ML051640385

Third 10-Year Interval Inservice Inspection Program Owner'S Activity Report

ML051640385
Person / Time
Site:	Hatch
Issue date:	06/07/2005
From:	Sumner H Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-05-0989
Download: ML051640385 (17)

Text

{{#Wiki_filter:H.L Sumner, Jr. Southern Nuclear Vice President Operating Company, Inc. Hatch Project Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7279 SOUTHERN A June 7, 2005 COMPANY Energy to Serve Your World Docket No.: 50-366 NL-05-0989 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Unit 2 Third 10-Year Interval Inservice Inspection Program Owner's Activity Report Ladies and Gentlemen: Enclosed is the ASME Section XI Code Case N-532 OAR-I Owner's Activity Report for the Hatch 2R17 Refueling Outage (3rd ISI Interval, 3 rd Period, 1" Report) and the Hatch 2R18 Refueling Outage (3rd ISI Interval, 3rd Period, 2nd Report). The Hatch 2R17 OAR-I Report (approved by site management on July 10, 2003) is submitted in accordance with the requirements set forth in Hatch Relief Request RR-14, which was approved by NRC safety evaluation dated June 16, 1997 (TAC Nos. M93918 and M93919). Relief Request RR-14 adopted the use of Code Case N-532 (no addenda), which required the submittal of OAR-I each ISI Period. The Hatch 2R1 8 OAR-I Report (approved by site management on May 27, 2005) is submitted in accordance with the requirements set forth in Revision 13 of Regulatory Guide 1.147 (effective date of August 7, 2003 as shown in Federal Register Vol. 68, No. 130). Regulatory Guide 1.147, Revision 13 approved the use of Code Case N-532-1 with the added requirement that the OAR-I Report be submitted for each outage within 90 days after the completion of the outage related 1SI activities. This letter contains no NRC commitments. If you have any questions, please advise. Sincerely, H. L. Sumner, Jr. HLS/IFL/daj

Enclosures:

1. Owner's Activity Report 2-3-3-1

2. Owner's Activity Report 2-3-3-2 AOW7

U. S. Nuclear Regulatory Commission NL-05-0989 Page 2 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. G. R. Frederick, General Manager - Plant Hatch RTYPE: CHAO2.004 U. S. Nuclear Regulatorv Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Hatch Mr. D. S. Simpkins, Senior Resident Inspector - Hatch

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Report Number 2-3-3-1 (Unit 2, 3rd Interval, 3rd Period. 1" Report) Owner Southern Nuclear Operating Co. (as agent for Georgia Power Company). 40 Inverness Center Parkway, Birmingham, Al 35242 (Name and Address of Owner) Plant Edwin 1.Hatch Nuclear Plant, Route 1, Box 278, Baxley, Georgia 31513 (Name and Address of Plant) Unit No. 2 Commercial service date 9/5/79 Refueling outage no. 2R17 (if applicable) Current inspection interval 3rd (Ist, 2nd, 3rd, 4th, other) Current inspection period 3rd (Ist, 2nd, 3rd) Edition and Addenda of Section Xl applicable to the inspection plan 1989 Edition Date and revision of inspection plan 11/19/02, Revision 8 Edition and Addenda of Section Xl applicable to repairs and replacements, if different than the inspection plan Same CERTIFICATE OF CONFORMANCE I certify that the statements made in the Owner's Activity Report are correct, ad that the examinations, tests, repairs, replacements, evaluations, and corrective measures represented by this report conform to the requirements of Section Xl. Certificate of Authorization No. N/A Expiration Date NIA

                                                      * (if applicable)

Signed 6A , , _ _ Date 9,//0o/q Zg

       ,V,4/6k7P7J'-04_           Owner or Owner's Designee, Title CERTIFICATE OF INSERVICE INSPECTION 1,the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of Georgia and employed by                     Hartford Steam Boiler Inspection & Insurance Company         of Hartford, CT have inspected the items described in this Owner's Activity Report, during the period                 10/18/01        to 3/31/03         , and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report in accordance with the requirements of Section Xl.

By signing this certificate neither the Inspector nor his employer makes any warranty, epressed or implied, concerning the examinations, tests, rrs, replacements, evaluations and corrective measures described in this report. Furthermore, neither the ipmpctor nor hisem °y be liable in any manner for any personal injury or proparty damage or a loss of any kind arising shq; 6Xomcallcte w hlls cton. Commissions Georgia - GA 00115 nspctor s Signature National Board, State, Province, and Endorsements Date 7-/6Ib3 This form (EQ0127) may be obtained from the Order Dept., ASME, 22 Law Drive, Box 2300, Fairfield, NJ 07007-2300. 2rl 7oar.doc Page 1 of 5

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R17 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS See Table 1 of the OAR-I Report for 2R1 8. 2rl 7oar.doc Page 2 of 5

FORM OAR-I OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R17 OUTAGE TABLE 2 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRED EVALUATION FOR CONTINUED SERVICE NO FLAWS OR RELEVANT CONDITIONS THAT REQUIRED EVALUATION FOR CONTINUED SERVICE WERE IDENTIFIED DURING THE PLANT HATCH UNIT 2, 2R17 OUTAGE. 2rl 7oar.doc Page 3 of 5

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R17 OUTAGE TABLE 3 ABSTRACT OF REPAIRS, REPLACEMENTS, OR CORRECTIVE MEASURES REQUIRED FOR CONTINUED SERVICE Flaw or Relevant Condition Found Repair, During Scheduled Replacement, Section XI Repair/ Code or Corrective Item Description Examination or Date Replacement Class Measures Description of Work Test (Yes/No) Complete Plan Number Replace stem/disc assembly due to inservice failure. Skim cut Replacement 24" MSIV new stem/disc assembly that has no hard facing. Component No 1/9/2002 2-01-03746 ______ MPL 2B21-F028B. II I _ _ _ I__ _ _ _ _ _ 1 2rl 7oar.doc Page 4 of 5

FORM OAR-I OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R17 OUTAGE ATTACHMENT 1 AUGMENTED INSPECTIONS PERFORMED ASME Exam Exam Cal Exam/Cal Result Section XI Figure No. Exam/Area Procedure Block Sheet No. Results Comments Remarks B9.11 A-17/05 2B31-I1RCM-28AD-3 UT-H-402 128-H S03H2P003 NRI Root 50% examined. B-J Valve to Elbow PT-H-600 S031H2U052 NRI Geometry Relief Request NUREG-0313A S03H2U053 NRI required. S03H2U054 NRI S03H2U055 RI B9.11 A-16/07 2B31-IRCM-28AS-9 UT-H-402 128-H S03H2P002 NRI Root NA B-J Valve to Elbow PT-H-600 S03H2U025 NRI Geometry NUREG-0313A S03H2U026 RI S03H2U028 NRI B83/04 2C11-2CRD-3-2FW-1611 UT-H-401 4-H S03H2U016 NRI NA NA Pipe to Reducer S03H2UO017 NRI NUREG-0619 B83/04 2C11-2CRD-4-2FW-1611 UT-H-401 142-H S03H2U018 NRI NA 66% examined. Reducer to Tee S03H2U019 NRI Relief Request NUREG-0619 required. B83/04 2G31-2RWCU4-2FW-33 UT-H-401 142-H S03H2U020 NRI NA 82% examined. Tee to Pipe S031H2U021 NRI Relief Request NUREG-0619 required. B85/04 2C11-2CRD-8N-SDV-5 MT-H-500 S03H2M027 NRI NA NA Elbow to Pipe NUREG-0803 Augmented IVVI was performed in accordance with the examination guidelines of the following reports: BWRVIP-18 BWRVIP-41 BWRVIP-48 2rl7oar.doc Page 5 of 5

PLANT HATCH UNIT 2, 2R18 OUTAGE FORM OAR-1 OWNER'S ACTIVITY REPORT Report Number 2-3-3-2(Unit 2, 3d Interval, 3d Period, 2nd Report) Owner Southern Nuclear Operating Co. (as agent for Georgia Power Companv), 40 Inverness Center Parkwav, Birmingham, AL 35242 (Name and Address of Owner) Plant Edwin I. Hatch Nuclear Plant, P. 0. Box 2010, Baxley, Georgia 31515 (Name and Address of Plant) Unit No. 2 Commercial service date 9/5/79 Refueling outage no. 2R18 (if applicable) Current Inspection Interval 3rd (1st, 2nd, 3rd, 4th, other) Current Inspection period 3 rd (1st, 2nd, 3rd) Edition and Addenda of Section Xi applicable to the Inspection plan 1989 Edition/lNo Addenda Date and revision of Inspection plan 11/12/04, Revision 8 Edition and Addenda of Section XI applicable to repairs and replacements, If different than the Inspection plan Same CERTIFICATE OF CONFORMANCE I certify that the statements made In the Owners Activity Report are correct, and that the exams, testss,repairs, replacements, evaluations, and corrective measures represented by this report conform to the requirements of Section (I. Certificate of Authorization No. N/A Expiration Date N/A (if applicable) Sign iP L . S'd / /Q Date 5/Z 7/105s Owner or Owner's Designee, Title CERTIFICATE OF INSERVICE INSPECTION 1,the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vess el Inspectors and the State or Province of Geormia and employed by Hartford Steam Boiler Inspection & Insuran<ce Corrivanv of Hartford, CT have inspected the items described In this Owners Activity Report, for Refueling Outaae 2R,18, and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report In accordanceewith the requirements of Section Xi. By signing this certifigdl neither the Inspector nor his employer makes any warranty, expressed or Imiplied, concerning the exams,

          ,sepairs,replacemrntq, eval tions and corrective measures described In this report. Furthermore, neither the Inspector nor his (npldyer aeI bejiablf in $ny rrlber for any personal Injury or property damage or a loss of any kind airising mr            ctmiq                                           mn Innn                 ron.
                 .t            Y(Y-{.
                              <v                                 tCommissions                  ( 2 11         0Z      I IS, Tnspectors Signature                                                National Board, State, Province, and Endorsements Date        -        P:27- O5 This form (E00127) may be obtained from the Order Dept., ASME, 22 Law Drive, Box 2300, Fairfield, NJ 07007-2300. (Modified for an outage frequency versus a period frequency)

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FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Exam Total Total Total Total Exams Category/ltem Exams Exams Exams Credited (%/) To Number Required Credited Credited Date for Remarks (See Note 1) (See Note 3) for for (%) Interval 3 Interval 3 Period 3 for Period 3 (See Note 2) B-ANB1.11 0 0 0% 0% NRC approved RR-38 allowed deletion of exams per BWRVIP-05. B-A/B1.12 12 12 100% 100% B-ANB1.21 2 2 100% 100% B-A/B1.22 19 11 58% 100% B-A/B1.30 1 1 100% 100% B-ANB1.40 1 0 0% 100% B-A Total 35 26 74% 100% Each item is either deferrable, required to be examined in a specific period, or there are less than 3 items. Therefore, N-532-1 percentages do not apply. See Relief Request RR-28. B-D/B3.90 28 19 68% 100% The 2N15 RPV drain nozzle is located inside the CRIs and is not accessible. NRC approved RR-3 allows deletion of the 2N15 examination. Therefore, 28 exams were scheduled. B-D/B3.100 28 19 68% 100% The 2N15 RPV drain nozzle is located inside the support skirt and is not accessible. NRC approved RR-3 allows deletion of the 2N15. examination. Therefore, 28 exams were scheduled. B-D Total 56 38 68% 100% B-E/B4.11 NA NA NA NA Performed as part of the Category B-P pressure tests. B-E/B4.12 B-2/1B4.13 B-F/B5.10 NA NA NA NA NRC approved Relief Request RR-39 eliminates Code exam B-F/B5.20 percentage requirements for dissimilar and stainless steel welds. B-F/B5.130 In lieu of the Code, the number of welds to be examined and the frequency of the exam will be as specified in BWRVIP-075. Page 2 of 10

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Exam Total Total Total Total Exams Category/Item Exams Exams Exams Credited (%) To Number Required Credited Credited Date for Remarks (See Note 1) for for (%) Interval 3 Interval 3 Period 3 for Period 3 (See Note 2) B-G-1/B6.10 56 20 36% 100% Per NRC approved relief request RR-1, a VT-1 exam was performed in lieu of the surface exam. B-G-1/B6.20 56 20 36% 100% NRC approved Relief Request RR-35 implements Code Case N-B-G-1/B6.30 307-3 and allows the deferral of these exams until the end of the interval as long as there is no more than 10 years between

                     ._                                          inspections.

B-G-1/B6.40 56 20 36% 100% NRC approved Relief Request RR-35 allows the deferral of these exams until the end of the interval as long as there are no more than 10 years between inspections. B-G-1/16.50 56 20 36% 100% NRC approved Relief Request RR-35 allows the deferral of these exams until the end of the interval as long as there are no more than 10 years between inspections. B-G-1/B6.180 NA NA NA 100% These exams are not deferrable; however, they are required only B-G-1/B6.200 when the B-L-2 visual exam of the internal surfaces of a pump are performed. During 2R16 (2'nd period), the B-L-2 visual examination was performed on Pump B and the 16 studs were volumetrically examined to meet B-G-1 requirements B-G-1 Total 224 80 36% 100% Each item is either deferrable or required only in conjunction with another exam. Therefore, N-532-1 percentages do not apply. B-G-2/B7.50 6 3 50% 100% Piping Flange Bolting examinations are required for flange bolting located on piping subject to examination. B-G-2/B7.70 NA NA NA NA Examination of pressure-retaining valve bolting is required only when Category B-M-2 visual exams are performed. B-G-21B7.80 NA NA NA NA A VT-1 is performed on existing bolting (for CRD's getting swapped out) prior to any bolting being replaced following removal of the bolting. A final VT-1 is performed for replacement bolting (for CRD's getting swapped out) prior to the bolting being installed. B-G-2 Total 6 3 50% 100% Only Item B7.50 bolting is scheduled for examination per the percentage requirements of Code Case N-532-1. Page 3 of 10

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Exam Total Total Total Total Exams Categoryfltem Exams Exams Exams Credited (%) To Number Required Credited Credited Date for Remarks (See Note 1) for for (%) Interval 3 Interval 3 Period 3 for Period 3 (See Note 2) B-H NA NA NA NA Code Case N-509 used for selection. Re-named as Category B-K by the Code Case. B-J/B9.12 NA NA NA NA Code Case N-524 provides alternate examination criteria for B-JIB9.22 longitudinal welds. B-J/B9.11 76 29 38% 100% NRC approved Relief Request RR-39 allows relief from Code exam B-JIB9.21 percentage requirements for stainless steel Category B-J piping. B-J/B9.31 (Also Category B-F). Therefore, only carbon steel welds are B-J/B9.32 shown. B-J Total 76 29 38% 100% B-K/B130.10 7 5 71% 100% Selected per Code Case N-509. Also, Relief Request 24 implements Code Case N-323-1 for the RPV skirt weld (with the provision that a best-effort UT exam be performed). B-K/B130.20 6 2 33% 100% Selected per Code Case N-509. B-K/B1 0.30 1 0 0% 100% Code Case N-509 was used; therefore, one integral attachment on

                        ._                                         one RC pump was examined during the 1st period.

B-K Total 14 7 50% 100% B-L-2 NA NA NA 100% Category B-L-2 applies only to the 2 RC pumps. During the 2'm period, the B-L-2 visual exam was performed on RC Pump B. Only one pump in a group is required to be examined per B-L-2 requirements, thus, B-L-2 requirements were satisfied. B-M-2 NA NA NA NA Category B-M-2 applies to 16 groups of valves. Examination of the valve internal surface is limited to one valve in a group and is required only when a valve is disassembled for maintenance or repair. Examinations were performed in nine of the valve groups during the 3id Interval. Page 4 of 10

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Exam Total Total Total Total Exams Category/item Exams Exams Exams Credited (%)To Number Required Credited Credited Date for Remarks (See Note 1) for for (%) Interval 3 Interval 3 Period 3 for Period 3 (See Note 2) B-N-1/B133.10 3 1 33% 100% Examination of vessel interior is performed once per period. B-N-2/ B13.20 NA NA NA 100% Exams are deferrable until the end of the 3"" interval. Item B-N-2/ B13.30 numbers are combined because a VT-1 is performed on all attachment welds. B-N-2/B1 3.40 NA NA NA 100% Exams are deferrable until the end of the 3"' interval; therefore, N-532-1 percentages do not apply. The accessible surfaces of the welded core support structure were examined. B-N-2 Total 3 1 33% 100% B-P/B135.10 NA NA NA NA A system leakage test is performed each refueling outage. B-P/B115.50 B-P/B315.60 B-P/B1 5.70 B-P/B1 5.11 NA NA NA NA Plant Hatch utilizes ASME Xl Code Case N-498-1 (which allows B-P/B1 5.51 pressure testing at nominal system operating pressure) to meet B-P/B1 5.61 hydrostatic test requirements. Therefore, the system leakage test B-P/B1 5.71 with extended boundary (to 2nd isolation valve) and 4-hour hold time satisfies the hydrostatic test requirement at the end of the interval. Page 5 of 10

FORM OAR-i OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2,2R1 8 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Exam Total Total Total Total Exams Category/Item Exams Exams Exams Credited (%)To Number Required Credited Credited Date for Remarks (See Note 1) for for (%/) Interval 3 _______ Interval 3 Period 3 for Period 3 (See Note 2) C-ANC1.10 3 1 33% 100% RHR Heat Exchanger A examined. C- /C 1.2 0_ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ C-B/C2.21 4 3 75% 100% There are two nozzles on each of the two RHR Heat Exchangers. C-BIC2.22 The Code requires that the equivalent of one RHR Heat Exchanger be examined in the 10-year interval. Two nozzle-to-shell and two ___ _ _ ___ ____ ___ __ ___ ___ ___ ___ inner radii w ere exam ined. 0-C/03.10 1 0 0% 100% Code Case N-509 was used; therefore, one integral attachment on __________ _______ ________one RHR Heat Exchanger was examined during the 1m period. C-C/C3.20 19 5 26% 100% Code Case N-509 was used. 10% of the non-exempt piping __________ __________________integral attachments is required to be examined. C-C/Total 20 5 20% 100% C-F-2/C5.52 NA NA NA NA Code Case N-524 provides alternate examination criteria for C-F-2/C5.62 longitudinal welds. C-F-2/C5.82 _____ C-F-2/C5.51 92 32 35% 100% C-F-21C5.81 _________ ______________________ C-F-2 Total 92 32 35% 100% C-H/C7.10 NA NA NA NA These operating pressure tests are performed each inspection C-HIC7.30 period; therefore they are performed three times per inspection C-HIC7.50 interval. Therefore, reporting percentage completion for these C-H/C7.70 ______ ___________________ pressure tests is not appropriate. Page 6 of 10

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Exam Total Total Total Total Exams Categorylitem Exams Exams Exams Credited (%/) To Number Required Credited Credited Date for Remarks (See Note 1) for for (%) Interval 3 Interval 3 Period 3 for Period 3 (See Note 2) C-H/C7.20 NA NA NA NA Plant Hatch utilizes Code Case N-498-1 (which allows pressure C-H/C7.40 testing at nominal system operating pressure) to meet hydrostatic C-H/C7.60 test requirements. Therefore, pressure testing of virtually all C-H/C7.80 Class 2 piping and components is performed in conjunction with system operating or surveillance procedures. Piping and components that are not pressurized in conjunction with any system operating procedure or system surveillance procedure require a N-498-1 pressure test once per interval. There are only two Class 2 tests that are not performed using either system or surveillance procedures. These two tests are performed once each interval and the ASME Xl Code allows deferral until the end of the interval; therefore, reporting percentage completion for these pressure tests is not appropriate. D-A 14 4 29% 100% Code Case N-509 was used. 10% of the non-exempt piping integral attachments is required to be examined. F-A/F1.10 27 10 37% 100% Class 1 piping supports selected per Code Case N-491-1 (25% of non-exempt supports required to be examined). F-A/F1.20 54 15 28% 100% Class 2 piping supports selected per Code Case N-491-1 (15% of non-exempt supports required to be examined). F-A/Fl.30 32 9 28% 100% Class 3 supports. Not required for this report, but included in the Code Case N-491-1 count to determine percentages. F-A/Fl.40 18 6 33% 100% Class 1 and 2 supports other than piping supports - selected per ICode Case N-491 -1. F-A/Class 1&2 132 41 31% 100% Total I Page 7 of 10

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS NOTES: Note 1: Interval 3 requirements were completed during 2R18. Note 2: NRC approved Code Case N-598 isused to determine the required percentage of exams, except in cases where there are less than three items or welds to be examined in an Exam Category. Inthis case the item or welds may be examined in any two periods or in any one period if there is only one item or weld. (See NRC approved Relief Request RR-28). Note 3: Those Category/Items not shown are not applicable for Plant Hatch. Page 8 of 10

IJ FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R18 OUTAGE TABLE 2 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRED ANALYTICAL EVALUATION FOR CONTINUED SERVICE None reported for the 2R1 8 outage. Page 9 of 10

FORM OAR-1 OWNER'S ACTIVITY REPORT PLANT HATCH UNIT 2, 2R1 8 OUTAGE TABLE 3 ABSTRACT OF REPAIRS, REPLACEMENTS, OR CORRECTIVE MEASURES REQUIRED FOR CONTINUED SERVICE Code Repair Item Description of Work Flaw or Relevant Date Repair/ Class Replacement Description Condition Found Complete Replacement Corrective during Scheduled Plan Measure Section XI Exam Number

                 ._                                                                          or Test (Yes/No)

I Replacement Snubber Replace mechanical snubber (PSA-35) with a Lisega No 3/1/2005 2040754201 hydraulic snubber (3072) per ED 00-9070. Functional testing was started but not fully completed for 2B21-MS-R49B, as it was apparent that it was failing its functional test. Therefore, by default, 2B21-MS-R49B is classified as an inservice failure due to failing its functional test. Additionally, 2B21-MS-R49A also failed its functional test and was classified as an inservice failure. I Replacement Snubber Replace mechanical snubber (PSA-35) with a Lisega No 3/1/2005 2040754101 hydraulic snubber (3072) per ED 00-9070. Additionally, attachment pin to be replaced due to having to be cut for removal of snubber from clamp. Following removal of mechanical snubber, it failed its functional test, as it was found locked up. Therefore, 2B21-MS-R49A is classified as an inservice failure due to failing its functional test. Reference CR's 2005102460 and 2005102492. Page 10 of 10}}