ML083010100

American Society of Mechanical Engineers (ASME)Section XI, Inservice Inspection Program for the Second Ten-year Inspection Interval - Request for Relief 1-ISI-18 - Response to NRC Request for Additional Information

ML083010100
Person / Time
Site:	Browns Ferry
Issue date:	10/22/2008
From:	Brandon M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD8797
Download: ML083010100 (528)

Text

{{#Wiki_filter:Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 October 22, 2008 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail.Stop: OWFN P1 Washington, D.C. 20555-0001 In the Matter of ) Docket No. 50-259 Tennessee Valley Authority ) BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 - AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI, INSERVICE INSPECTION PROGRAM FOR THE SECOND TEN-YEAR INSPECTION INTERVAL - REQUEST FOR RELIEF 1-ISI RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) (TAC NO. MD8797) By letter dated May 27, 2008, TVA submitted the BFN Unit 1 ASME Section Xl Inservice Inspection (ISI) program for the second Ten-year inspection interval. Included in the BFN Unit 1 program submittal was request for relief 1-ISI-18. Request for relief 1-ISI-18 addresses the BFN alternate program for the selection, examination, and testing of snubbers. By letter dated September 15, 2008, NRC requested additional information regarding the subject request for relief. TVA's response to this request is in the enclosure to this letter.

U.S. Nuclear Regulatory Commission Page 2 October 22, 2008 There are no new regulatory commitments in this letter. If you have any questions, please contact me at (256) 729-7658. Sincerely, Michael K. Brandon Interim Manager of Licensing and Industry Affairs Enclosure cc: See Page 3

U.S. Nuclear Regulatory Commission Page 3 October 22, 2008 cc (Enclosure): Mr. Eugene F. Guthrie, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Ms. Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North (MS 08G9) 11555 Rockville Pike Rockville, Maryland 20852-2739

U.S. Nuclear Regulatory Commission Page 4 October 22, 2008 JEE:JWD:DKR Enclosure cc (Enclosure): w/o enclosure G. P. Arent, EQB 1B-WBN N. T. Brumfield, BFT 2A-BFN W. R. Campbell, Jr., LP 3R-C S. M. Douglas, POB 2C-BFN D. E. Jernigan, LP 3R-C R. F. Marks, Jr., PAB 1C-BFN D. C. Matherly, NAB 2A-BFN L. E. Nicholson, LP 4K-C M. A. Purcell, BR 4X-C L. E. Thibault, LP 3R-C S. A. Vance, WT 6A-K E. J. Vigluicci, ET 11A-K R. G. West, NAB 2A-BFN B. A. Wetzel, LP 4K-C NSRB Support, LP 5M-C EDMS WT CA-K s:\Iicensing\everyone\UI1 ASME ISI 2nd Int 1-ISI-18 RAI Response.doc

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN) UNIT 1 AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI, INSERVICE INSPECTION (ISI) PROGRAM, SECOND TEN-YEAR INSPECTION INTERVAL REQUEST FOR RELIEF 1-ISI-18 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) (SEE ATTACHED)

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN) UNIT 1 AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI, INSERVICE INSPECTION (ISI) PROGRAM, SECOND TEN-YEAR INSPECTION INTERVAL REQUEST FOR RELIEF 1-ISI-18 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) Backaround By letter dated May 27, 2008, TVA submitted the BFN Unit 1 ASME Section XI Inservice Inspection (ISI) program for the second Ten-year inspection interval. Included in the BFN Unit 1 program submittal was request for relief 1-ISI-18. Request for relief 1-ISI-18 addresses the BFN alternate program for the selection, examination, and testing of snubbers. During its review of BFN request for relief 1-ISI-18, the NRC staff identified questions by letter dated September 15, 2008. Listed below are the specific NRC questions and the corresponding TVA response. In support of NRc's review the procedures referenced in this RAI response are provided as attachments to this enclosure. NRC Request No. 1 The licensee requested relief from the requirements of the 2001 Edition of the American Society of Mechanical Engineers Boiler and pressure Vessel Code (ASME Code) with 2003 addenda, Section IWF-5300(a) and (b) of Article IWF-5000. The Article IWF-5000 also contains requirements for snubber preservice examinations and tests in IWF-5200 and requirements for integral and nonintegral attachments for snubbers in IWF-5300(c). Explain whether and how the requirements of IWF-5200(a), (b), and (c) and IWF-5300(c) will be met. TVA Response to NRC Request No. 1 In lieu of requirements of IWF-5200(a) and (b), the examination and testing requirements will be met by the Technical Requirements Manual (TRM) Snubber Program, prepared in accordance with the guidance contained in Generic Letter 90-09. As stated in TVA's request for relief, the areas inclusive of the pins back to the building structure and to the component/piping being supported will remain in the ASME Section XI examination boundary (ISI Program); therefore, IWF-5200(c) and IWF-5300(c) will be met by the Section XI Program. E-2

NRC Request No. 2 On page 91 of 105 of the May 27, 2008 submittal, the licensee requested relief from Section IWF-5400 of the Article IWF-5000 and ASME/American National Standards Institute (ANSI) requirements OM-1987, Part 4 (OM-4) with OMa-1988, Section 1.5.6 and 1.5.7. IWF-5400, Repair/Replacement states that: Repair/replacement activities performed on snubbers shall be in accordance with IWA-4000. Snubbers installed, corrected or modified by repair/replacement activities shall be examined and tested in accordance with the applicable requirements of IWF-5200 prior to return to service. Provide an explanation whether and how IWA-4000 and IWF-5200 requirements will be met. TVA Response to NRC Reauest No. 2 The provisions of IWA-4000 will be met for the repair/replacement activities on snubbers by the current Repair and Replacement Program. TVA seeks relief from the examination and testing requirements of IWF-5200 required by IWF-5400 which requires snubbers installed, corrected, or modified by repair/replacement activities to be examined and tested in accordance with ASME/ANSI OM, Part 4. The examination and testing of snubbers [IWF-5200(a) and (b)] will be in accordance with the TRM Snubber Program. As stated in TVA's request for relief, the areas inclusive of the pins back to the building structure and to the component/piping being supported will remain in the ASME Section XI examination boundary (ISI Program); therefore, IWF-5200(c) will be met by the Section XI Program. NRC Request No. 3 On page 91 of 105 of the May 27, 2008 submittal, Basis for Relief, the licensee stated that the Plant Technical Requirement Manual (TRM), Section TR 3.7.4 is prepared in accordance with the guidance given in Generic Letter (GL) 90-09, Alternative Requirements for Snubber Visual Inspection Intervals and CorrectiveActions. GL 90-09 only provides guidance for Snubber Visual Examination Intervals and Corrective Actions. GL-90-09 does not replace any other requirements of the OM-4, such as preservice examination (section 2.1), examination documentation (section 2.4), inservice operability testing (section 3.2), testing documentation (section 3.3), etc. Explain how these requirements are met in the proposed alternative. TVA Response to NRC Request No. 3 Below, TVA is providing a comparison of the OM Part 4 requirements in Sections 2.1, 2.4, 3.2, and 3.3 and the BFN TRM alternatives. OM Part 4 Section 2.1.1(a) There are no visible signs of damage or impaired operability as a result of storage, handling or installation. The alternate requirements in the BFN Surveillance Instruction (SI) 1-SI-4.6.H-1, , "Visual Examination Checklist for All Snubbers" checklist Item A reads: "The E-3

snubber has no visible indications of damage or impaired operability" and specifically includes observing the exposed parts of the snubber for broken parts, deformation, or other damage that could result in unacceptable performance. OM Part 4 Section 2.1.1(b) the snubber load rating, location, orientation, position setting, and configuration (attachments, extensions, etc.) are in accordance with design drawings and specifications. Installation records (based on physical inspections) verifying the snubbers were installed according to design drawings and specifications shall be acceptable in meeting this requirement. The BFN alternate requirements in SI 1-SI-4.6.H-1 are as follows: Section 7.2 G states "The snubbers are assigned a UNID number in an appropriate tracking program, which provides current and historical information for a specific snubber or support location." Section 7.2 H states "The snubbers are listed in Appendix A by exam number." Appendix A provides additional information such as snubber drawing no., type/size, support number, and location. Snubber drawing number may be used to access the design drawing of a snubber, showing the location plan, material description, orientation, configuration (to include attachments, extensions and others), design requirements such as design travel/thermal movements and position settings. Section 7.2 I of the SI states that "A unique snubber/support number is given to each snubber location on a system." MPI-0-000-SNBOO4, Attachment 1, Note 2 states: "Document removal and reinstallation data for the snubber on Attachment 4." Snubber data listed in Attachment 4 relevant to these requirements includes: As-Found Position Indication Reading (for mechanical type), As-Found Index (Plunger) Reading, As-Found Piston Reading and others (for hydraulic type). Collection and recording data in Attachment 4 is done prior to removal of the snubber for functional testing and after reinstallation. OM Part 4 Section 2.1.1(c) adequate swing clearance is provided to allow snubber movement The BFN alternate states that the item is to be observed in performance of visual SI 1-SI-4.6.H-1. Attachment 2 of the SI contains the following verifications: Centerline of the clamp assembly and structural attachment offset (i.e., a misalignment with the snubber axis exists) by no greater than plus or minus 6 degrees based on the clearances between the rod eyes, paddles, and the attachment clevis. Contact of these parts, which produces a side load on the snubber is unacceptable. Observe spacers are installed on each side of the snubber eye to reduce the misalignment and or binding. Space shall not exceed 1/16 inch on either side or 1/8 inch total. Observe for evidence of torsional binding (i.e. mechanical snubber twisted along its axis by the pipe clamp and structural attachments). OM Part 4 Section 2.1.1(d) if applicable, fluid is at the recommended level and fluid is not leaking from the snubber system. The BFN Alternate fluid level acceptability check for hydraulic snubbers is included in the visual SI 1-SI-4.6.H-1 data sheets or Attachments 3, 4, and 6 that state: "If the reservoir E-4

Plunger cannot be seen the reservoir is empty. The fluid level is unacceptable. Notify immediately the Snubber Engineer/SE Designee. Write a Work Order to remove the snubber and take to the snubber test facility to have functional test performed. If the fluid level is unacceptable, but not empty, add GE SF 1154 silicon fluid using a fluid gun with a special hydraulic fill coupling until the fluid level reading is at or approximately same as the piston rod extension given above. Examine snubber for location and cause of leaks. Record locations in Remarks. Notify the Snubber Engineer/SE Designee to evaluate and document the unacceptable condition on Attachment 6." MPI-0-000-SNBOO4, Attachment 1, Section 1.0[1] states: "perform visual inspection of the snubber for any visible damage or fluid leakage." Further, Section 1.0[8.2] states: "if the fluid level is unacceptable, but not empty, add GE SF 1154 silicon fluid using a hydraulic fluid gun until the fluid level reading is at or approximately the same as the piston rod extension given above. Notify the Snubber Engineer/Designee to take appropriate action." OM Part 4 Section 2.1.1(e) structural connections such as pins, bearings, studs, fasteners, and other connecting hardware such as locknuts, tabs, wire and cotter pins are installed correctly. The BFN Unit 1 alternate checklist items in SI 1-SI-4.6.H-1, Attachment 2, Item B states: "Attachments to the foundation or supporting structure are functional" and verifies the following attributes: "Observe the exposed hanger structural steel, pipe clamps, base plates, lugs and other such plates of attachment for broken parts, deformation or other damage" and "Observe welds for visible damage at base plates, lugs, and other such points of attachment." , Item C states: "Fasteners for the attachment of snubber to the component and to the snubber anchorage are functional" and verifies the following attributes: Observe to ensure the security of essential threaded fasteners such as anchorage bolts and pipe clamp bolts that are exposed.

• Observe to ensure clevis bolts or pins are properly installed.
• Observe for the following attributes which may cause future problems but do not affect snubber operability or any acceptance criteria: pits, scratches, or rough places observed on the piston rod that would not contact the piston seal, cotter pins properly installed with legs bent sufficiently, but not completely, to prevent cotter pin from backing out, pivot pin retaining ring is properly installed, if required, and security locking devices (i.e., locking tabs or wire) on snubber attachment bolts properly installed, if required.

OM Part 4 Section 2.4 (a) checklists verifying preservice and inservice examination, fluids levels, and as-found conditions. Appendix A of this Part represents items normally included in a checklist (as follows):

• Rotated reservoirs (hydraulic fluid could not reach valve blocks)

BFN Unit 1 does not have rotated reservoirs as a specific snubber checklist item. E-5

Reservoir inventory is verified in Surveillance Instructionl-SI-4.6.H-1 for the hydraulic snubber models installed on Unit 1. The models installed have pressurized hydraulic reservoirs that allows mounting in any spatial orientation.

• Piston shaft painted, which could cause a frozen condition The BFN Unit 1 alternate requirements are provided in SI 1-SI-4.6.H-1, Attachment 2, Section A that contains the following checklist item: "The snubber has no visible indications of damage or impaired operability." This item includes the following verifications: "Observe for any signs of overstressing, Observe the exposed parts of the snubber for broken parts, deformation or other damage, such as weld arc strikes, paint, weld slag, adhesive, or other deposits on piston rod or support cylinder that could result in unacceptable snubber performance, Observe to see if there is any evidence that a snubber has experienced a potentially damaging transient since the last examination, and Observe the snubber and piston rod for excessive corrosion, solid deposits, which could impair operability of the snubber."
• Units installed upside down The BFN Unit 1 Alternate requirements are provided in SI 1-SI-4.6.H-1, Section 6.0 A. 4 which states: "The snubber has the proper orientation, and adequate fluid level, if applicable." MPI-0-000-SNBOO4, Attachment 3, Section 2.0[11.] verifies for Lisega Torus Dynamic Restraints, that the 2-way ball valve positioner is in the vertical position.

0 Sight glass broken The BFN Unit 1 Alternate requirements are provided in SI 1-SI-4.6.H-1, Attachment 2, Section A contains the following verification: "The snubber has no visible indications of damage or impaired operability. Observe the exposed parts of the snubber for broken parts, deformation or other damage, such as weld arc strikes, paint, weld slag, adhesive, or other deposits on piston rod or support cylinder that could result in unacceptable snubber performance."

• Installed with preset shipment screws for shipping (screws must be removed before service)

The BFN Unit 1 functional testing of snubbers demonstrates free/unrestricted snubber movement in tension and compression directions. For a snubber to move freely, the preset shipment screws for shipping must be removed before the test. There is no preset shipment screw for shipping to remove on a Lisega Torus Dynamic Restraints.

• Hydraulic fluid lines for snubber remote reservoir placed too close to hot pipe causing the lines to burst BFN currently has no snubbers with remote reservoirs. The BFN Unit 1 Alternate requirements are provided in MAI-4.2A Piping/Tubing Support Installation Data Sheet which documents clearances per MAI-4.10 applicable to SR, QR, or NQR supports in Category 1 Structures. MPI-0-000-SNB004, Attachment 1, section 2.1, Note (2) states E-6

that: "Any required relocation of the strut attachment to clear an interference should be brought to the attention of Site Engineering (Civil)."

• Snubber placed in wrong location The BFN Unit 1 alternate requirements are provided in SI 1-SI-4.6.H-1, Section 7.2.G: "The snubbers are assigned a UNID number in an appropriate tracking program, which provides current and historical information for a specific snubber or support location." Section 7.2.H; "The snubbers are listed in Appendix A by exam number." Note: Appendix A also provides a specific location of a snubber with a unique identification number (UNID).
• Clevis pins not attached to anchor The BFN Unit 1 alternate requirements are provided in SI 1-SI-4.6.H-1, Attachment 2, Section C which states: "Fasteners for the attachment of the snubber to the component and to the snubber anchorage are functional. Observe to ensure the security of essential threaded fasteners such as anchorage bolts and pipe clamp bolts that are exposed.

Observe to ensure clevis bolts or pins are properly installed."

• Snubber not installed at correct location The BFN Unit 1 Alternate requirements are provided in SI 1-SI-4.6.H-1, Section 7.2.G which states: "The snubbers are assigned a UNID number in an appropriate tracking program, which provides current and historical information for a specific snubber or support location. Section 7.2.H states: "The snubbers are listed in Appendix A by exam number."

Note: 1-SI-4.6.H-1, Appendix A also provides a specific location of a snubber with a unique identification number (UNID).

• Bent or scored piston rod The BFN Unit 1 Alternate requirements are provided in SI 1-SI-4.6. H-1, Attachment 2, Section A which states: "The snubber has no visible indications of damage or impaired operability.

Observe the exposed parts of the snubber for broken parts, deformation or other damage, such as weld arc strikes, paint, weld slag, adhesive, or other deposits on piston rod or support cylinder that could result in unacceptable snubber performance."

• Welding arc strikes The BFN Unit 1 alternate requirements are provided in SI 1-SI-4.6.H-1, Attachment 2, Section A which states: "The snubber has no visible indications of damage or impaired operability. Observe the exposed parts of the snubber for broken parts, deformation or other damage, such as weld arc strikes, paint, weld slag, adhesive, or other deposits on piston rod or support cylinder that could result in unacceptable snubber performance."
• Lubrication of pivot points The BFN Unit 1 alternate requirements are provided in MPI-0-000-SNBOO4, Attachment 2, Section 2.0[4] which states: "Apply anti-seize thread lubricant to the surface of the pivot pins and to all threaded fasteners that are being installed."

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0 Abnormal spherical bearing position The BFN Unit 1 Alternate requirements are provided in MPI-0-000-SNBOO4 Section 7.2[3] which states: "If a spherical bearing is found to be dislodged from the paddle housing, REINSERT by carefully pressing or tapping on the outer race. Use a Bergen-Paterson bearing installation tool or an appropriate sized pipe to assure proper alignment." MPI-0-000-SNB004, Section 7.2[3.2] states: "After the spherical bearing has been reinserted into the paddle if required, USE a center punch and MOVE approximately 1/32 inch away from the exterior of the spherical bearing race and with as little force as possible MAKE four punch indentations equally spaced around the race at approximately 90 degrees, on both sides of the paddle." 0 Protective coverings or plugs removed (after shipping or maintenance) Snubbers received from the warehouse are free of protective coverings or plugs removed and ready for examination and testing as required.

• Fluid level indicators andlor position indicators accessible for visual inspection The BFN Unit I Alternate requirements are provided in MPI-0-000-SNBOO4, Attachment 1 Section 2.2[10] which states: "At the end of each installation, CHECK each unit as a precaution for the following information."
• Snubber Serial Number.
• Piston rod extension dimension.
• Fluid level indicator reading.
• Whether or not fluid was added to bring unit to proper level.
• Visible condition of the unit.
• Condition of the strut assembly with particular attention to the clamp and the bolting tightness.
• Cotter pins installed in clevis pins.
• No visible corrosion or mechanical defects of working parts or surfaces The BFN Unit 1 alternate requirements are provided in 1-SI-4.6.H-1, Attachment 2, Section A which states: "The snubber has no visible indications of damage or impaired operability. Observe the exposed parts of the snubber for broken parts, deformation or other damage, such as weld arc strikes, paint, weld slag, adhesive, or other deposits on piston rod or support cylinder that could result in unacceptable snubber performance.

Observe the snubber and piston rod for excessive corrosion, solid deposits, which could impair operability." OM Part 4 Section 2.4(b) examination records All examination records are documented in Attachments 2, 3, 4, and 6 of 1-SI-4.6.H-1 and in Attachment 4 of MPI-0-000-SNBO04. Visual examination records performed to facilitate testing are also documented in the appropriate attachments of the applicable SIs, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E. E-8

OM Part 4 Section 2.4(c) thermal movement inspection records The stroke setting (As-Found/As-Left) which relates to thermal movement (shown in design drawings) for a given snubber are documented in Attachment 4 of MPI-0-000-SNBOO4, and Attachments 2, 3, 4, and 6 of 1-SI-4.6.H-1 and in the appropriate attachments of the applicable Sis, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and O-SI-4.6.H-2E. OM Part 4 Section 2.4 (d) nonconformance and corrective action required to be completed during the preservice and inspection interval The BFN Unit 1 alternate requirements are provided in 1-SI-4.6.H-1, Section 7.2[F] which states: Evaluation sheets (Attachments 5, 6, and 7) shall be prepared and submitted with the data package, as appropriate, by the Snubber Engineer/SE Designee for each degraded or inoperable snubber identified by the performance of this instruction. Section 7.3.1[1] states: "If any snubber is determined to be inoperable, Site Engineering Civil should initiate a Problem Evaluation Report (PER). MMG Planning should write a minor maintenance Work Order (WO) to perform the necessary repairs required to return the inoperable snubber to operable status." The checklist in Attachment 2, Sections A, B, and C states: "Responses marked (UNAC) are unacceptable and require immediate notification of the Snubber Engineer/SE Designee at the time of discovery. Handling of deficiencies shall be completed in accordance with SPP-8.1, Conduct of Testing and SPP-3. 1, Corrective Action Program." OM Part 4 Section 3.2.1.1 (a) the force that will initiate motion (breakaway force), the force that will maintain low velocity displacement (drag force), or both, as required by the documents of Paragraph 1.5.2 (Procedures and Instructions), is within specified limits, both in tension and compression Drag tests performed on snubbers are in accordance with 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E, generally using the STB 200 Test Bench. Drag test result/computer printout is a graph of Velocity (ipm), Position (inches) and Force (Ibs). 0-SI-4.6.H-2A, Section 6.OB states: The snubber functional test shall verify that:

1. "As-Found"

a. Activation (restraining action) occurs, in both tension and compression.

Snubbers with activation values less than or equal to 0.02 g's are acceptable. The measured value shall be rounded to the second decimal place. Activation values greater than 0.02 g's shall be considered as a failure (inoperable snubber), require a failure analysis, and be evaluated for additional scope or expansion testing.

b. The drag force shall not exceed the maximum acceptable drag force from Table 6.2-1.

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2. "As-Left"

a. Activation (restraining action) occurs, in both tension and compression.

Snubbers with activation values less than or equal to 0.02g's are acceptable. The measured value shall be rounded to the second decimal place.

b. The drag force shall not exceed 3% of the snubber rated load, except for PSA 1/4 the drag force shall not exceed 32.5 lbs.

Test data/computer print out are documented in Attachment 2 of the SI. 0-SI-4.6.H-2B, Section 6.0B states: The snubber functional test shall verify that:

1. "As-Found"

a. Corrected activation occurs in both directions of travel at a piston velocity greater than or equal 1 inch/minute and less than or equal 30 inches/minute.

b. Bleed takes place after activation of the snubber in both the tension and compression directions.

c. Drag forces do NOT exceed 2.0 percent of the snubber's rated load.

2. "As-Left"

a. Corrected activation occurs in both directions of travel at a piston velocity greater than or equal 5 inches/minute and less than or equal 20 inches/minute.

b. Corrected bleed takes place after activation of the snubber in both tension and compression and shall be within the ranges shown in Appendix C for each size of snubber.

c. Drag forces do NOT exceed 2.0 percent of the snubber's rated load.

Test data/computer print out are documented in Attachment 2 of the SI. 0-SI-4.6.H-2E, Section 6.0B states: The snubber functional test shall verify that:

1. "As-Found"

a. Activation occurs in both directions of travel at a piston velocity greater than or equal 6 inches/minute and less than or equal 25 inches/minute.

b. Bleed takes place after activation of the snubber, in both tension and compression directions.

c. Drag force does not exceed 15,000 pounds.

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2. "As-Left"

a. Activation occurs in both directions of travel at a piston velocity greater than or equal 6 inches/minute and less than or equal 25 inches/minute.

b. Bleed takes place after activation of the snubber, in both tension and compression, and is greater than 0.28 inch/minute and less than 1.18 inches/minute.

c. Drag force does not exceed 15,000 pounds.

Test data/computer print out are documented in Attachment 2 of the SI. Breakaway force is a test parameter printed in the test data for drag test performed, normally less than the maximum drag force. OM Part 4 Section 3.2.1.1(b) activation is within the specified range of velocity or acceleration in both tension and compression Acceleration tests performed on mechanical snubbers are in accordance with 0-SI-4.6.H-2A. LOCKUP and BLEED TEST performed on hydraulic type snubbers are in, accordance with 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E. These tests are generally done on the STB 200 Test Bench. Acceleration Test, Lockup and Bleed Test data/computer printouts are graphs of Velocity (ipm), Time (seconds) and Force (Ibs). 0-SI-4.6.H-2A, Section 6.0B states: The snubber functional test shall verify that:

1. "As-Found"

a. Activation (restraining action) occurs, in both tension and compression.

Snubbers with activation values less than or equal to 0.02 g's are acceptable. The measured value shall be rounded to the second decimal place. Activation values greater than 0.02 g's shall be considered as a failure (inoperable snubber), require a failure analysis, and be evaluated for additional scope or expansion testing.

2. "As-Left"

a. Activation (restraining action) occurs, in both tension and compression.

Snubbers with activation values less than or equal to 0.02g's are acceptable. The measured value shall be rounded to the second decimal place. Test data/computer print out are documented in Attachment 2. 0-SI-4.6.H-2B, Section 6.OB states: The snubber functional test shall verify that:

1. "As-Found"

a. Corrected activation occurs in both directions of travel at a piston velocity greater than or equal 1 inch/minute and less than or equal 30 inches/minute.

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2. "As-Left"

a. Corrected activation occurs in both directions of travel at a piston velocity greater than or equal 5 inches/minute and less than or equal 20 inches/minute.

Test data/computer print out are documented in Attachment 2 of the SI. 0-SI-4.6.H-2E, Section 6.OB states: The snubber functional test shall verify that:

1. "As-Found"

a. Activation occurs in both directions of travel at a piston velocity greater than or equal 6 inches/minute and less than or equal 25 inches/minute.

2. "As-Left"

a. Activation occurs in both directions of travel at a piston velocity greater than or equal 6 inches/minute and less than or equal 25 inches/minute.

Test data/computer print out are documented in Attachment 2 of the SI. OM Part 4, Section 3.2.1.1(c) - release rate, where applicable, 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. 0-SI-4.6.H-2B, Section 6.OB states: The snubber functional test shall verify that:

1. "As-Found"

b. Bleed takes place after activation of the snubber in both the tension and compression directions.

2. "As-Left"

b. Corrected bleed takes place after activation of the snubber in both tension and compression and shall be within the ranges shown in Appendix C for each size of snubber.

Test data BLEED (RELEASE) Rate are recorded in Attachment 2 of the SI. 0-Sl-4.6.H-2E, Section 6.OB states: The snubber functional test shall verify that:

1. "As-Found"

b. Bleed takes place after activation of the snubber, in both tension and compression directions.

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2. "As-Left"

b. Bleed takes place after activation of the snubber, in both tension and compression, and is greater than 0.24 inch/minute and less than 1.18 inches/minute.

Test data BLEED (RELEASE) Rate are recorded in Attachment 2 of the SI. Snubber specifically required not to displace under continuous load are addressed in TSR 3.7.4.2. OM Part 4, Section 3.2.1.2, - Operability Test Loads - Snubbers shall be tested at a load sufficient to verify the operating parameters specified in paragraph 3.2.1.1. Testing at less than rated load must be correlated to operability parameters at rated load. Test Load parameters are built into the Snubber Test Bench Machine Program, and are listed in the applicable Appendixes of 0-TI-398 as follows: 0-TI-398 Appendix B, Section 3.0 provides test parameters in the snubber test machine program for Bergen-Paterson, Anchor Darling or Fronek Hydraulic snubbers. Test Loads are in the Snubber Test Machine Program. These Test Loads are 80 percent of rated load for snubber sizes HSSA -3, -10, -20,- 30, ADH/FRONEK -20, -30, -50, -70, and -130. Lisega Torus Dynamic Restraints are functionally tested using the Lisega Surrogate snubber in accordance with 0-SI-4.6.H-2E. The test load in the Snubber Test Machine Program is 44.9 kip nominal value that is correlated to the 100 kip test load used in factory testing. Test data/results are recorded in Attachment 2 of the SI. Lisega Torus Dynamic Restraints may also be functionally tested by the manufacturer using a 100 kip test load prior to installation. Test data/results are recorded in Attachment 2 of the SI. 0-TI-398 Appendix F, Section 3.0, provides test parameters in the snubber test machine program for Pacific Scientific Company (PSA) Mechanical Snubbers, Test Load parameters in the Snubber Test Machine Program are 60 percent of rated load for PSA sizes 1/4, 1/2, 3, and 10 and 50 percent of rated load for PSA sizes 1, 35, and 100. OM Part 4, Section 3.2.1.3, Qualitative Testing. Qualitative testing may be used in lieu of quantitative measurements in meeting the requirements of paragraph 3.2.1.1, provided adequate justification can be presented and is acceptable to the regulatory authority having jurisdiction over the facility. In those cases, the Owner shall obtain sufficient data, based upon service history or life cycle testing, to justify the ability of the parameter in question to be within specifications over the life of the snubber (e.g., demonstrate that activation takes place without measurement of the activation level). A test report shall be available for each snubber exempted from an inservice quantitative test requirement. The test report must verify that the parameter was within specifications to allow exemption of the snubber from quantitative testing of the parameter. E-1 3

0-TI-398 has been revised to remove the "push-pull" functional testing of mechanical PSA snubbers. 0-TI-398, Section 7.17.2, Functional Testing of PSA Mechanical Snubbers states: A. BFN Technical Requirements require drag force measurements and activation verifications. B. Mechanical snubber functional testing is performed to verify two characteristics, activation and drag force. The limit for acceleration is not to exceed 0.02 g's. Pacific Scientific Company (PSC) performed qualification tests on new snubbers and performed tests on snubbers that have been in extended plant service to verify the activation levels at various loads. PSC concluded that there is no significant change in activation value at any level of rated load of the snubber. C. Performing a test for activation of PSA snubbers requires a specialized test machine. BFN has a computer controlled API/Barker STB-200 snubber test bench. The test bench is capable of testing any size PSA snubber and most medium and small bore hydraulic snubbers. The software performs four basic functions:

1. Operator interface

2. Machine control

3. Data acquisition and conversion

4. Data analysis and presentation Test results are presented in the form of a graph with maximum and average test values.

OM Part 4, Section 3.2.2, Inservice Operability testing Frequency. Testing shall take place at least every refueling outage using a sample of snubbers in the facility. TSR 3.7.4.2, Testing Frequency is 24 months. Surveillance Instructions O-SI-4.6.H-2A, 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E, Section 1.3A, Frequency/Conditions state: This Surveillance Instruction shall be performed each refueling outage and portions of it may be performed to establish operability in accordance with 1-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers. Testing of the 10% sample lot of hydraulic and mechanical snubbers takes place every 24 months/ at each scheduled unit refueling outage in accordance with the TSR 3.7.4.2 and the applicable SI. E-14

OM Part 4, Section 3.2.3, Inservice Operability testing Sample Plans: The inservice testing sample shall be selected using one of the three sample plans (a comparison of sampling plans is contained in Appendix C): (a) 10% testing plan (b) 37% testing plan (c) 55% testing plan The snubbers of parallel and multiple installations shall be identified and counted individually. All fractional sample sizes shall be rounded up to the next integer. 0-TI-398, Section 7.17, 2nd paragraph of the Functional Test Program Guidelines states: Functional tests are performed each operating cycle to meet Technical Requirements Manual TRM 3.7.4.2 verifying, by sampling 10% of each subgroup of snubber, that the safety-related or quality-related snubbers are operable. For each failure to meet the functional test acceptance criteria an additional 10% of the remaining snubbers in the subgroup shall be tested, until no additional failures occur. In addition to the required sampling, snubbers under service life monitoring and balance-of-plant programs should be addressed. Specific Technical Requirements are given in the appropriate functional testing SI. 1-SI-4.6.H-1, Appendix A is a snubber listing of each individual snubber shown on a pipe support drawing. Each snubber is given a unique identification number and are counted individually as listed in Appendix A. OM Part 4, Section 3.2.4, Inservice Operability Testing Failure Evaluations TSR 3.7.4.3 states that: A failure analysis shall be made of each failure to meet the functional test acceptance criteria of TSR 3.7.4.2 to determine the cause of failure. The frequency is once for each discovery of snubber failure to meet functional acceptance criteria. 0-SI-4.6.1H-2A, 0-SI-4.6.1H-2B, and 0-SI-4.6.H-2E, Attachment 3 provides the requirements for performing failure evaluations of failed snubbers. OM Part 4, Section 3.2.4.1, Failure Evaluation Requirements. Snubbers that do not meet the operability testing acceptance criteria in paragraph 3.2.1 shall be evaluated to determine the cause of the failure. The BFN Unit 1 TSR 3.7.4.3 mandates that failure analysis be made for each snubber, failure to meet the functional test acceptance criteria in TSR 3.7.4.2 or the applicable SIs: 0-SI-4.6. H-2A, 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E state: Evaluation of snubber operability, corrective actions, and selection of other suspect snubbers for verification shall be as specified on Attachment 3 or Attachment 6, as applicable. For each failure to meet the functional test acceptance criteria an additional 10% of the remaining snubbers in the subgroup shall be tested, until no additional failures occur. In E-15

addition to the required sampling, snubbers under service life monitoring and balance-of-plant programs should be addressed. Specific Technical Requirements are given in the appropriate functional testing SI. An Engineering Failure Analysis for Inoperable Snubber must be performed or completed using the appropriate data sheets or attachments of the applicable SIs to determine the cause of failure. Results of this analysis shall be used to select snubbers to be tested in an effort to determine the operability of other snubbers with the same failure mode. Selection of snubbers for future testing may also be based on the failure analysis. This evaluation may also be used by Site Engineering when required to perform a supported system/component analysis. For each failed snubber, a PER is initiated in accordance with SPP-8.1 and SPP-3.1, a Work Order is initiated to replace the snubber (if necessary), perform in place or STB 200 Test Bench functional test. An additional 10% of the remaining snubbers in the subgroup shall be tested, until no additional failures occur. In addition to the required sampling, snubbers under service life monitoring and balance-of-plant programs should be addressed. Specific Technical Requirements are given in the appropriate functional testing SI. 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and O-SI-4.6.H-2E state: "For an inoperable snubber(s), within 72 hours, replace or restore inoperable snubbers to an operable status and perform an engineering evaluation on the supported component or system, if the snubber does NOT meet the functional test acceptance criteria of TSR 3.7.4.2. Otherwise, declare the system inoperable and follow the required actions specified in the TRM. The engineering evaluation is to determine if the component or system restrained by the snubber(s) was adversely affected by inoperability of the snubber(s) during the previous operating cycle and ensure that the restrained component or system remains capable of meeting its design function. The engineering evaluation(s) for supported component or system analysis are to be documented on Attachment 4." OM Part 4, Section 3.2.4.2, Test Failure Mode Groups. Unacceptable snubber(s) shall be categorized into test failure mode group(s). A test failure mode group(s) shall include all unacceptable snubbers that have a given failure mode, and all other snubbers subject to the same failure mode. The following failure modes shall be used: (a) Designlmanufacturing (b) Application induced (c) Maintenancelrepairlinstallation (d) Isolated (e) Unexplained For BFN Unit 1, TSR 3.7.4.4, NOTE states: "This testing is independent of the requirements of TSR 3.7.4.3. For any snubber which fails to lockup or fails to move (i.e., frozen in place), evaluate the cause. If caused by manufacturer or design deficiency, perform in-place or bench functional test of all snubbers of the same design, subject to the same defect. The functional test acceptance criteria shall be as specified in TSR 3.7.4.2." In addition, the applicable Surveillance Instructions require an engineering evaluation of the snubber failure, and classification of the snubber failure mode as isolated, location, manufacturing, design, or other. The engineering evaluation includes determination of subsequent testing required, based on the failure mode, which may involve testing of E-16

snubbers susceptible to the same failure mode. However, establishment of specific groupings based on failure modes is not performed. OM Part 4, Section 3.2.4.3, Test failure Mode Group Boundaries. Once a test failure mode group has been established, any snubber(s) in that test failure mode group will not be part of the testing groups from which the snubbers originated except as noted in paragraph 3.2.4.4 below. The new test failure mode group will remain as defined until corrective action has been completed. As stated in response to Section 3.2.4.2 above, establishment of test failure mode groups is not performed. OM Part 4, Section 3.2.4.4, Snubbers in More Than One Test Failure Mode Group - In the event that a snubber(s) becomes included in more than one test failure mode group, it shall be counted in each failure mode group in which it is unacceptable and shall be subject to the corrective action of each test failure mode group. As stated in response to Section 3.2.4.2 above, establishment of test failure mode groups is not performed. The corrective action for a snubber subject to multiple failure modes is as determined and documented in the engineering evaluation in accordance with the applicable SI. OM Part 4, Section 3.2.5, Inservice operability Testing Corrective Action and Impact on Continued Testing - Snubbers which have been found unacceptable for the testing acceptance criteria of paragraph 3.2.1.1 shall be subjected to the following corrective actions(s) with its indicated impact on continued testing. Selection of the corrective action shall be governed by the sampling plan which is used. See TVA's response to OM Part 4 item 3.2.4.1 above. For each unacceptable or failed snubber, a PER is initiated in accordance with SPP-8.1 and SPP-3.1, failure analysis performed, Work Order initiated to replace the snubber (if necessary), or STB 200 Test Bench functional test performed on an additional lot equal to 10% of the remaining snubbers of that type. Testing shall continue until no additional inoperable snubbers are found within the subsequent lots or all snubbers of the original test type are tested or all suspect snubbers identified in the failure analysis have been tested, as applicable. The functional test criteria shall be as specified in TSR 3.7.4.2 or the applicable test Sis. OM Part 4, Section 3.2.6, Inservice Operability Testing Methods. The following test requirements shall apply: (a) Testing to be performed on the snubbers in their as-found condition to the fullest extent practical regarding the features to be tested (b) Test methods employed must not alter the condition of the snubber to the extent the results are not representative of the parameters prior to test E-17

(c) inservice operability testing may be accomplished with the snubber installed in its permanent location by utilizing Owner approved test methods and equipment (d) The snubbers may be removed and bench tested in accordance Owner approved test procedures. After reinstallation, the snubber shall meet the requirements of paragraph 2.1.1(e) (e) Where the physical size of the snubber, test equipment limitations, or inaccessibility of location prevent the use of methods in paragraphs (c) and (d) above, the snubber subcomponents shall be examined and tested in accordance with approved procedures. Reassembly of individual components must be in accordance with approved procedures. (f) Testing methods may be used which measure parameters indirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods. For BFN Unit 1, Operability testing methods for mechanical and hydraulic snubbers are quantitative (use of STB 200 Test Bench w/Windows program), in accordance with applicable SIs, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, 0-SI-4.6.H-2E and TSR 3.7.4.2 requirements and, MPI-0-000-SNBOO4 for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek and Lisega Torus Dynamic Restraint Snubbers and, MPI-0-000-SNBOO2 for Hydraulic shock and Sway Arrestor Bergen-Paterson, Anchor/Darling, Fronek Unit Disassembly and Reassembly to meet the requirements (a) through (f) above. OM Part 4, Section 3.3, Testing Documentation Documents necessary to verify result of the preservice and inservice program shall include as a minimum: (a) preservice operability test procedures and results (b) inservice operability test procedures and results noncomformance results, noncomformance evaluations, and corrective action. For BFN Unit 1, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E provide a means for the control and documentation of all snubber surveillance activities provided in this Surveillance Instruction. Snubber(s) operability tests results, including nonconformance results, nonconformance evaluations, and corrective actions are documented in the appropriate data sheets or attachments of the applicable SIs listed above. These documents are included in the work package for the tested snubber and transmitted to permanent record storage (EDMS) after closure of the work package/Work Order for entry into the database. E-18

NRC Request No. 4 On Page 91 of 105 of the May 27, 2008 submittal, Alternative Examination, the licensee stated that TR 3.7.4 requirements will be utilized for the examination and testing of snubbers for preservice, inservice, and repair/replacement activities. The NRC staff was unable to find a request for relief from IWF-5200, Preservice Examinations and Tests and IWF-5400, Repair and Replacements (see RAIs 1 and 2). If one was submitted and approve, provide the appropriate reference. If not, explain this discrepancy. TVA Response to NRC Reauest No. 4 See TVA's response to NRC questions 1 and 2 above. NRC Request No. 5 On Page 91 of 105 of the May 27, 2008 submittal, Alternative Examination, the licensee stated that several referenced procedures will be utilized for snubber examination. The details of these procedures are not provided in the relief request. Explain and provide details whether and how these procedures are equivalent to or meet the requirements of Sections 2.4, 3.2, and 3.3 of the OM-4 (also see RAI 3). TVA Response to NRC Reauest No. 5 See TVA's response to NRC question 3 above. NRC Request No. 6 On page 92 of 105 of the May 27, 2008 submittal, second paragraph, under Alternative Examination, the licensee stated that visual examination of repaired and replaced snubbers will be performed in accordance with MPI-0-000-SNB004. Explain in detail how this examination is equivalent to the requirements of Sections 1.5.6 and 1.5.7 of OM Part 4. TVA Response to NRC Request No. 6 OM Part 4, Section 1.5.6, Snubber Maintenance or Repair - maintenance or repair activities which can alter the snubber's intended function shall be evaluated by considering the effects of maintenance or repair on the snubber's ability to meet the snubber examination criteria. Maintenance or repair activities that affect the ability of the snubber to satisfy its intended function shall be completed in accordance with written procedures. Snubbers which undergo maintenance or repair activities which could alter the snubber's ability to perform its intended function shall be examined and tested in accordance with the applicable requirements of paragraphs 2.3.1.2 and 3.2.1.1. The requirements selected shall ensure that the function(s) which may be affected are verified by the examination and tests to be performed. For BFN Unit 1, the alternative requirements for Snubber Maintenance or repair is provided as follows. E-1 9

0-TI-398, Section 7.18, Rebuilding of Hydraulic Snubbers states: Rebuilding of hydraulic snubbers shall be performed by task qualified and trained persons. Hydraulic snubbers shall be rebuilt in accordance with the MPI-0-000-SNBOO2, Hydraulic Shock and Sway Arrestor Bergen-Paterson, Anchor/Darling, Fronek Unit Disassembly and Reassembly, as appropriate. MPI-0-000-SNBOO2, Section 6.2 states: Rebuilt snubber shall pass functional test criteria in 0-SI-4.6.H-2B. NRC Request No. 7 On page 92 of 105 of the May 27, 2008 submittal, third paragraph, the licensee stated that snubber examination and testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, SSP-3.1, and the implementing procedures. Explain how TR 3.7.4 and/or the other specified procedures meet OM Part 4, Section 3.3, Testing Documentationrequirements. TVA Response to NRC Request No. 7 OM Part 4 Section 3.3 Testing Documentation Documents necessary to verify the result of the pre-service and in-service program shall include, as a minimum: (a) pre-service operability test procedures and results (b) In-service operability test procedures and results (c) Nonconformance results, nonconformance evaluations, and corrective action. TR 3.7.4 documents the required action, completion time and conditions pertaining to the operability, inspection, testing, and acceptance criteria of snubbers at BFN. Surveillance instructions are utilized to implement the requirements of TR 3.7.4. Plant SIs, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and 0-SI-4.6.H-2E cover functional testing of all snubbers at BFN. Surveillance instruction 1-SI-4.6.H-1 covers the visual examination of Unit 1 hydraulic and mechanical snubbers. These SIs document pre-service operability test procedures and results. They also document in-service operability test procedures and results, nonconformance evaluations, and corrective actions. Plant procedure SPP-3.1 is utilized to document when snubbers are found to be outside of testing acceptance criteria or in a nonconforming condition. Surveillance instructions are included in the work package for the snubber and transmitted to permanent record storage (EDMS) after closure of the work package/work order. NRC Request No. 8 On Page 93 of 105 of the May 27, 2008 submittal, JustificationFor The Granting Of Relief, first paragraph, the licensee stated that the current program, as defined by TR 3.7.4 provides for a level of quality and safety equal to or greater than that provided by the OM and utilizes NRC guidance not incorporated into the OM Code. (1) Explain how TR 3.7.4 provides a level of quality and safety equal to and greater than that provided by OM E-20

Part 4. (2) clarify and provide information regarding the statement "and utilizes guidance not incorporated in the OM Code referenced by the 2001 Edition, 2003 addenda of ASME Section XI." (quotation marks added to facilitate identification) TVA Response to NRC Reauest No. 8 See TVA's response to NRC Request number 3 above. TVA's reference to guidance not incorporated in the OM Code will be deleted. This referral was to GL 90-09 which is incorporated into the BFN Unit 1 Snubber Program. NRC Request No. 9 On Page 93 of 105, JustificationFor The Grantingof Relief, second paragraph, the licensee stated that: Examination, testing, repair and replacement of snubbers is currently performed in accordance with TR 3.7.4, which utilizes the guidance provided by NRC in GL 90-09. The OM Code referenced by ASME Section XI has a different basis for examination (failure mode groups) and testing plans (10 percent, 37, or 55). It is impractical to implement both plans because of the resulting duplication of examination and testing. It should be noted that (1) GL 90-09 only provides guidance for Snubber Visual Examination Intervals and Corrective Actions. GL 90-09 does not provide guidance for testing and repair and replacement; and (2) the ASME Section XI references the use of ASME/ANSI OM-1987, Part 4 (OM-4), with OMa-1988, which is not same as OM Code. Please explain these discrepancies. TVA Response to NRC Request No. 9 The proposed BFN Unit 1 examination and testing plan alternatives are provided in TSR 3.7.4.1, TSR 3.7.4.2, and TSR 3.7.4.3. See, also, TVA's response to NRC request number 3 above. NRC Request No. 10 On page 93 of 105, Justification For The Granting Of Relief, fourth paragraph, the licensee stated that the maintenance procedure MPI-0-000-SNBOO4 provides visual examination criteria for installation of a snubber after repair or replacement. Provide details how the maintenance procedure visual examination requirements are equal to OM Part 4, Section 2.3.1.2 requirements. E-21

TVA Response to NRC Request No. 10 OM Part 4, Section 2.3.1.2, Visual Examination Requirements states: The snubber installation must meet the following requirements:

a. Snubbers shall be installed so that they can carry the load. Visual observation of loose fasteners, deformed members, or detection of disconnected components requires the identification of the installation as unacceptable.

The alternate requirements in the BFN SI, 1-SI-4.6.H-1, Attachment 2, "Visual Examination Checklist for All Snubbers" checklist Item A reads: "The snubber has no visible indications of damage or impaired operability." and specifically includes observing the exposed parts of the snubber for broken parts, deformation, or other damage that could result in unacceptable performance. See, also, TVA's response to NRC request number 3 above.

b. Snubbers shall be installed in such condition that they do not restrict the thermal movement to the extent that unacceptable overstressing could develop in the pipe or other equipment that the installation is designed to protect or restrain. If no indication of binding, misalignment, or deformation is observed, the provisions of this requirement are considered to be satisfied.

The BFN alternative states that the item is to be observed in performance of visual SI 1-SI-4.6.H-1. Attachment 2 of the SI contains the following verifications: Centerline of the clamp assembly and structural attachment offset (i.e., a based on the clearances between the rod eyes, paddles, and the attachment clevis. Contact of these parts, which produces a side load on the snubber is unacceptable. Observe spacers are installed on each side of the snubber eye to reduce the misalignment and or binding. Space shall not exceed 1/16 inch on either side or 1/8 inch total. Observe for evidence of torsional binding (i.e. mechanical snubber twisted along its axis by the pipe clamp and structural attachments). See, also, TVA's response to NRC request number 3 above.

c. Special features required for the actuation of the snubber shall be verified. For example, fluid supply or content for hydraulic snubbers shall be observed.

Observation that the fluid level is equal to or greater than the minimum amount which is sufficient for actuation at its operating extension is considered to satisfy the provisions of this requirement for hydraulic snubbers. If the fluid is less than the minimum amount, the installation is to be identified as unacceptable unless a test is performed establishing that the performance of the snubber is within specified limits. Tests shall be performed in accordance with paragraphs 3.2.1.1(b) and 3.2.1.1(c) and the initial test shall start with the piston at the as-found setting and be performed in the extension (tension) direction. See TVA's response to NRC request number 3 above. E-22

Also, 0-TI-398, Appendix A, under Alternate Examinations states: The BFN TRM, TR 3.7.4, requirements will be utilized for the examination and testing of snubbers for preservice, inservice, and repair/replacement activities. The procedures utilized for these examinations are 1-SI-4.6.H-1, "Visual Examination of Hydraulic and Mechanical Snubbers;" 0-SI-4.6.H-2A, "Functional Testing of Mechanical Snubbers;" 0-SI-4.6.H-2B, "Functional Testing of Bergen-Paterson Hydraulic Snubbers;" and 0-SI-4.6.H-2E, "Functional Testing of Lisega Large Bore Torus Dynamic Restraints;" MPI-0-000-SNBOO2, "Hydraulic Shock and Sway Arrestor Bergen-Paterson Unit Disassembly and Reassembly;" and MPI-0-000-SNBOO4, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson Hydraulic, Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Restraints Snubbers." This will include the pin-to-pin area inclusive of applicable snubbers. Testing of repaired and replaced snubbers will also be performed in accordance with TR 3.7.4. Visual examination of repaired and replaced snubbers will be performed in accordance with MPI-0-000-SNBOO4, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson Hydraulic, Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Restraints Snubbers". Snubber examination and testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, SPP-3.1, and the implementing procedures 1-SI-4.6.H-1, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, O-SI-4.6.H-2E, MPI-0-000-SNB002, and MPI-0-000-SNB004. The areas inclusive of the pins back to building structure and to the component/piping being supported will remain in the ASME Section XI examination boundary. NRC Request No. 11 On page 94 of 105, Justification For The Granting Of Relief, first paragraph, the licensee stated that the training and documentation of personnel to the visual acceptance criteria, specified in the TRM implementing procedures provides an acceptable level of quality and safety. Justify this statement and explain how TRM implementing procedures visual training is equal to VT-3 training as required by the OM, Section IWA-2300. TVA Response to NRC Reauest No. 11 The proposed alternative for snubber visual examination training qualification and documentation is provided by 1-SI-4.6.H-1 Step 7.1.1 [A] through [F]. The visual acuity requirements of IWA-2320 are satisfied. E-23

NRC Reauest No. 12 On page 94 of 105, Justification For The Granting Of Relief, second paragraph, the licensee stated that:

       "Because relief is sought from the ASME Section XI snubber examination and test requirements, there will be no ASME Section XI snubber examination and test activities to require ANII involvement.

A snubber program manager provides oversight of the TRM snubber program implementation for both visual examination and functional testing. The snubber program manager provides an acceptable level of quality and safety without ANII involvement in those activities." Provide a justification for this statement with respect to the fact that the snubber program manager or person performing snubber inspection should be trained as required by IWA-2300 or alternative method IWA-2317. TVA Response to NRC Request No. 12 IWA-2300 addresses qualifications of NDE personnel. The snubber program manager and persons performing the snubber inspections meet the visual requirements described by IWA-2300. NRC Request No. 13 On Page 94 of 105, JustificationFor Granting Of Relief, third paragraph, second sentence, the licensee stated that under the alternative requirements for snubbers, there will be no ASME Section Xl inservice examination and testing to document in a summary report and TR 3.7.4 is implemented by surveillance instructions and maintenance instruction. Justify how these specified surveillance instructions are equivalent to the Code requirements of Section IWA-6230 and OM-4, Section 2.3, and 3.3. TVA Response to NRC Request No. 13 OM Part 4 Section 2.3.1, Inservice Examination Requirements; Visual Examination for impaired functional ability; Visual Examination Requirements to verify snubbers can carry load, snubbers do not restrict movement, and verification of special features required for actuation. See TVA response in NRC request number 3, response to OM Part 4 sections 2.1a through 2.le. OM Part 4 Section 2.3.2, Inservice Examination Frequency TSR 3.7.4.1 requires performance of a visual inspection of snubbers with the frequency based on Table 3.7.4-1. Also, see TVA response in NRC request number 3, response to OM Part 4 section 3.2.2. E-24

OM Part 4 Section 2.3.4.1, Failure Evaluation; Section 2.3.4.2, Functional Test Evaluation See TVA response in NRC request number 3, response to OM Part 4 section 2.4d. OM Part 4 Sections 2.3.4.3 through 2.3.5.4, which address Failure Mode Groups and Corrective Actions See TVA response in NRC request number 3, response to OM Part 4 section 3.2.4.2. OM Part 4 Sections 2.3.5.5, Supported Component(s)/System Evaluation. See TVA response in NRC request number 3, response to OM Part 4 section 3.2.4.1. OM Part 4 Section 3.3, See TVA response to NRC Request 3 above. IWA-6230 Summary Report Preparation (a) A preservice inspection summary report shall be prepared prior to commercial service (b) An inservice inspection summary report shall be prepared at the completion of the inservice inspection conducted during a refueling outage. Examinations, test, and repairlreplacement activities conducted since the preceding summary support shall be included: (c) Each summary report required by IWA-6230(a) or (b) shall contain the following: (1) Interval, period and refueling outage number (when applicable) (2) Owner's report for Inservice Inspections, Form NIS-1, as shown in Appendix II 0-TI-398, Appendix A states: Under the alternate requirements for snubbers, there will be no ASME Section Xl inservice examination and testing to document in a summary report. TR 3.7.4 is implemented by Sis 1-SI-4.6.H-1, O-SI-4.6.H-2A, O-SI-4.6.H-2B, O-SI-4.6.H-2E, and maintenance instructions MPI-0-000-SNBOO2, and MPI-0-000-SNBOO4. These instructions are written and approved in accordance with the TVA Nuclear Quality Assurance Program, includes data sheets for documenting the visual examination and functional test data and results, and provides for documentation of non conforming results and evaluation of those results. The completed data sheets are Quality Assurance records and are controlled and maintained in accordance with the BFN QA records program. These records are available onsite for review and inspection. The QA records documenting snubber visual examinations and functional tests provide an acceptable level of quality and safety when compared to the requirements of ASME Section XI and OM-1987, Part 4. E-25

(3) Owner's Report for Repair Replacement Activities, Form NIS-2, as shown in Appendix II - ASME XI snubber repair replacement. (d) Summary sheets shall have a cover sheet providing the following: (1) Date of document completion (2) Name and address of Owner (3) Name and address of plant (4) Name and number designation of the unit (5) Commercial service date for the unit Completed data packages from O-SI-4.6.H.2A, 0-SI-4.6.H.2B, and O-SI-4.6.H-2E are permanent plant records prepared and stored in accordance with the TVA QA Program requirements. NRC Request No. 14 The TRM does not the address the requirements of OM Part 4, Section 2.3.4 "Inservice Examination Failure Evaluation." Explain how the proposed TRM revision meets this requirement. TVA Response to NRC Reauest No. 14 OM Part 4, Section 2.3.4.1, Failure Evaluation. Snubbers which fail to meet the examination acceptance criteria shall be evaluated to determine the cause of the unacceptability. TRM section TSR 3.7.4.1 states: Snubbers which appear inoperable as a result of visual inspection shall be classified unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per the criteria of TSR 3.7.4.2. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the system or train shall be declared inoperable. Additionally, TRM section TSR 3.7.4.3 states: A failure analysis shall be made of each failure to meet the functional test acceptance criteria of TSR 3.7.4.2 to determine the cause of the failure. OM Part 4, Section 2.3.4.2, Functional Test Evaluation - The snubber(s) that is found to be unacceptable as a result of inservice examination may be tested in accordance with requirements of paragraph 3.2, provided the testing can resolve the unacceptable condition. Results which satisfy the operability test criteria may be used to re-categorize the snubber(s) as acceptable. See TVA's response above regarding OM Part 4, Section 2.3.4.1 above. E-26

OM Part 4, Section 2.3.4.3, Examination Failure Mode Groups - Unacceptable snubbers shall be categorized into examination failure mode groups. An examination failure mode group shall include all unacceptable snubbers which have a given failure and all other snubbers subject to the same failure, except as permitted to be considered separately under paragraph 1.6. The examination failure mode groups shall be distinct for examination purposes from any testing failure mode groups. The following examination failure mode groups shall be used: (a) Design/manufacturing (b) Application induced (c) Maintenance/repair/installation (d) Isolated (e) Unexplained The BFN snubber program does not categorize examination failures into failure mode groups, although as reported in the above response to OM Part 4, Section 2.3.4.1, the cause of all examination failures is established and remedied for that particular snubber and for other snubbers that may be generically susceptible. In accordance with 0-TI-398, Snubber Program Procedure, snubber failures are classified as follows: Location - A failure of a snubber(s) resulting from environmental conditions. Examples include failure of a snubber due to excessive heat, failure due to excessive local system vibration or failure due to other localized anomalies. Manufacturing - A failure resulting from a potential defect in manufacturing. Examples include incorrectly assembled snubbers, inclusion of incorrect piece parts and failure of a snubber(s) due to improper or incorrect maintenance or repair practices performed by the vendor. Desian - A failure resulting from an error in the design. This classification would include incorrectly sized snubbers, snubbers provided with insufficient travel, snubbers with insufficient swing margins and design misapplications or errors. Unknown - A failure that cannot be categorized as location, manufacturing, design or other. This includes all failures for which the cause of failure cannot be determined. Other - When the unknown cause of the failure cannot be categorized as location, manufacturing or design. This classification would include snubbers that fail due to end of service life. Additional examples include failure of snubbers due to plant transients, misapplication of rigging loads to the snubber and incidental interaction of tools or equipment on the snubber. E-27

0-TI-398 sections 7.19.2A.3 and 7.19.2A.4 provide the following scope expansion and additional testing requirements due to the failure mode: If the failure was found as part of the Technical Requirements Manual initial or any subsequent samples the following is the minimum required testing expansion:

a. Expand the sample by 10% of the remaining snubbers in the subgroup, and

b. If the cause of the failure is determined to be a system transient, test all snubbers on that system, which could have been affected by the transient, and

c. If the cause is a generic manufacturing defect, test all snubbers of that same type, and

d. Identify and test all other snubbers suspected of the same failure mode.

If the failure was found outside of the Technical Requirements Manual initial or any subsequent samples (i.e., other maintenance activity, testing directed/requested by the Snubber Engineer, Service Life Monitoring testing, testing of snubbers on non-Technical Specification or Technical Requirements Manual systems, etc.) the following is the minimum required testing expansion:

a. If the cause of the failure is determined to be a system transient, test all snubbers on that system, which could have been affected by the transient, and

b. If the cause is a generic manufacturing defect, test all snubbers of that same type, and

c. Identify and test all other snubbers suspected of the same failure mode.

OM Part 4, Section 2.3.4.4, Examination Failure Mode Group Boundaries. Once an examination failure mode group has been established, any snubber(s) in that examination failure mode group(s) will not be part of the examination group(s) from which the snubber originated except as noted in paragraph 2.3.4.5 below. The new examination failure mode group will remain as defined until:- (a) the examination failure mode group has reached the maximum time interval allowed E-28

(b) replacement/modification action in accordance with paragraphs 2.3.5.1(a) or (c), or paragraph 2.3.5.2 provides an examination failure group with all acceptable snubbers. See TVA's response above regarding OM Part 4, Section 2.3.4.3. OM Part 4, Section 2.3.4.5, Snubbers in More Than One Failure Group - Any snubber(s) which is in more than one examination failure mode group, the examination schedule for that snubber will be determined by the examination failure mode group with the shortest examination schedule. See TVA's response above regarding OM Part 4, Section 2.3.4.3. Based on the information provided above, TVA considers that the alternate BFN Unit 1 program, in accordance with TR 3.7.4, for the examination and testing of snubbers will provide an acceptable level of quality and safety. Attachments: Attachment A - BFN Technical Requirements Manual, Section 3.7.4, Snubbers Attachment B - BFN Technical Instruction, 0-TI-398, Snubber Program Procedure Attachment C - BFN Surveillance Instruction, 1-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers Attachment D - BFN Mechanical Preventative Instruction, MPI-0-000-SNBOO4, Removal and Reinstallation of Snubbers Attachment E - BFN Surveillance Instruction, O-SI-4.6.H-2A, Functional Testing of Mechanical Snubbers Attachment F - BFN Surveillance Instruction, O-SI-4.6.H-2B, Functional Testing of Bergen-Patterson, Anchor/Darling or Fronek Hydraulic Snubbers Attachment G BFN Surveillance Instruction, O-SI-4.6.H-2E, Functional Testing of Lisega Large Bore Torus Dynamic Restraint Snubbers Attachment H BFN Modification and Addition Instruction, MAI-4.10, Piping Clearance Instruction Attachment I - BFN Modification and Additions Instruction, MAI-4.2A, TVA-BFNP Piping/Tubing Supports E-29

Attachment A BFN Technical Requirements Manual, Section 3.7.4, Snubbers

Snubbers TR 3.7.4 TR 3.7 PLANT SYSTEMS TR 3.7.4 Snubbers LCO 3.7.4 During all MODES of operation, all snubbers shall be OPERABLE. All safety-related snubbers are listed in plant procedures. APPLICABILITY: MODES 1, 2, 3, 4, 5 when the associated system/component is

                              . required to be OPERABLE.

---

NOTE-----------------------------

Snubbers located inside the drywell on reactor vessel attached piping shall be OPERABLE whenever fuel is in the reactor vessel. Snubbers on the Main Steam, HPCI, and RCIC piping, in the drywell, are exempt from the operability requirement when the steam line plugs are installed in the reactor vessel. ACTIONS

---

NOTE-----------------------------

Separate condition entry is allowed for each system/train - not per snubber. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1.1 Replace or restore the 72 hours snubber(s) inoperable. inoperable snubber(s) to OPERABLE status. AND (continued) BFN-UNIT 1 3.7-7 TRM Revision 7-- 17 April 07, 2000

Snubbers TR 3.7.4 ACTIONS CONDITION [ REQUIRED ACTION I COMPLETION TIME A. One or more NOTES---------------- snubber(s) inoperable 1. Only required if the (continued). snubber(s) do not meet the functional test acceptance criteria of TSR 3.7.4.2.

2. The evaluation must ensure the inoperable snubber did not adversely affect the supported component or system during the previous operating cycle.

A.1.2 Perform an engineering 72 hours evaluation to determine whether the snubber failure mode has adversely affected the supported component or system. OR A.2 Verify operability of the 72 hours supported system based on an engineering evaluation of its functional capability with the inoperable snubber(s). OR (continued) BFN-UNIT 1 3.7-7a TRM Revision 47, 42 February 10, 2004

Snubbers TR 3.7.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.3.1 Declare the supported 72 hours snubber(s) inoperable system inoperable. (continued). (Refer to applicable TS and TRM LCOs). AND

                                  ------------- NOTE ----------- w------

Only applicable to snubbers located inside the drywell on reactor vessel attached piping. A.3.2 Be in MODE 4 or 5. 108 hours B. Supported system ----------- NOTES--------- declared inoperable 1. Only applicable while in due to one or more MODE 4 or 5. inoperable snubbers. 2. Only applicable to snubbers located inside the drywell on reactor vessel attached piping. (Excluding MS, HPCI, and RCIC piping when the steam line plugs are installed in the reactor vessel.). B.1 Verify by administrative 4 hours means that two ECCS subsystems are in OPERABLE status. C. Required Action and C.1 Initiate action to restore Immediately. associated Completion two ECCS subsystems to Time B not met. OPERABLE status. BFN-UNIT 1 3.7-7b TRM Revision 42 February 10, 2004

Snubbers TR 3.7.4

---

-------------------------------------- NIfVTI~O ------------------------------------------------------

IlJ 'I

1. Each safety-related snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection and test program and the requirements of this Technical Requirement. These snubbers are listed in plant procedures.

2. As used in this Technical Requirement, "type of snubber" shall mean snubbers of the same design and manufacturer, irrespective of capacity.

3. As used in this Technical Requirement, "population or category" shall mean the total number of snubbers being visually inspected as a lot.

TECHNICAL SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSR 3.7.4.1 -NOTE Snubbers are categorized as inaccessible or accessible during reactor operations. Each of these categories (inaccessible or accessible) may be inspected separately or jointly according to the schedule determined by Table 3.7.4-1. The visual inspection interval for a snubber population or category shall be determined based upon the criteria provided by Table 3.7.4-1. The first inspection interval determined using Table 3.7.4-1 criteria shall be based on the

                                         .previous inspection interval established by the requirements in effect before Technical Specification Amendment 210 was issued.

Perform visual inspection of required In accordance snubber(s) based on the criteria of with Table Table 3.7.4-1 for each population or 3.7.4-1 category to verify:

a. No visible indications of damage or impaired OPERABILITY;

b. Attachments to the foundation or supporting structure are functional; and (continued)

BFN-UNIT 1 3.7-8 TRM Revision 7 March 17, 1999

Snubbers TR 3.7.4 TECHNICAL SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSR 3.7.4.1 c. Fasteners for the attachment of the (continued) snubber to the component or system and to the snubber anchorage are functional. The discovery of loose or missing attachment fasteners will be evaluated to determine whether the cause may be localized or generic. Snubbers which appear inoperable as a result of visual inspection shall be classified unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per the criteria of TSR 3.7.4.2. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the system or train shall be declared inoperable. Additionally, snubbers attached to sections of safety related systems that have experienced unexpected potentially damaging transients since the last inspection period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY. Snubbers which have been made inoperable as the result of unexpected transients, isolated damage, or other random (continued) BFN-UNIT 1 3.7-9 TRM Revision 7-- 17 April 07, 2000

Snubbers TR 3.7.4 TECHNICAL SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSR 3.7.4.1 events, when the provisions of TSR 3.7.4.5 (continued) and TSR 3.7.4.6 have been met and any other appropriate corrective action implemented, shall not be counted in determining the next visual inspection interval. TSR 3.7.4.2 Perform an in-place or bench functional test 24 months of a representative sample of 10% of the total of each type of safety-related snubber(s).

a. The representative sample selected for functional testing shall include the various configurations, operating environments, and the range of size and capacity of snubbers within the types;

b. The representative sample should be weighed to include more snubbers from severe service areas such as near heavy equipment;

c. The stroke setting and the security of fasteners for attachment of the snubbers to the component or system and to the snubber anchorage shall be verified.

(continued) BFN-UNIT 1 3.7-10 TRM Revision @, 17 April 07, 2000

Snubbers TR 3.7.4 TECHNICAL SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSR 3.7.4.2 Functional Test Acceptance Criteria: (continued) The snubber functional test shall verify that:

a. Activation (restraining action) is achieved in both tension and compression within the specified range, except that inertia dependent, acceleration limiting mechanical snubbers may be tested to verify only that activation takes place in both directions of travel.

b. Snubber bleed or release, where required, is present in both compression and tension within the specified range.

c. For mechanical snubbers, the force required to initiate or maintain motion of the snubber is not great enough to overstress the supported component or system during thermal movement, or to indicate impending failure of the snubber.

d. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

e. 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.

(continued) BFN-UNIT 1 3.7-11 TRM Revision 7 17 April 07, 2000

Snubbers TR 3.7.4 TECHNICAL SURVEILLANCE REQUIREMENTS (continued) I. SURVEILLANCE FREQUENCY 4. TSR 3.7.4.3 A failure analysis shall be made of each Once for each failure to meet the functional test acceptance discovery of criteria of TSR 3.7.4.2 to determine the snubber failure cause of the failure. The result of this to meet analysis shall be used, if applicable, in functional test selecting snubbers to be tested in the acceptance subsequent lot in an effort to determine the criteria OPERABILITY of other snubbers which may be subject to the same failure mode. Selection of snubbers for future testing may also be based on the failure analysis. For each failed snubber, perform in-place or bench functional test on an additional lot equal to 10% of the remainder of that type of snubber. Testing shall continue until no additional inoperable snubbers are found within subsequent lots or all snubbers of the original test type are tested or all suspect snubbers identified by the failure analysis have been tested, as applicable. The functional test criteria shall be as specified in TSR 3.7.4.2. Prior to functional testing the discovery of Once for each loose or missing attachment fasteners will be discovery of evaluated to determine whether the cause loose or missing may be localized or generic. The result of attachment the evaluation will be used to select other fasteners suspect snubbers for verifying the attachment fasteners, as applicable. (continued) BFN-UNIT 1 3.7-12 TRM Revision 7--, 17 April 07, 2000

Snubbers TR 3.7.4 TECHNICAL SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY

                                                                           +

TSR 3.7.4.4 ------------------- NOTE ------------------------- This testing is independent of the requirements of TSR 3.7.4.3. For any snubber which fails to lockup or fails Once for each to move (i.e., frozen in place), evaluate the discovery of cause. If caused by manufacturer or design snubber failure deficiency, perform in-place or bench to lockup or functional test of all snubbers of the same failure to move design, subject to the same defect. The functional test acceptance criteria shall be as specified in TSR 3.7.4.2. TSR 3.7.4.5 Perform an engineering evaluation on the Once for each component or system which is restrained by discovery of an the snubber(s) found inoperable due to not inoperable meeting their functional test acceptance snubber criteria as specified in TSR 3.7.4.2. TSR 3.7.4.6 Verify replacement snubbers and snubbers Once prior to having repairs which might affect the installation in functional test results meet the test criteria of the unit for each TSR 3.7.4.2. replacement snubber and

a. These snubbers shall have met the each snubber acceptance criteria subsequent to their which has most recent service; and repairs which might affect

b. The functional test must have been functional test performed within the 12 months prior to results being installed in the unit.

BFN-UNIT 1 3.7-13 TRM Revision 7-, 17 April 07, 2000

Snubbers TR 3.7.4 Table 3.7.4-1 Snubber Visual Inspection Interval NUMBER OF UNACCEPTABLE SNUBBERS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval (Notes 1 and 2) (Notes 3 and 6) (Notes 4 and 6) (Notes 5 and 6) 1 0 0 1 80 0 0 2 100 0 1 4 150 0 3 8 200 2 5 13 300 5 12 25 400 8 18 36 500 12 24 48 750 20 40 78 1000 or more 29 56 109 Note 1: The next visual inspection interval for a snubber population or category size shall be determined based upon the previous inspection interval and the number of unacceptable snubbers found during that interval. Snubbers may be categorized, based upon their accessibility during power operation, as accessible or inaccessible. These categories may be examined separately or jointly. However, the licensee must make and document that decision before any inspection and shall use that decision as the basis upon which to determine the next inspection interval for that category. Note 2: Interpolation between population or category sizes and the number of unacceptable snubbers is permissible. Use next lower integer for the value of the limit for Columns A, B, or C if that integer includes a fractional value of unacceptable snubbers as determined by interpolation. BFN-UNIT 1 3.7-14 TRM Revision 7 March 17, 1999

Snubbers TR 3.7.4 Table 3.7.4-1 (Continued) Snubber Visual Inspection Interval Note 3: If the number of unacceptable snubbers is equal to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months. Note 4: If the number of unacceptable snubbers is equal to or less than the number in Column B but greater than the number in Column A, the next inspection interval shall be the same as the previous interval. Note 5: If the number of unacceptable snubbers is equal to or greater than the number in Column C, the next inspection interval shall be two-thirds of the previous interval. However, if the number of unacceptable snubbers is less than the number in Column C, but greater than the number in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable snubbers found during the previous interval and the number in Column B to the difference in the numbers in Columns B and C. Note 6: The provisions of TSR 3.0.1, 3.0.2, and 3.0.3 are applicable for all inspection intervals up to and including 48 months. BFN-UNIT 1 3.7-15 TRM Revision 7 March 17, 1999

Attachment B BFN Technical Instruction, 0-TI-398, Snubber Program Procedure

Browns Ferry Nuclear Plant Unit 0 Technical Instruction 0-TI-398 Snubber Program Procedure Revision 0005 Quality Related Level of Use: Reference Use Effective Date: 12-23-2006 Responsible Organization: DEC, Design Eng Civil Prepared By: Stephen Samaras Approved By: Eric Frevold

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 2 of 166 Current Revision Description Pages Affected: Coversheet, revision log, 3 to 6, 10, 15 16, 26 (section 7.12 - deleted B, C & D), 27, 31, 32, 33, 44, 45, 48, 49, 166 and 167. Type of Change: REVISION Tracking Number: 006 This procedure is being revised as a corrective action for PER 103475 to provide additional clarification on the activation acceptance criteria for functional testing of PSA Mechanical snubbers, to remove the "push-pull" functional testing of mechanical PSA snubbers and to incorporate program enhancements identified by TVAN Self Assessment SQN-ENG 008 "Snubber Program".

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 3 of 166 Table of Contents

1.0 INTRODUCTION

............................................................................. 7 1.1 Purpose....................................................................................... 7 1.2 Scope ......................................................................................... 7

2.0 REFERENCES

............................................................................... 8 2.1 Source References .......................................................................... 8 2.2 Developmental References.................................................................. 9 3.0 DEFINITIONS............................................................................... 11 4.0 GENERAL PRECAUTIONS............................................................... 13 5.0 PREREQUISITES .......................................................................... 13 6.0 EQUIPMENT................................................................................ 13 7.0 PROCEDURE............................................................................... 14 7.1 General...................................................................................... 14 7.2 Program Ownership ........................................................................ 14 7.3 Duties and Responsibilities................................................................. 15 7.4 Interfaces.................................................................................... 16 7.4.1 Operations ........................................................................ 16 7.4.2 Mechanical Maintenance ........................................................ 16 7.4.3 Site Engineering - Design ........................................................ 16 7.4.4 Modifications ...................................................................... 17 7.4.5 Materials and Procurement....i................................................... 17 7.4.6 Component Engineering ......................................................... 17 7.4.7 Planning and Scheduling......................................................... 17 7.5 Regulatory Requirements.................................................................. 18 7.6 Snubber UNIDs, Lists, and Drawings...................................................... 18 7.6.1 Unique Identifiers (UNIDs) ....................................................... 18 7.6.2 Snubber Lists ..................................................................... 19 7.7 Outage Planning and Preparation ............ ............................................ 19 7.7.1 Previous SI Performance ........................................................ 19 7.7.2 Hydra ulic Snubber Seal Service Life ............................................ 20 7.7.3 Functional Test Sample .......................................................... 20

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 4 of 166 Table of Contents (continued) 7.7.4 Functional Testing of Large Bore Hydraulic Snubbers......................... 20 7.8 Receipt Inspection and Storage of Snubbers............................................. 21 7.8.1 Receipt Inspection ................................................................ 21 7.8.2 Storage of Snubbers After Initial Receipt Inspection and Prior To Installation (Nuclear Stores) ................................................. 21 7.8.3 Storage of Snubbers After Removal From Nuclear Stores or the Plant........................................................................... 22 7.9 ALARA Planning ............................................................................ 23 7.10 In-Service Inspection (ISI) (ASME Section XI Requirements)........................... 23 7.11 Spare Snubbers ............................................................................ 24 7.12 Functional Test Equipment ................................................................ 24 7.13 SI Performance Team and Facilities ...................................................... 25 7.14 Training and Qualification of Performers.................................................. 26 7.14.1 General ............................................................................ 26 7.14.2 Visual Examinations .............................................................. 26 7.14.3 Functional Tests of Hydraulic Snubbers........................................ 26 7.14.4 Rebuilding Hydraulic.Snubbers.................................................. 27 7.14.5 Functional Tests of PSA Mechanical Snubbers ................................ 27 7.14.6 Rebuilding PSA Mechanical Snubbers.......................................... 27 7.15 Visual Examination Program ............................................................... 28 7.15.1 Scope and Frequency............................................................. 28 7.15.2 Visual Inspection Package....................................................... 28 7.15.3 Examination Items................................................................ 29 7.15.4 Resolution of Anomalies ......................................................... 29 7.16 Decontamination............................................................................ 30 7.16.1 General Considerations.......................................................... 30 7.16.2 Decontamination of Mechanical Snubbers...................................... 30 7.16.3 Decontamination of Hydraulic Snubbers........................................ 30 7.17 Functional Test Program Guidelines....................................................... 31 7.17.1 Functional Test Packages........................................................ 31 7.17.2 Functional Testing of PSA Mechanical Snubbers.............................. 32

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 5 of 166 Table of Contents (continued) 7.17.3 Eu nctional Testing of Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers............................................. 34 7.18 Rebuilding of Hydraulic Snubbers ......................................................... 35 7.18.1 Hydraulic Rebuild Packages..................................................... 35 7.19 Evaluatio n of Degraded and Failed Snubbers............................................ 36 7.19.1 Degraded Snubbers .............................................................. 36 7.19.2 Failed Snubbers .................................................................. 38 7.20 Supported System/Component Analysis.................................................. 41 7.20.1 Mechanical Snubbers ............................................................ 41 7.20.2 Hydraulic Snubbers............................................................... 41 7.211 Performance Monitoring and Trending .................................................... 42 7.21.1 General Approach ................................................................ 42 7.21.2 Trending for Hydraulic Snubbers................................................ 42 7.21.3 Mechanical Snubber Performance Trending.................................... 43 7.22 Service Life Monitoring..................................................................... 44 7.22.1 Regulatory Requirements ......... e............................................. . 44 7.22.2 Hydraulic Snubber Service Life Program ....................................... 44 7.22.3 PSA Mechanical Snubber Service Life Monitoring ............................. 44 7.23 Balance of Plant Hydraulic and Mechanical Snubbers .................................. 45 7.24 Dynamic Transients ........................................................................ 46 7.25 Snubber Users Group (SNUG) ............................................................ 47 7.25.1 SNUG Organization Formation and Purpose................................... 47 7.26 Snubber Program Notebook............................................................... 47 8.0 ACCEPTANCE CRITERIA ................................................................ 47 9.0 APPENDICES .............................................................................. 48 Appendix A: Snubber Request for Relief 3-ISI-2 .......................................... 49 Appendix B: Bergen-Paters'on, Anchor/Darling or Fronek Hydraulic. Snubber......................................................................... 55 Appendix C: Grinnell Hydraulic Snubbers................................................. 63 Appendix D: Bergen-Paterson Torus Dynamic Hydraulic Restraint Snubbers......................m.................................................. 73

Table of Contents (continued) Appendix E: Lisega Torus Dynamic Restraint Hydraulic Snubbers ...................... 82 Appendix F: Pacific Scientific Company Mechanical Snubbers ........................... 87 Appendix G: Service Life Monitoring Recommendations ......................................... 108 Appendix H: Hydraulic Snubber Failure Analysis Approach, Failure Modes, Indications and Failure Cause .................................................. 122 Appendix I: Mechanical Snubber Failure Analysis Approach, Failure Modes, Indications and Failure Cause.................................................. 133 Appendix J: Snubber Request for Relief 2-ISI-13 ...................................................... 154 Appendix K: Snubber Request for Relief 1-ISI-18 ...................................................... 160 Appendix L: Snubber Program Notebook Table of Contents ................................... 165

1.0 INTRODUCTION

1.1 Purpose The purpose of this Technical Instruction (TI) is to provide a single source of guidance, explanations, and information, with regard to snubbers, that is required to establish and maintain the Browns Ferry Snubber Program. The more knowledgeable reader will be able to utilize this document to examine, evaluate, and/or administer the Browns Ferry Snubber Program. 1.2 Scope A. This TI applies to all mechanical and hydraulic snubbers, safety-related or non-safety-related. B. This TI applies to TVA employees, contractor, and vendor employees involved with snubber inspection, testing, maintenance, procurement, storage, design, installation, or modification. C. Snubber program regulatory requirements apply only to safety-related snubbers. D. Snubber program satisfies alternative to sub-article, IWF-5300 and IWA-6230 of Section XI of the ASME Code requirements for Unit 3 per NRC approval of "Snubber Request for Relief 3-ISI-2", dated May 3, 1999. E. Snubber program satisfies alternative to sub-article, IWF-5300 and IWA-6230 of Section XI of the ASME Code requirements for Unit 2 per NRC approval of "Snubber Request for Relief 2-ISI-1 3", dated January 7, 2003. F. Snubber program satisfies alternative to sub-article, IWF-5300 and IWA-6230 of Section XI of the ASME Code requirements for Unit 1 per NRC approval of "Snubber Request for Relief 1-1S1-1 8", dated April 30, 2004.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 8 of 166

2.0 REFERENCES

2.1 Source References A. API/Barker STB-200 Snubber Test Bench Manual B. API/Barker STB-200 Snubber Test Bench Software Quality Assurance Plan C. BFN-VTM-B209-0160, Vendor Technical Manual For Bergen-Paterson Reactor Torus Ring Hydraulic Shock Suppressors. D. BFN-VTD-B209-0180, Installation Techniques For Bergen-Paterson Series 78000 Hydraulic Shock Suppressors. E. BFN-VTD-B209-0200, Removal Techniques For Bergen-Paterson Series 78000 Hydraulic Shock Suppressors. F. BFN-VTM-P029-0010, Vendor Technical Manual for Pacific Scientific Instruction Manual for Repair, Overhaul, Installation Maintenance of Mechanical Shock Arrestors. G. BFN-VTD-P029-0050, Pacific Scientific Instruction Manual Installation and Maintenance Mechanical Shock Arrestors Models PSA-1/4, PSA-1/2, PSA-1, PSA-3, PSA-10, PSA-35, PSA-100 H. BFN-VMM-P029-0250, Vendor Miscellaneous Manual For Pacific Scientific Mechanical Shock Arrestors.

1. BFN-VTM-G257-0010, Vendor Technical Manual For Grinnell Corp. Hydraulic Snubbers J. BFN-VTM-L329-0010, Vendor Technical Manual For Lisega Reactor Torus Ring Hydraulic Snubbers K. BFN-VTD-L329-0070, Installation and Maintenance Instructions For Lisega Hydraulic Snubbers L. Relief Request 3-ISI-2 (TAC NO. M97805), dated May 3, 1999 NRC Letter, "Browns Ferry Nuclear Plant, Unit 3 - Relief From ASME Boiler and Pressure Vessel Code, Section Xl Requirements M. Technical Requirements Manual (TRM) Technical Requirement TR 3.7.4, "Snubbers"

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 9 of 166 2.1 Source References (continued) N. Relief Request 2-11-13 (TAC NO. MB6596), dated January 7, 2003 NRC Letter, "Browns Ferry Nuclear Plant, Unit 2 - Relief From ASME Boiler and Pressure Vessel Code, Section XI Requirements

0. Relief Request 1-ISI-18 (TAC NO. MC1 170), dated April 30, 2004 NRC Letter, "Browns Ferry Nuclear Plant, Unit 1 - Relief From ASME Boiler and Pressure Vessel Code, Section Xl Requirements 2.2 Developmental References A. General Engineering Specification G-43, "Installation, Modification, and Maintenance of Pipe Supports and Pipe Rupture Mitigative Devices" B. 0-TI-363, ASME Section Xl Repair and Replacements C. 1-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers D. 2-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers E. 3-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers F. 0-SI-4.6.H-2A, Functional Testing of Mechanical Snubbers G. Canceled and Superseded by 0-Sl-4.6.H-2A.

H. Canceled and Superseded by 0-SI-4.6.H-2A. I. 0-SI-4.6.H-2B, Functional Testing of Bergen-Paterson, Anchor Darling, Fronek Hydraulic Snubbers J. Canceled and Superseded by 0-SI-4.6.H-2B. K. Canceled and Superseded by 0-SI-4.6.H-2B. L. 0-SI-4.6.H-2C, Functional Testing of Bergen-Paterson Torus Dynamic Restraints M. Canceled and Superseded by 0-SI-4.6.H-2C. N. Canceled and Superseded by 0-SI-4.6.H-2C.

0. 0-SI-4.6.H-2D, Functional Testing of Grinnell Hydraulic Snubbers P. Canceled and Superseded by 0-SI-4.6.H-2D.

Q. 0-SI-4.6.H-2E, Functional Testing of Large Bore Lisega Torus Dynamic Restraint Snubbers

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 10 of 166 2.2 Developmental References (continued) R. Canceled and Superseded by O-SI-4.6.H-2E. S. MPI-0-000-SNBOO1, Hydraulic Shock and Sway Arrestor Grinnell Unit Disassembly and Reassembly T. MPI-0-000-SNBOO2, Hydraulic Shock and Sway Arrestor Bergen-Paterson, Anchor Darling, Fronek Unit Disassembly and Reassembly U. MPI-0-000-SNBOO4, Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Snubbers V. NUREG/CR-5870, Results of LWR Snubber Aging Research, Published May 1992 W. SPP-3.1, Corrective Action Program X. SPP-8.1, Conduct of Testing Y. SPP-9.1, ASME Section XI Z. Snubber Technical and ISI Review Course, by Lake Engineering Company, Warwick, Rhode Island AA. MPI-0-000-SNBOO5, Visual Examination of BOP Hydraulic and Mechanical Snubbers BB. Engineering Program Guide - Snubbers, Good Practice EPG-07, Institute of Nuclear Power Operations, July 2006

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 11 of 166 3.0 DEFINITIONS A. Activation (Lockup) - The change of condition from passive to active, in which the snubber restrains the rapid displacement of the supported system/component. B. API/BARKER Test Bench - An automated mechanical test device designed to perform functional testing of snubbers. The current name of the test bench vendor is Barker/Diacon. C. As-Found Test - As-found test means the snubber must be tested without performing any kind of maintenance on the snubber. Also any cleaning of the snubber exterior surface is precluded. Stroking of the snubber prior to testing should be avoided, however, test sequence (i.e. activation is to be done first or drag force test is to be done first) is insignificant. D. Bench Testing - Functional testing of snubbers utilizing the STB-200 or similar equipment. E. Bleed Rate (Release) - The rate of snubber axial movement under a specified load after activation of the snubber takes place. F. Breakaway Force - The minimum applied force to initiate extension or retraction of the snubber. G. Drag Force - The force required to maintain snubber movement at a low velocity or acceleration before activation. H. Fasteners - Securing devices such as lock wire, locking tabs, jam nuts, attachment welds, cotter pins, etc. which can be detected by visual observation. I. Freedom-of-Motion, or Push-Pull Method - Manual stroking of snubber through its full range of motion. This is commonly used to check suspected snubbers for damage due to transients. J. Functional Testing - Measurement or checks of parameters that verify operational readiness. K. Hydraulic Snubber - Snubbers in which load is transmitted through a hydraulic fluid. Hydraulic snubbers are equipped with control valves which defeat the restraining action of the snubber, allowing it to move relatively freely until a specific velocity called activation or lock-up velocity is reached. At this velocity the control valve closes and the snubber starts to restrain the velocity of the attached component. L. Maintenance - Action taken to prevent and correct deficiencies in the function of a snubber.

3.0 DEFINITIONS (continued) M. Mechanical Snubber - Snubber in which load is transmitted entirely through mechanical components. Mechanical snubbers are designed to restrain pipe or equipment to a specific limited acceleration or rate of velocity change during an event. For normal thermal motion the snubber will move freely in either direction through its operating stroke. N. Operable - The ability of a snubber to perform its intended design function.

0. Snubber - Dynamic restraints which are utilized to allow slow, constant movement of a supported system/component while providing rigid restraint against rapid motion due to dynamic loads (i.e., earthquakes, transients, etc.).

P. Spacers - Devices located on each side of the spherical bearing used to position the snubber clevis attachment in the center of the end attachment. These are also known as washers. Q. Spherical Bearing - Load bearing which allows the snubber to rotate in the end attachments. R. Stroke - Full length of the total possible snubber movement. S. Technical Requirements Manual Snubber - Snubbers that are required for safe shutdown, required to protect code boundaries and to ensure system/component structural integrity under dynamic loads. These are known as Essential, Safety-related or Quality-related. T. Thermal Movement - The amount the system/component is analytically predicted to move from its Cold position to its Hot (Operating) position during normal or emergency system operation. Thermal movement can be either in tension or compression and this movement is identified on the support design drawings. U. Unstaked, Internal - Rotation occurs between the support cylinder and the position tube indicator, for Mechanical snubbers. V. Unstaked, spherical Bearing - Spherical bearing, used for snubber alignment, is found displaced from the paddle plate. W. Visual Examination - The performance of visual observations for detection of improper installation and impaired functional ability caused by physical damage, leakage, corrosion, or degradation from environmental or operating conditions. X. Work Implementing Document (WID) - Workplan, Maintenance Instruction, Work Order, or other similar document which consists of written directions for performance of work.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 13 of 166 4.0 GENERAL PRECAUTIONS None 5.0 PREREQUISITES None 6.0 EQUIPMENT None

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 14 of 166 7.0 PROCEDURE 7.1 General Snubbers are dynamic restraints that are utilized to allow slow, constant movement of a supported system/component while providing rigid restraint against rapid movement due to dynamic loads. Snubbers are installed on piping and/or equipment primarily to limit the displacement of the piping or equipment during a seismic event or during a severe transient. They are sometimes installed to limit damage from pipe break, vibration, and water hammer. Snubbers accomplish this by absorbing the energy from the supported system/component motion and transmitting it to the building structure. Snubbers can directly affect plant safety, therefore, periodic inspection, testing, and appropriate maintenance is required to ensure their operability. Inoperable snubbers may severely damage piping or equipment either by NOT restraining them during a seismic event or transient, or by NOT allowing thermal expansion during normal plant operation. Technical Requirements Manual (TRM) Technical Requirement (TR) 3.7.4, "Snubbers", requires all safety-related snubbers to be operable during all modes of operation. However, if a component or system affected by the snubber(s) is NOT required to be OPERABLE, then the snubber is NOT required to be OPERABLE, except as follows: The snubber(s) located inside the drywell, on the reactor vessel attached piping systems shall be considered OPERABLE whenever fuel is in the reactor vessel. The snubber(s) on Main Steam, HPCI and RCIC piping, in the drywell, are exempt from this requirement when the steam line plugs are installed inside the reactor vessel. During the times snubber(s) are NOT required to be OPERABLE for an inoperable system, the inoperable snubber(s) will be tracked to prevent declaring the system OPERABLE with unanalyzed inoperable snubber(s). At the present time there are four manufacturers and five types of snubbers at Browns Ferry. These are Bergen-Paterson (also known as Anchor/Darling or Fronek) and Grinnell Hydraulic (piping and equipment), Bergen-Paterson and Lisega (Torus Dynamic Restraints) and Pacific Scientific Company Mechanical Snubbers. The types and pertinent information about each will be given in Appendix B, C, D, E and F of this procedure. 7.2 Program Ownership The snubber program is maintained by the Site Engineering, Civil Engineering Group. The primary owner of the program is the Site Snubber Program Engineer (SSPE). The SSPE should have a broad knowledge of plant systems and shall be cognizant of snubber inspections and testing requirements.

7.3 Duties and Responsibilities A. The SSPE responsibilities are as follows:

1. Ensures overall snubber operability and compliance with TR 3.7.4 requirements and other snubber related regulatory requirements.

2. Maintains the technical adequacy and accuracy of snubber program procedures.

3. Performs revisions and develops new procedures for snubbers, as required.

4. Implementation of program procedures.

5. Initiates all Work Orders for snubber work to be performed prior to and during the outage (i.e., removal and reinstallation, rebuild and functional testing).

6. Provides information to Planning for completion of ASME Section XI Repair and Replacement paperwork, Section XI NIS-2 form and Work Order, as required.

7. Ensures that proper maintenance is scheduled and performed on snubbers.

8. Ensures adequate inventories of required snubbers and spare parts.

9. Issues purchase request for snubber spare parts and personnel services, as required.

10. Updates the snubber tracking program with required information, as required.

11. Reviews and evaluates all snubber test data to ensure it meets all acceptance criteria.

12. Performs failure analyses and other evaluations of failed and degraded snubbers.

13. For Unit 1, 2, and 3 has primary responsibility for the implementation of the ASME Section XI inspection program for snubbers.

14. Maintains the Snubber Program Notebook

15. Maintains the Snubber Program Health Report

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 16 of 166 7.3 Duties and Responsibilities (continued)

16. Other duties include: reviews applicable Industry and TVAN operating experience (OE); reviews applicable TVAN PER; forwards BFN specific issues and concerns to TVAN Snubber Peer team to engage dialogue for issue resolution; participates in SNUG and other industry related forums; determines the need for continuing training; and performs periodic industry benchmarking.

7.4 Interfaces 7.4.1 Operations A. Ensures compliance with Technical Specification and Requirements Manuals by determining when removal of snubbers for testing or maintenance is allowed based on plant conditions. B. Tracks all Limiting Conditions Of Operation (LCOs) for snubbers. C. Approves and tracks Work Orders for snubbers being worked. 7.4.2 Mechanical Maintenance A. Supports surveillance activities by performing the removal, rebuild, installation and transport of all hydraulic snubbers. B. Performing the removal, installation and transport of some mechanical snubbers. C. Performs maintenance and repairs of failed or degraded snubbers. D. Performs all visual examinations, as required. E. Provides necessary information to the SSPE to ensure proper updating of snubber program procedures 7.4.3 Site Engineering - Design A. Provides clear and concise design requirements for both TVA and vendor installed equipment to ensure that all regulatory and Browns Ferry site specific requirements are met relative to snubbers. B. Defines and evaluates test acceptance criteria which is NOT met. C. Performs Supported System/Component Analyses for inoperable snubbers. D. Reviews and updates the snubber unique identifier list (Master Equipment List) in EMPAC.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 17 of 166 7.4.4 Modifications A. Deletes, installs, and/or modifies snubber supports in accordance with design output documents. B. Provides necessary information to the SSPE to ensure proper updating of snubber program procedures. 7.4.5 Materials and Procurement A. Procures and stores snubbers, snubber parts, support parts and hardware, in accordance with procurement documents. B. Maintains an adequate inventory of new spare parts, as specified by the SSPE, to ensure availability of parts for maintenance. 7.4.6 Component Engineering A. For Unit 1, 2, and 3 has primary responsibility for the implementation of the ASME Section Xl inspection program for snubbers. B. Has responsibility for the implementation of the ASME Section Xl Repair and Replacement Program. 7.4.7 Planning and Scheduling A. Coordinates with the SSPE for snubber surveillance activities to be performed for operating cycle. Snubbers installed on systems that are inside the drywell are to be scheduled for testing or maintenance during those system outages, if possible, so that system operability will NOT be affected. Scheduling of the Torus Restraint Snubbers for testing and maintenance must be performed during the refuel outage and coordinated with the SSPE to ensure the proper contracts are in place. B. Prepares and obtains approvals on ASME Section Xl Repair and Replacement paperwork, Section XI NIS-2 forms and Work Orders.

7.5 Regulatory Requirements A. The Units 1, 2, and 3 Technical Requirement Manual (TRM) 3.7.4 contains the snubber surveillance requirements and Limiting Conditions for Operation (LCO). Every requirement in the TRM should be reviewed carefully and should be specifically incorporated in the plant surveillance instructions. B. Adverse condition reporting requirements shall be in accordance with SPP-3.1, "Corrective Action Program". C. Those safety-related snubbers on the portions of systems covered by Section Xl are subject to the requirements of SPP-9.1, ASME Section XI. D. The ASME Section Xl Repair and Replacement process shall be performed in accordance with 0-TI-363, ASME Section Xl Repairs and Replacements. E. The ASME Section Xl requirements have been modified by the approval of Request for Relief 3-ISI-2, shown in Appendix A of this procedure. F. The ASME Section Xl requirements have been modified by the approval of Request for Relief 2-11-13, shown in Appendix J of this procedure. G. The ASME Section XI requirements have been modified by the approval of Request for Relief 1-ISI-18, shown in Appendix K of this procedure. 7.6 Snubber UNIDs, Lists, and Drawings 7.6.1 Unique Identifiers (UNIDs) Each snubber is represented on a pipe support drawing. The Unique Identifier Number (UNID) is a unique number with the Plant - Unit - Function Code - Unique No. The function code should be SNUB and the Unique No. should begin with 5001 for each system. The Torus Restraint Snubber Unique No. begins with 0001. The UNIDs should be accurately recorded on the WOs to properly identify and retrieve information for work performed on the snubbers. Site Engineering, Civil Design is responsible for maintaining the UNID list.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 19 of 166 7.6.2 Snubber Lists A. An accurate list of all safety-related/quality related snubbers is required to ensure implementation of Technical Requirement 3.7.4. The Unit 1 safety-related snubber list is provided in Surveillance Instruction 1-S1-4.6.H-1, the Unit 2 safety-related snubber list is provided in 2-SI-4.6.H-1, and the Unit 3 safety-related snubber list is provided in 3-SI-4.6.H-1. The list contains snubber number, system No., type, size, and location, as a minimum. The listing will include the drawing number and the Inservice Inspection (ISI) isometric drawing number. Non-safety related snubbers are listed in MPI-0-000-SNBOO5. B. The SSPE shall update the snubber listing in 1-SI-4.6.H-1, 2-SI-4.6.H-1, and 3-SI-4.6.H-1 when the design change process adds, deletes, or changes the type of existing snubber. Update of the snubber listing shall be made after implementation of the modification. If maintenance work is performed which changes any information in the procedures, the updates should be completed as soon as practical after the change has been completed. 7.7 Outage Planning and Preparation Outage planning and preparation should begin, as a minimum, approximately six months prior to the scheduled refueling outage (RFO). This is needed to obtain any required contract services and to review spare snubbers and spare parts inventories. 7.7.1 Previous SI Performance The previous SI data sheets performance information from the snubber database should be reviewed to determine any specific issues that should be addressed for the next scheduled Visual Surveillance or testing interval, i.e., pre-outage and outage. Some examples are: A. Previous functional failures due to location B. Snubbers requiring service life monitoring C. Recurring visual deficiencies and test failures D. Whether the visual exams are required during this operating cycle

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 20 of 166 7.7.2 Hydraulic Snubber Seal Service Life A. Review the snubber database and determine which hydraulic snubbers seal service life will expire prior to the next scheduled RFO. These should be scheduled for rebuild or identified for a seal life extension study. B. Ensure an adequate supply of parts, necessary to rebuild snubbers, including seals and load-bearing/pressure-retaining parts (i.e., cylinder, piston, piston rod, tie rods, control valves, etc.) are available. Also review spare snubber availability. C. Initiate work orders to rebuild the required selected snubbers. 7.7.3 Functional Test Sample A. Select a functional test sample of 10 % of each subgroup in accordance with the plant SI, preferably with the aid of the snubber database.

1. Consider the snubbers to be rebuilt to select the initial and possible second sample.

2. Identify candidates for possible additional samples for each subgroup.

B. Review the snubber database, visual inspection procedures and past performances to determine scaffolding and other restraints. 7.7.4 Functional Testing of Large Bore Hydraulic Snubbers A. Since TVA does NOT own the necessary test equipment, initiate purchase request for onsite testing of the Bergen-Paterson Torus Dynamic Restraint snubbers. The vendor should have the capability of in-place testing. B. Establish schedule for bringing vendors on and off site to minimize impact to other support activities. Consider scheduling contractor training at the least cost location and before the outage begins, if required. C. The Lisega Type 31 21 50 Torus Restraint Snubbers maybe tested on TVA's API/Barker STB-200 test bench using the Surrogate snubber furnished by Lisega. To satisfy the Technical Requirements Manual only the poppet valves from the Lisega Type 31 21 50 restraint are installed in the Surrogate snubber and tested. The Surrogate snubber test results are then converted to the Lisega Type 31 21 50 restraint values using conversion factors in O-SI-4.6.H-2E, Attachment 2, Page 1 of 5.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 21 of 166 7.8 Receipt Inspection and Storage of Snubbers 7.8.1 Receipt Inspection NOTE The SSPE should be notified if the receipt inspection reveals any damage or dimensional discrepancy. Snubber receipt inspection must be performed in accordance with the contract document and site Nuclear Stores procedure, SPP-4.2, Material Receipt and Inspection. Proper receipt inspection and storage of mechanical and hydraulic snubbers have a significant impact on the performance of the snubber after installation. Personnel involved in receipt inspection of snubbers are required to ensure proper care for handling and storage techniques in accordance with site procedures. 7.8.2 Storage of Snubbers After Initial Receipt Inspection and Prior To Installation (Nuclear Stores) A. The snubber storage should be in buildings designated for storage. B. Storage and Handling shall be performed as required in site Nuclear Stores procedure SPP-4.3, Material Storage and Handling. In part, this prescribes, "Items shall be protected from exposure to salt, spray, rain, dust, dirt, and other airborne and windblown contaminants." C. When practicable, snubbers should be stored in their shipping container, if the container provides protection to the snubber. Packages should be labeled for easy identification of the snubber. D. The snubbers, after removal from nuclear stores, should be protected from rain and the possibility of moisture or other liquids entering the snubber. They should also be protected from sand blasting or other activities that might result in foreign particles entering the snubber. E. Hydraulic snubber repair kits containing elastomeric parts should be treated as finite shelf-life components in accordance with applicable shelf-life programs.

7.8.3 Storage of Snubbers After Removal From Nuclear Stores or the Plant A. The snubber test/rebuild facility has been designated as a "B" Level Storage area. B. The requirements for a "B" Level Storage area are as follows:

1. Should be a fire resistant, tear resistant, weather tight, and well ventilated building or equivalent enclosure.

2. The area shall be situated and constructed so that it will NOT be subject to flooding.

3. Items shall be stored to permit air circulation.

4. The area shall be provided with temperature and humidity control or equivalent to prevent condensation and corrosion..

5. The minimum temperature shall be 40 degrees F and the maximum shall be 140 degrees F.

6. The storage area shallI be clearly identified as to its storage level.

7. Verification of the storage conditions shall be provided by calibrated recorders and shall be documented.

8. Limit and control access to the storage area.

9. Lock storage area when NOT attended by an authorized person.

10. Inspect and document on a semi-annual basis that storage area and stored items are maintained.

11. The inspection shall be performed by an ANSI N45.2.6, Level 11inspector, and documenting it on the inspection report form, Appendix E of SPP-4.3.

A sign designating the facility, as a "B"Level Storage Area, has been placed on the door. Access is controlled by a key lock. Only a limited number of keys are available for access to the facility. Only "Authorized Personnel" will be allowed entry into the facility without an escort. A list of "Authorized Personnel" will be issued and updated by the SSPE and the Mechanical Maintenance Manager. A copy of the list will be placed in the Duty Mechanical Maintenance Manager's log, placed on the door of the facility and other logs, as decided by management.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 23 of 166 7.9 ALARA Planning The SSPE must coordinate with RADCON to develop an ALARA preplanning package for the total scope of the snubber surveillance to be performed for the operating cycle. ALARA briefings should be held between RADCON and the test performers to explain high-rad areas, contamination, dress-out, stay times, and minimizing radwaste requirements. 7.10 In-Service Inspection (ISI) (ASME Section Xl Requirements) To fulfill Code of Record certification, in accordance with repair/replacement requirements of Section Xl, ensure that information is readily available (i.e., original purchase specification, for new snubbers received from Nuclear Stores, and previous location, UNID and removal work document (if possible) of used snubbers being stored as spares in the snubber test/rebuild facility, for each snubber mark number within the Section Xl boundary) to facilitate timely completion of work order documentation. The ASME Section XI Inservice Inspection of snubbers, for Unit 1, shall meet the requirements of this program as documented on the snubber request for relief in Appendix K. This request for relief is approved as referenced in Section 2.10. The ASME Section XI Inservice Inspection of snubbers, for Unit 2, shall meet the requirements of this program as documented on the snubber request for relief in Appendix J. This request for relief is approved as referenced in Section 2.1 N. The ASME Section XI Inservice Inspection of snubbers, for Unit 3, shall meet the requirements of this program as documented on the snubber request for relief in Appendix A. This request for relief is approved as referenced in Section 2.1 L.

7.11 Spare Snubbers A. Special emphasis should be placed on having in stock approximately 10 percent of the unit population of PSA 1/4 and PSA 1/2 mechanical snubber spares. B. Based on improved reliability of the larger models of PSA mechanical snubbers, a stock of from 3 to 5 percent, of those sizes as spares, should be sufficient. C. Hydraulic snubbers should be available as spares for snubbers which must be functionally tested under a Technical Requirement Limiting Condition for Operation (LCO). D. Hydraulic snubber metallic and non-metallic parts must be verified for availability for those hydraulic snubbers scheduled to be refurbished for the RFO. E. Spare snubbers for the Torus Dynamic Restraints are manufactured by Lisega and are approved as replacements for the Bergen-Paterson snubbers when removed. This replacement was approved under Design Change Notice V39267A. 7.12 Functional Test Equipment A. Ensure the API/Barker snubber test benches calibration due dates will remain valid for the duration of the RFO. B. If snubber end attachments are removed, from the snubber, for functional testing and a torque wrench is used to reinstall them, the torque wrench shall be post-use calibration checked after each torque performance to reduce the risk of having to retorque the end attachments, especially in the drywell, if the torque wrench is found out of calibration after extended use.

7.13 SI Performance Team and Facilities A. Prior to the RFO, manpower requirements must be determined to include the following:

1. Test director

2. Assistant/backup test director (outage snubber coordinator)

3. Functional test performance personnel (teams include technician or engineer and craft personnel)

4. Visual examination personnel (may be performed by craft personnel with review of possible anomalies by technician or engineer)

5. Hydraulic snubber test performance personnel (machine operator and craft personnel with engineering oversight)

6. Hydraulic snubber rebuild personnel (performed by craft/contract personnel with engineering oversight)

7. Computer data base entry personnel (engineer or technician)

B. Facilities should be made available to include the following:

1. Office space sufficient to coordinate snubber program team meetings with area to spread flow drawings, etc.

2. Test and rebuild facility with enough room for desk, file cabinet, two test benches, control center, 2 rebuild tables, tool boxes (with an assortment of hand tools and wrenches) and other required equipment, monorail(s) or other appropriate equipment to move snubbers around the facility and a fluid storage area with fire proof cabinet.

3. Personal computer with snubber tracking data base.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 26 of 166 7.14 Training and Qualification of Performers 7.14.1 General A. Thorough briefings should be conducted on SI performance of visual inspections and functional testing. B. Cognizant personnel must be qualified as test director in accordance with plant administrative procedures. C. Appropriate GET training (including respirator training) should be received by test personnel to perform the SI. D. GET training for contract personnel should be arranged to minimize expense and expedite getting on and off site. E. The designated backup to the SSPE shall be trained to the requirements of the SSPE. The backup to the lead Maintenance staff shall be trained to the requirements of the lead Maintenance staff. The SSPE will meet the qualifications card requirements for a snubber engineer and the Maintenance staff will have the necessary task specific qualifications. F. Specific training requirements will be described under each section. The training is performed to meet INPO, general regulatory requirements, and good business practices. 7.14.2 Visual Examinations A. The training for the visual exams should include orientation to the requirements of the Surveillance Instructions. Training aids should include actual snubbers and examples of discrepancies that should be noted on the data sheets for further review. B. Personnel performing the visual inspections of 1-SI-4.6.H-1, 2-SI-4.6.H-1 and 3-SI-4.6.H-1 must meet the visual acuity requirements of ASME Section Xl, Code, 2001 Edition, 2003 Addenda, Paragraph IWA-2321. 7.14.3 Functional Tests of Hydraulic Snubbers The operation of the test machines or test benches requires extensive training on the operation of the specific piece of equipment and thorough knowledge of the snubber design and test parameters. The best results should be obtained using engineers or technicians who may be assigned to the program on a continuing basis. Since this training should be performed by the test bench manufacturer or another qualified person, the training costs will be high, inefficient performance during outages, and invalid rejects may result when different personnel are used.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 27 of 166 7.14.4 Rebuilding Hydraulic Snubbers The rebuilding of hydraulic snubbers is typically assigned to personnel who are familiar with the requirements through experience. Additional basic training is required for personnel who have NOT previously rebuilt hydraulic cylinders and control valves. The training should include classroom instruction, practical demonstration and practice in the actual rebuilding of snubbers. Most of the training at Browns Ferry has been performed as On-the-Job Training (OJT) by personnel who are experienced and knowledgeable with the rebuilding of snubbers. 7.14.5 Functional Tests of PSA Mechanical Snubbers The training for drag force testing of PSA snubbers should include orientation on the operation of the snubber and the drag force effect on the piping. Actual snubbers and the STB-200 Test Bench should be demonstrated and used by the students to learn the proper technique of functional testing the snubber through its stroke. The entire requirement for stroking and as-left testing should be included. The method for determining activation should be discussed, demonstrated, and practiced by the students. 7.14.6 Rebuilding PSA Mechanical Snubbers The PSA mechanical snubber is a complex mechanism and the manufacturer recommends they provide the training. The manufacturer will issue a rebuild training certificate, which is required to be renewed every two years. Some vendors have been authorized by the Original Equipment Manufacturer (OEM) to provide the training and some of those in TVA who have taken the training may be qualified to teach others. The rebuilding requires careful attention to many details and precision measurement in some cases. The training should include classroom instruction, practical demonstration, and practice in actual rebuilding. Special tooling is required and post maintenance tests shall be included to verify the rebuilding has been performed correctly. Browns Ferry does NOT rebuild mechanical snubbers, at this time, due to the extensive training and cost of purchasing and storing spare parts.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 28 of 166 7.15 Visual Examination Program The following applies to the regulatory requirements of safety-related and quality-related snubbers only. Other aspects of the program are contained in the section on "Balance of Plant Hydraulic and Mechanical Snubbers." 7.15.1 Scope and Frequency A. This program covers safety-related and quality-related snubbers, of which ASME Section XI snubbers are a subset. The visual examination shall verify that:

1. There are no visible indications of damage or impaired operability.

2. Attachments to the foundation or supporting structure are functional.

3. Fasteners for attachment of the snubber to the component and to the snubber anchorage are functional.

B. Safety-related snubbers require visual examinations on an interval determined by the number of unacceptable snubbers found, during the visual examination process, using Table 3.7.4-1 in the Technical Requirements Manual TR 3.7.4. The basis of this frequency is provided in NRC Generic Letter 90-09. Removal of insulation is NOT required. Each time the performance is required the total population of the snubbers in the accessible or inaccessible category are required to be examined. The change in the frequency table described in the TRM requires that all the snubbers be examined either as separate categories or combined into one population. The table is more favorable if the snubbers are considered one population, and that usually is the choice that should be made and documented before the examinations begin. C. At Browns Ferry the decision has been made to count all snubbers as one group and this decision is documented in the unit specific SI. Based on past examinations, the results should permit skipping alternate outages and permit an interval between examinations up to 48 months. 7.15.2 Visual Inspection Package A. This package is the SI procedure and should be performed by locations, with ALARA considerations in mind, to minimize time spent or re-traveling through high radiation areas. B. In the process of performing visual examinations, special attention should be given to potential problems of snubbers which must be functionally tested, i.e., scaffolding/ladder required, total removal required, high radiation levels, etc.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 29 of 166 7.15.3 Examination Items The examination items are specified in the TRM. Additional detail shall be provided in the Surveillance Instructions. A check list of the items to be observed are clearly specified and data sheets have been developed to document examination results. These data sheets are located in Attachment 2 in 2-SI-4.6.H-1 and 3-SI-4.6.H-1 and Attachments 2, 3, and 4 in 1-SI-4.6.H-1. The Surveillance Instruction requires the completion of the appropriate Attachments for each snubber visually examined. 7.15.4 Resolution of Anomalies Many discrepancies can be found during the exams, but few actually result in inoperability of the snubber. All of the anomalies should be reviewed and dispositioned by an individual very knowledgeable in the operability requirements of the snubbers. A case of low fluid level may be resolved by functional test to verify the snubber will activate, followed by resolution of the leak. If a reservoir is found completely empty, the snubber shall be declared inoperable until a functional test has been performed, the results found acceptable and the leak has been resolved. Mechanical snubbers that are suspected of being bound up may be stroke tested to verify they are NOT bound up. Most other anomalies will require minor maintenance, if any action at all. All anomalies shall be handled in accordance with SPP-3.1, Corrective Action Program.

7.16 Decontamination 7.16.1 General Considerations A. Since the Snubber Rebuild and Test Facility is located in the Turbine Building, any snubber transported to the facility must satisfy RADCON requirements. B. Therefore, sometimes decontamination of snubbers may be necessary. A major consideration in decontaminating snubbers is avoiding changing the as-found condition (i.e., stroke setting) of the snubbers selected for as-found testing. Therefore, the ability to test the snubbers with a minimum amount of decontamination is desirable, but the inconvenience of testing and rebuilding contaminated snubbers can add significantly to the cost and time required for testing to be completed. 7.16.2 Decontamination of Mechanical Snubbers A. Mechanical snubbers are NOT water-tight. Where possible, these snubbers should be decontaminated by wiping with a dry cloth or using a foam cleaner rather than immersion into a cleaning fluid. Fluid that has entered the snubber may become trapped and eventually cause corrosion. Unless the snubber has been subjected to intrusion of contaminated fluid, the inside of the snubber should be free of contamination. 7.16.3 Decontamination of Hydraulic Snubbers A. Hydraulic snubbers are more resilient than mechanical snubbers. The only time a hydraulic snubber may have problems during decontamination is if high pressure water is used to remove the contamination. If this occurs care should be taken NOT to spray directly at the front rod wiper. The water pressure could force water past the rod wiper and the piston rod packing, since these seals are made to pressurize from the inside of the snubber. Water which has been forced into the snubber could affect the functional test results. B. Decontamination of hydraulic snubbers should be carefully controlled, especially for those that have a suspected low fluid level and supplied by a gravity feed reservoir. Ifthe fluid used to decontaminate the snubber seeps into the reservoir, or the reservoir is disassembled, the as-found fluid level is changed before the test is performed. For any snubber that is NOT scheduled for rebuild, the effects of the decontamination process should be thoroughly evaluated to determine whether the snubber should be disassembled to remove any fluid that might have entered. There should never be a need to disassemble a reservoir for decontamination. The vent hole in the reservoir of a gravity fed snubber is so small it should NOT allow contamination to enter, since it is always at the high point. Contamination usually falls instead of rising as it would have to do to infiltrate the reservoir.

7.17 Functional Test Program Guidelines Any newly added, replacement, or refurbished snubber should be tested in accordance with the applicable functional testing Surveillance Instruction prior to installation. Once the functional test has been performed it remains acceptable for 1 year after completion, unless something happens or there is a concern about the snubber. Functional tests are performed each operating cycle to meet Technical Requirements Manual TRM 3.7.4.2 verifying, by sampling 10% of each subgroup of snubber, that the safety-related or quality-related snubbers are operable. For each failure to meet the functional test acceptance criteria an additional 10% of the remaining snubbers in the subgroup shall be tested, until no additional failures occur. In addition to the required sampling, snubbers under service life monitoring and balance-of-plant programs should be addressed. Specific Technical Requirements are given in the appropriate functional testing SI. When the required 100 percent visual exam is also to be performed for the operating cycle, it should be performed before the functional tests are performed. When the 100 percent visual exam is NOT required, a visual check of the snubber for indication of service-related degradation or damage of the snubber installation should be made before the snubber is disconnected or removed. This is a good preventative maintenance practice and NOT a SI visual examination requirement. 7.17.1 Functional Test Packages A. Test packages should be prepared for each individual snubber to be tested and should include the following:

1. Marked-up flow diagram to illustrate the snubber location in the system for Shift Manager/Unit Supervisor's review and approval.

2. Shift Manager/Unit Supervisor's authorization for snubber removal.

3. Configuration Control Drawing (CCD) or Design Change Authorization (DCA), approved for use by Site Engineering (Civil), depicting the current physical configuration.

4. Inservice Inspection (ISI) location drawing, if appropriate.

5. Notes of any special considerations such as scaffold or ladder requirements.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 32 of 166 7.17.1 Functional Test Packages (continued)

6. SI procedure, including data sheets.

7. Removal and Reinstallation procedure, including data sheets.

8. Calibration sheets for all M&TE used for this Work Implementing Document.

7.17.2 Functional Testing of PSA Mechanical Snubbers A. BFN Technical Requirements require drag force measurements and activation verifications. B. Mechanical snubber functional testing is performed to verify two characteristics, activation and drag force. The limit for acceleration is not to exceed 0.02 g's. Pacific Scientific Company (PSC) performed qualification tests on new snubbers and performed tests on snubbers that have been in extended plant service to verify the activation levels at various loads. PSC concluded that there is no significant change in activation value at any level of rated load of the snubber. C. Performing a test for activation of PSA snubbers requires a specialized test machine. BFN has a computer controlled API/Barker STB-200 snubber test. bench. The test bench is capable of testing any size PSA snubber and most medium and small bore hydraulic snubbers. The software performs four basic functions:

1. Operator interface

2. Machine control

3. Data acquisition and conversion

4. Data analysis and presentation Test results are presented in the form of a graph with maximum and average test values. The printout is easy to read and understand.

D. Visual Examination (VE) Perform the VE according to the SI if the VE SI is scheduled for the current operating cycle. Otherwise, perform the visual check to determine overall integrity of the snubber.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 33 of 166 7.17.2 Functional Testing of PSA Mechanical Snubbers (continued) E. Activation Test Activation test is performed using the test bench. Testing is performed in both directions (tension and compression). The acceptance criteria are equal to or less than 0.02 g's. F. As-Found and As-Left Drag Force Test Drag force is the minimum force required to initiate or maintain motion of the snubber. The drag force of any snubber should NOT over-stress the supported system/component. The snubber manufacturers recommended drag force value is 5% of the rated load for an NF mechanical snubber, except for the PSA-1/4. This test is performed to verify the drag force of the snubber will NOT exceed 5% of the snubber rated load. An exception to this 5% of the rated load requirement is made when considering PSA 1/4 snubbers. In accordance with information from PSC, the PSA 1/4 snubber (Design Rated Load (DRL) - 350 lbs.) is evaluated to the same requirements as the PSA 1/2 (DRL - 650 lbs.) from a design load consideration. As determined by PSC, drag forces greater than 5% (except the PSA-1/4) is indicative of impending snubber failure. If the drag force of the snubber is acceptable during the As-Found testing it may be used for the As-Left test results. For As-Found drag forces that exceed 3% but are less than 5%, the snubber shall be stroked several times in an attempt to redistribute the grease and reduce the drag. The snubber shall then be retested for drag. If the drag force does NOT reduce to 3% or below, the snubber shall be replaced.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 34 of 166 7.17.3 Functional Testing of Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers The large size and difficult-to-remove snubbers, such as the Torus Dynamic Restraint snubbers, may be tested more economically in place, using machines designed for that purpose. The functional tests can be performed to determine lockup velocities, bleed rates, and seal integrity with the removal of only one pin. This functional testing will be performed by a contractor as BFN does NOT have a test machine with these capabilities. As with other snubbers this functional testing is performed in both the Extension (Tension) and Retraction (Compression) directions for lockup and bleed. Seal integrity is performed against the blind end and the rod end. The smaller hydraulic snubbers are removed from the installed location, decontaminated, if necessary, and taken to the test bench for testing. As with other snubbers this functional testing is performed in both the Extension (Tension) and Retraction (Compression) directions for lockup and bleed. The computer controlled API/Barker STB-200 snubber test benches are capable of testing all Bergen-Paterson, Anchor/Darling, Fronek or Grinnell hydraulic snubbers. The benches are easy to operate and the software is user friendly. The test results, i.e. lockup (activation) velocity, bleed (release) rate, and drag force are presented in the form of a graph with maximum and average test values. The printout is easy to read and understand. The graphs are to be placed with the SI functional test package and sent to the Electronic Document Management System (EMDS). A. Visual Examination (VE) Perform the VE according to the SI if the VE SI is scheduled for the current operating cycle. Otherwise, perform the visual check to determine overall integrity of the snubber. B. AS-Found and As-Left Lockup (Activation) and Drag Force Test Lockup (activation) velocity and bleed rate should be in accordance with the acceptance requirements of the applicable functional test Surveillance Instruction. The drag force of any snubber should NOT over-stress the supported system/component. The snubber manufacturers factory or recommended drag force value is 2% of the rated load of an NF hydraulic snubber. That is taken as a screening value and larger values are evaluated on a case by case basis when found. Higher generic screening values might be obtained with piping system reanalysis or evaluation performed by Site Engineering (Civil).

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 35 of 166 7.17.3 Functional Testing of Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers (continued) C. Replacement of Torus Dynamic Restraint Snubbers If a Bergen-Paterson Torus Dynamic Restraint fails to pass its functional test acceptance criteria, the restraint shall be replaced with a new Lisega Torus Dynamic Restraint. 7.18 Rebuilding of Hydraulic Snubbers Rebuilding of hydraulic snubbers shall be performed by task qualified and trained persons. Hydraulic snubbers shall be rebuilt in accordance with the following procedures, MPI-0-000-SNBOO1, Hydraulic Shock and Sway Arrestor Grinnell Unit Disassembly and Reassembly and MPI-0-000-SNBOO2, Hydraulic Shock and Sway Arrestor Bergen-Paterson, Anchor/Darling, Fronek Unit Disassembly and Reassembly, as appropriate. 7.18.1 Hydraulic Rebuild Packages A. Rebuild packages should be prepared for each individual snubber to be rebuilt and should include the following, as a minimum:

1. Removal and Reinstallation procedure, including data sheets.

2. Functional test SI procedure, including data sheets.

3. Appropriate rebuild procedure, including data sheets.

4. Shift Manager/Unit Supervisor's authorization for snubber removal.

5. Description, serial number, UNID, location history and the Work Implementing Document (WID) which removed the snubber, if the snubber was stored in the snubber test/rebuild facility.

6. Copy of the purchase contract, if the snubber was bought out of Nuclear Stores.

7. Completed ASME Section Xl paperwork and NIS-2 forms.

8. Marked-up flow diagram to illustrate the snubber location in the system for Shift Manager/Unit Supervisor's review and approval.

9. Configuration Control Drawing (CCD) or Design Change Authorization (DCA), approved for use by Site Engineering (Civil), depicting the current physical configuration.

7.18.1 Hydraulic Rebuild Packages (continued)

10. Inservice Inspection (ISI) location drawing, if appropriate.

11. Notes of any special considerations such as scaffold or ladder requirements.

12. SI procedure, including data sheets.

13. Removal and Reinstallation procedure, including data sheets.

14. Calibration sheets for all M&TE used for the WID.

15. PIC ticket for the seal kit, any new parts required and hydraulic fluid.

7.19 Evaluation of Degraded and Failed Snubbers 7.19.1 Degraded Snubbers A. General Information By the criteria established, degraded snubbers, are capable of performing their design basis function(s) and therefore have no effect on the system/component ability to perform its design basis function(s). (i.e., there are no Operability issues with degraded snubbers). There are several items which can cause both mechanical and hydraulic snubbers to be in a degraded condition. These are as follows:

1. Cotter pins missing or installed but legs NOT sufficiently bent to prevent the pin from backing out.

2. Pivot pin retaining ring missing.

3. Security locking devices (i.e., locking tabs or wire) on the snubber attachment bolts missing, if required.

4. Spacers missing, leaving excessive gap on one side of the clevis.

When any of these conditions are found a Problem Evaluation Report (PER) should be written and the condition is to be corrected to prevent a more serious condition or cause a failure of the snubber in the future.

7.19.1 Degraded Snubbers (continued) B. Mechanical Snubbers Drag force is the only criteria which has a degraded category. The degraded category, for the drag force, is considered to be between 3% and 5% of the snubbers rated load.

1. If the snubber drag force is less than or equal to 3% of the snubbers rated load, the snubber may be reinstalled in its location without any further evaluation.

2. If the snubber drag force is above 3% but less than or equal to 5% of the snubbers rated load, the snubber shall be evaluated for impending failure.

3. If the snubber as found drag force is found to be above 5% of the snubber rated load, the snubber shall be declared as a functional failure and replaced. Also a Problem Evaluation Report (PER), an engineering failure analysis and a supported system/component analysis shall be completed.

C. Hydraulic Snubbers The following conditions are considered as degradations for hydraulic snubbers:

1. Pits, scratches, or rough areas observed on the piston rod that would NOT contact the piston seals.

2. Fluid reservoir being below the minimum level, based on the temperature, but NOT empty.

3. Minor leaks which have NOT reduced the volume of the reservoir below the minimum required.

4. Minor rust or corrosion on the body of the snubber.

When any of these conditions are found a Problem Evaluation Report (PER) should be written and the condition corrected to prevent a more serious condition or cause a failure of the snubber in the future.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 38 of 166 7.19.2 Failed Snubbers A. General Information

1. Snubber Failure Classifications and Definitions:

a. Location - A failure of a snubber(s) resulting from environmental conditions. Examples include failure of a snubber due to excessive heat, failure due to excessive local system vibration or failure due to other localized anomalies.

b. Manufacturing - A failure resulting from a potential defect in manufacturing. Examples include incorrectly assembled snubbers, inclusion of incorrect piece parts and failure of a snubber(s) due to improper or incorrect maintenance or repair practices performed by the vendor.

c. Design - A failure resulting from an error in the design. This classification would include incorrectly sized snubbers, snubbers provided with insufficient travel, snubbers with insufficient swing margins and design misapplications or errors.

d. Unknown - A failure that cannot be categorized as location, manufacturing, design or other. This includes all failures for which the cause of failure cannot be determined.

e. Other - When the unknown cause of the failure cannot be categorized as location, manufacturing or design. This classification would include snubbers that fail due to end of service life. Additional examples include failure of snubbers due to plant transients, misapplication of rigging loads to the snubber and incidental interaction of tools or equipment on the snubber.

2. A failed snubber is "GENERALLY" considered as NOT being able to perform the design basis function of the snubber. However, for the specific location even a failed snubber may be capable of performing its design basis function.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 39 of 166 7.19.2 Failed Snubbers (continued)

3. If the failure was found as part of the Technical Requirements Manual initial or any subsequent samples the following is the minimum required testing expansion:

a. Expand the sample by 10% of the remaining snubbers in the subgroup, and

b. If the cause of the failure is determined to be a system transient, test all snubbers on that system, which could have been affected by the transient, and

c. If the cause is a generic manufacturing defect, test all snubbers of that same type, and

d. Identify and test all other snubbers suspected of the same failure mode.

4. If the failure was found outside of the Technical Requirements Manual initial or any subsequent samples (i.e., other maintenance activity, testing directed/requested by the Snubber Engineer, Service Life Monitoring testing, testing of snubbers on non-Technical Specification or Technical Requirements Manual systems, etc.) the following is the minimum required testing expansion:

a. If the cause of the failure is determined to be a system transient, test all snubbers on that system, which could have been affected by the transient, and

b. If the cause is a generic manufacturing defect, test all snubbers of that same type, and

c. Identify and test all other snubbers suspected of the same failure mode.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 40 of 166 7.19.2 Failed Snubbers (continued) B. Failure Analysis When a snubber fails to meet the functional test acceptance criteria, an engineering evaluation shall be made to determine the cause of the failure, as required by TSR 3.7.4.3. The results of this evaluation shall be used, if applicable, in selecting snubbers to be tested in an effort to determine the OPERABILITY of other snubbers irrespective of the type which may be subject to the same failure mode. This evaluation may also be used by Site Engineering (Civil) when they are required to perform a supported system/component analysis. During the failure analysis of hydraulic and mechanical snubbers, the performance should be very methodical. Hydraulic snubbers typically fail because of loss of fluid, which results in no restraining action. This is referred to as failing soft. Some types of snubbers are prone to fail from a loss of bleed capability. This will be of affect only if the snubber has been activated. The failure analysis is to determine the reasons these conditions developed. Appendix H provides many very good points to be investigated during the analysis of hydraulic snubbers and their component parts, but this Appendix should NOT be viewed as all inclusive. PSA mechanical snubbers typically fail from high drag forces that approach or are in the locked up condition. That condition requires a supported system/component analysis to determine the affect on the piping system or component from restriction of the thermal movement, in addition to the analysis to determine the cause of the high drag or locked up condition. Appendix I provides many very good points to be investigated during the analysis of mechanical snubbers and their component parts, but this Appendix should NOT be viewed as all inclusive. C. Failure Cause Determination Techniques Sometimes the cause of the inoperable condition can be determined by external examination, such as loose tubing connections or paint in the wrong places (i.e., on the moving parts). However, in most cases the snubber will require disassembly to determine what caused the condition. Visual examinations and measurements, coupled with the knowledge of what is required to keep the snubber operable are usually sufficient to determine what caused the condition. Sometimes additional knowledge is required to determine 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 the defect to develop. Such root causes may be improper maintenance, improper design or operation resulting in excessive vibration of the supported system/component.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 41 of 166 7.20 Supported System/Component Analysis 7.20.1 Mechanical Snubbers The drag force of the snubber should NOT overstress the supported system/component as a result of thermal expansion or contraction. The snubber manufacturer's recommended limiting drag force is 5% of the rated load of the snubber, except for the PSA-1/4. However, that value is applicable only to the functionality of the snubber. The structure, component, piping, or equipment that the snubber is supporting must be evaluated for high drag forces to ensure they have NOT been overstressed beyond their allowable limits. REFER TO General Construction Specification G-43 for screening values based on pipe size to determine when a supported system/component analysis is required. 7.20.2 Hydraulic Snubbers The drag force of the snubber should NOT overstress the supported system/component as a result of thermal expansion or contraction. The snubber manufacturer's recommended limiting drag force is 2% of the rated load. However, that value is applicable only to the functionality of the snubber. The drag force of a hydraulic snubber will NOT overstress the pipe, but an analysis is required since the snubber failed its functional test acceptance criteria. General Engineering Specification G-43 gives screening values based on pipe size to determine when a supported system/component analysis is required. The G-43 values have NOT been accepted at Browns Ferry for hydraulic snubbers at this time. A supported system/component analysis is required if the snubber failed the functional test acceptance criteria for activation and bleed.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 42 of 166 7.21 Performance Monitoring and Trending 7.21.1 General Approach The performance of snubbers is indicated by the results of the functional tests. The snubber tracking data base program is the primary means for tracking and trending of snubber performance. Some short term tracking is required by the Technical Requirements Manual relating to snubbers installed in the same location as other snubbers that failed during previous outage tests due to location or unknown causes. These snubbers are required to be tested during the next operating cycle if the failure was due to location or design deficiencies. Other manual tracking can be performed by referencing the functional test data sheets from previous outages; however, this tracking can be performed more efficiently if historical snubber tracking data base information is available. When the same snubber has been tested several times, its results may be reviewed to determine whether a trend may be developing in the results. Appendix G provides additional guidance for the performance monitoring and trending of snubbers. 7.21.2 Trending for Hydraulic Snubbers The test results that are significant for trending are the activation velocity and the bleed rate. Typically the snubber is rebuilt and as-left tests are performed to set the values in the optimum portion of the acceptance range. The results of the next as-found test should be compared to the last as-left test to determine any drift that has taken place. If the drift is consistent, the optimum setting might be changed to keep the as-found tests better in the acceptance range. If a snubber has NOT been rebuilt, the results of the next as-found test should be compared to the last as-found test to see if the acceptance range is degrading with the increased stay time.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 43 of 166 7.21.3 Mechanical Snubber Performance Trending A. Changes in drag force can take place for a number of reasons and there is no set pattern known to be specifically predictable. When high drag forces are caused by excessive or hardening lubricant, stroking the snubber can cause a redistribution of the lubricant, resulting in reducing the drag forces. The drag force may remain relatively low for a number of years when the lubricant is redistributed. Corrosion can be broken loose by stroking, but is usually progressive, and the drag force can be expected to increase again soon. Snubbers are monitored for performance, with increasing drag forces taken as an indication of impending failure of the snubber. Snubbers previous test results should be reviewed to determine whether the trend is upward and some preventive maintenance is advisable to avoid the requirement of having drag forces above the screening criteria evaluated. Snubber drag forces between 3 to 5 percent of rated load should be evaluated for impending failures. The acceptance criteria for "as-left" drag forces is equal to or below 3% of the rated load for the snubber, with the exception of PSA 1/4 which use the acceptance criteria for PSA 1/2 snubbers. This practice is consistent with good industry practice to proactively replace PSA mechanical snubbers to reduce future test failures. B. An upward trend in the drag force will effectively result in lowering the acceleration value, and there is no lower limit to the acceleration value. The concern with a locked up snubber is possible over stressing of the supported system/component under normal loading conditions. Some testing has indicated in some snubbers a slight upward trend in the acceleration value due to wear. Any performance monitoring of acceleration should be carefully evaluated using other plants and PSC test program results to determine its value.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 44 of 166 7.22 Service Life Monitoring 7.22.1 Regulatory Requirements The TR requires that the service life of hydraulic and mechanical snubbers be monitored to ensure that the service life is NOT exceeded between surveillance inspections. The object is to replace degraded components before they become inoperable. Service life varies with conditions and materials, and should be adjusted based on actual experience. Appendix G, of this procedure, provides additional guidance for a complete service life monitoring program. 7.22.2 Hydraulic Snubber Service Life Program The static and dynamic seals, moving parts and fluid are subject to wear or other degradation. Hydraulic snubbers at Browns Ferry have ethylene propylene seals. The ethylene propylene seals at Browns Ferry have an established nominal service life of 17.3 years. Balance of plant hydraulic snubbers may be treated the same as safety-related snubbers for seal life extension. The piston, piston rod, cylinder, and glands are also subject to wear, especially in high vibration installations. Those, and other moving parts of the snubber, should be examined carefully each time the seals are replaced, and replacements made to prevent leakage or other conditions of in-operability before the next time the snubber is to be rebuilt. The fluid, if to be reused, should be checked at the rebuild time for moisture content and particulate content to determine whether it should be filtered to bring it within the specifications. 7.22.3 PSA Mechanical Snubber Service Life Monitoring Drag force increase is NOT a reliable indicator of the remaining service life of the PSC snubber, but it is the best indicator identified to date. Therefore, service life effort involves tracking drag force variations.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 45 of 166 7.23 Balance of Plant Hydraulic and Mechanical Snubbers A. Snubbers installed in non-safety-related or non-quality-related applications are included in the Preventive Maintenance (PM) program for performance of visual examinations and functional tests on a basis subject to review and adjustment based on the results. Both hydraulic and mechanical snubbers will be included in the PM program. B. Hydraulic snubber visual exams should be performed for fluid level and obvious problems frequently enough to assure the fluid level stays within the operability range. Snubbers should be examined for fluid level the next outage after they have been rebuilt, and the next exams scheduled based on the results and past experience. Balance of plant snubbers installed in similar environmental conditions as safety-related snubbers may be used to verify extension of seal life for the safety-related snubbers. Functional tests should be performed on a percentage and frequency based on the results of the safety-related snubber test results. A low failure rate would indicate an extended interval between tests and possibly a small sample would be appropriate. C. The mechanical snubbers should be examined for signs of overload, abuse, and corrosion. The exams should be performed based on the environmental conditions and the activities performed in the area. A functional (activation or drag force) test or hand stroking, whichever is needed to confirm adequate freedom of movement, should be performed on suspect snubbers, and a sampling program should be considered.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 46 of 166 7.24 Dynamic Transients [1] In the event of a water hammer or an unanticipated transient, the following inspection and testing shall be performed to determine snubber operability. A Work Order (WO) is NOT required for a visual examination, but is required for performance of any functional testing or hand stroking required. [1.1] VISUALLY INSPECT all snubbers and snubber supports that have been subjected to the transient. The visual inspection shall be performed in accordance with 1-, 2-, or 3-SI-4.6.H-1, as applicable. [1.2] If the visual inspection reveals damage to the snubbers or to the snubber supports MANUALLY STROKE all mechanical snubbers, that have been subjected to the transient, to their full range of travel. Also PERFORM in-place drag force testing in accordance with O-SI-4.6.H-2A. [1.3] IF no visible damage to the snubber or snubber support is determined, THEN MANUALLY STROKE 10% of the snubbers that have been subjected to the transient and PERFORM in-place drag force testing in accordance with 0-SI-4.6.H-2A. [1.4] IF any snubber is found to be unacceptable THEN an additional 10% of the snubbers, subjected to the transient, shall be tested until no failure is found or all snubbers, subjected to the transient, have been tested. [1.5] PERFORM a failure analysis for each failed snubber to determine failure mode. [1.6] Testing of hydraulic snubbers is NOT required since internal damage to the hydraulic snubber in NOT likely to occur.

7.25 Snubber Users Group (SNUG) 7.25.1 SNUG Organization Formation and Purpose SNUG was formed in the winter of 1984 as an information sharing group which addresses industry snubber concerns including maintenance, regulation, and surveillance. SNUG does NOT formally address licensing concerns and vendors will NOT be allowed membership. The only membership requirements are that a utility must actively participate in the SNUG data base information exchange and a small fee, as designated by the Board of Directors. Each utility is requested also to select two designees at each plant and/or utility as primary and secondary contacts. Further information concerning SNUG may be found in the SNUG "By-Laws" and "Policy Statements". 7.26 Snubber Program Notebook The snubber program notebook contains the program description, future refueling outage schedule, trend data, results of recent snubber inspections, program health reports, industry operating experience, hard to find snubber information, and a log of recent program challenges or issues. Appendix L is an example of the suggested format. Procedures and other controlled documents do not need to be included, but should be specifically referenced, in the snubber program notebook. 8.0 ACCEPTANCE CRITERIA In accordance with the applicable and appropriate Maintenance and Surveillance Instructions.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 48 of 166 9.0 APPENDICES APPENDIX A: Snubber Request for Relief 3-ISI-2 APPENDIX B: Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubbers APPENDIX C: Grinnell Hydraulic Snubbers APPENDIX D: Bergen-Paterson Torus Dynamic Hydraulic Restraint Snubbers APPENDIX E: Lisega Torus Dynamic Restraint Hydraulic Snubbers APPENDIX F: Pacific Scientific Company Mechanical Snubbers APPENDIX G: Service Life Monitoring Recommendations APPENDIX H: Hydraulic Snubber Failure Analysis Approach, Failure Modes, Indications and Failure Cause APPENDIX I: Mechanical Snubber Failure Analysis Approach, Failure Modes, Indications and Failure Cause APPENDIX J: Snubber Request for Relief 2-ISI-13 APPENDIX K: Snubber Request for Relief 1-ISI-18 APPENDIX L Snubber Program Notebook Table of Contents

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 49 of 166 Appendix A (Page 1 of 6) Snubber Request for Relief 3-ISI-2 This relief request was approved by the NRC per Reference L and will be implemented during the Unit 3 Cycle 9 refueling outage.

SUMMARY

Pursuant to 10CFR50.55a(a)(3)(i), TVA is requesting relief from the identified ASME Section XI requirements related to examination and testing of snubbers. TVA proposes to continue use of the examination and testing plans currently defined in the Technical Requirements Manual (TR 3.7.4). The current Technical Requirements Manual requirements have been promulgated, accepted, and approved (on July 14, 1998 for Browns Ferry Plant, Units 1, 2, and 3) by NRC, while ASME Section Xl imposes overlapping requirements which do not enhance the quality and safety of the subject snubber examination and testing. COMPONENTS: Component/piping snubbers CODE CLASS: 1, 2 and 3 CODE REQUIREMENT: 1989 Edition of ASME Section XI (no addenda) IWF-5300(a) and (b) inservice examination and testing in accordance with the first Addenda to ASME/ANSI OM-1987, Part 4. IWF-5400 Repairs and Replacements of snubbers shall be in accordance with the first Addenda to ASME/ANSI OM-1987, Part 4. IWA-6230 requires inservice inspection summary reports for snubbers be filed with regulatory authority. IWA-21 10 requires Authorized Nuclear Inservice Inspector (ANII) involvement for snubber examination and testing.

Appendix A (Page 2 of 6) CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED: In accordance with 10CFR50.55a(a)(3)(i), relief is requested from the ASME Section Xl, 1989 Edition (no addenda), requirement for inservice examinations and tests for snubbers, and repair/replacement examinations and tests of snubbers: IWF-5300(a) and (b) Inservice Examination and Testing, and implied OM-1 987, Part 4, Sections 2.3, Inservice Examinations, 2.4, Examination Documentation, and 3.2, Inservice Operability Testing, and 3.3, Testing Documentation. IWF-5400 Repairs and Replacements of snubbers shall be in accordance with the first Addenda to ASME/ANSI OM-1987, Part 4, Sections 1.5.6, Snubber Maintenance or Repair, and 1.5.7, Snubber Modification and Replacement. IWA-6230, Summary Reports (for snubbers). IWA-21 10(a)(5) and (c), Duties of the Inspector (for involvement for snubber examination and testing). BASIS FOR RELIEF: ASME Section Xl Class 1, 2, and 3 equivalent snubbers are examined and tested in accordance with Browns Ferry Nuclear (BFN) Plant Technical Requirements Manual (TRM), TR 3.7.4. BFN TR 3.7.4 is prepared in accordance with the guidance given by NRC in Generic Letter 90-09. The scope for snubbers examined and tested in accordance with TR 3.7.4 is not limited by line size or other applicable code exemptions and includes a numerically greater population of snubbers than the Section Xl program. Examination and testing of the snubbers in accordance with both ASME Section Xl and the plant TRM would result in duplication of effort utilizing different standards and require the preparation of a separate program and associated procedures. This would result in additional cost and unnecessary radiological exposure. In addition the personnel performing snubber visual examinations would also be required to be certified in accordance with the American Society of Nondestructive Testing (ASNT) SNT-TC-1A "Personnel Qualification and Certification in Nondestructive Testing", which is an additional certification as compared to the task training qualification required to perform the TRM required examinations and testing of snubbers. The existing TRM program for examination and testing of snubbers was promulgated, accepted, and approved by NRC. The implementation of OM-1 987, Part 4, would require BFN to initiate a snubber examination and testing program that is more complicated and expensive to perform, without a compensating increase in the level of quality and safety.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 51 of 166 Appendix A (Page 3 of 6) ALTERNATE EXAMINATIONS: The BFN TRM, TR 3.7.4, requirements will be utilized for the examination and testing of snubbers for preservice, inservice, and repair/replacement activities. The procedures utilized for these examinations are: 3-SI-4.6.H-1, "Visual Examination of Hydraulic and Mechanical Snubbers"; O-SI-4.6.H-2A, "Functional Testing of Mechanical Snubbers"; 0-SI-4.6.H-2B, "Functional Testing of Bergen-Paterson Hydraulic Snubbers"; O-SI-4.6.H-2C, "Functional Testing of Bergen-Paterson Torus Dynamic Restraints"; O-SI-4.6.H-2E, "Functional Testing of Lisega Large Bore Torus Dynamic Restraints"; MPI-0-000-SNBOO2, "Hydraulic Shock and Sway Arrestor Bergen-Paterson Unit Disassembly and Reassembly"; and MPI-0-000-SNBOO4, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson Hydraulic, Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Restraints Snubbers". This will include the pin-to-pin area inclusive of applicable snubbers. Testing of repaired and replaced snubbers will also be performed in accordance with TR 3.7.4. Visual examination of repaired and replaced snubbers will be performed in accordance with MPI-0-000-SNBOO4, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson Hydraulic, Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Restraints Snubbers". Snubber examination and testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, SSP-3.1, and the implementing procedures (3-SI-4.6.H-1, O-SI-4.6.H-2A, O-SI-4.6.H-2B, O-SI-4.6.H-2C, O-SI-4.6.H-2E, MPI-0-000-SNBO02, and MPI-0-000-SNB004). The areas inclusive of the pins back to building structure and to the component/piping being supported will remain in the ASME Section Xl examination boundary.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 52 of 166 Appendix A (Page 4 of 6) JUSTIFICATION FOR THE GRANTING OF RELIEF: The current program, as defined by TR 3.7.4, provides for a level of quality and safety equal to or greater than that provided by OM-1987 Code, Part 4, and utilizes NRC guidance not incorporated in the OM Code referenced by the 1989 Edition of ASME Section XI. Examination, testing, repair and replacement of snubbers is currently performed in accordance with TR 3.7.4, which utilizes the guidance provided by NRC in Generic Letter 90-09. The OM Code referenced by ASME Section XI has a different basis for examination (failure mode groups) and test plans (10%, 37, or 55). It is impractical to implement both plans because of the resulting duplication of examination and testing efforts and different requirements for snubber quantities subject to examination or test, actually examined and/or tested, and sample expansion requirements. This would result in additional cost and unnecessary radiological exposure. The existing TRM program for examination and testing of snubbers has been promulgated and accepted by NRC. The differences in the two programs could create confusion when selecting test samples, applying acceptance criteria, corrective actions and examination schedules for failed snubbers. This situation could increase the possibility of applying the wrong action, thus creating a nonconformance, an in-operability or even a violation of a TRM requirement. To eliminate any misinterpretation or confusion in administering overlapping requirements for snubbers, and to remove the possibility of applying contradicting requirements to the same snubber(s), BFN proposes to examine and test snubbers in accordance with BFN TR 3.7.4. Sub-article IWF-5400 provides the requirements for repair and replacement of snubbers to be in accordance with OM-1987, Part 4, Section 1.5.6, "Snubber Maintenance or Repair" and 1.5.7, "Snubber Modification and Replacement" require repaired and replaced snubbers to meet the visual examination requirements of Paragraph 2.3.1.2 and the operability test requirements of Paragraph 3.2.1.1. Section 1.5.6 also requires an evaluation of the maintenance or repair activity and Section 1.5.7 requires a suitability evaluation on the replacement/modified snubber. TR 3.7.4 (TSR 3.7.4.6) requires replacement snubbers and snubbers which have repairs which might affect the functional test results to be tested to meet the functional test criteria prior to installation. Maintenance procedure MPI-0-000-SNBOO4 provides visual examination criteria for installation of a snubber after repair or replacement. The ASME Section XI repair/replacement program at BFN documents the suitability of repairs, IWA-4130(a)(4), and replacements, IWA-7220.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 53 of 166 Appendix A (Page 5 of 6) ASME Section Xl, VT-3 certification required for personnel performing snubber visual examinations is an additional certification as compared with the TRM program training qualifications. Personnel performing the TRM required visual examinations are "process qualified" to perform the examinations and testing required by the TRM and implemented by the referenced procedures. This training currently includes a visual test associated with face mask fit and specific training on the acceptance criteria associated with procedure MPI-0-000-SNBO04. Additional "visual acuity" verification for personnel performing snubber visual examinations will include visual acuity requirements that meet ASME Section XI. The training and documentation of personnel to the visual acceptance criteria, specified in the TRM implementing procedures, provides an acceptable level of quality and safety. Because relief is sought from the ASME Section Xl snubber examination and test requirements, there will be no ASME Section Xl snubber examination and test activities to require ANII involvement. The BFN TRM snubber program does not require the use of an ANII for examination and test requirements. The ANII will not be involved in the TRM required visual examination or testing activities performed in lieu of the ASME Code requirements. A snubber program manager provides oversight of the TRM snubber program implementation for both visual and functional testing. This oversight includes both review and evaluation of visual examination and functional testing data to ensure TRM requirements are met. The snubber program manager provides an acceptable level of quality and safety without ANII involvement in those activities. ANII involvement in other inservice repair and replacement snubber activities, as required by IWA-21 10(g) and (h) and implemented by BFN's ASME Section Xl repair and replacement program will be maintained. Sub-article IWA-6230 and OM-1987, Part 4, Sections 2.3 and 3.3 provide requirements for ASME Section Xl inservice examination and test documentation for snubbers and a summary report of examinations and testing. Under the alternate requirements for snubbers, there will be no ASME Section XI inservice examination and testing to document in a summary report. TR 3.7.4 is implemented by surveillance instructions 3-S1-4.6.H-1, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, 0-SI-4.6.H-2C, 0-SI-4.6.H-2E, and maintenance instructions MPI-0-000-SNBOO2, and MPI-0-000-SNBOO4. These instructions are written and approved in accordance with the TVA Nuclear Quality Assurance Program, include data sheets for documenting the visual examination and functional test data and results, and provide for documentation of non conforming results and evaluation of those results. The completed data sheets are QA records and are controlled and maintained in accordance with the BFN QA records program. These records are available onsite for review and inspection. The QA records documenting snubber visual examinations and functional tests provide an acceptable level of quality and safety when compared to the requirements of ASME Section Xl and OM-1 987, Part 4.

Appendix A (Page 6 of 6) Based on the justification provided, BFN's examination and testing of snubbers, in accordance with TR 3.7.4 will provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55(a)(3)(i), TVA requests that relief be granted from the 1989 Edition of ASME Section Xl Code requirements related to inservice examination and testing for snubbers. IMPLEMENTATION SCHEDULE: TR 3.7.4 will be implemented during the second ten-year ASME Section XI inspection interval for snubber examination and testing in lieu of the code requirements listed above.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 55 of 166 Appendix B (Page 1 of 8) Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubber 1.0 GENERAL DESCRIPTION Hydraulic snubbers consist basically of a main cylinder, main piston, fluid modulating (control valve) device and fluid makeup reservoir. Under normal operating conditions, when piping and equipment moves thermally at relatively low velocities, fluid passes from one end of the main cylinder to the other through the control valves with little or no resistance. Under dynamic conditions, at relatively high velocities, the fluid is "choked" (snubber lock up) or blocked at the control valve, allowing little or no further motion of the main piston rod other than that due to compression of the fluid and metallic parts. BFN purchased its original snubbers from Bergen-Paterson and they were purchased as Safety-Related, NF. The Bergen-Paterson Part Numbering was primarily used which reflects the rating in KIPS of each snubber. These snubbers were manufactured in lots and NOT given an individual serial number, therefore Browns Ferry developed an individual serial number and stamped this number on the snubber body. This numbering system has been the means of tracking these snubbers as they have been moved from location to location. In 1978 Bergen-Paterson revised their numbering system to the following: 2500 - XXX XXX Model No. Kip Rating Sequential Unit No. Later the numbering system was changed by Anchor/Darling to the following: ADH - XXX XXX Model No. Sequential Unit No. Fronek has retained the Anchor/Darling numbering system. The Bergen-Paterson, Anchor/Darling and Fronek snubbers are located in all three units.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 56 of 166 Appendix B (Page 2 of 8) 2.0 TYPES AND SIZES FOR THE BERGEN-PATERSON, ANCHOR/DARLING AND FRONEK HYDRAULIC SNUBBERS:

     "    HSSA-3, 3 Kips, 6 inch stroke (Bergen-Paterson part number HSSA-3 or 2500-3)

• HSSA-10, 10 Kips, 6 inch stroke (Bergen-Paterson part number HSSA-10 or 2500-10)
• HSSA-20, 20 Kips, 6 inch stroke (Bergen-Paterson part number HSSA-20 or 2500-20)
• HSSA-30, 30 Kips, 6 inch stroke (Bergen-Paterson part number HSSA-30 or 2500-30)
• ADH-3, 3 Kips, 6 inch stroke (Anchor/Darling part number ADH-300)
• ADH-10, 10 Kips, 6 inch stroke (Anchor/Darling part number ADH-1000)

     "    ADH-20, 20 Kips, 6 inch stroke (Anchor/Darling part number ADH-2000)
     "    ADH-30, 30 Kips, 6 inch stroke (Anchor/Darling part number ADH-3000)

• ADH-50, 50 Kips, 6 inch stroke (Anchor/Darling part number ADH-5000)
• ADH-70, 70 Kips, 6 inch stroke (Anchor/Darling part number ADH-7000)
• ADH-120, 120 Kips, 6 inch stroke (Anchor/Darling part number ADH-12000)
• ADH-130, 130 Kips, 6 inch stroke (Anchor/Darling part number ADH-1 3000) 3.0 TEST PARAMETERS IN THE SNUBBER TEST MACHINE PROGRAM:

The following parameters shall be verified to work on the test machine, with the associated snubbers, and the accompanying plot shall be located as close to the center of the graph as possible. If the plot does NOT show in the center of the graph the following parameters may be changed to center the plot and give the best looking plot available. Valve Open - This value is in percent of command output. If the operator wishes to start the valve sooner the percent value may be reduced, which will require the valve to open sooner causing the command ramp to "jump" up to an initial value and overcome the dead band.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 57 of 166 Appendix B (Page 3 of 8) 3.0 TEST PARAMETERS IN THE SNUBBER TEST MACHINE PROGRAM: (continued)

• Valve End - The valve end value allows the operator to set an endpoint for the proportional valve opening at less than 100 percent full open. If the operator wishes the profile to extend or reduce this value should be increased or decreased, as necessary. This value must be controlled enough so the snubber'will lockup and bleed, prior to the end of the test. This value controls the ramp profile in the activation tests.

          "    Ramp Duration - This value sets the time duration of the ramp between valve start and valve end. This value may be decreased, which moves the plot to the left on the graph. In the acceleration tests this value is limited to .45 sec maximum.
          "    Load Duration - This is the time that the valve will remain at the valve end position, after the ramp time has elapsed. Adjusting this value "up" will assure that the complete test will show on the graph.

TYPE HSSA 3 HSSA 10 HSSA 20 HSSA30 KIP RATING 3 10 20 30 STROKE 6 6 6 6 ACTIVATION RATE 10 10 10 10 RELEASE RATE 2 2 2 2 ACCELERATION RATE N/A N/A N/A N/A DRAG FORCE RATE 2 2 2 2 TEST LOAD 80 80 80 80 PRESSURE BOOST 100 100 100 100 VALVE START 7 8 8 8 VALVE END 15 25 25 25 DRAG SPEED 2 2 2 2 RAMP DURATION 7.0 9.5 9.5 9.5 LOAD DURATION 2.9 .4 .4 .4 BENCH (B)IG/ (S)MALL S B B B TYPE ADH/FRONEK ADH/FRONEK ADH/FRONEK ADH/FRONEK ADH/FRONEK 20 30 50 70 130 KIP RATING 20 30 50 70 130 STROKE 6 6 6 6 6 ACTIVATION RATE 10 10 10 10 10 RELEASE RATE 2 2 2 2 2 ACCELERATION RATE N/A N/A N/A N/A N/A DRAG FORCE RATE 2 2 2 2 2 TEST LOAD 80 80 80 80 80 PRESSURE BOOST 100 100 100 100 100 VALVE START 8 8 8 8 8 VALVE END 25 25 25 25 25 DRAG SPEED 2 2 2 2 2 RAMP DURATION 9.5 9.5 9.5 9.5 9.5 LOAD DURATION .4 .4 .4 .4 .4 BENCH (B)IG/ (S)MALL B B B B B

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 58 of 166 Appendix B (Page 4 of 8) 4.0 POPPET TYPE CONTROL VALVES Most snubber designs use spring loaded poppet (flow sensitive check) valves to limit the velocity of the piston rod. The lockup is controlled by the size of the flats on the head of the poppet and bleed rate is controlled by small grooves cut in the bottom portion (seating area) of the poppet. The spring is calibrated to keep the poppet valve from closing on its seat until the fluid velocity past the poppet head provides enough force on the poppet to overcome the spring and close the poppet. These valves are NOT adjustable and the poppet or spring are required to be replaced to achieve the desired lockup or bleed rate. When the cylinder has a single ended piston rod and the flow rate from the front and rear of the piston will be different for the same piston velocity, different size poppet heads are used to close at approximately the same piston velocity in either direction of travel. The small flow also prevents a solid lock-up of the valve and potential difficulty in the relief of pressure on the valve. If for some reason the grooves become clogged the snubber would remain a rigid strut until enough time elapsed to allow the snubber to depressurize. This could cause serious damage to the piping or equipment if thermal movements were required to take place immediately after a dynamic event. 5.0 RESERVOIRS Hydraulic snubbers usually require a fluid reservoir for the following reasons: to provide makeup fluid for the volume displaced by the piston rod in single ended piston rod models.

• to compensate for thermal expansion and contraction of the fluid.

    "      to provide a fluid reserve in the event of low level fluid loss such as that due to normal rod wetting during stroking.

This type of snubber contains a pressurized, external (integral) reservoir. These pressurized reservoirs are isolated from the atmosphere by a plunger attached to a piston. This type of reservoir is less prone to the intrusion of moisture, but they do have one fault. That is the reservoir plunger penetration does NOT have a seal and if the snubber is NOT oriented properly water can penetrate into the atmospheric side of the reservoir and deteriorate the piston and seals causing total fluid loss from the reservoir.

BFN Snubber Program Procedure 0-TI-398 Unit 0' Rev. 0005 Page 59 of 166 Appendix B (Page 5 of 8) 6.0 HYDRAULIC SNUBBER FLUIDS 6.1 General Requirements The fluid used in snubbers should be fire resistant, radiation resistant, have a flat viscosity curve, and be compatible with seal materials such as ethylene propylene. The silicon fluid used at BFN is General Electric (GE) SF-1 154. This fluid is expensive and should be reused when practical. The fluid should NOT get contaminated since it is used under pressure in these snubbers. Partially used container should be closed with an air tight cap to prevent moisture from entering the container. If open to the atmosphere this fluid is extremely prone to the absorption of moisture.

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BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 61 of 166 Appendix B (Page 7 of 8) 7.0 BERGEN-PATERSON, ANCHOR/DARLING OR FRONEK HYDRAULIC HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued) 4K.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 62 of 166 Appendix B (Page 8 of 8) 7.0 BERGEN-PATERSON, ANCHOR/DARLING OR FRONEK HYDRAULIC HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued) ITEM DESCRIPTION ITEM DESCRIPTION NO. NO. 1 MOUNTING FLANGE 33 RESERVOIR TIE ROD NUT 2 TIE ROD 34 RESERVOIR HEAD 3 CAP 35 RESERVOIR INDICATOR TUBE LOCK NUT 4 PISTON RING 36 RESERVOIR SPRING GUIDE 5 PISTON 37 RESERVOIR WARNING TAG 6 CYLINDER TUBE 38 RESERVOIR CYLINDER TUBE 7 PISTON ROD 39 RESERVOIR PISTON 8 FLUSH PLUG-PORT PLUG 40 RESERVOIR CAP 9 TIE ROD NUT 41 RESERVOIR SEAL SCREW 10 GLAND 42 RESERVOIR SEAL SCREW'O' RING 11 NAME PLATE 43 RESERVOIR CAP OR HEAD TO CYL.'O' RING 12 HEAD 44 VALVE TO RESERV'O' RING 13 PISTON ROD NUT 45 RESERVOIR PISTON ROD PACK 14 VALVE TO MAIN BODY'O' RING 46 RESERVOIR FILLER PLUG 15 CAP OR HEAD TO CYL.'O' RING 47 RESERVOIR FILL PLUG COVER 16 PISTON TO ROD'O' RING 48 POPPET STOP AND PLUG 17 MAIN PISTON ROD WIPER 49 FLOW CONTROL BODY 18 FLUSH PLUG-PORT PLUG'O' RING 50 RELIEF VALVE BALL 19 PISTON ROD PACKING SEAL 51 RELIEF VALVE SPRING 20 RESERVOIR TIE ROD - LONG 52 RELIEF VALVE PLUG 21 RESERVOIR TIE ROD NUT 53 CONNECTOR TUBE 22 RESERVOIR REAR MOUNTING LUG 54 EXTENSION POPPET 23 VALVE BODY MOUNTING SCREW 55 POPPET SPRING 24 RESERVOIR REAR MOUNT SCREW 56 COMPRESSION POPPET 25 RESERVOIR SPRING 57 SAE PORT PLUG 26 RESERVOIR TAIL ROD 58 POPPET STOP & PLUG'O' RING 27 RESERVOIR FRONT MOUNT LUG 59 SAE PORT PLUG'O' RING 28 RESERV FRONT MOUNT SCREW 60 CONNECTOR TUBE'O' RING 29 RESERV INDICATOR PROT TUBE 61 CONN TUBE - HEAD'O' RING 30 RESERV LEVEL INDICATOR PLATE 62 RELIEF VALVE PLUG'O' RING 31 NAME PLATE DRIVE SCREW 63 RELIEF VALVE'O' RING 32 RESERVOIR TIE ROD - SHORT

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 63 of 166 Appendix C (Page 1 of 10) Grinnell Hydraulic Snubbers 1.0 GENERAL DESCRIPTION Hydraulic snubbers consist basically of a main cylinder, main piston, fluid modulating (control valve) device and fluid makeup reservoir. Under normal operating conditions, when piping and equipment moves thermally at relatively low velocities, fluid passes from one end of the main cylinder to the other through control valves with little or no resistance. Under dynamic conditions, at relatively high velocities, the fluid is "choked" (snubber lock up) or blocked at the control valve, allowing little or no further motion of the main piston rod other than that due to compression of the fluid and metallic parts. BFN purchased its original snubbers from Grinnell Company and they were purchased as Safety-Related, NF. The Grinnell Part Numbering was primarily used which reflects a figure number and the bore size, in inches, of each snubber. These snubbers were manufactured in lots and NOT given individual serial numbers. Therefore, Browns Ferry developed an individual serial number and stamped this number on the snubber body. This numbering system has been the means of tracking these snubbers as they have been moved from location to location. There is only one size of Grinnell Hydraulic snubbers at Browns Ferry and this is a 4 inch bore and is listed in the procedures as ITT. There are two different body styles (Lynair and Lindco) of these snubbers. These snubbers are only located in Unit 2. 2.0 TYPES AND SIZES FOR THE GRINNELL HYDRAULIC SNUBBERS: GRNL 4, 27.3 Kips, 5 inch stroke (Grinnell part number Fig 200/201) 3.0 TEST PARAMETERS IN THE SNUBBER TEST MACHINE PROGRAM: The following parameters shall be verified to work on the test machine, with the associated snubbers, and the accompanying plot shall be located as close to the center of the graph as possible. If the plot does NOT show in the center of the graph the following parameters may be changed to center the plot and give the best looking plot available. Valve Open - This value is in percent of command output. If the operator wishes to start the valve sooner the percent value may be reduced, which will require the valve to open sooner causing the command ramp to "jump" up to an initial value and overcome the deadband.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 64 of 166 Appendix C (Page 2 of 10) 3.0 TEST PARAMETERS IN THE SNUBBER TEST MACHINE PROGRAM: (continued)

     "    Valve End - The valve end value allows the operator to set an endpoint for the proportional valve opening at less than 100 percent full open. If the operator wishes the profile to extend or reduce this value should be increased or decreased, as necessary. This value must be controlled enough so the snubber will lockup and bleed prior to the end of the test. This value controls the ramp profile in the activation tests.

• Ramp Duration - This value sets the time duration of the ramp between valve start and valve end. This value may be decreased, which moves the plot to the left on the graph. In the acceleration tests this value is limited to.45 sec maximum.

     "    Load Duration - This is the time that the valve will remain at the valve end position, after the ramp time has elapsed. Adjusting this value "up" will assure that the complete test will show on the graph.

TYPE GRNL 4 KIP RATING 27.3 STROKE 5 ACTIVATION RATE 8 RELEASE RATE 4 ACCELERATION RATE N/A DRAG FORCE RATE 2 TEST LOAD 80 PRESSURE BOOST 100 VALVE START 5 VALVE END 20 DRAG SPEED .5 RAMP DURATION 9.5 LOAD DURATION .4 BENCH (B)IG/ (S)MALL B

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 65 of 166 Appendix C (Page 3 of 10), 4.0 LOCKUP/BLEED TYPE CONTROL VALVES The type control valve used at Browns Ferry in both types of snubbers is a flow sensitive check valve (poppets) in parallel with bleed orifices. The spring is calibrated to keep the poppet valve from closing on its seat until the fluid velocity past the poppet head provides enough force on the poppet to overcome the spring and close the poppet. These are designed as adjustable valves which use screws-to make the adjustments. They can be more finely tuned for the lockup and bleed rate desired, but they are also easy to become out of tolerance due to vibration of piping or equipment to which they are attached. When the cylinder has a single ended piston rod and the flow rate from the front and rear of the piston will be different for the same piston velocity, different adjustments are used to force the poppets closed at approximately the same piston velocity in either direction of travel. These valves have two distinct modes of operation (locked and unlocked). In order for the snubber to return to the free movement mode, after becoming locked, the piston rod velocity must decrease to practically zero. This allows the pressure to drop, the spring to disengage the poppet and the valve assembly to become unlocked. If for some reason the bleed orifices become clogged the snubber would remain a rigid strut until enough time elapsed to allow the snubber to depressurize. This could cause serious damage to the piping or equipment if thermal movements were required to take place immediately after a dynamic event. 5.0 RESERVOIRS Hydraulic snubbers usually require a fluid reservoir for the following reasons:

• to provide makeup fluid for the volume displaced by the piston rod in single ended piston rod models.

     "     to compensate for thermal expansion and contraction of the fluid.

• to provide a fluid reserve in the event of low level fluid loss such as that due to normal rod wetting during stroking.

These snubbers contain non-pressurized (vented), external (integral) reservoirs. These non-pressurized reservoirs are vented to the atmosphere and should include a breather filter to prevent contaminants from entering. With the silicon fluids being used today there is also a danger of moisture entering the fluid, which may cause rusting, pitting and increased seal degradation to occur. These snubbers should only be installed in an orientation, with the breather port (vent) above the fluid level, to prevent the loss of fluid.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 66 of 166 Appendix C (Page 4 of 10) 6.0 HYDRAULIC SNUBBER FLUIDS 6.1 General Requirements A. The fluid used in snubbers should be fire resistant, radiation resistant, have a flat viscosity curve, and be compatible with seal materials such as ethylene propylene. B. The silicon fluid used at BFN is General Electric (GE) SF-1 154. This fluid is expensive and should be reused when practical. The fluid should NOT get contaminated since it has a breather filter on the reservoir vent. Partially used container should be closed with an air tight cap to prevent moisture from entering the container. If open to the atmosphere this fluid is extremely prone to the absorption of moisture.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 67 of 166 Appendix C (Page 5 of 10) 7.0 GRINNELL LINDCO HYDRAULIC HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 68 of 166 Appendix C (Page 6 of 10) 7.0 GRINNELL LINDCO HYDRAULIC HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued) ITEM DESCRIPTION NO. 1 REAR HEAD 2 PISTON ROD TO PISTON LOCKNUT 3 HEAD/CAP TO TUBE SEAL'O' RING 4 HEAD/CAP TO TUBE SEAL BACK-UP RING 5 PISTON T-SEAL 6 PISTON T-SEAL BACK-UP RING 7 MAIN PISTON 8 REAR HEAD TO TUBE LOCK RING 9 MAIN CYLINDER TUBE 10 PISTON ROD 11 PISTON TO PISTON ROD SEAL'O' RING 12 HEAD/CAP TUBE SEAL'O' RING 13 FRONT HEAD 14 ROD BEARING 15 ROD BEARING TO HEAD SEAL'O' RING 16 ROD BEARING TO HEAD SEAL BACK-UP RING 17 SNAP RING 18 ROD T-SEAL 19 ROD T-SEAL BACK-UP RING

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 69 of 166 Appendix C (Page 7 of 10) 8.0 GRINNELL LYNAIR HYDRAULIC HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 70 of 166 Appendix C (Page 8 of 10) 8.0 GRINNELL LYNAIR HYDRAULIC HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued) ITEM DESCRIPTION NO. 1 REAR HEAD 2 POLYPAK PISTON SEAL 3 MAIN CYLINDER SHELL 4 PISTON TO PISTON ROD SEAL'O'-RING 5 MAIN PISTON 6 SHELL TUBE END SEAL'O'-RING 7 FRONT HEAD 8 RETAINER PLATE 9 ROD BEARING 10 POLYPAK PISTON ROD SEAL 11 ROD BEARING TO HEAD SEAL'O'-RING 12 PISTON ROD WIPER 13 PISTON ROD 14 TIE ROD 15 TIE ROD NUT

Appendix C (Page 9 of 10) 9.0 GRINNELL HYDRAULIC DUAL ORIFICE CONTROL VALVE AND RESERVOIR HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST

Appendix C (Page 10 of 10) 9.0 GRINNELL HYDRAULIC DUAL ORIFICE CONTROL VALVE AND RESERVOIR HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued) ITEM DESCRIPTION NO. 1 FEMALE RUN LENZ TEE 2 3/8 NPT HEX SOCKET INSERT 3 LENZ TEE SEAL'O'-RING 4 TUBE PIPE NIPPLE 5 LENZ HEX BUSHING 6 LENZ TEE SEAL BACK-UP RING 7 TUBING CONNECTION 8 CONNECTING TUBE SEAL'O'-RING 9 SPRING PLUNGER 10 COMPRESSION SPRING 11 STEM GUIDE 12 SEAT 13 LOCK-UP ADJUSTMENT SCREW THREAD SEAL 14 LOCK-UP ADJUSTMENT SCREW LOCK NUT 15 LOCK-UP ADJUSTMENT SCREW 16 LOCK-UP ADJUSTMENT SCREW THREAD SEAL WASHER 17 LOCK-UP BARREL 18 EXTERNAL VALVE BARREL SEAL 'O'-RING 19 INTERNAL VALVE BARREL SEAL 'O'-RING 20 BLEED ADJUSTMENT SCREW 21 BLEED ADJUSTMENT SCREW LOCK NUT 22 BLEED ADJUSTMENT SCREW THREAD SEAL WASHER 23 BLEED ADJUSTMENT SCREW THREAD SEAL 24 CROWN NUT 25 CROWN NUT 'O'-RING 26 RESERVOIR END SEAL 27 RESERVOIR PLEXIGLASS CYLINDER 28 RESERVOIR TIE ROD 29 REAR RESERVOIR HEAD PLATE 30 FRONT RESERVOIR HEAD PLATE

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 73 of 166 Appendix D (Page 1 of 9) Bergen-Paterson Torus Dynamic Hydraulic Restraint Snubbers 1.0 GENERAL DESCRIPTION There are sixteen Torus Dynamic Restraints installed on each Torus and are located at 22-1/2 degree intervals around the exterior radius of the Torus. All of the restraints are dimensionally and functionally identical and can be installed at any location. All of the restraints are identified by individual serial numbers to serve as a specific identification for each restraint during manufacture, initial testing, and future recording purposes. These restraints effectively restrain forces in both tension and compression, along an axis of 45 degrees from the horizontal, in the radial direction from the centerline of the reactor. The restraints have a service life of 40 years and no service life monitoring program will be required for these restraints. The Torus Dynamic Restraints consist of a 12 inch bore, internally ported hydraulic, cylinder having a poppet valve assembly located in recesses machined in the blind and rod end heads. The valve controlling movement in the extension direction is located in the rod end head (nearest the Torus) and the valve controlling movement in the retraction direction is located in the blind end head (nearest the wall). The poppet valve has grooves which allow a small amount of fluid to pass the poppet after the activation velocity, of between 6 and 25 inches per minute, has been exceeded and the poppet has closed. A spring loaded pressurized fluid accumulator is mounted on flat machined surfaces on the upper portion of the circular surface of the blind end and rod end heads. The hydraulic system is maintained under pressure to maintain a minimum required 6300 kips/in spring constant. The restraint has a total stroke length of 1-1/2 inches. The rod end paddle of the restraint is pinned to a clevis bracket welded to each ring girder above the PSC ring header support. The blind end paddle is pinned to a clevis bracket mounted on the wall. The original pins are 4 inch diameter and have a slight interference fit between the clevis eye and the spherical bushing on the restraint.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 74 of 166 Appendix D (Page 2 of 9) 1.0 GENERAL DESCRIPTION (continued) When the restraints are removed for functional testing, a new two piece pin is installed in the place of the shrink fit pin to enhance the removal and reinstallation of the restraints in the future. All of the Bergen-Paterson Torus Dynamic Restraints are accessible during reactor operation and form a single group because they are identical in design. They are a group separate from other Bergen-Paterson snubbers because of the seal, valve design and size. The restraints are designed to reduce the dynamic response of the Torus to excitation caused by a design base LOCA. The principal specification governing performance of the restraints is the 7000 kip/inch minimum dynamic spring rate. The restraints have a maximum rated load of 200 KIPS in tension and 230 KIPS in compression. 2.0 OPERABILITY REQUIREMENTS AND MAINTENANCE RECOMMENDATIONS (CEB'84 0503 015) This information defines operability requirements for the Bergen-Paterson Torus Dynamic Restraint Snubbers and provides related maintenance recommendations. 2.1 General Operability Requirements Torus Restraint Snubber (TRS) operability is of concern for conditions requiring primary containment integrity and for which a significant potential for a Loss of Coolant Accident (LOCA) exists. Those conditions exist when the reactor is in the operating, hot standby, or hot shutdown mode, as defined by the BFN Technical Specifications. They do NOT exist in the refueling or cold shutdown mode. To be considered operable, a TRS must be installed and maintained in accordance with all applicable TVA design drawings and BP instruction manuals. In addition, the snubber reservoir fluid level must be maintained such that an acceptable axial spring rate is provided.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 75 of 166 Appendix D (Page 3 of 9) 2.2 Effect of Inoperability The TRS function is to reduce dynamic motion of a Torus and its attachments (structures and piping) during postulated LOCA events. They also limit Torus motion during normal safety/relief valve discharges and postulated seismic events but are NOT required for plant safety under those conditions. Each TRS restrains 1 of the 16 ring girders on a Torus. Its region of significant influence is within the two Torus bays adjacent to that ring girder. Each TRS basically functions independently during a postulated LOCA event. If one TRS was inoperable during a LOCA, the applicable code allowable stress for the Torus and attachments in the adjacent bays could be exceeded. If two or more snubbers were inoperable, proportionately larger regions of the Torus would be similarly affected. Maximum dynamic response would occur in a Torus bay if the snubbers for both adjacent ring girders were inoperable. Under such conditions, the affected Torus and attachment regions would be substantially degraded, relative to satisfying code allowable stresses, but still capable of withstanding the most probable design basis accident, intermediate break accident, and small break accident LOCA loads without loss of containment integrity. 2.3 Recommended Fluid Level Limits for Disk Spring Reservoirs 2.3.1 Applicability These limits are applicable during operating cycle 6 and later cycles of each unit when the reactor is in the operating, hot standby, or hot shutdown mode. 2.3.2 Limits (both must be satisfied) A. Maximum d = 1.595 - 0.01483 (100- T) B. Minimum d = 0.904 + 0.01561 (T- L) where: d Distance from end of indicator rod to face of reservoir at temperature T (inches). T Snubber temperature when d is measured (OF). L = Minimum snubber temperature for the time period of concern (OF).

Appendix D (Page 4 of 9) NOTES

1) The reservoir is full when d = 3.118 inches and it is 1/5 full when D = 0.904 inch.

2) L may be conservatively set at 50 OF. Less conservative values of L are also permissible if justified by in-plant temperature data. L may NOT be greater than T.

3) No maximum d limit is defined in consideration of the over pressure relief feature of the disc spring reservoirs.

2.3.3 Basis for limits These limits ensure a minimum spring rate of 6300 kips per inch for all anticipated snubber temperatures, including an upper limit of 100 OF. They are based upon approved BP test and design documentation for the TRS assemblies. An EN DES calculation CD-QOO10-890191 (CEB 840330 012) documents their deviation. 2.4 Recommended TRS Maintenance Policies for each BFN Unit 2.4.1 Operability of a leaking TRS A leaking TRS shall be declared inoperable if reservoir filling to maintain acceptable fluid levels is required at time intervals of 3 hours or less. A leaking TRS may be electively declared inoperable if another TRS or the drywell/wetwell differential pressure system is NOT already inoperable. The 3 hour time limit is based upon a 20 minute LOCA dynamic load duration with no reservoir filling during the event. Note that a TRS will NOT become inoperable due to air ingestion during operation as long as the fluid reservoir remains pressurized to levels ensured by the specified level limits. The restrictions on electively declaring inoperability are based upon minimizing the probability for maximum Torus response during postulated LOCA events. 2.4.2 Exceeding Fluid Reservoir Limits If a TRS reservoir fluid level is found outside the limits specified in this section at snubber temperature T and with L = T, the TRS shall be declared inoperable until the fluid level is restored to an acceptable value.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 77 of 166 Appendix D (Page 5 of 9) 2.4.3 Exceeding Temperature Limits If a TRS temperature is found outside the range from 50OF to 100°F, Site Engineering (Civil) shall be notified and an operability determination shall be made within 72 hours. This position is based upon the anticipated normal range of TRS fluid temperatures and the TRS design temperature range. Torus room ambient air temperatures outside this range would indicate a very unusual occurrence. Note that insignificant increases in TRS fluid temperatures are predicted during LOCA dynamic events. 2.4.4 Engineering Evaluations An engineering evaluation shall be performed for each instance in which a TRS is determined to be inoperable. Site Engineering (Civil) shall provide assistance upon request and shall be informed of the evaluation results. 2.4.5 Functionality Testing Functionality tests are NOT necessary on a routine basis or as a result of anticipated cases of TRS inoperability. It is possible, but NOT probable, that limited functionality tests may be required for extreme cases of inoperability. That determination must be made by the required engineering evaluations on a case-by case basis. This position is based upon the extensive qualification tests and functionality tests performed by BP. It is also based upon performing installation and maintenance in strict compliance with approved procedures. 2.5 References Concerning Operability of the Torus Restraint Snubbers A. H. J. Green's Memorandum to M. N. Sprouse dated March 15,1983 (DES 830316 019) B. M. N. Sprouse's Memorandum to H. J. Green dated April 4, 1983 (MEB 830404 006) C. Bergen-Paterson Pipesupport Corp. Memorandum to TVA (Gil Payne) dated March 29, 1983 (MEB 830330 526) D. G. L. Payne Note to R. 0. Barnett dated April 1, 1984 (MEB 830401 028) E. R. 0. Barnett Memorandum to G. R. Hall dated April 12, 1984 (CEB 830412 015)

Appendix D (Page 6 of 9) 2.5 References Concerning Operability of the Torus Restraint Snubbers (continued) F. Bergen-Paterson Pipesupport Corp. Memorandum to TVA (Mr. C. A. Chandley) dated July 25, 1983 (MEB 830728 503) G. Bergen-Paterson Pipesupport Corp. Memorandum to TVA (Mr. C. A. Chandley) dated September 7, 1983 (MEB 830909 525) H. R. 0. Barnett Note to J. K. Rochelle dated September 12 1984 (MEB 830912 021)

1. Bergen-Paterson Pipesupport Corp. Memorandum to TVA (Mr. C. A. Chandley) dated March 7, 1984 (MEB 840313 502)

J. R. 0. Barnett Note to J. K. Rochelle dated March 15,1984 (MEB 840316 010) K. E. H. New Memorandum to C. A. Chandley dated January 12, 1984 (MEB 840116 507) L. C. A. Chandley Memorandum to E. H. New dated February 8, 1984 (MEB 840208 019) M. E. H. New Memorandum to C. A. Chandley dated February 27, 1984 (LOO 840228 191) N. C. A. Chandley Memorandum to E. H. New dated March 12, 1984 (MEB 840312 016)

0. G. T. Jones Memorandum to P. R. Wallace dated March 13, 1984 (L52 840313 809)

P. J. A. Coffey's Memorandum to R. W. Cantrell dated March 21, 1984 (L22 840321 800) Q. Calculation for Fluid Level Limits for Torus Restraint Snubbers (CEB 840330 012) R. W. S. Wilburn's Memorandum to G. T. Jones dated April 6, 1984 (L22 840406 801) S. R. W. Cantrell's Memorandum to J. A. Coffey dated April 11, 1984 (MEB 840411 009)

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 79 of 166 Appendix D (Page 7 of 9) 2.5 References Concerning Operability of the Torus Restraint Snubbers (continued) T. R. W. Cantrell's Memorandum to J. A. Coffey dated May 3, 1984 (CEB 840503 015) U. J. P. Darling Memorandum to R. W. Cantrell dated May 4, 1984 (L22 840504 800) V. Gil Payne's Memorandum to Mechanical Engineering Support Branch Files dated May 31, 1984 (MEB 840531 008) W. J. P. Darling's Memorandum to R. W. Cantrell dated June 21, 1984 (L22 840618 800) X. Bergen-Paterson Pipesupport Corp. Memorandum to TVA (Mr. H. E. Crisler) dated May 8, 1986 (B22 860512 001) Y. H. B. Bounds' Memorandum to G.G. Campbell dated November 25, 1988 (B22 881123 305) Z. D. C. Mims' Memorandum to J. W. Hutton dated July 25, 1989 (R20 890725 999) AA. Torus Integrity Long - Term Program, Plant Unique Analysis Report (CEB 841210 008) BB. Technical Operability Evaluation 2-96-064-0834 (R40 960715 950) CC. Engineering Work Request 98-3-064-071 (R21 980921 003) DD. Technical Operability Evaluation 2-99-064-11704 dated October 18, 1999

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 80 of 166 Appendix D (Page 8 of 9) 3.0 BERGEN-PATERSON TORUS DYNAMIC RESTRAINT HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST 0 N D V

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 81 of 166 Appendix D (Page 9 of 9) 3.0 BERGEN-PATERSON TORUS DYNAMIC RESTRAINT HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued) ITEM DESCRIPTION ITEM DESCRIPTION NO NO 1 RESERVOIR HEAD 31 ROD EYE 2 RESERVOIR CAP 32 LOCK NUT 3 RESERVOIR TUBE 33 MAIN PISTON ROD 4 TIE RODS 34 MAIN CYL. ROD HEAD 5 TIE ROD NUTS 35 ROD HEAD GLAND BUSHING 6 36 MAIN CYL. BASE HEAD 7 37 BASE HEAD GLAND BUSHING 8 INDICATOR ROD 38 ROD HEAD BUSHING RET. RING 9 RESERVOIR PISTON 39 MAIN PISTON RIDER 10 RESERVOIR SPRING SPACER 40 LOCATOR PIN 11 BELLEVILLE SPRING 41 MAIN CYL. BARREL TUBE 12 42 BALL BUSHINGS 13 RESERVOIR PISTON PACKING 43 CAP SCREWS 14 RESERVOIR BLEEDER 44 BASE HEAD BREATHER 15 FILLER FITTING 45 ROD WIPER 16 CAP SCREWS 46 TUBE BLEEDERS 17 VALVE BLOCK 47 ROD SEAL ENERGIZERS 18 48 ROD SEAL V - PACKING 19 49 ROD SEAL BACK- UP RING 20 50 ROD SEAL WAVE SPRING 21 51 ROS SEAL RETAINING RING 22 52 PISTON SEAL ENERGIZERS 23 CAP SCREWS 53 PISTON SEAL V - PACKING 24 CYL. TUBE/HEAD INNER RING 54 PISTON SEAL BACK - UP RING 25 CYL. TUBE/HEAD OUTER RING 55 PISTON SEAL WAVE SPRING 26 RESERVOIR TO HEAD 56 PISTON SEAL RETAINING RING 27 HEAD TO TUBE MANIFOLD 57 ALUMINUM SPACER RING 28 58 POPPET STOP 29 59 POPPET 30 RESERVOIR SEAL 60 POPPET SPRING

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 82 of 166 Appendix E (Page 1 of 5) Lisega Torus Dynamic Restraint Hydraulic Snubbers 1.0 GENERAL DESCRIPTION The mode of operation of these hydraulic shock absorber rests on the fact that, except for a minimal friction, no resistance is offered to a slow movement of the connected components. Under undesirable, shock-type movements resulting from unplanned load conditions the shock absorber locks and forms momentarily an almost rigid connection. The dynamic forces occurring as a result are absorbed and conducted harmlessly into the structural connection. At the reduction of the pressure wave to almost 0, the locking terminates and a possible simultaneous temperature movement is no longer inhibited. During reversal of direction of movement caused by counter-oscillation or renewed impulse, the mode of operation takes place in the reverse direction. It can change infinitely within the frame of complex oscillation spectrums. The response reaction of these shock absorbers lies in a frequency band of 0.5-100 Hz. During slow movement of the piston (*5 4.72 in/min.), spring pressure keeps the valve open, allowing the hydraulic fluid to flow from one side of the piston to the other. During fast movement of the piston (Ž!4.72 in/mmn. approx.), fluid flow pressure on the valve plate closes the main valve. The flow of hydraulic fluid is stopped and the movement of the piston is restricted. The compressibility of the fluid has a softening effect on the restriction of the piston. As fluid is compressed by the piston, the movement is arrested elastically. As a result, damaging load spikes are avoided. As the load subsides, the pressure on the closed valve is reduced. When the force of the spring is greater than the compression force of the fluid, the valve opens. To eliminate any possibility of the valve remaining closed, it is fitted with a by-pass bleed system. This allows a very limited movement of the piston under load, and ensures quick equalization of pressure between the cylinder chambers when the load is removed.

Appendix E (Page 2 of 5) 1.0 GENERAL DESCRIPTION (continued) The position of the main piston within the cylinder car be instantly read by checking the concentric scale rings machined into the piston rod. The sturdy stainless steel shroud protecting the piston rod also duals as a position indicator. In order to maintain the functional performance of the snubber, sufficient hydraulic fluid must be maintained within the unit. The reservoir has a rod attached to the reservoir piston that protrudes from the reservoir. Markings to indicate the fluid level in the unit are scribed onto the rod. Inspection of this indicator eliminates the necessity for dismantling the snubber cylinder to determine the fluid level. 2.0 CONTROL VALVES The control valves are placed in the body of the shock absorber on opposite ends of the cylinder. They are aligned to the reservoir, and work directly with the volume compensator. In order to facilitate scheduled maintenance, the control valves can be removed while the snubber remains in place. Previously qualified and tested valves can be installed immediately and the snubber returned to service. The original valves can then be remotely tested using a surrogate snubber on a standard snubber test bench. 3.0 RESERVOIR In order to accommodate increased fluid volume compensation requirements, the reservoir cylinder is positioned parallel to the working cylinder to avoid disproportionate dimension and weights. The reservoir is sealed against the atmosphere by a spring-loaded piston. While sealing the reservoir, the piston also generates a small amount of pressure within the system. This positive pressure energizes the seals in the snubber, increases their effectiveness and prevents ingestion of air.

Appendix E (Page 3 of 5) 4.0 HYDRAULIC SNUBBER FLUIDS 4.1 General Requirements The fluid in the snubbers should be fire resistant, radiation resistant, have a flat viscosity curve, and be compatible with seal materials such as Viton. The silicon fluid used at BFN for these snubbers is Silicone AP 280 furnished by LISEGA. This fluid is expensive and should be reused when practical. The fluid should NOT get contaminated since it is used under pressure in these snubbers. Partially used containers should be closed with air tight cap to prevent moisture from entering the container.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 85 of 166 Appendix E (Page 4 of 5) 5.0 LISEGA TORUS DYNAMIC RESTRAINT HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST

BFN Snubber Program Procedure 0-TI-398

       .Unit 0                                               Rev. 0005 Page 86 of 166 Appendix E (Page 5 of 5) 5.0        LISEGA TORUS DYNAMIC RESTRAINT HARDWARE AND SOFTWARE PARTS NUMBERS AND PARTS LIST (continued)

ITEM DESCRIPTION ITEM DESCRIPTION NO. NO. 1 TRAVEL INDICATOR TUBE 22 FRONT VALVE SEAT CIRCLIP 2 PROTECTIVE TUBE 23 FRONT LOWER VALVE "O"RING 3 PROTECTIVE TUBE WIPER 24 FRONT VALVE RING 4 THREADED RING (Upper 25 FRONT UPPER VALVE "O"RING Cylinder) 5 CYLINDER BODY LID (Upper 26 FRONT VALVE LID "O"RING Cylinder) 6 COMPLETE ROD SEALING 27 FRONT VALVE LID SET 7 GUIDE BAND 28 RESERVOIR BOTTOM 8 PISTON ROD COMPACT 29 RESERVOIR TUBE SEAL 9 CYLINDER DOUBLE WHIPER 30 CLOSING PISTON RING. 10 MAIN CYLINDER BODY 31 CLOSING PISTON SPRING 11 MAIN CYLINDER PISTON 32 CLOSING PISTON "O"RING 12 MAIN CYLINDER PISTON 33 RESERVOIR PISTON ROD 13 PISTON "O"RING 34 RESERVOIR PISTON GUIDE BAND 14 PISTON SEAL SET 35 RESERVOIR PISTON V-PACKING RING 15 GUIDE BAND 36 RESERVOIR PISTON ROD CIRCLIP 16 REAR VALVE SEAT CIRCLIP 37 RESERVOIR SPRING 17 REAR LOWER VALVE 38 RESERVOIR LID "O"RING 18 REAR VALVE 39 RESERVOIR FLUID INDICATOR ROD 19 REAR UPPER VALVE 40 RESERVOIR FLUID FILL CAP "O"RING 20 REAR VALVE LID "O"RING 41 RESERVOIR DEAERATING VALVE 21 REAR VALVE LID

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 87 of 166 Appendix F (Page 1 of 21) Pacific Scientific Company Mechanical Snubbers

1.0 DESCRIPTION

, DESIGN AND OPERATION OF MECHANICAL SNUBBERS 1.1 General Description Mechanical snubbers are manufactured by Pacific Scientific Company and are designated as PSA. Mechanical snubbers have dual failure modes in that they may either fail to activate or may "freeze" or lockup, becoming a rigid restraint. The PSA snubber is acceleration limiting, and is effective in a seismic event because the motion is cyclic in a frequency range of 3 to 33 Hertz. PSA snubbers operate on the principle of limiting acceleration values of any pipe movement to a threshold level of 0.02 g's (7.7 in/sec squared). This is the maximum acceleration that the snubber will permit, and a breaking force will be applied within the snubber of whatever magnitude is required to limit the acceleration to a value less than 0.02 g's. At the same time, thermal expansion, being a gradual movement, is NOT restricted. A particular feature of mechanical snubbers is that at no time does it lock and become a rigid strut. When sudden acceleration occurs and is sustained continuously in one direction, the snubber will apply necessary force to limit the pipe movement to its preset threshold value. The snubber's performance is independent of the amount of force being applied (provided the force is less than the rated load). BFN purchased all of its PSA snubbers through Bergen-Paterson, therefore, the Bergen-Paterson Part Numbering was primarily used which reflects the rating in KIPS of each snubber. Additionally, a majority of the PSA snubbers were purchased Safety-Related, NF. The PSA Part Numbers differ from the Bergen-Paterson because the snubbers were originally qualified Pre-NF, and given Part Numbers in accordance with that KIP rating. When the same components were re-qualified under NF, their KIP ratings increased but PSA never changed Part Numbers. Only a few PSA-10 snubbers were purchased as Pre-NF. These snubbers are located in all three units and are painted white to distinguish them from the NF snubbers. The Pre-NF snubbers are rated at 10 Kips while the NF snubbers are rated at 15 Kips. They are located on the Main Steam Relief Valve (MSRV) Tail Pipes. When the Pre-NF, 10 Kip, snubbers are replaced in Unit 2, they will be replaced with NF snubbers rated at 15 Kips, by changing the end plug and the rear attachment from the Pre-NF to the new NF snubber.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 88 of 166 Appendix F (Page 2 of 21) 1.2 Pacific Scientific Mechanical Snubber (PSA-1/4 AND PSA-1/2) Design and Operation Following is a description of the design and method of operation of the three versions of the PSA snubbers. Some details of the internal mechanism are different, depending on the capacity of the snubber, but the principle of operation is essentially the same. Figure 1 shows a cross section representing PSA-1/4 and PSA-1/2 snubbers. Also, Figure 2 shows the part numbers of the snubbers. The snubber consists essentially of an inertia mass containing a clutch spring, a torque carrier and screw shaft assembly which also contains a capstan spring, a rod and bearing assembly, an inner tube, an anti-rotation key, a housing and a telescoping outer tube. The rod and bearing assembly consists of a spherical bearing, end plug, two connecting rods and a helical cam bearing. The helical cam bearing end of the rod and bearing assembly engages the screw shaft of the torque carrier and shaft assembly. The shaft mounts the inertia mass, inside which is installed the clutch spring. The tangs of the capstan spring installed in the torque carrier are positioned between the lips of the clutch spring installed in the inertia mass. In this manner, the torque carrier is coupled to the inertia mass. The housing is secured by a retaining ring to the flange on the end of the inner tube. The housing shields the internal parts of the arrestor and prevents contaminants from entering. The restricting function of the snubber is primarily accomplished by changing the relative linear motion, of the telescoping inner and outer tubes of the snubber, into rotary motion of the torque carrier and the inertia mass. Figure 1 shows the snubber almost fully retracted. As the snubber is extended, the outer cylinder attached to the spherical bearing end, slides over the inner cylinder which is attached to the housing. The nut is attached to the spherical bearing end by the two rods. As the nut moves with the spherical bearing and, it forces the shaft screw to turn which makes the torque carrier spin, since they have a press fit. The capstan spring rotates with the torque carrier, and the tangs of the capstan spring also drive the inertia mass through engagement with the up-turned ends of the clutch spring. Ifthe speed of the torque carrier is changed, the speed of the inertia mass must also change since they are connected by the tangs of the capstan spring.

Appendix F (Page 3 of 21) 1.2 Pacific Scientific Mechanical Snubber (PSA-1/4 AND PSA-1/2) Design and Operation (continued) If the speed change is made suddenly, the inertia mass, by tending to stay at its existing speed, will overcome the capstan spring resistance and close it down on the end of the inner cylinder which is stationary in the housing. The spring in contact with the inner cylinder acts as a brake and slows the change in speed of the torque carrier as it is driven by the nut moving, as the snubber is extended. The same type of action takes place as the snubber is retracted. By this action the snubber limits the rate of velocity change or acceleration. Vibrations cause rapid changes in direction and velocity which activate the snubber by causing the capstan spring to close down on the end of the inner cylinder.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 90 of 166 Appendix F (Page 4 of 21) 2.0 PSA-1/4 AND PSA-1/2 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST RING KEEPERS BEARINGý ANTI-ROTATION INSERT

ROD AND BEARING ASSEMBLY [ CAPSTAN SPRING BALL RETAINING RETAINING.

PLAY E RING

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 91 of 166 Appendix F (Page 5 of 21) 2.0 PSA-1/4 AND PSA-1/2 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued)

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 92 of 166 Appendix F (Page 6 of 21) 2.0 PSA-1/4 AND PSA-1/2 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & USABLE INDEX PART NO. DESCRIPTION ON NO. CODE 1801104-05 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-1/4 A 1801104-07 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-1/2 B 1 0911100-89 RING, RETAINING A,B 2 1801247-01 TUBE, OUTER A 1801247-03 TUBE, OUTER B 3 0911100-90 RING, RETAINING A,B 4 1801900-01 HOUSING AND INSERT ASSEMBLY A,B 5 1801367-01 BALL A,B 6 0903100-36 WASHER A,B 7 0903100-37 WASHER A,B 8 1801241-01 INTERIA MASS A,B 9 1801537-01 RING, KEEPER A,B 10 1801612-01 SPRING, CAPSTAN A,B 11 1801537-01 RING, KEEPER A,B 12 1801305-01 SPRING, CLUTCH A,B 13 0903100-50 WASHER, FLAT A,B 14 1801861-01 CARRIER AND SHAFT ASSEMBLY, TORQUE A 1801862-01 CARRIER AND SHAFT ASSEMBLY, TORQUE B 15 0911100-91 RING, RETAINER A,B 16 1801306-01 WASHER, SUPPORT A,B 17 1801303-01 KEY, ANTI-ROTATION A,B 18 0911100-08 RING, RETAINING A,B 19 1801533-01 ROD AND BEARING ASSEMBLY A 1801533-03 ROD AND BEARING ASSEMBLY B 20 NAS671-8 NUT, JAM A,B 21 MS35335-31 WASHER, LOCK A,B 22 1801311-01 BEARING, PIVOT A,B 23 1801367-01 BALL A,B 24 1801252-01 GUIDE PLATE A,B 25 1801250-01 TUBE, INNER A 1801250-03 TUBE, INNER B 26 AN535-2-2 SCREW, DRIVE A,B 27 1801301-01 NAMEPLATE A,B

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 93 of 166 Appendix F (Page 7 of 21) 2.1 Pacific Scientific Mechanical Snubber (PSA-1, PSA-3 AND PSA-10) Design and Operation Figure 3 is a cross section that represents the PSA-1, PSA-3, and PSA-10 snubbers. Also, Figure 4 shows the part numbers of the snubbers. The snubbers consists of a support cylinder, an inertia mass containing a clutch spring, a torque transfer drum containing a capstan spring, an end plug assembly, a position indicator tube, and a housing. The support cylinder contains a telescoping cylinder, and anti-rotation key, and a ball bearing screw assembly. The telescoping cylinder and recirculating ball nut and screw assembly are the main design concept difference from the PSA-1/4 and PSA-1/2. The ball screw is supported by the traveling recirculating ball nut and by a ball bearing assembly near one end. The recirculating ball nut is staked to and travels with the telescoping cylinder, as do the end plug assembly and the position indicator tube. The ball screw shaft extends through the thrust bearing fitted into the bore of the support cylinder. The ball screw shaft mounts through the torque drum and inertia mass and is keyed to the torque drum and the inner race of the thrust bearing. The inertia mass is free to rotate on the end of the ball screw shaft. The tangs of the capstan spring installed in the torque drum extend through a slot in the torque drum and are located between the up-turned ends of the clutch spring installed in the inertia mass. This couples the torque drum to the inertia mass. The housing is attached by a retaining ring to a flange at the capstan end of the support cylinder. The housing and a dust cover shield the internal parts of the arrestor and prevent contaminants from entering. The restraining function of the PSA-1, -3, and

     -10 snubbers is accomplished by translating linear motion of the telescoping cylinder, within the support cylinder, into rotary motion of the torque drum and the inertia mass. As the snubber is extended or retracted, the telescoping cylinder moves inside the support cylinder. The recirculating ball nut is fixed to the telescoping cylinder, and the telescoping cylinder is prevented from rotating by the anti-rotation key attached to the stationary support cylinder. Therefore, as the recirculating ball nut is moved in or out with the telescoping cylinder, the ball screw is forced to rotate, and the torque drum spins with it. The tangs of the capstan spring drive the inertia mass, and if the speed is changed gradually, the spring does NOT tighten down on the end of the support cylinder. Ifthe speed changes suddenly, either slowing down or increasing, the inertia mass displaces the tangs of the capstan spring and closes the spring down on the end of the support cylinder, acting as a brake. The arresting action of the snubber is essentially the same as for the PSA-1/4 and PSA-1/2.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 94 of 166 Appendix F (Page 8 of 21) 3.0 PSA-1, PSA-3 AND PSA-10 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST ANTI4ROTATION KEY PRECISION END PLUG POSfTION INDICATOR LEAD IRETAINING HOU31NG WUT CLUTCH ASSEMBLY TUBE I& INTERLA MASS MACHINE KEY SPHERICAL SUPPORT TELESCOPING CYLINDER BEARING CYLINDER CAPSTAN TORQUE

                                                           $PRNG      DRUM I             THRUST RECIRCULATING          BEARING BALL ASSEMBLY

Appendix F (Page 9 of 21) 3.0 PSA-1, PSA-3 AND PSA-10 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) S. I

                                                   '3
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BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 96 of 166 Appendix F * (Page 10 of 21) 3.0 PSA-1, PSA-3 AND PSA-10 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & USABLE INDEX PART NO. DESCRIPTION ON NO. CODE 1801102-05 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-1 A 1801106-05 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-3 B 1801103-07 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-10 C 1 0911100-84 RING, RETAINING A 0911100-80 RING, RETAINING B 0911100-96 RING, RETAINING C 2 1801232-01 COVER, DUST A 1801260-01 COVER, DUST B 1801217-01 COVER, DUST C 3 AN503-8-4 SCREW, FILLISTER HEAD A AN501A10-4 SCREW, FILLISTER HEAD B AN501A10-5 SCREW, FILLISTER HEAD C 4 AN960-8 WAHSER, FLAT A AN960-1OL WASHER, FLAT B,C 5 1801238-05 TUBE, POSITION INDICATOR A 1801267-05 TUBE, POSITION INDICATOR B 1801216-05 TUBE, POSITION INDICATOR C 6 0911100-98 RING, RETAINING A 0911100-81 RING, RETAINING B 0911100-97 RING, RETAINING C 7 1801281-05 HOUSING A 1801274-05 HOUSING B 1801360-07 HOUSING C 8 0911100-111 RING, RETAINING A 0911100-110 RING, RETAINING B 0911100-109 RING, RETAINING C 9 0903100-41 WASHER, FLAT A 0903100-33 WASHER, FLAT B 0903100-39 WASHER, FLAT C 10 0903100-23 WASHER, FLAT A 0903100-33 WASHER, FLAT B 0903100-38 WASHER, FLAT C 11 1801224-03 INERTIA MASS A 1801276-01 INERTIA MASS B

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 97 of 166 Appendix F (Page 11 of 21) 3.0 PSA-1, PSA-3 AND PSA-10 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & USABLE INDEX PART NO. DESCRIPTION ON NO. CODE 1801205-01 INTERIA MASS C 12 1801288-01 SPRING, CLUTCH A 1801272-01 SPRING, CLUTCH B 1801201-01 SPRING, CLUTCH C 13 0903100-41 WASHER, FLAT A 0903100-33 WASHER, FLAT B 0903100-39 WASHER, FLAT C 14 0911100-99 RING, RETAINING A 0911100-100 RING, RETAINING B 0911100-101 RING, RETAINING C 15 903100-42 WASHER, FLAT A AN960-716 WASHER, FLAT B 903100-43 WASHER, FLAT B 903100-45 WASHER, FLAT C 16 1801218-03 DRUM, TORQUE A 1801275-03 DRUM, TORQUE B 1801206-01 CARRIER, TORQUE C 17 1801538-01 RING, KEEPER A 1801539-01 RING, KEEPER B 1801540-01 RING, KEEPER C 18 1801613-01 SPRING, CAPSTAN A 1801614-01 SPRING, CAPSTAN B 1801615-01 SPRING, CAPSTAN C 19 1801538-01 RING, KEEPER A 1801539-01 RING, KEEPER B 1801540-01 RING, KEEPER C 20 1801235-01 NUT, BEARING RETAINER A 1801262-01 NUT, BEARING RETAINER B 1801214-01 NUT, BEARING RETAINER C

21. 1801236-01 RACE, THRUST OUTER A (FOR REPLACEMENT ORDER KIT NO. 1811041-01) 1811041-*01 KIT, THRUST BEARING A (REPLACEMENT FOR PART NO. 1801236-01) 1801442-01 RACE ASSEMBLY, OUTER B (FOR REPLACEMENT ORDER KIT NO. 1811042-01

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 98 of 166 Appendix F (Page 12 of 21) 3.0 PSA-1, PSA-3 AND PSA-10 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & USABLE INDEX PART NO. DESCRIPTION ON NO. CODE 1811042-01 KIT, THRUST BEARING B (REPLACEMENT FOR PART NO. 1801442-01) 1801443-01 RACE ASSEMBLY, OUTER C (FOR REPLACEMENT ORDER KIT NO. 1811043-01 1811043-01 KIT, THRUST BEARING C (REPLACEMENT FOR PART NO. 1801443-01) 22 1801493-02 BALL (0.1860 INCH/40724 MM DIAMETER) A (INCLUDED IN KIT NO. 1811041-01) 1801493-03 BALL (0.1865 INCH/40737 MM DIAMETER) A (INCLUDED IN KIT NO. 1811041-01) 1801493-02 BALL (0.1860 INCH/40724 MM DIAMETER) B (INCLUDED IN KIT NO. 1811042-01) 1801493-03 BALL (0.1865 INCH/40737 MM DIAMETER) B (INCLUDED IN KIT NO. 1811042-01) 1801493-02 BALL (0.1860 INCH/40724 MM DIAMETER) C (INCLUDED IN KIT NO. 1811043-01) 1801493-03 BALL (0.1865 INCH/40737 MM DIAMETER) C (INCLUDED IN KIT NO. 1811043-01) 23 0911100-82 RING, RETAINER A,B,C 24 AN565B8H3 SETSCREW A AN565B1032H4 SETSCREW B AN565B1032H3 SETSCREW C 25 1801860-01 PLUG ASSEMBLY, END A 1801858-01 PLUG ASSEMBLY, END B 1801856-01 PLUG ASSEMBLY, END C 26 1801227-01 CYLINDER, TELESCOPING A 1801270-01 CYLINDER, TELESCOPING B 1801211-01 CYLINDER, TELESCOPING C 27 1801382-01 SCREW ASSEMBLY, BALL BEARING A 1801324-01 SCREW ASSEMBLY, BALL BEARING B 1801384-01 SCREW ASSEMBLY, BALL BEARING C 28 1801287-01 KEY, MACHINE A 1801280-03 KEY, MACHINE B 1801298-01 KEY, MACHINE C 29 1801230-01 RACE, INNER THRUST A (FOR REPLACEMENT ORDER KIT NO. 1811041-01)

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 99 of 166 Appendix F (Page 13 of 21) 3.0 PSA-1, PSA-3 AND PSA-10 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & USABLE INDEX PART NO. DESCRIPTION ON NO. CODE 1811041-01 KIT, THRUST BEARING A (REPLACEMENT FOR PART NO. 1801230-01) 1801264-01 RACE, INNER THRUST B (FOR REPLACEMENT ORDER KIT NO. 1811042-01) 1811042-01 KIT, THRUST BEARING B (REPLACEMENT FOR PART NO. 1801264-01) 1801391-01 RACE, INNER THRUST C (FOR REPLACEMENT ORDER KIT NO. 1811043-01) 1811043-01 KIT, THRUST BEARING C (REPLACEMENT FOR PART NO. 1801391-01) 30 MS24694-S1 SCREW, FLATHEAD A,B MA24694-S92 SCREW, FLATHEAD C 31 MS35790-9 WASHER, LOCK A,B MS35790-25 WASHER, LOCK C 32 1801234-01 KEY, ANTI-ROTATION A 1801265-01 KEY, ANTI-ROTATION B 1801212-01 KEY, ANTI-ROTATION C 33 1801226-01 CYLINDER, SUPPORT A 1801277-01 CYLINDER, SUPPORT B 1801210-01 CYLINDER, SUPPORT C 34 AN535-2-2 SCREW, DRIVE A,B,C 35 1801301-01 NAMEPLATE A,B,C

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 100 of 166 Appendix F (Page 14 of 21) 3.1 Pacific Scientific Mechanical Snubber (PSA-35 AND PSA-100) Design and Operation Figure 5 is a cross section that represents the PSA-35, and PSA-100 snubbers. Also, Figure 6 shows the part numbers of the snubbers. The PSA-35 and PSA-100 snubbers are the largest capacity Pacific Scientific snubbers manufactured. Their external configuration is similar but distinctive from other PSC snubbers. In addition to being much larger, the outside diameter is essentially the same throughout its length. The snubber consists of a support cylinder assembly, torque carrier assembly, an inertia mass assembly, an adapter nut or transition tube, an end cap assembly, and end cap nut, and a position indicator tube. A dust cover is installed in the adapter nut, or transition tube, to prevent contaminants from entering the arrestor internal mechanisms. The support cylinder assembly includes a support cylinder, a telescoping cylinder, a capstan spring, a recirculating ball assembly, ball bearings, a system of planetary gears, a ring gear and a housing. The recirculating ball assembly is attached to and travels with the telescoping cylinder, as do the externally mounted end cap assembly, end cap nut and indicator tube. The opposite end of the recirculating ball assembly is keyed to the inner race of the thrust bearing assembly which is coupled to the planetary gear system. The outer race of the ball bearing and the ring gear are fitted into the bore of the support cylinder housing. This arrangement translates rotation of the precision ball screw into rotation of the planetary gears. The capstan and an internally mounted ball bearing are installed in the support cylinder housing at the output side of the planetary gear system. The capstan is keyed to the housing and does NOT rotate. Installed in the support cylinder housing, but NOT part of the support cylinder assembly, are a torque carrier assembly, an inertia mass assembly and a capstan spring. The pinion gear of the torque carrier assembly engages the planetary gears. The hub of the torque carrier is supported by the internal bearing of the capstan. The capstan spring is internally contained in the torque carrier shell and rotates with the torque carrier. The hub of the inertia mass assembly is supported in a needle bearing installed in the torque carrier assembly. A clutch spring is installed in the bore of the inertia mass assembly. The lips of the clutch spring are centered on the slot in the inertia mass shell. The tangs of the capstan spring are centered between the lips of the clutch spring. In this manner, the torque carrier assembly is coupled to the inertia mass assembly.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 101 of 166 Appendix F (Page 15 of 21) 3.1 Pacific Scientific Mechanical Snubber (PSA-35 AND PSA-100) Design and Operation (continued) The operation of these larger size PSA's is generally the same as for the other sizes as described. The use of the planetary gear system permits the use of a reasonable size inertia mass because the gear system rotates the mass at a greater speed than the ball screw turns. The restraining function of the PSA-35 and -100 snubbers is accomplished by translating linear motion of the telescoping cylinder, within the support cylinder assembly, into rotary motion of the output gear train, the torque carrier assembly and the inertia mass assembly. As the snubber is extended or retracted, the telescoping cylinder moves inside the support cylinder. The recirculating ball assembly is fixed to the telescoping cylinder, and the telescoping cylinder is prevented from rotating by the anti-rotation key attached to the stationary support cylinder. Therefore, as the recirculating ball assembly is moved in or out with the telescoping cylinder, the ball screw is forced to rotate, and the torque carrier spins with it. The tangs of the capstan spring drive the inertia mass, and if the speed is changed gradually, the spring does NOT tighten down on the end of the support cylinder. If the speed changes suddenly, either slowing down or increasing the inertia mass displaces the tangs of the capstan spring and closes the spring down on the end of the support cylinder, acting as a brake. The arresting action of the snubber is essentially the same as for all the other PSA mechanical snubbers.

Appendix F (Page 16 of 21) 4.0 PSA-35 AND PSA-100 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST

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BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 103 of 166 Appendix F (Page 17 of 21) 4.0 PSA-35 AND PSA-100 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued)

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 104 of 166 Appendix F (Page 18 of 21) 4.0 PSA-35 AND PSA-100 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & PART NO. DESCRIPTION USABLE INDEX ON NO. CODE 1801112-09 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-35 A 1801112-11 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-35 B 1801112-13 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-35 C 1801119-09 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-100 D 1801119-11 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-100 E 1801119-13 ARRESTOR, MECHANICAL SHOCK, MODEL PSA-100 F 1 AN501-416-8 SCREW, FILISTER HEAD A,B,C AN501-561-10 SCREW, FILISTER HEAD D,E,F 2 AN960-416L WASHER, FLAT A,B,C AN960-516L WASHER, FLAT D,E,F 3 1801455-03 TUBE, INDICATOR A,B,C 1801438-03 TUBE, INDICATOR D,E,F 4 1801506-05 NUTADAPTER A 1801506-07 NUT,ADAPTER B 1801507-05 NUT,ADAPTER D 1801507-07 NUT,ADAPTER E 5 1801480-01 TUBE, TRANSITION C 1801478-01 TUBE, TRANSITION F 6 1801497-01 WASHER, LOCKING A,B,C 1801526-01 WASHER, LOCKING D,E,F 7 0911100-80 RING, RETAINING A,B,C 0911100-106 RING, RETAINING D,E,F 8 1801260-01 COVER, DUST A,B,C 1801217-03 COVER, DUST D,E,F 9 MS24665-152 PIN, COTTER ALL 10 AN310-4 NUT, CASTELLATED ALL 11 AN960-416 WASHER, FLAT A,B,C AN960-416L WASHER, FLAT D,E,F 12 1801868-01 INTERIA MASS ASEMBLY A,B,C 1801863-01 INTERIA MASS ASEMBLY D,E,F 13 0903100-45 WASHER D,E,F 14 1801867-01 CARRIER ASSEMBLY, TORQUE A,B,C 1801865-01 CARRIER ASSEMBLY, TORQUE D,E,F 15 0903100-48 WASHER, (PSA-35) A,B,C 1801524-01 RING, WEAR, (PSA-100) D,E,F 16 1801540-01 RING, KEEPER A,B,C 1801611-01 RING, KEEPER D,E,F 17 1801615-01 SPRINGCAPSTAN A,B,C 1801617-01 SPRING, CAPSTAN D,E,F 18 1801540-01 RING, KEEPER A,B,C 1801611-01 RING, KEEPER D,E,F 19 1801546-03 CAP ASSEMBLY, END A,B,C 1801545-03 CAP ASSEMBLY, END D,E,F

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 105 of 166 Appendix F (Page 19 of 21) 4.0 PSA-35 AND PSA-100 CROSSSECTION, HARDWARE PARTS NUMBERS AND HARDWARE PARTS LIST (continued) FIG & PART NO. DESCRIPTION USABLE INDEX ON NO. CODE 20 1801451-03 NUT, END CAP A,B,C 1801432-03 NUT, END CAP D,E,F 21 1801457-77 CYLINDER ASSEMBLY, SUPPORT A,B,C 1801430-77 CYLINDER ASSEMBLY, SUPPORT D,E,F 22 AN535-2-2 SCREW, DRIVE ALL 23 1801301-01 NAMEPLATE ALL 24 1801201-01 SPRING, CLUTCH A,B,C 1801409-01 SPRING, CLUTCH D,E,F 25 1801670-01 THRUST BEARING ASSEMBLY (KIT) A,B,C 1801673-01 THRUST BEARING ASSEMBLY (KIT) D,E,F 26 1801465-01 PLANETARY GEARS A,B,C 1801419-01 PLANETARY GEARS D,E,F 27 1801734-01 RECIRCULATION BEARING ASSEMBLY A,B,C 1801671-01 RECIRCULATION BEARING ASSEMBLY D,E,F 28 1801521 BEARING BALLS A,B,C 1801525 BEARING BALLS D,E,F 29 1801456-01 TELESCOPING CYLINDER A,B,C, 1801434-01 TELESCOPING CYLINDER D,E,F 30 1801453-77 HOUSING ASSEMBLY A,B,C 1801428-77 HOUSING ASSEMBLY D,E,F 31 AN565DC524H5 SETSCREW ALL 32 AN565-E428H4 SET SCREW A,B,C AN565-E524H5 SET SCREW D,E,F 33 1801477-03 LOCKING RING A,B,C 1801445-03 LOCKING RING D,E,F 34 1801458-01 CAPSTAN A,B,C 1801421-01 CAPSTAN D,E,F 35 1801466-01 RING GEAR A,B,C 1801420-01 RING GEAR D,E,F 36 1801476-01 WASHER PLATE A,B,C 1801440-01 WASHER PLATE D,E,F 37 MS20066-A-353 THRUST BEARING MACHINE KEY AB.C MS20066-A-256 THRUST BEARING MACHINE KEY D,E,F

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 106 of 166 Appendix F (Page 20 of 21) 5.0 THE TYPES AND SIZES FOR THE MECHANICAL SNUBBERS:

• PSA-1/4, 0.35 Kips, 4 inch stroke (Bergen-Paterson part number 2540-.35 or 2410-.35).
• PSA-1/2, 0.65 Kips, 2.5 inch stroke (Bergen-Paterson part number 2540-.65 or 2410-.65).
• PSA-1, 1.5 Kips, 4 inch stroke (Bergen-Paterson part number 2540-1.5 or 2410-1.5).
• PSA-3, 6 Kips, 5 inch stroke (Bergen-Paterson part number 2540-6 or 2410-6).
• PSA-10, 10 Kips, 6 inch stroke (Located in Unit 2 only. Pre-NF design NOT manufactured any longer)

PSA-1 0,.15 Kips, 6 inch stroke (Bergen-Paterson part number 2540-15 or 2410-15). PSA-35, 50 Kips, 6 inch stroke (Bergen-Paterson part number 2540-50 or 2410-50). PSA-100, 120 Kips, 6 inch stroke (Bergen-Paterson part number 2540-120 or 2410-120). 6.0 TEST PARAMETERS IN THE SNUBBER TEST MACHINE PROGRAM: The following parameters shall be verified to work on the test machine, with the associated snubbers, and the accompanying plot shall be located as close to the center of the graph as possible. Ifthe plot does NOT show in the center of the graph the following parameters may be changed to center the plot and give the best looking plot available. Valve Open - This value is in percent of command output. If the operator wishes to start the valve sooner the percent value may be reduced, which will require the valve to open sooner causing the command ramp to "jump" up to an initial value and overcome the dead band.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 107 of 166 Appendix F (Page 21 of 21) 6.0 TEST PARAMETERS IN THE SNUBBER TEST MACHINE PROGRAM: (continued) Valve End - The valve end value allows the operator to set an endpoint for the proportional valve opening at less than 100 percent full open. If the operator wishes the profile to extend or reduce this value should be increased or decreased, as necessary. This value has to be controlled enough that the snubber will activate, prior to the end of the test. This value controls the ramp profile in the activation tests.

         "    Ramp Duration - This value sets the time duration of the ramp between valve start and valve end. This value may be decreased, which moves the plot to the left on the graph. In the acceleration tests this value is limited to.45 sec maximum.

• Load Duration - This is the time that the valve will remain at the valve end position, after the ramp time has elapsed. Adjusting this value "up" will assure that the complete test will show on the graph.

TPYE PSA 1/4 PSA 1/2 PSA 1 PSA 3 PSA PSA PSA 10 35 100 KIP RATING .35 .65 1.5 6 15 50 120 STROKE 2.5 2.5 4 5 6 6 6 ACTIVATION RATE 0 0 0 0 0 0 0 RELEASE RATE 0 0 0 0 .0 0 0 ACCELERATION RATE .02 .02 .02 .02 .02 .02 .02 DRAG FORCE LIMIT 5 5 5 5 5 5 5 TEST LOAD 60 60 50 60 60 50 50 PRESSURE BOOST 100 100 100 100 120 100 100 VALVE START 0 *0 0 0 0 0 0 VALVE END 100 100 100 100 100 100 100 DRAG SPEED 2 2 2 2 2 2 2 RAMP DURATION .35 .35 .25 .25 .24 .35 .35 LOAD DURATION .35 .35 .25 .25 .24 .35 .35 BENCH (B)IG/(S)MALL S S S S B B B

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 108 of 166 Appendix G (Page 1 of 14) Service Life Monitoring Recommendations Service life monitoring enables plant personnel to gain knowledge of the plant's operating environment and the associated capabilities of snubbers. Service life monitoring also helps to identify and control problem applications and establish practical scheduled maintenance intervals based on realistic expectations of snubber aging. Current practices call for periodic visual examinations and functional testing of both hydraulic and mechanical snubbers. Visual examination of 100% of all safety-related snubbers is performed on a standard inspection interval controlled by NRC Generic Letter 90-09. The inspection interval may be shortened or lengthened depending on the number of inoperable snubbers found. The examination plan assumes a constant frequency of occurrence of snubber failures and is intended to ensure that no more than one snubber is inoperable at a given time. A plant can either maintain a low snubber failure rate or inspect snubbers more frequently. Current practices also call for testing of a sample batch of snubbers during each operating cycle. Testing of an additional sample for each inoperable snubber is also normal practice. In contrast to the visual examination plan, the functional test plan is NOT time-related. It simply ensures a given snubber operability level at the time the testing is completed. As plant specific knowledge of snubber aging is gained through effective service life monitoring, it is anticipated that less emphasis will be placed on such statistical plans. Our Technical Requirements Manual does NOT require a specific service life monitoring program to be established. This is handled by our functional testing, visual examinations and other maintenance history for the snubbers. The ASME OM Code (Subsection ISTD) and NRC NUREG/CR-5870 give recommendations for establishing a service life monitoring program. Snubbers located in isolated severe environments should be separated from the general population and managed on a case-by-case basis. It may be desirable to group the general snubber population into two or more sub-populations with separate service lives. 1.0 PURPOSE Degradation due to service environment and maintenance errors can adversely affect snubber performance. This Appendix discusses methods and considerations that can be used to predict and reevaluate snubber service life to optimize snubber availability during plant operation. A service life monitoring program should be based on knowledge of the operating environment, snubber design limits and service record.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 109 of 166 Appendix G (Page 2 of 14) 2.0 PREDICTED SERVICE LIFE Before entering a snubber into service, its service life should be conservatively predicted, based on manufacturer recommendations and design review. Manufacturer recommendations may include seal and fluid replacement intervals for hydraulic snubbers and critical parts or snubber replacement intervals for mechanical snubbers. Such intervals may vary, depending on the application. Snubber design review should consider materials, design features and the plant operating environment. Evaluation of the effects of the environment on critical snubber parts such as seals, hydraulic fluid, lubricants, platings, etc., should be particularly emphasized. 3.0 SERVICE LIFE REEVALUATION Service life reevaluation should include the following considerations. 3.1 Knowledge, Determination and Documentation of the Operating Environment Service life monitoring takes into consideration the capability of the various snubber models to endure the full range of plant environments. Actual plant operating environments can differ significantly from the original plant design specifications. Some snubbers may be subjected to localized high temperatures that are NOT representative of the general snubber population. Such applications may require augmented inspections or more frequent snubber overhaul or replacement than originally predicted. Indicators of severe operating conditions can often be identified during snubber overhauls and other maintenance related activities. The operating environment for the majority of snubbers may be significantly less severe than described in the plant design specifications. Therefore, unnecessary overhauls or replacements may increase the number of failed or degraded snubbers due to handling or maintenance errors.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 110 of 166 Appendix G (Page 3 of 14) 3.1 Knowledge, Determination and Documentation of the Operating Environment (continued) It is important that the operating environment be identified and appropriate maintenance intervals established for the various snubber applications in the plant and appropriate applicable service life established. Environmental parameters may include the following:

• temperature
• vibration
• transient loading
• radiation

     "      humidity
     "      airborne contaminants (e.g., sand and dusts)

• leakage of adjacent pipes or equipment Severe environments may be identified by plant operating data, direct measurement of environmental parameters, evaluation of installed location (e.g., proximity to high temperature components) or by examination of snubbers (or snubber parts).

Determining specific environmental information often involves specialized instrumentation and equipment that would be impractical for use at every snubber location. Such equipment should be used in applications where moderate to severe environments are anticipated or as a diagnostic aid in determining the cause of snubber degradation or failure.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 111 of 166 Appendix G (Page 4 of 14) 3.1.1 Direct Measurement of Environmental Parameters Various types of instrumentation and equipment are available for direct measurement of environmental parameters such as temperature, vibration, radiation and humidity. Such equipment may be used for specific snubber locations where severe environments are expected or as an aid in determining the cause of snubber degradation. A. Temperature Continuous temperature recording devices are available to indicate the general area temperatures within the plant (which often vary by elevation) or to measure local snubber or component temperatures. Temperature sensitive tape may be placed directly on the snubber to determine the maximum temperature. One shortcoming of this approach is that a time/temperature profile is NOT provided. Contact and non contact temperature devices (e.g., infrared type) are also available. B. Radiation Normal radiation levels of an operating plant do NOT usually contribute significantly to snubber degradation. This is probably due to the following considerations:

1. actual in-plant radiation levels are, in most cases, less than was originally anticipated

2. the snubber body provides a significant amount of shielding

3. originally anticipated radiation effects were based upon 40-year dose; in actuality, snubber parts that are sensitive to radiation degradation are replaced at intervals that are significantly less than 40 years.

Data pertaining to plant radiation levels can generally be obtained from Radiological Control area surveys. Measurements of radiation levels specifically for service life monitoring is NOT recommended except in evaluating the cause of snubber degradation in cases where other causes have been ruled out.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 112 of 166 Appendix G (Page 5 of 14) 3.1.1 Direct Measurement of Environmental Parameters (continued) C. Vibration Vibration may be continuous, in which case snubbers may degrade in as little time as one operating cycle. Vibration may also be intermittent (e.g., during pump startup), in which case it may be undetected for long periods and result in long-term degradation of the snubber. The available methods for detecting and measuring vibration vary from simple visual observation, detection by feel, portable vibration measuring instrumentation and remote vibration measuring equipment. Snubbers subject to vibration can often be detected by visual examination. Metal filings, darkened hydraulic fluid, deformed connecting pins, elongated attachment holes and fretting of mating parts are all signs of vibration effects. D. Transients As with vibration, the existence of dynamic load transients may be identified during routine snubber inspections, augmented inspections and failure evaluation. Deformed structural members, jammed snubbers and deformed internal parts are all potential indicators of dynamic overloading. Inplace devices such as load measuring clevis pins are available for monitoring snubber loads where such transients are suspected. 3.2 Knowledge of Operating Environment Effects Reevaluation of a snubber service life should include a thorough knowledge of the effects of various operating environments on snubber performance. Such knowledge may NOT be readily available from the manufacturer and may require engineering evaluation, including monitoring of trendable degradation parameters for snubbers removed from service. This might include periodic measurement of potentially trendable test parameters (e.g., drag force) for selected snubbers. Periodic disassembly and evaluation of snubber internal parts (e.g., seals, springs, fluid, etc.) may also be required. Degraded snubbers may be identified by visual examination of snubbers or their parts, by sampling of hydraulic fluid or evaluation of characteristics including time traces (e.g., load and velocity), obtained during testing.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 113 of 166 Appendix G (Page 6 of 14) 3.2.1 Managing Snubbers in Severe Operating Environments Significant environmental stressors that can effect snubber performance include overloading, vibration, elevated temperature, moisture, chemicals and radiation. Snubbers operating in severe environments can be identified as plant operation continues. Such applications are often NOT identified until the snubbers are functionally tested. This supports the need for some random functional testing, but the extent of functional testing required by the Technical Requirements Manual may NOT be necessary as plants gain empirical knowledge pertaining to the plant operating environments and the associated snubber capabilities. Snubber failures involving severe operating environments may be mitigated by conducting augmented inspections, periodic maintenance, periodic replacement with like kind, retrofitting with snubbers more suitable for the environment or eliminating the snubber by approved engineering analysis methods. 3.2.2 Augmented Surveillance Practices A number of practices may be used for evaluating snubbers for degradation and identifying operating environments. Since evaluation methods often do NOT employ quantifiable parameters, judgment is required on the part of the evaluating person. Experience of the evaluating person is therefore important. A. Hand Stroking Probably the most common "hands-on" evaluation method is hand stroking of mechanical snubbers. This method is often used to identify snubbers that are damaged or jammed due to transients. In using this method, the evaluating person removes the connecting pin at one end of the snubber and slowly strokes the snubber while feeling and listening for abnormalities such as intermittent or continuous excess noise or resistance. Using this method, an experienced person can often identify impending failure. An example, during hand stroking of a mechanical snubber, is periodic resistance accompanied by a chaffing sound for each revolution of the inertia mass. This indicates binding caused by lack of concentricity of the rotating parts. Irregular, intermittent noise and resistance indicates surface discontinuities on the lead screw.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 114 of 166 Appendix G (Page 7 of 14) 3.2.2 Augmented Surveillance Practices (continued) B. Rotation of Snubbers in Place Jammed snubbers (i.e., snubbers unable to allow free thermal motion) may often be identified by attempting to rotate the snubber about its spherical end attachment bearings. If the snubber is NOT free to rotate, it is possible that axial loading exists, resulting in jamming or premature lockup. It should be noted that this method is most effective for snubbers with a load capacity of 3,000 lbs. or less. Normal friction in the bearings often prevents rotation of larger sizes. C. Hand Detection of Vibration Hand detection of vibration, by placing a hand on the snubber during operation, is a useful technique for evaluating accessible snubbers. D. End of Outage Examination Just prior to startup, reinspection of snubbers that are susceptible to damage due to outage-related activities will reduce the probability of plant operation with inoperable snubbers. Future verification that consequent failures were NOT the result of service-related influences would be more difficult.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 115 of 166 Appendix G (Page 8 of 14) 3.2.3 Trending Progressive degradation, in the general snubber population (i.e., those snubbers NOT subject to rapid degradation), should be monitored by trending applicable degradation parameters for a selected number of snubbers that are representative of the plant operating environment. Some important considerations in this regard are listed below:

       "     The establishment of baseline data is essential for identifying trends. Data to be used for identifying trends should be sufficiently accurate to demonstrate trends.

• Trending parameters that relate directly to the anticipated aging failure mode should be used. Such degradation parameters might include compression set for elastomeric seals for hydraulic snubbers or average drag force for mechanical snubbers.

An inappropriate monitoring parameter is the use of functional test data,(i.e., locking velocity and release rate) for monitoring or trending of seal degradation. Although functional test results can be affected to some extent by seal degradation, the primary aging failure mode for snubber seals (i.e., loss of low pressure seal integrity) would NOT be reflected in the functional test data.

• Acceleration threshold (activation velocity) in acceleration-limiting mechanical snubbers is a potentially trendable parameter that may indicate internal snubber degradation. A decreasing acceleration threshold may indicate internal corrosion or internal friction between the inertia mass and its spindle.

An increasing acceleration threshold may indicate weakening of the capstan spring tangs as a result of wear or a decrease in friction between the capstan spring and its braking surface.

• Although changes in active hydraulic snubber parameters [i.e., locking velocity and bleed(release) rate] can indicate snubber degradation, these parameters are NOT considered practical trending parameters for monitoring progressive degradation.
• Reservoir fluid level is the most appropriate parameter for monitoring snubber fluid leakage.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 116 of 166 Appendix G (Page 9 of 14) 3.2.4 Testing The following functional test parameters are normally measured during inservice testing:

• Activation Velocity: Locking velocity for poppet-valve hydraulic snubbers.

Acceleration threshold for acceleration-limiting mechanical snubbers.

• Release Rate: Snubber velocity at a given load, after snubber activation.
• Drag Force: Snubber resistance load at a given stroke velocity.
• Breakaway Force: Force required to initiate snubber motion.

These parameters are also useful in identifying potential degradation or determining the cause of snubber failure. A. Evaluation of Test Results Since existing test plans are statistically based on the number of failures, test results are often evaluated on only a pass/fail basis. Most test machines provide a continuous trace of load and velocity for both activation and drag force tests. Such traces often contain information useful in identifying snubber degradation. During mechanical snubber drag force (i.e., the number of load spikes, consistency of the load spikes, duration of load spikes, noise, variations in drag force with stroke position and directional sensitivity) are all useful in identifying potential snubber degradation or impending snubber failure. For hydraulic snubbers, traces can be used to identify air in the snubber or a clogged bleed orifice. B. As-Found Testing As-Found testing of snubbers removed from service can identify degradation due to severe operating environments. A considerable amount of information can be obtained by conducting post-service functional tests on snubbers removed from service. Such tests are recommended any time a snubber is removed from service, regardless of whether or NOT the snubber is to be reinstalled. This is a requirement of the Technical Requirements Manual at BFN.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 117 of 166 Appendix G (Page 10 of 14) 3.2.4 Testing (continued) C. Diagnostic Testing Diagnostic tests are specifically designed to obtain useful information about the condition of a particular snubber, beyond what may be available from routine testing. Diagnostic testing may often be helpful in identifying a failure or degradation mechanism before the snubber is disassembled. Repeat tests are helpful in determining the repeatability of a given anomaly. It may sometimes be desirable to vary test parameters (i.e., applied load, drag force velocity or test time duration) in order to observe the effect on snubber performance. D. Trending Test Results Trending is a useful tool for monitoring progressive snubber degradation. If test data are to be used for trending, the following should be considered:

1. Because the prevalent failure mode is failure to allow free thermal motion, a potential trending parameter for mechanical snubbers is drag force. This is supported by test data obtained that suggest an increase in drag force with service time for mechanical snubbers.

It is important that test data to be used for trending are consistently obtained using the same type of test machine, under the same conditions. The data from the same snubber should be used for comparison purposes. Administrative limits for functional test results are intended to ensure replacement or repair of a given snubber before failure. It is important to have a reasonable indication that the selected test parameter is progressing toward the failure limit. Overly restrictive administrative limits can have the negative effect of limiting the amount of data available for trending. They can also encourage replacement of reliable snubbers. If test data are obtained for a different set of snubbers at each refueling outage, then the test results are NOT appropriate for trending. If snubbers are tested on different types of test machines, the test data are generally NOT adequate for identifying trends. Another important consideration involves defining the test parameter. A test parameter may be defined in different ways for the same parameter. A test parameter must be defined both from the standpoint of snubber operability (i.e., for testing) and for service-life monitoring (i.e., for trending).

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 118 of 166 Appendix G (Page 11 of 14) 3.2.4 Testing (continued) E. Test Equipment The types of snubber test equipment used in the industry varies considerably. Some provide only a single value for a given test parameter (i.e., load or velocity) while others provide a continuous trace of the parameter versus time. The operation of some test equipment is totally manual, while others are fully automated. It is recommended that functional test equipment be provided with a data acquisition system (i.e., analog or digital) that is capable of providing a continuous trace of load and velocity versus time for the duration of the test. Information from such traces is useful in detecting degradation and identifying failure mechanisms. Many test machines are totally automatic. Automatic test machines may be advantageous for required testing because operator bias is minimized. Data from automatic testers are generally acceptable for trending purposes. For diagnostic testing the test operator should be able to vary the level of various test parameters for exploratory purposes. It should be noted that when a snubber is tested in a different type of test machine than the one previously used, a number of new variables (i.e., test control methods and parameters, data acquisition systems, etc.) are introduced that may complicate the identification of trends. For this reason, trending tests are most effectively conducted using the same test machine as well as the same test methods.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 119 of 166 Appendix G (Page 12 of 14) 3.2.5 External Seal Leakage Detection and Leakage Rate Determination Minor seal leakage is common for many snubber types and applications. A number of influences can cause seal leakage. A leaking snubber does NOT necessarily imply inoperability nor does it necessarily require immediate snubber overhaul. Measurement and trending of reservoir fluid level is probably the most practical approach to monitoring for external seal leakage. For this reason, reservoir fluid level should be recorded whenever fluid is added. The location of seal leakage in many cases may be obvious by visual observation. In some cases the precise location of the seal leakage may require a time consuming follow-up evaluation. It should be noted that in many cases, seal leakage can be the result of improper snubber assembly, defective parts, etc. A practical method for checking for seal leakage following snubber overhaul is to place the snubber on an absorbent (paper) pad, where it can be observed for a period of time, approximately 1 hour, prior to installation. 3.2.6 Visual Examination Snubbers, at BFN, are visually examined in accordance with the Technical Requirements Manual. The intent of the examinations are to identify characteristics that might indicate snubber inoperability. Service-life monitoring examinations may be conducted at the same time as those required by the Technical Requirements Manual or separately. The qualification of personnel for such examinations is critical. Visual characteristics, that would provide information in regard to service degradation, are listed below. These snubber attributes may be used to define a visual examination checklist for service-life monitoring.

1. Deformed structural member or piston rod

2. Loose or missing threaded fasteners

3. Cold or hot position varies from specified value

4. Evidence of corrosion

5. Evidence of solid deposits (e.g., boric acid) from leaking components

6. Loss of hydraulic fluid since previous visual examination

Appendix G (Page 13 of 14) 3.2.6 Visual Examination (continued)

7. Metal filings on or in the vicinity of the snubber

8. Observed fluid leakage

9. Evidence of significant dark (i.e., black or dark brown) material deposit on piston rod

10. Rod wiper adhered to piston rod

11. Abnormal color of hydraulic fluid

12. Wear or deformation of clevis pins

13. Elongation of attachment holes

14. Evidence of wear on support cylinder

15. Cracked or deformed fluid reservoir

16. Evidence of foreign material (e.g., water, solid particles, etc.) in hydraulic fluid

17. Discoloration of metallic parts due to elevated temperature 3.2.7 Root-Cause Evaluation of Degraded or Failed Snubbers Failures often result from influences (i.e., maintenance activities, construction activities and manufacturing defects) NOT related to service time or environment. It is important to ensure that service life, when based upon service history, is NOT unjustifiably influenced by such failures or degradation. Snubbers that failed inservice examinations or tests, or snubbers removed from service due to excessive degradation, should be evaluated to determine the root cause of the degradation or failure.

Failure evaluation data sheets should include information pertaining to failure mode, failure mechanism, environment, service time, abnormal conditions, visual observations, test results and test observations. Data sheets should NOT utilize a format that might lead the examiner to a potentially incorrect failure cause (e.g., a checklist of failure causes). Diagnostic testing may be useful to identify the failure or degradation mechanism.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 121 of 166 Appendix G (Page 14 of 14) 3.2.8 Shortening or Extending Service Life It may be necessary to shorten the service life of snubbers subjected to severe environments, such as excessively high temperatures and vibration. Snubbers in severe environments may require augmented surveillance, including "hands-on" evaluations (e.g., hand stroking) or inplace monitoring. Where there has been minimal degradation due to the service environment, it may be appropriate to extend the previously established service life. Service life extension should be based on a technical evaluation of the snubber performance that includes knowledge pertaining to the current level of service-related degradation as well as to the degradation rate. Service life extension evaluations might include monitoring degradation parameters (i.e., seal compression set in hydraulic snubbers, drag force in mechanical snubbers or operating experience in a similar environment).

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 122 of 166 Appendix H (Page 1 of 11) Hydraulic Snubber Failure Analysis Approach, Failure Modes, Indications and Failure Cause 1.0 GENERAL In performing any snubber analysis a full investigation should be performed prior to making any determination of the failure cause. This should be done since there may be very subtle causes, which can be masked by NOT performing a slow and methodical investigation. All parts should be Match Marked prior to disassembly, since the disassembly of the snubber may destroy evidence of the true apparent cause of the snubber failure. In this approach a failure denotes a snubber NOT meeting its functional test acceptance criteria. The test data may show that the snubber is degraded or that it is a functional failure. If solvents are required during the performance of the investigation, only approved solvents should be used to clean the parts. 2.0 SNUBBER LOCATION HISTORY DATA [1] GIVE a general history of the snubber location using the following as a guideline:

• Any previous functional test or visual examinations

              **   Snubber location in the plant

• Snubber installed orientation
• Does the snubber have a transition tube kit or a forward bracket installed? If a transition kit is installed what is the pin-to-pin dimension?
• Which end of the snubber (transition tube/forward bracket or the snubber body) is attached to the pipe?

[2] REVIEW any and all previously performed snubber visual examination and functional test data. [3] PERFORM a field walk down of the snubber location to determine any adverse environmental conditions, such as:

• Is the snubber in a location where it could be hit, kicked or stepped upon during maintenance activities?
• Are there any signs of pipe leakage (water, steam, etc.) in the area?

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 123 of 166 Appendix H (Page 2 of 11) 2.0 SNUBBER LOCATION HISTORY DATA (continued) [4] REVIEW the piping system records to determine if any transient events have occurred in this section of piping. [5] REVIEW the piping stress analysis to determine the design loading conditions of this location, the pipe support orientations, locations and the relative stiffness of the piping system. Some examples are:

          "     Is this location designed to take water hammer loads or other transient loads and did one occur?

• Is this location subject to pipe vibration?
• Is this location required for seismic or is it only required for operational transient loads?

[6] REVIEW the piping stress analyses to determine if there are other snubbers subject to the same failure mode. An example is, if a snubber failure occurred on the "A" loop is there a similar location on the "B" loop? [7] CHECK the environmental data for the snubber location: Harsh or mild environment Temperature range Radiation dose

• Humidity

Appendix H (Page 3 of 11) 3.0 EXTERNAL SNUBBER EVALUATION FOR ALL SIZE HYDRAULIC SNUBBERS In almost every case, the evaluation performed on the exterior of the snubber can give clues to the nature of the failure. Following are some things which should be looked at and evaluated during the snubber evaluation. [1] RECORD the following data:

• Snubber size
• Snubber serial number
• Year of manufacture
• Manufacturer's part number
• Evaluation date

[2] CHECK the condition of the spherical bearing on both ends of the snubber: NOTE A bound or "frozen" spherical bearing can put unanalyzed forces into the snubber during thermal movements, causing internal stress or damage.

• Can they be moved by hand?
• Do they "squeak" when they are moved?
• Is there foreign material on the bearings?
• Are they rusty?
• Are the spherical bearings staked in place?
• Any signs of deformation?

[3] Is there any physical damage to the snubbers' externals:

• Ding marks on exterior surfaces 0 Welding arc marks on exterior surfaces

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 125 of 166 Appendix H (Page 4 of 11) 3.0 EXTERNAL SNUBBER EVALUATION FOR ALL SIZE HYDRAULIC SNUBBERS (continued) [4] Are there any foreign materials on the exterior of the snubber? If so, would they interfere with the operation of the snubber?

• Duct tape
• Insulation materials Corrosion products Dirt or debris
• Paint or other coatings

[5] CHECK the external surfaces of the snubber for any signs of discoloration due to excessive temperatures. [6] FULLY EXTEND the snubber, if possible, and DENOTE any wear or other types of marks found. The location and measurement (length, width and direction) of these marks and the actual snubber orientation during operation can be a vital clue as to what was happening to the snubber during operation. One important aspect is to determine exactly what the snubber settings were prior to the failure and what the snubber settings were at the time of the failure. Some utilities perform snubber measurements from a fixed point on the snubber. These measurements are recorded during the visual examinations, as well as, being documented in the Work Orders (WO) that remove the snubber from the piping system. These measurements are usually documented to the nearest 1/32nd of an inch. The importance of these measurements is that the evaluator can measure any wear marks found on the snubber and correlate the location and lengths of these wear marks to the actual snubber settings. This information can aid the evaluator in determining if these wear marks are due to the normal snubber movements (cold or hot setting) or due to vibration in either the hot or cold position. [7] CHECK the retainer ring at the housing to ensure that it was installed correctly (flat side down).

Appendix H (Page 5 of 11) 3.0 EXTERNAL SNUBBER EVALUATION FOR ALL SIZE HYDRAULIC SNUBBERS (continued) [8] CHECK the connection of the transition tube kit or the forward bracket to the snubber.

• Is the tie wire intact?
• Has the transition tube loosened from the backing plate?

[9] SLOWLY STROKE the snubber by hand, if possible.

• ORIENT the snubber, as best as possible, to the orientation that the snubber was in the field prior to stroking.
• RECORD any rough spots and the location (stroke location).
• RECORD any noises heard.
• Did the snubber stroke under its own weight or was force needed to be applied to stroke the snubber? Was the applied force excessive?
• Did the snubber "stick" at any point in the stroke?
• Did any rough spots in the stroke correspond to any mark locations?

[10] MATCH MARK the transition tube kit or forward bracket to the snubber body and REMOVE the transition tube kit or forward bracket. Throughout the disassembly process, all parts should be checked for any signs of contamination, damage or wear.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 127 of 166 Appendix H (Page 6 of 11) 4.0 INTERNAL SNUBBER EVALUATION FOR ALL SIZE HYDRAULIC SNUBBERS The evaluation guidelines that follow will highlight the prime areas of concern for the snubber components. The following instruments may be used for the evaluation and in particular when any doubt persists as to the cause of the failure.

• Flat machinist's Surface Plate
• Surface Comparitor/Surface Profilometer
• Dial bore gauges
• Plug gauges 4.1 Evaluation of the Snubber Reservoir:

[1] Using the appropriate plant procedures, REMOVE the reservoir hold down screws and LIFT the reservoir from the control valve assembly and snubber body. After removal PERFORM the following inspections and evaluations:

             "    INSPECT the "0"Ring seal between the reservoir and the control valve assembly for deterioration, cuts or other damage.
             "    INSPECT the matting surfaces between the reservoir, the control valve assembly and the snubber front head for rust, pits, scratches and straightness.

[2] MATCH MARK each piece and DISASSEMBLE the reservoir in the following order and PERFORM the inspections and evaluations as follows:

• REMOVE the tie rods from the reservoir and INSPECT the threads of the rods and nuts.
• REMOVE the rear cap and INSPECT the tube ends, the "0" Ring and the "0" Ring contact surfaces.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 128 of 166 Appendix H (Page 7 of 11) 4.1 Evaluation of the Snubber Reservoir: (continued) [3] RELEASE the pressure from the reservoir piston spring and REMOVE the piston and spring. INSPECT the reservoir parts as follows: REMOVE and INSPECT the reservoir piston packing for any imperfections, degradation or nicks.

           "    INSPECT the reservoir piston sealing areas for rough surfaces or nicks.
           "    INSPECT the piston and reservoir tube contact areas for surface imperfections, nicks or rough spots. If nicks or rough spots persist on the largest diameter, DISCARD the part.

INSPECT the spring for mechanical damage, breakage or corrosion. If any are evident DISCARD and REPLACE the part.

           "    REMOVE and INSPECT the reservoir bleeder screw threads.

• INSPECT the "0" Ring and sealing surface under the screw head.

4.2 Evaluation of the Snubber Control Valve Assembly: [1] Using the appropriate plant procedures, REMOVE the control valve assembly hold down screws and LIFT the control valve assembly from the snubber body. After removal PERFORM the following inspections and evaluations:

• INSPECT the "0" Ring seal between the control valve assembly and the snubber body for deterioration, cuts or other damage.
• INSPECT the mating surfaces between the control valve assembly and the snubber rear cap for rust, pits and scratches.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 129 of 166 Appendix H (Page 8 of 11) 4.2 Evaluation of the Snubber Control Valve Assembly: (continued) [2] MATCH MARK each piece, DISASSEMBLE the control valve assembly and PERFORM the inspections and evaluations as follows:

           "    REMOVE and INSPECT the threads, "0" Rings and sealing surfaces of the 3 SAE port plugs for deterioration, degradation, rust, nicks or pits.

• REMOVE the compression poppet stop and plug, the extension connector tube and INSPECT the threads, "0" Rings and sealing surfaces for deterioration, degradation, rust, nicks or pits.
• REMOVE and INSPECT the compression and extension poppets for degradation, rust, nicks or pits on the head and the conical bleed groove area.
• INSPECT the compress*ionand extension poppet seat areas for degradation, rust, nicks or pits.
• INSPECT the poppet springs for mechanical damage, weakness, breakage or corrosion. Ifany are evident DISCARD and REPLACE the part.

           "    REMOVE the relief valve plug, ball and spring and PERFORM the same inspections as listed above.

4.3 Evaluation of the Snubber Main Body: [1] Using the appropriate plant procedures, DISASSEMBLE the main snubber body. After removal MATCH MARK each piece and PERFORM the inspections and evaluations as follows:

• REMOVE the tie rods from the main snubber body and INSPECT the threads of the rods and nuts.
• REMOVE the rear cap and INSPECT the tube ends, the "0"Ring and the "0" Ring contact surfaces.
• REMOVE and INSPECT the main piston rings for any imperfections, degradation or nicks.
• INSPECT the main piston sealing areas for rough surfaces or nicks.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 130 of 166 Appendix H (Page 9 of 11) 4.3 Evaluation of the Snubber Main Body: (continued)

           "    INSPECT the piston and main cylinder tube contact areas for surface imperfections, nicks or rough spots. If nicks or rough spots persist on the largest diameter, DISCARD the part.

• REMOVE the front head and INSPECT the tube ends, the "0"Ring and the "0"Ring contact surfaces.

           "    INSPECT the rod bearing gland contact areas for surface imperfections, nicks or rough spots. If nicks or rough spots persist on the largest diameter, DISCARD the part.

• REMOVE and INSPECT the rod bearing gland rod packing contact areas for surface imperfections, nicks or rough spots.
• REMOVE and INSPECT the piston rod wiper and contact surface for imperfections, nicks or rough spots.
• REMOVE and INSPECT the threads, "0"Rings and sealing surface of the front head port plug for deterioration, degradation, rust, nicks or pits.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 131 of 166 Appendix H (Page 10 of 11) 5.0 HYDRAULIC SNUBBER FAILURE MODES, INDICATIONS AND FAILURE CAUSE FAILURE MODE INDICATIONS FAILURE CAUSE LOW FLUID LEVEL LEAKAGE OVER LOAD OR TRANSIENT IMPROPER FILLING AND PURGING MAINTENANCE OR MANUFACTURE LOW LOCKING VELOCITY FIELD TAMPERING MAINTENANCE IMPROPER INITIAL SETTING MAINTENANCE LOW TEST TEMPERATURE TESTING IMPROPER TEST TESTING FLUID VISCOSITY CHANGE ENVIRONMENT INCORRECT FLUID MAINTENANCE INADEQUATE PURGE MAINTENANCE INCORRECT VALVE PARTS MAINTENANCE OR MANUFACTURE LOW BLEED FATE CLOGGED BLEED ORIFICE ENVIRONMENT OR MAINTENANCE FIELD TAMPERING MAINTENANCE IMPROPER INITIAL SETTING MAINTENANCE _ LOW TEST TEMPERATURE TESTING IMPROPER TEST TESTING FLUID VISCOSITY CHANGE ENVIRONMENT INCORRECT FLUID MAINTENANCE OR MANUFACTURE INADEQUATE PURGE MAINTENANCE HIGH LOCKING VELOCITY AIR IN FLUID MAINTENANCE INTERNAL SEAL BY-PASS MAINTENANCE FIELD TAMPERING MAINTENANCE IMPROPER INITIAL SETTING MAINTENANCE, MANUFACTURE, UNKNOWN OR TESTING HIGH TEST TEMPERATURE MAINTENANCE

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 132 of 166 Appendix H (Page 11 of 11) 5.0 HYDRAULIC SNUBBER FAILURE MODES, INDICATIONS AND FAILURE CAUSE (continued) FAILURE MODE INDICATIONS FAILURE CAUSE HIGH LOCKING VELOCITY IMPROPER TEST TESTING (CONTINUED) FLUID VISCOSITY CHANGE ENVIRONMENT INCORRECT FLUID MAINTENANCE INADEQUATE PURGE MAINTENANCE HIGH BLEED RATE AIR IN FLUID MAINTENANCE INTERNAL SEAL BY-PASS MAINTENANCE OR MANUFACTURE

                          .CLOGGING DURING CALIBRATION        MAINTENANCE, MANUFACTURE, UNKNOWN OR TESTING FIELD TAMPERING            MAINTENANCE IMPROPER INITIAL SETTING         MAINTENANCE HIGH TEST TEMPERATURE             TESTING IMPROPER TEST               TESTING FLUID VISCOSITY CHANGE          ENVIRONMENT INCORRECT FLUID           MAINTENANCE OR MANUFACTURE INADEQUATE PURGE             MAINTENANCE

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 133 of 166 Appendix I (Page 1 of 21) Mechanical Snubber Failure Analysis Approach, Failure Modes, Indications and Failure Cause 1.0 GENERAL In performing any snubber analysis a full investigation should be performed prior to making any determination of the failure cause. This should be done since there may be very subtle causes, which can be masked by NOT performing a slow and methodical investigation. All parts should be Match Marked prior to disassembly, since the disassembly of the snubber may destroy evidence of the true cause of the snubber failure. In this approach a failure denotes a snubber NOT meeting its functional test acceptance criteria. The test data may show that the snubber is degraded or that it is a functional failure. If solvents are required during the performance of the investigation, only approved solvents should be used to clean the parts. 2.0 SNUBBER LOCATION HISTORY DATA: [1] GIVE a general history of the snubber location using the following as a guideline:

• Any previous functional test or visual examinations
• Snubber location in the plant
• Snubber installed orientation
• Does the snubber have a transition tube kit or a forward bracket installed? If a transition kit is installed what is the pin-to-pin dimension?
• Which end of the snubber (transition tube/forward bracket or the snubber body) is attached to the pipe?

[2] REVIEW any and all previously performed snubber visual examination and functional test data. [3] PERFORM a field walk down of the snubber location to determine any adverse environmental conditions, such as:

• Is the snubber in a location where it could be hit, kicked or stepped upon during maintenance activities?
• Are there any signs of pipe leakage (water, steam, etc.) in the area?

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 134 of 166 Appendix I (Page 2 of 21) 2.0 SNUBBER LOCATION HISTORY DATA: (continued) [4] REVIEW the piping system records to determine if any transient events have occurred in this section of piping. [5] REVIEW the piping stress analysis to determine the design loading conditions of this location, the pipe support orientations, locations and the relative stiffness of the piping system. Some examples are:

          "     Is this location designed to take water hammer loads or other transient loads and did one occur?

• Is this location subject to pipe vibration?

          "     Is this location required for seismic or is it only required for operational transient loads?

[6] REVIEW the piping stress analyses to determine if there are other snubbers subject to the same failure mode. An example is, if a snubber failure occurred on the "A" loop is there a similar location on the "B" loop? [7] CHECK the environmental data for the snubber location:

• Harsh or mild environment
• Temperature range
• Radiation dose
• Humidity

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 135 of 166 Appendix I (Page 3 of 21) 3.0 EXTERNAL SNUBBER EVALUATION FOR ALL SIZE PSA SNUBBERS: In almost every case, the evaluation performed on the exterior of the snubber can give clues to the nature of the failure. Following are some things which should be looked at and evaluated during the snubber evaluation. [1] RECORD the following data:

• Snubber size

               *. Snubber serial number

• Year of manufacture
• Manufacturer's part number
• Evaluation date

[2] CHECK the condition of the spherical bearing on both ends of the snubber: NOTE A bound or "frozen" spherical bearing can put unanalyzed forces into the snubber during thermal movements, causing internal stress or damage.

• Can they be moved by hand?
• Do they "squeak" when they are moved?

               *. Is there foreign material on the bearings?

• Are they rusty?
• Are the spherical bearings staked in place?
• Any signs of deformation?

[3] Is there any physical damage to the snubbers':externals:

• Ding marks on exterior surfaces
• Welding arc marks on exterior surfaces

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 136 of 166 Appendix I (Page 4 of 21) 3.0 EXTERNAL SNUBBER EVALUATION FOR ALL SIZE PSA SNUBBERS: (continued) [4] Are there any foreign materials on the exterior of the snubber? If so, would they interfere with the operation of the snubber?

• Duct tape
• Insulation materials
• Corrosion products
• Dirt or debris
• Paint or other coatings

[5] CHECK the external surfaces of the snubber for any signs of discoloration due to excessive temperatures. [6] FULLY EXTEND the snubber, if possible, and DENOTE any wear or other types of marks found. The location and measurement (length, width and direction) of these marks and the actual snubber orientation during operation can be a vital clue as to what was happening to the snubber during operation. One important aspect is to determine exactly what the snubber settings were prior to the failure and what the snubber settings were at the time of the failure. Some utilities perform snubber measurements from a fixed point on the snubber. These measurements are recorded during the visual examinations, as well as, being documented in the Work Orders (WO) that remove the snubber from the piping system. These measurements are usually documented to the nearest 1/32nd of an inch. The importance of these measurements is that the evaluator can measure any wear marks found on the snubber and correlate the location and lengths of these wear marks to the actual snubber settings. This information can aid the evaluator in determining if these wear marks are due to the normal snubber movements (cold or hot setting) or due to vibration in either the hot or cold position. [7] CHECK the retainer ring at the housing to ensure that it was installed correctly (flat side down).

Appendix I (Page 5 of 21) 3.0 EXTERNAL SNUBBER EVALUATION FOR ALL SIZE PSA SNUBBERS: (continued) [8] CHECK the connection of the transition tube kit or the forward bracket to the snubber.

• Is the tie wire intact?
• Has the transition tube loosened from the backing plate?

[9] SLOWLY STROKE the snubber by hand, if possible.

• ORIENT the snubber, as best as possible, to the orientation that the snubber was in the field prior to stroking.
• RECORD any rough spots and the location (stroke location).
• RECORD any noises heard.
• Did the snubber stroke under its own weight or was force needed to be applied to stroke the snubber? Was the applied force excessive?

         "    Did the snubber "stick" at any point in the stroke?
         "    Did any rough spots in the stroke correspond to any mark locations?

[10] MATCH MARK the transition tube kit or forward bracket to the snubber body and remove the transition tube kit or forward bracket. Throughout the disassembly process, all parts should be checked for any signs of contamination, damage or wear.

Appendix I (Page 6 of 21) 4.0 INTERNAL SNUBBER EVALUATION FOR ALL SIZE PSA SNUBBERS: 4.1 General [1] Contamination has most notably been caused by wear products due to internal friction between the parts. A very fine reddish brown colored substance found on the internal parts may be due to fretting corrosion due to a vibration concern. This reddish brown colored substance has the consistency of a fine dust and is usually found throughout the snubber during disassembly. This substance can contaminate the lubricant causing it to dry out or become sticky. [2] The following are areas of notable wear, all contacting surfaces should be examined thoroughly:

• The inner tube rubbing against the outer tube on the PSA-1/4 and -1/2.

The position indicating tube and the support cylinder on the PSA-1, -3, and -10.

        "    The brass bearing of the rod and bearing assembly rubbing against the inside surface of the Inner Tube on the PSA-1/4 and -1/2.
        "    All faces and surfaces of the capstan spring and keeper rings on all size snubbers.

• The rods of the rod and bearing assembly rubbing against the "ears" of the guide plate on PSA-1/4 and -1/2.
• Telescoping cylinder against the support cylinder on PSA-1, -3 and -10.
• Inertia mass rubbing against the housing on all sizes.

[3] Other forms of contamination (i.e., dirt, debris, broken parts and corrosion particles) have also been seen frequently during disassembly. The location, amount and form of contamination should be noted throughout the disassembly process. [4] During disassembly the lubricant should be checked in all accessible areas.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 139 of 166 Appendix I (Page 7 of 21) 4.1 General (continued) [5] It is suggested that "surgeons" gloves be worn during disassembly. Parts (i.e., the shaft of the torque carrier and shaft assembly) can be rolled on the gloves so the tracks of the lubricant can be seen.

           "      Is the lubricant moist?
           "      Is the lubricant dried out and/or contaminated?

• Does the lubricant "track" when the part is rolled over something?
• Check the color of the lubricant. Is it reddish brown? Is it reddish black?

Is it black?

• Feel the lubricant. Does it still have its lubricating properties? Is it dried out? Does it feel gritty like it is contaminated?

           "      Is the amount of lubricant excessive?

[6] Prior to disassembling the PSA-1/4 and -1/2 snubber, hold the snubber in a horizontal position up next to your ear and shake the snubber back and forth. A slight "clicking" noise should be heard indicating the snubber internals have some "free play".

• If no sound is heard, the snubber internals may be bound or the pivot bearing may NOT have been torqued properly (too tight).

           "      If excessive noise is heard, the pivot bearing may NOT have been torqued properly (too loose).

Appendix I (Page 8 of 21) 4.1 General (continued) [7] SLOWLY STROKE the snubber by pulling straight up on the end plug. With the snubber stroked fully in the tension direction, SLIDE the outer tube up to the end plug.

• Does the outer tube align with the end plug? If NOT, are the rods of the rod and bearing assembly bent?
• Are the rods of the rod and bearing assembly twisted?
• Twisted rods are normally an indication of mishandling during installation.
• Are the rods of the rod and bearing assembly bowed?

Rods that are "bowed" outward or inward are usually a sign of a compressive overload.

• Does the outer tube slide easily over the inner tube?
• The outer tube should slide easily over the inner tube with little to no resistance. If NOT, is there foreign material, corrosion or debris between the inner and outer tubes?

[8] Look at the internals of the snubber down through the inner tube. Is there any contamination or degradation?

         ,    Is the pivot bearing intact?
         "    PSA put a small dab of white paint on the jam nut of the pivot bearing to mark the fact that the jam nut was torqued. Excessive amounts of this white paint have been found in snubbers. Thiswhite paint has been found on the rods of the rod and bearing assembly. When this paint comes in contact with the guide plate it will cause the drag loads to increase up to the point of stalling the test bench.

• Is the anti-rotation key intact?
• Is the guide plate retaining ring intact?

[9] SLOWLY COMPRESS the snubber to its fully retracted position.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 141 of 166 Appendix I (Page 9 of 21) 4.2 PSA-1/4 and -1/2 Snubber Housing and Insert Assembly Evaluation: [1] Removing the housing and insert assembly: [2] STAND the unit vertically on the housing and insert assembly and REMOVE the retaining ring holding the outer tube to the housing and insert assembly. [3] Keep a gentle pressure on the snubber and TURN the snubber upside down so the housing and insert assembly is pointing upwards. SLOWLY LIFT the housing and insert assembly from the snubber. Care should be taken NOT to lose the ball from the housing and insert assembly. The ball usually sticks in the insert assembly or to the end of the shaft. Did the ball stick to the end of the shaft or did it stick in the insert area of the housing and insert assembly?

• INSPECT the lubricant on the ball.
• CLEAN and INSPECT the ball. USE a magnifying glass.
• INSPECT the inside of the housing and insert assembly.

Is there any lubricant in the insert area of the housing and insert assembly. CLEAN the housing and insert assembly and USE a magnifying glass to INSPECT the insert area for damage or contamination.

Appendix I (Page 10 of 21) 4.3 PSA-114 and -1/2 Snubber Inertia Mass Evaluation: [1] Prior to removing or touching the inertia mass PERFORM the following:

• INSPECT the outsides for any contamination or damage. Ifthere are wear marks on the outside surface, CHECK the inside of the housing and insert assembly for a corresponding wear mark. Was the inertia mass hitting the inside of the housing?
• CHECK the tip of the shaft to see if it is bent, nicked or "mushroomed".

         "    CHECK the washers. Are they shiny from wear? Are they bent?
         "    CHECK the lubricant at the hole area of the inertia mass. Is it contaminated?

• CHECK that the capstan spring tangs are captured in the opened area of the clutch spring.
• CHECK for deformed or damaged washers on the shaft.
• Can the washers be easily removed?

[2] REMOVE and INSPECT the washers.

• Damaged washers could be a sign of a snubber overload.

[3] REMOVE the inertia mass and PERFORM the following:

• NOTE whether the inertia mass came off the shaft easily or if force had to be used to remove it from the shaft.
• INSPECT the inside surfaces of the inertia mass.
• NOTE any contamination or damage.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 143 of 166 Appendix I (Page 11 of 21) 4.4 PSA-1/4 and -1/2 Snubber Clutch Spring Evaluation: [1] Prior to removing the clutch spring, INSPECT it to ensure that it was installed properly (fully seated in the inertia mass).

• A disengaged clutch spring can cause the snubbers acceleration test to be unacceptable if one or both of the capstan spring tangs are NOT captured.

[2] REMOVE and INSPECT the clutch spring.

• Are there any marks or indentations on the clutch spring where the capstan spring tangs had contacted it?
• Are there any signs of contamination?

4.5 PSA-1/4 and -1/2 Snubber Torque Carrier and Shaft Assembly Evaluation: [1] Before removing the torque carrier and shaft assembly, CHECK the lubricant on the tip of the compression side of the shaft.

• SLOWLY REMOVE and then INSPECT the torque carrier and shaft assembly.
• CHECK the lubricant on the shaft.
• INSPECT the compression and tension side ends of the shaft.
• The ends of the shaft of the torque carrier and shaft assembly are "cupped". It is very important to inspect these ends for wear or damage.

Use a magnifying glass. Damaged ends of the shaft could cause the shaft to bind in the insert area of the housing and insert assembly or in the pivot bearing. If the cupped ends are "mushroomed", the shaft may have been subjected to an overload.

           "    CHECK the run-outs on the shaft in three places: At the torque carrier, at mid span and at the tension side end.

Appendix I (Page 12 of 21) 4.6 PSA-1/4 and -1/2 Snubber Capstan Spring Evaluation: [1] Prior to removing the capstan spring, mark it so you can tell which side was toward the tension side of the shaft. A "Sharpie" marker works good. DRAW an arrow on the capstan spring pointing to the tension side of the shaft. Wear on the capstan spring tangs and the faces of the capstan spring, that contact the keeper rings, can give evidence of a normal operating snubber or one that has been subjected to piping vibration. CHECK that the keeper rings are installed properly. Improper installation of the keeper rings could cause the capstan spring to be "cocked". This could lead to the capstan spring binding on the capstan area of the inner tube. This would lead to high drag loads during the functional test. REMOVE the outer keeper ring and REMOVE the capstan spring. ENSURE that you know what side of the keeper was contacting the capstan spring.

• INSPECT the outside surface, the inside surface, the faces that contact the keeper rings and especially the "tang" areas of the capstan spring for wear or damage.
• NOTE excessive wear on the capstan spring surfaces, especially at the "tang" areas. Wear in these areas may be an indication of a piping vibration concern.

          ,   Is the inside "running" surface of the capstan spring greasy or dry?

4.7 PSA-1/4 and -1/2 Snubber Rod and Bearing Assembly Evaluation: [1] ROTATE the rod and bearing assembly to disengage the anti-rotation key and REMOVE the anti-rotation key. [2] REMOVE the retaining ring that holds the rod and bearing assembly to the inside of the inner tube and REMOVE the rod and bearing assembly. INSPECT the rod and bearing assembly for any signs of contamination or degradation.

         ,    TAKE run-outs on the rod and bearing assembly.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 145 of 166 Appendix I (Page 13 of 21) 4.8 PSA-1/4 and -1/2 Snubber Inner and Outer Tube Evaluation: [1] INSPECT the internals of the inner tube and outer tube for any signs of contamination or degradation. 4.9 PSA-1/4 and -1/2 Snubber Pivot Bearing, Jam Nut and Lock Washer Evaluation: [1] REMOVE and INSPECT the pivot bearing, jam nut and lock washer. NOTE any areas of excessive wear, contamination or any damaged parts. 5.0 PSA-1, -3, -10, -35 AND -100 POSITION INDICATOR TUBE, FILISTER HEAD SCREWS AND FLAT WASHERS EVALUATION: [1] REMOVE the Filister head screws, flat washers and position indicator tube.

           "     CHECK the inside surface of the Indicator tube for contamination and wear markings and debris.

• CHECK the Filister head screws for damaged threads.,

6.0 PSA-1, -3, -10, -35 AND -100 HOUSING EVALUATION: [1] Removing the housing from the snubber internals: [2] STAND unit up vertically on the housing and REMOVE the retaining ring holding the outer tube to the housing.

• INSPECT the retaining ring.

[3] Keep gentle pressure on the housing while lifting the snubber with its internals from the housing.

• INSPECT the inside of the, housing.
• Is there any contamination or degradation? Look for internal rust, corrosion, loose debris and broken parts. Are there signs of wear due to the inertia mass contacting the housing?
• CHECK the dust cover for signs of impingement. Indent marks on the center of the dust cover are a sign that the shaft impacted the dust cover.

This is a sign of overload.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 146 of 166 Appendix I (Page 14 of 21) 7.0 PSA-1, -3, -10, -35 AND -100 INTERNAL EVALUATION: 7.1 PSA-1, -3, -10, -35 and -100 Inertia Mass Evaluation: [1] Prior to removing or touching the inertia mass PERFORM the following:

• INSPECT the outside for any contamination or damage. If there are wear marks on the outside surface, CHECK the inside of the housing and insert assembly for a corresponding wear mark. Was the inertia mass hitting the inside of the housing?
• CHECK the tip of the shaft to see if it is bent, nicked or "mushroomed".
• CHECK the washers. Are they shiny from wear? Are they bent?
• CHECK the lubricant at the hole area of the inertia mass. Is it contaminated?
• CHECK that the capstan spring tangs are captured in the opened area of the clutch spring.
• CHECK for deformed or damaged washers on the shaft.
• Can the washers be easily removed?

[2] REMOVE and INSPECT the washers.

• Damaged washers could be a sign of a snubber overload.

[3] REMOVE the inertia mass and PERFORM the following:

• NOTE whether the inertia mass came off the shaft easily or if force had to be used to remove it from the shaft.

           "    INSPECT the inside surfaces of the inertia mass.
           "    NOTE any contamination or damage.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 147 of 166 Appendix I (Page 15 of 21) 7.2 PSA-1, -3, -10, -35 and,-100 Clutch Spring Evaluation: [1] Prior to removing the clutch spring, INSPECT it to ensure that it was installed properly (fully seated in the inertia mass).

• A disengaged clutch spring can cause the snubbers acceleration test to be unacceptable if one or both of the capstan spring tangs are NOT captured.

[2] REMOVE and INSPECT the clutch spring.

• Are there any marks or indentations on the clutch spring where the capstan spring tangs had contacted it?
• Are there any signs of contamination?

7.3 PSA-1, -3, -10, -35 and -100 Torque Drum (Carrier) Evaluation: [1] Prior to removing the torque drum (carrier), INSPECT the outside surfaces for contamination or degradation. [2] INSPECT the flat washers and retaining ring for signs of contamination or degradation.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 148 of 166 Appendix I (Page 16 of 21) 7.3 PSA-1, -3, -10, -35 and -100 Torque Drum (Carrier) Evaluation: (continued) [3] REMOVE the flat washers, retaining ring and torque drum and PERFORM the following:

• NOTE whether the torque drum (carrier) came off the shaft easily or if force had to be used to remove it from the shaft.
• INSPECT the inside surfaces of the torque drum (carrier).
• NOTE any contamination or damage.
• CHECK the washers. Are they shiny from wear? Are they bent?
• CHECK the lubricant at the hole area of the torque drum. Is it contaminated or dried out?
• CHECK for deformed or damaged washers.

            "    Can the washers be easily removed?

• REMOVE and INSPECT the retaining ring and washers from the ball screw and shaft.
• CHECK the lubrication on all removed parts.

            "     CHECK lubricant on the washers.

• Are the washers damaged? Damaged washers could be a sign of an overload.

Appendix I (Page 17 of 21) 7.4 PSA-1, -3, -10, -35 and -100 Capstan Spring Evaluation: [1] Prior to removing the capstan spring, MARK it so you can tell which side was toward the tension side of the shaft. A "Sharpie" marker works good. DRAW an arrow on the capstan spring pointing to the tension side of the shaft. Wear on the capstan spring tangs and the faces of the capstan spring, that contact the keeper rings, can give evidence of a normal operating snubber or one that has been subjected to piping vibration. [2] CHECK that the keeper rings are installed properly. Improper installation of the keeper rings could cause the capstan spring to be "cocked". This could lead to the capstan spring binding on the capstan area of the inner tube. This would lead to high drag loads during the functional test.

         "    REMOVE the outer keeper ring and REMOVE the capstan spring.

ENSURE that you know what side of the keeper was contacting the capstan spring.

         "    INSPECT the outside surface, the inside surface, the faces that contact the keeper rings and especially the "tang" areas of the capstan spring for wear or damage.

• NOTE excessive wear on the capstan spring surfaces, especially at the "tang" areas. Wear in these areas may be an indication of a piping vibration concern.

         "    Is the inside "running" surface of the capstan spring greasy or dry?

7.5 PSA-1, -3, and -10 Bearing Nut Evaluation: [1] REMOVE and INSPECT the bearing nut. NOTE any signs of contamination or degradation. [2] DENOTE the condition of the lubricant on the bearing nut threads.

Appendix I (Page 18 of 21) 7.6 PSA-1, -3, -10, -35 and -100 Thrust Bearing Evaluation: [1] Prior to removing the thrust bearing, MATCH MARK the outer and inner races. It is important to note that the outer race is the compression side outer race. [2] REMOVE the thrust bearing.

• DOCUMENT any wear marks found on the races. Radial "cat's eyes" markings are a sign of vibration.
• Marks that appear to be small evenly spaced dots are a sign of possible overload.

[3] CHECK the lubricant on all of the parts. [4] INSPECT the bearing balls for the following:

• Were they installed properly?
• Were there any signs of contamination or degradation?
• What is the condition of the lubricant?

7.7 PSA-1, -3, -10, -35 and -100 End Plug Evaluation: [1] REMOVE and INSPECT the end plug for any signs of contamination or degradation. Oil that has separated from the lubricant has been found in the end plug. 7.8 PSA-1, -3, -10, -35 and -100 Ball (Recirculating Ball) Screw and Shaft (Precision Leadscrew) Assembly Evaluation: [1] REMOVE and INSPECT the ball (recirculating ball) screw and shaft (precision leadscrew) assembly. [2] CHECK the lubricant on the shaft. [3] Does the bearing assembly run up and down the shaft under its own weight? [4] Does the bearing assembly run up and down the shaft under its own weight after the lubricant has been removed or redistributed? [5] CHECK the shaft (precision leadscrew) threads for signs of vibration or overload.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 151 of 166 Appendix I (Page 19 of 21) 7.9 PSA-1, -3, -10, -35 and -100 Telescoping Cylinder Evaluation: [1] REMOVE and INSPECT the telescoping cylinder for any signs of contamination or degradation. [2] NOTE the location of all areas of wear. Snubbers that are installed horizontally usually have some amount of wear due to the telescoping cylinder rubbing against the support cylinder. 7.10 PSA-1, -3, -10, -35 and -100 Support Cylinder Evaluation: [1] CHECK all surfaces of the support cylinder for indications of wear, contamination or degradation. 7.11 PSA-35 and -100 Planetary and Ring Gear Evaluation: [1] CHECK gears for any dents, burrs or defects on the teeth. 7.12 PSA-35 and -100 Washer Plate Evaluation: [1] CHECK the washers. Are they shiny from wear? Are they bent? [2] CHECK for deformed or damaged washers. [3] Can the washers be easily removed? [4] REMOVE and INSPECT the washers. A damaged washer could be a sign of a snubber overload.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 152 of 166 Appendix I (Page 20 of 21) 8.0 MECHANICAL SNUBBER FAILURE MODES, INDICATIONS AND FAILURE CAUSE FAILURE MODE INDICATIONS FAILURE CAUSE HIGH DRAG BENT SCREW SHAFT OVER LOAD OR ________________TRANSIENT INERTIA MASS TOUCHING OVER LOAD OR ______________DUST COVER TRANSIENT FOREIGN MATERIAL ON ENVIRONMENT ________ ________SCREW SHAFT_ _ _ _ _ _ _ _ _ _ FORE IGN MATERIAL ON ENVIRONMENT _________ _______.INDICATOR TUBE_ _ _ _ _ _ _ _ _ _ _ CRACKED THRUST BEARING OVER LOAD OR ____ ____TRANSIlENT____ ____ ______________DRY LUBRICANT ENVIRONMENT CORROSION OF TORQUE ENVIRONMENT _____ _____DRUM _ _ _ _ _ _ _ _ _ _ CORROSION OF CAPSTAN ENVIRONMENT _________SPRING _ _ _ _ _ _ _ _ _ _ _ ROUGH SPOTS ON MAINTENANCE _______________ PLANETARY GEARS THRUST BEARING FRETTING OVER LOAD OR ________________TRANSIENT CAPSTAN SPRING WOUND MANUFACTURE ____ ____ ____ ___TOO TIGHT BINDING OF TELESCOPING OVER LOAD OR ______________MEMBERS TRANSIENT LOOSE BEARING RETAINER MANUFACTURE N UT _ _ _ _ _ _ _ _ _ _ _ TELESCOPIC MEMBERS NOT MANUFACTURE CONCENTRIC___________ WELD SPATTER ON MAINTENANCE INDICATOR TUBE___________ BENT GUIDE RODS OVER LOAD OR ____ ___ ___ ___ ___ ___TRANSIENT FLAKED PLATING ON MOVING MANUFACTURE PARTS__ _ _ _ _ _ _ _ _ _ BROKEN TEETH OVER LOAD OR ____ ___ ___ ___ ___ ___TRANSIENT FLATTENED BALLS OVER LOAD OR ________________TRANSIENT MISMATCHED BALLS AND BALL MANUFACTURE _______ _N UT _ _ _ _ _ _ _ _ _ _ _ UNKNOWN UNKNOWN

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 153 of 166 Appendix I (Page 21 of 21) 8.0 MECHANICAL SNUBBER FAILURE MODES, INDICATIONS AND FAILURE CAUSE (continued) FAILURE MODE INDICATIONS FAILURE CAUSE ACCELERATION OR CAPSTAN SPRING TOO LOOSE MANUFACTURE HIGH VELOCITY CAPSTAN SPRING NOT MANUFACTURE INSTALLED PROPERLY WORN CAPSTAN SPRING OVER LOAD OR TRANSIENT KEEPER RING NOT INSTALLED MANUFACTURE CORRECTLY EXCESSIVE LUBRICANT ON MANUFACTURE TORQUE DRUM LUBRICANT ON INERTIA MASS MANUFACTURE BENT CLUTCH TANG MANUFACTURE FRACTURED BALL SCREW OVER LOAD OR SHAFT TRANSIENT LOCKED DUE TO CORROSION ENVIRONMENT LOCKED DUE TO INTERNAL ENVIRONMENT DAMAGE BROKEN FREE ENVIRONMENT

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 154 of 166 Appendix J (Page 1 of 6) Snubber Request for Relief 2-ISI-13 This relief request was approved by the NRC per Reference N and will be implemented during the Unit 2 Cycle 12 refueling outage.

SUMMARY

Pursuant to 10CFR50.55a(g)(6)(i), (a)(3)(i) or (a)(3)(ii), TVA is requesting relief from the identified ASME Section Xl requirements related to examination and testing of snubbers. TVA proposes to continue use of the examination and testing plans currently defined in the Technical Requirements Manual (TR 3.7.4). The current Technical Requirements Manual requirements have been promulgated, accepted, and approved (on July 14, 1998, for Browns Ferry Plant, Units 1, 2, and 3) by NRC, while ASME Section XI imposes overlapping requirements which do NOT enhance the quality and safety of the-subject snubber examination and testing. COMPONENTS: Component/piping snubbers CODE CLASS: 1, 2 and 3 CODE REQUIREMENT: 1995 Edition of ASME Section XI Code, 1996 Addenda IWF-5300(a), (b), and (c) inservice examination and testing shall be performed in accordance with ASME/ANSI 0 & M, Part 4, using VT-3 visual examination method in IWA-2213. IWF-5400 Repair/Replacement activities performed on snubbers shall be in accordance with IWA-4000. Snubbers installed, corrected, or modified by repair/replacement activities shall be examined and tested in accordance with the applicable requirements of IWF-5200 prior to return to service. IWA-6230 requires inservice inspection summary reports for snubbers be filed with regulatory authority. IWA-21 10 requires Authorized Nuclear Inservice Inspector (ANII) involvement for snubber examination and testing.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 155 of 166 Appendix J (Page 2 of 6) CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED: In accordance with 10CFR50.55a(g)(6)(i), (a)(3)(i) or (a)(3)(ii) relief is requested from the ASME Section Xl, Code, 1995 Edition, 1996 Addenda, Article IWF-5000 which provides, among other things, inservice inspection requirements, repair/replacement activities performed on snubbers, and the ASME/ANSI 0 & M, Part 4 for examinations and tests performed on snubbers: IWF-5300(a), (b), and (c) Inservice Examinations and Tests, ASME/ANSI 0 & M, Part 4, using VT-3 visual exam method describe in IWA-2213. IWF-5400 Repairs/Replacements of snubbers shall be in accordance with IWA-4000. Repaired or Replacement snubbers examined and tested in accordance with the requirements of IWF-5200 prior to return to service. IWA-6230, Summary Report Preparation (for snubbers). IWA-2110(a)(5) and (c), Duties of the Inspector (involvement on snubber Examination and Inspection). BASIS FOR RELIEF: ASME Section XI Code, Class 1, 2, and 3 equivalent snubbers are examined and tested in accordance with Browns Ferry Nuclear (BFN) Plant Technical Requirements Manual (TRM), TR 3.7.4. BFN TR 3.7.4 is prepared in accordance with the guidance given by NRC in Generic Letter 90-09. The scope for snubbers examined and tested in accordance with TR 3.7.4 is not limited by line size or other applicable code exemptions and includes a numerically greater population of snubbers than the Section XI program. Examination and testing of the snubbers in accordance with both ASME Section XI and the plant TRM would result in duplication of effort utilizing different standards and require the preparation of a separate program and associated procedures. This would result in additional cost and unnecessary radiological exposure. In addition the personnel performing snubber visual examinations would also be required to be certified in accordance with the American Society of Nondestructive Testing (ASNT) SNT-TC-1A "Personnel Qualification and Certification in Nondestructive Testing", which is an additional certification as compared to the task training qualification required to perform the TRM required examinations and testing of snubbers. The existing TRM program for examination and testing of snubbers was promulgated, accepted, and approved by NRC. The implementation of ASME/ANSI 0 & M, Part 4, would require BFN to initiate a snubber examination and testing program that is more complicated and expensive to perform, without a compensating increase in the level of quality and safety.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 156 of 166 Appendix J (Page 3 of 6) ALTERNATE EXAMINATIONS: The BFN TRM, TR 3.7.4, requirements will be utilized for the examination and testing of snubbers for preservice, inservice, and repair/replacement activities. The procedures utilized for these examinations are: 2-SI-4.6.H-1, "Visual Examination of Hydraulic and Mechanical Snubbers"; 0-SI-4.6.H-2A, "Functional Testing of Mechanical Snubbers"; 0-SI-4.6.H-2B, "Functional Testing of Bergen-Paterson Hydraulic Snubbers"; 0-SI-4.6.H-2C, "Functional Testing of Bergen-Paterson Torus Dynamic Restraints"; 0-SI-4.6.H-2D, "Functional Testing of Grinnell Hydraulic Snubbers"; 0-SI-4.6.H-2E, "Functional Testing of Lisega Large Bore Torus Dynamic Restraint Snubbers"; MPI-0-000-SNBOO2, "Hydraulic Shock and Sway Arrestor Bergen-Paterson Unit Disassembly and Reassembly"; and MPI-0-000-SNB004, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson Hydraulic, Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Restraints Snubbers". This will include the pin-to-pin area inclusive of applicable snubbers. Testing of repaired and replaced snubbers will also be performed in accordance with TR 3.7.4. Visual examination of repaired and replaced snubbers will be performed in accordance with MPI-0-000-SNB004, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson Hydraulic, Grinnell Hydraulic, and Bergen-Paterson or Lisega Large Bore Torus Dynamic Restraints Snubbers". Snubber examination and testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, SSP-3.1, and the implementing procedures (2-SI-4.6.H-1, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, 0-SI-4.6.H-2C, 0-SI-4.6.H-2D, 0-SI-4.6.H-2E, MPI-0-000-SNBOO2, and MPI-0-000-SNBO04). The areas inclusive of the pins back to building structure and to the component/piping being supported will remain in the ASME Section XI examination boundary.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 157 of 166 Appendix J (Page 4 of 6) JUSTIFICATION FOR THE GRANTING OF RELIEF: The current program, as defined by TR 3.7.4, provides for a level of quality and safety equal to or greater than that provided by ASME Section XI Code, 1995 Edition, 1996 Addenda and requirements defined in ASME/ANSI 0 & M, Part 4, and utilizes NRC guidance not incorporated in the 0 & M Code referenced by the 1995 Edition. IWF-5300(a) covers the snubber visual inspection requirements and IWF-5300(b) covers the snubber functional test requirements. Examination, testing, repair and replacement of snubbers is currently performed in accordance with TR 3.7.4, which utilizes the guidance provided by NRC in Generic Letter 90-09. The 0 & M Code referenced by ASME Section XI has a different basis for examination (failure mode groups) and test plans (10%, 37, or 55). It is impractical to implement both plans because of the resulting duplication of examination and testing efforts and different requirements for snubber quantities subject to examination or test, actually examined and/or tested, and sample expansion requirements. This would result in additional cost and unnecessary radiological exposure. The existing TRM program for examination and testing of snubbers has been promulgated and accepted by NRC. The differences in the two programs could create confusion when selecting test samples, applying acceptance criteria, corrective actions and examination schedules for failed snubbers. This situation could increase the possibility of applying the wrong action, thus creating a nonconformance, an in-operability or even a violation of a TRM requirement. To eliminate any misinterpretation or confusion in administering overlapping requirements for snubbers, and to remove the possibility of applying contradicting requirements to the same snubber(s), BFN proposes to examine and test snubbers in accordance with BFN TR 3.7.4. Sub-article IWF-5400 provides the requirements for repair/replacement activities performed on snubbers to be in accordance with IWA-4000. Snubbers installed, corrected, or modified by repair/replacement activities examined and tested in accordance with the applicable requirements of IWF-5200 prior to return to service. TR 3.7.4 (TSR 3.7.4.6) requires replacement snubbers and snubbers with repairs which might affect the functional test results be tested to meet the functional test criteria prior to installation. Maintenance procedure MPI-0-000-SNB004 provides pre-service inspection procedure for ASME Section XI repair/replacement and for removal/installation of snubbers at BFN.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 158 of 166 Appendix J (Page 5 of 6) JUSTIFICATION FOR THE GRANTING OF RELIEF: (Continued) ASME Section X1, VT-3 certification required for personnel performing snubber visual examinations is an additional certification as compared with the TRM program training qualifications. Personnel performing the TRM required visual examinations are "process qualified" to perform the examinations and testing required by the TRM and implemented by the referenced procedures. This training currently includes a visual test associated with face mask fit and specific training on the acceptance criteria associated with procedure MPI-0-000-SNBO04. Additional "visual acuity" verification for personnel performing snubber visual examinations will include visual acuity requirements that meet ASME Section X1. The training and documentation of personnel to the visual acceptance criteria, specified in the TRM implementing procedures, provides an acceptable level of quality and safety. Since relief is sought from the ASME Section XI snubber examination and test requirements, there will be no ASME Section XI snubber examination and test activities to require ANII involvement. The BFN TRM snubber program does not require the use of an ANII for examination and test requirements. The ANII will not be involved in the TRM required visual examination or testing activities performed in lieu of the ASME Code requirements. A snubber program manager provides oversight of the TRM snubber program implementation for both visual and functional testing. This oversight includes both review and evaluation of visual examination and functional testing data to ensure TRM requirements are met. The snubber program manager provides an acceptable level of quality and safety without ANII involvement in those activities. ANII involvement in other inservice repair and replacement snubber activities, as required by IWA-2110(g) and (h) and implemented by BFN's ASME Section Xl repair and replacement program will be maintained. ASME Xl, 1995 Edition, 1996 Addenda, Sub-article IWA-6230 provides the requirements in the preparation of summary report documenting the preservice and inservice inspections, and ASME OMa Code, Part 4, Sections 2.2 and 3.3 provides necessary documentation to verify the results of preservice and inservice examination and testing programs for snubbers. Under the alternate requirements for snubbers, there will be no ASME Section XI preservice and inservice examination and testing to document in a summary report. TR 3.7.4 is implemented by surveillance instructions 3-SI-4.6.H-1, 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, 0-SI-4.6.H-2C, 0-SI-4.6.H-2D, 0-SI-4.6.H-2E, and maintenance instruction MPI-0-000-SNBOO4. These instructions are written and approved in accordance with the TVA Nuclear Quality Assurance Program, include data sheets for documenting the visual examination, functional test data, and results, and provides documentation and evaluation of non conforming results. The completed data sheets are QA records and are controlled and maintained in accordance with the BFN QA records program. These records are available onsite for review and inspection. The QA records documenting snubber visual examinations and functional tests results provides an acceptable level of quality and safety when compared to the requirements of ASME Section XI and ASME OM Code-1995 Edition, 1996 Addenda, Part 4.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 159 of 166 Appendix J (Page 6 of 6) JUSTIFICATION FOR THE GRANTING OF RELIEF: (Continued) Based on the justification provided, BFN's examination and testing of snubbers, in accordance with TR 3.7.4 will provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i), (a)(3)(i) or (a)(3)(ii), TVA requests that relief be granted from the 1995 Edition of ASME Section XI Code requirements related to inservice examination and testing for snubbers. IMPLEMENTATION SCHEDULE: TR 3.7.4 will be implemented during the third ten-year ASME Section Xl inspection interval for snubber examination and testing in lieu of the code requirements listed above.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 160 of 166 Appendix K (Page 1 of 5) Snubber Request for Relief 1-ISI-18 This relief request was approved by the NRC per Reference 0 and will be implemented during the Unit 1 Cycle 7 refueling outage.

SUMMARY

Pursuant to 10 CFR 50.55a (a) (3) (i), TVA is requesting relief from the ASME Section XI Code requirements related to selection, examination, and testing of snubbers. TVA proposes to use the selection, examination, and testing plans currently contained in the BFN Unit 1 Technical Requirements Manual (TRM) TR 3.7.4, which are based on the guidance contained in Nuclear Regulatory Commission (NRC) Generic Letter 90-09. ASME Section XI imposes overlapping requirements that do not enhance the quality or safety of the snubber examination and testing program. COMPONENTS: Snubbers on Class 1, 2, and 3 (equivalent) piping and components CODE CLASS: 1, 2, and 3 (equivalent) CODE REQUIREMENT: 1995 Edition of ASME Section XI Code, 1996 Addenda CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED: IWF-5300(a) and (b), Inservice Examinations and Tests and referenced ASME/ANSI OM Part 4 (1987 with OMa-1988). IWF-5400, Repair/Replacement Activities and referenced ASME/ANSI OM Part 4 (1987 with OMa-1 988). IWA-6230, Summary Report Preparation, for snubbers. IWF-21 10(a) (5) and (c), Duties of the Authorized Nuclear Inservice Inspector (ANII), for snubbers.

Appendix K (Page 2 of 5) BASIS FOR RELIEF: ASME Section X1, Class 1, 2, and 3 equivalent snubbers are required to be selected, examined, and tested in accordance with BFN Plant Technical Requirements Manual (TRM), Technical Requirement (TR) 3.7.4. The TRM was developed based on the guidance contained in NRC Generic Letter 90-09. The Generic Letter 90-09 methodology for selection of snubbers for inspection and testing was developed to maintain a high confidence level that snubbers are capable of fulfilling their function, while minimizing radiological exposure associated with these activities. The scope for snubbers examined and tested in accordance with TR 3.7.4 is not limited by line size or other applicable code exemptions. Personnel performing examinations and testing under the TRM program are task-qualified to demonstrate the capability to perform the tasks. Under the ASME Section Xl program, inspection personnel would require qualification to ANSI/ASNT CP-189 "ASNT Standard for Qualification and Certification of Nondestructive Testing Personnel." This places an additional qualification and certification burden that is not needed to ensure the quality of snubber examinations and testing. Examination and testing of the snubbers in accordance with both ASME Section XI and the plant TRM would require maintaining two programs with different standards for selection, examination and testing of snubbers. This duplication of an existing NRC-accepted program imposes unnecessary costs and administrative burden, and would result in unnecessary additional radiological exposure without a compensating increase in safety. ALTERNATE EXAMINATIONS: The BFN TRM, TR 3.7.4, requirements will be utilized for the selection, visual examination and functional testing of snubbers for preservice, inservice, and for repair/replacement activities. The procedures utilized for these examinations are maintained by TVA per the requirements of the TVA Nuclear Quality Assurance Program. Visual examination and testing of snubbers is performed in accordance with the following procedures: 1-SI-4.6.H-1, "Visual Examination of Hydraulic and Mechanical Snubbers", 0-SI-4.6.H-2A, "Functional Testing of Mechanical Snubbers", 0-Sl-4.6.H-2B, "Functional Testing of Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubbers", 0-SI-4.6.H-2C, "Functional Testing of Bergen-Paterson Torus Dynamic Restraints", 0-SI-4.6.H-2D, "Functional Testing of Grinnell Hydraulic Snubbers", 0-SI-4.6.H-2E, "Functional Testing of Lisega Large Bore Torus Dynamic Restraint Snubbers",

Appendix K (Page 3 of 5) MPI-0-000-SNBOO1, "Hydraulic Shock and Sway Arrestor Grinnell Unit Disassembly and Reassembly", MPI-0-000-SNBOO2, "Hydraulic Shock and Sway Arrestor Bergen-Paterson, Anchor/Darling and Fronek Unit Disassembly and Reassembly", and MPI-0-000-SNBOO4, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek and Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers". The TRM requirements are applicable to the pin-to-pin portion, inclusive, of applicable snubbers. Snubber examination testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, and the implementing procedures. The structural portions of the component supports, other than the snubbers, inclusive of the pin back to the building structure and also to the component/piping being supported, will remain in the ASME Section Xl examination boundary (ISI Program). JUSTIFICATION FOR THE GRANTING OF RELIEF: The BFN Unit 1 TRM snubber inspection and testing program, defined by TR 3.7.4, provides for a level of quality and safety equal to or greater than that provided by 1995 Edition, 1996 Addenda of ASME Section XI and ASME/ANSI OM Part 4 (1987 with OMa-1988) and requirements. For BFN Unit 1, selection, examination, testing, repair and replacement of snubbers is required to be performed in accordance with both ASME'Section XI and TR 3.7.4, which is based on the guidance contained in NRC Generic Letter 90-09. The Generic Letter 90-09 methodology for selection of snubbers for inspection and testing was developed to maintain a high confidence level that snubbers are capable of fulfilling their function, while minimizing radiological exposure associated with these activities. Because ASME Section XI has a different basis for developing examination and testing plans, it is impractical to implement the requirements of both programs. Implementing both programs would require employing different criteria for identifying the total snubber inspection and testing populations, for identifying the test groups and intervals, and for determining inspection and test sample expansion when required. These contradictory requirements would result in additional cost, unnecessary program implementation complexity, and unnecessary radiological exposure. Therefore, TVA proposes that the BFN Unit 1 snubber examination and testing program be based on the requirements contained in the BFN TR 3.7.4.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 163 of 166 Appendix K (Page 4 of 5) The 1995 Edition, 1996 Addenda of ASME Section XI, Subarticle IWF-1 220 requires that inservice inspection of snubbers be performed in accordance with IWF-5000. IWF-5200 requires that examinations be performed in accordance with ASME/ANSI OM Part 4 (1987 with OMa-1988). IWF-5400 of the 1995 Edition, 1996 Addenda of ASME Section Xl requires snubber repair and replacement to be performed in accordance with IWA-4000. The BFN TRM program, defined in TR 3.7.4 (TSR 3.7.4.6) requires replacement snubbers, and snubbers that have repairs which might affect the functional test results, to be tested to meet the functional test acceptance criteria prior to installation. Accordingly, the intent of IWA-4000 is already met under the BFN Unit 1 TRM program. Futher, BFN Maintenance Procedure MPI-0-000-SNBOO4 provides visual examination criteria following installation of a snubber after repair or replacement. To meet the requirements, personnel performing snubber visual inspections must be certified in accordance with ASME Section XI VT-3 requirements. Under the TRM program, personnel are required to be "process qualified" to perform the examinations and testing. This training requires a visual test associated with face mask fit and specific training on the requirements and maintenance procedure acceptance criteria. Additional "visual acuity" verification for personnel performing snubber visual examinations will include visual acuity requirements that meet ASME Section XI. The training and documentation of personnel to the visual acceptance criteria specified in the TRM implementing procedures will provide an acceptable level of quality and safety. Because relief is sought from the ASME Section XI snubber examination and test requirements, there will be no ASME Section XI snubber examination and test activities that will require ANII involvement. The BFN TRM snubber program will not require the use of an ANII for examination and test requirements. The ANII will not be involved in the TRM required Visual examination or testing activities performed in lieu of the ASME Code requirements. A snubber program engineer will provide the oversight of the TRM snubber program implementation for both the visualexamination and functional testing. This oversight will include both review and evaluation of visual examination and functional testing data to ensure TRM requirements are met. The snubber program manager will provide the oversight that will ensure an acceptable level of quality and safety exist without ANII involvement in these activities. ANII involvement will be maintained in inservice repair and replacement snubber activities, as required by IWA-21 10(g) and (h) and implemented by BFN's ASME Section XI Repair and Replacement Program. ASME Section XI Subarticle IWA-6230 provides requirements for ISI and testing documentation for snubbers in the framework of a summary report. Under the alternate requirements for snubbers, there will be no ASME Section XI ISI to document in a summary report.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 164 of 166 Appendix K (Page 5 of 5) TR 3.7.4 will be implemented per surveillance instructions and maintenance instructions written and approved in accordance with the TVA Nuclear Quality Assurance Program. These procedures include data sheets for documenting the visual examination and functional test data and results, and provide for documentation of nonconforming results and evaluation of those results. The completed data sheets will be QA records controlled and maintained in accordance with the BFN QA records program. These records will be available onsite for review and inspection. The examination and testing of snubbers under the BFN Unit 1 TRM program provides and acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a (a) (3) (i), TVA requests that relief be granted from the ASME Section XI requirements related to IS[ and testing of snubbers. TVA's request for relief 1-ISI-18 is consistent with request for relief 3-ISI-2 submitted by TVA letters dated January 22, 1997, as supplemented by TVA letter dated October 29, 1998, for the BFN Unit 3 Second Ten-Year Inservice Inspection Interval. The NRC staff approved the request for relief by letter dated May 3, 1999. TVA's relief for Unit 1 is also consistent with request for relief 2-ISI-1 3 submitted by TVA letter dated October 25, 2002, for the BFN Unit 2 Third Ten-Year Inservice Inspection Interval. The NRC staff approved the request for relief by letter dated January 7, 2003. IMPLEMENTATION SCHEDULE: This request for relief is applicable to the remainder of the First Ten-Year Inservice (ISI) Interval for BFN Unit 1, which extends until one year following restart of the unit.

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 165 of 166 Appendix L (Page 1 of 2) Snubber Program Notebook Table of Contents (Example) Al Program Description A2 Program Basis: Technical Requirements Manual, FSAR & Design Criteria A3 Program Procedures A4 Program Contacts A5 Program Turnover B1 Drawings B2 Vendor

References:

Vendor Manuals, Vendor Correspondence B3 Snubber Program Computer Databases: Snubber Inventory Tracking Database B4 Miscellaneous Snubber Calculations B5 Master Equipment List (MEL) UNID's C1 Outstanding Modifications C2 Outstanding Temporary Conditions C3 Outstanding Changes to Design Input/Output Documents C4 Outstanding Changes to Program Procedures C5 Recommended Program Changes C6 Material Procurement Requests (Open & Closed) C7 Work Orders (Open & Closed) D1 BFN Snubber Program Health Report D2 BFN Refueling Outage Histogram D3 Snubber Program Data Packages

BFN Snubber Program Procedure 0-TI-398 Unit 0 Rev. 0005 Page 166 of 166 Appendix L (Page 2 of 2) D4 Refueling Outage Mode 4 Restraint Actions D5 Refueling Outage Final Snubber Reports / Critiques El Program Related Technical Requirements / Commitments E2 Program Related NER, OE, & INPO Documents E3 Program Related PERs E4 Program Related NRC Letters, SER, Nuregt's & LER's E5 Program Related ASME Section XI Documents E6 Program Related Incident Investigation & Employee Concerns Reports E7 Program Related Assessments E8 Program Related QDCN's and QIR's E9 Program Related TVA Correspondence F1 Training G1 Snubber Spare Parts Inventory G2 Program Service Contracts (Active & Inactive) G3 API/Barker Snubber Test Bench H1 Snubber Users Group (SNUG) Ji Miscellaneous

Attachment C BFN Surveillance Instruction, 1-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers

Browns Ferry Nuclear Plant Unit 1 Surveillance Instruction 1 -SI-4.6.H-1 Visual Examination of Hydraulic and Mechanical Snubbers Revision 0017 Quality Related Level of Use: Continuous Use Effective Date: 07-28-2008 Responsible Organization: DEC, Design Eng Civil Prepared By: Stephen Samaras Approved By: Kevin L. Groom

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 2 of 37 Current Revision Description Pages Affected: Coversheet, 2, and 25 Type of Change: REVISION Tracking Number: 019 This procedure is being revised to add a line item to record the piston indication for PSA mechanical model snubbers on Attachment 2. This revision is required by PER 139972

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 3 of 37 Table of Contents

1.0 INTRODUCTION

............................................................................. 4 1.1 Purpose....................................................................................... 4 1.2 Scope ............. ........................................................................... 4

2.0 REFERENCES

............................................................................... 5 3.0 PRECAUTIONS AND LIMITATIONS ...................................................... 5 4.0 PREREQUISITES............................................................................ 5 5.0 SPECIAL TOOLS AND EQUIPMENT RECOMMENDED ................................ 5 6.0 ACCEPTANCE CRITERIA.................................................................. 6 7.0 PROCEDURE STEPS....................................................................... 7 7.1 Training and Qualifications of Performers .................................................. 7 7.1 .1 Visual Examinations................................................................ 7 7.2 General Information .......................................................................... 7 7.3 Examination Instructions, Acceptance Criteria and Data Entry........................... 9 7.3.1 Package Preparation and Evaluation............................................. 9 7.3.2 Data Sheet Review............................................................... 10 8.0 ILLUSTRATION/ATTACHMENTS........................................................ 10 Appendix A: Snubber Listing................................................................ 11 : Surveillance Instruction Review Form...................................... 22 : Snubber Visual Examination Checklist for All Snubbers ................ 23 : Snubber Visual Examination Checklist for Bergen-Paterson, Anchor/Darling, Fronek Hydraulic Snubbers.................. 27 : Snubber Visual Examination Checklist for Lisega Torus Dynamic Restraint Hydraulic Snubbers .................................... 29 : Evaluation of Loose or Missing Attachment Fasteners.................. 33 : Engineering Evaluation of Unacceptable Indication ..................... 34 : Engineering Evaluation of Transient Event Indication(s) and Effect(s)..................................................... 36

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 4 of 37

1.0 INTRODUCTION

1.1 Purpose This Surveillance Instruction implements Technical Requirements Manual (TRM) TR 3.7.4, and provides direction for the visual examination of hydraulic and mechanical snubbers, as given in the Snubber Program Procedure (0-TI-398), on all safety-related systems, inside and outside of the drywell. 1.2 Scope For the purposes of this instruction, all snubbers are combined as one population. The snubbers are listed in Appendix A by the manufacturer and sizes which are required for the functional testing requirements. As used in this instruction, "type of snubber" shall mean snubbers of the same design and manufacturer, irrespective of capacity. The portions of Technical Requirements 3.7.4 pertaining to the functional testing of snubbers are implemented by Surveillance Instructions 0-SI-4.6.H-2A, 0-SI-4.6.H-2B, and O-SI-4.6.H-2E. This Surveillance Instruction (SI) includes provision for the as-found functional testing to establish operability of snubbers which appear inoperable as a result of the visual examination. This Surveillance Instruction (SI) provides the requirements and guidance to perform the visual examinations of all snubbers for Unit 1 as follows:

• Provides the requirements to completely fulfill the Technical Requirements Manual (TRM) visual examination of all snubbers. The interval will be as required by TR 3.7.4, Table 3.7.4-1.

     "     Provides a means for the control and documentation of all snubber visual surveillance activities provided in this Surveillance Instruction.

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 5 of 37

2.0 REFERENCES

A. Technical Requirements Manual (TR 3.7.4), Snubbers. B. Q-SI-4.6.H-2A, Functional Testing of Mechanical Snubbers. C. O-SI-4.6.H-2B, Functional Testing of Bergen-Paterson, Anchor/Darling, Fronek Hydraulic Snubbers. D. O-SI-4.6.H-2E, Functional Testing of Lisega Torus Dynamic Restraint Snubbers E. MPI-0-000-SNBOO2, Hydraulic Shock and Sway Arrestor Bergen-Paterson, Anchor/Darling, Fronek Unit Disassembly and Reassembly. F. MPI-0-000-SNBOO4, Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic, and Bergen-Paterson or Lisega Torus Dynamic Snubbers. G. 0-TI-398, Snubber Program Procedure H. SPP-3.1, Corrective Action Program I. SPP-8.1, Conduct of Testing 3.0 PRECAUTIONS AND LIMITATIONS None 4.0 PREREQUISITES None 5.0 SPECIAL TOOLS AND EQUIPMENT RECOMMENDED A. Length Measuring Scales, M&TE Measuring Test Equipment for Torus Restraints B. Inspection Mirrors, as required C. GE SF 1154 Silicon Fluid, as required (To be used for all snubbers except the LISEGA Torus Dynamic Restraints). D. LISEGA AP-280 Silicon Fluid, as required (To be used only in the LISEGA Torus Dynamic Restraints). E. Calibrated Pyrometer and M&TE measuring test equipment.

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 6 of 37 6.0 ACCEPTANCE CRITERIA Responses which fail to meet the following visual examination acceptance criteria require immediate notification of the Snubber Engineer or his designee. Ifthe snubber is determined to be inoperable, immediately notify the Shift Manager or Unit Supervisor. A. Visual examinations shall verify:

1. The snubber has no visible indications of damage or impaired operability.

2. Attachments to the foundation or supporting structure are functional.

3. Fasteners for the attachment of the snubber to the component or system and to the snubber anchorage are functional. The discovery of loose or missing attachment fasteners will be evaluated to determine whether the cause may be localized or generic. Otherwise complete Attachment 5.

4. The snubber has the proper orientation, correct location and adequate fluid level, if applicable.

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 7 of 37 7.0 PROCEDURE STEPS 7.1 Training and Qualifications of Performers 7.1.1 Visual Examinations A. A thorough briefing should be conducted on SI performance prior to starting. B. The performer or cognizant individual responsible for the performance of the Surveillance Instruction must be task qualified. C. Appropriate General Employee Training (GET) (including respirator training) should be received by the examining personnel prior to performing this SI. D. The training for the visual examinations should include orientation to the requirements of this Surveillance Instruction and will be performed under task number MMY 501, as required. E. Personnel performing this visual examination must meet the visual acuity requirements of ASME Section XI, 2001 Edition, 2003 Addenda, Paragraph IWA-2321. F. Documentation shall be maintained by the Snubber Engineer for the Visual Acuity Examinations. 7.2 General Information A. Snubbers which appear inoperable as a result of visual examination shall be classified unacceptable and may be reclassified as acceptable for the purpose of establishing the next visual examination interval, provided that:

1. The cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible, AND

2. The affected snubber is functionally tested in the As-Found condition and determined OPERABLE per the As-Found functional test acceptance criteria for that snubber.

A review and evaluation shall be performed and documented in Attachment 5, 6, or 7 as applicable, to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the LIMITING CONDITIONS OF OPERATION (LCO) for the system shall be met.

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 8 of 37 7.2 General Information (continued) B. Snubbers attached to sections of safety-related systems that have experienced unexpected potentially damaging transients since the last examination period shall be evaluated for the possibility of concealed damage and functionally tested, if applicable, to confirm OPERABILITY. C. Snubbers which have been made inoperable as the result of an unexpected transient, isolated damage, or other random events, when the provisions of TSR 3.7.4.5 and 3.7.4.6 have been met and any other appropriate corrective action implemented, shall NOT be counted in determining the next visual examination interval. D. A Surveillance Instruction Review Form, Attachment 1, shall be completed and submitted with the data package for each complete or partial performance of this SI. E. All visual examinations shall be performed and documented on Attachments 2, 3, and 4, as applicable prior to removal of each snubber for the As-Found functional testing. The Attachments shall be submitted with the data package. F. Evaluation sheets Attachments 5, 6, and 7 shall be prepared and submitted with the data package, as appropriate, by the Snubber Engineer/SE Designee for each degraded/ inoperable snubber identified by performance of this instruction. G. The snubbers are assigned a UNID number in an appropriate tracking program, which provides current and historical information for a specific snubber/support location. H. The snubbers are listed in Appendix A by exam number. I. A unique snubber/support number is given to each snubber location on a system.

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 9 of 37 7.3 Examination Instructions, Acceptance Criteria and Data Entry 7.3.1 Package Preparation and Evaluation NOTES

1) The operability of the snubber is determined based on the examinations performed and further evaluations which may include a functional test. If it is determined that the snubber does not meet the visual examination acceptance criteria, immediately notify the Snubber Engineer/SE Designee.

2) If further evaluations, which may include a functional test, are acceptable, the snubber is operable.

3) The snubber is NOT counted as inoperable, and the examination interval is NOT shortened, if the snubber is proven operable by the functional test.

[1] If any snubber is determined to be inoperable, Site Engineering Civil should INITIATE a Problem Evaluation Report (PER). MMG Planning should write a minor maintenance Work Order (WO) to perform the necessary repairs required to return the inoperable snubber to operable status. [2] At the discretion of the Snubber Engineer/SE Designee, FUNCTIONALLY TEST snubbers indicated to be inoperable by visual examination to establish operability if the unacceptable indication relates to the internal functioning of the snubber. This shall be documented on Attachment 6 or 7, as appropriate. [3] Functional tests shall be performed in accordance with O-SI-4.6.H-2A, -2B, or

                 -2E.

[4] NOTIFY Site Engineering Civil to perform an engineering evaluation for any inoperable snubber. [5] An "AC", "UNAC", or "N/A" entry must be provided in the appropriate space, on Attachments 2, 3, or 4, as appropriate, for each snubber scheduled for examination that the SI is fulfilling. [6] VERIFY Attachment 1, 2, 3, 4, and other appropriate Attachments, have been reviewed by the Snubber Engineer/SE Designee from Site Engineering Civil, prior to closure of this Surveillance Instruction.

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 10 of 37 7.3.2 Data Sheet Review [1] VERIFY any Work Orders have been satisfactorily completed and PERs have had the corrective actions completed or closed. [2] VERIFY that all applicable Attachments are complete for the snubber being visually examined. [3] VERIFY failure analysis of inoperable snubber(s) has been completed, as required. [4] VERIFY the Site Engineering Civil evaluation for the supported system/component analysis, from the appropriate functional test procedure for inoperable snubber(s), has been completed and is acceptable. [5] VERIFY that the evaluation of loose or missing attachment fasteners has been completed, if required. [6] VERIFY the Snubber Engineer or SE-Designee has reviewed all appropriate Attachments 2, 3, 4, 5, 6, and 7. 8.0 ILLUSTRATION/ATTACHMENTS Appendix A- Snubber Listing. Attachment 1, Surveillance Instruction Review Form. Attachment 2, Snubber Visual Examination Checklist For All Snubbers. Attachment 3, Snubber Visual Examination Checklist For Bergen-Paterson, Anchor/Darling, Fronek Hydraulic Snubbers. Attachment 4, Snubbe, Visual Examination Checklist For Lisega Torus Dynamic Restraint Hydraulic Snubbers. Attachment 5, Evaluation of Loose or Missing Attachment Fasteners. Attachment 6, Engineering Evaluation of Unacceptable Indication. Attachment 7, Engineering Evaluation of Transient Event Indication and Effect.

Visual Examination of Hydraulic and 11-SI-4.6.H-1 Mechanical Snubbers Rev. 0017 Page 11 of 37 Appendix A (Page I of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional Test 1 1-47B403-SU 1-471403-8 BFN-1-SNUB-064-5030 PSA 35 TORUS ROOM EL. 525 AZ. 30 L Y 2 1-47B403-8L 1-47B403-8 BFN-1-SNUB-064-5031 PSA 35 TORUS.ROOM EL. 525 AZ. 30 N N 3 1-47B403-1 1-47B403-1 BFN-1-SNUB-064-5020 PSA 35 TORUS ROOM EL. 525 AZ. 45 N N 4 1-47B403-7U 1-47B403-7 BFN-1-SNUB-064-5028 PSA 35 TORUS ROOM EL. 525 AZ. 57 L Y 5 1-47B403-7L 1-47B403-7 BFN-1-SNUB-064-5029 PSA 35 TORUS ROOM EL. 525 AZ. 57 N N 6 1-47B-403-4 1-4784034 BFN-1-SNUB-064-5023 PSA 35 TORUS ROOM EL. 525 AZ. 109 N N 7 1-47B403-9U 1-47B403-9 BFN-1-SNUB-064-5032 PSA 35 TORUS ROOM EL. 525 AZ. 143 L Y 8 1-471403-9L 1-47B403-9 BFN-1-SNUB-064-5033 PSA 35 TORUS ROOM EL. 525 AZ. 143 N N 9 1-47B403-5U 1-47B403-5 BFN-1-SNUB-064-5024 PSA 35'.- TORUS ROOM EL. 525 AZ. 225 L Y 10 1-47B403-5L 1-471403-5 BFN-1-SNUB-064-5025 PSA 35 TORUS ROOM EL. 525 AZ. 225 N N 11 1-47B403-2 1-478403-2 BFN-1-SNUB-064-5021 PSA 35 TORUS ROOM EL. 525 AZ. 242 N N 12 1-47B403-3 1-478403-3 BFN-1-SNUB-064-5022 PSA 35 TORUS ROOM EL. 525 AZ. 315 N N 13 1-47B403-6U 1-478403-6 BFN-1-SNUB-064-5026 PSA 35 TORUS ROOM EL. 525 AZ. 330 L Y 14 1-47B403-6L 1-478403-6 BFN-1-SNUB-064-5027 PSA 35 TORUS ROOM EL. 525 AZ. 330 N N 15 TORUS R1 1-48W1264-1 BFN-1-SNUB-064-5001 LISEGA 312150 TORUS ROOM EL. 526 BAY 1 AZ. 11 L Y 16 TORUS R2 1-48W1264-1 BFN-1-SNUB-064-5002 LISEGA 312150 TORUS ROOM EL. 526 BAY 2 AZ. 34 L Y 17 TORUS R3 1-48W1264-1 BFN-1-SNUB-064-5003 LISEGA 312150 TORUS ROOM EL. 526 BAY 3 AZ. 56 L Y 18 TORUS R4 1-48W1264-1 BFN-1-SNUB-064-5004 LISEGA 312150 TORUS ROOM EL. 526 BAY 4 AZ. 79 L Y 19 TORUS R5 1-48W1264-1 BFN-1-SNUB-064-5005 LISEGA 312150 TORUS ROOM EL. 526 BAY 5 AZ. 101 L Y 20 TORUS R6 1-48W1264-1 BFN-1-SNUB-064-5006 LISEGA 312150 TORUS ROOM EL. 526 BAY 6 AZ. 124 L Y 21 TORUS R7 1-48W1264-1 BFN-1-SNUB-064-5007 LISEGA 312150 TORUS ROOM EL. 526 BAY 7 AZ. 146 L Y 22 TORUS R8 1-48W1264-1 BFN-1-SNUB-064-5008 LISEGA 312150 TORUS ROOM EL. 526 BAY 8 AZ. 169 L Y 23 TORUS R9 1-48W1264-1 BFN-1-SNUB-064-5009 LISEGA 312150 TORUS ROOM EL. 526 BAY 9 AZ. 191 L Y 24 TORUS R10 1-48W1264-1 BFN-1-SNUB-064-5010 LISEGA 312150 TORUS ROOM EL. 526 BAY 10 AZ. 213 L Y 25 TORUS R11 1-48W1264-1 BFN-1-SNUB-064-5011 LISEGA 312150 TORUS ROOM EL. 526 BAY 11 AZ. 236 L Y

Visual Examination of Hydraulic and 1-SI-4.6.H-1 Mechanical Snubbers Rev. 0017 Page 12 of 37 Appendix A (Page 2 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPEISIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional ITest 26 TORUS R12 1-48W1264-1 BFN-1-SNUB-064-5012 LISEGA 312150 TORUS ROOM EL, 526 BAY 12 AZ. 259 L Y 27 -TORUS Ri;3 1-48W1264-1 jBFN-1-SNUB-064-5013 LISEGA 312150 TORUS ROOM EL. 5,26 BAY 13 AZ. 281 L 28 TORUS R14 1-48W1264-1 BFN-1-SNUB-064-5014 LISEGA 312150 I TORUS ROOM EL. 526 BAY 14 AZ. 304 L Y 29 TORUS R15 1-48W1264-1 BFN-1-SNUB-064-5015 LISEGA 312150 j TORUS ROOM EL. 526 BAY 15 AZ. 327 L Y 30 TORUS R16 1-43W1264-1 BFN-1-SNUB-064-5016 LISEGA 312150 I TORUS ROOM EL. 526 BAY 16 AZ. 348 L Y 31 1-47B452-3291 1-47B452-3291-i BFN-1-SNUB-074-5101 PSA 35 TOP OF TORUS EL. 552 BAY 3 1-ISI-0363-C 8 OF 12 N N 32 1-47B452-3077 1-47B452-3077 BFN-1-SNUB-074-5072 PSA 10 TOP OF TORUS EL. 549 BAY 3, AZ 530 1-ISI-0363-C 8 OF 12 N Y 33 1-47B455-39 1-47B455-39 BFN-1-SNUB-073-5023 PSA 3 TOP OF TORUS EL. 539 BAY 4, AZ 670 Y Y 34 1-47B452-3295 1-47B452-3295 BFN-1-SNUB-074-5090 PSA 10 TOP-OF TORUS EL. 555 BAY4 1-ISI-0363-C 8 OF 12 Y Y 35 1-47B553-151 1-47B553-151 BFN-1-SNUB-002-5021 PSA 3 TOP OF TORUS EL. 548 BAY 5 Y Y 36 1-47B452-3302 1-47B452-3302 BFN-1-SNUB-074-5106 PSA 3 TOP OF TORUS EL. 555 BAY 5 N N 37 1-47B452-3306 1-47B452-3306 BFN-1-SNUB-074-5092 PSA 10 TOP OF TORUS EL. 554 BAY 5 N N 38 1-47B452-3304N 1-47B452-3304 BFN-1-SNUB-074-5102 PSA 1 TOP OF TORUS EL. 554 BAY 5 N N 39 1-47B452-3304S 1-47B452-3304 BFN-1-SNUB-074-5103 PSA 1 TOP OF TORUS EL. 554 BAY 5 N N 40 1-47B452-3307NE 1-47B452-3307 BFN-1-SNUB-074-5104 PSA 1 TOP OF TORUS EL. 554 BAY 5 N N 41 1-47B452-3307SW 1-47B452-3307 BFN-1-SNUB-074-5105 PSA 1 TOP OF TORUS EL. 554 BAY 5 N N 42 1-47B452-3299 1-47B452-3299 BFN-1-SNUB-074-5091 PSA 10 TOP OF TORUS EL. 555 BAY 5 N N 43 1-47B452-3318N 147B452-3318 BFN-1-SNUB-074-5096 PSA 35 TOP OF TORUS EL. 549 BAY 5 Y Y 44 1-47B452-3318S 1-47B452-3318 BFN-1-SNUB-074-5097 PSA 35 TOP OF TORUS EL. 549 BAY 5 Y Y 45 1-47B456-65 1-47B456-65 BFN-1-SNUB-071-5025 PSA 1 TOP OF TORUS EL. 553 BAY 5 N N 46 1-47B456-618 1-47B456-618 BFN-1-SNUB-071-5026 PSA 3 TOP OF TORUS EL. 553 BAY 5 N N 47 1-47B553-154 1-47B553-154 BFN-1-SNUB-002-5022 PSA 3 TOP OF TORUS EL. 548 BAY 6 Y Y 48 1-47B553-156 1-47B553-156 BFN-1-SNUB-002-5023 PSA 3 TOP OF TORUS EL. 548 BAY 6 Y Y 49 1-47B553-162NW 1-47B553-162 BFN-1-SNUB-002-5025 PSA 3 TOP OF TORUS EL. 548 BAY 8 Y Y 50 1-47B553-162NE 1-47B553-162 BFN-1-SNUB-002-5026 PSA 10 TOP OF TORUS EL. 548 BAY 8 Y Y

Visual Examination of Hydraulic and 1-SI-4.6.H-1 Mechanical Snubbers Rev. 0017 Page 13 of 37 Appendix A (Page 3 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional _Test 262 RCIC R-7U BP1808 SHT,1 OF 2 BFN-1-SNUB-071-5013 HSSA3 TOP OF TORUS EL. 548 BAY 8 N Y 263 RCIC R-7L BP1808 SHT 101F 2 BFN-1-SNUB-071-5014 HSSA 3 TOP OF TORUS EL. 548 BAY 8 N Y 51 1-47B553-165 . 1-47553-165 [BFN-1-SNUB-002-5016 'PSA10 TOP OF TORUS EL. 548 BAY 9 Y Y 52 1-47B553-169 1-47B553-169 BFN-1-SNUB-002-5024 PSA 3 TOP OF TORUS EL. 548 BAY 9 Y Y 53  !-47B55-11-47-478553-172 BFN-1-SNUB-002-5017 PSA 10 TOP OF TORUS EL. 548 BAY 10 Y Y 54 1-47B553-175 1-471553-175 BFN-1-SNUB-002-5019 PSA 3 TOP OF TORUS EL. 548 BAY 11 Y Y 5 i-47B452-3317N 1-47B452-3317 BFN-1-SNUB-074-5094 PSA 35 TOP OF TORUS EL. 549 BAY 13 Y Y 56 1-47B452-3317S 1-478452-3317 BFN-1-SNUB-074-5095 PSA 35 TOP OF TORUS EL. 549 BAY 13 Y Y 57 1-47D452-3263 1-47B452-3263 BFN-1-SNUB-074-5084 PSA 10 TOP OF TORUS EL. 555 BAY 13 1-ISI-0363-C 9 OF 12 Y Y 58 1-47B452-3250NW 1-47B452-3250 BFN-1-SNUB-074-5075 PSA 3 TOP OF TORUS EL. 553 BAY 13 N N 59 1-47B452-3250NE 1-47B452-3250 BFN-1-SNUB-074-5076 PSA 3 TOP OF TORUS EL. 553 BAY 13 N N 60 1-47B452-3251 1-47B452-3251 BFN-1-SNUB-074-5077 PSA 3 TOP OF TORUS EL. 555 BAY 13 N N 61 1-47B452-3252N 1-47B452-3252 BFN-1-SNUB-074-5078 PSA 1 TOP OF TORUS EL. 556 BAY 13 1-ISI-0363-C 9 OF 12 N N 62 1-47B452-3252S 1-478452-3252 BFN-1-SNUB-074-5079 PSA 1 TOP OF TORUS EL. 556 BAY 13 1-ISI-0363-C 9 OF 12 N N 63 1-478452-3254 1-47B452-3254 BFN-1-SNUB-074-5080 PSA 3 TOP OF TORUS EL. 555 BAY 13 1-ISI-0363-C 9 OF 12 N N 64 1-478553-183 1-47B553-183 BFN-1-SNUB-002-5020. PSA 3 TOP OF TORUS EL. 548 BAY 13 Y Y 65 1-47B553-186 1-478553-186 BFN-1-SNUB-002-5018 PSA 10 TOP OF TORUS EL. 548 BAY 14 Y Y 66 1-47B452-3266 1-478452-3266 BFN-1-SNUB-074-5085 PSA 10 TOP OF TORUS EL. 555 BAY 14 1-ISI-0363-C 9 OF 12 N N 67 1-47B452-3259 1-47B452-3259 BFN-1-SNUB-074-5083 PSA 3 TOP OF TORUS EL. 555 BAY 14 1-ISI-0363-C 10 OF 12 N N 68 1-47B452-3258NW 1-47B452-3258 BFN-1-SNUB-074-5081 PSA 3 TOP OF TORUS EL. 553 BAY 14 1-1SI-0363-C 10 OF 12 N N 69 1-47B452-3258SE 1-47B452-3258 BFN-1-SNUB-074-5082 PSA 3 TOP OF TORUS EL. 553 BAY 14 1-ISI-0363-C 10 OF 12 N N 70 1-47B452-3274 1-478452-3274 BFN-1-SNUB-074-5100 PSA35 TOP OF TORUS EL. 553 BAY 15 1-ISI-0363-C 9 OF 12 N N 71 1-47B452S0175 1-47B452S0175 BFN-1-SNUB-074-5043 HSSA 20 TOP OF TORUS EL. 549 BAY 15 1-ISI-0363-C 9 OF 12 Y Y 72 1-47B452R0012 1-47B452R0012 BFN-1-SNUB-074-5044 HSSA 20 TOP OF TORUS EL. 549 BAY 15 1-ISI-0363-C 9 OF 12 Y Y 73 1-47B452R0007 1-47B452R0007 BFN-1-SNUB-074-5037 HSSA 10 S E QUAD RHR PUMP ROOM B & D EL. 536 1-ISI-0363-C 6 OF 12 L Y

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 14 of 37 Appendix A (Page 4 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional _ __ ITest 74 1-47B452S0204 1-475452S0204 BFN-1.-SNUB-074-5036 I -',SSA 10 SE QUAD RHR PUMP ROOM B & DEL. 536 1-S-0363-C6OF 12 L Y 75 1-4,DV,2R_006 1-47B452R0006 S -SSA S E QUAD RHR PUMP ROOM B & D EL. 539 . 1-1SI-0363-C 6 OF 12 L Y 7 1-47B452S0203 1-47B452S0203 BFN-1-SNUB-074-5035 PSA 10 S E QUAD RHR PUMP ROOM B & D EL. 542 1 1-ISI-0363-C 6 OF 12 N N 77 1-47B452R0008 1-47B452R0008 BFN-1-SNUB-074-5039 PSA 3 S E QUAD RHR PUMP ROOM B & D EL. 558 1-ISI-0363-C 6 OF 12 L Y S147B452S0205 BFN-1-SNUR-074-5033 PSA 3 S E QUAD RHR PUMP ROOM B & D EL. 558 1-iSI-0363-C 6 OF i2 L Y

      '-47B458-828E 1__                  1-47B458-828    BFN-I-SNUB-075-5036     PSA 10        NE QUAD C S PUMP ROOM B & D EL. 538                               L          Y 1

800 -47B458-328W . 1-47B458-828 BFN-1-SNUB-075-5037 PSA i0 NE QUAD C S PUMP ROOM B & D EL. 538 L Y 81 i-47B458-826E 1-47B458-826 BFN-1-SNUB-075-5034 PSA 10 NE QUAD C S PUMP ROOM B & D EL. 554 L Y 82 1-47B458-826W 1-47B458-826 BFN-1-SNUB-075-5035 PSA 10 NE QUAD C S PUMP ROOM B & D EL. 554 L Y 83 1-47B458-824 1-47B458-824 BFN-1-SNUB-075-5033 PSA 3 NE QUAD C S PUMP ROOM B & D EL. 544 L Y 84 1-47B456-97NW 1-47B456-97 BFN-1-SNUB-071-5029 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 527 1-ISI-0094-C 1 OF 1 L Y 85 1-47B456-97SW 1-47B456-97 BFN-1-SNUB-071-5030 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 527 1-ISI-0094-C 1 OF 1 L Y 86 1-47B456-57U 1-47B456-57 BFN-1-SNUB-071-5027 PSA 1/2 NW QUAD C S PUMP ROOM A & C EL. 527 1-ISI-0094-C 1 OF 1 L Y 87 1-47B456-57L 1-47B456-57 BFN-1-SNUB-071-5028 PSA 1/2 NW QUAD C S PUMP ROOM A & C EL. 527 1-ISI-0094-C 1 OF 1 L Y 88 1-47B456-49N 1-47B456-49 BFN-1-SNUB-071-5023 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 535 1-ISI-0094-C 1 OF 1 L Y 89 1-47B456-49W 1-47B456-49 BFN-1-SNUB-071-5024 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 535 1-ISI-0094-C 1 OF 1 L Y 90 1-47B456-48NE 1-47B456-48 BFN-1-SNUB-071-5022 PSA 10 NW QUAD C S PUMP ROOM A & C EL. 538 1-ISI-0094-C 1 OF 1 L Y 91 1-47B456-48SW 1-47B456-48 BFN-1-SNUB-071-5021 PSA 10 NW QUAD C S PUMP ROOM A & C EL. 538 1-ISI-0094-C 1 OF 1 L Y 92 1-47B458-969E 1-471458-969 BFN-1-SNUB-075-5041 PSA 10 NW QUAD C S PUMP ROOM A & C EL. 538 L Y 93 1-47B458-969W 1-47B458-969 BFN-1-SNUB-075-5042 PSA 10 NW QUAD C S PUMP ROOM A &C EL. 538 L Y 94 1-47B458-965 1-47B458-965 BFN-1-SNUB-075-5038 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 544 N N 95 1-47B458-966E 1-47B458-966 BFN-1-SNUB-075-5039 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 544 N N 260 RCIC R-5E BP1806 SHT 1 OF 2 BFN-1-SNUB-071-5011 HSSA 3 NW QUAD C S PUMP ROOM A & C EL. 538 N Y 261 RCIC R-5S BP1806 SHT 1 OF 2 BFN-1-SNUB-071-5012 HSSA 3 NW QUAD C S PUMP ROOM A & C EL. 538 N N 96 1-478458-966W 1-47B458-966 BFN-1-SNUB-075-5040 PSA 3 NW QUAD C S PUMP ROOM A & C EL. 544 N N

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 15 of 37 Appendix A (Page 5 of 11) Snubber Listing EXAM SUPPORT# SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional Test 01"_  !"47B455-746 --4713455-746 BFN-l-SNUB-073-5027 PSA 3 SW QUAD RHR PUMP ROOM A & C EL. 525 1-6SI-0092-C 2 OF 2 N N 9 1-7421347E -47B452-14741 BFN-!-SNUB-S i S 1E-474ý074-5068

                                                                             £_         SW QLIAD RHR PUMP ROOM A & C EL. 532    i'1-ISI-0363-C 4 OF 1 99      1-47B452-1472         1-47B452-1472    BFN-1-SNUB-074-5010      PSA10                                       A& C EL. 534    1-ISI-0363-C 4 OF 12        L
 -100* 1-47B452-1466     1  -74713452-1466    BFN-1 --SNUB-074-5069    PSA 10           SW- QUAD RHR PUMP ROOM A & C EL. 537       1-1SI-0363-C 4 OF 12        LY 101,    1-47345)5-50          _1-47B455-50               U.-7375026 1N-1          PSAI!           SW QUAD RHR PUMP ROOM A & C EL. 538                                    L          Y 102     1-47B455-49NE           1-47B455-149   BFN-1-SNU-073-5024       PSA 104        sw   QUAD RHR PUMP ROOM A & C EL. 539                                    L          Y 103"-*  1-47B455--49SW          1-47B455-49    BFN-1-SNUB-073-5025      PSA 1/4 ...      SW. QUAD RHR PUMP ROOM A & C EL. 539                                   L          Y 104     11-47134,59-781-1       1-478455-78    BFN-1-SNUB-073-5028      PSA10                      HPCI ROOM EL. 527,                 !-ISI-0092-C 2 OF 2       L          Y 105     11-47455-781-           1-47B455-78    BFN-1-SNUB-073-5029      PSA 10                     HPCI ROOM EL. 523                  1-ISI-0092-C 2 OF 2       L          Y 106     1-47B455-55U            1-47B455-55    BFN-1-SNUB-073-5021      PSA 35                     HPCI ROOM EL. 539                  1-ISI-0092-C 1 OF 2       L          Y 107     1-47B455-55L            1-47B455-55    BFN-1-SNUB-073-5022      PSA 35                     HPCI ROOM EL. 537                  1-9SI-0092-C 1 OF 2       L          Y 108     1-47B455-54             1-47B455-54    BFN-1-SNUB-073-5020      PSA 10                     HPCI ROOM EL. 538                                            L          Y 109     1-47B452-3286NE       1-47B452-3286    BFN-1-SNUB-074-5088      PSA 10          CLEAN ROOM WEST SIDE R3-R4 & T EL.565      I1-ISI-0363-C 8 OF    12     N          N 110     1-47B452-3286NW       1-47B452-3286    BFN-1-SNUB-074-5089      PSA 10         CLEAN ROOM WEST SIDE R3-R4 & T EL565          1-ISI-0363-C 8 OF 12       N          N 16      1-47B452-3276NE       1-478452-3276    BFN-1-SNUB-074-5086      PSA10           CLEAN ROOM EAST SIDE R3-R4 & T EL.565        1-ISI-0363-C 9 OF 12       N          N 112     1-47B452-3276NW       1-47B452-3276    BFN-1-SNUB-074-5087      PSA 10          CLEAN ROOM EAST SIDE R3-R4 & T EL.565        1-ISI-0363-C 9 OF 12       N          N 113     1-47B452-3257N        1-47B452-3257    BFN-1-SNUB-074-5098      PSA 10                       R6 & S EL. 578                 1-ISI-0363-C 10 OF 12       L          Y 114     1-47B452-3257S        1478452-3257     BFN-1-SNUB-074-5099      PSA 10                       R6 & S EL. 578                 1-1S-0363-C 10 OF 12        L          Y 264     RCIC R-9N           BP1810 SHT 1 OF 2  BFN-1-SNUB-071-5015      HSSA 3                   STEAM TUNNEL EL. 564                                           N          N 265     RClC R-9S           BP1810 SliT 1 OF 2 BFN-1-SNUB-071-5016      HSSA 3 -                 STEAM TUNNEL EL. 564                                           N          N 115     1-47B452R0014E        1-47B452R-214    BFN-1-SNUB-074-5046       PSA 3            RHR HEAT EXCHGR ROOM B & D EL.572               1-SI-0363-C-7         L          Y 116     1-47B452R0014W        1-47B452R-214    BFN-1-SNUB-074-5047       PSA 3            RHR HEAT EXCHGR ROOM B & D EL.572               1-SI-0363-C-7         L          Y 117     1-47B452R0013         1-47B452R-213    BFN-1-SNUB-074-5045      PSA 10            RHR HEAT EXCHGR ROOM B & D EL.572               1-ISI-0363-C-7        L          Y 118     1-47B452-3315         147B452-3315     BFN-1-SNUB-074-5093      PSA 10                     R3-R4 & S-T EL. 598                1-ISI-0363-C-11           N          N 119     1-478452-3249         1-47B452-3249    BFR-1-SNUB-074-5073      PSA 1/2                       R3 &S EL. 601                                             N          N

Visual Examination of Hydraulic and l-SI-4.6.H-1 Mechanical Snubbers Rev. 0017 Page 16 of 37 Appendix A (Page 6 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For - Functional

                                                                                                                                                             'rest
,20    1-47B465-480   I         ---

1-47B465-480 BFN-1-SNUB-068-5023 PSA 10 DRYIA/ELL BASEMENT EL. 556 AZ 90 1-CHM-2037-C 2 OF 2 N N 21 i_ -47B46598 1-47B455-498 BFN-1-SNUB-068-5026 PSA 35 I DRYWELL BASEMENT EL. 560 AZ 122 1-CHM-2037-C 2 OF 2 L N5

       .471465-497           1-47B465-497     BFN-1-SNUB-068-5025     PS/\ 35        DRYWELL BASEMENT EL. 552 AZ 135     1-CHM-2037-C 2 OF 2       N           N 12       -471465-474          47B1465-474   BFN-1-SNUB-068-5O22     PSA 10         DRYWELL BASEMENT EL. 552 AZ 175     1-CH1HM-2037-C 2 OF 2                 N 1-47B465499           1-47B465-499     BFN-1-SNUB-068-5027     PSA 35.        DRYWELL BASEMENT EL. 560 AZ 148     1-CHM-2037-C 2 OF 2       N           N 1

12 1 1-47B401-62 1-47B465-457 li-47B401-62

                             ;.-47B465-457 I BFN1SNUB-010-50221 BFN-1-SNUB-068-5021 PSA3           DRYWELL BASEMENTEL. 562 AZ 257                                L            '

PSA 3 DRYWELL BASEMENT EL. 556 AZ 270 1-CHM-2037-C 1 OF 2 N N 7 1-47B465-515 -47B465-515 BFN-1-SNUE-068-5036 PSA 35 DRYWELL BASEMENT EL. 560 AZ 302 PMP 1A 1-CHM-2037-C 1 OF 2 L Y 128 1-47B465-513 1-47B465-513 BFN-1-SNUB-068-5034 PSA 35 DRYWELL BASEMENT EL. 552 AZ 315 1-CHM-2037-C 1 OF 2 N N 129 1-47B465-514 1-47B465-514 BFN-1-SNUB-068-5035 PSA 35 DRYWELL BASEMENT EL. 560 AZ 320 1-CHM-2037-C 1 OF 2 L Y 130 1-478465-454 1-47B465-454 BFN-1-SNUB-068-5020 PSA 35 DRYWELL BASEMENT EL. 554 AZ 356 1-CHM-2037-C 1 OF 2 L Y 131 1-478452-3041 1-47B452-3041 BFN-1-SNUB-074-5065 PSA 35 DRYWELL GRATING EL. 579 AZ 0 1-CHM-2039-C 1 OF 1 L Y 132 1-478452-3042 1-478452-3042 BFN-1-SNUB-074-5066 PSA 35 DRYWELL GRATING EL. 579 AZ 0 1-CHM-2039-C 1 OF 1 L Y 133 1-47B452-3040 1-478452-3040 BFN-1-SNUB-074-5064 PSA 35 DRYWELL GRATING EL. 579 AZ 30 1-CHM-2039-C 1 OF 1 L Y 134 1-478400-118 1-478400-118 BFN-1-SNUB-001-5073 HSSA-10 DRYWELL GRATING EL. 582 AZ 39 1-CHM-2038-C-2 L Y 135 1-47B455-2125 1478455-2125 BFN-1-SNUB-073-5078 PSA 3 DRYWELL GRATING EL. 571 AZ 45 1-CHM-2043-C 1 OF 1 L . Y 136 1-478455-622 1-478455-622 BFN-1-SNUB-073-5077 PSA 3 DRYWELL GRATING EL. 563 AZ 45 1-CHM-2043-C 1 OF 1 N N 137 1-47B452-3359 147B452-3359 BFR-1-SNUB-074-5107 PSA 35 DRYWELL GRATING EL. 581 AZ 90 1-CHM-2039-C 1 OF I L Y 138 1478465-546 1-478465-546 BFN-1-SNUB-068-5042 PSA 35 DRYWELL GRATING EL. 565 AZ 90 1-CHM-2037-C 2 OF 2 N N 139 147B465-484 1-478465-484 BFN-1-SNUB-068-5024 PSA 35 DRYWELL GRATING EL. 566 AZ 90 1-CHM-2037-C 2 OF 2 N N 140 1-478400-229 147B400-229 BFN-1-SNUB-001-5091 PSA I DRYWELL GRATING EL. 566 AZ161 N N 141 1-47B400-89 1-47B400-89 BFN-1-SNUB-001-5080 HSSA 20 DRYWELL GRATING EL. 584 AZ 98 1-CHM-2038-C-1 N N 142 1-478400-88 1-47B400-88 BFN-1-SNUB-001-5079 HSSA 20 DRYWELL GRATING EL. 584 AZ 98 1-CHM-2038-C-1 N N 143 1478465-508 1-478465-508 BFN-1-SNUB-068-5031 PSA 35 DRYWELL GRATING EL. 580 AZ 98 1-CHM-2037-C 2 OF 2 L Y 144 1-478401-74 NE 1-47B401-74 BFN-1-SNUB-010-5051 PSA10 DRYWELL GRATING EL. 564 AZ 104 N N

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 17 of 37 Appendix A (Page 7 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional 14 1-4713401-74 SAW i.-E47B401-74 BFN-1-SNUB-010-505,`2 PSA t0 DRYWELL GRATING EL. 564 AZ 104 N Test Nes 146 ..... 4-

                               -,47,9465-503      F'--SU-8-28                SA3DRWLGATNE.56AZ115                             1-CH-M-2037-C 2OF 2          N          Y 14    1-4713465-504 f-47B465-505              -,.1 D,,,4,1-5*,4*

1-47B465-5055** BN1SU-18-r2 BFN-l-SNUB-068-500 PSA 35. PSA 35 j DRYW,.ELL GRATING DRYWELL GRATIlNG EL. EL. 566 570 AZ AZ 154 135 1-CHM-2037-C 2 I-CHM-2037-C 2OF OF 22 L N Y YF 1-473400-2200-224 BFN-I-SNUB-001-5089 PSA 1 DRYWELL GRATING EL. 575 AZ 172 [ L Y 1-47B400-225 150 4 -4 r,, 1-47B456-693

                      -2 V_       13400225 1--!,B4700-235 1-4713456-693 BFN-1-SNUB-001-50390 BFN-1-SNUB-071-50-20 I"

{ PSA1!4tDRYWELL PSA 11 G I GRATING EL. 576 AZ 172 DRYWELL GRATING EL. 584 AZ 223 L L Y 153 1-47N401-51 NW 1-478401-51 BFN-1-SNUB-010-5045 PSAP10 DRYWELL GRATING EL. 584 AZ 223 L Y 154 1-47N401-51 NE 1-47B401-51 BFN-1-SNUB-010-5046 PSA 10 DRYWELL GRATING EL. 584 AZ 223 L Y 155 1-47B401-41 NE 1-47B401-41 BFN-1-SNUB-010-5023 PSA 10 DRYWELL GRATING EL. 583 AZ 229 L Y 156 1-478401-41 SE 1-478401-41 BFN-1-SNUB-010-5024 PSA 10 DRYWELL GRATING EL. 583 AZ 229 L Y 157 1-47B401-61 1-47B401-61 BFN-1-SNUB-010-5013 PSA 3 DRYWELL GRATING EL. 575 AZ 258 L Y 158 1-47B465-512 1-47B465-512 BFN-1-SNUB-068-5033 PSA 35 DRYWELL GRATING EL. 580 AZ 260 1-CHM-2037-C 1 OF 2 L Y 159 1-47B400-74 1-47B400-74 BFN-1-SNUB-001-5067 PSA 35 DRYWELL GRATING EL. 584 AZ 261 1-CHM-2038-C-1 L Y 160 1-47B465-511 1-47B465-511 BFN-1-SNUB-068-5032 PSA 35 DRYWELL GRATING EL. 580 AZ 262 1-CHM-2037-C 10F2 L Y 161 1-47B465-545 1-47B465-545 BFN-1-SNUB-068-5041 PSA 35 DRYWELL GRATING EL. 566 AZ 270 1-CHM-2037-C 1 OF 2 L Y 162 1-47B465-524 1-478465-524 BFN-1-SNUB-068-5040 PSA 35 DRYWELL GRATING EL. 565 AZ 270 1-CHM-2037-C 1 OF 2 L Y 163 1-47B452-3034 1-47B452-3034 BFN-1-SNUB-074-5063 PSA 35 DRYWELL GRATING EL. 577 AZ 270 1-CHM-2039-C 1 OF 1 N N 164 1-47B452-3047 1-47B452-3047 BFN-1-SNUB-074-5067 PSA 35 DRYWELL GRATING EL. 577 AZ 276 1-CHM-2039-C 1 OF 1 N N 165 1-478465-521 1-47B465-521 BFN-1-SNUB-068-5039 PSA 35 DRYWELL GRATING EL. 566 AZ 285 1-CHM-2037-C I OF 2 N Y 166 1-47B465-520 1-47B465-520 BFN-1-SNUB-068-5038 PSA 35 DRYWELL GRATING EL. 570 AZ 315 1-CHM-2037-C 1 OF 2 L Y 167 1-478400-103 1-47B400-103 BFN-1-SNUB-001-5086 PSA 10 DRYWELL GRATING EL. 584 AZ 320 1-CHM-2038-C-2 N N 168 1-47B400-104 1-478400-104 BFN-1-SNUB-001-5087 HSSA 10 DRYWELL GRATING EL. 584 AZ 327 1-CHM-2038-C-2 N Y 169 1-47B401-46 E 1-47B401-46 BFN-1-SNUB-010-5041 PSA 10 DRYWELL GRATING EL. 576 AZ 330 L Y

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 18 of 37 Appendix A (Page 8 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional Test 170 .1-47B401 -6 W 17-401-46 BFN-1-SNUB-010-5042 PSA '0 DRYWELL GRATING EL. 576 AZ 330 L y

 -17!   ! 1-4713_-_,__       , _        1-4713401-33

_B,_,-1-SNU_-0__0-_,__ __ I PSA 10 DRYWELL GRATING EL. 583 A.Z ..,4 L Y 1722 1-47B401-33 SW 1-47B401-33 BFN-1-SNUB-010-5009 PSA 10 DRYWELL GRATING EL. 583 AZ 334 L Y L2173._ 1-4713401-31 iW-1-713401-31 BFN-I-SNUB-010-5020O PSA 10 DRYWELL GRATING EL. 572 AZ 325 L Y

    ...     "32.-i        ! SW          1-.47,B401           U                PSA 10          DRYWELL GRATING EL. 573 AZ 334                                 L          Y 78 4 0 i- 3
             -4_b 35              1-47B401-35     BFN-1-SNUB-,     -14      PSA10           DRYWELL GRATING EL. 583 AZ 334                                 L          Y I B176 I 1-47B401-35 NW j                1-47B401-35     BFN-1-SNUB-010-015    I   PSA 10          DRYWELL GRATING EL. 583 AZ 3254                                ,          Y 177      i -47B465-19             1-478465-5119        BFN-1.-SNUB-068-5037      PSA 35          DRYWELL GRATING EL. 566 AZ 335        1-CHM-20'37-C1 OF 2      N          Y 178       1-47B401-30 NE               1-47B401-30     BFN-1-SNUB-010-5037       PSA 10          DRYWELL GRATING EL. 581 AZ 331                                 L          Y 179       1-4713401-30 SW              1-47B401-30     BFN-1-SNUB-010-5038       PSA10           DRYWELL GRATING EL. 581 AZ 331                                 L          Y 180       !-47B452-3032             1-47B452-3032      BFN-1-SNUB-074-5062       PSAl3           DRYWELL GRATING EL. 576 AZ 340        1-CHM-2039-C 1 OF 1      L          Y 1771      1-478406-288                1-47B406-288     BFN-1-SNUB-069-5001        PSA 3        DRYWELL STEAM DECK EL.586 AZ 10         1-CHM-2042-C 1 OF 1      N          N 182       1-478406-293                1-47B406-291     BFN-1-SNUB-069-5003        PSA 3         DRYWELL STEAM DECK EL. 585 3 AZ 8      1-CHM-2042-C    OF I     L          Y 183       1-47B406-289                1-47B406-289     BFN-1-SNUB-069-5002        PSA 3        DRYWELL STEAM DECK EL. 598 AZ 3-CHM-2042-C 20                  1 OF 1     N          Y 184       1-47B415-19                  1-478415-19     BFN-1-SNUB-003-5033       HSSA 10       DRYWELL STEAM DECK EL. 601 AZ 30           1-CHM-2036-C-1        L          Y 185       1-478415-20                  1-478415-20     BFN-1-SNUB-003-5034       HSSA10        DRYWELL STEAM DECK EL. 601 AZ 30           1-CHM-2036-C-1        L          Y 186       1-478401-13 NW               1-4784061-13    BFN-1-SNUB-010-5003       PSA 10        DRYWELL STEAM DECK EL. 585 AZ 32                                 N          N 187       1-478401-13 SW               1-478401-13     BFN-1-SNUB-010-5004       PSA 10        DRYWELL STEAM DECK EL. 585 AZ 32                                 N          N 188       1-47B400-119                1-478400-119     BFN-1-SNUB-001-5074       PSA 10        DRYWELL STEAM DECK EL. 585 AZ 32           1-CHM-2038-C-2        N          N 189       1-47B400-121                1-47B400-121     BFN-1-SNUB-001-5075       HSSA 20       DRYWELL STEAM DECK EL. 585 AZ 32           1-CHM-2038-C-2        L          Y 190       1-47B401-11 NW               1-47B401-11     BFN-1-SNUB-010-5033       PSA 10        DRYWELL STEAM DECK EL. 586 AZ 32                                 N          N 191       1-478401-11 SE               1-47B401-11     BFN-1-SNUB-010-5034       PSA 10        DRYWELL STEAM DECK EL. 586 AZ 32                                 N          N 192       1-47B415-21                  1-47B415-21     BFN-1-SNUB-003-5035       HSSA 10       DRYWELL STEAM DECK EL. 586 AZ 55           1-CHM-2036-C-1        N          N 193       1-47B415-22                  1-47B415-22     BFN-1-SNUB-003-5036       HSSA10        DRYWELL STEAM DECK EL. 586 AZ 43           1-CHM-2036-C-1        N          N 194       1-47B401-15 NW               1-47B401-15     BFN-1-SNUB-010-5035       PSA10         DRYWELL STEAM DECK EL. 586 AZ 47                                 N          N

Visual Examination of Hydraulic and I-Sl-4.6.H-1 Mechanical Snubbers Rev. 0017 Page 19 of 37 Appendix A (Page 9 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional Test I1-473401-15 SE 1-47241-15 FN-1*SNUE-010-55736[ PA1 DRYWELL STEAM DECK EL. 586 AZ 47 J N I N 1-478401-17 NE 4.47,401-17 BFN-1 -SNUB-0 t0-5(205 PSA 10 DRYWELL STEAM DECK EL. 585 AZ 4, J 1-7B401-17 BFN-1-SNUB-010-5006 PSA 10 DRYWELL STEAM DECK EL. 585 AZ 48 1-47B401-17 SE N DRYWELL STEAM DECK EL. 586 AZ 60 1-47B401-3 NW 1-47B401-3 BFN-1-SNUE-010-5025 PSA 10 N N DRYWELL STEAM DECK EL. 586 AZ 60 I + 1-47B401-3 SE 1-471401-3 -'F.!-S-NUB-010-5026 PSA 10 N DRYVWELL STEAM DECK EL. 58" AZ 60 2~00 1-471340-1+/- i-47B401-4 BFN-i -SNUE.-0-iG-5007 PSA 10 N N DRYWELL STEAM DECK EL. 587 AZ 60 1-4713401-5 1-471401-5 BFN-! -SNUEI-00I-50,16 PSA 10 N N ______________ ________- ;. 4 4-202 1-47141 5-23 1-47,415:23 SFN-1 -SNUB-003-5037 HSSA 10 DRYWELL STEAM DECK EL. 601 AZ 75 I 1-CHM- 2036-C-1 L Y 203 1-47B400-91 TOP 1-478400-91 1FN-1-SNUB-001-5081 PSA 10 DRYWELL STEAM DECK EL. 587 AZ 82 1-CHM-2038-C-1 N N 204 1-478400-91 BOT 1-47B400-91 BFN-1-SNUB-001-5082 PSA 10 DRYWELL STEAM DECK EL. 585 AZ 82 1-CHM-2038-C-1 N N 205 1-472400-116 1-472400-116 BFN-1-SNUB-001-5072 PSA 10 DRYWELL STEAM DECK EL. 586 AZ 110 1-CHM-2038-C-2 N N 206 1-472401-54 NW 1-478401-54 BFN-1-SNUB-010-5047 PSA 10 DRYWELL STEAM DECK EL. 587 AZ 102 N N 207 1-47B401-54 SE 1-478401-54 BFN-1-SNUB-010-5048 PSA 10 DRYWELL STEAM DECK EL. 587 AZ 102 N N 208 1-47B400-115 1-472400-115 BFN-1-SNUB-001-5071 PSA 35 DRYWELL STEAM DECK EL. 586 AZ 106 1-CHM-2038-C-2 N N 209 1-47B415-24 1-47B415-24 BFN-1-SNUB-003-5038 HSSA 10 DRYWELL STEAM DECK EL. 601 AZ 105 1-CHM-2036-C-1 L Y 210 1-47B415-25 1-47B415-25 BFN-1-SNUB-003-5039 PSA 10 DRYWELL STEAM DECK EL. 585 AZ 96 1-CHM-2036-C-1 L Y 211 1-47B401-19 1-47B401-19 BFN-1-SNUB-010-5017 PSA 10 DRYWELL STEAM DECK EL. 589 AZ 136 L Y 212 1-478400-208 1-47B400-208 BFN-1-SNUB-001-5076 PSA 35 DRYWELL STEAM DECK EL. 586 AZ 138 1-CHM-2038-C-2 N N 213 1-478415-26 1-47B415-26 BFN-1-SNUB-003-5040 PSA 35 DRYWELL STEAM DECK EL. 585 AZ 138 1-CHM-2036-C-1 N N 214 1-47B415-27 1-47B415-27 BFN-1-SNUB-003-5041 PSA 35 DRYWELL STEAM DECK EL. 585 AZ 138 1-CHM-2036-C-1 L Y 215 1-478401-8 NW 1-478401-8 BFN-1-SNUB-010-5027 PSA 10 DRYWELL STM DECK EL. 590 AZ 143 LINE B N N 216 1-47B401-8 SE 1-47B401-8 BFN-1-SNUB-010-5028 PSA 10 DRYWELL STM DECK EL. 590 AZ 143 LINE B N N 217 1-47B401-8 SW 1-47B401-8 BFN-1-SNUB-010-5029 PSA 10 DRYWELL STM DECK EL. 589 AZ 151 LINE F N N 218 1-47B401-8 NE 1-47B401-8 BFN-1-SNUB-010-5030 PSA 10 DRYWELL STM DECK EL. 589 AZ 151 LINE F N N 219 1-47B401-8 SW 1-47B401-8 BFN-1-SNUB-010-5031 PSA 10 DRYWELL STM DECK EL. 590 AZ 153 LINE E N N

Visual Examination of Hydraulic and 1-SI-4.6.H-1 Mechanical Snubbers Rev. 0017 Page 20 of 37 Appendix A (Page 10 of 11) Snubber Listing EXAM SUPPORT # SNUBBER UNID # TYPE/SIZE LOCATION ISI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional

                                             '                                                                                                               Test
 !       1-47B401-8 NE        11-47E401-8      BFN-1-SNU-010..5032         PSA 10      DRYWELL STM DECK EL. 590 AZ 153 LINE E                      N          N 22       r-,

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                                                         'BFN-1-SNU,-0035'051 PSAl1         DRYWELL STEAM DECK EL. 587 AZ 20,    1-CHM-2036-C-1,N NI         N 1-47B401-49 NW      1-47B401-49       BFN-1-SNUB-010-5043         PSA 10        DRYWELL STEAM DECK EL. 586 AZ 220                         N          N 223       1-47B401-49 SE      1-47B401-49       BFN-1-SNUB-010-5044         PEA10     I   DRYWELL STEAM DECK EL. 586 AZ 2.20                        NN

22. , _1-4713415-5.6 1-47B13,1!5-516 BFIN-1-SNUB-003-5047 PSA 10 DRYWELL STEAM DECK EL. 585 AZ 22-1 1-CHM-2036-C-1 N

     ..        B415-57    1       13 5-57      BFN-I--SNUI3-003-5048       PSA 35        DRYWELL STEAM DECK EL. 585 AZ 222    1-CHM-2036-C-1       N          N 226       1-47B401-33 NiW     1-47B401-38       BFN!-1-SNUB.010-5039        PSA10         DRYWELL STEAM DECK EL. 586 AZ 234                         N          N 22 7      1-47B401-38 SE      1-47B401     BFN-1-SNUB-010-5040   r     PSA 10        DRYWELL STEAM DECK EL. 586 AZ 234                         N          N 228 229 1-47B400-101 1-478400-102 1471400-101 1-47B400-102 BFN-1-SNUB;-001-5084 BFN-1-SNUB-001-5085 I     PSA 35 PSA 35 DRYWELL STEAM DECK EL.585.AZ 250 DRYWELL STEAM DECK EL.585 AZ 253 1-0M-2038-0-2 1-CHM-2038-C-2 N

N N N 230 1-47B415-55 1-47B415-55 BFN-1-SNUB-003-5046 HSSA 10 DRYWELL STEAM DECK EL. 601 AZ 255 1-CHM-2036-C-1 L Y 231 1-47B400-75 1-47B400-75 BFN-1-SNUB-001-5068 PSA 10 J DRYWELL STEAM DECK EL. 585 AZ 261 1-CHM-2038-C-1 N N 232 1-47B401-59 NE 1-476401-59 BFN-1-SNUB-0i0-5049 PSA 10 DRYWELL STEAM DECK EL. 586 AZ 268 N N 233 1-47B401-59 SW 1-47B401-59 BFN-1-SNUB-010-5050 PSA 10 DRYWELL STEAM DECK EL. 586 AZ 268 N N 234 1-47B415-48 1-47B415-48 BFN-1-SNUB-003-5042 HSSA 10 DRYWELL STEAM DECK EL. 584 AZ 270 1-CHM-2036-C-1 L Y 235 1-47B400-77 TOP 1-47B400-77 BFN-1-SNUB-001-5069 PSA 10 DRYWELL STEAM DECK EL. 588 AZ 278 1-CHM-2038-C-1 N N 236 1-47B400-77 BOT 1-47B400-77 BFN-1-SNUB-001-5070 PSA 10 DRYWELL STEAM DECK EL. 585 AZ 278 1-CHM-2038-C-1 N N 237 1-47B415-64 1-47B415-64 BFN-1-SNUB-003-5050 HSSA 10 DRYWELL STEAM DECK EL. 601 AZ 285 1-CHM-2036-C-1 L Y 238 1-47B415-54 1-478415-54 BFN-1-SNUB-003-5045 HSSA 10 DRYWELL STEAM DECK EL. 585 AZ 301 1-CHM-2036-C-1 L Y 239 1-47B415-52 1-47B415-52 BFN-1-SNUB-003-5043 HSSA 10 DRYWELL STEAM DECK EL. 601 AZ 315 1-CHM-2036-C-1 L Y 240 1-478400-105 1-478400-105 BFN-1-SNUB-001-5088 HSSA 20 DRYWELL STEAM DECK EL.585 AZ 321 1-CHM-2038-C-2 N N 241 1-47B401-44 SW 1-47B401-44 BFN-1-SNUB-010-5011 PSA10 DRYWELL STEAM DECK EL.585 AZ 318 N N 242 1-478401-44 SE 1-47B401-44 BFN-1-SNUB-010-5012 PSA 10 DRYWELL STEAM DECK EL.585 AZ 318 N N 243 1-47B401-43 1-47B401-43 BFN-1-SNUB-010-5010 PSA 10 DRYWELL STEAM DECK EL.586 AZ 315 IN N 244 1-47B415-53 1-47B415-53 BFN-1-SNUB-003-5044 HSSA 10 DRYWELL STEAM DECK EL. 585 AZ 334 1-CHM-2036-C-1 N N

BFN Visual Examination of Hydraulic and 1-SI-46.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 21 of 37 Appendix A (Page 11 of 11) Snubber Listing EXAM SUPPORT# SNUBBER UNID # TYPE/SIZE LOCATION iSI DRAWING # Scaffold Scaffold DRAWING # Required Required For Visual For Functional

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          .. 53 554,-

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f . N"

                ';4B5-5    -4358-558          1  FN-1-SNUB-075-502             ___________I 1251    1-47B453-,61      1-.47B458-566         BFIF-I-SNUB--075-5031           fSA 35          DRYWELL STEAM DECK EL.608 AZ 214       _                       N 252     1-47B458-567      1-47B458-567          BFN--i-SNUB-075-5032           HSSA 10          DRYWELL STEAM DECK EL.608 AZ 233         1-CHM-2040-C-I        N            N 253     1-47860-1634     1-47B600-1634          B      --                 .______            __           STEAM DECK EL631AZN                                               N 253   I 1-47B600-1634    1-47B600-1634          BFN-1-SNUB-003-50523             PSA 1           DRYWELL STEAM DECK EL 631 AZ 27                               N            N 254     1-47B600-1636H   1-47B600-1636          BFN-1-SNUB-003-5053              PSA 1           DRYWELL STEAM DECK EL 631 AZ 37                               N            N 255     1-47B600-1636V   1-.472600-1636         BFN-1-SNUB-003-5054              PSA 1           DRYWVELL STEAM DECK EL 631 AZ 37                              N-__________ N 256     1-47B600-1637    1-47B600-1637          BFN-1-SNUB-003-5055              PSA 1          DRYWELL STEAM DECK EL 631 AZ 220                               N            N 257     1-47B600-1638    1-472600-1638          BFN-1-SNUB-003-5056              PSA 1          DRYWELL STEAM DECK EL 629 AZ 210                               N            N 258     1-47B465-552 E    1-47B465-552          BFN-1-SNUB-010-5001              PSAI1           RPV HEAD VENT PIPE EL. 645 AZ 225                             N            N 259     1-47B465-552 W    1-47B465-552          BFN-1-SNUB-010-5002              PSA 1           RPV HEAD VENT PIPE EL. 645 AZ 225                             N            N

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 22 of 37 Attachment 1 (Page 1 of 1) Surveillance lnstruction Review Form DATE/TIME STARTED: DATE/TIME COMPLETED: REASON FOR TEST: o Scheduled Surveillance o System Inoperable (Explain in Remarks) UNIT MODE o Maintenance (SEE W.O. NO. BELOW) o Other (Explain in Remarks) PRE-TEST REMARKS: PERFORMED BY: Initials Name (Print) Name (Signature) NOTE: The following entries for contacting Shift Manager/Unit Supervisor shall be marked N/A if the snubber is NOT Inoperable. NOTIFY Shift Manager/Unit Supervisor when snubber found Inoperable. SM/UNIT SUPERVISOR CONTACTED Date Time NOTIFY Shift Manager/Unit Supervisor when snubber Operability is restored. SM/UNIT SUPERVISOR CONTACTED Date Time MECHANICAL MAINTENANCE REVIEWER Date Signature attests that I understand the scope and purpose of this instruction and that, to the best of my knowledge, it was properly performed in accordance with instruction in that: the recording, reduction, and evaluation of data is complete and correct; acceptance criteria is met or justification for exceptions is provided; portions of test performed were appropriate for specified test conditions or reasons for test; deficiencies were evaluated and dispositioned; reportability was evaluated; marginal results were evaluated with respect to potential for future problems based on operating experience and regulatory requirements; and instruction was complete except as noted in post-test remarks. SNUBBER ENGINEER/SITE Date ENGINEERING CIVIL REVIEWER SCHEDULING COORDINATOR Date POST-TEST REMARKS:

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 23 of 37 Attachment 2 (Page 1 of 4) Snubber Visual Examinal:ion Checklist for All Snubbers Unit 1 Snubber UNID No. 1-SNUB- - Serial No. Exam No. Manuf. ANCHOR/DARLING,BERC-GEN-P,#,TERSON,LIISEGA,PSA,FRONEK Size (Circle type snubber beirig o':amined) PER No. Attachments 3, or 4, shall be attached with Attachrnent 2 for the appropriate type hydraulic snubber being examined. A. The snubber has no visible indications of damage or impaired operability. The following attributes will determine the acceptability in accordance with the appropriate acceptance criteria. Responses marked (UNAC) are unacceptable and require immediate notification of the Snubber Engineer!SýT. Designee at the time of discovery. Handling of deficiencies shall be completed in accordance with SPP-8.1 and SPP-3.1. AC UNAC N/A o 0 0 OBSERVE for any signs of over stressing o 0 El OBSERVE the exposed parts of the snubber for broken parts, deformation or other damage, such as, weld arc strikes, paint, weld slag, adhesive, or other deposits on piston rod or support cylinder that could result in unacceptable snubber performance. o 0 01 OBSEL'RVE to see if there is any evidence that a snubber has experienced a potentially damaging transient since the last examination. o 0 01 OBSERVE the srubber and piston rod for excessive corrosion, solid deposits, which could impair operability of the snubber. o 0 01 OBSER VIE to ensure the security of essential threaded fasteners of the snubber installation such as tie rods and rear bracket bolts. 0 0 01 OBSERVIE. for evidence of clamp binding due to missing spacers. 0 0 0 OES,:C'V"vv hydr-ýjuli snubbers for evidence of damage to external tubingc. ý'external pipa, configuration snubbers) 0 0 0 OBSERVE for evidence of torsional binding (i.e. mechanical snubber twisted along its axis by the pipe clamp and structural attachrnents). Performer Signature Date

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 24 of 37 Attachment 2 (Page 2 of 4) Snubber Visual Examination Checklist for All Snubbers Unit 1 Snubber UNID No. 1-SNUB- Serial No. Exam No. Manuf. ANCHOR/DARLING,BEIkGEN-.PATERSON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined) PER No. B. Attachments to the foundation or supporting structure are functional. The following attributes will determine acceptability in accordance with the appropriate acceptance criteria. Responses marked (UNAC) are unacceptable and require immediate notification of the Snubber Engineer/SE Designee at the time of discovery. Handling of deficiencies shall be completed in accordance with SPP-8.1 and SPP-3.1. AC UNAC N/A 0 0 0 OBSERVE the exposed hanger structural steel, pipe clamps, base plates, lugs and other such plates of attachment for broken parts, deformation or other damage. o 0 0 OBSERVE welds for visible damage at base plates, lugs, and other such points of attachment. Performer Signature Date C. Fasteners for the attachment of the snubber to the component and to the snubber anchorage are functional. The following attributes will determine the acceptability in accordance with the appropriate acceptance criteria. Responses marked (UNAC) are unacceptable and require immediate notification of the Snubber Engineer/SE Designee at the time of discovery. Handling of deficiencies shall be completed in accordance with SPP-8.1 and SPP-3.1. AC UNAC N/A 0 0 0 OBSERVE to ensure the security of essential threaded fasteners such as anchorage bolts and pipe clamp bolts that are exposed. 0 0 0 OBSERVE to ensure clevis bolts or pins are properly installed. Performer Signature Date

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 25 of 37 Attachment 2 (Page 3 of 4) Snubber Visual Examination Checklist for All Snubbers Unit 1 Snubber UNID No. i-SNUB- Serial No. Exam No. Manuf. ANCHORIDARLING,BERGEN-PATERSON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined) PER No. Observe for the following attributes which may cause future problems but do NOT affect snubber operability or any acceptance criteria. If any of the following attributes are found to be deficient, NOTE them in the Remarks, and NOTIFY the Snubber Engineer/SE Designee to disposition the finding on Attachment 6. Pits, scratches, or rough places obseived on the piston rod that would NOT contact the piston seal. Cotter pins properly installed with legs bent sufficiently, but not completely, to prevent cotter pin from backing out. Pivot pin retaining ring is properly instailed, if required. Security locking devices (i.e., locking tabs or wire) on snubber attachment bolts properly installed, if required. Centerline of the clamp assembly and structurai attachment offset (i.e., a misalignment with the snubber axis exists) should be no greater than + or - 6 degrees based on the clearances between the rod eyes, or paddles, and the attachment clevis. Contact of these parts, which produces a side load on the snubber is unacceptable. Observe spacers are installed on each side of the snubber eye to reduce the misalignment and /or binding. Space should NOT exceed 1/16 inch on either side or 1/8 inch total. Piston Indication for PSA mechanical snubber inches. Performer Signature Date

BFN Visual Examination of Hydraulic and I1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 26 of 37 Attachment 2 (Page 4 of 4) Snubber Visual Examination Checklist for All Snubbers Unit 1 Snubber UNID No. 1-SNUB- Serial No. Exam No. Manuf. ANCHOR/DARLINGBERGEN-PAXTE-'-'_ON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined) PER No. Snubber meets all visual acceptance criteria N/A this step, and sign, if functional test is required. Yes__ No__ N/A___ Snubber Engineer/SE Designee Date Snubber is found acceptable functionally and neets all applicable acceptance criteria. N/A this step, and sign, if snubber meets all visual acceptance criteria. Yes __ No __ N/A___ Snubber Engineer/SE Designee Date Based on the As-Found condition, including functional test if applicable, is the snubber operable? Yes__ No__ If "NO", notify Shift Manager/Unit Supervisor immediately of the inoperable snubber. Snubber Engineer/SE Designee Date Prior to the final review the Snubber Engineer/SE Designee shall VERIFY that all of the appropriate Attachments 3, 4, 5, 6, or 7 have been completed and are attached with . Final Review Snubber Engineer/SE Designee Date REMARKS:

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 27 of 37 Attachment 3 (Page 1 of 2) Snubber Visual Examination Checklist for Bergen-Paterson, Anchor/Darling, Fronek Hydraulic Snubbers Unit 1 Snubber UNID No. 1-SNUB- Serial No. Exam No. Manuf. BERGEN-PATERSON, ANCHOR/DARLING, FRONEK Size (Circle type snubber being examined) PER No. FLUID LEVEL ACCEPTABILITY FOR BERGNN--PATERSON, ANCHOR/DARLING AND FRONEK HYDRAULIC SUNBBERS. AC UNAC N/A 0 01 01 If the Reservoir Plunger cannot be seen the reservoir is empty. The fluid level is unacceptable. NOTIFY immediately the Snubber Engineer/SE Designee. WRITE a Work Order 't REMC)VE the snubber and take to the snubber test facility to have functional test performed. Piston rod extension is the distance from end of front head to the punch mark or scribed line (nearest 1/8 inch)- 3/4 inch, as shown on Page 2 of 2 of this

Attachment:

                                                                   -3/4 =                inches RECORD the reading from the scale along the protective tube, as shown on Page 2 of 2 of this 

Attachment:

inches Reservoir plunger roading from above: Minus pistoný rod extension from above: - Calculated value: O 0 01 If the calculated value above is greater than +2 inches, the fluid level is unacceptable. If the fluid level is unacceptable, but NOT empty, ADD GE SF 1154 Silicon fluid using a ,Iuld gun with a special hydraulic fill coupling until the fluid level reading is at or approximately the same as the piston rod extension given above. RECORD fluid PIC ticke. and TIIC numbers below for any fluid added. Fluid PIC ticket (SIR) , TIIC EXAMINE snubber for location and cause of any leaks. RECORD locations in Remarks. NOTIFY the Snubber Engineer/SE Designee, to evaluate and document the unacceptable condition on Attachment 6. Performer Signature Date

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 28 of 37 Attachment 3 (Page 2 of 2) Snubber Visual Examination Checklist for Bergen-Paterson, Anchor/Darling, Fronek Hydraulic Snubbers BERGEN-PATER3O1, ANCHIC-Z/DARLING,: FRONEK FLUID :LEVEL INDICATOR. A1O iIT3 TC OD..:.R)MEASUREMENT METHODS. ACCMJTO FHUN,~RONTPLATh.

                                           ....... ... T cR P. RpbD :(:PLUNGE ý):

LEVEL INDICATOR ROD NRY F, 1f :p~ro ::R n < **:...........

                                                                                      .WRNH:FLAT.:::
                                                                                **<*:DRIjLL HOLE:

L INE

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 29 of 37 Attachment 4 (Page 1 of 4) Snubber Visual Examination Checklist for Lisega Torus Dynamic Restraint Hydraulic Snubbers Unit 1 Snubber UNID No. 1-S&NUB- - Serial No. Exam No. Manuf. LISEGA TORUS DYNAMIC RESTRAINT SNUBBERS Size PER No. FLUID LEVEL ACCEPTABILITY FOR LISEGA TORUS DYNAMIC RESTRAINT SUNBBERS. AC UNAC N/A 0 0 0 If the Res-rvoir Plunoer cannot be seen the reservoir is empty. The fluid level is unacceptable. NOTIFY immediately the Snubber Engineer/SE Designee. WRITE a Work Order to REMOVE the snubber and package/ship it to the appropriate test facility to have functional test perfoumed. Piston rod extension is Uhe distance X, from the front head of the snubber to the outside edge marked on piston rod (nearest 1/8 inch), as shown on Page 2 of 4 of this Attachment. RECORD on Page 4 of 4 of this Attachment. Reservoir plunger reading is the reading from the rear plate to the end of the plunger rod (nearest 1/8 inch), as shown on Page 2 of 4 of this

Attachment:

L.= inches, and RECORD on Page 4 of 4 of this Attachment. COMPX,,RE. the piston rod position X from above to the reservoir plunger reading to ensure measurements are within the minimum and maximum limits shown on the chart on Page 3 of 4 of this Attachment. If the fluid lvel is below L minimum, add Lisega AP-280 Silicon fluid using a fluid gun with a special hydraulic fill coupling to the maximum fluid level reading, as shown on the chart on Page 3 of 4 of this Attachment. Ifthe fluid level is above the L maximum value, contact the Snubber EIngineer/SE Designee. RECORO: fluid PIC ticket and TIIC numbers, and optimum/maximum fluid level a:-dded above and COMPLETE page 4 of 4 of this Attachment. Fluid PIC ticket (SIR) , TIIC EXAMlNE snubber for location and cause of any leaks. RECORD locations in Remark.. on Attachment 1. NOTIFY the Snubber Engineer/SE Designee, to evaluate and document the unacceptable condition on Attachment 6. Performer Signature Date

BFN Visual Examination cf Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 30 of 37 Attachment 4 (Page 2 of 4) Snubber Visual Examination Checklist for Lisega Torus Dynamic Restraint Hydraulic Snubbers LIiEEGA 11tINIFL14 AND, HýK1ITLJ4 FLUID LEVEL:PLUNGER ANID P L5 TOff PF1-III C1'N`MEAZUREHEN IN ::THE: FIELD

Xý

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 31 of 37 Attachment 4 (Page 3 of 4) Snubber Visual Examination Checklist for Lisega Torus Dynamic Restraint Hydraulic Snubbers LISEGA MINIMUM AND MA)XIMUM FLUID LEVEL PLUNGER AND PISTON POSITION MEASUREMENT IN THE FIELD If the as-found plunger position "L"is below the minimum value given, but the reservoir is not empty, ADD Lisega AP-280 fluid to the snubber to bring the reservoir, as close as possible, to its optimum (maximum) level. No functional testing of the Lisega Torus Dynamic Restraint Snubber is required due to this refilling operation. The Lisega Torus Dynamic Restraint Snubbers are NOT considered inoperable until the reservoir is completely empty. This can be identified when the reservoir plunger is flush with the top of the reservoir plate. The snubber will be considered inoperabe when 1te "L" dimension is equal to "0". Nomenclature: X- Measurement of the snubber piston rod position in inches from the front head of the snubber to the outside edge marked piston rod. L Minimum - The minimum fluid level in the reservoir using the reservoir piston rod position measured from the frontof the reservoir to the end of the reservoir piston rod. L Maximum - The maximum fluid leval in the reservoir using the reservoir piston rod position measured from the front of the reservoir to the end of the reservoir piston rod. IF the X measurement is betwc-.,?r, the values given in the table below for "X", THEN GO TO the next lower reading for "X" to determine the L Minimum and L maximum. X L L (INCHES) M!NIMUM MAXIMUM

                                            .IL CHES)      (INCHES)

• 0.C001 2.52 3.31 0.125 2.43 3.22 0.250 2,34 3.13 0.375 2.26 3.04 0.500' 2.17 2.96 0.625 2.08 2.87 0.750 1.99 22.78

0. ,75 1.91 2.69 1.000 [" 1.82 2.60 1.125 1.73 2.52 1 501- 1.64 2.42 1.3-75 1._E' _ 2.34 1 (100 1.47 2.25

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 32 of 37 Attachment 4 (Page 4 of 4) Snubber Visual Examination Checklist for Lisega Torus Dynamic Restraint Hydraulic Snubbers SURVEILLANCE INSTRUCTION DATA SHEET LISEGA LARGE BORE TO'lRUS DYNAMIC RESTRAINT SNLUEBBER VISUAL E,./-AMiNATION CHECKLIST Work Order: Outage/Cycle (RFO): Fluid Type: Visual Exam Date: Fluid PIC Ticket (SIR): , TI!C: Ex TDR TDR Piston Reservoir *Optimum/ Performer Signature/ No. UNID No. Rod Plunger Max. As-Left Date Pos. Reading Fluid Level "X"(in) 'L"(in) (in)

*Optimum/Maximum         Fluid Level isresefvoir plunger reading measured after adding the Lisega AP-280 silicon fluid to the snubber.

BFN Visual Examination cf Hydraulic and 1-S1-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 33 of 37 Attachment 5 (Page 1 of 1) Evaluation of Loose or Missing Attachment Fasteners This evaluation should be performed when fasteners, used for attachment of snubber to component, and to snubber anchorage, are discovered loose or missing. This Attachment may be completed on the computer, as a form, if desired. Unit 1 Snubber UNID No. 1-SNUB- Serial No. Exam No. Manuf. ANCHOR/DARLING, BERGEN-PATERSON,LISEGA,PSA,FRON EK Size (Circle type snubber being examihed) PER No.

1. Describe the discovered condition and, if possible, determine cause:

2. Evaluate to determine whether the cause may be localized or generic. Use this evaluation to select and list other suspect snubbers for verification, as applicable.

3. Describe the corrective action(s) and provide the As-Found test result, if applicable.

4.

Conclusion:

Is the snubber operable? YES NO Justification: Evaluated by: Snubber Engineer/SE Designee Date

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 34 of 37 Attachment 6 (Page 1 of 2) Engineering Evaluation of Unacceptable Indication This Attachment may be completed on the computer, as a form, if desired. Unit 1 Snubber UNID No. 1-SNUB- Serial No. Exam No. Manuf. ANCHOR/DARLING,BERGEN-P 8 TERSON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined) PER No.

1. Describe the unacceptable indication(s) observed.

2. What is the cause of the indicai:ion(s) (i~e., vibration, water leaking on surface, possible failure to torque at last reinrstallation, etc.)?

3. What is the basis for the conclusions reached by question 2 above?

4. Which additional snubber's are suspected to be subject to the same unacceptable indication(s)?

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit 1 Mechanical Snubbers Rev. 0017 Page 35 of 37 Attachment 6 (Page 2 of 2) Engineering Evaluation of Unacceptable Indication This Attachment may be completed on the computer, as a form, if desired. Unit 1 Snubber UNID No. 1-SNUB- - Serial No. Exam No. Manuf. ANCHOR/DARLING, BERGEN-PATERSON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined) PER No.

5. What further examination(s) and/or test(s) of the initial and other suspect snubber(s) are to be performed?

6. What are the results of the examination(s) and/or test(s) performed by Step 5 above, and what changes in the initial evaluation should be made?

7. What corrective action(s) is/are to be taken for the initial snubber and/or any other suspect snubbers?

8. Has/have the corrective action(s) bee~n taken? YES NO

9. Number of snubbers that will affect the next visual inspection interval.

Evaluated by: Snubber Engineer/SE Designee Date

BFN Visual Examination of Hydraulic and 11-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 36 of 37 Attachment 7 (Page 1 of 2) Engineering Evaluation of Transient Event Indication(s) and Effect(s) This Attachment may be completed on the computer, as a form, if desired. Unit 1 Snubber UNID No. 1-SNUB- - Serial No. Exam No. Manuf. ANCHOR/DARLINC',[3ERGEN-PATEf-B.S ON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined) PER No.

1. What is/are the indication(s) that a potentially damaging transient event has taken place?

2. Which snubber installation(s) are suLSpected of being subject to the transient?

3. What are the result(s) of the visual ex.rnination for bent or broken parts and other signs of damage to the installation(s)? (Attach extra sheets, if necessary, to detail the results for each suspect installation(s).)

BFN Visual Examination of Hydraulic and 1-SI-4.6.H-1 Unit I Mechanical Snubbers Rev. 0017 Page 37 of 37 Attachment 7 (Page 2 of 2) Engineering Evaluation of Transient Event Indication(s) and Effect(s) This Attachment may be completed on the computer, as a form, if desired. Unit 1 Snubber UNID No. 1-SNUB- Serial No. Exam No. Manuf. ANCHOR/DARLING,BERGEN-PATERSON,LISEGA,PSA,FRONEK Size (Circle type snubber being examined.) PER No.

4. What additional test(s), NDE examination(s), etc., is/are required to be performed to verify structural integrity of the snubber(s) and its attachment(s)? (PSA snubbers are to be stroked to verify they are NOT jammed or broken internally.)

5. What are the results of the additional test(s) and/or examination(s) performed in question 4?

6. What is/are the corrective action(s) to be taken to correct the problem(s) found?

7. Has/have the corrective action(s) been completed for all suspect snubbers?

8. How many of the snubber installations are to be counted as inoperable to affect the surveillance schedule?

Evaluated by: Snubber Engineer/SE Designee Date

Attachment D BFN Mechanical Preventative Instruction, MPI-0-000-SNBOO4, Removal and Reinstallation of Snubbers

Browns Ferry Nuclear Plant Unit 0 Mechanical Preventive Instruction MPI-0-000-SNBOO4 Removal and Reinstallation of Snubbers Revision 0036 Quality Related Level of Use: Reference Use Effective Date: 04-03-2007 Responsible Organization: MMG, Mechanical Maintenance Prepared By: William Mark Hill Approved By: William Mark Hill

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 2 of 58 Current Revision Description Pages Affected: 4, 16, 17, 22-25 Type of Change: INTENT Tracking Number: 037 Revised to include Type 30 Lisega snubbers.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 3 of 58 Table of Contents 1.0 PURPOSE/SCOPE/FREQUENCY ........................................................................... 4 1 .1 P u rp o s e ........................................................................................................................ 4 1 .2 S c o p e ............................................................................................................................ 4 1 .3 F re q u e ncy ..................................................................................................................... 4

2.0 REFERENCES

.........................................................................................................                             4 3.0   PRECAUTIONS/LIMITATIONS/ALARA .................................................................                                                  5 4.0   PREREQUISITES ....................................................................................................                               5 5.0   RECOMMENDED EQUIPMENT ..............................................................................                                             6 6.0   ACCEPTANCE REQUIREMENTS ........................................                                          ...................................... 7 7.0   INSTRUCTION STEPS ..........................................                                                                                     8 7.1   Preparation for M aintenance ....................................................................................                                8 7.2   Staking of Carbon Steel Spherical Bearings .............................................................                                         9 7.3   Replacing Original One Piece Pins with New'Two Piece Pins ...............................                                                       11 8.0   RETURN TO SERVICE ........................................................................................                                      12 : Removal and Reinstallation of Hydraulic Snubbers ..........................                                                             13 :         Removal and Reinstallation of Mechanical Snubbers .......................                                                       31 :         Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints ......................................................                                          37 : Data Sheet .........................................                        ....................................................        51 :         Evaluation of Loose or Missing Attachment Fasteners .................... 54 :         Engineering Evaluation of Unacceptable Indication .........................                                                     55 :         Instructions for Exchanging the Snubber End Plug ..........................                                                     57

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 4 of 58 1.0 PURPOSE/SCOPE/FREQUENCY 1.1 Purpose This instruction is to serve as a guide in the removal and reinstallation of Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek, Grinnell and Lisega Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers. This procedure also serves as the pre-service inspection procedure for Section XI Repair/Replacement snubber work order packages. 1.2 Scope This instruction is applicable to Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek, Grinnell and Lisega Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers. 1.3 Frequency [PER/C] Frequencies are established and maintained in accordance with the plant Preventive Maintenance (PM) Program and Qualification Maintenance Data Sheets (QMDS), as applicable, Surveillance Instructions or as required for maintenance. [PER BFPER940037]

2.0 REFERENCES

BFN-VTD-B209-0160, Vendor Technical Manual For Bergen-Paterson Reactor Torus Ring Hydraulic Shock Suppressers. BFN-VTD-B209-0180, Installation Techniques For Bergen-Paterson Series 78000 Hydraulic Shock Suppressers. BFN-VTD-B209-0200, Removal Techniques For Bergen-Paterson Series 78000 Hydraulic Shock Suppressers. BFN-VTM-P029-0010, Vendor Technical Manual For Pacific Scientific Instruction Manual for Repair, Overhaul, Installation Maintenance of Mechanical Shock Arrestors. BFN-VTD-P029-0050, Pacific Scientific Instruction Manual For Installation and Maintenance of Mechanical Shock Arrestors Models PSA-1/4, PSA-1/2, PSA-1, PSA-3, PSA-10, PSA-35, PSA-100 BFN-VMM-P029-0250, Vendor Miscellaneous Manual For Pacific Scientific Mechanical Shock Arrestors. BFN-VTM-G257-0010, Vendor Technical Manual For Grinnell Corp. Hydraulic Snubbers

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 5 of 58

2.0 REFERENCES

(continued) BFN-VTM-L329-0010, Vendor Technical Manual For Lisega Reactor Torus Ring Hydraulic Snubbers BFN-VTD-L329-0070, Installation and Maintenance Instructions For Lisega Hydraulic Snubbers 0-TI-397, Performance of InspectionNerification by Maintenance EDC 66240, Revise General Notes (Drawing 0-47B435-5B) 3.0 PRECAUTIONS/LIMITATIONS/ALARA A. When removing or reinstalling a snubber, do NOT rotate the piston rod end of the unit. If the snubber cannot be removed or installed without rotating the piston, contact the Snubber Engineer/designee for instruction. B. Only remove one snubber at any time from a safety-related system while that system is required to be operable. C. Caution should be taken NOT to drop any spacers, washers, cotter pins, etc., while removing end attachments. D. Safety measures must be used to ensure personnel safety when working on difficult to reach snubbers. E. At no time shall snubbers be used as steps or hand holds. F. Use care when removing or installing attachment pins to avoid damage to end attachments and spherical bearings. G. Steps deemed inapplicable to the specific type of snubber to be worked may be marked Not Applicable (N/A) with prior concurrence from the Work Supervisor. Concurrence must be documented in Section 8.0. 4.0 PREREQUISITES A. Craftsmen conducting maintenance have reviewed and are familiar with this instruction. B. Applicable portions of related WO are complete and Unit Supervisor's authorization obtained to begin work per SDP-MMDP-1, Maintenance Management System.

5.0 RECOMMENDED EQUIPMENT NOTE Part numbers furnished in this procedure are for reference only. 1/2" drive socket set 1/2" drive Torque wrench (5 to 250 ft-lbs.) Adjustable wrenches (8" or 12") Screwdriver (1/4" or 1/8" blade) Vise grips Needle-nose pliers Slip-joint pliers Snap ring pliers Lock wire pliers Lock wire (stainless steel) Hammer (Rubber hammer, Mallet or soft-faced hammer) Brass drift pin Rigging slings and hoist Ladders Scaffolding Safety belt Flashlight Inspection mirror File (fine tooth) Cotter pins

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 7 of 58 5.0 RECOMMENDED EQUIPMENT (continued) Tie wire Positioning fixture (BP P/N 78044). Hand spanner wrench (BP P/N 78031). Lifting fixture (BP P/N 78048). Jam nut torquing fixture (BP P/N 78022). Porta-power. 6.0 ACCEPTANCE REQUIREMENTS Successful completion of the Work Order.

BFN Removal and Reinstallation of MPI-O-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 8 of 58 Date 7.0 INSTRUCTION STEPS 7.1 Preparation for Maintenance NOTE The following step is to be performed by all personnel performing this procedure. [1] READ this procedure. IF required, THEN CONTACT Work Supervisor for clarification. WHEN procedure is understood, THEN PRINT your name and SIGN initials. Printed Name Initials 4 1*

                                                   *1~

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 9 of 58 Date ____ 7.1 Preparation for Maintenance (continued) [2] FOLLOW the appropriate Removal and Reinstallation Attachment for the type snubber to be worked. [2.1 .1] REFERENCE Attachment 1 for Removal and Reinstallation of Hydraulic Snubbers. [2.1.2] REFERENCE Attachment 2 for Removal and Reinstallation of Mechanical Pacific Scientific Sn ubbers. [2.1.3] REFERENCE Attachment 3 for Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints. [2.1.4] REFERENCE Section 7.3 for replacing old solid pins with the new two piece pin. 7.2 Staking of Carbon Steel Spherical Bearings NOTE The following is a list of Bergen-Paterson part numbers for strut and snubber assemblies which use carbon steel and stainless steel spherical bearings: Stainless steel bearings: 2015, 2249 (end attachment end), 2250, 2251 (end attachment end), 2252, 2410 (end attachment end), 2411 (end attachment end), 2420, 2421, 2440, 2525, 2530, and 2540 (end attachment end). Carbon steel bearings: 2000, 2010, 2100, 2200, 2249 (clamp end), 2251 (clamp end), 2410 (clamp end), 2411 (clamp end), 2510, 2515, and 2540 (clamp end). [1] IF a snubber contains a stainless steel bearing which has become dislodged, NOTIFY the Snubber Engineer/designee for instruction. Stainless steel bearings are NOT to be staked. [2] IF a snubber contains a carbon steel spherical bearing which has become dislodged, STAKE the spherical bearing in accordance with paragraph 7.2[3.2], unless it has been previously staked. [2.1] IF the bearing has'been staked previously, REQUEST the Site Engineering Lead Civil Engineer to provide needed corrective action.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 10 of 58 Date 7.2 Staking of Carbon Steel Spherical Bearings (continued) [3] IF a spherical bearing is found to be dislodged from the paddle housing, REINSERT by carefully pressing or tapping on the outer race. [3.1] USE a Bergen-Paterson bearing installation tool or an appropriate sized pipe to assure proper alignment. NOTE The punch indentations should displace a small amount of metal over the edge of the spherical bearing race to keep it from dislodging again. [3.2] After the spherical bearing has been reinserted into the paddle if required, USE a center punch and MOVE approximately 1/32 inch away from the exterior of the spherical bearing race and with as little force as possible MAKE four punch indentations equally spaced around the race at approximately 90 degrees, on both sides of the paddle. [3.3] VERIFY the staking process has NOT damaged the race in any way, such as cracking, deforming, chips or flaking. [3.4] VERIFY the ball moves with little force in the race. [3.5] IF the ball sticks, ROTATE it to expose the exterior surface and PLACE a small amount of Never-Seize compound on it. [3.6] MOVE the ball around until it moves with little force. [3.7] IF the ball does NOT move with little force after this, CONTACT the Snubber Engineer/designee to evaluate the spherical bearing.

BFN Removal and Reinstallation of MPI-O-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 11 of 58 Date 7.3 Replacing Original One Piece Pins with New Two Piece Pins NOTES

1) Pin replacement may begin on either end of the snubber.

2) After the first pin is replaced the steps are repeated to replace the pin on the opposite end.

[1] REMOVE original pin, retainers, and spacer washers. [1.1] RETAIN spacer washers for reinstallation. [1.2] DISCARD old pin and retainers. [2] VERIFY the bore of the bracket and bearing are free of burrs, rust, and debris. [3] DISASSEMBLE new pin by removing the slotted hex nut, washer, and sleeve. [4] APPLY a thin film of lubricant to the OD of the sleeve, the threads and tapered surface of the pin. USE Never Seez Pure Nickel, Neolube 1 or 2, Felpro C5-A Nuclear Grade, Fel-Pro N-7000 or G.E. Silicone Grease, G-351. [5] ALIGN hole in spherical bearing with bracket lug holes. [6] INSTALL sleeve and spacer washers. [6.1] ENSURE sleeve is in full contact with holes in the bracket lugs. [7] INSTALL pin and ATTACH washer and slotted hex nut. [8] ADJUST pin sleeve assembly by tightening the slotted hex nut snug until spherical bearing will NOT slide along sleeve. [9] ENSURE spherical bearing is centered, approximately, between the bracket lugs. [10] INSTALL cotter pin by slightly turning the slotted hex nut in either direction, as required, to allow the cotter pin to be inserted in the first available hole. [11] SPREAD legs on cotter pin enough to prevent falling out.

BFN Removal and Reinstallation of MPI-0-000-SNB004 Unit 0 Snubbers Rev. 0036 Page 12 of 58 Date 8.0 RETURN TO SERVICE [1] COMPLETE Maintenance documentation in accordance with MMDP-1, Maintenance Management System. [2] ENSURE printed names, initials and signatures of all personnel performing this instruction have been recorded below: Comments:

Attachment I (Page 1 of 18) Removal and Reinstallation of Hydraulic Snubbers NOTES

1) The pivot pins and pipe clamp stud bolts are designed to be a light press fit in the snubber spherical bearing and in the attachment lug or pipe clamp.

2) Document removal and reinstallation data on Attachment 4 Data Sheet.

1.0 REMOVAL OF SNUBBERS [1] PERFORM visual inspection of the snubber for any visible damage or fluid leakage. [2] ENSURE snubber attachment fasteners are NOT loose or missing prior to unpinning the snubber(s). [3] IF visible damage such as loose/missing attachment fasteners, or unacceptable conditions such as low fluid level or leakage are discovered, NOTIFY the Snubber Engineer/designee. NOTES

1) Reference Illustration 1 during performance of the following step.

2) The following step is applicable to Bergen-Paterson, Anchor/Darling, and Fronek snubbers.

[4] MEASURE the "As-Found" index/plunger position setting to the nearest 1/8 inch. RECORD the value on Attachment 4 Data Sheet. [4.1] IF the reservoir index/plunger cannot be seen, the fluid level is unacceptable and the snubber is visually inoperable. [4.2] IF the snubber is visually inoperable, NOTIFY the Shift Manager/Unit Supervisor immediately and the Snubber Engineer/Designee. INITIATE a Work Order to remove the snubber for a functional test to determine operability.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 14 of 58 Attachment I (Page 2 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 1.0 REMOVAL OF SNUBBERS (continued) NOTE The piston rod extension is the distance from end of front head to the punch mark or scribed line on the piston. [5] RECORD piston rod extension on Attachment 4 Data Sheet to the nearest 1/8 inch. [6] SUBTRACT 3/4 inch from piston rod extension on Attachment 4 Data Sheet. [7] RECORD actual piston reading on Attachment 4 Data Sheet. [8] SUBTRACT actual piston reading from the "As-Found" index/plunger measurement. RECORD actual fluid level on Attachment 4 Data Sheet. [8.1] IF the calculated value above is greater than +2 inches, the fluid level is unacceptable. [8.2] IF the fluid level is unacceptable, but NOT empty, ADD GE SF 1154 Silicon fluid using a hydraulic fluid gun until the fluid level reading is at or approximately the same as the piston rod extension given above. NOTIFY the Snubber Engineer/Designee to take appropriate action.

BFN Removal and Reinstallation of MPI-0-000-SNB004. Unit 0 Snubbers Rev. 0036 Page 15 of 58 Attachment I (Page 3 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 1.0 REMOVAL OF SNUBBERS (continued) NOTES

1) The following step is applicable to Grinnell snubbers.

2) Reference Illustration 3 during performance of the following step.

[9] MEASURE the "As-Found" position setting as follows (see Illustration 3). RECORD the value on Attachment 4 Data Sheet to the nearest 1/8 inch. [9.1] IF the fluid in the plastic reservoir is below the supply hole for the snubber piston, the fluid level is unacceptable and the snubber is visually inoperable. [9.2] IF the snubber is visually inoperable, NOTIFY the Shift Manager/Unit Supervisor immediately and the Snubber Engineer/Designee. INITIATE a Work Order to remove the snubber for a functional test to determine operability. [9.3] IF the fluid level is above the supply hole for the snubber piston but below 1/2 full in the reservoir, ADD GE SF 1154 Silicon fluid through the reservoir vent hole until the reservoir is at least 1/2 full. [9.4] EXAMINE the snubber for location of leaks. NOTIFY the Snubber Engineer/Designee to take appropriate action. NOTE In the following step, the tie wire should be tightened as much as possible. [10] PLACE tie wire around the end of the snubber piston rod and an appropriate place on the body of the snubber to restrain the piston rod at the "As-Found" position setting for reinstallation. [11] ENSURE 1/4 inch vent plug in reservoir cylinder is removed and a 1/4 inch solid plug is installed before snubber removal.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 16 of 58 Attachment 1 (Page 4 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 1.0 REMOVAL OF SNUBBERS (continued) [12] REMOVE cotter pin(s) from the end of the clevis pins. NOTE Care should be exercised to catch the spacers as the pin or stud is removed. [13] USE a chain fall, block and tackle, or similar method to secure and lower the unit for removal as necessary. [14] REMOVE the pivot pins from the end attachment and/or pipe attachment, as required. [15] ENSURE the snubber setting is NOT disturbed while unpinning the snubber, if possible. [16] TRANSPORT the unit to the designated testing area after it has been decontaminated, if required. 1.2 Removal of Lisega Type 30 Snubbers [1] PERFORM visual inspection of the snubber for any visible damage or fluid leakage. [2] ENSURE snubber attachment fasteners are NOT loose or missing prior to unpinningthe snubber(s).

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 17 of 58 Attachment I (Page 5 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 1.2 Removal of Lisega Type 30 Snubbers (continued) NOTES

1) The sightglass is located in a brass alloy housing near the back end of the snubber body.

2) The leading edge of the reservoir piston acts as the fluid level indicator.

3) When the reservoir is full, the sightglass will show the silver color of the stainless steel cylinder tube.

4) When there is a loss of fluid, the brass alloy (gold color) reservoir piston will appear in the sightglass, either partially or completely.

[3] IF visible damage such as loose/missing attachment fasteners, or unacceptable conditions such as low fluid level or leakage are discovered, NOTIFY the Snubber Engineer/designee. [4] MEASURE the "As-Found" position setting as follows: [4.1] MEASURE from the end position (last machined ring) on the snubber body to the face of the piston rod cover. [4.2] RECORD the value on Attachment 4 Data Sheet.

Attachment I (Page 6 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 2.0 REINSTALLATION OF HYDRAULIC SNUBBERS CAUTION Care should be exercised during the reinstallation of the snubber to prevent damage to the piston rod and the accumulator indicator housing. 2.1 Hydraulic Strut Assembly Installation NOTES

1) The required thread engagement is verified by use of sight holes provided in the coupling. Threads must be visible at these holes to ensure the proper engagement of 1-1/2 times the diameter of the shaft is obtained.

2) Any required relocation of the strut attachment to clear an interference should be brought to the attention of Site Engineering (Civil).

3) When installing the threaded adapter, rotate either the adapter or the entire snubber unit to prevent possible scoring of the piston rod cylinder tube. Use the wrench flats provided on the piston rod to hold the rod in place and prevent scoring.

[1] Prior to the installation of the unit, CHECK that piston rod is at the "As-Found" position setting or approximately 1 inch less than the "As-Found" position setting as recorded on Attachment 4 Data Sheet. [2] ENGAGE the piston rod in the threaded adapter until it is tight and aligned properly. [3] CHECK for the required overall pin-to-pin dimension. [4] USE a chain fall, block and tackle, -or similar method to secure and raise the unit for installation as necessary. [5] ORIENT snubber end attachment and BOLT in place.

BFN Removal and Reinstallation of MPI-0-000-SNB004 Unit 0 Snubbers Rev. 0036 Page 19 of 58 Attachment 1 (Page 7 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 2.1 Hydraulic Strut Assembly Installation (continued) [6] INSERT clevis pins in the appropriate clevis. [6.1] IF piston rod extends too far, PERFORM the following: [6.1.1] PUSH or PULL on the piston rod, as required, to obtain the proper position setting, OR [6.1.21 To relieve the spring force and subsequent fluid pressure in the accumulator housing (1), THREAD the 5/16-18 NC rod with nut and two flat washers into the indicator rod (5) (Min. 1/2-inch) and TIGHTEN until resistance is felt on the indicator plunger (5) indicating compression of the accumulator spring (1 3a). [6.1.3] ADJUST piston rod to the proper setting. [7] VERIFY that the cotter pins have been reinstalled in the clevis pins. [8] ENSURE 1/4 inch solid plug removed from reservoir and 1/4 vent plug reinstalled. NOTES

1) Reference Illustration 2 for Bergen-Paterson, Anchor/Darling and Fronek torque requirements.

2) Reference Illustration 4 for Grinnell tightening requirements.

[9] TORQUE or TIGHTEN fasteners as required. RECORD the torque data on Attachment 4 Data Sheet.

BFN Removal and Reinstallation of ' MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 20 of 58 Attachment I (Page 8 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 2.2 Structural Mounted Units NOTE For units NOT having struts for adjustment, the method of adjusting the unit is through extension or compression of the piston rod. [1] Prior to the installation of the unit, CHECK that piston rod is at the "As-Found" position setting or approximately 1 inch less than the "As-Found" position setting as recorded on Attachment 4 Data Sheet. [2] ENGAGE the piston rod in the threaded adapter until it is tight and aligned properly. [3] CHECK for the required overall pin-to-pin dimension. [4] USE a chain fall, block and tackle, or similar method to secure and raise the unit for installation as necessary. [5] ORIENT snubber end attachment and BOLT in place. [6] INSERT clevis pins in the appropriate clevis. [6.1] IF piston rod extends too far, PERFORM the following: [6.1.1] PUSH or PULL on the piston rod, as required, to obtain the proper position setting, OR [6.1.2] To relieve the spring force and subsequent fluid pressure in the accumulator housing (1), THREAD the 5/16-18 NC rod with nut and two flat washers into the indicator rod (5) (Min. 1/2-inch) and TIGHTEN until resistance is felt on the indicator plunger (5) indicating compression of the accumulator spring (1 3a). [6.1.3] ADJUST piston rod to the proper setting. [7] VERIFY cotter pins have been reinstalled in the clevis pins.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 21 of 58 Attachment 1 (Page 9 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 2.2 Structural Mounted Units (continued) NOTES

1) Reference Illustration 2 for Bergen-Paterson, Anchor/Darling and Fronek torque requirements.

2) Reference Illustration 4 for Grinnell tightening requirements.

[8] TORQUE or TIGHTEN fasteners as required. RECORD data on Attachment 4 Data Sheet. NOTES

1) Due to the internal fluid pressure caused by the spring-loaded piston in the accumulator, the piston rod will slowly extend when NOT restrained.

2) The minus 1 inch setting will allow for this growth during the time the unit is being reinstalled at its location.

[9] OBTAIN the "As-Left" position setting. RECORD the value on Attachment 4 Data Sheet. [10] At the end of each installation, CHECK each unit as a precaution for the following information. A. Snubber Serial Number. B. Piston rod extension dimension. C. Fluid level indicator reading. D. Whether or not fluid was added to bring unit to proper level. E. Visible condition of the unit.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 22 of 58 Attachment 1 (Page 10 of 18) Removal and Reinstallation of Hydraulic Snubbers Date 2.2 Structural Mounted Units (continued) F. Condition of the strut assembly with particular attention to the clamp and the bolting tightness. G. Cotter pins installed in clevis pins. [11] IF the snubber is subject to moisture, high humidity, or vibration, GREASE the end attachment spherical bearings as required with GP-2 (or equivalent). [12] COMPLETE Attachment 4 Data Sheet, and SUBMIT to the Snubber Engineer/designee for final evaluation. 2.3 Installation of Lisega Type 30 Snubbers NOTES

1) The sightglass is located in a brass alloy housing near the back end of the snubber body.

2) The leading edge of the reservoir piston acts as the fluid level indicator.

3) When the reservoir is full, the sightglass will show the silver color of the stainless steel cylinder tube.

4) When there is a loss of fluid, the brass alloy (gold color) reservoir piston will appear in the sightglass, either partially or completely.

[1] EXTEND snubber to proper installation position as follows: [1.1] STROKE snubber slowly to avoid activating snubber.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 23 of 58 Attachment I (Page 11 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.3 Installation of Lisega Type 30 Snubbers (continued) LOCKING FLANGEý JAM NUTr

     &I                                     EXTENSION TUBE

[1.2] IF snubber becomes activated, REVERSE direction. [2] IF an extension strut is required, PERFORM the following: [2.1] For Type 3018 snubbers, BOLT extension strut at rear flange. TORQUE bolts to 22 in-lbs. RECORD data on Attachment 4 Data Sheet.. [2.2] For Type 3038 through 3092 snubbers, THREAD strut directly onto

                    ýthreaded stud protruding from rear plate of snubber.

[2.2.1] TIGHTEN extension strut until locking flange firmly contacts rear plate of snubber.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 24 of 58 Attachment I (Page 12 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.3 Installation of Lisega Type 30 Snubbers (continued) [2.2.2] TORQUE set screw in locking flange to rear plate of snubber in accordance with the following table. RECORD data on Attachment 4 Data Sheet. Snubber Type Set Screw (ft-lbs) 3038 3 3042 3 3052 7 3062 7 3072 19 3082 28 3092 28 NOTES

1) Exercise care NOT to move snubber from the proper installed position (cold) during handling.

2) Small adjustments (1/4 inch or less) may be made to align pin holes and spherical bearings.

3) For extended pin-to-pin assemblies, adjustment of up to 1-1/2 inches may be made using the extension strut.

• This is accomplished by loosening the lock nut and threading the paddle end in or out of the extension tube.
• A circumferential thread relief in the male threads of the paddle end will indicate minimum thread engagement with the extension tube. This thread relief should not extend beyond the extension tube.

[3] INSTALL snubber assembly. [4] ROTATE snubber side to side to check for proper lug alignment and absence of binding.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 25 of 58 Attachment I (Page 13 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.3 Installation of Lisega Type 30 Snubbers (continued) [5] ENSURE threaded connections are secure. [6] OBTAIN the "As-Left" position setting. RECORD the value on Attachment 4 Data Sheet.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 26 of 58 Attachment I (Page 14 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.4 Ilustrations BER%3EN-PAJYER.SON, fl:ACHOR/DAPLIUG3,: fLPOHZK ETUD. L97=L fl4DCATOR/PISTON ROD MZASURZHE J~CUNUATOFHUSING FRONT PLATE5 Z.Z.*

                          . . . . >Z>>

Z Z; . . Z . : ;;.;. . 'ZIA Z Z ' UIIU

• OR ZFLUID LEVEL INDICATOR ii ii~i;zz *~zzzzzz ROD; z I ACCUTMUATOR ROD: (PLUNGER)

PISTON. ROD WRENCH FLAT DRILL HOLE PISTON -ROD , .SCRIBEDELINE MMEASUREMENT PISTON ROD

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 27 of 58 Attachment I (Page 15 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.4 Ilustrations (continued) Illustration 2 Bergen - Paterson, Anchor/Darling and Fronek Hydraulic Snubber Bloting Guide Bolting information for mounting flanges on Bergen-Paterson, Anchor/Darling and Fronek Hydraulic snubbers. Snubber Size Bolt Material Required Torque (1) HSSA-3 3/8-16 SA307 GR. A 6 FT-LBS HSSA-10 1/2-13 SA307 GR. A 25 FT-LBS HSSA-20 5/8-11 SA325 70 FT-LBS HSSA-30 5/8-11 SA325 100 FT-LBS ADH-300 3/8-16 SA307 GR. A 6 FT-LBS ADH-1000 1/2-13 SA307 GR..A 25 FT-LBS ADH-2000 5/8-11 SA325 70 FT-LBS ADH-3000 5/8-11 SA325 100 FT-LBS ADH-5000 7/8-9 SA325 225 FT-LBS ADH-7000 1-8 SA325 290 FT-LBS ADH-13000 1-3/8-6 SA325 650 FT-LBS (1) The bolts should be torqued to +/- 10 percent of the values shown above.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 28 of 58 Attachment I (Page 16 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.4 liustrations (continued) GRINNELL HYDUr.LIC SNUBBER ILLUSTRATION 3 PISTON ROD POSITION MEASUREMENT PISTON ROD MEASURIEMENT

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 29 of 58 Attachment I (Page 17 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.4 Ilustrations (continued) Illustration 4 Grinnell Hydraulic Snubber Bolting Guide Bolting information for mounting flanges on Grinnell Hydraulic snubbers. Snubber Size Bolt Material Required Tightness (1) 1-1/2 3/8-24x 1-1/4 SA307 GR. A Snug Tight 2-1/2 3/8-24x 1-1/4 SA307 GR. A Snug Tight 3-1/4 1/2-20x1-1/2 SA307 GR. A Snug Tight 3-1/2 1/2-20x1-1/2 SA307 GR. A Snug Tight 4 5/8-18x 1-3/4 SA307 GR. A Snug Tight (1) The bolts should be tightened snug tight without additional nut rotation. Snug tight is the condition of tightness that exists-when all: of the parts of the joint are in firm contact. This tightness may be achieved by an unmodified commercial open-end wrench or a sprocket type ratchet.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 30 of 58 Attachment I (Page 18 of 18) Removal and Reinstallation of Hydraulic Snubbers 2.4 Ilustrations (continued) REMARKS:

Attachment 2 (Page I of 6) Removal and Reinstallation of Mechanical Snubbers NOTES

1) The early version of the PSC snubbers was finished with a white epoxy enamel exterior coating. The later version of the snubbers has a zi no-cadmnium-chro mate stabilized plating.

2) The standard size of the spherical bearing on the PSA-10 snubbers was changed from 7/8 inch to 1 inch on the later version. However, the later version can be furnished with the 7/8 inch spherical bearing.

3) Removal/Reinstallation of snubbers is to be performed generally in accordance with the following steps. The steps may be performed out of sequence as required to best facilitate the flow of work.

4) Document removal and reinstallation data for the snubber on Attachment 4 Data Sheet, Removal and Reinstallation of Snubbers.

1.0 REMOVAL OF PACIFIC SCIENTIFIC MECHANICAL SNUBBERS NOTES

1) Care should be exercised to catch the spacers as the pin or stud is removed.

2) The snubbers through size PSA 10 may be easily operated by hand to extend or retract, as necessary, to ease removal of the snubber. For sizes PSA-35 and -100, both pivot pins will require removal, and rigging should be used as necessary to support the snubber.

3) The foreman should record the diameter of the pivot pin from the PSA-1 0 snubbers as either 7/8 inch or 1 inch in the remarks section of the Attachment 4 Data Sheet, as a reminder when reinstalling the snubber.

4) When exchanging of an end plug is required on an existing PSA 10 with 7/8 inch diameter pins to a PSA 10 with 1 inch diameter pins, refer to Attachment 7 for instructions.

[1] PERFORM visual inspection of the snubber for any visible damage and freedom of movement. [1.1] IF visible damage or difficulty of movement are discovered, NOTIFY the Snubber Engineer/designee to evaluate the condition in accordance with Attachment 6.

BFN Removal and Reinstallation of MPI-0-000-SNB004 Unit 0 Snubbers Rev. 0036 Page 32 of 58 Attachment 2 (Page 2 of 6) Removal and Reinstallation of Mechanical Snubbers Date 1.0 REMOVAL OF PACIFIC SCIENTIFIC MECHANICAL SNUBBERS (continued) [2] ENSURE snubber attachment fasteners are NOT loose or missing prior to unpinning the snubber(s). [2.1] IF loose or missing attachment fasteners are discovered, NOTIFY Snubber Engineer/Designee to initiate a Problem Event Report (PER) in accordance with SPP-3.1, Corrective Action Program, and evaluate the condition in accordance with Attachment 5. NOTE The position setting is the measured distance from the housing lip to the edge of the position indicator tube. [3] RECORD the "As-Found" position setting on Attachment 4 Data Sheet. [3.1] IF the "As-Found" position setting is not legible, THEN MEASURE the "As-Found" position setting in accordance with Illustration 1 to the nearest 1/8 inch. RECORD the value on Attachment 4 Data Sheet. [4] REMOVE cotter pin(s) from the end of the clevis pins. [5] USE a chain fall, block and tackle, or similar method to secure and lower the unit for removal as necessary. [6] REMOVE the pivot pins from the end attachments and/or pipe as required. [7] TRANSPORT the unit to the designated testing area after it has been decontaminated, if required.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 33 of 58 Attachment 2 (Page 3 of 6) Removal and Reinstallation of Mechanical Snubbers Date 2.0 REINSTALLATION OF PACIFIC SCIENTIFIC MECHANICAL SNUBBERS NOTE If practical, the snubber should be reinstalled such that the position setting may be read from a convenient location. [1] USE a chain fall, block and tackle, or similar method to secure and raise the unit for installation as necessary. CHECK the alignment of the snubber with its rear-bracket and/or pipe clamp. [2] ENSURE snubbers which are oriented vertically are reinstalled such that the base of the housing assembly is up to avoid accumulation of moisture in the base housing of the snubber. CAUTION Do NOT twist or rotate the snubber shaft. Damage to the internal parts will result if the snubber is rotated, one end relative to the other end. [3] ORIENT snubber end attachment and BOLT in place, if required. USE Illustration 2 for torquing requirements. RECORD the torque data on Attachment 4 Data Sheet. [4] APPLY anti-seize thread lubricant to the surface of the pivot pins and to all threaded fasteners that are being installed. [5] At the end of each installation, CHECK each unit for the following information. A. Snubber Serial Number. B. Piston rod extension dimension. C. Visible condition of the unit.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 34 of 58 Attachment 2 (Page 4 of 6) Removal and Reinstallation of Mechanical Snubbers Date 2.0 REINSTALLATION OF PACIFIC SCIENTIFIC MECHANICAL SNUBBERS (continued) D. Cotter pins installed in clevis pins. E. Gaps between the spacers and the spherical bearing is 1/16 inch or less. [6] OBTAIN the "As-Left" position setting. RECORD the value on Attachment 4 Data Sheet. NOTE The "As-Left position setting should be the same as the "As-Found" position setting if they are measured identically both times. However, it should be recorded in the remarks section of Attachment 4 Data Sheet, if it is different. [7] COMPLETE Attachment 4 Data Sheet, and SUBMIT to the Snubber Engineer/Designee for final evaluation. [8] IF the snubber is subject to moisture, high humidity, or vibration, GREASE the end attachment spherical bearings as required with GP-2 (or equivalent).

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 35 of 58 Attachment 2 (Page 5 of 6) Removal and Reinstallation of Mechanical Snubbers REINSTALLATION OF PACIFIC SCIENTIFIC MECHANICAL 2.0 SNUBBERS (continued) ILLUSTRATION 1 111111111 0 cv~c'J'-

                                         '"I'll     ________________

Attachment 2 (Page 6 of 6) Removal and Reinstallation of Mechanical Snubbers 2.0 REINSTALLATION OF PACIFIC SCIENTIFIC MECHANICAL SNUBBERS (continued) Illustration 2 Size Spacers (5) Cotter Pin Pivot Pin Stud Bolt (1) PSA-1/4 1/2 x 3/8 x 1/16 1/8 x 1 3/8 x 2 3/8 x 2, 2-1/4, 2-1/2 PSA-1/2 1/2 x 3/8 x 1/16 3/8 x 1 3/8 x 2 3/8 x 2, 2-1/4, 2-1/2 PSA-1 5/8 x 1/2 x 1/16 1/8 x 1 1/2 x 2 1/2 x 2-3/4, 3, 3-1/4 PSA-3 7/8 x 3/4 x 1/16 1/8 x 1-1/2 3/4 x 2-1/2 3/8 x 4-1/2, 4-3/4, 5 PSA-10 1 x 7/8 x 1/16 3/16 x 2 7/8 x 2-3/4 7/8 x 4, 4-1/4, 4-3/4, 5, 5-1/4, 5-1/2, 6 PSA-35 1-7/8 x 1-1/2 x 3/16 1/4 x 2-3/4 1-1/2 x 4-3/8 1-1/2 x 9-1/4, 9-3/4 PSA-100 2-7/8 x 2-1/2 x 1/2 3/8 x 4 2-1/2 x 7-3/8 2-1/2 x 15-5/8 Size Stud Nut Snubber End Indicator Tube Snubber End Attachment Bolts (1) Attachment Bolts Bolt Torque PSA-1/4 3/8- 16 UNC 10 - 24 X 3/4 N/A 22 +/-2 in-lb PSA-1/2 1/2- 13 UNC 10- 24 X 3/4 N/A 22 +/-2 in-lb PSA-1 1/2- 13 UNC 1/4 - 20 X 1 8- 32 X 1/4 45 +/-5 in-lb PSA-3 3/4- 13 UNC 5/16- 24 X 1-1/4 10 - 32 X 1/4 120 +/-10 in-lb PSA-10 7/8- 9 UNC 1/2 - 13 X 1-1/2 10 - 32 X 5/16 37 +/-2 ft-lb PSA-35 1-1/2-6 UNC N/A 1/2 - 28 X 1/2 N/A PSA-100 2-1/2-4 UNC N/A 5/16 -24 X 5/8 N/A Size Rod Ext. Nut Pliers (2) Safety Size of Snap Ring Wire Telescope Cylinder PSA-1/4 1/2 - 13 UNC S - 6500 0.032 3/4 N5002 - 200 MD PSA-1/2 1/2 - 13 UNC S - 6500 0.032 3/4 N5002 - 200 MD PSA-1 3/4 - 10 UNC S - 6700 0.032 1 N5002 - 312 MD PSA-3 1-1/4 - 7 UNC S-6700 0.032 2 N5002 - 412 MD PSA-10 1-1/2 - 6 UNC S-6700 0.032 2-1/2 N5002 - 500 MD PSA-35 2-1/2 - 4 UNC N/A N/A 4 N/A PSA-100 N/A N/A N/A 4 N/A NOTES

1) Head Drilled for lock wire.

2) Retains support cylinder in housing assembly sizes through PSA 10.

3) Size of hydraulic snubber which uses the same size attachments.

4) Browns Ferry has early version with 7/8" ball bushing and is now special order. (new standard is 1" diameter).

5) The spaces (A) between the spaces/washers of the bracket assemblies or pipe clamp shall NOT allow more than 1/16 inch of lateral movement of the spherical, bearing. Spacers/washers may be added, as necessary, to ensure this maximum gap is maintained.

BFN Removal and Reinstallation of MPI-0-000-SNB004 Unit 0 Snubbers Rev. 0036 Page 37 of 58 Attachment 3 (Page 1 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints NOTE Document removal and reinstallation data for the snubber on Attachment 4 Data Sheet, Removal and Reinstallation of Snubbers. Steps may be performed out of sequence as required to best facilitate the flow of work. 1.0 REMOVAL OF BERGEN-PATERSON OR LISEGA HYDRAULIC TORUS DYNAMIC RESTRAINTS (TDR) [1] PERFORM visual inspection of the snubber visible damage or fluid leakage. RECORD the observed condition on Attachment 4 Data Sheet. [1.1] IF visible damage or fluid leakage are discovered, NOTIFY the Snubber Engineer to evaluate the condition in accordance with Attachment 6. [2] ENSURE the visual examination has been performed prior to the removal of the snubber. [3] ENSURE snubber attachment fasteners are NOT loose or missing prior to unpinning the snubber(s). [3.1] IF loose or missing attachment fasteners are discovered, NOTIFY the Snubber Engineer to initiate a Problem Event Report (PER) in accordance SPP-3.1, Corrective Action Program, and evaluate the condition in accordance with Attachment 5. [4] MEASURE the "As-Found" position setting in accordance with Illustration 1A. RECORD the value on Attachment 4 Data Sheet, to the nearest 1/8 inch.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 38 of 58 Attachment 3 (Page 2 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 1.0 REMOVAL OF BERGEN-PATERSON OR LISEGA HYDRAULIC TORUS DYNAMIC RESTRAINTS (TDR) (continued) NOTES

1) For Bergen-Paterson, the piston position setting may be obtained by measuring from the face of the rod head to the beginning of the taper on the rod near the wrench flats and subtracting 1/16 of an inch. See Illustration 1A.

2) For Lisega, the piston rod extension is the distance(X)from the front head of the snubber to the outside edge marked on piston rod (nearest 1/8 inch), as shown on Illustration 1B: Record on Attachment 4 Data Sheet.

3) For Lisega, reservoir plunger reading (L) is the reading from the rear plate to the end of the plunger rod (nearest 1/8 inch), as shown on Illustration lB. Record on Attachment 4 Data Sheet.

4) For Lisega, RECORD the "As-Found" position of the 2-way ball valve on Attachment 4 Data Sheet.

5) If the lifting and stroke positioning fixtures are to be used, perform Steps 1.0[5]

thru 1.0[7].

6) Ifthe lifting and stroke positioning fixtures are NOT used, perform Steps 1.0[8]

thru 1.0[8.4].

7) For testing purposes only the upper pin of the restraint is required to be removed, unless the restraint is required to be completely removed to perform the test.

[5] POSITION the lifting fixture on the front head by removing the top adjustment bolt and spreading its arms apart. [5.1] CLOSE fixture arms around the restraint's front head, making sure the fixture's tabs fit flush against the restraint's front head. [5.2] REPLACE the top adjustment bolt, but do NOT tighten.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 39 of 58 Attachment 3 (Page 3 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 1.0 REMOVAL OF BERGEN-PATERSON OR LISEGA HYDRAULIC TORUS DYNAMIC RESTRAINTS (TDR) (continued) [6] ASSEMBLE the stroke positioning fixture as shown on Illustration 2, as follows: [6.1] THREAD the Enerpac cylinder into the cylinder mounting bracket, making sure that the Enerpac cylinder has full thread engagement into the mounting bracket. [6.2] CONNECT the hydraulic hoses to the Enerpac cylinder. [6.3] TURN ON the power unit and STROKE the Enerpac cylinder piston rod out 2-1/2 inches from its fully retracted position. [7] INSTALL the stroke positioning fixture onto the Torus Dynamic Restraint front clevis per Illustration 3 and the following: [7.1] ATTACH the cylinder/bracket assembly onto the rod clevis round. [7.2] TORQUE the 1-1/4 inch - 7 (cap screw Illustration 3) to 350 FT-LB. The orientation of the cylinder/bracket assembly should be 90 degrees from the perpendicular and in line with the trunnion threaded hole. NOTE The lifting fixture may require alignment with the cylinder/bracket assembly to enable the load rod to thread into the trunnion. [7.3] INSERT the load connection rod and THREAD it through the Enerpac threaded collar (Illustration 3). [7.4] TORQUE the top adjustment bolt on the lifting fixture to 50 ft-lbs.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 40 of 58 Attachment 3 (Page 4 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 1.0 REMOVAL OF BERGEN-PATERSON OR LISEGA HYDRAULIC TORUS DYNAMIC RESTRAINTS (TDR) (continued) [8] IF the stroke positioning fixture is not to be used, THEN PERFORM the following: [8.1] INSTALL an eye bolt into one of the tapped holes in the locknut. [8.2] ATTACH nylon lifting straps or chokers to previously installed eyebolts. [8.3] ATTACH nylon lifting straps or chokers around the body of the restraint to replace the lifting fixture. [8.4] With two Come-A-Longs or chain falls, RELIEVE the restraint's weight by pulling upward on the lifting strap(s) with a force of approximately 1800 pounds. [9] If the freeze fit pins have already been removed PROCEED TO Step 1.0[13]. [10] With the restraint being held in place by the Come-A-Long or chain fall, SET UP the drill rig for the removal of the freeze fit pins. [11] DRILL the pin out. [12] ENSURE the snubber setting is NOT disturbed while unpinning the snubber before testing, if possible.

BFN Removal and Reinstallation of MPI-0-O00-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 41 of 58 Attachment 3 (Page 5 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 1.0 REMOVAL OF BERGEN-PATERSON OR LISEGA HYDRAULIC TORUS DYNAMIC RESTRAINTS (TDR) (continued) [13] REMOVE the Special 4 Inch Tapered Two Piece Pins as follows: [13.1] REMOVE the 1/2 inch cotter pin from the end of the tapered pin and slotted nut. [13.2] Using a wrench on the head of the pin to restrain the pin, LOOSEN slotted nut. [13.3] BACK OFF the nut until there is approximately 1/2 inch clearance between the washer and the shoulder of the pin. [13.4] Using a brass plate or similar device to protect the slotted nut, TAP the brass plate to break loose the self-locking taper of the pin and sleeve. CAUTION Do NOT allow the threads of the pin to contact and gouge the sleeve. [13.5] REMOVE the slotted nut and washer from the pin and REMOVE the pin from the sleeve.

Attachment 3 (Page 6 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS NOTES

1) It is preferred to reinstall the unit in the same restraint assembly, using the identification mark. Using units of similar bore and stroke is possible at any given location, but should be done on a case-by-case basis under the direction of the Snubber Engineer or designee.

2) The permanent spacer washers on the end attachments may be filed smooth in order to facilitate installation of the end piece of the Lisega dynamic restraint.

3) Prior to rigging a Lisega snubber into place verify pin-to-pin dimensions of snubber and attachments to ensure they match and adjust snubber's length as required. For adjustment instructions see Steps 2.0[9.1] thru 2.0[9.4].

[1] PERFORM the following: [1.1] INSERT the short alignment pin into the torus wall bracket. [1.2] INSERT the torus dynamic restraint bottom paddle between the torus wall bracket. [1.3] INSERT the special 4 inch tapered two piece pin as directed by Step 2.0[8] into the torus wall bracket. [1.4] SWING the front clevis down between the torus bracket ears. NOTE If the test machine is attached to the restraint it may be used to adjust the restraint for repining and Steps 2.0[2] thru 2.0[6] may be omitted. [2] CONNECT the hydraulic hoses from the Enerpac power unit to the Enerpac cylinder.

Attachment 3 (Page 7 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) [3] INSERT the short alignment pin into one of the torus ears (tapered end first). [4] TURN the power unit on and EXTEND the restraints' stroke out until the alignment pin slides freely through both the ball bushing and the opposite torus ear. [5] Once the temporary pin is inserted, DISCONNECT the hydraulic hoses and UNTHREAD the 1-1/4 inch - 7 UNC load rod from the trunnion until the 1-1/4 inch - 7 UNC screw is accessible. [6] REMOVE the cap screw and bracket/cylinder/load rod. [7] ENSURE the restraint is completely restrained. [8] INSTALL the Special 4 Inch Tapered Two Piece Pins as follows: [8.1] DISASSEMBLE the tapered pin assembly. [8.2] APPLY a thin film of lubricant to the OD of the sleeve and to the threads and tapered surface of the pin. USE Never Seez Pure Nickel, Neolube 1 or 2, Felpro C5-A Nuclear Grade, Fel-Pro N-7000 or G.E. Silicone Grease, G-351. [8.3] VERIFY the bore of the bracket and the bearing are free of burrs, rust, and debris. [8.4] INSERT the tapered pin in the thin end of the sleeve until the threaded portion of the pin is such that the slotted nut can be started. [8.5] PLACE a wrench on the pin head to restrain the pin while tightening the slotted nut.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 44 of 58 Attachment 3 (Page 8 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) [8.6] TORQUE both slotted nuts of both special 4 inch tapered two piece pins to 100 ft-lbs. Otherwise, TORQUE the upper paddle special 4 inch tapered two piece pin to 100 ft-lbs. [8.7] BACK the nut off only enough to align a set of slots in the nut with the first available hole. [8.8] INSERT the cotter pin(s) in the hole(s). SPREAD the cotter pin(s) enough to prevent falling out. [9] OBTAIN the "As-Left" position setting. RECORD the value on Attachment 4 Data Sheet. NOTES

1) For Bergen-Paterson, the piston position setting may be obtained by measuring from the face of the rod head to the beginning of the taper on the rod near the wrench flats and subtracting 1/16 of an inch. See Illustration 1A.

2) For Lisega, the piston rod extension is the distance(X)from the front head of the snubber to the outside edge marked on piston rod (nearest 1/8 inch), as shown on Illustration 1B: Record on Attachment 4 Data Sheet.

3) For Lisega, the reservoir plunger reading (L) is the reading from the rear plate to the end of the plunger rod (nearest 1/8 inch), as shown on Illustration 1 B: Record on Attachment 4 Data Sheet.

4) If the torus dynamic restraint (Lisega or Bergen-Paterson) piston is at the end of its stroke it may be necessary to adjust the piston length. This may be performed on the snubber installed in the plant without removing the installation pins. This adjustment is performed under the direction of the Snubber Engineer/Designee utilizing the following steps.

Lisega

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 45 of 58 Attachment 3 (Page 9 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) [9.1] LOOSEN the hex head bolts on the end attachment paddle 1-2 turns to allow the piston to be turned. [9.2] Using a spanner wrench or other suitable tool, TURN the piston clockwise to lengthen the piston or counter clockwise to shorten the piston. [9.3] ADJUST piston to provide 1/8" to 1/4" of reserve travel as determined by the Snubber Engineer/Designee. [9.4] RE-TIGHTEN the hex head bolts on the end attachment paddle after desired piston adjustment is completed. Bergen-Paterson [9.5] LOOSEN lock nut on the end attachment paddle. [9.6] Using an open end wrench, TURN the piston clockwise to lengthen the piston or counter clockwise to shorten the piston. [9.7] ADJUST piston as determined by the Snubber Engineer/Designee. [9.8] RETIGHTEN the lock nut on the end attachment paddle after desired piston adjustment is completed.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 46 of 58 Attachment 3 (Page 10 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints Date 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) [10] At the end of each installation, CHECK each unit as a precaution for the following information:

• Snubber Serial Number.
• Piston rod extension dimension.

            "    Fluid level indicator reading.
            "    Whether or NOT fluid was added to bring unit to proper level.
            "    Visible condition of the unit.

• Condition of the strut assembly, with particular attention to the clamp and bolting tightness.
• Cotter pins installed in clevis pins.

[11] For Lisega Torus Dynamic Restraints, VERIFY the 2-way ball valve positioner is in the vertical position. RECORD on Attachment 4 Data Sheet. [12] IF the snubber is subject to moisture, high humidity, or vibration, GREASE the end attachment spherical bearings with a high-quality grease (such as GP-2, etc.) for this application. [13] COMPLETE Attachment 4 Data Sheet, and SUBMIT to the Snubber Engineer/designee for final evaluation.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 47 of 58 Attachment 3 (Page 11 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) ZILLUSTRATIOR 1.A - BERGEN.-PATERSON FACE OF ROD HEAD JO BEGINNING OF' TAPER MINUS 1/16 INCHý:: ILLUSTRATION 1B3 - LISEWL i >iiiii i !: ~ ~~ii:i~ ~~~i!!!::::Li: t*AX

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 48 of 58 Attachment 3 (Page 12 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) Lisega Minimum and Maximum Fluid Level Plunger and Piston Position Measurement In The Field. Nomenclature: X - Measurement of the snubber piston rod position in inches from the front head of the snubber to the outside edge marked piston rod. L Minimum - The minimum fluid level in the reservoir using the reservoir piston rod position measured from the front of the reservoir to the end of the reservoir piston rod. L Maximum - The maximum fluid level in the reservoir using the reservoir piston rod position measured from the front of the reservoir to the end of the reservoir piston rod. If the X measurement is between the values given in the table below for "X", then GO TO the next lower reading for "X" to determine the L Minimum and L maximum. X L L (INCHES) MINIMUM MAXIMUM (INCHES) (INCHES) 0.000 2.52 3.31 0.125 2.43 3.22 0.250 2.34 3.13 0.375 2.26 3.04 0.500 2.17 2.96 0.625 2.08 2.87 0.750 1.99 2.78 0.875 1.91 2.69 1.000 1.82 2.60 1.125 1.73 2.52 1.250 1.64 2.42 1.375 1.55 2.34 1.500 1.47 2.25

Attachment 3 (Page 13 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued) Illustration 2

                             .A                    B1~ACKF~                 ""PAC)

SEXCTICt A-A I F ý. E T"1P VIEW

                          -K                          .......           HYDRAULIC 110 Mv PCi'i, Uie CAP

BFN Removal and Reinstallation of MPI-0-000-SNBO04 Unit 0 Snubbers Rev. 0036 Page 50 of 58 Attachment 3 (Page 14 of 14) Removal and Reinstallation of Bergen-Paterson or Lisega Torus Dynamic Restraints 2.0 REINSTALLATION OF BERGEN-PATERSON OR LISEGA DYNAMIC RESTRAINTS (continued)

* > ~ ~~~..

  .....                                                LL.T.TIO            3*t*

RO D .... .... .7 17. 1 . . . . . . . - - . 1.I~zz:*Z >" ~11

                             > 11 1 Zzzz~ > >>11111
                                                > >> > 11 1 1-..111..11 11 1i~ > >> > >> > >> > >1                Z/>

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 51 of 58 Attachment 4 (Page 1 of 3) Data Sheet Snubber Type: Unit Cycle WO # Snubber UNID # Snubber S/N (removed) Snubber S/N (installed) Instruction Performer Signature/Date Unit Supervisor Notified of Snubber Foreman/Designee Removal Time Name REMOVAL Visible Damage of Snubber Craftsman Found: YES NO Fluid Leakage from Snubber Craftsman Found: YES NO Freedom of Movement for Mechanical Craftsman Snubber: YES NO Loose or Missing Craftsman Fasteners: YES NO Mechanical Craftsman Position Indication Reading "As-Found" Reading: Bergen-Paterson, Anchor/Darling, Fronek Craftsman Hydraulic Record Readings: AF Index/Plunger: AF Piston: -3/4

     =    _    _(Actual         Piston Reading)

AF Index/Plunger - Actual Piston Reading

      =     _        _      (Fluid Level)

Grinnell Hydraulic Craftsman AF Piston Measurement:

   *Fluid Level Acceptable:             YES      NO
   *Reservoir should be approx. half full.

Lisega Type 30 AF Reading: Craftsman Bergen-Paterson Torus Dynamic Restraint Craftsman Index / Piston Reading - "As-Found": Record Readings: AF Index(Plunger): AF Piston: -1/16 =

BFN Removal and Reinstallation of MPI-0-000-SNB004 Unit 0 Snubbers Rev. 0036 Page 52 of 58 Attachment 4 (Page 2 of 3) Data Sheet Instruction Performer Signature/Date Lisega Torus Dynamic Restraint Craftsman Piston Rod Position X - "As-Found": Record Reading: Lisega Torus Dynamic Restraint Craftsman Reservoir Plunger L - "As-Found": Record Reading: Lisega Torus Dynamic Restraint lst/2nd Party 2-Way Ball Valve - "As-Found": Record Position: REINSTALLATION Snap ring seated or Line Verifier / Telescoping tube nut torqued Torque Wrench: Craftsman M&TE No. Cal. Due Date Torque of Base Plate Bolts or Line Verifier Threaded Extension Connector Torque Wrench: Craftsman M&TE No. Cal. Due Date Fasteners & Pins Secure Craftsman Mechanical Craftsman Position Indication Reading "As-Left" Reading: Bergen-Paterson, Anchor/Darling, Fronek Craftsman Hydraulic Record Readings: AL Index/Plunger: AL Piston: -3/4

=    _    _(Actual        Piston Reading)

AL Index/Plunger - Actual Piston Reading (Fluid Level) Grinnell Hydraulic Craftsman AL Piston Measurement:

• Fluid Level Acceptable: YES NO
• Reservoir should be approx. half full.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 53 of 58 Attachment 4 (Page 3 of 3) Data Sheet Instruction Performer Signature/Date Torque of Type 3018 Extension Strut Bolts Line Verifier / Torque Wrench: M&TE No. Craftsman Cal. Due Date, Torque of Type 3038 - 3092 Locking Line Verifier Flange Set Screw. Torque Wrench: Craftsman M&TE No. Cal. Due Date Lisega Type 30 AL Reading: Craftsman Bergen-Paterson Torus Dynamic Restraint Craftsman Index / Piston Reading - "As-Left": Record Readings: AL Index(Plunger): AL Piston: -1/16 = Lisega Torus Dynamic Restraint Craftsman Piston Rod Position X - "As-Left": Record Reading: Lisega Torus Dynamic Restraint Craftsman Reservoir Plunger L - "As-Left": Record Reading: Lisega Torus Dynamic Restraint 1st/2nd Party 2-Way Ball Valve - "As-Left": Record Position: Fluid Level Reading Acceptable Craftsman Bolts and Jam Nuts Torqued Line Verifier Torque Wrench: M&TE No. Craftsman Cat. Due Date Unit Supervisor Notified Snubber Foreman/Designee Reinstalled Time Name Remarks:

Attachment 5 (Page 1 of 1) Evaluation of Loose or Missing Attachment Fasteners NOTE This evaluation shall be performed only when fasteners, used for attachment of snubber(s) to component and to snubber anchorage, are discovered loose or missing prior to the "As-Found" functional testing. Snubber Type Unit Serial No. Snubber UNID No. PER No. Subgroup Size

1. Describe the discovered condition(s):

2. If possible, determine cause:

3. Evaluate to determine whether the cause may be localized or generic. Use this evaluation to select and list other suspect snubbers for verifying attachment fasteners, as applicable.

4. Describe the corrective action(s) and provide the "As-Found" test results.

Evaluated by: Snubber Engr./Designee Date

Attachment 6 (Page l of 2) Engineering Evaluation of Unacceptable Indication Unit Snubber UNID No. Serial No. Exam No._ Manuf. Size PER No.

1. Describe the unacceptable indication(s) observed.

2. What is the cause of the indication(s) (i.e., vibration, water leaking on surface, possible failure to torque at last reinstallation, etc.)?

3. What is the basis for the conclusions reached by question 2 above?

4. Which additional snubbers are suspected to be subject to the same unacceptable indication(s)?

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 56 of 58 Attachment 6 (Page 2 of 2) Engineering Evaluation of Unacceptable Indication Unit Snubber UNID No. Serial No. Exam No._ Manuf. Size PER No.

5. What further examination(s) and/or test(s) of the snubber(s) are to be performed?

6. What are the results of the examination(s) and/or test(s) performed by Step 5 above, and what changes in the initial evaluation should be made?

7. What corrective action(s) is/are to be taken for the initial snubber and/or any other suspect snubbers?

8. Has/have the corrective action(s) been taken?

Evaluated by: Snubber Engr./Designee Date

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 57 of 58 Attachment 7 (Page 1 of 2) Instructions for Exchanging the Snubber End Plug NOTES

1) These instructions are applicable'to PSA 10 mechanical snubbers.

2) These instructions are to be followed when an existing PSA 10 mechanical snubber with a 7/8 inch diameter pin is replaced with a PSA 10 mechanical snubber with a 1 inch diameter pin.

1.0 PERFORMANCE [1] REMOVE the fillister head screws and flat washers to free the position indicator tube from the end plug assembly of the old and new snubber. [2] REPLACE screws if distorted or damaged. [3] REMOVE the position indicator tube. [4] PLACE the snubber on an appropriate workbench or stand. [5] Using an Allen wrench, REMOVE the set screws from the end plug assembly. [6] REPLACE screws if distorted or damaged. [7] REMOVE the distorted threads of the telescoping cylinder as needed. A drill size number 23 may be used. Drill only to the depth necessary to remove the distortions, allowing the end plug to rotate freely. [8] SECURE the telescoping cylinder to prevent rotation. [9] REMOVE the end plug from each snubber. [10] INSTALL the appropriate end plug on the snubber.

BFN Removal and Reinstallation of MPI-0-000-SNBOO4 Unit 0 Snubbers Rev. 0036 Page 58 of 58 Attachment 7 (Page 2 of 2) Instructions for Exchanging the Snubber End Plug Date 1.0 PERFORMANCE (continued) [11] TORQUE the end plug to 40 - 60 inch pounds. Performer Signature Date Final torque applied: Line Verifier Signature Date [11.1] BACK OFF end plug to achieve proper alignment, if needed. [12] COAT set screw threads with approved retaining compound. INSTALL the set screws. [13] TORQUE set screws to 15 - 25 inch pounds. Performer Signature Date Final torque applied: Line Verifier Signature Date [14] REINSTALL the position indicator tube over the end plug assembly. [15] COAT fillister screw threads with approved retaining compound. REINSTALL the fillister head screws snug tight. Safety wire fillister head screws.

Attachment E BFN Surveillance Instruction, O-SI-4.6.H-2A, Functional Testing of Mechanical Snubbers

Browns Ferry Nuclear Plant Unit 0 Surveillance Instruction 0-SI-4.6.H-2A Functional Testing of Mechanical Snubbers Revision 0008 Quality Related Level of Use: Continuous Use Effective Date: 03-16-2007 Responsible Organization: DEC, Design Eng Civil Prepared By: Stephen Samaras Approved By: Eric Frevold

BFN Functional Testing of Mechanical O-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 2 of 36 Current Revision Description Pages Affected: Cover sheet, revision log, 7, 8, and 9. Type of Change: REVISION Tracking Number: 009 This procedure is being revised to provide additional clarification on the activation rate acceptance criteria.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 3 of 36 Table of Contents

1.0 INTRODUCTION

....................................................................................................                           5 1.1   P u rp os e ........................................................................................................................        5 1 .2  S c o p e ............................................................................................................................      5 1.3   Frequency/C onditions ...............................................................................................                       6

2.0 REFERENCES

......................................................................................................                           7 3.0   PRECAUTIONS AND LIMITATIONS .......................................................................                                         7 4.0   PREREQUISITES ..................................................................................................                            8 5.0   SPECIAL TOOLS AND EQUIPMENT RECOMMENDED .......................................                                                             8 6.0   ACCEPTANCE CRITERIA .......................................................................................                                 8 7.0   PROCEDURE STEPS .............................................................................................                              10 7.1   Training and Qualification of Performers .................................................................                                 10 7.2   Preparation of Test Data Package .........................................................................                                 10 7.3   "As-Found" and "As-Left" Functional Test Using the STB 200 Test B e n c h ..........................................................................................................................       11 7.4   R esults Evaluation ................................................................................................                   . . 17 7.5   D ata Sheet R eview ................................................................................................                       17 8.0   APPENDIX/ATTACHMENTS ..................................................................................                                    18 Appendix A:           Subgrouping of Mechanical Snubbers ...............................................                                         19 Appendix B:           Daily Startup Procedures for the STB-200 Test Bench .....................                                                  21 Appendix C:           PSA Mechanical Snubber Rated Load ...............................................                                          24 Appendix D:           Common Modes of Snubber Failure and Possible Causes ...............                                                        25 Appendix E:           Instructions for Exchanging the End Plug from Old to New Snubber .........................................................................................                      26 : Surveillance Instruction Review Form ...............................................                                               27 : Test Data for Removed and Reinstalled Snubber Using the STB-200 Test Bench .......................................................................                             28 : Engineering Failure Analysis for Inoperable Snubbers ....................                                                          31

BFN Functional Testing of Mechanical '0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 4 of 36 Table of Contents (continued) : Supported System/Component Analysis for Inoperable Snubber ................................................................................................ 33 : Test Data for New, Replacement, or Rebuilt Snubber Using the STB-200 Test Bench ............................ 34 : Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range ................................................................................ 35

1.0 INTRODUCTION

1.1 Purpose This Surveillance Instruction implements Technical Requirements Manual (TRM) TR 3.7.4, and provides direction for the functional testing of mechanical snubbers, as given in the Snubber Program Procedure (0-TI-398), on all safety related systems, inside and outside of the drywell. 1.2 Scope The snubbers within the scope of this instruction are accessible during reactor operation (outside the drywell) and inaccessible during reactor operation (inside the drywell). The Pacific Scientific Company (PSC) mechanical snubbers belong to Subgroups 3a, 3b, 4, and 6. The portions of Technical Requirements TR 3.7.4 pertaining to the visual examination of snubbers are implemented by Surveillance Instructions 1-SI-4.6.H-1, 2-SI-4.6.H-1, and 3-SI-4.6.H-1. This Surveillance Instruction (SI) provides the requirements and guidance to perform functional testing of Pacific Scientific mechanical snubbers addressed as PSA-1/4,

   -1/2, -1, etc. for Units 1, 2, and 3 as follows:

• Removal and reinstallation of Pacific Scientific mechanical snubbers to facilitate testing is accomplished in accordance with MPI-0-000-SNBOO4 and recorded in Attachment 2 and 5.
• Provides the requirements for functional testing of Pacific Scientific mechanical snubbers. This instruction covers subgroups 3a, 3b, 4 and 6 (see Appendix A for snubber subgroup information). To completely fulfill the snubber Technical Requirements Manual (TRM) functional testing requirements, other Surveillance Instructions, O-SI-4.6.H-2B, O-SI-4.6.H-2C, O-SI-4.6.H-2D, and O-SI-4.6.H-2E must also be performed as required per TSR 3.7.4.2.
• Provides a means for the control and documentation of all snubber surveillance activities provided in this Surveillance Instruction.

   "     This Surveillance Instruction shall be used to verify operability of mechanical snubbers suspected inoperable during performance of the visual examination SI's.

• All PSA-1/4 snubbers (inside the drywell) should be stroke tested during each refueling outage, as close to the end of the outage as possible.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 6 of 36 1.3 Frequency/Conditions A. This Surveillance Instruction shall be performed each refueling outage and portions of it may be performed to establish operability in accordance with 1-SI-4.6.H-1, 2-SI-4.6.H-1, and 3-SI-4.6.H-1 Visual Examination of Hydraulic and Mechanical Snubbers. B. This instruction may be performed at any time for snubbers outside the drywell (preferably no earlier than 60 days prior to the start of the outage), but may only be performed at a time when the drywell may be entered for snubbers inside the drywell. C. All safety related snubbers shall be operable during all modes of operation as described in the Technical Requirements Manual TR 3.7.4, if the system is required to be operable during that mode. D. Snubbers located inside the drywell on reactor vessel attached piping shall be OPERABLE whenever fuel is in the reactor vessel. Snubbers on the Main Steam, HPCI, and RCIC piping in the drywell are exempt from the operability requirement when the steam line plugs are installed in the reactor vessel. E. Snubbers on safety related systems that have experienced unexpected potentially damaging transients shall be evaluated for the possibility of concealed damage and functionally tested, if applicable. F. A snubber removed from an operable safety related system must be reinstalled or replaced within 72 hours of its removal or declare the supported component or system inoperable and follow the appropriate action statement for that system. G. For an inoperable snubber(s), within 72 hours, replace or restore inoperable snubbers to an operable status and perform an engineering evaluation on the supported component or system, if the snubber does NOT meet the functional test acceptance criteria of TSR 3.7.4.2. Otherwise, declare the system inoperable and follow the required actions specified in the TRM. The engineering evaluation is to determine if the component or system restrained by the snubber(s) was adversely affected by inoperability of the snubber(s) during the previous operating cycle and ensure that the restrained component or system remains capable of meeting its design function. The engineering evaluation(s) for supported component or system analysis are to be documented on Attachment 4. H. Alternately, for a snubber removed and NOT replaced within 72 hours, or an inoperable snubber NOT replaced or restored within 72 hours, operability of the supported system may be verified based on an engineering evaluation of the system functional capability with the removed or inoperable snubber.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 7 of 36 1.3 Frequency/Conditions (continued)

1. Snubbers removed for maintenance or determined to be inoperable on a non-operable safety related system must be reinstalled or replaced, in accordance with MPI-0-000-SNBOO4 and tested in accordance with this instruction, prior to declaring the system operable.

J. For all subgroups, when subsequent testing is required, it shall continue within the respective subgroup until no failure is found. K. New, replaced or rebuilt snubber(s) shall meet the functional test acceptance criteria before their installation in the unit and must have been functionally tested "Satisfactory", within 12 months prior to their installation.

2.0 REFERENCES

A. Technical Requirements Manual, TR 3.7.4 Snubbers. B. 1-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers. C. 2-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers. D. 3-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers. E. MPI-0-000-SNBOO4, Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers. F. BFN-VTM-P029-0010, Pacific Scientific Instruction Manual for Repair, Overhaul, Installation and Maintenance of Mechanical Shock Arrestors. G. 0-TI-398, Snubber Program Procedure H. SPP-3.1, Corrective Action Program I. SPP-8.1, Conduct of Testing. J. A Snubber Response Sensitivity Study, A. T. Onesto, Energy Technology Engineering Center (ASME Technical Conference Paper PVP-37 "Piping Restraint Effect on Piping Integrity" June, 1979) 3.0 PRECAUTIONS AND LIMITATIONS None

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 8 of 36 4.0 PREREQUISITES A. Six months prior to each refueling outage, the supply of mechanical snubbers in Power Stores and the Snubber Rebuild Facility shall be reviewed. A number of snubbers equal to the 10% sample population for the Subgroup selected for functional testing during the upcoming refueling outage shall be identified and available for installation. The snubbers shall have the proper paperwork with them to comply with the requirements of the Section XI Repair and Replacement Program. This paperwork should include the purchase contract and Certificate of Compliance for any material requiring traceability. 5.0 SPECIAL TOOLS AND EQUIPMENT RECOMMENDED None 6.0 ACCEPTANCE CRITERIA A. Responses which fail to meet the following As-Found functional test acceptance criteria require immediate notification of the Shift Manager or Unit Supervisor at the time of failure. B. The snubber functional test shall verify that:

1. "As-Found"

a. Activation (restraining action) occurs, in both tension and compression. Snubbers with activation values less than or equal to 0.02 g's are acceptable. The measured value shall be rounded to the second decimal place. Activation values greater than 0.02 g's shall be considered as a failure (inoperable snubber), require a failure analysis, and be evaluated for additional scope or expansion testing.

b. The drag force shall not exceed the maximum acceptable drag force from Table 6.2-1.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 9 of 36 6.0 ACCEPTANCE CRITERIA (continued)

2. "As-Left"

a. Activation (restraining action) occurs, in both tension and compression. Snubbers with activation values less than or equal to O.02g's are acceptable. The measured value shall be rounded to the second decimal place.

b. The drag force shall not exceed 3% of the snubber rated load, except for PSA 1/4 the drag force shall not exceed 32.5 lbs.

C. The stroke setting, adjusted for pipe temperature other than ambient if necessary, shall be within the limits shown on the design drawing. Otherwise, complete Attachment 6. D. There shall be no loose or missing fasteners for attachment of the As-Found mechanical snubber(s) to the component or the anchorage. Otherwise, complete Attachment 6. E. NOT meeting acceptance criteria for the stroke setting, or loose or missing fasteners, does NOT require testing an additional lot equal to 10% of that type of snubber. Evaluation of snubber operability, corrective actions, and selection of other suspect snubbers for verification shall be as specified on Attachment 3 or Attachment 6, as applicable. TABLE 6.2-1 MAXIMUM ACCEPTABLE DRAG FORCE VS. SNUBBER SIZE SNUBBER SIZE ACCEPTABLE SNUBBER SIZE ACCEPTABLE DRAG FORCE DRAG FORCE (lbs.) (lbs.) PSA-1/4 & 1/2 NF 32.5 PSA-10 PRE- NF 500.0 PSA-1 NF 75.0 PSA-10 NF 750.0 PSA-3 NF 300.0 PSA-35 NF 2500.0 PSA-100 NF 6000.0 F. "As-Found" drag forces greater than the maximum acceptable drag force from Table 6.2-1 shall be considered as a failure (inoperable snubber), be evaluated for additional or scope expansion testing, and require a supported component or system analysis by Site Engineering Civil, Attachment 4. G. For snubber(s) specifically required NOT to displace under continuous load, the ability of the snubber(s) to withstand load without displacement shall be verified.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 10 of 36 7.0 PROCEDURE STEPS 7.1 Training and Qualification of Performers A. A thorough briefing should be conducted on SI performance prior to starting. B. The cognizant individual or Snubber Engineer responsible for the performance of the Surveillance Instruction must be qualified as a test director. C. Appropriate General Employee Training (GET) (including respirator training) should be received by test personnel prior to performing this SI. D. Training required for the testing of mechanical snubbers shall meet the requirements of Task Number MMY 502. 7.2 Preparation of Test Data Package [1] EXCLUDE the snubbers from the initial test lot (sample plan) which are scheduled for deletion in accordance with approved Design Change Notices. [2] EXCLUDE the snubbers until the next outage from the initial test lot (sample plan) which are to be added in accordance with approved Design Change Notices. [3] SELECT snubbers for retest which were placed in the same location as snubbers which failed during the previous outage, if the failure analysis showed that the failure was due to the location. However, these snubbers shall be tested in addition to the initial 10 percent test lot (sample plan). [4] DETERMINE the initial test lot (sample plan) as follows:

             "    SELECT 10 percent of the snubbers from subgroups 3a, 3b, 4 and 6 (see Appendix A).

• In general, SELECT the snubbers with the most time from the previous test.
• Sample should be weighed to include more snubbers from severe service areas (i.e., inside the drywell).
• SELECT snubbers that have experienced severe transients.

             "    SELECT snubbers of various sizes.

• If one snubber from a pair of parallel snubbers at the same location along the pipe (restrain in the same direction) is selected for testing the other snubber from that pair also should be selected for testing.

7.2 .2 Preparation of Test Data Package (continued) [5] REVIEW the applicable support drawings to verify the location and any conditions that will require special preparation or equipment. [6] REQUEST scaffold or similar devices to be built, as necessary. [7] RECORD the required information on Attachment 1,and prior to REMOVAL of a snubber per MPI-O-OOO-SNBOO4 for functional test, RECORD the "As-Found' Stroke Setting in Attachment 2. 7.3 "As-Found" and "As-Left" Functional Test Using the STB 200 Test Bench [1] IF the extension or one of the end attachments has been removed, THEN INSTALL the appropriate end attachments located in the snubber test facility. [2] ENSURE the test bench has been Warmed Up in accordance with Appendix B of this procedure. NOTE The following describes a suggested procedure for "Testing a Snubber" using the STB 200 Snubber Test Bench with the upgraded Windows Software Operations Manual. [3] POWERING UP THE TEST SYSTEM TURN ON the master power switch on the control console. Make sure that the computer, monitor, and printer are turned on. TURN ON the main breaker on the Hydraulic Power Unit (HPU) located at the end of the power unit. ENSURE that all emergency stop buttons are pulled out. [4] STARTING THE SOFTWARE Once the computer has "Booted Up", the Windows Desktop will be displayed. SELECT the "STB 200" icon and DOUBLE CLICK on it, this will Start the Test program. The "LOG ON" prompt window will appear. ENTER your user name and password in either upper or lower case letters. All functions required by the system are available in the screen, or from one of the Pull Down Menus at the top of the screen. [5] DAILY CALIBRATION CHECK PERFORM the Daily Calibration Check using Section 3.0 of Appendix B, and SIGN the daily calibration form. After the daily calibration check has been completed, and the Daily Calibration Report is "SATISFACTORY", PROCEED on testing a snubber.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 12 of 36 7.3 "As-Found" and "As-Left" Functional Test Using the STB 200 Test Bench (continued) [6] TESTING A SNUBBER [6.1] Pick the Snubber Type Using the Snubber Pull Down List in the User Supplied Information block, SELECT the Type Snubber to be tested. [6.2] Enter the Header Information FILL in the other information as indicated in the User Supplied Information block. [6.3] Running the Test [6.3.1] Pick the Test CLICK on the Type of Test (i.e., "As-Found" or "As-Left") desired. [6.3.2] Start the Test CLICK on the Start Test button. If this is the first test performed on the snubber, the following two windows will appear: [6.3.3] Tare weight Window This window allows the User to "zero out" any offset load that the load cell may be reading. This should be DONE BEFORE installing the snubber in the test bench. WAIT for the "Raw Reading" to settle (as far as possible), and then CLICK "Adjust Load Cell". The "Adjustment" will be updated, and the "Adjusted Reading" should now read close to zero (0) lb. The "Adjust Load Cell" button may be Clicked again if a new adjustment value is desired. Once the readings are as desired, CLICK the "Continue" button. ENSURE the correct load cell is connected to the machine. CHOOSE the proper bushings and pins for the snubber being tested, then INSTALL the bushings in both clevis attachments on the machine. [6.3.4] Stroke and Position Window INSTALL the snubber in the test bench, with the piston or operable end toward the drive piston of the machine if possible. ADJUST the backstop and or USE the Jog Speed Slider to adjust~the bench and the driver cylinder to the desired pin to pin dimension. The jog slider adjusts the jog speed. The joystick on the test frame controls the actual motion of the driver. INSTALL the pins through the bushing and the snubber spherical bearings.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 13 of 36 7.3 "As-Found" and "As-Left" Functional Test Using the STB 200 Test Bench (continued) ONCE the snubber has been pinned, the snubber's piston position (distance from the fully retracted position) should be accurately measured (within 0.1 inch) and entered in the SNUBBER EXTENSION window. If the test program calculates that it cannot fully extend or fully retract the snubber during drag testing, one or more of the text windows on the screen will be highlighted in red. If this happens, the backstop will have to be adjusted and the snubber extension recalculated. The program calculates whether it can fully test the snubber through its stroke range. It will display the two ends of stroke (minus the 1/2" safety zones), the calculated center position and the bottomed out position for the snubber. Once the data has been successfully entered, TIGHTEN the lock nuts on the load cell threaded rod snug tight to prevent slippage during the test. ENTER the snubber number, system number, serial number, and test equipment information on Attachment 2 or 5 as required, and CLICK on "Continue with Test" to continue the test. [6.3.5] If an Activation Test is Selected After all the above steps has been completed, and PRIOR to starting an "As-Found" Activation Test, the test program will initiate a routine to set and stabilize the hydraulic system pressure at a calculated level sufficient to achieve the requested test load. During this period, the set point and actual pressures are displayed, along with the output voltage, and a "count down" value. When the pressure is near the desired value, the countdown value will decrement towards zero. If the pressure fluctuates out of limits, the countdown will reset to six. Once the pressure is stable enough to let the countdown complete, the test will begin automatically. OBSERVE that the snubber activates in both directions, to establish operability of the snubber in the "As-Found" condition. RECORD all necessary information on Attachment 2 or 5, as appropriate.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 14 of 36 7.3 "As-Found" and "As-Left" Functional Test Using the STB 200 Test Bench (continued) NOTE Forcing a test may allow the machine to overstress the snubber during the test! If the user wishes to force a test, clicking the "Force the Test" button will initiate the test regardless of pressure. Clicking the "Abort the Test" button will cause the test cycle to abort without performing the test. [6.3.6] If Drag Test is Selected If a Drag Test (i.e., ID, AC, and FD test sequence for the "As-Left", and AC, FD test sequence for "As-Found" functional test) is selected, the test system will automatically begin the drag test. The system will determine the starting position of the snubber, and choose the initial test direction to move towards the farthest end of stroke. The drag speed will be automatically controlled to the target speed set earlier. This test is to VERIFY free travel of the piston rod through its full stroke, and that the Raw Test Data graphed in real time. VERIFY that the drag force of the snubber is less than the values shown in Table 6.2-1. RECORD this information on Attachment 2 or 5, as appropriate. [6.3.7] Printing the Results After the test is complete, the calculations appropriate to that test are performed and the results are displayed on the screen. This allows the user to review and determine if the "As-Found" test results meet the "As-Left" acceptance criteria in Section 6.0B, and plot the test results: IF the results are within the "As-Left" acceptance range, THEN CLICK on the "Print Test" button to open the standard Windows printer dialog box. SELECT the proper printer, and CLICK "OK" to start the printing. ATTACH the Printed Results in Attachment 2 or 5, as part of the work package.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 15 of 36 7.3 "As-Found" and "As-Left" Functional Test Using the STB 200 Test Bench (continued) IF the test results are NOT within acceptable range, THEN DO NOT start printing or saving the test results. PROCEED TO Step 7.3[8] below. For Activation tests on acceleration limiting snubbers only, the calculated acceleration lines will be printed if they are displayed on the graph when printing is requested. [6.3.8] Saving the Test Results To save a test file to disk, CLICK the "Save Test" button. This saves the test results in the "test-data" directory. The file name of the saved test result is as follows: WorkOrder-number Serialnumber TestDate TestType.csv Where: Work Order number is the value entered in the work order number entry Serialnumber is the value entered in the serial number entry TestDate is the date when test was performed Test_Type is ID_ for initial drag tests, AC for activation tests and FD for final drag tests. Tests are saved as comma separated variable files and may be directly loaded into Excel or similar spreadsheet programs as desired. [6.3.9] Running Another Test CLICK on the Type of test to be performed. The results of the last test will be erased, and the graph will rescale for the test to be done. REPEAT the procedure from Step 7.3[6.3.2] to COMPLETE Running Another Test (i.e., the "As-Left"), as needed. [6.3.10] Testing Another Snubber SELECT a new snubber type, if necessary, from the snubber pull down list. If a snubber of the same type is to be tested, the user has to only change the serial number, hanger number, and work order entries. REPEAT this procedure from Step 7.3[6.3.1] to COMPLETE Testing Another Snubber.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 16 of 36 7.3 "As-Found" and "As-Left" Functional Test Using the STB 200 Test Bench (continued) NOTES

1) At this time the machine has completed Running the Test. Unless you are leaving the building, leave the machine running so it will NOT have to be warmed up to perform another test (i.e., the "As-Left" test) as needed.

2) Do NOT shutdown the console power without exiting Windows properly.

[6.4] Quitting and Shutting Down the System TURN OFF the 480Vac power on the HPU. On the computer screen, SELECT EXIT from the File Menu. When the Windows95 screen appears, CLICK on START, then SHUTDOWN, and CLICK on SHUT DOWN the Computer. Then CLICK OK. When the computer has completely shutdown, TURN OFF the main power switch on the current control consoles. [7] ENTER the information on Attachment 2 or Attachment 5. [8] DETERMINE if the "As-Found" test results meet the acceptable criteria in Section 6.0B. [9] IF a snubber is determined to be inoperable, THEN

               "    NOTIFY the Shift Manager or Unit Supervisor immediately.

• REQUEST a failure analysis using Attachment 3 and a supported component or system analysis on Attachment 4, as necessary.
• DETERMINE the subsequent test lot (sample plan), as required.
• SELECT the number of snubbers equal to 10 percent of the remaining snubbers in that subgroup.

               "    In general, SELECT the snubbers with the most time from the previous test.

• FILL OUT the applicable sections of Attachment 2 as required.
• ENSURE test data package is ready for Shift Manager/Unit Supervisor authorization.
• PERFORM applicable functional test for the subsequent test lot (sample plan).

7.4 Results Evaluation NOTE The following reviews are usually performed by the Snubber Engineer/SE-Designee, or a representative of Site Engineering Civil: [1] REVIEW all of the test data on Attachment 2 or 5, as applicable. [2] If any snubber is determined to have been inoperable:

               "     ENSURE the Shift Manager/Unit Supervisor has been notified of the inoperable snubber.
                "    ENSURE that a PER has been initiated in accordance with SPP-8.1 and SPP-3.1.

• INITIATE a Work Order (WO) to replace the snubber, if necessary.
• PERFORM a failure evaluation of any inoperable snubber(s) and DOCUMENT on Attachment 3.
• PERFORM the supported system or component evaluation on Attachment 4, if required.
• SELECT subsequent test lot(s), as required for functional test failure, or other snubbers for verification, as specified on Attachment 6.

7.5 Data Sheet Review [1] VERIFY all of the necessary attachments are included and all acceptance criteria have been met. [2] REVIEW the completed SI package for final acceptance. NOTE Computer generated data sheets containing information regarding the initial test lot, subsequent test lots, rebuild, etc., should be submitted with the SI data package. [3] SUBMIT the completed package for closure.

BFN Functional Testing of Mechanical 0-Sl-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 18 of 36 8.0 APPENDIXIATTACHMENTS Appendix A - Subgrouping of Mechanical Snubbers Appendix B - Daily Startup Procedures For The STB-200 Test Bench Appendix C - PSA Mechanical Snubber Rated Load Appendix D - Common Modes of Snubber Failure and Possible Causes Appendix E - Instructions For Exchanging the End Plug From Old to New Snubber Attachment 1 - Surveillance Instruction Review Form Attachment 2- Test Data for Removed and Reinstalled Snubber Using the STB-200 Test Bench Attachment 3 - Engineering Failure Analysis for Inoperable Snubbers Attachment 4 - Supported System/Component Analysis for Inoperable Snubber Attachment 5 - Test Data for New, Replacement, or Rebuilt Snubber Using STB-200 Test Bench Attachment 6 - Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 19 of 36 Appendix A (Page 1 of 2) Subgrouping of Mechanical Snubbers 1.0 SUBGROUPINGS For functional testing, mechanical snubbers are divided into four subgroups as described below: 1.1 Subgroups 3a and 3b These subgroups are based on design features and are composed of medium mechanical snubbers as designed and manufactured by Pacific Scientific Company. They range in capacity from 1500 pounds to 15,000 pounds and are designated as PSA-1, PSA-3, and PSA-10. The design features that set the PSA-1, PSA-3 and PSA-10 mechanical snubbers apart from the small and large mechanical snubbers are the use of a ball screw with a traveling nut that is prevented from rotating by keys traveling in slots. This arrangement is used to transform stroking motion of the snubber into rotation of the inertial mass. These snubbers are divided into subgroups 3a and 3b. Subgroup 3a NF design - These snubbers were designed and manufactured in accordance with subsection NF of Section III of the ASME Boiler and Pressure Vessel Code. Materials used for manufacture of the snubber components meet the subsection NF code requirements. Subgroup 3b Pre-NF design - These snubbers were designed and manufactured to good commercial practice, NOT to the subsection NF code requirements. Materials used for some of the snubber components do NOT meet the subsection NF code requirements. Previous functional testing shows that these snubbers have a higher than average failure rate. Ui

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 20 of 36 Appendix A (Page 2 of 2) Subgrouping of Mechanical Snubbers 1.2 Subgroup 4 This subgroup is based on the design features and is composed of Pacific Scientific Company small mechanical snubbers ranging in capacity from 350 pounds to 650 pounds and are designated as PSA-1/4 and PSA-1/2. The design features that set them apart from the other PSA mechanical snubbers are the use of a coarse lead screw and brass nut to transform stroking of the snubber into rotation of the inertial mass. The brass nut has two slots engaged with two small diameter steel rods that prevent rotation of the nut, but permit the nut to travel along the rods as the snubber is stroked. The rods can be bent during sudden overload of the snubber or by rotating the ends of the snubber during installation when the pins in the front end attachment or pipe clamp and the base plate clevis are NOT in proper alignment. 1.3 Subgroup 6 This subgroup is based on design features and is composed of large mechanical snubbers as designed and manufactured by Pacific Scientific Company. They range in capacity from 50,000 pounds to 120,000 pounds and are designated as PSA-35 and PSA-100. The PSA-35 and PSA-100 snubbers are equipped with planetary gearing which is NOT used in the other sizes. As stated above this arrangement is used to transform stroking motion of the snubber into rotation of the inertial mass. When snubbers are added, deleted, or changed, based on modifications, they are added or deleted from their appropriate subgroups. If the added snubbers do NOT fit an existing subgroup, a revision to this SI describing the new subgroup or a revision to an existing subgroup is required. Snubbers tested from severe service areas will remain a part of their respective design subgroup, unless a failure analysis is performed and a separate subgroup is justified and incorporated into this SI. Severe service areas include inside the drywell and in the main steam valve vault room. There have been minimal failures of snubbers in these locations, therefore, testing 10 percent of the snubbers in these areas each refueling outage satisfies the intent of the surveillance requirement.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 21 of 36 Appendix B (Page 1 of 3) Daily Startup Procedures for the STB-200 Test Bench 1.0 DAILY STARTUP PROCEDURE [1] WARM-UP Exercise both benches (i.e., small and large) by selecting the Manual Control Panel function from the Tool Menu. Clicking on "Auto Exercise" in the Operating Mode block will cause the selected bench to automatically stroke back and forth. The system should be run this way until the oil temperature is above approximately 70°F or smooth operation is attained. Both test benches should be exercised. To change from one bench to the other, CLICK on the bench label. [2] CHECK THE PRESSURE TRANSMITTER NOTE This instrument does NOT provide safety-related data. This check is optional. In the Manual Control Panel mode, SELECT Manual in the Operating Mode block. TURN the "HP Pump" on, Then USE the HP Pump slider to increase the pressure command setting until the "Pressure" reading is approximately 2000 psi. CHECK the 0-3000 psi gauge in the front of the HPU. The two readings should be within - 200 psi. [3] PARK THE RAM SELECT the "Park the Ram" to prepare the bench for the Daily Calibration Check. This should be done for both benches. [4] SHUT DOWN THE MANUAL CONTROL PANEL CLICK on "SHUT DOWN" to exit the Manual Control Panel.

BFN Functional Testing of Mechanical 0-Sl-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 22 of 36 Appendix B (Page 2 of 3) Daily Startup Procedures for the STB-200 Test Bench 2.0 STATUS CHECK [1] During the warm-up period, the frame drive cylinders should be stroked using the proportional valve and or the jog/drag valve. [2] The system should be checked for loose fittings, bolts, etc. [3] The filter indicators should be watched during cylinder stroking to insure that they are NOT illuminating. [4] Ifthe indicators are illuminating, the filters should be changed before continuing with operation of the machine or any testing. 3.0 DAILY CALIBRATION CHECKS The following calibration checks assure the functionality of the instrument and the Data Acquisition and Control System (DAS) for testing. They do NOT take the place of full system calibrations that must be performed on a periodic basis. The instrument system (DAS system and transmitters) should be powered up for 30 minutes before any checks or testing is performed. Prior to performing this function, both rams should have been "Parked' using the "Park the Ram" function in the Manual Control Panel. [1] SELECT THE DAILY CALIBRATION FUNCTION SELECT the Daily Calibration Check function from the "Tools' menu. [2] CONNECT THE LOW RANGE LOAD CELL AS DIRECTED If directed to by the software, ELECTRICALLY CONNECT the Low Range Load Cell as instructed. The load cell does NOT need to be mechanically mounted in the test bench, but it must be connected to its electrical cable. [3] STORE THE "ZERO" CALIBRATION READINGS For each instrument CLICK the "STORE"button in the "ZERO" column on the Daily Calibration screen for that instrument. The zero reading will be captured in the "Actual" "Zero" column. If it is within limits, the box will turn gray. If it is NOT within limits, the box will turn yellow.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 23 of 36 Appendix B (Page 3 of 3) Daily Startup Procedures for the STB-200 Test Bench 3.0 DAILY CALIBRATION CHECKS (continued) [4] STORE THE ."SPAN" CALIBRATION READINGS For each instrument, PRESS in the "CAL" button on the front of the instrument, then CLICK the "STORE" button in the "SPAN" column on the Daily Calibration screen for that instrument. The span reading will be captured in the "ACTUAL" "SPAN" column. If it is within limits, the box will turn gray. If it is NOT within limits, the box will turn yellow. [5] PRINT THE REPORT When all readings for both benches have been stored, CLICK on the "PRINT" button to print the Daily Calibration Report. If the report is "SATISFACTORY", CONTINUE the testing. If the report is "UNSATISFACTORY", HALT and CORRECT the problem before continuing.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 24 of 36 Appendix C (Page 1 of 1) PSA Mechanical Snubber Rated Load NOTE (NF) identifies the later model PSA mechanical snubbers that were designed to ASME, B&PV Code, Section III, Subsection NF. Model Rated Load (lbs.) Stroke Length (in.) PSA-1/4 (NF). 350 4 PSA-1/2 (NF) 650 2-1/2 PSA-1 (NF) 1500 4 PSA-3 (NF) 6000 5 PSA-10 (NF) 15000 6 PSA-10 (PRE-NF) 10000 6 PSA-35 (NF) 50000 6 PSA-100 (NF) 120000 6

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 25 of 36 Appendix D (Page 1 of 1) Common Modes of Snubber Failure and Possible Causes TYPE COMMON MODES OF FAILURE POSSIBLE CAUSES Mechanical Locked in place Damaged Thrust Bearing Bent Lead Screw Bent Guides Internal Parts Damaged Due To Wear In Service High Drag Internal Parts Damaged Due To Wear In Service Improper Internal Lubrication Does NOT Activate Broken Capstan Spring Internal Parts Damaged Due To Wear In Service Damage to Snubber Hardware Improper Reassembly Improper Installation Improper Handling or Abuse Misapplication Overload Vibration or Wear

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 26 of 36 Appendix E (Page 1 of 1) Instructions for Exchanging the End Plug from Old to New Snubber These instructions are to be followed at any time the end plug is required to be removed from one snubber and placed on a different snubber. This will most likely take place when a PRE-NF (white) PSA-10 snubber is replaced with a new NF PSA-10 snubber. All of these snubbers are found on the MSRV Tailpipes in the Units 2 and 3 drywells. When one of these snubbers fails it is to be replaced with a new PSA-10 snubber and the end plug and rear bracket are required to be transferred to the new snubber. This is required because the pin size of the existing snubber is 7/8 inch and the new snubber is 1 inch diameter. The following instructions are to be followed when exchanging the end plug. A. REMOVE the filister head screws and flat washers to free the position indicator tube from the end plug assembly of the old and the new snubber. B. If the screws are distorted or damaged DISCARD and REPLACE. C. REMOVE the position indicator tube. D. PLACE the snubber on a work bench or stand. E. Using an appropriate Allen Wrench, REMOVE the set screws from the end plug assembly. F. Ifthe screws are distorted or damaged DISCARD and REPLACE. G. After removing the set screws, USE a size No. 30 drill for a PSA-1 and size No. 23 for a PSA-10, to remove the distorted threads of the telescoping cylinder caused by the set screws. H. DRILL only to the depth necessary to remove the distortions so the end plug assembly can rotate freely. I. USE eye protection, and REMOVE any loose drill shavings with clean compressed air. J. REMOVE the end plugs from the snubbers and exchange them as required. K. INSTALL the set screws and TIGHTEN to distort the threads on the telescoping cylinder. L. REINSTALL the position indicator tube over the end plug assembly and REINSTALL the filister head screws.

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 27 of 36 Attachment 1 (Page 1 of 1) Surveillance Instruction Review Form REASON FOR TEST: o Scheduled Surveillance o System Inoperable (Explain in Remarks) UNIT MODE O Maintenance (WO No. [o Other (Explain in Remarks) W.O. SNUBBER SERIAL NO. UNID NO. PRE-TEST REMARKS: PERFORMED BY: Initials Name (Print) Name (Signature) NOTE: The following entries for contacting Shift Manager/Unit Supervisor shall be marked N/A if the snubber is NOT Inoperable. NOTIFY Shift Manager/Unit Supervisor when snubber found Inoperable. SM/UNIT SUPERVISOR CONTACTED Date Time NOTIFY Shift Manager/Unit Supervisor when snubber Operability is restored. SM/UNIT SUPERVISOR CONTACTED Date Time MECHANICAL MAINTENANCE REVIEWER Date Signature attests that I understand the scope and purpose of this instruction and that, to the best of my knowledge, it was properly performed in accordance with instruction in that: the recording, reduction, and evaluation of data is complete and correct; acceptance criteria is met or justification for exceptions is provided; portions of test performed were appropriate for specified test conditions or reasons for test; deficiencies were evaluated and dispositioned; reportability was evaluated; marginal results were evaluated with respect to potential for future problems based on operating experience and regulatory requirements; and instruction was complete except as noted in post-test remarks. SNUBBER ENGINEER/SITE Date ENGINEERING CIVIL REVIEWER SCHEDULING COORDINATOR Date POST-TEST REMARKS:

Attachment 2 (Page 1 of 3) Test Data for Removed and Reinstalled Snubber Using the STB-200 Test Bench WO No. Unit Snubber UNID No. System No. Serial No. Subgroup Initial Test Lot Subsequent Exam No. Size Rated Load Pipe Size Design drawing number Shift Manager/Unit Supervisor and Snubber Engineer notified prior to removal of snubber for functional testing. Foreman/Designee Date Time As-Found Stroke Setting Required Stroke Setting (from Design drawing) Pipe Temp.: IF, If other than ambient (per 0-47B435-5F, Note 24), notify Snubber Engineer/Site Engineering Civil. Pyrometer No.: Calibration Due Date: The As-Found Stroke Setting is within the acceptable limits shown in the design drawing listed above. Yes No (AC) Performer Signature Date All fasteners for the As-Found snubber(s) are secured and acceptable (i.e., no loose or missing fasteners on the component or anchorage). If the answer is "No", complete Attachment 6. Yes No (AC) Performer Signature Date

Attachment 2 (Page 2 of 3) Test Data for Removed and Reinstalled Snubber Using the STB-200 Test Bench WO No. Unit Snubber UNID No. System No. Snubber Test Data: Record maximum acceptable drag force from Table 6.2-1 Lbs. As-Found Final Test Results: Peak Final Drag Forces (lbs.): Tension Compression The As-Found final drag force in tension and compression meets acceptance criteria based on the allowable load from Table 6.2-1. Yes No (AC) Performer Signature Date Activation takes place in both tension and compression and is less than or equal 0.02 g's. Yes No (AC) Performer Signature Date Snubber Stroked Full Length Yes No (If No, explain in remarks) Maintenance reviewer has reviewed the test data to determine whether the snubber meets all of the functional test acceptance criteria. Maintenance reviewer may be the performer of the test or an independent reviewer. Acceptance criteria satisfied Yes No Maintenance Reviewer Date The Snubber Engineer/SE Designee has performed a second party review of the test data to verify that the snubber meets all of the functional test acceptance criteria. If the response is No (the snubber has NOT satisfied the acceptance criteria), specify in remarks actions to be taken: Acceptance criteria satisfied Yes No Remarks: SITE ENGINEERING (SNUBBER ENGINEER/SE DESIGNEE) REVIEW DATE

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 30 of 36 Attachment 2 (Page 3 of 3) Test Data for Removed and Reinstalled Snubber Using the STB-200 Test Bench WO No. Unit Snubber UNID No. System No. Snubber reinstallation: Same snubber reinstalled Yes No N/A If No, enter serial number (N/A if same snubber is reinstalled) and include Attachment 6 Serial Number Snubber is reinstalled in proper location Yes No N/A Snubber is reinstalled with base of housing up (for vertical snubbers) Yes No N/A All locking devices are secured Yes No N/A Cotter pins are spread Yes No N/A Spherical bearing greased Yes No N/A Gaps between spacers and spherical bearing are 1/16 inch each side, 1/8 inch total or less Yes No N/A Snubber is tagged Yes No N/A Bolts and jam nuts torqued Yes No N/A Anti-seize compound applied, as needed Yes No N/A Torque Wrench No. Calibration Due Date As-Left Stroke Setting Performer Signature Date The As-Left Stroke Setting is within the acceptable limits shown in the Design Drawing as verified. Yes No Performer Signature r)ate SHIFT MANAGER/UNIT SUPERVISOR notified of operable and reinstalled snubber. Foreman/Designee Date Remarks:

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 31 of 36 Attachment 3 (Page 1 of 2) Engineering Failure Analysis for Inoperable Snubbers WO No. Unit Snubber UNID No. Subgrouip No. PER No. Mfg./Size Serial No. Rated Load Exam No. Lot

1. Describe the mode of failure(s), as discussed on Appendix D.

o Locked up 0 High Drag Force 0 Snubber would NOT activate O Damage to snubber hardware 0 Other Explain (if necessary)

2. Describe the conditions of the failure:

3. Determine the cause of failure, using Appendix D for the possible causes (disassembly of the snubber may be necessary):

4. For a snubber that does NOT activate or meet the activation acceptance criteria, release, is locked up, or damaged hardware, was the cause of the failure a design or manufacturing defect?

[]Yes 0 No Explain Evaluation:

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 32 of 36 Attachment 3 (Page 2 of 2) Engineering Failure Analysis for Inoperable Snubbers WO No. Unit Snubber UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No. Lot

5. Snubber Failure classified as: 0 Location 0 Manufacturing 0 Design OUnknown 0 Other Describe basis for the classification:

6. Does the vendor need to be contacted? 0 Yes 0 No Vendor Name:

Person contacted: Date: Vendor's comments:

7. What subsequent testing is required because of this failure?

Subsequent Lot No. No. of snubbers to be tested

8. What corrective action and recurrence controls are to be taken?

Evaluation performed by: Snubber Engineer/SE Designee Date

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 33 of 36 Attachment 4 (Page 1 of 1) Supported System/Component Analysis for Inoperable Snubber WO No. Unit Snubber UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No.

1. Describe the condition(s) (e.g., snubber would not meet activation acceptance criteria, was locked up, had excessive drag force, damaged hardware etc.)

2. Attach the SE Evaluation of the attached component:

3. Based on the results of the Engineering Evaluation, has the snubber failure mode adversely affected the supported system or component?

0 Yes 11 No Snubber Engineer/SE Designee Date

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 34 of 36 Attachment 5 (Page 1 of 1) Test Data for New, Replacement, or Rebuilt Snubber Using the STB-200 Test Bench NOTE This Data Sheet is to be used only to document test bench functional test data of new, replacement or rebuilt snubbers and shall be attached to the Work Order, as appropriate. WO No. Unit Snubber UNID No. Serial No. Size Rated Load Exam No. Snubber Test Data: Record maximum acceptable drag force based on Lbs. Section 6.0B.2 As-Left Test results: Peak Final Drag Forces(lbs): Tension Compression The As-Left drag force of the snubber is within the allowable load based on Section 6.0B.2 Yes No (AC) Performer Signature Date Activation takes place in both tension and compression and is less than or equal 0.02 g's. Yes No (AC) Performer Signature Date Snubber Stroked Full Length Yes No Snubber meets acceptance criteria Yes No Performer Signature Date Review test data for acceptability. If the test results are unacceptable, do not install snubber in any piping system, component, or feature in the plant. Snubber Engineer/SE Designee Date

BFN Functional Testing of Mechanical 0-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 35 of 36 Attachment 6 (Page 1 of 2) Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range This evaluation shall be performed when fasteners, used for attachment of snubber to component, and to snubber anchorage, are discovered loose or missing prior to the As-Found functional testing. This evaluation also shall be performed if the snubber "As-Found" setting is outside of the acceptable range specified on the design drawing. WO No. Unit Date Discovered Snubber UNID No. Serial No. Subgroup Exam No. Size Rated Load Lbs.

1. Describe the discovered condition and, if possible, determine cause:

Performer Initials Date

BFN Functional Testing of Mechanical O-SI-4.6.H-2A Unit 0 Snubbers Rev. 0008 Page 36 of 36 Attachment 6 (Page 2 of 2) Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range Items 2, 3, and 4 are to be completed by Site Engineering Civil.

2. Evaluate to determine whether the cause may be localized or generic. Use this evaluation to select and list other suspect snubbers for verification, as applicable.:

3. Describe the corrective action(s) and provide the As-Found test result.

4.

Conclusion:

Is the snubber operable? YES NO Justification: If "No", notify the.Shift Manager or Unit Supervisor immediately. Then complete or request a failure analysis using Attachment 3, and a supported component or system analysis on Attachment 4, as necessary. Evaluated by: Site Engineering Civil Date

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Attachment F BFN Surveillance Instruction, O-SI-4.6.H-2B, Functional Testing of Bergen-Patterson, Anchor/Darling or Fronek Hydraulic Snubbers

Browns Ferry Nuclear Plant Unit 0 Surveillance Instruction 0-SI-4.6.H-2B Functional Testing of Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubbers Revision 0008 Quality Related Level of Use: Continuous Use Effective Date: 03-08-2007 Responsible Organization: DEC, Design Eng Civil Prepared By: Stephen Samaras Approved By: Eric Frevold

BFN Functional Testing of Bergen-Paterson, 0 -SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 2 of 48 Current Revision Description Pages Affected: Cover sheet, revision log and 28 Type of Change: REVISION Tracking Number: 009 This procedure is being revised to clarify the Subgroup 1 criteria.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 3 of 48 Table of Contents

1.0 INTRODUCTION

...................................................................................................                       5 1.1     P u rp o se ........................................................................................................................ 5 1.2     Sc o p e ............................................................................................................................ 5 1.3     Frequency/C onditions ...............................................................................................                  6

2.0 REFERENCES

......................................................................................................                      7 3.0     PRECAUTIONS AND LIMITATIONS .......................................................................                                    8 4.0     PREREQUISITES ......................................................................................................                   8 5.0     SPECIAL TOOLS AND EQUIPMENT RECOMMENDED .......................................                                                        8 6.0     ACCEPTANCE CRITERIA .......................................................................................                            8 7.0     PROCEDURE STEPS .............................................................................................                         10 7.1     Training and Qualification of Performers .................................................................                            10 7.2     Preparation of Test Data Package .......................... *...............................................                          10 7.3     "As-Found" Functional Test Using the STB-200 Test Bench ................................... 11 7.4     "As-Left" Functional Test Using the STB-200 Test Bench ....................................... 17 7.5     Hydraulic Snubber Service Life Monitoring ............................................................ 21 7.6     R esults E valuation ...................................................................................................              22 7.7     D ata S heet R eview .................................................................................................                22 8.0     ILLUSTRATIONS/ATTACHMENTS .......................................................................                                     23 Illustration 1:        Piston Rod Position Measurement .......................................................                                24 Appendix A:            Snubber Flow Path, Control Valve Assembly, and Poppet S izes .......................................................................................................         25 Appendix B:            Subgrouping of Snubbers ...................................................................                            28 Appendix C:            Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubber Acceptance Criteria ...............................................................                            29 Appendix D:            Correction for Temperature .................................................................                           32 Appendix E:            Daily Startup Procedure for the STB-200 Test Bench ....................... 33 Appendix F:            Common Modes of Snubber Failure and Possible Causes ............... 36

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 4 of 48 Table of Contents (continued) Appendix G: Service Life Monitoring for Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubbers ................ 37 : Surveillance Instruction Review Form ............................................... 38 : As Found and As Left Test Data, Removal and Reinstallation Data Sheets for Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubbers .................................. 39 : Engineering Failure Analysis for Inoperable Snubber ...................... 43 : Supported System/Component Analysis for Inoperable S n ubber .................................................................................................... 45 : Case Specific Acceptance Criteria ...................................................... 46 : Evaluation of Loose or Missing Attachment Fasteners or of "As-Found" Stroke Setting Outside of Acceptable Range ................................................................................ 47

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 5 of 48

1.0 INTRODUCTION

1.1 Purpose This Surveillance Instruction implements Technical Requirements Manual (TRM) TR 3.7.4, and provides direction for the functional testing of Bergen-Paterson, Anchor/Darling, or Fronek hydraulic snubbers, as given in the Snubber Program Procedure (0-TI-398), on all safety related systems, inside and outside of the drywell. 1.2 Scope The snubbers within the scope of this instruction are either accessible (outside of the Drywell) or inaccessible (inside the Drywell) during reactor operation. The Bergen-Paterson, Anchor/Darling, or Fronek hydraulic snubbers belong to Subgroup 1. The portions of Technical Requirements TR 3.7.4 pertaining to visual examination of snubbers are implemented by Surveillance Instructions 1-SI-4.6.H-1, 2-SI-4.6.H-1, and 3-SI-4.6.H-1. This Surveillance Instruction (SI) provides the requirements and guidance to perform functional testing of Bergen-Paterson, Anchor/Darling or Fronek hydraulic snubbers addressed as HSSA-3, -10, -20, -30, ADH-1 0, -20, -30, -50, -70 and -130 for Units 1, 2, and 3 as follows:

• Removal and reinstallation of Bergen-Paterson, Anchor/Darling or Fronek hydraulic snubbers to facilitate testing is accomplished in accordance with MPI-0-000-SNBOO4 and recorded in Attachment 2.
• Provides the requirements for functional testing and service life monitoring of Bergen-Paterson, Anchor/Darling or Fronek hydraulic snubbers. This instruction covers subgroup 1 (see Appendix B for snubber subgroup information). To completely fulfill the snubber Technical Requirements Manual (TRM) functional testing requirements, Surveillance Instructions 0-SI-4.6.H-2A, 0-SI-4.6.H-2C, 0-SI-4.6.H-2D, and 0-SI-4.6.H-2E must also be performed as required per TSR 3.7.4.2.
• Provides a means for the control and documentation of all snubber surveillance activities provided in this Surveillance Instruction.

     "    This Surveillance Instruction shall be used to verify operability of hydraulic snubbers suspected inoperable during performance of the visual examination SI's.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008

                            .Hydraulic Snubbers               Page 6 of 48 1.3   Frequency/Conditions A. This Surveillance Instruction shall be performed each refueling outage and portions of it may be performed to establish operability in accordance with 1-SI-4.6.H-1, 2-SI-4.6.H-1, and 3-SI-4.6.H-1, Visual Examination of Hydraulic and Mechanical Snubbers.

B. This instruction may be performed at any time for snubbers outside the drywell, but may only be performed at a time when the drywell may be entered for snubbers inside the drywell. C. All safety related snubbers shall be operable during all modes of operation as described in the Technical Requirements Manual TR 3.7.4, if the system is required to be operable during that mode. D. Snubbers located inside the drywell on reactor vessel attached piping shall be OPERABLE whenever fuel is in the reactor vessel. Snubbers on the Main Steam, HPCI, and RCIC piping in the drywell are exempt from the operability requirement when the steam line plugs are installed in the reactor vessel. E. Snubbers on safety related systems that have experienced unexpected potentially damaging transients shall be evaluated for the possibility of concealed damage and functionally tested, if applicable. F. A snubber removed from an operable safety related system must be reinstalled or replaced within 72 hours of its removal or declare the supported component or system inoperable and follow the appropriate action statement for that system. G. For an inoperable snubber(s), within 72 hours, replace or restore inoperable snubbers to an operable status and perform an engineering evaluation on the supported component or system, if the snubber does NOT meet the functional test acceptance criteria of TSR 3.7.4.2. Otherwise, declare the system inoperable and follow the required actions specified in the TRM. The engineering evaluation is to determine if the component or system restrained by the snubber(s) was adversely affected by inoperability of the snubber(s) during the previous operating cycle and ensure that the restrained component or system remains capable of meeting its design function. The engineering evaluation(s) for supported component or system analysis are to be recorded on Attachment 4. H. Alternately, for a snubber removed and NOT replaced within 72 hours, or an inoperable snubber NOT replaced or restored within 72 hours, operability of the supported system may be verified based on an engineering evaluation of the system functional capability with the removed or inoperable snubber.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 7 of 48 1.3 Frequency/Conditions (continued) I. Snubbers removed for maintenance or determined to be inoperable on a non-operable safety related system must be reinstalled or replaced, in accordance with MPI-0-000-SNBOO4, and tested in accordance with this instruction prior to declaring the system operable. J. For all subgroups, when subsequent testing is required, it shall continue within the respective subgroup until no failure is found. K. New, replaced or rebuilt snubber(s) shall meet the functional test acceptance criteria before their installation in the unit and must have been functionally tested "Satisfactory", within 12 months prior to their installation.

2.0 REFERENCES

A. Technical Requirements Manual, TR 3.7.4, Snubbers. B. 1-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers. C. 2-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers. D. 3-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers. E. MPI-0-000-SNBOO2, Hydraulic Shock and Sway Arrestor Bergen-Paterson, Anchor/Darling and Fronek Unit Disassembly and Reassembly F. MPI-O-OO-SNBOO4, Instructions for Removing and Installing Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers. G. BFN-VTM-B209-0230, Vendor Technical Manual for Bergen-Paterson Hydraulic Shock and Sway Arrestors. H. 0-TI-398, Snubber Program Procedure I. SPP-3.1, Corrective Action Program J. SPP-8.1, Conduct of Testing. K. CDQO-999-2002-0772, Evaluation for Seal Service Life Extension for Bergen Paterson, Anchor/Darling or Fronek Hydraulic Snubbers.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 8 of 48 3.0 PRECAUTIONS AND LIMITATIONS None 4.0 PREREQUISITES A. Six months prior to each refueling outage, the supply of Bergen-Paterson, Anchor/Darling or Fronek hydraulic snubbers in the Snubber Rebuild Facility shall be reviewed. A number of snubbers equal to the 10% sample population for the Subgroup selected for functional testing during the upcoming refueling shall be identified and available for installation. The rebuilt snubbers shall have the proper paperwork with them to comply with the requirements of the Section XI Repair and Replacement Program. This paperwork should include the purchase contract and Certificate of Compliance for any material requiring traceability. 5.0 SPECIAL TOOLS AND EQUIPMENT RECOMMENDED None 6.0 ACCEPTANCE CRITERIA A. Responses which fail to meet the following "As-Found" functional test acceptance criteria require immediate notification of the Shift Manager or Unit Supervisor at the time of failure. B. The snubber functional test shall verify that: NOTE Activation, bleed, or drag force acceptance criteria may be other than that described in the Steps below, if approved by Site Engineering on Attachment 5.

1. "As-Found"

a. Corrected activation occurs in both directions of travel at a piston velocity greater than or equal 1 inch/minute and less than or equal 30 inches/minute.

b. Bleed takes place after activation of the snubber in both the tension and compression directions.

c. Drag forces do NOT exceed 2.0 percent of the snubber's rated load.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 9 of 48 6.0 ACCEPTANCE CRITERIA (continued)

2. "As-Left"

a. Corrected activation occurs in both directions of travel at a piston velocity greater than or equal 5 inches/minute and less than or equal 20 inches/minute.

b. Corrected bleed takes place after activation of the snubber in both tension and compression and shall be within the ranges shown in Appendix C for each size of snubber.

c. Drag forces do NOT exceed 2.0 percent of the snubber's rated load.

C. The stroke setting shall be within the limits shown on the design drawing. Otherwise, complete Attachment 6. D. There shall be no loose or missing fasteners for attachment of the As-Found Bergen-Paterson, Anchor/Darling or Fronek hydraulic snubber(s) to the component or the anchorage. Otherwise, complete Attachment 6. E. NOT meeting acceptance criteria for stroke setting, or loose or missing fasteners, does NOT require testing an additional lot equal to 10% of the subgroup of snubbers. Evaluation of snubber operability, corrective actions, and selection of other suspect snubbers for verification shall be as specified on Attachment 3 or Attachment 6, as applicable.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 10 of 48 7.0 PROCEDURE STEPS 7.1 Training and Qualification of Performers [1] A thorough briefing should be conducted on SI performance prior to starting. [2] The cognizant individual or Snubber Engineer responsible for the performance of the Surveillance Instruction must be qualified as a test director. [3] Appropriate General Employee Training (GET) (including respirator training) should be completed by test personnel prior to performing this SI. [4] Training required for the testing of hydraulic snubbers shall meet the requirements of Task Number MMY 510. 7.2 Preparation of Test Data Package [1] EXCLUDE the snubbers from the initial test lot (sample plan) which are scheduled for deletion, in accordance with approved Design Change Notices. [2] EXCLUDE the snubbers until the next outage from the initial test lot (sample plan) which are to be added, in accordance with approved Design Change Notices. [3] SELECT snubbers for retest which were placed in the same location as snubbers which failed during the previous outage, if the failure analysis showed that the failure was due to the location. However, these snubbers shall be tested in addition to the initial 10 percent test lot (sample plan). [4] DETERMINE the initial test lot (sample plan) as follows:

• SELECT 10 percent of the snubbers from subgroup 1 (SEE Appendix B).

In general, SELECT the snubbers with the most time from the previous test. Sample should be weighed to include more snubbers from severe service areas (i.e. inside the drywell).

• SELECT snubbers that have experienced severe transients.
• SELECT snubbers of various sizes.

[5] REVIEW the applicable hanger drawings to verify the location and any conditions that will require special preparation or equipment.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 11 of 48 7.2 Preparation of Test Data Package (continued) [6] REQUEST scaffold or similar devices to be built or available, as necessary. [7] RECORD the date, time and other required information on Attachment 1, and prior to REMOVAL of a snubber per MPI-0-000-SNBOO4 for functional test, RECORD the "As-Found" Stroke Setting in Attachment 2. 7.3 "As-Found" Functional Test Using the STB-200 Test Bench [1] IF the extension or one of the end attachments has been removed, THEN INSTALL the appropriate end attachments located in the snubber test facility. [2] ENSURE the test bench has been warmed up in accordance with Appendix D of this procedure. NOTE The following describes a suggested procedure for "Testing a Snubber" using the STB 200 Snubber Test Bench with the upgraded Windows Software Operations Manual. [3] Powering Up The Test System TURN ON the master power switch on the control console. Make sure that the computer, monitor, and printer are turned on. TURN ON the main breaker on the Hydraulic Power Unit (HPU) located at the end of the power unit. ENSURE that all emergency stop buttons are pulled out. [4] Starting The Software Once the computer has "Booted Up", the Windows Desktop will be displayed. SELECT the "STB 200" icon and double click on it, this will Start the Test program. The "LOG ON" prompt window will appear. ENTER your user name and password in either upper or lower case letters. All functions required by the system are available in the screen, or from one of the Pull Down Menus at the top of the screen. [5] Daily Calibration Check PERFORM the Daily Calibration Check using Appendix D and sign the daily calibration form. After Daily Calibration Check has been completed, and the Daily Calibration Report is "Satisfactory", proceed on testing a snubber. [6] A surface contact pyrometer may be used to OBTAIN the surface temperature of the snubber, and RECORD the temperature correction from Appendix D for the surface temperature obtained, on Attachment 2 as appropriate.

BFN Functional Testing of Bergen-Paterson, O-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 12 of 48 7.3 "As-Found" Functional Test Using the STB-200 Test Bench (continued) [7] Testing a Snubber [7.1] Pick the Snubber Type Using the Snubber Pull Down List in the User Supplied Information block, SELECT the Type Snubber to be tested. [7.2] Enter the Header Information FILL in the other information as indicated in the User Supplied Information block. [7.3] Running the Test [7.3.1] Pick the Test CLICK on the Type of Test (i.e., "As-Found" or "As-Left") desired. [7.3.2] Start the Test CLICK on the Start Test button. Ifthis is the first test performed on the snubber, the following two windows will appear: [7.3.3] Tare weight Window This window allows the User to "zero out" any offset load that the load cell may be reading. This should be performed BEFORE installing the snubber in the test bench. WAIT for the "Raw Reading" to settle (as far as possible), and then CLICK "Adjust Load Cell". The "Adjustment" will be updated, and the "Adjusted Reading" should now read close to zero (0) lb. The "Adjust Load Cell" button may be Clicked again if a new adjustment value is desired. Once the readings are as desired, CLICK the "Continue" button. ENSURE the correct load cell is connected to the machine. CHOOSE the proper bushings and pins for the snubber being tested, then INSTALL the bushings in both clevis attachments on the machine.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 13 of 48 7.3 "As-Found" Functional Test Using the STB-200 Test Bench (continued) [7.3.4] Stroke and Position Window INSTALL the snubber in the test bench, with the piston or operable end toward the drive piston of the machine if possible. ADJUST the backstop and/or use the Jog Speed Slider to adjust the bench and the driver. cylinder to the desired pin to pin dimension. The jog slider adjusts the jog speed. The joystick on the test frame controls the actual motion of the driver. INSTALL the pins through the bushing and the snubber spherical bearings. ONCE the snubber has been pinned for a test, the snubber's piston position (distance from fully retracted position) should be accurately measured (within 0.1 inch) and entered in the SNUBBER EXTENSION window. If the test program calculates that it cannot fully extend or fully retract the snubber during drag testing, one or more of the text windows on the screen will be highlighted in red. If this happens, the backstop will have to be adjusted and the snubber extension recalculated. The program calculates whether it can fully test the snubber through its stroke range. It will display the two ends of stroke (minus a 1/2 inch safety zones), the calculated center position and the bottomed out position for the snubber. Once the data has been successfully entered, TIGHTEN the lock nuts on the load cell threaded rod snug tight to prevent slippage during the test. ENTER the snubber UNID number, WO number, system number, serial number, and the test equipment information on Attachment 2 as required, and CLICK on "Continue with Test" to continue the test. [7.3.5] If an Activation Test is Selected After all the above steps have been completed, and PRIOR to starting an "As-Found" Activation Test, the test program will initiate a routine to set and stabilize the hydraulic system pressure at a calculated level sufficient to achieve the requested test load. During this period, the setpoint and actual pressures are displayed, along with the output voltage, and a "count down" value. When the pressure is near the desired value, the countdown value will decrement towards zero. If the pressure fluctuates out of limits, the countdown will reset to six. Once the pressure is stable enough to let the countdown complete, the test will begin automatically.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 14 of 48 7.3 "As-Found" Functional Test Using the STB-200 Test Bench (continued) OBSERVE that the snubber activates in both directions, to establish operability of the snubber in the "As-Found" condition. RECORD all necessary information on Attachment 2, as appropriate. NOTE Forcing a test may allow the machine to overstress the snubber during the test! If the user wishes to force a test, clicking the "Force the Test" button will initiate the test regardless of pressure. Clicking the "Abort the Test" button will cause the test cycle to abort without performing the test. [7.3.6] If Drag Test is Selected If a Drag Test (i.e., ID, AC, and FD test sequence for "As-Left", and AC, FD test sequence for "As-Found" test) is selected, the test system will automatically begin the drag test. The system will determine the starting position of the snubber, and choose the initial test direction to move towards the farthest end of stroke. The drag speed will be automatically controlled to the target speed set earlier. This test is to VERIFY free travel of the piston rod through its full stroke. The Raw Test Data graphed inreal time is reviewed to: VERIFY that the drag force of the snubber does NOT exceed 2% of the rated load. RECORD this information on Attachment 2, as appropriate. [7.3.7] Printing the Results After the test is complete, the calculations appropriate to that test are performed and the results are displayed on the screen. This allows the user to review and determine if the "As-Found" test results meet the "As-Left" acceptance criteria, and plot the test results: IF the results are within the "As-Left" acceptance range, THEN CLICK on the "Print Test" button to open the standard Windows printer dialog box. SELECT the proper printer, and CLICK "OK" to start the printing.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 15 of 48 7.3 "As-Found" Functional Test Using the STB-200 Test Bench (continued) ATTACH the Printed Results in Attachment 2, as part of the work package. For Activation tests on acceleration limiting snubbers only, the calculated acceleration lines will be printed if they are displayed on the graph when printing is requested. [7.3.8] Saving the Test Results To save a test file to disk, CLICK the "Save Test" button. This saves the test results in the "testdata"directory. The file name of the saved test result is as follows: WorkOrdernumber Serialnumber TestDate TestType.csv Where: Work Order number is the value entered in the work order number entry Serialnumber is the value entered in the serial number entry TestDate is the date when test was performed Test_Type is ID for initial drag tests, AC for activation tests and FD for final drag tests. Tests are saved as comma separated variable files and may be directly loaded into Excel or similar spreadsheet programs as desired. [7.3.9] Running Another Test CLICK on the Type of test to be performed. The results of the last test will be erased, and the graph will rescale for the test to be done. REPEAT the procedure from Step 7.3[7.3.2]. to complete Running Another Test (i.e., the "As-Left"), as needed. [7.3.10] Testing Another Snubber SELECT a new snubber type, if necessary, from the snubber pull down list. If a snubber of the same type is to be tested, the user has to only change the serial number, hanger number, and work order entries. REPEAT this procedure from Step 7.3[7.3.1]. to COMPLETE Testing Another Snubber.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 16 of 48 7.3 "As-Found" Functional Test Using the STB-200 Test Bench (continued) NOTE Do NOT shutdown the console power without exiting Windows properly. [7.4] Quitting and Shutting Down the System TURN OFF the 480Vac power on the HPU. On the computer screen, SELECT EXIT from the File Menu. When the Windows screen appears, CLICK on START, then SHUTDOWN, and CLICK on SHUT DOWN the Computer. Then CLICK OK. When the computer has completely shutdown, TURN OFF the main power switch on the current control consoles. NOTE At this time the machine has completed Running the Test. Unless you are leaving the building, leave the machine running so it will NOT have to be warmed up to perform another test (i.e., the "As-Left" test) as needed. [8] DETERMINE if the "As-Found" test results meet the acceptance criteria in Section 6.0B.1. [9] ENTER the information on Attachment 2, as appropriate. [10] IF the test results are within the acceptable range of Section 6.0B1, THEN COMPARE the "As-Found" test results with the "As-Left" acceptance criteria in Section 6.0B.2. [11] IF the test results are within the "As-Left" acceptance criteria, THEN PREPARE the snubber for reinstallation. IF NOT, THEN PERFORM the "As-Left" testing in accordance with Section 7.4, as necessary, to obtain the acceptable "As-Left" range.

7.3 E3FN U'nit 0 Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Anchor/Darling or Fronek Hydraulic Snubbers "As-Found" Functional Test Using the STB-200 Test Bench Rev. 0008 Page 17 of 48 I (continued) [12] IF a snubber is determined to be inoperable, including case specific criteria, THEN

• NOTIFY the Shift Manager or Unit Supervisor immediately.
• REQUEST a failure analysis using Attachment 3, and a supported component or system analysis on Attachment 4, as necessary.
• DETERMINE the subsequent test lot (sample plan), as required.

SELECT the number of snubbers equal to 10 percent of the remaining snubbers in that subgroup.

• In general, SELECT the snubbers with the most time from the previous test.
• FILL OUT the applicable sections of Attachment 2, as required.
• ENSURE test data package is ready for Shift Manager/Unit Supervisor authorization.
• PERFORM applicable functional test for the subsequent test lot (sample plan).

7.4 "As-Left" Functional Test Using the STB-200 Test Bench [1] DETERMINE if the "As-Left" testing is required based on the following:

• IF the snubber has been rebuilt, THEN PERFORM the "As-Left" testing in accordance with this Section.
• IF the results of Step 7.3[10] DO NOT meet the acceptance criteria in Section 6.OB.2, THEN MAKE adjustments and PERFORM the "As-Left" test.

[2] If the test machine has been left on, it will be ready to Run Another Test. CLICK on the type of test (i.e., "As-Left") to be performed. The results of the last test will be erased, and the graph will rescale for the "As-Left" test to be done. REPEAT "Running the Test" procedure for the "As-Left" test starting from Step 7.3[7.3.2].

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 18 of 48 7.4 "As-Left" Functional Test Using the STB-200 Test Bench (continued) [3] If the machine has been turned off, THEN REPEAT the daily startup procedure, Appendix E and Steps 7.3[l] thru 7.3[7.2]. [4] ENTER the snubber number, WO number, system number, serial number and test equipment information on Attachment 2, as appropriate. [5] MEASURE the snubber surface temperature with a pyrometer, and RECORD the temperature correction from Appendix D for the measured surface temperature reading on Attachment 2, as appropriate. [6] REPEAT Steps 7.3[7.3] through 7.3[7.4] to complete the "As-Left" test. NOTE that the "As-Left" test sequence may start with the Initial Drag (ID) test, then the Activation (AC) test, and the Final Drag (FD) test. The "As-Found" test sequence may start with the Activation (AC) test, and then the Final Drag (FD) test. [7] As shown in Appendix A, Illustrations A-1 and A-2, fluid from the rod end (extension or "out" direction) activates the poppet in the connector tube end of the valve block. Fluid from the blind end (compression or "in" direction) activates the poppet under the poppet stop and plug. [8] If the snubber locks up at too low of a velocity, the width between the flats on the poppet head is too great, causing too much resistance to flow and the poppet closes at a low flow rate. [9] REPLACE the poppet with one which has a smaller distance between the flats Appendix A, Table A-1. NOTE A change of approximately 0.006 inches (0.003 inches each side) in the distance between the flats will change the lock-up velocity approximately one inch per minute. [10] If poppets are NOT available with the required dimensions, a small amount of material may be removed by filing/shaving or added by welding and then machined to the needed/finished dimension.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 19 of 48 7.4 "As-Left" Functional Test Using the STB-200 Test Bench (continued) NOTE When enough material is to be removed that the squareness and symmetry is likely to be lost, the poppet heads are to be milled, removing the same amount of material from each side of the head. [11] Material may be added to the poppet head which is too narrow, using weld procedure GE-i 1-0-1. After welding, the flats are to be milled to the proper dimension. NOTES

1) Poppets supplied by Bergen-Paterson, manufactured after August 1977, are identified by an "E" stamped on the head of extension poppets. Compression poppets are NOT marked. Prior toAugust 1977, neither extension or compression poppets were marked. Appendix A, Table A-1 lists the current factory dimensions and part numbers for the poppets.

2) The valve and poppets used for the external pipe configuration snubbers do NOT have the exact dimensions as the later models, the current model poppets can be adjusted to give the required results in the external pipe configuration.

3) The bleed rate is determined by the amount of fluid that goes through the grooves in the tapered part of the poppet when it closes on the valve seat.

4) If the bleed rate is too fast for the amount of force developed, the grooves are too deep.

[12] MACHINE the tapered portion of the poppet at the existing angle just enough to almost clean off the grooves. NOTE A Noburod or Severance chamfering tool may be used to remove the grooves. [13] ENSURE that the tapered portion of the poppet is machined smoothly and true, since it is a sealing surface.

BFN Functional Testing of Bergen -Paterson, 0-Sl-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 20 of 48 7.4 "As-Left" Functional Test Using the STB-200 Test Bench (continued) NOTE If too much material is removed, the POPPET will be shortened and the spring will be compressed solid before the poppet reaches the seat. [14] RESTORE the grooves, as necessary, using a machinist file. NOTE A slight change in the depth of the groove makes a lot of difference in the bleed rate of the snubber. [15] Each time the valve, cylinder or accumulator are reassembled, REFILL them with silicone fluid and BLEED/PURGE any entrapped air from the passages of the snubber. NOTE Air contained in the fluid changes the lock-up and bleed rate, therefore the fluid should be free of air when the functional tests are performed. [16] When the bleed rate has been adjusted or replacement poppets have been installed, the complete As-Left functional test is to be repeated. [17] REPEAT Steps 7.3[7.3] through 7.3[7.4], as necessary, to achieve the lock-up and bleed rates, as required to meet the acceptance criteria stated in Section 6.0B.2. [18] .RECORD the "As-Left" test results on Attachment 2, and indicate" As-Left" test "Passed" on a tag to be wired to the snubber. [19] The person responsible for performing the functional test shall SIGN, DATE the tag, and ATTACH/WIRE the tag to the snubber.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 21 of 48 7.5 Hydraulic Snubber Service Life Monitoring [1] RECORD the "As-Found" stroke setting in Attachment 2, as appropriate and REMOVE the snubber in accordance with MPI-0-000-SNBOO4. [2] PERFORM "As-Found" test on the snubber, as required per Section 7.3. [3] REBUILD the snubber replacing all seals and fluid in accordance with MPI-0-000-SNBO02. [4] PERFORM "As-Left" test for the snubber in accordance with Section 7.4. [5] REINSTALL the snubbers in accordance with MPI-0-000-SNBOO4, and RECORD the "As-Left" Stroke Setting in Attachment 2, as appropriate. [6] PROVIDE the Snubber Engineer with the following information: A. Month and year the new seals were installed (actual service date) B. Serial number [7] Snubber Engineer is to ADD the service life (17 years) to the new service date and ENTER the month and year of the next required service in the appropriate data base. [8] SUBMIT the completed original Attachment 2 to the Snubber Engineer/SE Designee for review and to include in the SI package.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 22 of 48 7.6 Results Evaluation NOTE The following reviews are performed by the Snubber Engineer/SE-Designee, or a representative of Site Engineering Civil: [1] REVIEW all of the test data on Attachment 2, as applicable. [2] If any snubber is determined inoperable:

               "     ENSURE that the Shift Manager/Unit Supervisor has been notified of the inoperable snubber.

• ENSURE a PER has been initiated in accordance with SPP-8.1 and SPP-3.1.
• INITIATE a Work Order (WO) to replace the snubber, if necessary.
• PERFORM a failure evaluation of any inoperable snubber(s) and DOCUMENT on Attachment 3.
• PERFORM the supported system/component evaluation on Attachment 4.
• SELECT subsequent test lot, as required for functional test failure, or other snubbers for verification, as specified on Attachment 6.

7.7 Data Sheet Review [1] VERIFY that all necessary attachments are included and all acceptance criteria have been met. [2] REVIEW the completed SI package for final acceptance. NOTE Computer generated data sheets containing information regarding the initial test log, subsequent test logs, rebuilds, and etc., should be submitted with the SI data package. [3] SUBMIT the completed package for closure.

E3FN

                                                                                     ~1 Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B U'nit 0                 Anchor/Darling or Fronek         Rev. 0008 Hydraulic Snubbers            Page 23 of 48 8.0    ILLUSTRATIONS/ATTACHMENTS Illustration 1 - Piston Rod Position Measurement Appendix A - Snubber Flow Path, Control Valve Assembly, and Poppet Sizes Appendix B - Subgrouping of Snubbers Appendix C - Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubber Acceptance Criteria Appendix D - Correction for Temperature Appendix E - Daily Startup Procedure for the STB-200 Test Bench Appendix F - Common Modes of Snubber Failure and Possible Causes Appendix G - Service Life Monitoring for Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubbers Attachment 1 - Surveillance Instruction Review Form Attachment 2 - As-Found and As-Left Test Data, Removal and Reinstallation Data Sheets for Bergen Paterson Hydraulic Snubber Attachment 3 - Engineering Failure Analysis for Inoperable Snubber Attachment 4 - Supported System/Component Analysis for Inoperable Snubber Attachment 5 - Functional Test Case Specific Acceptance Criteria Attachment 6 - Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range

BFN Functional Testing of Bergen-Paterson, O-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 24 of 48 Illustration 1 (Page 1 of 1) Piston Rod Position Measurement K FRONT HEAD:.....

                                                .:_         WRENCH 7     FLAT DRILLED HOLE RETRACTED::::         3/4':

DIMENSION..

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 25 of 48 Appendix A (Page 1 of 3) Snubber Flow Path, Control Valve Assembly, and Poppet Sizes IL-LUS TRATI1O.N A-i

BER:

G :N-P:ATERSON,: ANCHOýR/-DARLING O:R FRONE. . HYDRAULIC FOW .ATH ISPRING LOADED:

ACCUMULATOR :: COMPRESSION POPPET EXTENSION MAIN CYFINDER FLOWJ DURING EXTENSION SPRING LOADED

                                                                   =         =ACCUMULATOR COMPRESSION P POPPET
                                                                       . .(1. ... ,SIO,N RETRACTON MAIN CYLINDER FLOWg DURING RETRACTION

BFN Functional Testing of Bergen-Paterson, O-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 26 of 48 Appendix A (Page 2 of 3) ILLUS17TRATION A-2 CONTROL VALVE ASSEMýBLY FOR MANIFOLD DESIGN 0

                          ....  ~~ ~ ~ Luuu,01 Iuu ,u . ..  .
                    ...      ,, , uu u . .. , , uuu4 U

w-I U

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 27 of 48 Appendix A (Page 3 of 3) TABLE A-1 STANDARD BERGEN-PATERSON, ANCHOR/DARLING AND FRONEK POPPETS CYLINDER MODEL DIRECTION BETWEEN NO. OF PART NUMBER BORE NUMBER FLATS

• FLATS 1.5 HSSA-3 COMPRESSION 0.457" 202-1061-001 EXTENSION 0.470" 202-1061-002 2.5 HSSA-10 COMPRESSION 0.415" 202-1061-003 EXTENSION 0.435" 202-1061-004 3.25 HSSA-20 COMPRESSION 0.389" 202-1061-005 EXTENSION 0.400" 202-1061-006 4.00 HSSA-30 COMPRESSION 0.389" 202-1061-007 EXTENSION 0.410" 202-1061-008 5.00 HSSA-50 COMPRESSION 0.420" 202-1061-009 EXTENSION 0.430" 202-1061-010 6.00 HSSA-70 COMPRESSION 0.375" 202-1061-011 EXTENSION 0.410" 202-1061-012 8.00 HSSA-130 COMPRESSION 0.875" 202-1061-013 EXTENSION 0.875" 202-1061-014 Factory tolerance +/- 0.0005"

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 28 of 48 Appendix B (Page 1 of 1) Subgrouping of Snubbers

1.0 SUBGROUPING

For functional testing, the Bergen-Paterson, Anchor/Darling, or Fronek hydraulic snubbers, except 12 inch bore Torus dynamic restraints, belong to one subgroup as described below: Subgroup 1 All sizes of Bergen-Paterson (except the 12 inch bore Torus Dynamic Restraints), Anchor/Darling, and Fronek hydraulic snubbers. When snubbers are added, deleted, or changed, based on modifications, they are added or deleted from their appropriate subgroups. If the added snubbers do NOT fit an existing subgroup, a revision to this SI describing the new subgroup or a revision to an existing subgroup is required. Snubbers tested from severe service areas will remain a part of their respective subgroup, unless a failure analysis is performed and a separate subgroup is justified and incorporated into this SI. Severe service areas include inside the drywell and in the main steam valve vault room. There have been minimal failures of snubbers in these locations, therefore, testing 10 percent of the snubbers in these areas each refueling outage satisfies the intent of the surveillance requirement.

BFN Functional Testing of Bergen-Paterson, O-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 29 of 48 Appendix C (Page 1 of 3) Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubber Acceptance Criteria AS-FOUND AS-LEFT LOCKUP LOCKUP SIZE IN/MIN SIZE IN/MIN HSSA-3 1-30 HSSA-3 5-20 HSSA-10 1-30 HSSA-10 5-20 HSSA-20 1-30 HSSA-20 5-20 HSSA-30 1-30 HSSA-30 5-20 ADH-20 1-30 ADH-20 5-20 ADH-30 1-30 ADH-30 5-20 ADH-50 1-30 ADH-50 .5-20 ADH-70 1-30 ADH-70 5-20 ADH-130 1-30 ADH-130 5-20

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 30 of 48 Appendix C (Page 2 of 3) Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubber Acceptance Criteria LOAD AND BLEED TABLE RFRCFN-PATFRSON 3 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 1000 0.6 4.95 33% 1500 1 7.5 50% 1800 1 1.2 9 60% 2000 1.34 10.05 67% 2400 1.6 12 80% 2500 1.66 12.45 83% 3000 2.0 15.0 100% BERGEN-PATERSON 10 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 1000 0.2 1.5 10% 2000 0.4 3 20% 3000 1 0.6 4.5 30% 4000 0.8 6 40% 5000 1 7.5 50% 6000 1.2 9 60% 7000 1.4 10.5 70% 8000 1 1.6 12 80% 9000 1.8 13.5 90% 10000 2.0 15.0 100% BERGEN-PATERSON, ANCHOR/DARLING (ADH), Fronek 20 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 5000 0.5 2.5 25% 10000 1 5 50% 12000 1.2 6 60% 15000 1.5 7.5 75% 16000 1.6 8 80% 20000 2.0 10.0 100% BERGEN-PATERSON, ANCHOR/DARLING (ADH), Fronek 30 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 5000 0.33 1.67 17% 10000 0.66 3.34 33% 15000 1 5.01 50% 18000 1.2 6.01 60% 20000 1.33 6.68 67% 24000 1.59 8.02 80% 25000 1.66 8.35 83% 30000 2.0 10.0 100%

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 31 of 48 Appendix C (Page 3 of 3) Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubber Acceptance Criteria LOAD AND BLEED TABLE ANCHOR/DARLING (ADH), Fronek 50 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 5000 .2 .8 10% 10000 .4 1.6 20% 15000 .6 2.4 30% 20000 .8 3.2 40% 25000 1.0 4.0 50% 30000 1.2 4.8 60% 35000 1.4 5.6 70% 40000 1 1.6 6.4 80% 45000 1.8 7.2 90% 50000 2.0 8.0 100% ANCHOR/DARLING (ADH), Fronek 70 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 7000 .2 .8 10% 14000 .4 1.6 20% 21000 .6 2.4 30% 28000 .8 3.2 40% 35000 1.0 4.0 50% 42000 1.2 4.8 60% 49000 1.4 5.6 70% 56000 1.6 6.4 80% 63000 1.8 7.2 90% 70000 2.0 8.0 100% ANCHOR/DARLING (ADH), Fronek 130 BLEED RATE PERCENT LOAD MIN. MAX. LOAD 13000 .2 .8 10% 26000 .4 1.6 20% 39000 .6 2.4 30% 52000 .8 3.2 40% 65000 1.0 4.0 50% 78000 1.2 4.8 60% 91000 1.4 5.6 '70% 104000 1.6 6.4 80% 117000 1.8 7.2 90% 130000 2.0 8.0 100%

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 32 of 48 Appendix D (Page 1 of 1) Correction for Temperature LOCKUP (ACTUATION) BLEED (RELEASE) F Correction F Correction F Correction F Correction 50 4 75 -1 50 1.00 75 -0.25 51 3.8 76 -1.2 51 0.95 76 -0.30 52 3.6 77 -1.4 52 0.90 77 -0.35 53 3.4 78 -1.6 53 0.85 78 -0.40 54 3.2 79 -1.8 54 0.80 79 -0.45 55 3 80 -2 55 0.75 80 -0.50 56 2.8 81 -2.2 56 0.70 81 -0.55 57 2.6 82 -2.4 57 0.65 82 -0.60 58 2.4 83 -2.6 58 0.60 83 -0.65 59 2.2 84 -2.8 59 0.55 84 -0.70 60 2 85 -3 60 0.50 85 -0.75 61 1.8 86 -3.2 61 0.45 86 -0.80 62 1.6 87 -3.4 62 0.40 87 -0.85 63 1.4 88 -3.6 63 0.35 88 -0.90 64 1.2 89 -3.8 64 0.30 89 -0.95 65 1 90 -4 65 0.25 90 -1.00 66 0.8 91 -4.2 66 0.20 91 -1.05 67 0.6 92 -4.4 67 0.15 92 -1.10 68 0.4 93 -4.6 68 0.10 93 -1.15 69 0.2 94 -4.8 69 0.05 94 -1.20 70 0 95 -5 70 0 95 -1.25 71 -0.2 96 -5.2 71 -0.05 96 -1.30 72 -0.4 97 -5.4 72 -0.10 97 -1.35 73 -0.6 98 -5.6 73 -0.15 98 -1.40 74 -0.8 99 -5.8 74 -0.20 99 -1.45 100 -6 1 1 100 -1.50 NOTES

1) Correction Factor is 0.2 in/min/°F for snubber lockup (activation).

2) Correction Factor is 0.05 in/min/°F for snubber bleed (release).

3) These correction factors are for GE SF-1 154 Silicone fluid.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 33 of 48 Appendix E (Page 1 of 3) Daily Startup Procedure for the STB-200 Test Bench 1.0 DAILY STARTUP PROCEDURE [1] WARM-UP EXERCISE both benches (i.e., small and large) by selecting the Manual Control Panel function from the Tool Menu. CLICK on "Auto Exercise" in the Operating Mode block to engage the selected bench to automatically stroke back and forth. The system should be run this way until the oil temperature is above approximately 701F or smooth operation is attained. Both test benches should be exercised. To change from one bench to the other, CLICK on the bench label. [2] CHECK THE PRESSURE TRANSMITTER NOTE This instrument does NOT provide safety-related data. This check is optional. In the Manual Control Panel mode, SELECT Manual in the Operating Mode block. TURN the "HP Pump" on, then use the HP Pump slider to increase the pressure command setting until the "Pressure" reading is approximately 2000 psi. CHECK the 0-3000 psi gauge in the front of the HPU. The two readings should be within - 200 psi. [3] PARK THE RAM SELECT the "Park the Ram" to prepare the bench for the Daily Calibration Check. This should be done for both benches. [4] SHUT DOWN THE MANUAL CONTROL PANEL CLICK on "Shut Down" to exit the Manual Control Panel.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 34 of 48 Appendix E (Page 2 of 3) Daily Startup Procedure for the STB-200 Test Bench 2.0 STATUS CHECK [1] During the warm-up period, the frame drive cylinders should be stroked using the proportional valve and/or the jog/drag valve. [2] The system should be checked for loose fittings, bolts, etc. [3] The filter indicators should be watched during cylinder stroking to insure that they are NOT illuminating. [4] If the indicators are illuminating the filters should be changed before continuing with operation of the machine or any testing. 3.0 DAILY CALIBRATION CHECKS The following calibration checks assure the functionality of the instrument and Data Acquisition and control System (DAS) for testing. They do not take the place of full system calibrations which must be performed on a periodic basis. The instrument system (DAS system and transmitters) should be powered up for 30 minutes before any checks or testing is performed. Prior to performing this function, both rams should have been "Parked" using the "Park the Ram" function in the Manual Control Panel. [1] SELECT THE DAILY CALIBRATION FUNCTION SELECT the Daily Calibration Check function from the "Tools" menu. [2] CONNECT THE LOW RANGE LOAD CELL AS DIRECTED If directed to by the software, electrically connect the Low Range Load Cell as instructed. The load cell does NOT need to be mechanically mounted in the test bench, but it must be connected to its electrical cable. [3] STORE THE "ZERO" CALIBRATION READINGS For each instrument click the "STORE" button in the "ZERO" column on the Daily Calibration screen for that instrument. The zero reading will be captured in the "Actual" "Zero" column. If it is within limits, the box will turn gray. If it is NOT within limits, the box will turn yellow.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 35 of 48 Appendix E (Page 3 of 3) Daily Startup Procedure for the STB-200 Test Bench 3.0 DAILY CALIBRATION CHECKS (continued) [4] STORE THE "SPAN" CALIBRATION READINGS For each instrument, press in the "CAL" button on the front of the instrument, then CLICK the "STORE" button in the "SPAN" column on the Daily Calibration screen for that instrument. The span reading will be captured in the "ACTUAL" "SPAN" column. If it is within limits, the box will turn gray. If it is NOT within limits, the box will turn yellow. [5] PRINT THE REPORT When all readings for both benches have been stored, CLICK on the "PRINT" button to print the Daily Calibration Report. If the report is "SATISFACTORY", continue the testing. If the report is "UNSATISFACTORY", halt and correct the problem before continuing.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 36 of 48 Appendix F (Page 1 of 1) Common Modes of Snubber Failure and Possible Causes TYPE COMMON MODES OF FAILURE POSSIBLE CAUSE HYDRAULIC No Lockup Wrong Size Poppet Wrong Size Poppet Spring Poppet Frozen or Blocked Open Excessively low or No Fluid Lockup Adjustment Set Improperly Damaged Piston Rod Seal Damaged "0"Ring High Lockup Wrong Size Poppet Wrong Size Poppet Spring Lockup Velocity Adjustment Set Improperly Damaged "0"Ring Low Lockup Broken Poppet Spring Poppet Frozen or Blocked Closed Lockup velocity Adjustment Set Improperly Foreign Objects in Fluid High Bleed Defective or Damaged Poppet Defective or Damaged Poppet Seat Wrong Size Poppet Bleed Adjustment Set Improperly Damaged "0"Ring No Bleed Foreign Objects in Fluid Bleed Adjustment Set Improperly Miscellaneous Hardware Improper Installation Improper Handling or Abuse Misapplication Overload Vibration or Wear

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 37 of 48 Appendix G (Page 1 of 1) Service Life Monitoring for Bergen-Paterson, Anchor/Darling and Fronek Hydraulic Snubbers The service life of snubbers may be extended based on an evaluation of the records of functional tests, maintenance history, and environment conditions to which the snubbers have been exposed. Seal service life of hydraulic snubbers shall be monitored to ensure that the service life of the seals is NOT exceeded. The maximum expected service life for various seals, seal materials and applications shall be estimated, based on engineering information and seals shall be replaced so that the maximum expected seal service life does NOT expire during a period when the snubber(s) are required to be operable. Based on current seal manufacturer's data and operating experience, ethylene propylene seals are expected to have a maximum service life of approximately 10 years for the Bergen-Paterson, Anchor/Darling, or Fronek hydraulic snubbers. This maximum seal service life may be extended to 17.3 years based on the evaluation results documented in Ref. 2.0K. The piston, piston rod, cylinder and glands are also subject to wear, especially in high vibration installations. Those, and other moving parts of the snubber, should be examined carefully each time the seals are replaced, and replacements made to prevent leakage or other conditions of loss of function before the next time the snubber is to be rebuilt. To ensure that the seal service life does NOT expire and to distribute the work load between the refueling outages, replace the seals in approximately 10 percent of the Bergen-Paterson hydraulic snubbers each refueling outage. However, review the required seal service date on the data base and replace the seals whose required seal service date will occur before the next scheduled refueling outage, unless justification is provided for extending the service life of those seals. Seals replacement work shall be performed and documented in accordance with MPI-0-000-SNBOO2. Seal service life monitoring data shall be recorded in an appropriate data base as determined by the Snubber Engineer/SE Designee. Each time that the seal service life start and expiration dates change as a result of seals replacement the data base should be revised to incorporate current status of the seal service life.

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 38 of 48 Attachment I (Page 1 of 1) Surveillance Instruction Review Form REASON FOR TEST: o1 Scheduled Surveillance o1 System Inoperable (Explain in Remarks) UNIT MODE o Maintenance (See WO No. below) o Other (Explain in Remarks) W.O. SNUBBER SERIAL NO. UNID NO. PRE-TEST REMARKS: PERFORMED BY Initials Name (Print) Name (Signature) NOTE: The following entries for contacting Shift Manager/Unit Supervisor shall be marked N/A if the snubber is NOT Inoperable. NOTIFY Shift Manager/Unit Supervisor when snubber found Inoperable. SM/UNIT SUPERVISOR CONTACTED Date Time NOTIFY Shift Manager/Unit Supervisor when snubber Operability is restored. SM/UNIT SUPERVISOR CONTACTED Date Time MECHANICAL MAINTENANCE REVIEWER Date Signature attests that I understand the scope and purpose of this instruction and that, to the best of my knowledge, it was properly performed in accordance with instruction in that: the recording, reduction, and evaluation of data is complete and correct; acceptance criteria is met or justification for exceptions is provided; portions of test performed were appropriate for specified test conditions or reasons for test; deficiencies were evaluated and dispositioned; reportability was evaluated; marginal results were evaluated with respect to potential for future problems based on operating experience and regulatory requirements; and instruction was complete except as noted in post-test remarks. SNUBBER ENGINEER/SITE ENGINEERING CIVIL REVIEWER Date SCHEDULING COORDINATOR Date POST-TEST REMARKS:

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 39 of 48 Attachment 2 (Page 1 of 4) As Found and As Left Test Data, Removal and Reinstallation Data Sheets for Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubbers AS-FOUND BERGEN-PATERSON, ANCHOR/DARLING OR FRONEK HYDRAULIC SNUBBER TEST DATA W.O. No. Date: Snubber UNID: Pyrometer Number: Serial Number: Calibration Due Date: Exam Number: Snubber Rated Load: Temperature/Correction: Activation Temp Corrected Generic Performer (in/min) Correction Activation Acceptance Signature/Date (in/min) (in/min) Criteria

• 1 in/minm Tension Corrected Signature Cornmpression Compression__ _______Activation

_____ in/min < 30 Date (AC) Bleed Temp Corrected (in/min) Correction Bleed (in/min) (in/min), Tension ______ N/A N/A Bleed takes Signature place after snubber Compression N/A N/A activation Date (AC) Drag(lbs) Tension Does not exceed Max: N/A N/A 2% of snubber Signature rated load Rated Load x Date ____(AC) Compression Max: N/A N/A 0.02 = I_ LBS Copy of the plotted as-found test results is attached to this data sheet. /

                                                                                                 /

Initials Date

• Case Specific Acceptance Criteria may be approved on Attachment 5.

Snubber meets Generic Acceptance Criteria: Yes No / Initials / Date Snubber meets Case Specific Acceptance Criteria _Yes _No _N/A / Initials / Date If neither the Generic nor the Case Specific acceptance criteria has been met, Notify the Shift Manager or Unit Supervisor immediately. SNUBBER ENGINEER/SE DESIGNEE Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 40 of 48 Attachment 2 (Page 2 of 4) AS-LEFT BERGEN-PATERSON, ANCHOR/DARLING OR FRONEK HYDRAULIC SNUBBER TEST DATA W.O. No. Date: Pyrometer Number: Snubber UNID: Calibration Due Date: Serial Number: Exam Number: Snubber Rated Load: Temperature/Correction: Activation Temp Corrected Generic Performer Signature/Date (in/min) Correction Activation Acceptance (in/min) (in/min) Criteria

• Tension 5 in/min <

Corrected Signature Compression Activation < 20 Date (AC) in/min Bleed Temp Corrected (in/min) Correction Bleed (in/min) (in/min) Corrected bleed Tension takes place after snubber activation Signature Compression and shall within the be range Date (AC) shown in App. C Drag(lbs) Tension Does not exceed Max: N/A N/A 2% of snubber Signature rated load Compression Rated Load x Date (AC) Max: N/A N/A 0.02 = LBS Copy of the plotted as-found test results is attached to this data sheet. / Initials / Date

• Case Specific Acceptance Criteria may be approved on Attachment 5.

Snubber meets Generic Acceptance Criteria: Yes No Initials / Date SNUBBER ENGINEER/SE DESIGNEE Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 41 of 48 Attachment 2 (Page 3 of 4) REMOVAL AND REINSTALLATION OF BERGEN-PATERSON, ANCHOR/DARLING OR FRONEK HYDRAULIC SNUBBER W.O. No. Unit Snubber UNID No. Serial No. Subgroup Test Lot: Initial Subsequent Exam No. Size Rated Load lbs. Design drawing number Shift Manager/Unit Supervisor and Snubber Engineer/SE Designee notified prior to removal of snubber for functional testing. Foreman/Designee Date Time As-Found Stroke Setting_ (Equals piston rod measurement minus 3/4". Refer to ILLUSTRATION 1.) Required Stroke Setting Range (from Design drawing) Pipe Temp.: _F, If other than ambient (per 0-47B435-5F, Note 24), notify Snubber Engineer/Site Engineering Civil. Pyrometer No.: Calibration Due Date: The As-Found Stroke Setting is within the acceptable limits shown in the design drawing listed above. If the answer is "No", initiate Attachment 6. Yes No (AC) Performer Signature Date All fasteners for the As-Found snubber are secured and acceptable (i.e., no loose or missing fasteners on the component anchorage). Ifthe answer to the above is "No", intiate Attachment 6. Yes No (AC) Performer Signature Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 42 of 48 Attachment 2 (Page 4 of 4) REMOVAL AND REINSTALLATION OF BERGEN-PATERSON, ANCHOR/DARLING OR FRONEK HYDRAULIC SNUBBERS W.O. No. Unit Snubber UNID No. Snubber reinstallation: Same snubber reinstalled Yes No If No, enter Bergen-Paterson, Anchor/Darling or Fronek serial number Setrial Number Snubber is reinstalled in proper location Yes No Snubber is reinstalled with base of housing up (for Yes No vertical snubbers) All locking devices are secured Yes No Cotter pins are spread Yes No N/A Spherical bearing greased Yes No N/A Gaps between spacers and spherical bearing are 1/16 inch each side, 1/8 inch total or less Yes No Snubber is tagged Yes No Bolts and jam nuts torqued Yes No N/A Anti-seize compound applied, as needed Yes No N/A As-Left Stroke Setting Torque Wrench No. Calibration Due Date Performer Signature Date The As-Left Stroke Setting is within the acceptable limits shown in the design drawing. Yes No Performer Signature Date SHIFT MANAGER/UNIT SUPERVISOR notified of operable and reinstalled snubber. (AC) Foreman/Designee Date Remarks:

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 43 of 48 Attachment 3 (Page 1 of 2) Engineering Failure Analysis for Inoperable Snubber WO No. Unit Snubber.UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No. Lot

1. Describe the mode of failure, as discussed on Appendix F.

o Locked up 0 High Drag Force 0 Snubber would NOT activate o Damage to snubber hardware 0 Other Explain (if necessary)

2. Describe the conditions of the failure:

3. Determine the cause of failure, using Appendix F for the possible causes (disassembly of the snubber may be necessary):

4. For a snubber that does NOT activate, release, is locked up, or damaged hardware, was the cause of the failure a design or manufacturing defect?

0 Yes 0 No Explain Evaluation:

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 44 of 48 Attachment 3 (Page 2 of 2) Engineering Failure Analysis for Inoperable Snubber WO No. Unit Snubber UNID No. Subgrour No. PER No. Mfg./Size Serial No. Rated Load Exam No. Lot

5. Snubber failure classified as: 0 Location 0 Manufacturing 0 Design 0 Unknown 0 Other Explain:

6. Does the vendor need to be contacted? 0 Yes 0 No Vendor Name:

Person contacted: Date: Vendor's comments:

7. What subsequent testing is required because of this failure?

Subsequent Lot No. No. of snubbers to be tested

8. What corrective action and recurrence controls are to be taken?

Evaluation performed by: Snubber Engineer/SE Designee Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 45 of 48 Attachment 4 (Page 1 of 1) Supported System/Component Analysis for Inoperable Snubber WO No. Unit Snubber UNID No. Subgroup) No. PER No. Mfg./Size Serial No. Rated Load Exam No.

1. Describe the condition(s) (e.g., snubber would NOT activate, was locked up, or excessive drag force, damaged hardware etc.).

2. Attach the SE Evaluation of the attached component:

3. Based on the results of the Engineering Evaluation, has the snubber failure mode adversely affected the supported system or component?

0 Yes 0 No Snubber Enaineer/SE Desianee Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 46 of 48 Attachment 5 (Page 1 of 1) Case Specific Acceptance Criteria WO No. Unit Snubber UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No.

1. Record the parameter (i.e., activation, drag) and the test results that are outside the standard acceptance criteria:

2. Specify the Case Specific Acceptance Criteria and provide justification:

Site Engineering Civil Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 47 of 48 Attachment 6 (Page 1 of 2) Evaluation of Loose or Missing Attachment Fasteners or of "As-Found" Stroke Setting Outside of Acceptable Range This evaluation shall be performed when fasteners, used for attachment of snubber to component, and to snubber anchorage, are discovered loose or missing prior to the As-Found functional testing. This evaluation also shall be performed if the snubber "As-Found" setting is outside of the acceptable range specified on the design drawing. WO No. Unit Date Discovered Snubber UNID No. Serial No. Subgroup Exam No. Size Rated Load Lbs.

1. Describe the discovered condition and, if possible, determine cause:

Performer Initials Date

BFN Functional Testing of Bergen-Paterson, 0-SI-4.6.H-2B Unit 0 Anchor/Darling or Fronek Rev. 0008 Hydraulic Snubbers Page 48 of 48 Attachment 6 (Page 2 of 2) Evaluation of Loose or Missing Attachment Fasteners or of "As-Found" Stroke Setting Outside of Acceptable Range Items 2, 3, and 4 are to be completed by Site Engineering Civil.

2. Evaluate to determine whether the cause may be localized or generic. Use this evaluation to select and list other suspect snubbers for verification, as applicable.:

3. Describe the corrective action(s) and provide the As-Found test result.

4.

Conclusion:

Is the snubber operable? YES NO Justification: If"No", notify the Shift Manager or Unit Supervisor immediately. Then complete or request a failure analysis using Attachment 3, and a supported component or system analysis on Attachment 4, as necessary. Evaluated by: Date

Attachment G BFN Surveillance Instruction, O-SI-4.6.H-2E, Functional Testing of Lisega Large Bore Torus Dynamic Restraint Snubbers

Browns Ferry Nuclear Plant Unit 0 Surveillance Instruction 0-SI-4.6.H-2E Functional Testing of Lisega Large Bore Torus Dynamic Restraint Snubbers Revision 0007 Quality Related Level of Use: Continuous Use Effective Date: 08-28-2008 Responsible Organization: DEC, Design Eng Civil Prepared By: Stephen Samaras Approved By: Kevin L Groom

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 2 of 49 Current Revision Description Pages Affected: Cover sheet, revision log, 9 and 41 Type of Change: REVISION Tracking Number: 009 This procedure is being revised as a corrective action to PER 140467 to revise the parameters for the "as-left" bleed rate.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 3 of 49 Table of Contents

1.0 INTRODUCTION

......................................................................................................                        5 1 .1    P u rp o se ........................................................................................................................       5 1 .2    Sc o p e ............................................................................................................................      5 1.3     Frequency/C onditions .............................................................................................                        6

2.0 REFERENCES

........................................................................................................                        7 3.0     PRECAUTIONS AND LIMITATIONS ......................................................................                                         7 4.0     PREREQUISITES ....................................................................................................                         8 5.0     SPECIAL TOOLS AND EQUIPMENT RECOMMENDED ........................................                                                           8 6.0     ACCEPTANCE CRITERIA ........................................................................................                               8 7.0     PROCEDURE STEPS ............................................................................................                              10 7.1     Training and Qualification of Performers ................................................................                                 10 7.2     Preparation of Test Data Package .........................................................................                                10 7.3     Removal of Valves From Restraint/Surrogate .........................................................                                      11 7.4     Installation of the Valves in the Restraint/Surrogate ...............................................                                     12 7.5     "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine ............... 13 7.6     R esults E valuation ................................................................................................                 . . 22 7.7     D ata S heet R eview ...............................................................................................                      22 8.0     ILLUSTRATIONS/APPENDIX/ATTACHMENTS ....................................................                                                   23 Illustration 1:        Two Way Ball Valve Locations and Positions ....................................                                            24 Illustration 2:        Cover and Valve Removal and Reinstallation .....................................                                           25 Illustration 3:        Drain Hose Connection ......................................................................                               26 Illustration 4:        Oil Level in Valve Hole Prior to Replacing the Removed V alve ......................................................................................................              27 Illustration 5:        Fluid Level in Surrogate Test Snubber Holes ...................................                                            28 Illustration 6:        Lisega Fluid Level Measurement of Surrogate Test Snubber ................................................................................................                   29 Illustration 7:        Lisega Piston Position Measurement .................................................                                       30

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 4 of 49 Table of Contents (continued) Illustration 8: Lisega Minimum Fluid Level Plunger and Piston Position Measurement in the Field .................................................................... 31 Appendix A: Subgrouping and Service Life Monitoring of Snubbers .................... 33 Appendix B: Common Modes of Snubber Failure and Possible Causes ............... 34 Appendix C: Daily Startup Procedure for the STB-200 Test Bench ....................... 35 : Surveillance Instruction Review Form ............................................... 38 : Nomenclature, Conversion, As-Found and As-Left Test Data, Removal and Reinstallation Data Sheets for Lisega Large Bore Torus Dynamic Restraints ............................................... 39 : Engineering Failure Analysis For Snubber Declared Inoperable .............................................................................................. 44 : Supported System /Component Analysis For Inoperable Snubber ................................................................................................ 46 : Case Specific Acceptance Criteria ...................................................... 47 : Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range .............................................. 48

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 5 of 49

1.0 INTRODUCTION

1.1 Purpose This Surveillance Instruction implements Technical Requirements Manual (TRM) TR 3.7.4, and provides direction for the functional testing, of Lisega Large Bore Torus Dynamic Restraints, as given in the Snubber Program Procedure (0-TI-398), on safety related systems outside of the drywell. 1.2 Scope The snubbers within the scope of this instruction are accessible during reactor operation. The Lisega Large Bore Torus Dynamic Restraints belong to Subgroup 5. The portions of Technical Requirements TR 3.7.4 pertaining to the visual examination of snubbers are implemented by Surveillance Instructions 1-SI-4.6.H-1, 2-SI-4.6.H-1 and 3-SI-4.6.H-1. This Surveillance Instruction (SI) provides the requirements and guidance to perform functional testing of Lisega Torus Dynamic Restraints for Units 1, 2 and 3, as follows:

• Removal and reinstallation of Lisega Torus Dynamic Restraints is accomplished per MPI-0-000-SNBOO4 and recorded in Attachment 2.
• Provides the requirements for functional testing and service life monitoring of Lisega Torus Dynamic Restraints. This instruction covers subgroup 5 only (see Appendix A for snubber subgroup information). To completely fulfill the snubber Technical Requirements (TR) functional testing requirements, Surveillance Instructions O-SI-4.6.H-2A, O-SI-4.6.H-2B, O-SI-4.6.H-2C and O-SI-4.6.H-2D must be performed as required per TSR 3.7.4.2.
• Provides a means for the control and documentation of all Lisega Torus Dynamic Restraint snubber surveillance activities provided in this Surveillance Instruction.

     "    This Surveillance Instruction shall be used to verify operability of Lisega Torus Dynamic Restraint snubbers suspected inoperable during performance of the visual examination Sis.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 6 of 49 1.3 Frequency/Conditions A. This Surveillance Instruction shall be performed each refueling outage and portions of it may be performed to establish operability in accordance with 1-SI-4.6.H-1, 2-SI-4.6.H-1, and 3-SI-4.6.H-1 Visual Examination of Hydraulic and Mechanical Snubbers. B. This instruction may only be performed during an outage for the Lisega Large Bore Torus Dynamic Restraints. C. All safety related snubbers shall be operable during all modes of operation as described in the Technical Requirements Manual TR 3.7.4, if the system is required to be operable during that mode. D. Snubbers located inside the drywell on reactor vessel attached piping shall be OPERABLE whenever fuel is in the reactor vessel. Snubbers on the Main Steam, HPCI, and RCIC piping in the drywell are exempt from the operability requirement when the steam line plugs are installed in the reactor vessel. E. Snubbers on safety related systems that have experienced unexpected potentially damaging transients shall be evaluated for the possibility of concealed damage and functionally tested, if applicable. F. A snubber removed from an operable safety related system must be reinstalled or replaced within 72 hours of its removal or declare the supported system/component inoperable and follow the appropriate action statement for that system. G. For inoperable snubber(s), within 72 hours, replace or restore inoperable snubber(s) to an operable status and perform an engineering evaluation on the supported component or system, if the snubber does NOT meet the functional test acceptance criteria of TSR 3.7.4.2. Otherwise, declare the system inoperable and follow the required actions specified in the TRM. The engineering evaluation is to determine if component or system restrained by the snubber(s) was adversely affected by inoperability of the snubber(s) during the previous operating cycle and ensure that the restrained component or system remains capable of meeting its design function. The engineering evaluation(s) for supported component or system analysis are to be recorded on Attachment 4. H. Alternately, for a snubber removed and not replaced within 72 hours, or an inoperable snubber not replaced or restored within 72 hours, operability of the supported system maybe verified based on an engineering evaluation of the system functional capability with the removed or inoperable snubber.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 7 of 49 1.3 Frequency/Conditions (continued) I. Snubbers removed for maintenance or determined to be inoperable on a non-operable safety related system must be reinstalled or replaced, in accordance with MPI-0-000-SNBOO4 and tested in accordance with this instruction, prior to declaring the system operable. J. For all subgroups, when subsequent testing is required, it shall continue within the respective subgroup until no failure is found. K. New, replaced, or rebuilt snubber(s) shall meet the functional test acceptance criteria before their installation in the unit and must have been functionally tested "Satisfactory", within 12 months prior to their installation.

2.0 REFERENCES

A. Technical Requirements Manual TR 3.7.4, Snubbers B. 1-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers C. 2-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers D. 3-SI-4.6.H-1, Surveillance Instruction Visual Examination of Hydraulic and Mechanical Snubbers E. MPI-0-000-SNBOO4, Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek, Grinnell Hydraulic and Bergen-Paterson or Lisega Torus Dynamic Restraint Snubbers F. BFN-VTM-L329-0010, Vendor Technical Manual for Lisega Torus Dynamic Restraint Snubbers G. BFN-VTD-L329-0070, Installation and Maintenance Instruction for Lisega Type 31 21 50 and Test (Surrogate) Type 31 Hydraulic Shock Absorber H. PE-8997-P1, Special 4 Inch Tapered Pin Installation and Removal Procedure I. 0-TI-398, Snubber Program Procedure J. SPP-3.1, Corrective Action Program K. SPP-8.1, Conduct of Testing 3.0 PRECAUTIONS AND LIMITATIONS None

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 8 of 49 4.0 PREREQUISITES [1] Six months prior to each refueling outage, ensure a minimum of two(2) new Lisega Torus Dynamic Restraint snubbers have been tested and are ready for installation, if required. No paperwork is required, since these snubbers are NOT under the Section XI Repair and Replacement Program. 5.0 SPECIAL TOOLS AND EQUIPMENT RECOMMENDED DESCRIPTION SIZE QUANTITY AP 280 (Lisega Spec. No. 151) As required Snubber Test Machine As required 1 6.0 ACCEPTANCE CRITERIA A. Responses which fail to meet the following As-Found functional test Acceptance Criteria require immediate notification of the Shift Manager or Unit Supervisor at the time of failure. B. The snubber functional test shall verify that: NOTE Activation, bleed, or drag force acceptance criteria may be other than that described in the steps below, if approved by Site Engineering on Attachment 5.

1. "As-Found"

a. Activation occurs in both directions of travel at a piston velocity greater than or equal 6 inches/minute and less than or equal 25 inches/minute.

b. Bleed takes place after activation of the snubber, in both tension and compression directions.

c. Drag force does not exceed 15,000 pounds.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 9 of 49 6.0 ACCEPTANCE CRITERIA (continued)

2. "As-Left"

a. Activation occurs in both directions of travel at a piston velocity greater than or equal 6 inches/minute and less than or equal 25 inches/minute.

b. Bleed takes place after activation of the snubber, in both tension and compression, and is greater than 0.24 inch/minute and less than 1.18 inches/minute.

c. Drag force does not exceed 15,000 pounds.

C. The stroke setting shall be within the limits shown on the design drawing. Otherwise, complete Attachment 6. D. There shall be no loose or missing fasteners for attachment of the "As-Found" dynamic restraint(s) to the component or the anchorage. Otherwise, complete Attachment 6. E. Not meeting acceptance criteria for stroke setting, or loose or missing fasteners, does not require testing an additional lot equal to 10% of the subgroup of snubbers. Evaluation of snubber operability, corrective actions, and selection of other suspect snubbers for verification shall be as specified on Attachment 3 or Attachment 6, as applicable.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 10 of 49 7.0 PROCEDURE STEPS 7.1 Training and Qualification of Performers [1] Thorough briefing should be conducted on SI performance prior to starting. [2]. The cognizant individual or Snubber Engineer responsible for the performance of the Surveillance Instruction must be qualified as a test director. [3] Appropriate General Employee Training (GET) (including respirator training) should be received by personnel prior to performing this SI. 7.2 Preparation of Test Data Package [1] SELECT snubbers for retest which were placed in the same location as snubbers which failed during the previous outage, if the failure analysis showed that the failure was due to the location. However, these snubbers shall be tested in addition to the initial 10 percent test lot (sample plan). [2] DETERMINE the initial test lot (sample plan) as follows:

• SELECT 10 percent of the snubbers from subgroup 5 (see Appendix A).
• In general, SELECT the snubbers with the most time from the previous test.
• SELECT snubbers that have experienced severe transients.
• FILL OUT the applicable section(s) of Attachment 2.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 11 of 49 7.3 Removal of Valves From Restraint/Surrogate NOTES

1) Before the existing valves are removed, record the "As-Found" stroke setting on Attachment 2. There must be no external forces exerted on the restraint, either in compression or tension.

2) Prior to removal of the existing valves ensure there are spare valves on hand which have been tested and passed their functional test within the past 12 months.

3) For valve removal, always remove the front valve 1st and the rear valve 2nd.

For valve installation, always install the rear valve 1st and the front valve 2nd. [1] REMOVE the hexagon screw, disk, bushing and lock plate from the face side of the valve body. See Illustration 1. [2] TURN the 2-way ball valve positioner from the slot being in the vertical to the horizontal direction as shown in position 2, of Illustration 1. This disconnects the snubber main body cylinder from the rear valve. [3] REMOVE the hex screws from the cover of the front valve. See Illustration 2. NOTE When lifting the valve the automatic shut-off valve between the pressurized reservoir and the restraint body interrupts the connection, so that the cylinder is no longer pressurized. [4] REMOVE the front cover, then REMOVE the valve with the extraction tool. See Illustration 2. [5] CONNECT a drain hose to the coupling at the snubber drain port shown in Illustration 3, on the interior face of the valve body. [6] DRAIN the oil from between the valves. After draining is complete, REMOVE the drain hose. [7] REMOVE the hex screws from the cover over the rear valve. See Illustration 2 [8] REMOVE the rear cover, then REMOVE the valve with the extraction tool. See Illustration 2.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 12 of 49 7.4 Installation of the Valves in the Restraint/Surrogate NOTES

1) Prior to installation of the tested valves all 0-rings shall be checked and replaced, if necessary.

2) The screws for the valve covers are only to be tightened snug-tight.

[1] ADD AP 280 hydraulic fluid to the hole for the rear valve. The fluid level shall be approximately equal to the level shown in Illustration 4. [2] INSERT the tested rear valve, then REPLACE the COVER over this valve and SECURE it with the lock washers and screws removed in Step 7.3[7]. See Illustration 2. [3] ADD AP 280 hydraulic fluid to the hole for the front valve. The fluid level shall be approximately equal to the level shown in Illustration 4. [4] ENSURE all of the air in the cross-tie line has been removed. NOTES

1) At the installation of the front valve the shut-off valve to the reservoir opens automatically, repressurizing the restraint.

2) The front valve requires sufficient force added to insert it, due to the pressure on the shut-off valve from the reservoir.

[5] INSERT the tested front valve, then REPLACE the cover over this valve and SECURE it with the lock washers and screws removed in Step 7.3[3]. See Illustration 2. [6] TURN the 2-way ball valve positioner from the slot being in the horizontal to the vertical direction, as shown in position 1 of Illustration 1. This connects the snubber main body cylinder to the rear valve. [7] REPLACE the bushing, lock plate and disk. See Illustration 1.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 13 of 49 7.4 Installation of the Valves in the Restraint/Surrogate (continued) NOTE Prior to the performance of the next step, it is required that parts to receive locking fluid (such as Loctite) are free of oil or grease. [8] APPLY a small amount of locking fluid (such as Loctite) to the threads of the hex screw removed in Step 7.3[1]. 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine [1] ENSURE the test machine has been warmed up in accordance with Appendix C of this procedure. NOTE The word "Test SNUBBER" as used in this test means the Lisega Surrogate Snubber with properly installed valves in accordance with Section 7.4. The following describes a suggested procedure for "Testing a Surrogate Snubber" using the STB 200 Snubber Test Machine with the upgraded Windows Software Operations Manual. [2] POWERING UP THE TEST SYSTEM TURN ON the master power switch on the control console. Make sure that the computer, monitor, and printer are turned on. TURN ON the main breaker on the Hydraulic Power Unit (HPU) located at the end of the power unit. ENSURE that all emergency stop buttons are pulled out.

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 14 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) [3] STARTING THE SOFTWARE Once the computer has "Booted Up", the Windows Desktop will be displayed. SELECT the "STB 200" icon and double click on it, this will Start the Test program. The LOG ON prompt window will appear. ENTER you user name and password in either upper or lower case letters. All functions required by the system are available in the screen, or from one of the Pull Down Menus at the top of the screen. [4] DAILY CALIBRATION CHECK PERFORM the daily calibration check, using Section 3.0 of Appendix C and sign the daily calibration form. After the daily calibration check has been completed, and the Daily Calibration Report is "SATISFACTORY", proceed on testing a snubber. [5] TESTING A SNUBBER [5.1] Pick the Snubber Type Using the Snubber Pull Down List in the User Supplied Information block, SELECT the Type Snubber to be tested. [5.2] Enter the Header Information FILL in the other information as indicated in the User Supplied Information block. [5.3] Running the Test [5.3.1] Pick the Test CLICK on the Type of Test (i.e., "As-Found" or "As-Left") as desired.

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 15 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) [5.3.2] Start the Test CLICK on the Start Test button. Ifthis is the first test performed on the snubber, the following two windows will appear: [5.3.3] Tare weight Window This window allows the User to "zero out" any offset load that the load cell may be reading. This should be performed BEFORE installing the snubber in the test bench. Wait for the "Raw Reading" to settle (as far as possible), and then Click "Adjust Load Cell". The "Adjustment" will be updated, and the "Adjusted Reading" should now read close to zero (0) lb. The "Adjust Load Cell" button may be Clicked again if a new adjustment value is desired. Once the readings are as desired, Click the "Continue" button. ENSURE the correct load cell is connected to the machine. CHOOSE the proper bushings and pins for the snubber being tested, then INSTALL the bushings in both clevis attachments on the machine. [5.3.4] Stroke and Position Window INSTALL the snubber in the test bench, with the piston or operable end toward the drive piston of the machine, if possible. Adjust the backstop and/or use the Jog Speed Slider to adjust the bench and the driver cylinder to the desired pin to pin dimension. The jog slider adjusts the jog speed. The joystick on the test frame controls the actual motion of the driver. INSTALL the pins through the bushings and the snubber spherical bearings. With the surrogate snubber installed in the horizontal position, REMOVE any tested valves from the surrogate snubber using the steps in Section 7.3, as appropriate.

BFN 'Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 16 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) NOTE A small amount of AP 280 Silicon hydraulic fluid may have to be added to the hole for the front valve. The oil level should be approximately at the upper edge of the connection bore between the front and rear valve. This can also be accomplished by opening the shut-off-valve by hand. INSERT the valves removed from the existing restraint to be tested, using the steps in Section 7.4, as appropriate. ONCE the snubber has been pinned and the valves installed, the snubber's piston position (distance from the fully retracted position) should be accurately measured (within 0.1 inch) and entered in the SNUBBER EXTENSION window. If the test program calculates that it cannot fully extend or fully retract the snubber during drag testing, one or more of the text windows on the screen will be highlighted in red. If this happens, the backstop will have to be adjusted and the snubber extension recalculated. The program calculates whether it can fully test the snubber through its stroke range. It will display the two ends of stroke (minus a 1/2 inch safety zones), the calculated center position and the bottomed out position for the snubber. Once the data has been successfully entered, TIGHTEN the lock nuts on the load cell threaded rod snug tight to prevent slippage during the test. ENTER the snubber UNID number, WO number, system number, serial number, and test equipment information on Attachment 2 as required, and,Click on "Continue with Test" to continue the test.

BFN Functional Testing of Lisega Large 00-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 17 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) [5.3.5] If an Activation Test is Selected After all the above steps have been completed, and PRIOR to starting the test (i.e., "As-Found" Activation Test), the test program will initiate a routine to set and stabilize the hydraulic system pressure at a calculated level sufficient to achieve the requested test load. During this period, the setpoint and actual pressures are displayed, along with the output voltage, and a "count down" value. When the pressure is near the desired value, the countdown value will decrement towards zero. If the pressure fluctuates out of limits, the countdown will reset to six. Once the pressure is stable enough to let the countdown complete, the test will begin automatically.

                          - OBSERVE that the snubber activates in both directions to establish operability of the snubber in the "As-Found" condition.
                          - RECORD all necessary information on Attachment 2, as appropriate.

NOTE Forcing a test may allow the machine to overstress the snubber during the test! If the user wishes to force a test, clicking the "Force the Test" button will initiate the test regardless of pressure. Clicking the "Abort the Test" button will cause the test cycle to abort without performing the test.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 18 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) [5.3.6] If Drag Test is Selected If a Drag Test (i.e., ID, AC, and FD test sequence for "As-Left", and AC, FD test sequence for "As-Found" test) is selected, the test system will automatically begin the drag test. The system will determine the starting position of the snubber, and choose the initial test direction to move towards the farthest end of stroke. The drag speed will be automatically controlled to the target speed set earlier. This test is to VERIFY free travel of the piston rod through its full stroke. The Raw Test Data graphed in real time is reviewed to:

                      - VERIFY that freedom of movement is NOT restricted, and drag force of the snubber does not exceed 15,000 pounds.
                      - RECORD this information on Attachment 2, as appropriate.

[5.3.7] Printing the Results After the test on the surrogate snubber is complete, the calculations appropriate to that test are performed and the results are displayed on the screen. This allows the user to review and determine if the "As-Found" test results meet the "As-Found" acceptance criteria in Section 6.0B, or Section 6.0B.2 for the "As-Left" test, and plot the test results. For Activation tests on acceleration limiting snubbers only, the calculated acceleration lines will be printed if they are displayed on the graph when printing is requested.

                      - If the results are within the acceptance range for the type of test performed, THEN CLICK on the "Print Test" button to open the standard Windows printer dialog box. SELECT the proper printer, and CLICK "OK" to start the printing.
                      - ATTACH the Printed Results of the surrogate snubber tests in Attachment 2, as part of the work package.

CONVERT the surrogate snubber test results to the Lisega Large Bore (Type 31 21 50) values, using the conversion factors and nomenclature in Attachment 2. VERIFY that the converted values meet the acceptance criteria, and RECORD in Attachment 2.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 19 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) [5.3.8] Saving the Test Results To save a test file to disk, click the "Save Test" button. This saves the test results in the "testdata" directory. The file name of the saved test result is as follows: WorkOrdernumber Serialnumber TestDate TestType.csv Where: Work Order number is the value entered in the work order number entry Serialnumber is the value entered in the serial number entry TestDate is the date when test was performed TestType is ID for initial drag tests, AC for activation tests and FD for final drag tests. Tests are saved as comma separated variable files and may be directly loaded into Excel or similar spreadsheet programs as desired. [5.3.9] Running Another Test CLICK on the Type of test to be performed. The results of the last test will be erased, and the graph will rescale for the test to be done.

                      - REPEAT the procedure from Step 7.5[5.3.2] to complete Running Another Test (i.e., the "As-Left"), as needed.

[5.3.10] Testing Another Snubber SELECT a new snubber type, if necessary, from the snubber pull down list. If a snubber of the same type is to be tested, the user has to only change the serial number, hanger number, and work order entries.

                      - REPEAT this procedure from Step 7.5[5.3.1] to complete Testing Another Snubber.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 20 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) NOTES

1) At this time the machine has completed Running the Test. Unless you are leaving the building, leave the machine running so it will NOT have to be warmed up to perform another test (i.e., the "As-Left" test as needed).

2) Do NOT shutdown the console power without exiting Windows properly.

[5.4] Quitting and Shutting Down the System TURN OFF the 480Vac power on the HPU. On the computer screen, SELECT EXIT from the File Menu. When the Windows screen appears, CLICK on START, then SHUTDOWN, and click on SHUT DOWN the Computer, then CLICK OK. When the computer has completely shutdown, TURN OFF the main power switch on the current control consoles. [6] DETERMINE if the "As-Found" test result values as CONVERTED for the Lisega Large Bore snubber (Type 31 21 50) meet the acceptance criteria in Section 6.0B.1. [7] IF the CONVERTED test result values for the Lisega Large Bore snubber (Type 31 21 50) meet the "As-Found" acceptance criteria, THEN ENTER the information on Attachment 2. PLACE the tested valves in storage until needed. [8] IF the CONVERTED test result values meet the "As-Left" Acceptance Criteria in Section 6.OB.2, THEN ENTER the information on Attachment 2.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E U'lit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 21 of 49 7.5 "As-Found" and "As-Left" Functional Test Using STB-200 Test Machine (continued) [9] IF, based on the As-Found test results, a snubber is determined to be inoperable, including case specific criteria, THEN

• NOTIFY the Shift Manager or Unit Supervisor immediately.
• REQUEST a failure analysis on Attachment 3 and a supported component or system analysis on Attachment 4, as necessary.
• DETERMINE the subsequent test lot (sample plan), as required.
• SELECT the number of restraints equal to 10 percent of the remaining snubbers in that subgroup.
• In general, SELECT the restraints with the most time from the previous test.
• FILL OUT ALL applicable sections of Attachment 2, as required.
• ENSURE test data package is ready for Shift Manager/Unit Supervisor authorization.
• PERFORM applicable functional test for the subsequent test lot (sample plan).

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 22 of 49 7.6 Results Evaluation NOTE The following reviews are usually performed by the Snubber Engineer/SE Designee, or a Site Engineering Civil representative: [1] REVIEW all of the test data on Attachment 2, as applicable. [2] IF any snubber is determined to have been inoperable, THEN

• ENSURE that the Shift Manager/Unit Supervisor has been notified of the inoperable snubber.
• INITIATE a PER in accordance with SPP-8.1 and SPP-3.1.
• INITIATE a WO to replace or rebuild the snubber, if necessary.

               "     PERFORM a failure evaluation of any inoperable snubber and DOCUMENT on Attachment 3.

• PERFORM the supported system or component evaluation on Attachment 4.

               "     SELECT the subsequent test lot as required for functional test failure, or other snubbers for verification, as specified on Attachment 6.

7.7 Data Sheet Review [1] VERIFY all of the necessary Attachments are included and all acceptance criteria have been met. [2] REVIEW the completed SI package for final acceptance. NOTE Computer generated data sheets containing information regarding the initial test log, subsequent test logs, rebuild, etc., should be submitted with the SI data package. [3] SUBMIT the completed data package for closure.

8.0 E3FN Unit 0 Functional Testing of Lisega Large Bore Torus Dynamic Restraint Snubbers ILLUSTRATIONS/APPENDIX/ATTACHMENTS 0-SI-4.6.H-2E Rev. 0007 Page 23 of 49 i Illustration 1 - Two Way Ball Valve Locations and Positions Illustration 2 - Cover and Valve Removal and Reinstallation Illustration 3 - Drain Hose Connection Illustration 4 - Oil Level in Valve Hole Prior to Replacing the Removed Valve Illustration 5 - Fluid Level in Surrogate Test Snubber Holes Illustration 6 - Lisega Fluid Level Measurement of Surrogate Test Snubber Illustration 7 - Lisega Piston Position Measurement Illustration 8 - Lisega Minimum Fluid Level Plunger and Piston Position Measurement in the Field Appendix A - Subgrouping and Service Life Monitoring of Snubbers Appendix B - Common Modes of Snubber Failure and Possible Causes Appendix C - Daily Startup Procedure for the STB-200 Test Bench Attachment 1 - Surveillance Instruction Review Form Attachment 2 - Nomenclature, Conversion, As-Found and As-Left Test Data, Removal and Reinstallation Data Sheets for Lisega Large Bore Torus Dynamic Restraints Attachment 3 - Engineering Failure Analysis for Inoperable Snubbers Attachment 4 - Supported Component or System Analysis for Inoperable Snubbers Attachment 5 - Functional Test Case Specific Acceptance Criteria Attachment 6 - Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 24 of 49 Illustration I (Page 1 of 1) Two Way Ball Valve Locations and Positions POSITION I SLOT VERTICAL SLOT HORIZONTAL 2 WAY BALL VALVE

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 25 of 49 Illustration 2 (Page 1 of 1) Cover and Valve Removal and Reinstallation REMOVABLE PROTECTIVE CAP IW$7*f7flPIYL7tL[ REAR COVER HEX SCREWS REAR VALVE

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 26 of 49 Illustration 3 (Page 1 of 1) Drain Hose Connection t~Wkr*rt+uin ~"tstr~ :V 6ý

      . .. . . . . . . .  ..   . , . t..

4.9 ~ XO>.~fl~fl '2 b.7

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 27 of 49 Illustration 4 (Page 1 of 1) Oil Level in Valve Hole Prior to Replacing the Removed Valve

• ~ur~2, Oil laveliln )ro~rýt Vý9ve befo~e, replacin- the removedvFe

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 28 of 49 Illustration 5 (Page 1 of 1) Fluid Level in Surrogate Test Snubber Holes OIL LEVEL SHOULD BE AT THE UPPER EDGE OF THE CONNECTION BETWEEN THE FRONT AND REAR VALVE.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 29 of 49 Illustration 6 (Page 1 of 1) Lisega Fluid Level Measurement of Surrogate Test Snubber 22-.5 ' +/-t"-@ E = 28.5" FRONT VALVE, REAR VALVE - riIl \ L FLUID LEVEL INDICATOR

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 30 of 49 Illustration 7 (Page 1 of 1) Lisega Piston Position Measurement iREMOVABLE VALVES VALVE "X" from the first machfine groove, not the end of the indicator

BFN Functional Testing of Lisega Large O-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 31 of 49 Illustration 8 (Page 1 of 2) Lisega Minimum Fluid Level Plunger and Piston Position Measurement in the Field

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 32 of 49 Illustration 8 (Page 2 of 2) Lisega Minimum Fluid Level Plunger and Piston Position Measurement in the Field If the as-found Reservoir plunger position "L" is below the minimum value given, the fluid level is unacceptable. ADD AP 280 Silicon hydraulic fluid to the snubber to bring the reservoir, as close as possible, to its optimum (maximum) level. No functional testing of the Lisega Torus Dynamic Restraint Snubber is required due to this refilling operation. Nomenclature: X - Measurement of the piston position in inches from the front head of the snubber to the first machined groove on the indicator, NOT the end (See ILLUSTRATION 7). L Minimum - The minimum fluid level in the reservoir for the piston position measured from the front of the reservoir to the end of the reservoir piston rod. L Maximum - The maximum fluid level in the reservoir for the piston position measured from the front of the reservoir to the end of the reservoir piston rod. Ifthe "X"' measurement.shown in Illustration 7 is between the numbers given in the table below for "X", then go to the next lower reading for "X" to determine the L Minimum and L Maximum.

                                  "X"            L              L (INCHES)      MINIMUM       MAXIMUM (INCHES)       (INCHES) 0.000          2.49           3.27 0.125          2.39           3.18 0.250          2.30           3.09 0.375          2.21           3.00 0.500          2.12           2.91 0.625          2.03           2.81 0.750          1.93           2.72 0.875          1.84           2.63 1.000         1.75           2.54 1.125         1.66           2.45 1.250         1.57           2.35 1.375         1.47           2.26 1.500         1.38           2.17

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 33 of 49 Appendix A (Page 1 of 1) Subgrouping and Service Life Monitoring of Snubbers 1.0 SUBGROUPINGS For functional testing, the snubbers belong to one subgroup as described below: Subgroup 5 Bergen-Paterson and Lisega Torus Dynamic Restraint hydraulic snubbers. For functional testing of Bergen Paterson snubbers, see O-SI-4.6.H-2C. When snubbers are added, deleted, or changed, based on modifications, they are added or deleted from their appropriate subgroups. If the added snubbers do NOT fit an existing subgroup, a revision to this SI describing the new subgroup or a revision to an existing subgroup is required. There have been no failures of snubbers from subgroup 5; therefore, testing 10 percent of the snubbers in these areas each refueling outage satisfies the intent of the surveillance requirement.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 34 of 49 Appendix B (Page 1 of 1) Common Modes of Snubber Failure and Possible Causes TYPE COMMON MODES OF FAILURE POSSIBLE CAUSE HYDRAULIC No Lockup Wrong size poppet Wrong size poppet spring Poppet frozen or blocked open Excessively low or no fluid Lockup adjustment set improperly Damaged piston rod seal Damaged 0-ring High Lockup Wrong size poppet Wrong size poppet spring lockup velocity Adjustment set improperly Damaged O-ring Low Lockup Broken poppet spring Poppet frozen or blocked closed Lockup velocity Adjustment set improperly Foreign objects in fluid High Bleed Defective or damaged poppet Defective or damage poppet seat Wrong size poppet Bleed adjustment set improperly Damaged O-ring No Bleed Foreign objects in fluid Bleed adjustment set improperly Miscellaneous Hardware. Improper installation Improper handling or abuse Misapplication. Overload Vibration or wear

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 35 of 49 Appendix C (Page 1 of 3) Daily Startup Procedure for the STB-200 Test Bench 1.0 DAILY STARTUP PROCEDURE [1] WARM-UP Exercise both benches (i.e., small and large) by selecting the Manual Control Panel function from the Tool Menu. Clicking on "Auto Exercise" in the Operating Mode block will cause the selected bench to automatically stroke back and forth. The system should be run this way until the oil temperature is above approximately 70°F or smooth operation is attained. Both test benches should be exercised. To change from one bench to the other, click on the bench label. [2] CHECK THE PRESSURE TRANSMITTER NOTE This instrument does NOT provide safety-related data. This check is optional. In the Manual Control Panel mode, SELECT Manual in the Operating Mode block. Turn the "HP Pump" on, then use the HP Pump slider to increase the pressure command setting until the "Pressure" reading is approximately 2000 psi. CHECK the 0-3000 psi gauge in the front of the HPU. The two readings should be within - 200 psi. [3] PARK THE RAM SELECT the "Park the Ram" to prepare the bench for the Daily Calibration Check. This should be done for both benches. [4] SHUT DOWN THE MANUAL CONTROL PANEL Click on "SHUT DOWN" to exit the Manual Control Panel.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 36 of 49 Appendix C (Page 2 of 3) Daily Startup Procedure for the STB-200 Test Bench 2.0 STATUS CHECK A. During the warm-up period, the frame drive cylinders should be stroked using the proportional valve and/or the jog/drag valve. B. The system should be checked for loose fittings, bolts, etc. C. The filter indicators should be watched during cylinder stroking to ensure that they are not illuminating. D. If the indicators are illuminating, the filters should be changed before continuing with operation of the machine or any testing. 3.0 DAILY CALIBRATION CHECKS The following calibration checks assure the functionality of the instrument and Data Acquisition and control System (DAS) for testing. They do NOT take the place of full system calibrations which must be performed on a periodic basis. The instrument system (DAS system and transmitters) should be powered up for 30 minutes before any checks or testing is performed. Prior to performing this function, both rams should have been "Parked" using the "Park the Ram" function in the Manual Control Panel. [1] SELECT THE DAILY CALIBRATION FUNCTION SELECT the Daily Calibration Check function from the "Tools" menu. [2] CONNECT THE LOW RANGE LOAD CELL AS DIRECTED If directed to by the software, electrically connect the Low Range Load Cell as instructed. The load cell does not need to be mechanically mounted in the test bench, but it must be connected to its electrical cable. [3] STORE THE "ZERO" CALIBRATION READINGS For each instrument click the "STORE" button in the "ZERO" column on the Daily Calibration screen for that instrument. The zero reading will be captured in the "Actual" "Zero" column. If it is within limits, the box will turn gray. If it is not within limits, the box will turn yellow.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 37 of 49 Appendix C (Page 3 of 3) Daily Startup Procedure for the STB-200 Test Bench 3.0 DAILY CALIBRATION CHECKS (continued) [4] STORE THE "SPAN" CALIBRATION READINGS For each instrument, press in the "CAL" button on the front of the instrument, then click the "STORE" button in the "SPAN" column on the Daily Calibration screen for that instrument. The span reading will be captured in the "ACTUAL" "SPAN" column. If it is within limits, the box will turn gray. If it is not within limits, the box will turn yellow. [5] PRINT THE REPORT When all readings for both benches have been stored, click on the "PRINT" button to print the Daily Calibration Report. If the report is "SATISFACTORY", continue the testing. If the report is "UNSATISFACTORY", halt and correct the problem before continuing.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 38 of 49 Attachment 1 (Page 1 of 1) Surveillance Instruction Review Form REASON FOR TEST: o Scheduled Surveillance o System Inoperable (Explain in Remarks) UNIT MODE o Maintenance (See WO No. below) o Other (Explain in Remarks) W.O. SNUBBER SERIAL NO. UNID NO. PRE-TEST REMARKS: PERFORMED BY: Initials Name (Print) Name (Signature) NOTE: The following entries for contacting Shift Manager/Unit Supervisor shall be marked N/A if the snubber is NOT Inoperable. NOTIFY Shift Manager/Unit Supervisor when snubber found Inoperable. SM/UNIT SUPERVISOR CONTACTED Date Time NOTIFY Shift Manager/Unit Supervisor when snubber Operability is restored. SM/UNIT SUPERVISOR CONTACTED Date Time MECHANICAL MAINTENANCE REVIEWER Date Signature attests that I understand the scope and purpose of this instruction and that, to the best of my knowledge, it was properly performed in accordance with instruction in that: the recording, reduction, and evaluation of data is complete and correct; acceptance criteria is met or justification for exceptions is provided; portions of test performed were appropriate for specified test conditions or reasons for test; deficiencies were evaluated and dispositioned; reportability was evaluated; marginal results were evaluated with respect to potential for future problems based on operating experience and regulatory requirements; and instruction was complete except as noted in post-test remarks. SNUBBER ENGINEER/SITE Date ENGINEERING CIVIL REVIEWER SCHEDULING COORDINATOR Date POST-TEST REMARKS:

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 39 of 49 Attachment 2 (Page 1 of 5) Nomenclature, Conversion, As-Found and As-Left Test Data, Removal and Reinstallation Data Sheets for Lisega Large Bore Torus Dynamic Restraints NOMENCLATURE TYPE 312150 TEST/SURROGATE SNUBBER FORCE OF SNUBBER Fs *FT LOCK-UP VELOCITY **VLs *VET (ACTIVATION VELOCITY) BY-PASS VELOCITY **VBs *VT (RELEASE/BLEED RATE) I I

1. Fs value of 247 kips may be used as excerpted from Vendor Document Number: BFN-VTD-L329-0070.

CONVERSION Lock-up Lock-up velocity, in Tension: VLS Tension = 0.59 x VLT Tension VLs Tension = 0.59 x__ Lock-up velocity, in Compression: VLS Comp = 0.69 x VLT Comp VLS Comp = 0.69 x = By-pass velocity By-pass velocity, in Tension: VBs Tension = 0.37 X VBT Tension x *FT FF~ VBs Tension = 0.37 x __ x = By-pass velocity, in Compression: VHs Comnp=O0. 3 9 xVBT Comp x F/5 FFT VBS Comp =0.39x_ x = Snubber Engineer/SE Designee Date Legend:

• - Data from the "Printed Test Result" of a functional test performed on Lisega Test/Surrogate snubber.

  -  CONVERTED value resulting from the above conversion for the Lisega (Type 312150) restraint.

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 40 of 49 Attachment 2 (Page 2 of 5) AS-FOUND TORUS DYNAMIC RESTRAINT TEST DATA W.O. No. Date: Snubber UNID Serial Number: Exam Number: Load Cell No. Snubber Rated Load: Calibration Due Date: Activation (in/min) Generic Performer Signature/ Date Acceptance Criteria* Tension 6 in/min Signature

                                                  < Activation Compression                      _              <_25 in/min               Date                  (AC)

Bleed (in/min) Tension Bleed takes place Signature after snubber Compression activation Date (AC) Drag (Ibs) Tension Max: MAXIMUM Signature Compression 15,000 Pounds Date (AC) Max: Copy of the plotted As-Found test results is attached to this data / sheet. Initials / Date

• Case specific Acceptance Criteria may be approved on Attachment 5.

Snubber meets Generic Acceptance Criteria: Yes No / Initials / Date Snubber meets Case Specific Acceptance Criteria: _Yes _No _NA / Initials / Date Ifneither the Generic nor Case Specific acceptance criteria has been met, Notify the Shift Manager or Unit Supervisor immediately. SNUBBER ENGINEER/SE DESIGNEE Date

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 41 of 49 Attachment 2 (Page 3 of 5) AS-LEFT TORUS DYNAMIC RESTRAINT TEST DATA W.O. No. Date: Snubber UNID Serial Number: Exam Number: Load Cell No. Snubber Rated Load: Calibration Due Date: Activation Acceptance Performer Signature/ Date (in/min) Criteria* Tension 6 in/min < Signature Activation Compression < 25 in/min Date (AC) Bleed (in/min) Tension Bleed follows Signature Compression Activation, shall be in the range of 0.24 Date (AC) in/min - 1.18 in/min Drag (Ibs) Tension Max: MAXIMUM Signature Compression 15,000 Pounds Date (AC) Max: Copy of the plotted As-Left test results is attached to this / data sheet. Initials / Date

• Case specific Acceptance Criteria may be approved on Attachment 5.

Snubber meets Generic Acceptance Criteria: Yes No / Initials / Date SNUBBER ENGINEER/SE DESIGNEE Date

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 42 of 49 Attachment 2 (Page 4 of 5) REMOVAL OF LISEGA TORUS DYNAMIC RESTRAINTS W.O. No. Unit Snubber UNID No. Serial No. Subgroup Test Lot: Initial Subsequent Exam No. Size Rated Load lbs. Design drawing number Shift Manager/Unit Supervisor and Snubber Engineer/SE Designee notified prior to removal of restraint for functional testing. Foreman/Designee Date Time As-Found Stroke/Piston Setting Required Stroke/Piston Setting Range (from Design drawing) The As-Found Stroke Setting is within the acceptable limits shown in the design drawing listed above. Yes No (AC) Performer Signature Date All fasteners for the As-Found snubber are secured and acceptable (i.e., no loose or missing fasteners on the component anchorage). Ifthe answer is "No", complete Attachment 6. Yes No (AC) Performer Signature Date

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 43 of 49 Attachment 2 (Page 5 of 5) REINSTALLATION OF LISEGA TORUS DYNAMIC RESTRAINTS W.O. No. Unit Snubber UNID No. Snubber reinstallation: Same snubber reinstalled Yes No If No, enter Lisega TDR serial number Serial Number (Lisega TDR) Snubber is reinstalled in proper location Yes No Snubber is reinstalled with base of housing up Yes No All locking devices are secured Yes No Cotter pins are spread Yes No N/A Spherical bearing greased Yes No N/A Gaps between spacers and spherical bearing are 1/16 inch each side, 1/8 inch total or less Yes No Snubber is tagged Yes No Bolts and jam nuts torqued Yes No N/A Anti-seize compound applied, as needed Yes No N/A As-Left Stroke Setting Torque Wrench No. Calibration Due Date Performer Signature Date The As-Left Stroke Setting is within the acceptable limits shown in the design drawing as verified. Yes No Performer Signature Date SHIFT MANAGER/UNIT SUPERVISOR notified of operable and reinstalled snubber. (AC) Foreman/Designee Date Remarks:

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 44 of 49 Attachment 3 (Page 1 of 2) Engineering Failure Analysis For Snubber Declared Inoperable WO No. Unit Snubber UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No. Lot

1. Describe the mode of failure as discussed on Appendix B.

o Locked up 0 High Drag Force 0 Snubber would not activate o Damage to snubber hardware 0 Other Explain (if necessary)

2. Describe the conditions of the failure:

3. Determine the cause of the failure, using Appendix B for the possible causes (disassembly of the snubber may be necessary):

4. For a snubber that does not activate, release, is locked up, damaged hardware, was the cause of the failure a design or manufacturing defect? 0 Yes 0 No Explain evaluation:

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 45 of 49 Attachment 3 (Page 2 of 2) WO No. Unit Snubber UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No. Lot

5. Snubber Failure classified as: 0 Location 0 Manufacturing 0 Design 0 Unknown 0 Other Explain:

6. Does the vendor need to be contacted? 0 Yes 0 No Vendor Name:

Person contacted: Date: Vendor's comments:

7. What subsequent testing is required because of this failure?

Subsequent Lot No. No. of snubbers to be tested

8. What corrective action and recurrence controls are to be taken?

Evaluation performed by: Date Snubber Engineer/SE Designee

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 46 of 49 Attachment 4 (Page 1 of 1) Supported System /Component Analysis For Inoperable Snubber WO No. _ _ _ _ _ _ Unit Snubber UNID No. Subgroup No. PER No. Mfg./Size Serial No. Rated Load Exam No.

1. Describe the condition(s) (e.g., snubber would not activate, was locked up, had excessive drag force, damaged hardware, etc.).

2. Attach the SE evaluation of the attached component:

3. Based on the results of the Engineering evaluation, has the snubber failure mode adversely affected the supported system or component?

Snubber Engineer/SE Designee Date

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 47 of 49 Attachment 5 (Page 1 of 1) Case Specific Acceptance Criteria WO No. Unit Snubber UNID No. PER No. Mfg./Size Subgroup No. Serial No. Rated Load Exam No.

1. Record the parameter(i.e., actuation, bleed, drag) and the test results that are outside the standard acceptance criteria:

2. Specify the case specific Acceptance Criteria and provide justification.

Site Engineering Civil Date

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 48 of 49 Attachment 6 (Page 1 of 2) Evaluation of Loose or Missing Attachment Fasteners, or of "As-Found" Stroke Setting Outside of Acceptable Range This evaluation shall be performed when fasteners, used for attachment of snubber to component, and to snubber anchorage, are discovered loose or missing prior to the As-Found functional testing. This evaluation also shall be performed if the snubber "As-Found setting is outside of the acceptable range specified on design drawing. W.O. No. Unit Date Discovered Snubber UNID No. Serial No. Subgroup Exam No. Size Rated Load Lbs.

1. Describe the discovered condition and, if possible, determine cause:

Performer: Date Performer: Date

BFN Functional Testing of Lisega Large 0-SI-4.6.H-2E Unit 0 Bore Torus Dynamic Restraint Rev. 0007 Snubbers Page 49 of 49 Attachment 6 (Page 2 of 2) Items 2, 3, and 4 are to be completed by Site Engineering Civil.

2. Evaluate to determine whether the cause may be localized or generic. Use this evaluation to select and list other suspect snubbers for verification, as applicable.

3. Describe the corrective action(s) and provide the As-Found test result.

4.

Conclusion:

Is the snubber operable? Yes No Justification If"No", notify the Shift Manager or Unit Supervisor immediately. Then complete or request a failure analysis using Attachment 3, and a supported component or system analysis on Attachment 4, as necessary. Evaluated by: Date Site Engineering Civil

Attachment H BFN Modification and Addition Instruction, MAI-4.10, Piping Clearance Instruction

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT MODIFICATION AND ADDITION INSTRUCTION MAI-4.10 PIPING CLEARANCE INSTRUCTION REVISION10 PREPARED BY: KENNETH R. DALTON PHONE: 6219 RESPONSIBLE ORGANIZATION: MODIFICATIONS APPROVED BY: RICHARD V. DRAKE DATE: 02/01/2005 EFFECTIVE DATE: 02/01/2005 LEVEL OF USE: INFORMATION USE QUALITY-RELATED

REVISION LOG Procedure Number: MAI-4.10 Revision Number: 10 Pages Affected: 1, 4, 5, 6, 7, 8, 9 Pagination Pages: None Description of Change: IC- 012 Page 1 - Revised Table of contents Page 4 - Removed reference to MAI- 1.3 and MTS 175 verification training requirements. Page 5 - Deleted section 6.1 and renamed 6.2 as 6.1. Page 6,7,8,9 - Changed 6.2 to 6.1

REV 0010 Page I MAI-4.10 PIPING CLEARANCE INSTRUCTION TABLE OF CONTENTS SECTION PAGE 1 .0 PURPOSE ....................................................... 2 2 .0 SCOPE ......................................................... 2 3 .0 REFERENCES .................................................... 3 4 .0 DEFINITIONS .................................................... 4 5.0 RESPONSIBILITIES .............................................. 4 6.0 PROCEDURE/ACCEPTANCE CRITERIA ................................. 5 6.1 Clearance Requirements ................................... 5 7 .0 RECORDS ....................................................... 8

REV 0010 Page 2 MAI-4.10 1.0 PURPOSE This procedure provides the requirements for new modification and maintenance work to ensure that sufficient space is available for thermal and seismic deflection of piping, components, and supports. Compliance with these requirements will ensure that piping is free to function with the as-analyzed conditions without detrimental contact with other components/features and that all future work performed by plant personnel will not invalidate the analysis of Seismic Class I piping systems or Seismic Class II piping within the water spray program as evaluated by EQE Report 51001.02-ROO1. [See CAQR BFP870631 (R76 870831 894)] 2.0 SCOPE Seismic Class I piping has been analyzed based on as-built data obtained from piping system walkdowns. During the walkdowns, all objects within a 2" envelope of the piping were identified. Using the pipe movement data from the piping analyses, clearances were evaluated and modifications were performed as necessary. Where the piping analyses indicated movement greater than 2", additional walkdowns were performed to identify any potential interferences. In addition to the Seismic Class I piping, Seismic Class II water filled piping was walked down to evaluate water spray hazards for Unit 2 operation. This MAI ensures that future modification and maintenance work does not invalidate these existing clearance evaluations. This procedure applies to the following activities: All new modification and maintenance activities (except for cases where identical replacement components are used) which could compromise the clearance envelope required for piping, components and supports for all units. This is not to be construed to mean that existing objects (previously installed) less than 3" from the pipe need to be reported per this procedure. This only applies when a new item is added or an existing item is moved closer to the pipe than its original position.

REV 0010 Page 3 MAI-4.10

3.0 REFERENCES

CAQR BFP 870631 (R76 870831 894). DCN Q 26202A NUREG CR 4306. REG GUIDE 1.29. MMDP-I - Maintenance Management System. SPP-9.3 - Plant Modification and Design Change Control. SPP-8.3 - Modification Test Program. NADP-I - Conduct of Quality Assessment and Inspection. SPP-3.1 - Corrective Action. NEDP-11 - Design Input Walkdown Controls G Construction of Piping Systems for Boiling Water Reactor Nuclear Power Plants. G Installation, Modification, and Maintenance of Electrical Conduit, Cable Trays, Boxes, Containment Electrical Penetrations, Electrical Conductor Seal Assemblies, Lighting and Miscellaneous Systems. G Installation, Modification, and Maintenance of Pipe Supports and Pipe Rupture Mitigative Devices. G Installation, Modification, and Maintenance of Insulation. G Piping Installation, Modification, and Maintenance. NlE-003 - Instrument and Instrument Line Installation and Inspection. NIM-001 - Installation, Modification, and Maintenance of Thermal Anti-sweat Insulation. EQE Report 51001.02-RO01 Evaluation of Seismic-Induced Spray Hazards at BFNP (B22 91 0215 101). 3-47E491-837 - Mechanical Fire Protection System Plan EL 565.0.

REV 0010 Page 4 MAI-4.10 4.0 DEFINITIONS Piping - For the purpose of this MAI, the term "piping" includes not only the pipe itself, but also pipe-mounted components (e.g., valves, flanges, etc.) and pipe supports that may move with the pipe (e.g., rods, snubber, stuts, etc.). "Piping," as used in this document, also encompasses tubing. Clearance Envelope - The space around the piping system/component being evaluated for potential interferences. Responsible Engineer - The engineer responsible for the activity being performed (Mods, SE, etc.). Interference - An unintended restriction of the thermal or seismic displacement of piping. Potential Clearance Discrepancy (PCD) - Any item found infringing upon the clearance envelope as defined in this procedure. Surface - The outermost surface of the adjacent piping or component. Where insulation is required but not yet installed, the "surface" shall be that of the insulation when installed. 5.0 RESPONSIBILITIES 5.1 Site Modifications and Maintenance Assure Maintenance and Modification work is performed without violation of the clearance envelope as defined in section 6.1 and document on tle applicable MAI Data Sheet. If proposed installation creates violation of clearances, a PCD shalli be initiated/checked by Field Engineering (FE) and forwarded to Site Engineering (SE) for approval. 5.2 Site Engineering (SE)

            - Evaluate PCD.
            - If a modification is required to resolve PCD, initiate     a PIC or WO, as applicable.
            - Return dispositioned PCD to Modification/Maintenance.

NOTE: No QC Inspection is required for this Procedure (MAI-4.10). Potential clearance discrepancies that are identified on existing piping listed in section 6.1 shall be identified and documented on MAI-4.10 Data Sheet 1 (PCD) by FE and dispositioned by (SE). New or revised components (Piping, Pipe supports, etc.) are subject to applicable procedure clearance requirements.

REV 0010 Page. 5 MAI-4.10 6.0 PROCEDURE/ACCEPTANCE CRITERIA 6.1 Clearance Requirements Seismic Class I piping and Seismic Class II water filled piping is considered as requiring a nominal clearance of 3 inches from the surface (see definitions) to permit thermal and seismic motions without detrimental contacts with any other elements of the plant. Nominal clearance less than 3 inches which are shown and dimensioned on the design drawings are not required to be identified as a discrepancy. All other clearance discrepancies shall be documented on the Potential Clearance Discrepancy (PCD) and submitted to Site Engineering for evaluation. Consideration shall be given to the following drawings which show Unit 1, Unit 2 and Unit 3 and common piping with thermal movements greater than 3 inches. 1-47B400-2001, Main Steam piping inside Unit 1 drywell (A Main Steam Line) 1-47B400-2002, Main Steam piping inside Unit 1 drywell (B Main Steam Line) 1-47B400-2003, Main Steam piping inside Unit 1 drywell (1" Drain off 10" Supply to HPCI) 1-47B400-2004, Main Steam piping inside Unit 1 drywell (C Main Steam Line) 1-47B400-2005, Main Steam piping inside Unit 1 drywell (C Main Steam Line) 1-47B400-2006, Main Steam piping inside Unit 1 drywell (D Main Steam Line) 1-47B400-2007, Main Steam piping inside Unit I drywell (3" Steam Line Drain) 1-47B400-2008, Main Steam piping inside Unit 1 drywell (3" Steam Line Drain) 1-47B401-2001, Main Steam SRV piping inside Unit I drywell (1-PCV-1-18) 1-47B401-2002, Main Steam SRV piping inside Unit 1 drywell (1-PCV-1-19) 1-47B401-2003, Main Steam SRV piping inside Unit 1 drywell (1-PCV-1-22) 1-47B401-2004, Main Steam SRV piping inside Unit 1 drywell (1-PCV-1-31) 1-47B401-2005, Main Steam SRV piping inside Unit 1 drywell (1-PCV-1-30) 1-47B401-2006, Main Steam SRV piping inside Unit 1 drywell (1-PCV-1-41) 1-47B401-2007, Main Steam SRV piping inside Unit I drywell (1-PCV-1-4) 1-47B415-2001, Reactor Water Level Ref. Leg piping inside Unit 1 drywell (Nozzle N12B) 1-47B415-2002, Reactor Head LP Seal Leakoff piping inside Unit I drywell 1-47B415-2003, Reactor Head HP Seal Leakoff piping inside Unit I drywell 1-47B455-2001, HPCI piping in Unit 1 reactor building (14" pipe) 1-47B455-2002, HPCI piping inside Unit 1 drywell (10" supply off of Main Steam Line) 1-47B465-2001, RPV Head Vent piping inside Unit 1 drywell 1-47B465-2002, RPV Head Vent piping inside Unit 1 drywell 1-47B465-2003, RPV Head Vent piping inside Unit 1 drywell 1-47B468-2001, CRDH piping in Unit I reactor bldg (vicinity of support 1-47E468-131) 1-47B468-2002, CRDH piping in Unit 1 reactor bldg (vicinity of support 1-47E468-115) 1-47B468-2003, CRDH piping in Unit I reactor bldg (vicinity of support 1-47E468-123) 1-47B468-2004, CRDH piping in Unit 1 reactor bldg (vicinity of support 1-47E468-131) 1-47B468-2005, CRDH piping in Unit I reactor bldg (vicinity of support 1-47E468-120) 1-47B468-2006, CRDH piping in Unit I reactor bldg (vicinity of support 1-47E468-122) 1-47B468-2007, CRDH piping in Unit I reactor bldg (vicinity of support 1-47E468-125) 1-47B468-2008, CRDH piping in Unit 1 reactor bldg (vicinity of support 1-47E468-125)

REV 0010 Page 6 MAI-4.10 6.1 Clearance Requirements (continued) 2-47B400-2001, Main Steam SRV piping inside Unit 2 drywell 2-47B400-2002, Main Steam SRV piping inside Unit 2 drywell 2-47B400-2003, Main Steam SRV piping inside Unit 2 dryweli 2-47B400-2004, Main Steam SRV piping inside Unit 2 drywell 2-47B400-2005, Main Steam SRV piping inside Unit 2 drywell 2-47B400-2006, Main Steam SRV piping inside Unit 2 dryweli 2-47B400-2007, Main Steam SRV piping inside Unit 2 drywell 2-47B400-2008, Main Steam SRV piping inside Unit 2 drywell 2-47B400-2009, Main Steam SRV piping inside Unit 2 drywell 1-47B451-2001, EECW piping in Unit 1 reactor building 1-47B451-2002, EECW piping in Unit 1 reactor building 1-47B451-2003, EECW piping in Unit 1 reactor building 2-47B451-2004, EECW piping in Unit 2 reactor building 2-47B451-2005, EECW piping in Unit 2 reactor building 2-47B451-2006, EECW piping in Unit 2 reactor building 2-47B452-2001, RHR piping in Unit 2 reactor building 2-47B455-2001, HPCI piping in Unit 2 reactor building 2-47B456-2001, RCIC piping in Unit 2 reactor building 2-47B465-2001, RPV vent piping, inside Unit 2 drywell 0-47B590-2001, CO2 piping, in Unit 1 reactor building 2-47B600-2001, Sample and Water Quality piping, inside Unit 2 drywell 2-47B600-2002, Control Air piping in Unit 2 reactor building 2-47B600-2003, Containment Inerting piping in Unit 2 reactor building 2-47B600-2004, Containment Inerting piping in Unit 2 reactor building 2-47B600-2005, Containment Inerting piping in Unit 2 reactor building 2-47B600-2006, Containment Inerting piping in Unit 2 reactor building 2-47B650-2001, Feedwater instrument piping in Unit 2 drywell

REV 0010 Page 7 MAI-4.10 6.1 Clearance Requirements (Continued) 3-47B400-2001, Main Steam SRV piping inside Unit 3 dryweli 3-47B400-2002 Main Steam SRV piping inside Unit 3 drywell 3-47B400-2003, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2004, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2005, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2006, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2007, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2008, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2009, Main Steam SRV piping inside Unit 3 drywell 3-47B400-2010, Main Steam Drain Pipiing inside Unit 3 drywell 3-47B465-2001-1, RPV Head Vent pipin g inside Unit 3 dryweli 3-47B465-2001-2, REV Head Vent pipin g inside Unit 3 drywell 3-47B462-2001, Standby Liquid Control1 piping in Unit 3 reactor building 3-47B451-2001, EECW piping in Unit 3 reactor building 3-47B406-2001, RWCU piping in Unit 3 reactor building 3-47B456-2001, RCIC piping in Unit 3 reactor building 3-47B456-2005, RCIC piping in Unit 3 reactor building 3-47B455-2113, HPCI piping in Unit 3 reactor building 3-47B455-2114-1, HPCI piping in Unit 3 reactor building 3-47B455-2114-2, HPCI piping in Unit 3 reactor building 3-47B468-2001, CRD Scram Discharge p:i ping in Unit 3 reactor building 3-47B468-2002, CRDH piping in Unit 3 reactor building 3-47B468-2003, CRDH piping in Unit 3 reactor building 3-47B468-2004, CRDH piping in Unit 3 reactor building 3-47B468-2005, CRDH piping in Unit 3 reactor building 3-47B468-2006, CRDH piping in Unit 3 reactor building 3-47B415-2001, Reactor Head Low Pressure Seal Leakoff piping inside Unit 3 drywell 3-47B415-2002, Reactor Head High Pressure Seal Leakoff piping inside Unit 3 drywell 3-47B600-2001, Reactor Vessel Level Instrumentation piping inside Unit 3 drywell

REV 0010 Page 8 MAI-4.10 6.1 Clearance Requirements (Continued) The clearance requirements apply to piping and all components associated with the piping including valves and their operators, in-line tanks and filters, pumps, equipment, or supports which are not fixed to a foundation and moves with the piping system. If the other component is a pipe, the pipe clearance envelope is doubled. Field activities that infringe upon this 3" envelope shall be documented as defined in this procedure. Clearances from Unit 3 Fire Protection (FP) piping, down stream of the FP Flow Control Valves 3-FCV-26-77 and 3-FCV-26-37 shall be in accordance with Drawing 3-47E491-837. Piping within an instrument panel is excluded from the requirements of this procedure when the piping, and the components within the clearance envelope of the piping, are all attached to the panel. Tubing within tube track is also excluded from the requirements of this procedure, except when the tube track is within 3" of a pipe. Special attention should be paid to equipment with moving parts such as rising stems on valves. Sufficient clearance must be maintained for moving parts to cycle to their limits and still provide minimum required clearance (3") to other components or features. When checking clearance envelope of uninsulated piping, verify that this piping will remain uninsulated, and is not required to be insulated by design output documents. (Refer to 0-47E235 series drawings - System Insulation Boundaries.) All modification or maintenance work in the areas listed below shall meet the clearance requirements of this procedure: minimum of 3" between the surface of the pipe and the modified component or feature.

• Reactor Building (including the Control Bay)

   "  Reinforced Concrete Chimney
   "   Pumping Station Structure, including the Residual Heat Removal

• Service Water Intake Structure
• Diesel Generator Buildings

   "  Equipment Access Lock
   "   Standby Gas Treatment Building
   "  Off Gas Treatment Building
   "  Vacuum Pump Building
   "  Radwaste Building:      exterior wall adjacent to Diesel Generator Building (Waste Surge and Waste Collection Tank Room)

REV 0010 Page 9 MAI-4.10 6.1 Clearance Requirements (Continued) Any infringement of the clearance envelope should be evaluated prior to or at the time of installation to limit the impact should rework be required. NOTE: If the PCD can be eliminated by notching insulation in accordance with Specification G-82, the Responsible Engineer shall submit a Work Order (WO) to have the insulation notched. If insulation notching will not resolve the PCD, the PCD will be transmitted to Site Engineering (SE). 7.0 RECORDS Data Sheet 1 - Potential Clearance Discrepancy Form The completed PCD is a QA record and will be retained as a lifetime record by Records Management (RM). Working files are classified as nonpermanent-QA records. Appropriate requirements are addressed in SPP-2.4. A copy of the completed PCD will be kept with the work document and the original Data Sheet 1 will be transmitted to SE-Lead Civil Engineer prior to/or upon closure of the work document. END OF TEXT

Attachment I BFN Modification and Additions Instruction, MAI-4.2A TVA-BFNP Piping/Tubing Supports

Browns Ferry Nuclear Plant Unit 0 Modification And Additions Instruction MAI-4.2A TVA-BFNP Piping/Tubing Supports Revision 0038 Quality Related Level of Use: Information Use Effective Date: 12-01-2007 Responsible Organization: MMG, Mechanical Maintenance Prepared By: Annie Hackett Approved By: William M. Hill

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 2 of 63 Current Revision Description Pages Affected: All Type of Change: INTENT Tracking Number: 040 This procedure has been converted from Word 95 to Word 2003 (XP) using Rev 37.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 3 of 63 Table of Contents 1.0 PURPOSE ............................................................................................................ 4 2.0 SCOPE ......................................................................................................................... 4

3.0 REFERENCES

.........................................................................................................                     4 4.0   DEFINITIONS ........................................................................................................                     6 5.0   RESPONSIBILITIES ..............................................................................................                         10 6.0   PROCEDURE/ACCEPTANCE CRITERIA .............................................................                                             11 6.1   General Requirements ..........................................................................................                         11 6.2   Installation Instructions ...........................................................................................                   25 7.0   RECORDS ........................................................             .......................................................... 41 7 .1  Q A R e co rd ..................................................................................................................        41 7.2   Non-QA Records ....................................................................................................                     41 8.0   ATTACHMENTS ....................................................................................................                        41 :     Support Fabrication Tolerances .........................................................                                    42 :     Support Installation Tolerances ........................................................                                    44 :     Deleted ..................................................................................................                  47 :     Figures ..................................................................................................                  48 :     Pipe Rupture Mitigative Devices ........................................................                                    50 :     Permanent Support Removal Sketch ..................................................                                         57 :     Staking of Carbon Steel Spherical Bearings on Struts and Snubbers ...........................................................................                             58 :     Shimming to Obtain Clearance on Pipe Supports .............................                                                 60 : Verification Checklist ...........................................................................                              62

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 4 of 63 1.0 PURPOSE A. This instruction establishes minimum requirements and tolerances for the fabrication, verification, installation, and modification of Class I and II pipe supports and all pipe rupture mitigative devices. Unless otherwise noted, these requirements for pipe supports include the supports for piping and tubing. 2.0 SCOPE This instruction only applies when implemented by specific drawing reference to General Engineering Specification G-43. Pipe support installation and modification shall be in compliance with G-43 and the appropriate plant support design output documents. Any changes in the installation of pipe supports which fall within the tolerances of this specification do not require drawing revisions, or any reference to "as constructed" dimensions, unless specifically stated herein. Where two tolerances in this document appear to conflict (i.e., two separate requirements), the more restrictive tolerance shall govern.

3.0 REFERENCES

General Engineering Specification G-43, "Installation, Modification, and Maintenance of Pipe Supports and Pipe Rupture Mitigative Devices." [NRC/C] All vendor information and instructions as specified by the design drawing, applicable bill of materials or work instructions. DCC Control No. - 109 Contract No. 828819, Pipe Hanger And Support Manual Vol. I. [NRC Report 85-26] General Engineering Specification G-29, Process Specification 4.M.1.3, "Material Fabrication and Handling Requirements." General Engineering Specification G-29, Process Specification 4.M.1.1, "Material Fabrication and Handling Requirements Austenitic Stainless Steel." General Engineering Specification G-29,Process Specification 4.M.4.4 "ASME Section III and Non-ASME Section III (Including ANSI/ASME B31.1, and ANSI B31.5) Bolting Material." MAI-1.3, General Requirements for Modifications. MAI-4.4A, Instrument Line Installation. MAI-4.10, Piping Clearance Instruction. MAI-5.1A, Expansion Shell Anchors Installation. MAI-5.1 B, Wedge Bolt (WB) Anchor Installation.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 5 of 63

3.0 REFERENCES

(continued) MAI-5.1C, Undercut (UC) Concrete Anchors Installation. MAI-5.1 D, Installation of Thru-Bolts. MAI-5.2, Bolting and Structural Connections. MAI-5.3, Protective Coatings. MAI-5.4, Concrete Removal, Repair, Grouting, and Drypacking. MAI-5.7, Painting and Coating. MAI-5.9, Fabrication and Installation of Structural and Miscellaneous Steel. SPP-2.4, Records Management. SPP-3.1, Corrective Action Program. SPP-9.1, ASME Section XI. MMDP-1, Maintenance Management System MMDP-10, Controlling, Welding, Brazing and Soldering Processes. SPP-4.1, Procurement of Material, Labor and Services. SPP-4.2, Material Receipt and Inspection. SPP-4.3, Material Storage and Handling. SPP-4.4, Material Issue, Control, and Return. NEDP-4, Q-List and UNID Control. MCI-0-000-GNG002, Temporary Removal and Reinstallation of Pipe and Tubing Supports. MPI-0-000-SNBOO4, Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Grinnell Hydraulics and Torus Dynamic Restraint Snubbers. 0-SI-4.6.H-2A, Functional Testing of Mechanical Snubbers. 0-SI-4.6.H-2B, Functional Testing of Bergen-Patterson Hydraulic Snubbers. 1,2,3-SI-4.6.G, Inservice Inspection Program. O-TI-252, Verification, Pinning and Setting of Variable Spring Supports.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 6 of 63

3.0 REFERENCES

(continued) Q15273A, Spring Can Scales. CD-Q0999-940314, Qualification of Staking of Spherical Bearings. 47B435 Series Drawings, Mechanical General Notes, Pipe Supports. 4.0 DEFINITIONS ANCHOR - A rigid restraint providing substantially full fixation, permitting neither translatory nor rotational displacement of the pipe. Anchor type examples include box, sleeve, flange and flued head. BOLT ANCHOR, CONCRETE - A threaded device for fastening attachments to hardened concrete. (See MAI-5.1 A, MAI-5.1 B, MAI-5.1C, MAI-5.1 D) BUILDING STEEL - Structural steel or embedded steel erected as part of the building structure. COMPONENT - A piece of mechanical equipment such as a vessel, piping, pump, valve, or core support structure, which will be combined with other components to form an assembly. COMPONENT STANDARD SUPPORT - A support assembly consisting of one or more units usually referred to as catalog items and generally mass produced. Some examples are: snubbers, constant springs, rods, struts, variable springs, and clamps. Component standard supports are usually installed between the pipe or tube system and the structure using pre-engineered support elements. CONSTANT SPRING - A spring actuated mechanical device which provides a relatively constant supporting force at all positions throughout the travel range. DESIGN DOCUMENTS - Documents, such as drawings and specifications, that implement the design criteria and specify the technical requirements of systems, structures, and components. They are prepared by or for Engineering and issued for the use of organizations outside Engineering. FABRICATION - The forming and joining of component parts into integral pieces ready for assembly. This includes cutting, bending, forming, threading, welding, and other operations upon these items. Fabrication may be performed in the shop or in the field. FIELD FABRICATED - Pipe support subassemblies fabricated in a shop on site or at the final installation location. GUIDE - A device used to permit pipe movement in a predetermined direction while restraining movement in other directions.

4.0 DEFINITIONS (continued) INTEGRAL ATTACHMENT - A member connected to the wall of a pressure retaining component (pipe) with no jurisdictional boundary separating the two. Integral attachments shall be welded, cast or forged integrally with the pressure retaining component, and may include lugs, shoes, rings, skirts, and trunnions which transmit the loading induced by the component. INSTALLATION - Activities required to erect the pipe supports prior to commercial operation or after operation to add a new system. MODIFICATION - A planned change in facility design or operation accomplished in accordance with a Design Change Notification (DCN) and the requirements and limitations of applicable codes, standards, specifications, licenses, and predetermined safety restrictions. PIPE SUPPORT - Elements designed to transmit loads from the pressure retaining component to the load carrying building structure. Support and hanger may be used synonymously. Varieties of these elements are listed below:

• Spring (Variable or Constant)
• Shock Suppressor (Snubber)
• Anchor
• Rigid Support (Strut, Guide, Seismic Restraint, or Tie-back Support)

PIPING SYSTEM - Pipe, pipe fittings, bolts, gaskets, and the pressure-retaining parts of other components (such as valves), normally considered part of the piping system. Also includes supports and other component items necessary to prevent overstressing the pressure retaining parts. REPAIR - The process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safety is unimpaired, even though the item still may not conform to the original requirement. Repair includes those operations involving welding, heat treatment, or defect removal which are required to restore any item to a safe and satisfactory operating condition. REWORK - The process by which a nonconforming item is made to conform to prior specified requirements by completion, remachining, reassembling, or other corrective means. RIGID SUPPORT - A support designed to transfer piping loads to the building structure, and to prevent movement of piping in specified directions. Includes struts, guides, and seismic restraints. ROTATING EQUIPMENT - Pumps, compressors, turbines, and other equipment that must perform a rotating mechanical motion to fulfill its intended function.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 8 of 63 4.0 DEFINITIONS (continued) SAFETY CLASSIFICATION - Systems, structures, and/or components shall be classified in accordance with their importance to nuclear safety. For the purposes of the Q-List, this classification shall be divided into three categories: quality-related (QR), safety-related (SR) which is subset of quality-related, and nonquality-related (NQR). QUALITY-RELATED (QR) A category which includes those structures, systems and components (SSC) and activities that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public. In addition to SR SSCs and activities, quality-related encompasses the broad class of plant features covered (not necessarily explicitly) in the General Design Criteria of 10 CFR 50, Appendix A, that contribute in an important way to the safe operation and protection of the public in all phases and aspects of facility operation (that is, normal operation and transient and special event control as well as accident mitigation). Items classified as quality-related are subject to the requirements of SDP-NEDP-4. SAFETY-RELATED (SR) A category whick includes all those structures, systems, and components that are necessary to ensure: (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shutdown the reactor and maintain it in a safe shutdown condition, or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposure of Title 10 Code of Federal Regulation (CFR) Part 100 (10 CFR 100) or items outside the scope of 10 CFR 50, Appendix B which are included in the Q-List and classified as safety-related due to requirements resulting from TVA commitments. The accomplishment of this safety function is commonly known as Primary Safety Function. Items classified as safety related are subject, without exception, to the requirements of 10 CFR 50, Appendix B. NONQUALITY-RELATED (NQR) A category which includes those structures, systems, and components which are not part of the TVA Quality Assurance Program. The 10 CFR 50, Appendix B, or quality assurance special programs do not apply to items in this classification. SEISMIC CATEGORY - Three different seismic categories exist to which structure, systems, and components are designed and installed in accordance with their safety function to withstand earthquakes. The first category is applied to those structures, systems, and components which perform primary safety functions and are designated as Seismic Class I. Safety-related structures, systems, or components are Seismic Class I. The second category is applied to those structures, systems, and components which are quality-related but not safety-related. Those portions of structures, systems, and components which perform a secondary safety function are designated as Seismic Class II [1(L)] for BFN. Seismic Class II [1 (L)] is defined in NEDP-4 Code Q10 and Q44. The third category is applied to structures, systems, and components which do not perform a primary or secondary safety function and are designated as non-seismic (N).

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 9 of 63 4.0 DEFINITIONS (continued) SEISMIC CLASS II PRESSURE BOUNDARY RETENTION PIPE SUPPORT - A support which must be qualified such that the pressure boundary integrity of the piping system is maintained. (Also classified as "Category I(L)" at other TVA nuclear plants.) SEISMIC CLASS II POSITION RETENTION PIPE SUPPORT - a pipe support that must maintain the pipe in position only to prevent damage to other nuclear safety related features. (Also classified as "Category I(L)" at other TVA nuclear plants.) SEISMIC RESTRAINT - A device which restricts the displacement of the piping or tubing system when excited by a seismic disturbance. SHIM - A member which may or may not be detailed in the original support design which is required to maintain clearance between the pipe and the support within design tolerances. A shim may be temporary for construction purposes only, or may act as a spacer and be detailed on the support drawing. SHOCK SUPPRESSOR (SNUBBER) - A device used to arrest shock loading but still allow normal thermal movement of the piping; commonly referred to as a snubber. SITE ENGINEERING - The engineering organization responsible for the design basis of the plant. SNUG TIGHT - Tightness required to pull the member to be clamped to full seat or contact. STROKE RANGE - The distance over which a snubber is free to move (contraction or extension) so as to permit thermal movement of the piping to which the snubber is attached. STRUT - A rigid tension/compression member (component support) used to restrain movement of piping in a given direction while permitting pipe movements in other directions. SUPPORT STEEL - All piping support steel members excluding building steel. TIE-BACK SUPPORT - A structure which supports a branch line by connecting to the run pipe. TOLERANCE - A specified acceptable departure from a prescribed nominal dimension which provides local installation flexibility when the prescribed dimension cannot be satisfied. TRAVEL STOP - A mechanical device that locks a spring support at a specified load position transforming the support into a rigid support during shipment, installation, and system hydrotest.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 10 of 63 4.0 DEFINITIONS (continued) TYPICAL PIPE SUPPORT - A support designed within certain enveloping limitations but not assigned to a specific location. VARIABLE SPRING SUPPORT - A spring loaded device used for the deadweight support of piping and equipment while permitting vertical movement due to thermal movement. Its resisting force varies with the piping movement. VERIFY - An act of confirming, substantiating, and assuring that an activity or condition has been implemented in conformance with the specified requirements. When the term verify is used, it is intended that 100% of the activity will be evaluated. 5.0 RESPONSIBILITIES The contents and guidelines of MAI-1.3 shall be followed as applicable. Determination of InspectionNerification type shall be in accordance with MAI-1.3 Attachment C unless otherwise noted. For quality related features which require Inspections/Verifications to be performed by a trained and qualified persons, personnel performing these inspections for MAI-4.2A shall have satisfactorily met the training requirements of MTS 175.000 (Verification Program) and completed training on MAI-4.2A. Quality Control Inspector shall inspect applicable attributes as delineated in Attachment 9 (Verification Checklist) for each data Sheet.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 11 of 63 6.0 PROCEDURE/ACCEPTANCE CRITERIA 6.1 General Requirements NOTES

1) Prior to installation of supports ensure that all prerequisites are met and general requirements are adhered to.

2) Attributes of vendor fabricated items (i.e. welds, bolts holes in base plates, etc.) do not require re-inspection in this procedure unless the items have been modified. Modified attributes of vendor fabricated items shall be inspected in accordance with this or other appropriate procedures (i.e., MMDP-1O for welding etc.).

A. Tolerances and requirements of this instruction shall govern unless otherwise specified on the specific support drawing or applicable general notes drawings. refer to Attachment 1. B. Documentation of pipe/tubing supports installation/inspection shall be on Data Sheet 1. C. Permanent sliding surfaces (e.g. Lubrite or Flurogold Plate) shall be as specified in engineering design documents. D. Bolt anchors set in hardened concrete shall be in accordance with MAI-5.1A, MAI-5.1 B, MAI-5.1C, or MAI-5.1D for thru-bolts, unless otherwise specified in design documents. E. Temporary supports, hangers, and brackets may be used as necessary and shall be removed before any preoperational testing or system operation. Temporary supports on inoperable systems shall be in accordance with Section 6.2B.2. Temporary supports may be used on operable systems only when specified on Design Output Documents (i.e., DCN's) or when evaluated and approved by site engineering. Temporary supports on operable systems shall be installed and removed in accordance with MCI-0-000-GNG002.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 12 of 63 6.1 General Requirements (continued) F. The support drawing key plan or elevation view shall be used to locate the support from a piping feature. Support locations on piping are determined by dimensions given from piping components or fittings. Dimensions presented from column lines, azimuths, and floor/ceiling elevations are intended as reference information only. In no case shall the pipe location tolerance change the direction or function of a restraint such as by moving around an elbow, bend, or branch. G. On any support, fasteners or other threaded parts shall be tight and spherical bearing shall be free to rotate. H. Welding, cutting, bending, and forming of structural shapes as shown on design documents and nondestructive examination shall be performed in accordance with MMDP-10. I. Welded areas and material identification markings shall be accessible for verification, or shall have verifications performed prior to installation of structure which covers the welds. J. Painting and protective coating shall be in accordance with MAI-5.3 or MAI-5.7, as required by design output documents and site specific requirements. K. Prerequisites

1. All material used for the fabrication, installation, modification, and maintenance of pipe supports shall be in accordance with the engineering approved design documents.

These documents may include:

a. General Engineering Specifications

b. Pipe Support Drawings

c. Site Specific Requirements

d. Purchase Specifications

e. Manufacturer's Requirements

f. Design Change Notices

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 13 of 63 6.1 General Requirements (continued) NOTE All painting activities (including touch-up) shall be completed before closure of the applicable work implementing document or transferred to another work order. Verification of these activities shall be documented on Data Sheet 1 by the responsible painting supervisor or designee.

2. Verify that all related activities (excluding painting) like material traceability, welding, concrete grouting, bolt anchor installation, etc., are performed and accepted by the appropriate InspectorNerifier (See discussion on Inspection/Verifier type in Section 5.0). This shall be done by verifying the applicable data sheets in the work instruction have been signed acceptable by the appropriate inspector/verifier. If data sheets are signed, reinspection of the activites shall not be performed.

3. [QAICi Verify spacing is maintained between an anchor and any attachment welded to an embedded plate or between an anchor and any bolt installed into a strip insert in accordance with the MAI-5.1A, MAI-5.1 B, MAI-5.1 C, or MAI-5.1D series [CAQR BFN 900109].

For embedded plates, an attachment welded to the embedded plate may be closer than 18" to an expansion anchor, grouted anchor, thru-bolt, or undercut anchor provided at least two rows of anchors welded to the embedded plate are between the attachment and a line parallel with the rows which passes through the anchor or For strip inserts, a bolt may be installed into a strip insert closer than 18" to an expansion anchor, grouted anchor, or undercut anchor provided at least two studs welded to the strip insert are between the bolt and a line perpendicular to the strip insert. [CAQR BFP 900109]

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 14 of 63 6.1 General Requirements (continued) L. Identification

1. Verify that the support is properly identified with the correct support number and/or drawing number as shown on the support drawing.

If support identification tags are used for identification, they shall be made of stainless steel and attached to the support by one of the following methods: Tack welding in accordance with MMDP-1 0. Tack welds do not require documentation. Riveting the tag to the structure by drilling 1/8" diameter hole(s) in structural steel and the tag. NOTE A stainless steel tag should be constructed from light gage (approximately 12-16 Ga.) sheet steel approximately 2" to 2-1/2" by 3/4" to 1". Wiring the tag to the support member using single or multiple strand stainless wire/cable. Attach the identification tag to the support by means of wire passing through a hole in the tag and around the support member in such a way that the tag will not slip down the support member or fall off. If the support member is unistrut, a 1/8" diameter hole may be drilled through the unistrut and the identification tag attached to the unistrut using single or multiple strand stainless wire/cable. In lieu of tagging, support identifications may be by steel indentation as follows: Die stamping - Round bottom, low-stress continuous or interrupted dot die stamps conforming to the requirements of P.S. 4.M.1.1 and P.S. 4.M.1.3 may be used for identification marking of material 1/4" thick and over. Material less than 1/4" thick shall not be stamped without consideration of required minimum wall or material thickness. For nonpressure retaining structural material, the depth of impression shall be limited to 1/32".

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 15 of 63 6.1 General Requirements (continued) Hardened materials (with mechanical strength increased by quenching and tempering, aging, or cold working) shall not be marked by die stamping. In order to easily identify the support, painting using a stencil may be used in combination with steel indentation.

2. All identification shall be legible and accessible after application of paint.

M. Physical Damage *HOLD POINT (*When repair or material will be covered up) NOTE Physical Damage Hold Point is not applicable for items installed in accordance with MAI-5.1A, MAI-5.1B, MAI-5.1C, or MAI-5.1D.

1. Visually determine that there is no physical damage such as: missing or loose bolting or mis-drilled holes.

2. [NRC/C] Flame cut bolt holes For New Installation:

Flame cutting of bolt holes is not permitted. All bolt holes within the scope of the modification shall be checked. [NRC/Report 85-30] Baseplate holes are verified in accordance with MAI-5.1A, MAI-5.1 B, MAI-5.1C, or MAI-5.1D. For Existing Installations: Flame cut holes and oversize holes that have been evaluated by Engineering (Note 57 and Note 100 on 47B435 dwgs) are acceptable unless otherwise noted on the hanger drawing.

6.1 General Requirements (continued)

3. Verify that Base metal damage or fabrication damage has been evaluated in ccordance with MMDP-10 or identified in the work instruction for evaluation.

The area to be evaluated and repaired should be limited to the attachment area and 2" beyond the bounds of the attaching item in all directions.

4. For piping struts, visually determine that the staking process on carbon steel spherical bearings has not:

a. Damaged the bearing race in any way (such as cracking, deforming, or spalling).

b. The ball moves with little force within the bearing race.

c. The spherical bearing is not dislodged from the paddle housing.

N. Material Size, Shape, Type and Grade

1. Structural Material:

Verify that structural material is correct size, shape, type and grade, including thickness per the design drawing. Nominal cross sectional dimensions for structural shapes are given in the AISC Manual, 8th edition. Tolerances need not be verified unless the cross-section is altered by the design drawing.

2. Material Substitution:

Carbon steel plate less than or equal to 1/4" in thickness specified as A-36 may be replaced with A-570 Grades 36, 40, or 45 materials. Structural tubing specified as A500-74A Grade B or A500-76 Grade B, may be replaced by A500 Grade B.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 17 of 63 6.1 General Requirements (continued)

3. Bolting Material:

Verify the diameter, length and head style is as specified on either the design drawing, bill of materials, MAI-5.2 or manufacturer's catalog for the specific application.

4. Catalog Items:

Using the manufacturer's catalog, verify that catalog items are the specified item including size and shape or an acceptable substitute as allowed by the design drawing or general notes as applicable. Verify the Bergen-Patterson mechanical snubber part number load designation coincides with the PSA snubber load capacity rating. See Table 6.1.14.4 below for PSA load capacities. (e.g. BP 2410-50 = PSA-35, 50 KIPS) Manufactures catalog items specified as "reference only" are not to be used for inspection purposes. Table 6.1.14.4 Pacific Scientific (PSA) Snubber Load Capacity Ratings PSA-1/4, 0.35 KIPS PSA-1/2, 0.65 KIPS PSA-1, 1.5 KIPS PSA-3, 6 KIPS PSA-10, 10 KIPS PSA-35, 50 KIPS PSA-100, 120 KIPS

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 18 of 63 6.1 General Requirements (continued)

0. Material Identification:

Structural members and support components can be identified by applicable type/number (i.e., Material specification and grade/mark number) in accordance with approved engineering design documents, drawings, bill of materials or vendor catalogs. Integrally welded attachments to pressure boundary material over 2" nominal pipe size for TVA Piping classes A and B and over 4" nominal pipe size for TVA Piping classes C, D, E, and P shall be marked or tagged with a valid heat number/code as required in accordance with MMDP-1. Material specification and grade shall be' marked for safety related and quality related use. The identification shall be plainly evident on the item or packing (for small items) in accordance with SPP-4.2. When materials are required to be sectioned or divided after issue from Power Stores, the craft shall transfer the-appropriate marking. A craft foreman shall verify each transfer. Material markings that may be destroyed or becomes inaccessible during fabrication or installation shall be verified by QC or appropriate Verifier, and documented in the comment section of the applicable Data Sheet. Material type and grade that cannot be verified shall be documented in accordance with the Corrective Action Program described in SPP-3.1. P. Material Traceability: Material shall comply with the applicable section of SPP-4.1, SPP-4.2, SPP-4.3 and SPP-4.4, which provides considerations for the material procurement specification, documentation, and traceability. Q. Surface Condition:

1. Visually verify that surfaces and edges to be joined for bolted connections are smooth, uniform and free from fins, tears, burrs, cracks. Weld joints and concrete joints are covered under other procedures.

2. Verify that there is no loose material, chips, gouges or other surface defects between two surfaces that are to be in contact such as the support or pipe clamp and the pipe.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 19 of 63 6.1 General Requirements (continued) R. ASME Section XI Requirements: All repairs, replacements or modifications (including the addition of new supports) to the pipe supports covered by ASME Section XI program, shall be performed in accordance with SPP-9.1 requirements. NOTES

1) [NRC/C] Any maintenance or modification necessitating the removal of supports MS-GA1, MS-GB1, MS-GC1, MS-GD1, FW-G1 OR FW-G2 shall be reported to the In Service Inspection Group so that inspection of welds KMS-29, KMS-1, KMS-81, KMS-51, KFW-4 OR KFW-22, respectively, can be performed in accordance with the commitment request for relief (ISI-7).

2) Additionally for Unit 3 only, the removal of supports FW-H2, FW-H4, FW-H6, FW-H8, FW-H10, or FW-H12 shall be reported to the In Service Inspection Group so that welds KFW-40, 41,42, 43, 44, or 45 as applicable can be inspected. [NRC 82 0467-001]

S. Component Standard Supports

1. Snubbers Hydraulic and mechanical snubbers, clamps, and attachments shall be installed in accordance with Manufacturer's installation procedures and Engineering design documents.

[NRC/C] Manufacturer's recommended installation procedures shall be followed. Sensitive components, such as snubbers, shall not be used as steps or to support other construction loads. The Responsible Engineer/Planner shall assure that adequate instructions are in work packages to accomplish this. [NRC Report 85-26] Legible nameplates are required on snubbers at the time of installation. When arc welding, do not attach ground to snubber or any part of the snubber which will cause the arcing current to pass through it. Verify that moving parts of snubbers (e.g., piston rods, bearings and travel indicators), fluid fill fittings, weep holes, and sight glasses are free of paint. Snubbers shall not be sand blasted or painted unless otherwise specified by Engineering or Engineering approved design documents. If sandblasting is to be performed on adjacent parts; such as unfinished pipe or structure, the snubbers shall be masked for protection.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 20 of 63 6.1 General Requirements (continued) Mechanical snubbers shall be stroke tested per O-SI-4.6.H-2A prior to being placed in service. Bearing retention and installation and pin installation in the paddle ends of snubber attachments shall be in accordance with Engineering design documents. Install pins in a manner to avoid driving spherical bearings free or damaging them. Pins should be snug but not tight. Light tapping with a fiber mallet is allowed to install pin or reposition spherical bearing. For hydraulic snubbers, the snubber body (or heavier end) should be oriented away from the pipe or pipe clamp, unless otherwise specified in Engineering design documents. For mechanical snubbers, the heavier end should be oriented away from the pipe, but may be installed either way unless specified by note in Engineering design documents. For inclined or vertical mechanical snubbers, the heavier end should be oriented, where possible, such that liquids will drain off rather than collect inside the mechanism. Hydraulic snubbers with a clear plastic gravity-fed external reservoir shall be installed so that the reservoir is in a vertical plane on top of the cylinder. The reservoir vent shall be located over the high end of the cylinder. Use care to align snubbers as closely as possible to avoid forces tending to rotate the pipe clamps or induce bending. The space between the washers of the bracket assemblies or pipe clamp shall not allow more than 1/16" total lateral free movement of the spherical bearing unless justified by the component manufacturer and approved by engineering. Spacers/washers in accordance with Engineering Design documents shall be added to assure this maximum gap is maintained. For Unit 1, due to the potential for damage to occur to a permanent snubber after installation, it may not be practical to install the permanent snubber until all construction activities in the area have been completed. In these cases, a surrogate (substitute) may be fabricated at an onsite fabrication shop and installed at the location of the permanent snubber. For these instances, the attributes to be inspected in the field will be limited to pin to pin dimension and verification of end bracket/clamp alignment in relation to the snubber.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 21 of 63 6.1 General Requirements (continued)

2. Strut Supports Struts, clamps, and attachments shall be installed as specified on the Engineering design documents.

Strut supports are designed to permit variances in nominal distances between piping and building structures. The welding of telescoping elements, etc., should be performed after all alignment of piping and adjusting of support is complete. (See Section 6.2E) Care shall be exercised in the installation of rigid supports to lines which have been previously aligned. Supports shall not be installed such that they are relieving adjacent supports of their load. Care shall be taken not to disturb the alignment or elevation of the pipe. Bearing retention and installation and pin installation in the paddle ends of strut attachments shall be in accordance with engineering design documents. [QA/Cl Staking of carbon steel spherical bearings shall be performed only if the bearing has become dislodged. Install pins in a manner to avoid driving spherical bearings free or damaging them. Pin should be snug but not tight. Light tapping with a fiber mallet is allowed to install pin or reposition spherical bearing. The space between the washers of the bracket assemblies or pipe clamp shall not allow more than 1/16" total lateral free movement of the spherical bearing unless justified by the component manufacturer and approved by engineering. Spacers/washers in accordance with engineering Design documents shall be added to assure this maximum gap is maintained. When arc welding, do not attach ground to strut or any part of the strut which will cause the arcing current to pass through it.

6.1 General Requirements (continued)

3. Constant and Variable Spring Hangers All constant and variable spring supports, clamps, and attachments shall be as specified on the engineering design documents.

Spring supports should be oriented if possible, such that the spring load setting can be observed with minimal effort. Springs may be located anywhere on the rod between support steel or building steel and pipe attachment, unless specifically prohibited on engineering design documents. Variable and constant support springs on nonliquid piping systems (i.e., filled with air, steam, nitrogen, etc.) require travel stops or temporary supports during hydrostatic testing of the lines. The travel stops or temporary supports shall be removed after the testing and prior to any preoperational tests or plant operation. Springs shall show no visible signs of damage such as broken or binding coils, cracked welds, canister deformation or corrosion. Restrain (pin, wedge, etc.) the variable spring support in place after setting to "cold" position. For variable spring supports where a load/travel scale does not exist on the spring can, it is acceptable to locate a spring can of the same manufacturer, series or style, and size (such as Bergen-Paterson VS2 size

9) and measure from a point at the top of the spring can slot down to a point(s) on the load/travel scale that represents the load value(s) needed for spring setting verification or resetting and transfer the measurement(s) to the spring can without the load/travel scale.

It is acceptable to transfer the above type information from one spring can to another since springs of the same manufacturer, series or style, and size have the same physical size and spring rates.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 23 of 63 6.1 General Requirements (continued) NOTE Additional adjustments and inspections to safety related variable spring supports are required after Modification work has been completed per 0-TI-252. The following steps shall be performed to assure compliance with 0-TI-252:

1) The Responsible Engineer/Foreman shall initiate and complete the applicable sections of Data Sheet 4 and forward to Maintenance Technical/Technical Support. The Responsible Engineer/Foreman shall initial/date Data Sheet 1 to indicate this step has been completed.

2) Maintenance Technical/Technical Support shall review Data Sheet 4 and obtain a Work Order number from Maintenance Planning.

3) The Work Order number shall be recorded on Data Sheet 4 and returned to the Responsible Engineer/Foreman.

4) Upon receiving Data Sheet 4 from Maintenance Technical/Technical Support, the Responsible Engineer/Foreman shall record the Work Order number in the appropriate section of Data sheet 1, and initial/date to indicate this step has been completed.

Legible nameplates are required on springs at the time of installation. T. Rigid Supports Care shall be exercised in the installation of rigid supports to lines which have been previously aligned. Supports shall not be installed such that they are relieving adjacent supports of their load. Care shall be taken not to disturb the alignment or elevation of the pipe. U. Instrument Line Supports Attached to Building/Supplemental Steel Attachments to building or supplemental steel requires Engineering approval. A sketch showing the location of the attachment to the building or supplemental steel shall be submitted to Engineering for formal approval using a tolerance of

             + 1".

V. Instrument Line Supports Attached to Supports

1. Engineering approval is required to attach one support to another support.

2. The attachment of an engineered support to a typical support is not permitted.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 24 of 63 6.1 General Requirements (continued) W. Non-Seismic Instrument Line Supports

1. Supports for non-safety related instruments and lines located in non-seismic structures should be installed utilizing the 47B610 drawing series as guidance. Support configuration, material, etc., as shown on the drawing, may be deviated from at the discretion of the responsible engineer, provided the supports do not sag, sway, or allow excessive movement of the instrument line.

2. Support for instrument lines serving instruments designated as Protection Set and installed in non-seismic areas shall be installed in accordance with details provided by Engineering.

X. Instrument Line Slope Requirements When modifications or additions to existing supports have the potential to affect the location of installed instrument lines, verification of instrument line slope shall be performed again in accordance with MAI-4.4A.

6.2 Installation Instructions A. Support Categories

1. For modification of existing supports follow requirements of Section 6.2B.

2. For installation of new supports on existing piping follow the requirements of Section 6.2C and Section 6.2E.1 (Option I).

3. For installation of supports on new piping follow the requirements of Section 6.2D and Section 6.2E (Option I or II).

B. Existing Supports The following sequence should be followed whenever possible.

1. Location

a. Verify that the support is installed on the correct pipe at the location as specified on the specific support drawing. Building line, elevation, azimuth, etc., may be used for reference purposes only and are not required to be verified.

b. For small bore pipe supports where no location plan is given, location shall be verified to be correct relative to other supports and piping features shown on the design drawing (schematic diagram).

c. When allowed by the design drawing, an existing support can be relocated within the tolerances specified in Section 6.2C.4.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 26 of 63 6.2 Installation Instructions (continued)

2. Temporary Supports NOTES

1) Snubbers do not support the dead weight of the piping and therefore do not require temporary supports prior to removal.

2) All piping systems and associated supports within the drywell and attached to the reactor pressure vessel shall be considered operable regardless of the system operability status when fuel is in the reactor vessel.

The applicable section of MCI-0-000-GNG002 shall be used when installing or removing temporary supports on Class I operable structures, systems, or components. Temporary supports on any inoperable system shall be installed and documented on Data Sheet 2 prior to removing permanent dead weight supports. However, if an existing dead weight support is to be replaced by a new dead weight support, a temporary support is not required if the new support is installed before the existing support is removed. This shall be so noted in the comments section of Data Sheet 2 when applicable.

a. These temporary supports may be cables, rod, or specially fabricated devices. Temporary supports should permit positioning and securing of the piping in its final position until the permanent supports are installed. (See Section 6.2E.2, Option II)

b. Temporary supports shall be identifiable for easy recognition.

Temporary supports such as wood, chain hoists, and cable which are easily recognized without distinctive coloring need not be painted.

c. It is recommended that temporary supports be painted a distinctive color.

d. Temporary supports shall not be supported off existing pipe or supports or where damage to the supporting structure may occur (wide flanges, grating, etc.) without approval of Engineering.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 27 of 63 6.2 Installation Instructions (continued)

3. Permanent Removal of Existing Support NOTE When removing identified permanent supports, and additional systems or items (e.g.

instrument line, conduit, etc.) are affected, the Responsible Engineer or Planner shall obtain Site Engineering approval. The permanent removal of supports shall be documented on Data Sheet 1 or 3 as appropriate. Data Sheet 1 shall be used for removing a support and installing a new support in its place. Data Sheet 3 shall be used only when an existing support is being permanently removed and a new support is not installed in its place. All permanent supports required to be removed should be identified or adequately located on the design documents to assure removal of the correct support. When supports are identified on design drawings to be removed, the responsible engineering/planner shall prepare Data Sheets 3 for each support to be removed. The design drawings shall be used to locate the supports. When supports are not uniquely identified on design drawings, the Responsible Engineer, craft foreman, or planner will be required to determine the location and actual number of supports to be removed. The Responsible Engineer/Planner shall prepare Data Sheet 3 for supports, and initiate Attachment 6 (Permanent Support Removal Sketch) to identify the general location of the supports to be removed. Line verification of permanent support removal is not required.

4. Temporary Removal of Existing Support NOTE Removal of an existing support for purposes of relocation shall be handled by the work instruction.

[QNC] Use the applicable sections of MCI-0-000-GNG002 when removing and reinstalling supports where no design drawing exist, the design information is incomplete, or the support is being removed to facilitate construction and later reinstalled. [CAQR BFN 900112P]

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 28 of 63 6.2 Installation Instructions (continued)

5. Layout

a. Craftsman should layout the support/components to be modified in accordance with the design drawing and supplemental views.

b. Craftsmen will review the design for interferences.

6. Orientation

a. Verify that the support is in the proper orientation to the pipe(s) being supported, including baseplates.

b. Verify that weld lugs on the pipe are oriented as specified in the Work Instructions (Design Drawings).

c. The installation tolerance for the angular orientation of component standard supports (rods, variable and constant spring hangers, rigid struts, and snubbers) shall be +/- 2 degrees.

7. Configuration Visually verify that the support has been installed/modified in accordance with the design drawing.

8. Dimension

a. For baseplates, verify that the hole location (minimum edge distance) is as specified on the Design Drawings.

b. All other dimension tolerances will be in accordance with Attachment 1 or the design output document.

c. Verify sizes of all new bolt holes are correct in accordance with design output document.

9. Support Gaps

a. Gaps for box supports, U-bolts, etc., shall be maintained as specified in Attachment 2, Section 1.0B1.2 unless otherwise specified on design drawing.

b. Install/verify shims in accordance with Attachment 1.

c. On initial installation, all vertical deadweight supports shall be in contact with the pipe.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 29 of 63 6.2 Installation Instructions (continued)

10. Torque/Tightening

a. All concrete anchors shall be torqued/tensioned and documented in accordance with MAI-5.1A, MAI-5.1 B, MAI-5.1C, or MAI-5.1D series instructions.

b. Torquing/tightening of snubber bolts shall be performed and documented in accordance with MPI-0-000-SNBOO4. These data sheets shall be included in the work order.

c. Catalog item bolt and structural bolts such as U-bolts, strut assemblies, unistruts, pipe clamps, etc., shall be torqued if torquing value is specified on specific design drawing in the work instruction.

d. All bolting material of pipe supports where a torque value is not specified shall be tightened, verified, and documented in accordance with Section 6.2F.

11. Settings

a. Sway strut - Adjust/Verify the pin-to-pin dimension per tolerances given on specific support drawing or vendor catalog.

b. By taking field measurements, verify all snubber cold settings are within the range specified on the support drawing. Final snubber settings shall be verified by the applicable SI, 1-,2-, 3-SI-4.6.H-1.

c. Settings for Variable spring supports that have been pinned, or wedged in accordance with Section 6.1S.3 do not require QC verification. Final settings shall be verified in accordance with 0-TI-252.

12. Clearances

a. Verify that clearance between supports and adjacent components and structures will allow for full travel of non-rigid supports.

b. Clearances between the new support or modified components of an existing support and pipe shall be verified to the requirements of MAI-4. 10.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 30 of 63 6.2 Installation Instructions (continued) C. New Support on Existing Piping

1. All the requirements specified in Section 6.2B are applicable for this type of installation with the exception of location criteria of Section 6.2B.1.

2. Location and Configuration of Pipe Supports The support drawing key plan or elevation view shall be used to locate the support from a piping feature.

Support locations on piping are determined by dimensions given from piping components or fittings. Dimensions presented from column lines, azimuths, and floor/ceiling elevations are intended as reference information only. In no case shall the pipe location tolerance change the direction or function of a restraint such as by moving around an elbow, bend, or branch.

3. Capping Open Ended Tube Steel All structural steel tubing positioned so that it could collect water in areas subject to freezing conditions or collect trash shall be capped with a minimum 1/4 inch thickness A-36 plate. The cap plate shall be attached to the tubing using appropriate weld procedure in accordance with MMDP-10.

QC shall not inspect the weld. The inside of the tube steel shall be free of water and debris before capping. A 1/4" weep hole may be drilled in the tube steel to allow any collected water to be removed from enclosed structural section. The weep hole shall be within 1" of the bottom of the tube.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 31 of 63 6.2 Installation Instructions (continued) NOTE These weld caps or weep holes will not necessarily be shown on NE support drawings.

4. Relocation of Supports

a. Support relocation tolerances are specified in Table 6.2.3.4. To select the relocation tolerance, it must be determined if the support is classified as "adjacent" or "non-adjacent" to a Valve, Anchor, Equipment Nozzle, Elbow, Branch, or Tee. This classification is dependent on the distance between the Design location of the centerline of the support and the nearest weld point on the Valve, Anchor, Equipment Nozzle, Elbow, Branch, or Tee.

b. Table 6.2.3.4 provides the most restrictive tolerances for all cases derived from G-43. If a support cannot be installed within these limits, the responsible engineer may determine the maximum tolerance allowed by G-43 and specify the acceptable tolerances on Data Sheet 1. In no case will G-43 provide a tolerance greater than +/- 6" for 6" and under pipe or one pipe diameter for over 6" pipe.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 32 of 63 6.2 Installation Instructions (continued) TABLE 6.2.3.4 (NOMINAL DIA.) RELOCATION RELOCATION COLUMN A RUN PIPE SIZE TOLERANCES TOLERANCES DIMENSIONS FOR FOR FOR DETERMINING ADJACENT NON-ADJACENT ADJACENT SUPPORTS SUPPORTS SUPPORTS NOTE 1 NOTE 2 NOTE 2

     < 1-1/2"         +/- 2 DIA              + 6"                WITHIN 24" OF WELD JOINT 1-1/2" - 4"       +/- 3"                 + 6"                WITHIN 24" OF WELD JOINT
     > 411- 6"        ++/-1DIA               + 6"                WITHIN 24" OF WELD JOINT
        >6"           +/-6"                  ++/-1DIA              WITHIN 4 DIA. WELD JOINT NOTES

1) A support is defined as "adjacent" when the design dimension between the centerline of the support and the nearest weld point on Valve, Anchor, Equipment Nozzle, Elbow, Branch, or Tee is located within the distance shown in Table 6.2.3.4, Column A.

For Threaded or Flanged Components the connecting face of the component shall be considered the weld joint.

2) For supports with more than one pipe, the support relocation tolerance is to be determined for each pipe. The most restrictive tolerance is then to be applied.

5. Relocation of Supports Near Piping Welds

a. Although not mandatory, pipe clamps and/or bolted construction supports should not be installed directly over circumferential welds when such installations can be avoided.

b. Supports fabricated from structural shapes by welding (i.e., not easily disassembled) shall not be installed directly over circumferential welds that are required to be in-service examined. (See 1,2,3-SI-4.6.G, and SPP-9.1 to determine ISI requirements.)

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 33 of 63 6.2 Installation Instructions (continued)

c. Using the limits established in Section 6.2C.4 supports should be positioned on the piping to permit in-service verification and testing of piping welds as follows:

(1) ASME Class 1 and 2 piping (TVA Class A, B, C, D) provide at least 2T + 2" (T = piping nominal wall thickness) or 6" (whichever is larger) clear access to piping welds from one side that requires in-service inspection. (2) ASME Class 3 and ANSI B31.1 or B31.5 piping (All other TVA Classes) - Provide clear visual access to piping welds where possible.

6. Location of Integral Attachments The minimum required edge distance between an integral attachment and a pipe weld or other discontinuity is provided by the table below:

Nominal STD Pipe Size D (Inches) 3 inches and under 1 3 1/2 inches to 6 inches 1.6 8 inches to 12 inches 2.75 14 inches to 18 inches 3.80 20 inches to 24 inches 5.10 For larger sizes, use actual value (Rmt)/. Smaller actual values for (Rmt)/ may be calculated using the actual pipe size and wall thickness. A smaller edge distance may be acceptable by calculating (RmtA)/2 where: Rm = Mean radius of the pipe t = Nominal pipe wall thickness or as specified by the Engineering design document. Lugs designed to be placed on pipe shall not be moved onto a fitting in order to satisfy this clearance criteria. The radial face of lugs which are welded to the process pipe or welded to clamps on the process pipe may be ground down to provide proper clearance in rigid supports if the lug is loaded in a radial direction only. Provisions must be made to prevent damage to the process pipe during grinding.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 34 of 63 6.2 Installation Instructions (continued) D. Supports On New Piping All the requirements as specified in Section 6.2C shall apply. Also instructions given in Section 6.2E shall be followed after selecting Option I or Option II for support installations. E. Optional Support Installation Instructions

1. Option I: Install Piping Before Supports Piping supported by temporary supports shall not be forced into position to permit permanent support installation. Permanent supports can be installed in any sequence but preferably in the sequence listed below:

a. Install remaining vertical adjustable supports and adjust to begin taking tension.

b. Install lateral struts with the pin on one end removed; adjust until the pin can be installed without moving the pipe.

c. Assemble rigid supports around pipe. Use shims to provide proper clearance. Ensure that all final vertical rigid supports, saddles, slides, etc., actually contact the pipe (see Attachment 2 Section 1.0B.2 for exceptions). Shims shall be left in position while support welds are made.

d. Complete installation of in-line anchors. Weld lugs to pipe at axial supports requiring lugs.

e. Remove temporary supports (see Section 6.2B.2).

f. Install snubber(s) and adjust to the set position indicated.

g. A final support verification should ensure that all temporary shims have been removed. Adjust all rods, turnbuckles, and struts to ensure that the pipe is "sifting on" all vertical rigid saddles, guides, etc. If pipe is not contacting vertical rigid supports, permanently shim or modify support to provide rigid contact (see Attachment 2, Section 1.0B.2 for exceptions).

h. With the line insulated and waterlines filled, adjust spring hanger to the point where spring pins can be removed. (Adjust to set position specified on drawing.)

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 35 of 63 6.2 Installation Instructions (continued)

2. Option II- Install Supports Prior to Piping

a. Step 1: Install equipment.

b. Step 2: Install all vertical supports. Provide a means for getting the pipe in place.

Anchors may be treated as rigid supports or shop welded to the pipe subassembly if provisions for adjustment of the support structure are provided.

c. Step 3: Begin erection of the pipe by laying any number of pipe assemblies in place using all rigid supports, struts, rod hangers, and spring hangers (with pins installed) to support the pipe. When adjacent pipe assemblies are in place, use the following alignment procedure:

(1) Provide proper clearance for all rigid supports by shims. (2) Adjust supports to align adjacent pipe assemblies. Do not use force to align adjacent assemblies. (3) Weld or bolt adjacent assemblies together as applicable. If any section of pipe, valve, anchor flange, or similar in-line subassembly is not available, ensure proper alignment by installing a temporary in-line subassembly or fabricating a continuous piece of pipe with the intent of removing a section of pipe later.

d. Step 4: Complete permanent support installation in any sequence as follows:

(1) Complete installation of in-line anchors. Weld lugs to pipe at axial supports requiring lugs. (2) Install lateral struts. With the pin on one end removed, adjust until the pin can be installed without moving the pipe. (3) Install snubber(s) and adjust until it is positioned to permit travel as indicated on the support drawing.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 36 of 63 6.2 Installation Instructions (continued)

e. Step 5: The closure connection can be made at any time after the following conditions are met:

(1) All piping is in place or sufficient piping adjacent to the closure connection is in place to ensure that subsequent assembly of piping will not cause a preload on the connection. Piping supported on final vertical supports for a minimum of three vertical supports from the closure connection will meet the intent of this requirement. (2) The final supports have been adjusted to line up the closure connection for final assembly to within 1/16" of the final position while swinging free on the supports. (3) The shims in the three lateral rigid supports closest to the equipment nozzle are in place. Only those rigid supports within three bends (45 degrees or greater) or three deadload supports of the equipment, whichever is greater, shall be considered within the scope of this requirement.

f. Step 6: Once all pipe assemblies and supports are installed, adjust all vertical supports to be in tension. If the pipe is not contacting vertical rigid supports, permanently shim or modify to provide vertical contact.

Where permanent supports are used to align pipe for final closure welds, there should be no vertical gaps (support must contact bottom of pipe), but after pipe is completely welded and all supports are installed and adjusted, the support gap may be verified to the requirements of Attachment 2, Section 1.0B.2.

g. Step 7: With the line insulated and water lines filled, adjust spring hangers to the point where spring pins can be removed.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 37 of 63 6.2 Installation Instructions (continued) F. Fasteners/Bolts

1. When the work implementing document, DCN, etc., specifies for bolting to be installed per the design pipe support general notes drawings 0-47B435 series, the installation shall be documented on Data Sheet 1 of MAI-4.2A.

When the work implementing document, DCN, etc., specifies bolting to be installed in accordance with P.S. 4.M.4.4 (or if no reference is specified), bolting shall be installed and documented in accordance with MAI-5.2.

2. At the time of the final hanger verification for SA/A307 bolts, the Craft and QCN Inspector shall verify all threaded connections are "Snug Tight". The term "snug tight" refers to the tightness required to pull the members to be clamped by the fastener into full seat or contact. Properly performed, snug tightening will result in a connection where the clamped members of the joint are in full designed contact and the nut or bolt cannot be loosened by hand. The snug tightening of bolts shall be accomplished using the following criteria. [NRC Report 85-26] QCN inspection of snug tightness shall be verification that the nut cannot be loosened by hand.

a. Bolts 1" and Larger in Diameter "Snug tight" may be achieved with a few impacts of an impact wrench, the full effort of a person using an ordinary spud wrench, an unmodified commercial open-end wrench or a sprocket type ratchet.

b. Bolts Less Than 1" in Diameter "Snug tight" may be achieved by any of the methods in item (1) above, except that the effort involved shall be less than a full effort and only 2 or 3 impacts of an impact wrench such that the fastener cannot be loosened by hand.

G. Structural Attachments Attachments to embedded plates shall be in accordance with the provisions of MAI-5.9, unless specifically shown otherwise on the support design drawing. H. Trapeze-type Supports Tolerances for trapeze-type supports are specified in Attachment 4, Figure D1.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 38 of 63 6.2 Installation Instructions (continued) I. Welding Welds shall be as detailed on the engineering design documents. Welding and NDE shall be in accordance with MMDP-10. Welds made by TVA and designated as shop welds on Engineering design drawings may be welded as field welds, and those designated as field welds may be welded in the shop. When all around welds are detailed for the connection of an open structural member to a member of the same size, the welds at the tip of the leg or flange may be deleted as shown in Attachment 4, Figure D2. J. Grouting Grouting shall conform to MAI-5.4.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 39 of 63 6.2 Installation Instructions (continued) K. Unistrut Attachments Unistrut Clamps Used as Guides (two direction restraint): When a Unistrut pipe strap (clamp - P2558) assembly is specified with washers, the washer width (w) and length (L) shall be sized in accordance with the table below. A washer thickness (t) sized in accordance with the table below will normally ensure the gap requirements of Attachment 2 are satisfied for most of the fabrication tolerances associated with the clamp and pipe. Because the gap requirements may not be satisfied for all the fabrication tolerances, the gap shall be checked, and if required, the clamp and/or the washer thickness adjusted to ensure the requirements of Attachment 2 are satisfied. 3 PLATE WASHER TABLE PIPE SIZE 1/2" 3/4"-1 1/4" 1-1/2" 2" - 4" 5" - 6" ti 1/8" 5/32" 3/16" 3/16" 7/32" W2 1" 1" 1" 1-5/8" 1-5/8" L2 1-5/8" 1-5/8" 1-5/8" 1-5/8" 1-5/8" HOLE DIA. 9/32" 9/32" 9/32" 13/32" 13/32" Thickness values other than those listed in this table may be used as long as the gap requirements of Attachment 2, Section 1.OE, Table 1, are satisfied. 2 Width (w) and length (L) tolerance is +1/8",-0". 3 The plate washers are to be fabricated using A36, A569 or A570 material. These rectangular washers, when installed between the clamp and the unistrut, prevent the clamp from axially restraining the pipe and allow the pipe to slide in the clamp. When specified on the support design drawing, the loading condition will determine whether washers are used or not. For two directions of restraint, washers shall be installed and for three directions of restraint, washers shall be omitted. Bolt Tightening Requirements: Unistrut pipe and tubing clamps are to be tightened to the requirements below including Notes 1 through 5.

BFN TVA-BFNP Piping/Tubing Supports IMAI-4.2A Unit 0 Rev. 0038 Page 40 of 63 6.2 Installation Instructions (continued) Unistrut Pipe & Tubing Clamp Bolt Tightening Requirements BOLT SERIES CLAMP SIZE TIGHTENING REQUIREMENTS REMARKS P2558-05 thru 1/4" 6 ft-lbs or 72 in-lbs One piece pipe clamp P2558-15 P2558-20 thru 3/8" 19 ft-lbs or 228 in-lbs One piece pipe clamp P2558-60 P1111 B thru P11 13B 1/4" 6 ft-lbs or 72 in-lbs Two piece pipe clamp P1109, P1111, 1/4" 6 ft-lbs or 72 in-lbs Two piece pipe clamp thru P1115 & P1117 P1118 & P1119 5/16" 11 ft-lbs or 132 in-lbs Two piece pipe clamp P1120, P1121, 3/8" 19 ft-lbs or 228-in lbs Two piece pipe clamp P1123, P1124,

& P1126 P2008 thru P2012             1/4"        1/4 turn past handtight                   One hole tube clamp P2014 thru P2020             1/4"        6 ft-lbs or 72-in-lbs                     One hole tube clamp P2024 thru P2035             1/4"        6 ft-lbs or 72 in-lbs                     Two piece tube clamp
& P1430 P2037 thru P2040,            5/16"       11 ft-lbs or 132 in-lbs                   Two piece tube clamp P2042 thru P2044, P2046 thru P2049 P2051 thru P2053,            3/8"        19 ft-lbs or 228 in-lbs                   Two piece tube clamp P2055 thru P2057, P2059 thru P2070, P2070-61 thru P2070-64, P2070-66 P2070-67, P2070-70 thru P2070-77, P2070-80 thru P2070-84 NOTE 1 The edge of the unistrut spring nut should be a minimum of 1/8" away from the open cut end of the unistrut and shall be installed with the spring nut grooves engaged in the unistrut. For two piece one hole clamps that do not use spring nuts, a 1/4" minimum edge distance must be maintained between the edge of the unistrut and the edge of the clamp.

NOTE 2 Handtight is defined as: tightening of the bolts to the maximum possible by hand (i.e., without use of wrenches) with the head of the bolt in contact with the clamp. NOTE 3 Unistrut P2558 clamps do not have to be completely flush with the unistrut or structural member, however, all clamps shall be free of any visual damage (e.g., no cracks, wrinkles, or bulges) after tightening. NOTE 4 P1111 B through P1113B clamp assemblies shall not be used in new installations. Tightening requirements are provided for maintenance of existing installations only. NOTE 5 P-Series and N-Series parts may be used interchangeably, unless otherwise specified on engineering output documents.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 41 of 63 7.0 RECORDS 7.1 QA Record The following QA records are maintained and transmitted with the Work Implementing Document (WID) to RM. Data Sheet 1 - Piping/Tubing Support Installation Data Sheet Data Sheet 2 - Inoperable CSSC/NON-CSSC System Temporary Supports Data Sheet 3 - Permanent Removal of Existing Supports. Attachment 6 - Permanent Support Removal Sketch. 7.2 Non-QA Records Date Sheet 4 - Notification of New Constant/Variable Spring Supports or Modification of Existing Constant/Variable Spring Supports. 8.0 ATTACHMENTS Attachment 1 - Support Fabrication Tolerances. Attachment 2 - Support Installation Tolerances. Attachment 3 - Deleted. Attachment 4 - Figures. Attachment 5 - Pipe Rupture Mitigative Devices. Attachment 6 - Permanent Support Removal Sketch. Attachment 7 - Staking of Carbon Steel Spherical Bearings on Struts and Snubbers. Attachment 8 - Shimming to Obtain Clearance on Pipe Supports. Attachment 9 - Verification Checklist

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 42 of 63 Attachment I (Page 1 of 2) Support Fabrication Tolerances NOTE The following tolerances shall not apply.

1) If the specific support drawing gives more restrictive tolerances.

2) If the specific support drawing refers to the General notes drawing such as 47B435 series which includes these type of tolerances.

Plates and Baseplates A. For plates and baseplates (excluding integral lugs), the width and length dimensional tolerance is +/- 1/4-inch. The thickness may be increased a maximum of 1/4" provided attachment weld size is increased as applicable to meet AISC minimum weld size requirements and maximum attachment thickness in accordance with MAI-5.1B and MAI-5.1C is not exceeded. Integral Lugs B. For integral lugs, the length and height dimensional tolerance is + 1/16 inch and -0 inch. Lug thickness may vary only as permitted by mill tolerances. Structural Members (Angles, Channels, Plates, Beams, etc.) C. For structural members, the member dimensions from building structure to pipe centerline (support point) may be increased or decreased up to 2" to accommodate building or pipe installation tolerances. Internal members of frames may be cut to fit provided all other members meet applicable length tolerances. An erection tolerance of

    +/- 1/4" is allowed for all dimensions pertaining to the pipe support shown on the pipe support drawings, unless otherwise addressed in this document.

D. For nonloaded support overhangs, the length of overhang may be increased by 1/6 of the depth of the member or 2", whichever is greater. E. Rod diameter = + 1/4", -0" F. Angles (except knee braces) = +/- 2 degrees

Attachment I (Page 2 of 2) G. Bolt hole diameter

1. For fasteners subjected to shear, other than baseplates, the hole diameter shall be no more than 1/16" larger than the nominal diameter of the fastener.

2. For fasteners subjected to tension only, such as those used for the attachment of struts, rod hangers, spring hangers, and snubbers, the hole shall be no more than 1/8" larger than the nominal diameter of the fastener for all sizes.

3. Holes in baseplates for concrete anchors may be oversized by a maximum of 1/8" based upon the nominal bolt anchor size. Baseplates with oversize holes in excess of this limit shall be repaired in accordance with MAI-5.9, unless specifically shown otherwise on the support design drawing. Baseplate holes shall be drilled.

Attachment 2 (Page 1 of 3) Support Installation Tolerances 1.0 INSTALLATION TOLERANCES A. Component Standard Support Component Standard Support (Except Sway Struts and Snubbers) [NRC/C] The tolerance of the installation shall be within the range of support adjustment. Full thread engagement of all parts must be maintained. Locking nuts will be acceptable when 50 percent thread engagement of a heavy hex nut is obtained. [NRC Report 85-26] B. Rigid Supports

1. Out-of-roundness of the pipe is a tolerance which must be accommodated.

The inside-to-inside dimension of a support intended to provide lateral support to a pipe shall be interpreted as approximate. The support shall be fabricated around the pipe and shall accommodate this out-of-roundness. All vertical deadweight supports shall be in contact with the pipe upon initial installation.

2. Rigid support drawings typically specify a 1/16" gap between the pipe and the support. The following rules apply to the installation of this type of support:

a. A temporary shim may be used in the fit-up stage of all rigid supports to provide the 1/16" clearance before the installation welding is performed. The temporary shim shall be removed prior to the pipe support acceptance.

b. Note that once the temporary shims are pulled, the clearance may change. This can be caused either by weld shrinkage or expansion of the piping system due to changes in the ambient temperature. This is of no consequence, and no further gap adjustment is required provided the total gap requirements of Section B.2.b.3 are met.

c. Prefabricated and fabricated-in-place supports shall maintain a maximum total gap of 5/32" and a minimum total gap of 1/16". Total gap is the sum of the two gaps on each side of the pipe. The pipe may contact the support on one side provided the total gap tolerance is met. Section B.6 gives additional criteria for minimum total support gap.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 45 of 63 Attachment 2 (Page 2 of 3) 1.0 INSTALLATION TOLERANCES (continued) C. Support members welded to plates which are attached to the building structure by bolting may be located up to 1/2" from the position specified on the support detail sheet. (Plate misalignment may be required to permit installation of concrete anchors.) D. The radial face of lugs which are welded to the process pipe or welded to clamps on the process pipe may be ground down to provide proper clearance in rigid supports if the lugs are located in a radial direction only. Provisions must be made to prevent damage to the process pipe during grinding. E. Shims Shims may be installed to maintain proper clearance between the pipe and the support. Shims shall not be used to correct designs which exceed the tolerance limitations specified above. No shim less than 1/16" thick or greater than 1" thick shall be used. Additional requirements are provided on Attachment 8, Figures H.1 and H.2. The shim size provided in Attachment 8, Figure H.1 is for two-way box type supports only. Shims added to other type supports shall be sized considering pipe movements to ensure restraint during all operating conditions. Shimming material shall be compatible with the material in contact with the pipe for weldability and not producing corrosion through galvanic action. Interfaces between carbon steel and stainless steel shall meet the requirements of G-29, Process Specification 4.M.1.1. The weld sizes for all shim plates shall be as specified on Attachment 8.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 46 of 63 Attachment 2 (Page 3 of 3) 1.0 INSTALLATION TOLERANCES (continued) NOTE SHIMS AND WELDS INSTALLED PER THIS SECTION NEED NOT BE SHOWN ON THE SUPPORT DRAWING. F. Minimum Total Support Gap Criteria Where support drawings show 1/16" or 1/8" gap, Section B.2.b provides a tolerance of a maximum total gap of 5/32" and a minimum total gap of 1/16". Gaps less than 1/16" are acceptable when the criteria in Table 1 are met. Table 1 lists various pipe sizes, operating temperatures, and the respective gap requirements. Piping design temperature may be used if operating temperature is not available. Temperature used may be obtained from flow diagrams, operating mode drawings, or mechanical piping drawing and must be recorded (in IF) on the verification data sheet. Table 1 Minimum Total Support Gaps (inches) TEMPERATURE, T NOMINAL PIPE DIAMETER d (INCHES) (OF) d<6 6< d< 12 12 <d<* 24 T*< 150 L L 1/64 150 < T*< 200 L 1/64 1/32 200 < T < 350 1/64 1/32 1/16 NOTES

1) "Gap" as used above is the total gap of any two opposite sides.

2) "L" is defined as a gap allowing passage of light.

When Table 1 is utilized, record the system operating or design temperature and the minimum total support gap on Data Sheet 1.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 47 of 63 Attachment 3 (Page 1 of 1) Deleted (THIS PAGE HAS BEEN DELETED)

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 48 of 63 Attachment 4 (Page 1 of 2) Figures TRAPEZE TOLERANCE FIGURE D.1 STRU::C:TURE (TYPF) CENTER: LINEOF:RODS, SPRINGS Aii ~i i i~i STUSO SUBR 0 0 A +/- 1/2" B. - I/2"

                                               +~

s CPFR1 STEEL

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 49 of 63 Attachment 4 (Page 2 of 2) OPEN SECTION WELD DETAILS FIGURE D.2 WELD: MAY:.BE:DELETEDý TýWELD MA`Y BE DIELETED-IL WELD MAY BE DELETED

BFN TVA-BFNP.Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 50 of 63 Attachment 5 (Page 1 of 7) Pipe Rupture Mitigative Devices 1.0 SCOPE A. This attachment defines the engineering requirements for installation, modification, and maintenance including materials and erection of pipe whip restraints and jet impingement barriers. General engineering requirements for installation, modification, and maintenance of pipe rupture mitigative devices comply with this document except for some specific aspects as delineated in the remainder of this section. 2.0 DEFINITIONS A. BARRIER - A structural element which mitigates the effect of blowdown jetting by intercepting and redirecting the fluid emitting from a postulated pipe rupture. B. HONEYCOMB CUSHION - A structural element which mitigates the effects of pipe whip resulting from a postulated pipe rupture by absorbing those forces by compressive crushing of the honeycomb core. C. PIPE WHIP RESTRAINT - A structural element which mitigates the effects of pipe whip by constraining the pipe whipping motion caused by a postulated pipe rupture.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 51 of 63 Attachment 5 (Page 2 of 7) 3.0 GENERAL REQUIREMENTS A. Material Requirements Crushable honeycomb cushion material shall be aluminum or stainless steel as defined in Engineering design documents. Crushable honeycomb cushion material shall have a uniform crushing strength. Crushing strengths and material variations shall be as specified in Engineering design documents. Crushable honeycomb cushion material and its bonding adhesive shall be capable of withstanding radiation degradation and shall be fire retardant when cured. B. Technical Requirements An adhesive material, as specified in Engineering design documents, shall be used for bonding honeycomb cushion interface surfaces to a steel or concrete substructure. Tolerances for restraint or barrier steel spacing, orientation, alignment and location on a specific structure (steel plate, structural steel member, or hardened concrete) shall be as specified in Engineering design documents. The joint centerline of structural steel elements shall be installed within +/- 1/2" in plan and elevation as specified in Engineering design documents. Gap clearances between pipe and restraint or barrier steel shall be as specified in Engineering design documents for the hot or cold position of a piping system. Final shimming in either the hot or cold position shall assure that the gap is as specified on Engineering design documents. Tolerances for a gap clearance shall be as follows, unless specified on Engineering design documents:

1. The actual hot and cold position gaps shall not vary more than + 1/8" or - 1/8" from the specified hot and cold position gaps.

2. Pipe and restraints shall not be in contact during any plant mode except for the pipe break event (faulted) or when the restraint is specified as a seismic support in which case the gap clearance shall be in accordance with the pipe support requirements of this document.

Insulation removal or reduction to provide gap clearance shall be as specified on Engineering design documents.

Attachment 5 (Page 3 of 7) 3.0 GENERAL REQUIREMENTS (continued) C. Verification/Monitoring Requirements This section defines the activities and physical attributes that must be verified/monitored to assure that the installed or restored condition conforms to design requirements. Standards and site specific specifications will state the responsibilities for verification/monitoring activities. Verify that the restraint or barrier assembly complies with Engineering design documents with respect to location, orientation, and dimensional tolerances. Verify that restraint and barrier welded assemblies are not installed over areas that require inservice verification. Verification records shall be transmitted to Document Control and Management Services for retention in accordance with SPP-2.4, Records Management. FIGURES FIGURE E.4.1 TYPICAL HONEYCOMB CUSHION PIPE WHIP RESTRAINTS WITH SLEEVE AND LOAD HEAD FIGURE E.4.2 TYPICAL U-BOLT PIPE WHIP RESTRAINT WELDED TO SUBSTRUCTURE FIGURE E.4.3 TYPICAL U-BOLT PIPE WHIP RESTRAINT BOLTED TO SUBSTRUCTURE FIGURE E.4.4 TYPICAL BARRIER

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 53 of 63 Attachment 5 (Page 4 of 7) 3.0 GENERAL REQUIREMENTS (continued) FIGURE E.4.1 NORMAL LOAD DIRECTION PARALLEL WITH LONGITUDINAL IHRUST PIPE AXIS OF HONEYCOMB CELLS

                                                        > <       LATERAL LOAD DIRECTION SLEEVE LOAD HEAD BONDED INTERFACE'_

BASE PLATE, LONIGITUDINAL CELL AXES SUBSTPUCT URE 1 . TYPICAL IHONEYCOHB CUSIIION PIPE WHIP IESTRA114T WITH SLEEVE MND LOAD HIEAD

Attachment 5 (Page 5 of 7) 3.0 GENERAL REQUIREMENTS (continued) FIGURE E.4.2 Ku - oOLTAYde, EFOD4T VIEW vj1EV5W~ 4A TYPICAL U-BOLT PIPE WHIL RESTRAINT WELDED TO SUBSTRUCTURE

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 55 of 63 Attachment 5 (Page 6 of 7) 3.0 GENERAL REQUIREMENTS (continued) FIGURE E.4.3 D- B3OLT MIS il-DOLT PIPE RESTRAIIT BOLTED TO SUBSTRUCTURE TYPICAL.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 56 of 63 Attachment 5 (Page 7 of 7) 3.0 GENERAL REQUIREMENTS (continued) FIGURE E.4.4 6 011C L TYPICAL BARRIER

Attachment 6 (Page 1 of 1) Permanent Support Removal Sketch System No. Work Implementing Document Unit Bldg. Elev. SR 0 QR 0 NQR 0 Locations Design Document/Rev. SKETCH Prepared By Date Retention Period: Lifetime Responsibility: RM ResDonsibilitv: RM Retention Period: Lifetime

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 58 of 63 Attachment 7 (Page 1 of 2) Staking of Carbon Steel Spherical Bearings on Struts and Snubbers NOTE Stainless steel spherical bearings are not to be staked. If any are found to be dislodged, notify the Site Engineering Lead Civil Engineer for instruction. When a strut or snubber contains a carbon steel spherical bearing, which has become dislodged, the spherical bearing shall be staked as described below, unless it has already been previously staked. If the bearing has been staked previously, contact the Site Engineering Lead Civil Engineer for needed corrective action. If a spherical bearing is found to be dislodged from the paddle housing, reinsert by carefully pressing or tapping on the outer race. Use a Bergen Paterson bearing installation tool or an appropriate sized pipe to assure proper alignment. After the spherical bearing has been reinserted into the paddle, use a center punch and move approximately 1/32" away from the exterior of the spherical bearing race and with as little force as possible make 4 punch indentations equally spaced around the race at approximately 90 degrees apart on both sides of the paddle. The punch indentations should displace a small amount of metal over the edge of the exterior spherical bearing race to keep it from dislodging again. The spherical bearing race is a hardened material and shall be looked at very closely to ensure that the staking process has not damaged the race in any way (i.e., such as cracking, deforming, or spalling). Ensure that the ball moves with little force in the race. If the ball sticks or binds, rotate it to expose the exterior surface and place a small amount of Never-Seize compound on it. Move the ball around until it moves with little force. If unable to move the ball with little force after this, contact the Site Engineering Lead Civil Engineer to evaluate the spherical bearing. The following is a list of Bergen-Paterson part numbers for strut and snubber assemblies which use carbon steel and stainless steel spherical bearings.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 59 of 63 Attachment 7 (Page 2 of 2) These part numbers use stainless steel bearings: 2015, 2249 (end attachment end), 2250, 2251 (end attachment end), 2252, 2410.(end attachment end), 2411 (end attachment end), 2420, 2421, 2440, 2525, 2530, and 2540 (end attachment end). These part numbers use carbon steel bearings: 2000, 2010, 2100, 2200, 2249 (clamp end), 2251 (clamp end), 2410 (clamp end), 2411 (clamp end), 2510, 2515, and 2540 (clamp end).

Attachment 8 (Page 1 of 2) Shimming to Obtain Clearance on Pipe Supports

                                                             ...          OR AAý r~q LEGEND, A      =   SHIM LENGTH =(b    + 3q ),  (TOL -1/4", -Fr OR -3F]   F13R FLARE BEVEL WELDS)

B SHIM WIDTH = MINIMUM SHALL IE THE GREATER OF 1/3 NOMINAL DIAMETER OR 1/2" b= WIDTH OF MEMBER TO BE SHIMMED t SHIM THICKNES,; F= FILLET WELD SIZE NOTES,'

1) WELD LENGTH TO BE 1/2 THE VIDTH OF THE SHIM (MINIMUM) AN) TO BE PLACED IN THM MIDDLE OF SHIM WIDTH OR AT EACH EN1, LENGTH OF WELD SHALL NOT BE LESS THAN V' - DXCEPT WHEN SHIN WIITH T, 1 1',

VELD ENTIRE LENGTH. rOR 6 INCH AND LAPRr' PIPE TOTAL WELD LENGTH SHALL BE AT LEAST 2"

2) AItC MINIMUM WEL. 3SIZE REQUIRED' SHALL BE MET FO SHIMS < ]/8' THICKNESS, WELD SIZE SHALL BE THICKNESS OF SHIN.

3) VELDING IS REQUIRED[ON A MINIMUM [IF TWO OPPOSITE SIDES OF THE SHIM

4) WHEN'JDETERMINING SHIM SIZE IN CONJUNCTION WITH FLARE BEVEL VELDS, F1 SHALL BE TAKEN AS 1/4'

         -   FOR USE WITH TUBE STEEL MEMBERS SHIMMING TO OBTAIN CLEARENCE FOR 2-/AY ]BOX TYPE SUPPORTS ONLY RESTRAINT SHIMMING FIGURE H.1

Attachment 8 (Page 2 of 2) A OPTIONAL WELDED SHIM HOLE C/C - (U*ED T EN0 APPVAL OILY) U-BOLT ROD C/C w.Ds sAI4 As Pir. 14 0, SHIM PLATE [MAX. THICKNESS = I-) SECTION A-A CLEARANCE AND SHIMS AT U-BOLTS FIGURE H.2 NOTE SHIMS BETWEEN THE PIPE AND STRUCTURAL STEEL ARE TO BE INSTALLED WHEN REQUIRED WITH A FILLET WELD ALONG TWO OPPOSITE SIDES OR WITH THE U-BOLT INSTALLED THROUGH HOLES IN THE SHIM.

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 62 of 63 Attachment 9 (Page 1 of 2) Verification Checklist Data Sheet1 (PIPING/TUBING SUPPORT INSTALLATION) MIP Procedure Description / Instruction Attribute Code Paragraph U08-D03 6.1K Verify documents used to perform inspections are Documentation/ 6.1S as specified in the work controlling document. Prerequisites Verify that the work performance documents/data sheets have been signed acceptable. Verify that anchor spacing for supports utilizing concrete anchors and supports attaching to embeds is acceptable. U08-M12 6.1N Verify structural member size and shapes are Size / Shape correct. Verify standard components i.e. catalog items are the correct size. Verify the Bergen-Patterson mechanical snubber part number load designation coincides with the PSA snubber load capacity rating. U08-M1 3 6.1 N Verify structural member type and grade are correct. Type / Grade Verify bolting material spec and grade are correct. U08-MO1 6.1 L All supports shall be inspected for proper unique Identification identifier, as defined by design output documents, and identification method. U08-W1 1 6.2B.7 Verify support is correct in regards to the Configuration relationship of members as required by design output/ work documents (e.g., structure to pipe dimensions, connection angles, attachment locations, etc.). U08-W13 6.2B.8 Verify base plate dimensions are acceptable. Verify Dimensions support member lengths are acceptable. Verify bolt hole minimum edge distances are acceptable. U08-W12 6.1F Verify support location is acceptable. Location 6.2B.1 6.2C.2 6.2C.4 6.2C.5 6.2C.6

BFN TVA-BFNP Piping/Tubing Supports MAI-4.2A Unit 0 Rev. 0038 Page 63 of 63 Attachment 9 (Page 2 of 2) Data Sheet1 (PIPING/TUBING SUPPORT INSTALLATION) MIP Procedure Description / Instruction Attribute Code Paragraph U08-M04 6.1G Verify that support material and/or components are Physical 6.1M free of physical damage. Damage 6.1Q Verify that moving parts of snubbers, fluid fill fittings, 6.1S weep holes and sight glasses are free of paint. ATT. 7 Verify springs shall show no visible signs of damage such as broken or deformed coils, cracked welds, canister deformation or corrosion. Verify spherical bearings are properly in place and free to rotate. U08-W54 6.2B.10 Verify that minimum thread engagement Torque / 6.2F requirements are met for completed attachments. Engagement/ 6.2K Verify fasteners (i.e. bolting materials, springs nuts, Tightening 6.6.1.7 etc.) for completed attachments are properly ATT. 2 Item 1.OA tightened. Verify locking devices are installed if specified by design output. U08-M02 6.10 Verify that materials used have valid heat numbers / Traceability lot numbers / serial numbers, as required. U08-W1 0 6.1S Verify that directional orientation of the support Orientation 6.2B.6 (structural and components) including baseplates, is as required (i.e., vertical, longitudinal and lateral). U08-W1 7 6.1S Verify that clearance between supports and Support 6.2B.9 adjacent components / structures will allow for full Clearances / ATT. 2 Items travel of non-rigid supports. Gaps 1.0B, 1.0D, Verify that gaps between supports and pipe / tubing 1.OE, 1.0F / lugs are acceptable. Verify that the space between the ears of bracket _ _ _ assemblies and / or clamps is acceptable. U08-T22 6.1 S.1, 6.1S.3 Verify that spring and snubber settings are as Settings 6.2B.11 .b, required by manufacturers' instructions and design 6.2B.11.c output.

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