td kfs in the "Ae" regio. tunng ofd of snu~ber mity be temfnaed.
ER - LOWT 1                              3/4 7-17                         Ameodment No. 4V, 4M1.141

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Document Control Desk CR-12-06014 RC-13-0048 Page 7 of 10 VISMIPTO              INMIAL Pouaiel"m                  A               Colum I                 Column C or Ctor             xten   Interval        Aepest Ineral           Reuc Interal
                         )      (Notas     eand 6)      (Notes 4 and 6)         (Notes 6 ad 1                       0                        0                      1 so                       0                        0                      2 100                        0                         1                     4 1i0                        0                         3 20o                        2                         S 300                                                12                    25 400                                                                      368 600                                                24                    48 75O                                                40                    78 2000 orrgreater                                         5 slzt s~hall be determined b ad              t     prev      Inspectio Intrval O1 m erd,                   b        pn          acces bilty during powt eperation as amccessble or Inaccessble.                  c        tee may be examined separately or Jointly. However.       the licensee        t        and document that decision before ary inspection      and shall use           decision as the basis upoe which to determine the next      inspection I              for that category.
(2)  Interpolation between      population o csitzes               eOd the nraer of unaceptable snufers Is pertissi a.               Use     t lower Integer for the value of the limit for Columns A, 8,            C if that       ludes a fractional value of unacceptable snubers as deta nod by into                  ation.
(3) If th          ber of              IaccPt snubbers Is qual        or less than the nmber in Column A, the n          i        Ion Interval way be       ceothe previous interval but not greater than 48           the.
(4) If the nmber of unace              %e snubbers Is equal to         les than the number In Column S but grec           than the amer in Colun A,              n0A inspeti*R interval shall be           "mneas the previous Interval.
(5) If the :mher of v                  Ie snu*bers is equal to or 9 t than the nm-ber In Column C,          next inspection interval shall be               Irds of the previous Interv . However, If the nmber of                  ccepess then the numbe In Colum C but greater than the mndr 1n oae,                       the next interva shall be reduced proportionally by interpolaion, that is, the previ        Interval shall bereduced byafctor that is on-                 rdofthe ration of        difference between the numer of unacceptable a                  found during         previous interval end the amber in Column &to the di                n in the       _ rsInColumnsBandC.
(6)   The       isions of Specification 4.0.2 are applicable for all Inspectia I      als up to and including 48 moths.
                 - UNIT                             3/4 7-22                      Amendeent Ho. 103 JK IA I

Document Control Desk CR-12-06014 RC-13-0048 Page 8 of 10 INSERT NEW PAGE (Section 6.8 Procedures and Programs) 6.8.4 continued
: n. Snubber Testinq Progqram This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISI) requirements for supports. The program shall be in accordance with the following:
: 1)     This program shall meet 10 CFR 50.55a(g) ISI requirements for supports.
: 2)     The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference. in 10 CFR 50.55a(b) subject to limitations and modifications listed in 10 CFR 50.55a(b) and subject to Commission approval.
: 3)     The program shall, as allowed by 10 CFR 50.55a(b)(3)(v), meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," or meet authorized alternatives pursuant to 10 CFR 50.55a(a)(3).
: 4)     The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10 CFR 50.55a(b)(3)(v)) subject to the limitations and modifications listed therein.
6.12i

Document Control Desk CR-12-06014 RC-13-0048 Page 9 of 10 PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS) (Contnued)
SURVEILLANCE REQUIREMENTS (Continued) wlich endows, wit exceptions, NE 99-03, Section 8.4 and Appendx F (Ref. 6). These corpensatoFy measures may also be used as nnigating actions as required by Action 3.7.6.a2. Ternporay analytical methods may also be used as cornpensato*y measures to restore OPERABILITY (Ret. 7). Options for 1estorin" te CRE boundary to OPERABLE status include changing te licensing basis DBA consequence analysis, repaiing the CRE bounday, or a combination of these actions. Depending upon the nature dthe problem and the corrective action, a full scope iuleakage test may not be necessary to establish that the CRE bounday has been restored to OPERABLE status.
REFERENCES
: 1. FSAR, Section 9.4.
: 2. FSAR, Ch*aer 15.
: 3. FSAR, Section 6.4.
: 4. FSAR, Section 9.5.
: 5. Regulatoy Guide 1.196.
: 6. NEI 9903, "Control Room Habftty Assessment" March 2003.
: 7. Letter frim Eric J. Leeds (NRC) to J.ames W.Davis (NEM)     dated anuary 30,2004, "NB Dralt White Paper, Use of Genedc Letter 91-18 Process and Alemative Source Tems in the Context of Contr     Room Habitability." (ADAMS Accession No. ML040300694) 3/4.7.7 SNUBBERS Al snubbers on systems required for safe shutdownlaccident mitigation shal be OPERABLE This includes safety and non-safety related snubbers on systems used to protect the code boundary and to ensure the structural integity of these systems under dynamic bads.
The "Snubber Testing Program" manages the requirement for demonstrating snubber operability (examination, testing and service life monitoring) as reflected in section 6.8.4.n thereby ensuring the TS remains consistent with the ISI program. The program for ISI and testing of snubbers in accordance with ASME OM Code and the applicable addenda as required by 10 CFR 50.55a(g) is required to include evaluation of supported components/systems when snubbers are found to be unacceptable.
SUMMER - UNIT 1                               8 3/4 7-4f            - Amendment T          N7 Z11. IBRNA8,

Document Control Desk CR-1 2-06014 RC-13-0048 Page 10 of 10
                                                                                                                        /
we classed and grouped by degn and mrarfaclamer but not by For example**,                 subber utlzkng the Same design faMtuMs of the 2 klp, kip and 100Mp cab                                 company A weaotfthe same yp. The oiwsm. gn mech       al               anfat re by compaoy                   othe purpose ofthismcno a would betype,                    as wouid hydraulic. snubbers trom        either         imn rer.
The visual         in*    fremuency is based upo nmaIntalning a                       level of snubber protlection to             .Therefore,        the required inspection            varies inversely with the observed wwobr            ures and is determined by the nmber                  operable snubers fund din a Inspection.                     4.7-2 establishes thrse tnfts fr               h,,ng the nwet visual Inspection nterval                        performed belore that            he*
h e           moy be used assa new reference point              etermine the ns" inspectiont.           inspection whose results requiresa shorterI                   nerNed wTo    ovrr the               soliedule.
To provifd assurance of                   r functlio*al              of two sampling and acceptance Ito* methode Ore uted
: 11)       ftcliondlytMet 10 percent                    r*    er with an addtiona 10 percet tested for aod* functlonedto
: 2)     f*nctionelly last s sample size and              innl e sample acceptance usng Figure 4.7-14 .
Figure 4.7.1 was davopd using Wacf'                             I~tobabNiiY Ratilo Plar as described In "OusftyControl and Industrial 8acSWV            IW Ach The servics e    Wofsa enubber                blished!via mam        rer Input wad Information through cons*ieraton of the snIA                         condions ad                        ,Instsltio and maIntea. recof (nevty I                         snubber, seal replaced,           replaced, In high raditio arms, Inh*gh                        are, etc. . .). The req             to monitor the onubber service 111Is Included to               that the snubber* perlo*ducy                  a perormnce evkAeorn In vw of "AeIr                    operating conditions. These                Wil pVie stastical bases For future            Ideration of snubber service fe. The               rements for the maintenance of rekodm thes snubber service lMe review ar nOt I                              to affect plant operation.
Permanenut         otherexemptions form the surveillancaprogrom for I                     al snubbers may                   by the Commission If a justilale beis for exemption pre*ented and. if apo                     t desucivetsting was perorrmed to quafy the sn
                                , snubber We                                                                        for the                9minconditions at either the completion of their fabrici*on or at a eSnubbers                         so exempted "I be fited In Section 3.7.7 with foono exemptions.
extnoftthe indic U&#xfd; fIR    -UNT       I                               B W/4 7-5              Amendiment No. 4;1-4O 171

Document Control Desk CR-12-06014 RC-13-0048 Page 1 of 6 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 3 Revised Technical Specification Pages Proposed Technical Specification Changes Summary Replace the following pages of the Appendix A to Operating License Number NPF-12, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Paqes                 Insert Pages 3/4 7-16                    3/4 7-16 3/4 7-17                    3/4 7-17 3/4 7-18 3/4 7-19 3/4 7-20 3/4 7-21 6-12i B 3/4 7-4f                  B 3/4 7-4f B 3/4 7-5                    B 3/4 7-5

PLANT SYSTEMS 3/4.7.7 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.7      All snubbers on systems required for safe shutdown/accident mitigation shall be OPERABLE. This includes safety and non-safety related snubbers on systems used to protect the code boundary and to ensure the structural integrity of these systems under dynamic loads.
APPLICABILITY:        MODES 1, 2, 3 and 4. MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.
ACTION:
With one or more snubbers inoperable, within 72 hours replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation for Specification 4.7.7 on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.
SURVEILLANCE REQUIREMENTS 4.7.7      Each snubber shall be demonstrated OPERABLE by performance of the Snubber Testing Program.
SUMMER - UNIT 1                        3/4 7-16                     Amendment No. 47, 103,

The following pages have been deleted.
3/4 7-17 3/4 7-18 3/4 7-19 3/4 7-20 3/4 7-21 SUMMER - UNIT 1                 3/4 7-17               Amendment No.

PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS) (Continued)
SURVEILLANCE REQUIREMENTS (Continued) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). These compensatory measures may also be used as mitigating actions as required by Action 3.7.6.a.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 7). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.
REFERENCES
: 1. FSAR, Section 9.4.
: 2. FSAR, Chapter 15.
: 3. FSAR, Section 6.4.
: 4. FSAR, Section 9.5.
: 5. Regulatory Guide 1.196.
: 6. NEI 99-03, "Control Room Habitability Assessment," March 2003.
: 7. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).
3/4.7.7 SNUBBERS All snubbers on systems required for safe shutdown/accident mitigation shall be OPERABLE. This includes safety and non-safety related snubbers on systems used to protect the code boundary and to ensure the structural integrity of these systems under dynamic loads.
The "Snubber Testing Program" manages the requirement for demonstrating snubber operability (examination, testing and service life monitoring) as reflected in section 6.8.4.n thereby ensuring the TS remains consistent with the ISI program. The program for ISI and testing of snubbers in accordance with ASME OM Code and the applicable addenda as required by 10 CFR 50.55a(g) is required to include evaluation of supported components/systems when snubbers are found to be unacceptable.
SUMMER - UNIT 1                              B 3/4 7-4f              Amendment No. BRN 08 002,

Bases Page 3/4 7-5 deleted SUMMER - UNIT 1         B 3/4 7-5          Amendment No. 47,103,17-1,

ADMINISTRATIVE CONTROLS
: n. Snubber Testing Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISI) requirements for supports. The program shall be in accordance with the following:
: 1)      This program shall meet 10 CFR 50.55a(g) ISI requirements for supports.
: 2)      The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(b) subject to limitations and modifications listed in 10 CFR 50.55a(b) and subject to Commission approval.
: 3)      The program shall, as allowed by 10 CFR 50.55a(b)(3)(v), meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," or meet authorized alternatives pursuant to 10 CFR 50.55a(a)(3).
: 4)      The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b)
(including 10 CFR 50.55a(b)(3)(v)) subject to the limitations and modifications listed therein.
SUMMER - UNIT 1                         6-12i                             Amendment No.

Document Control Desk CR-12-06014 RC-13-0048 Page 1 of 13 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 4 TS 4.7.7 SR Comparison to ISI Program Requirements

Document Control Desk CR-12-06014 RC-1 3-0048 Page 2 of 13 Current TS Surveillance Requirement                Revised ISI Program Requirement                         Justification for Change 4.7.7.a Inspection Types                          ISTD-5252 allows for defined test plan groups      The revised ISI program requirements for As used in this specification, type of snubber    (DTPGs) to be established based upon               inspection types allow the same distinction for shall mean snubbers of the same design and        differences in design, application, size, or type. DTPGs as SR 4.7.7.a.
manufacturer, irrespective of capacity.
4.7.7.b Visual Inspections                        ISTD-4220(a) requires all snubbers to be           Use of ISTD-4200 for snubber inservice considered one population for examination, or      examination in lieu of current SR 4.7.7.b does Snubbers are categorized as accessible or         alternatively, to categorize them individually as  not change the number of snubbers required to inaccessible during power operation. Each of      accessible or inaccessible. The categories of      be examined or the required examination these categories may be inspected                 accessible and inaccessible snubbers shall be      intervals.
independently according to the schedule           cniee eaaeyfreaiain separately for examination.
determined by    Table 47-2 Tale detemind b 4.7-2. The viualconsidered Th   visual inspection interval for each category of          ISTD-4220(b) requires the decision to examine snubber shall be determined based on the          the snubbers as one population or as separate criteria provided in Table 4.7.2, and the first   categories to be made and documented before inspection interval determined using this         the scheduled examination begins and not criteria shall be based upon the previous         changed during the examination.
inspection interval as established by the requirements in effect before Amendment No.
103.

Document Control Desk CR-12-06014 RC-13-0048 Page 3 of 13 Current TS Surveillance Requirement               Revised ISI Program Requirement                    Justification for Change 4.7.7.c Refueling Outage Inspections             ISTD-1 750 states that if a transient dynamic Use of ISTD-1750, ISTD-1800 and ISTD-5325 Each refueling outage an inspection shall be     event (e.g., water hammer, steam hammer)      to evaluate snubbers subject to any occurs that may affect snubber operability,   unexpected potentially damaging transients as performed of all the snubbers defined in then the affected snubbers and systems shall  do the requirements of SR 4.7.7.c.
section 3.7.7 attached to sections of safety be reviewed and any appropriate corrective systems piping that have experienced unexpected, potentially damaging transients as   action taken.
determined from a review of operational data     ISTD-1800 requires an evaluation to be and a visual inspection of the systems. In       performed of the system(s) or components of addition to satisfying the visual inspection     which an unacceptable snubber is a part, for acceptance criteria, freedom of motion of        possible damage to the supported system or riiechanical snubbers shall be verified using at component.
least one of the following:
ISTD-5325 also requires the operational (i) manually induced snubber movement; (ii)      readiness of all snubbers in this FMG to be evaluation of in-place snubber piston setting;   evaluated by stroking or testing.
or (iii) stroking the mechanical snubber through it full range of travel.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 4 of 13 Current TS Surveillance Requirement                  Revised IS[ Program Requirement                        Justification for Change 4.7.7.d Visual Inspection Acceptance Criteria      ISTD-4210 states that inservice examination       10 CFR 50.55a(b)(3)(v) allows the use of shall be a visual examination to identify         subsection ISTD for inservice examination Visual inspections shall verify (1) that there are                                                   requirements.
physical damage, leakage, corrosion, or no visible indications of damage or impaired       degradation that may have been caused by OPERABILITY and (2) attachments to the                                                               The revised ISI program requirements for environmental exposure or operating foundation or supporting structure are                                                               inservice examination satisfy the visual conditions; and that external characteristics functional, and (3) fasteners for the attachment                                                     inspection acceptance criteria in SR 4.7.7.d.
that may indicate operational readiness of the of the snubbers to the component and to the snubber shall be examined.
snubber anchorage are functional.
ISTD-4231 requires that examinations shall include observations for loose fasteners, or members that are corroded or deformed disconnected components or other conditions that might interfere with the proper restraint of movement. If observed these conditions shall be evaluated.
ISTD-4232 requires that examinations verify snubbers do not restrain thermal movement to an extent that unacceptable stresses could develop in the snubber, the pipe, or other equipment that the snubber is designed to protect or restrain.
ISTD-4233 requires that examinations verify snubbers are free of defects that may be generic to particular designs as may be detected by visual examination.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 5 of 13 Current TS Surveillance Requirement                 Revised ISI Program Requirement                    Justification for Change 4.7.7.d Visual Inspection Acceptance Criteria       ISTD-4240 permits snubbers classified as      The revised ISI program requirements for (cont)                                              unacceptable during inservice examination to  inservice examination is equivalent to the be tested in accordance with the requirements visual inspection acceptance criteria in SR Snubbers which appear inoperable as a result of ISTD-5210. Results that satisfy the        4.7.7.d.
of visual inspections shall be classified as operational readiness test criteria of ISTD-unacceptable and may be reclassified 5210 shall be used to accept the snubber, acceptable for the purpose of establishing the provided the test demonstrates that the next interval, provided that (i) the cause for unacceptable condition did not affect being classified as unacceptable is clearly operational readiness.
established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.7.f.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 6 of 13 Current TS Surveillance Requirement                   Revised ISI Program Requirement                       Justification for Change 4.7.7.d Visual Inspection Acceptance Criteria       ISTD-4233 requires that fluid supply or content   The revised ISl program requirements for (cont)                                              for hydraulic snubbers shall be observed. If      inservice examination is equivalent to the the fluid is less than the minimum amount, the    visual inspection acceptance criteria in SR When a fluid port of a hydraulic snubber is installation shall be identified as unacceptable, 4.7.7.d.
found to be uncovered, the snubber shall be unless a test establishes that the performance declared inoperable and shall not be of the snubber is within specified limits. Tests determined OPERABLE via functional testing shall be performed in accordance with ISTD-unless the test is started with the piston in the   5210(b) and ISTD-5210(c). The initial test shall as-found setting, extending the piston rod in       start with the piston at the as-found setting and the tension mode direction. All snubbers found be performed in the extension (tension) connected to an inoperable common hydraulic direction, or in a mode that more closely fluid reservoir shall be counted as resembles the operating and design unacceptable and may be reclassified as             requirements of the snubber.
acceptable for determining the next inspection interval provided that criterion (i) and (ii) above ISTD-4270 requires that snubbers that do not are met. A review and evaluation shall be           meet examination requirements of ISTD-4230 performed and documented to justify continued       shall be evaluated to determine the root cause operation with an unacceptable snubber. If          of the unacceptability.
continued operation cannot be justified, the ISTD-4280 requires that unacceptable snubber shall be declared inoperable and the snubbers shall be adjusted, repaired, modified, ACTION requirements of 3.7.7 shall be met.
or replaced.

Document Control Desk CR-12-06014 RC-13-0048 Page 7 of 13 Current TS Surveillance Requirement                  Revised ISI Program Requirement                    Justification for Change 4.7.7.e Functional Tests                          ISTD-5200 requires snubber operational        The frequency of snubber testing in the revised readiness testing to be performed each fuel   program is unchanged from the frequency During the first refueling shutdown and at least cycle. Testing shall be performed during      specified in current TS SR 4.7.7.e.
once per 18 months thereafter, a normal system operation, or during system or representative sample of either:                                                                The initial sample size in the revised program plant outages.
is as large as the size specified in current SR (1) At least 10% of the total of each type of ISTD-5223 and ISTD-5224 permit snubbers to    4.7.7.e.
snubber in use in the plant shall be functionally be tested in their installed location or in a tested either in place or in a bench test.                                                      The revised program provides for an expanded bench test.
sample of one half the initial sample be tested For each snubber of a type that does not meet ISTD-5261 requires snubbers of each Defined   for each failed snubber when using the 10%
the functional test acceptance criteria of Test Plan Group (DTPG) to be tested using     test plan. Although the present program specification 4.7.7.f, an additional 10% of that either:                                       requires an additional sample of the same 10%
type of snubber shall be functionally tested, or for each failed snubber this is not considered (a) the 10% testing sample plan to be a reduction in safety since the proposed (b) the 37 testing sample size           program includes an increased emphasis on service life monitoring, and this proposed test ISTD-5330 requires the snubbers of each program has been previously approved by the DTPG and failure mode group (FMG) to be regulator and is widely in use elsewhere.
tested as required. Testing is complete when the mathematical expressions of ISTD-5331 are satisfied, or all snubbers in the DTPG or FMG have been tested.
ISTD-5331 requires that testing shall satisfy the mathematical expressions as follows:
(a) for each DTPG N > 0.1n + C(0.1n/2)
(b) for each FMG NF > CF(O.1n/2)

Document Control Desk CR-12-06014 RC-13-0048 Page 8 of 13 Current TS Surveillance Requirement                    Revised ISI Program Requirement                        Justification for Change 4.7.7.e Functional Tests (cont.)                     ISTD-5411 requires an initial sample of 37        The initial sample size using the 37 plan in the snubbers to be selected randomly from each        revised program is as large as the size (2) A representative sample of each type of 37 plan DTPG.                                     specified in current SR 4.7.7.e.
snubber shall be functionally tested in accordance with Figure 4.7-1, "C" is the total       ISTD-5431 requires testing to satisfy the         Figure ISTD-5431-1 reflects the same number of snubbers of a type found not               mathematical expressions as follows:              acceptance line as SR Figure 4.7-1 only it is meeting the acceptance requirements of                                                                 defined in terms of N rather than C.
(a) for each DTPG Specification 4.7.7.f. The cumulative number of                                                        It requires the same equation to be satisfied to snubbers of a type tested is denoted by "N". At      N &#x17d;>36.49 + 18.18C (Fig. ISTD-5431-1)             complete testing.
the end of each days testing, the new values of "N" and "C" (previous day's total plus current       Figure ISTD-5431-1 reflects the same day's increments) shall be plotted on Figure         acceptance line as SR Figure 4.7-1 only it is 4.7-1. If at any time the point plotted falls in the defined in terms of N rather than C.
"Accept" region, testing of that type snubber may be terminated.
When the point plotted lies in the "Continue Testing" region, additional snubbers of that type shall be tested until the point falls in the "Accept" region or all the snubbers of that type have been tested.                                    ISTD-5500 requires that snubbers placed in the same location as snubbers that failed the     Retests of failed snubber locations are The representative sample selected for               previous inservice operational readiness test functional testing shall include the various                                                           required by the revised program as in SR shall be retested at the time of next operational 4.7.7.e.
configurations, operating environments, and          readiness testing unless the cause of the the range of size and capacity of snubbers of        failure is clearly established and corrected.
each type. The representative sample shall be weighted to include more snubbers from severe service areas such as near heavy equipment. Snubbers placed in the same location as snubbers which failed the previous functional test shall be included in the next test lot if the failure analysis shows that a failure was due to location.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 9 of 13 Current TS Surveillance Requirement                Revised ISI Program Requirement                     Justification for Change 4.7.7.f Functional Test Acceptance Criteria      ISTD-5210(a), (b) and (c) require the same      The revised ISI program requirements for verification for operational readiness testing. snubber acceptance criteria are equivalent to The snubber functional test shall verify that:                                                   those of current SR 4.7.7.f.
: 1. Activation (restraining action) is achieved within the specified range in both tension and   ISTD-4231 Requires Snubbers to be installed compression, except that inertia dependent,      so they are capable of restraining movement acceleration limiting mechanical snubbers,       when activated. Examinations include may be tested to verify only that activation     fasteners and other components that might takes place in both directions of travel.        interfere with proper restraint of movement.
: 2. Snubber bleed, or release rate where required, is present in both tension and ISTD-5226 States when test methods are used compression, within the specified range.
that either measure parameters indirectly, or
: 3. Where required, the force required to         measure parameters other than those initiate or maintain motion of the snubber is    specified, the results shall be correlated with within the specified range in both directions of specified parameters through established travel.                                          methods.
: 4. The snubber ability to withstand displacement under continuous loading.
: 5. Fasteners for attachment of the snubber to the component and to the snubber anchorage are secure.
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.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 10 of 13 Current TS Su,rveillance Requirement                Revised ISI Program Requirement                      Justification for Change 4.7.7.g Functional Test Failure Analysis          ISTD-5271 states that snubbers that do not      The revised ISI program requirements for meet test requirements shall be evaluated to    snubber acceptance criteria are equivalent to An engineering evaluation shall be made of determine the root cause of the failure.        those of current SR 4.7.7.g.
each failure to meet the functional test acceptance criteria to determine the cause of     ISTD-5272 states that snubbers found the failure. The results of this evaluation shall unacceptable according to operational be used, if applicable, in selecting snubbers to  readiness test requirements should be be tested in an effort to determine the           assigned to FMGs unless the failure is isolated OPERABILITY of other snubbers irrespective        or unexplained. FMGs shall include all of the type that may be subject to the same       unacceptable snubbers with the same failure failure mode.                                     mode and all other snubbers with similar potential for similar failure.
4.7.7.g Functional Test Failure Analysis          ISTD-1800 requires an evaluation be             The revised ISI program requirements for (cont.)                                           performed on the system(s) or component(s)      snubber acceptance criteria are equivalent to of which an unacceptable snubber is a part, for those of current SR 4.7.7.g.
For snubbers found inoperable, an engineering possible damage to the supported system or evaluation shall be performed on the components to which the inoperable snubbers       component.
are attached. The purpose of this engineering evaluation shall be to determine if the components to which the inoperable snubbers are attached were adversely affected by the inoperability of the snubbers in order to ensure that the component remains capable of meeting the desired service.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 11 of 13 Current TS Surveillance Requirement                Revised ISI Program Requirement            I              Justification for Change 4.7.7.g Functional Test Failure Analysis         ISTD-5271 states that snubbers that do not         The revised program requirements for (cont.)                                          meet test requirements shall be evaluated to       manufacturer or design deficiencies require determine the root cause of the failure.           replacement or modification of all snubbers in If any snubber selected for functional testing the FMG or additional testing until the either fails to lockup or fails to move, i.e.,   ISTD-5272 states that snubbers found mathematical expression of ISTD-5331(b) is frozen in place, the cause will be evaluated     unacceptable according to operational satisfied or all snubbers in the FMG have been and if caused by the manufacturer or design      readiness test requirements should be tested. This may result in fewer snubbers deficiency all snubbers of the same type         assigned to FMGs unless the failure is isolated being tested after a test failure. However, the subject to the same defect shall be functionally or unexplained. FMGs shall include all             revised program requirements provide tested. This testing requirement shall be        unacceptable snubbers with the same failure adequate assurance of snubber independent of the requirements stated in        mode and all other snubbers with similar OPERABILITY because all potentially affected Specification 4.7.7.e for snubbers not meeting   potential for similar failure.
snubbers will be replaced or modified; or the the functional test acceptance criteria.
As an alternative to additional testing for        acceptance limit for additional testing will be Design or Manufacturing FMGs, ISTD-5323            met, demonstrating an acceptable level of requires no additional testing when all            reliability.
snubbers in the FMGs are replaced or modified in accordance with ISTD-1600.
If replacement or modification is not performed in accordance with ISTD-5323, additional testing is required in accordance with ISTD-5324. Testing is required to continue until the acceptance limit is satisfied or all snubbers in the FMG have been tested.

Document Control Desk CR-1 2-06014 RC-13-0048 Page 12 of 13 Current TS Surveillance Requirement                  Revised ISI Program Requirement                      Justification for Change 4.7.7,h Functional Testing of Repaired and        ISTD-1610 Requires replacement or modified       The revised ISI program requirements for Replaced Snubbers                                 snubber(s) to have a proven suitability for the  supported component(s) or system evaluation Snubbers which fail the visual inspection or the  application and environment and;                 are equivalent to those of current SR 4.7.7.h.
functional test acceptance criteria shall be      ISTD-5134 Requires adjusted, modified, repaired or replaced. Replacement snubbers        repaired, or replacement snubbers to be tested and snubbers which have repairs which might       to meet the requirements of ISTD-5120 prior to affect the functional test result shall be tested service.
to meet the functional test criteria before installation in the unit. These snubbers shall have met the acceptance criteria subsequent to their most recent service, and the functional test must have been performed within 12 months before being installed in the unit.
4.7.7,i Snubber Seal Replacement Program          ISTD-6100 requires initial snubber service life  The service life evaluation requirements in The seal service life of hydraulic snubbers       to be predicted based on manufacturer's          ISTD-6100 and ISTD-6200 are equivalent to shall be monitored to ensure that the seal's      recommendation or design review.                 the requirements in current TS SR 4.7.7.i.
service life is not exceeded between              ISTD-6200 and ISTD-6200(c) requires service surveillance inspections. Seal materials, and     life to be evaluated at least once each fuel applications shall be determined and              cycle. If the evaluation indicates that service established based on engineering information      life will be exceeded before the next scheduled and the seals shall be replaced so that the       system or plant outage, the snubber shall be maximum service life will not be exceeded         reconditioned such that its service life will be during a period when the snubber is required      extended to or beyond the next scheduled to be OPERABLE. The seal replacements             system or plant outage.
shall be documented and the documentation         ISTA-9310 requires the maintenance of shall be retained in accordance with              records in accordance with the Owners QA Specification 6.10.2.                             program.
Figure 4.7-1 SAMPLING PLAN FOR                    Fig. ISTD-5431-1, The 37 Testing Sample Plan     Figure ISTD-5431-1 reflects the same SNUBBER FUNCTIONAL TEST                                                                            acceptance line as SR Figure 4.7-1 only it is defined in terms of N rather than C.

Document Control Desk CR-12-06014 RC-13-0048 Page 13 of 13 Current TS Surveillance Requirement       Revised ISI Program Requirement                   Justification for Change TABLE 4.7-2 SNUBBER VISUAL             ISTD-4252(b) requires inservice examinations Table ISTD-4252-1 is identical to SR Table INSPECTION INTERVAL                    to be conducted in accordance with Table     4.7-2 for population/category population sizes.
ISTD-4252-1.

Document Control Desk CR-12-06014 RC-1 3-0048 Page 1 of 8 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 5 Proposed Snubber Program Plan

Virgil C. Summer Nuclear Station, Unit I Snubber Examination, Testing, and Service Life Monitoring Program Plan Revision 0 South Carolina Electric & Gas Virgil C. Summer Nuclear Station, Unit 1 P.O. Box 88 Jenkinsville, SC 29065

South CarolinaElectric & Gas Virgil C. Summer Nuclear Station Unit I Revision Log Effective   Revision Description                Prepared:          Date    Approved:        Date Date                                            Snubber                    Engineering Program                    Manager Engineer 4                                  4.                 4.       +                I 2013                                           Rev 0                               Page 1 of 6

South CarolinaElectric & Gas Virgil C. Summer Nuclear Station Unit 1 TABLE OF CONTENTS SECTION

==1.0  INTRODUCTION==
2.0  EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:
3.0  EXAMINATION and TESTING METHODS:
4.0  EXAMINATION and TESTING FREQUENCY:
5.0  EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:
6.0  REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:

==7.0 SCHEDULING==
8.0  REPORTS AND RECORDS:
2013                                Rev 0                    Page 2 of 6

South CarolinaElectric & Gas Virgil C. Summer Nuclear Station Unit 1 INTRODUCTION:

===1.1 Purpose===
To provide requirements for the performance and administration of assessing the operational readiness of those dynamic restraints (Snubbers) whose specific functions are required to ensure the integrity of the Reactor Coolant Pressure Boundary.

===1.2 Scope===
The program plan was prepared to meet the requirements of the following subsections of the American Society of Mechanical Engineers (ASME) OM Code 2004 Edition with 2005 and 2006 Addenda.
* Subsection ISTA, "GeneralRequirements" ISTA contains the requirements directly applicable to inservice examination and testing including the Owner's Responsibility and Records Requirements.
* Subsection ISTD, "Preserviceand Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water ReactorNuclear Power Plants" ISTD establishes requirements for preservice and inservice examination and testing, and the service life monitoring of Dynamic Restraints (Snubbers)in light-water reactor nuclear power plants. The snubbers covered are required to support the systems and components that are required in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

===1.3 Discussion===
In order to ensure the required operability of all safety related snubbers for VCSNS during a seismic or other events, initiating dynamic loads, the inspection, testing, and the service life monitoring of these snubbers shall be implemented and performed in accordance with the requirements of SAP-0161, Station Administrative Snubber Program Document.
The examination boundaries shall include the snubber assembly from pin to pin inclusive. Coordination with the ISI program owner will be required to complete the surveillance requirements for piping and structural attachments. Integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of the ASME Code Section Xl, Article IWF-2500(a), (b), (c) and (d) within the ISI program.
The Snubber Program described in SAP-0161 adheres to the requirements of the ASME OM Code, Subsection ISTD, 2004 Edition with 2005 and 2006 Addenda, as required by 10CF.R50.55a(b)(3)(v).
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South CarolinaElectric & Gas Virgil C. Summer Nuclear Station Unit I 2.0  EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:
2.1  Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the extent specified within SAP-0161 and referenced Surveillance Test Procedures (STP).
2.2  Snubbers are grouped into Defined Test Plan Groups (DTPGs) by design type, size, and accessibility in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample plan per ISTD-5300. There are no snubbers attached to the Steam Generators. All mechanical snubbers at Virgil C. Summer Station Unit 1 are grouped as separate DTPGs by size.
DTPGs PSA 1/4 PSA 1/2 PSA 1 PSA 3 PSA 10 PSA 35 PSA 100 2.4  The service life of all snubbers shall be monitored and snubbers replaced, reconditioned or evaluated in accordance with SAP-0161 and ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections.
The replacement or reconditioning shall be documented and records retained in accordance with VCSNS procedures.
3.0  EXAMINATION and TESTING METHODS:
3.1  Visual examinations shall be performed by individuals qualified in accordance with VCSNS procedures. These examinations are conducted to ensure the mechanical and structural condition of the snubber support location and to observe conditions that could affect functional adequacy. Visual examinations and functional testing shall be performed to verify the requirements specified within SAP-0161 are met in accordance with Subsection ISTD.
4.0  EXAMINATION and TESTING FREQUENCY:
4.1  Visual Examinations and Functional Testing shall be performed at the frequency specified within SAP-0161 and ISTD-4250 and ISTD-5240. VCSNS currently performs accessible and inaccessible snubber visual examinations as one group with the frequency shown in Table ISTD 4252-1.
4.2   Code Case OMN-13, which allows the extension of the visual examination interval, will be implemented for snubber inspections during this interval. Code Case OMN-1 3 is approved for use in Regulatory Guide 1.192 (June 2003). The Visual Examinations of Table ISTD 4252-1 may be extended in accordance with Code Case OMN-1 3 once the prerequisites of the code case have been satisfied.
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South Carolina Electric & Gas Virgil C. Summer NuclearStation Unit 1 4.3  Visual Examinations shall be performed whenever new snubbers are installed, reinstallation of existing or swapped snubbers that were functionally tested, or after repairs, replacements or modifications.
4.4  Functional testing requirements for new installations or spares shall be equal to or more stringent than that specified within SAP-0 161.
5.0  EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:
5.1  Snubbers that do not appear to conform to the Visual Examination requirements of SAP-0161, shall be reported for evaluation and appropriate corrective action.
5.2  Snubbers that do not appear to conform to the visual examination acceptance requirements and are later confirmed as operable as a result of functional testing may be declared operable for the purpose of establishing the next visual inspection interval, providing that the unacceptable condition did not affect operational readiness.
5.3  Snubbers that do not meet the operability testing acceptance criteria in SAP-0161 shall be evaluated to determine the cause of the failure and appropriate corrective action taken.
5.4  The service life of a snubber is evaluated using manufacturing input and engineering information gained through consideration of the snubber service conditions and inservice functional test results. A service life monitoring program is included in SAP-0161.
6.0  REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:
6.1  Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the ASME Code, Section Xl.

==7.0 SCHEDULING==
7.1  The Visual Examinations, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with SAP-0161 and Subsection ISTD by the Snubber Program Engineer.
7.2  The Snubber Program Engineer shall identify and track expanded or additional testing and/or examinations as required by SAP-0161 and Subsection ISTD.
8.0  REPORTS and RECORDS:
8.1  Reports and records for the Visual Examinations and Functional Testing shall be maintained for all snubbers included within the Snubber Program.
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South CarolinaElectric & Gas Virgil C. Summer Nuclear Station Unit 1 8.2 Applicable records and reports, as required for Repair and Replacements, shall be maintained for snubbers.
8.3 Records of the service life of all snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records will be maintained.
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Document Control Desk CR-12-06014 RC-1 3-0048 Page 1 of 1 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 6 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Virgil C. Summer Nuclear Station (VCSNS) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Bruce L. Thompson at (803) 931-5042.
Commitment                                       Due Date None.}}