L-2015-164, Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Requirements

Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Requirements

ML15198A029
Person / Time
Site:	Saint Lucie
Issue date:	07/15/2015
From:	Costanzo C Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2015-164
Download: ML15198A029 (36)

Text

0July

]*FPL 15, 2015 L21-6 10 CFR 50.90 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

St. Lucie Unit 1 Docket No. 50-335 Fourth Ten-Year Inservice Inspection Interval License Amendment Request Changes to Snubber Surveillance Reqiuirements Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) is submitting a request for an amendment to the Technical Specifications (TS) for St. Lucie Unit 1.

The proposed amendment would revise the Technical Specification (TS) surveillance requirements (SRs) for snubbers to conform to revisions to the Snubber Testing Program. provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 contains a detailed comparison of the current TS 4.7.9 SR to the proposed Snubber Program requirements and justification of changes. Attachment 5 provides a copy of the proposed Snubber Testing Program Plan. Attachment 6 provides the revised snubber program bases description, for information only.

FPL is requesting that this be processed as a normal amendment request, with approval of the proposed amendment by September 1, 2016 to support the fall 2016 Unit 1 outage. Once approved, the amendment shall be implemented within 60 days.

If you should have any questions, please contact Mr. Ken Frehafer at (772) 467-7748.

I declare under penalty of perjury that the foregoing is true and correct.

Florida Power &,Light Company 6501S8. Ocean Drive, Jensen Beach, FL 34957

L-2015-164 Page 2 Executed on -* - [ ,2015.

Sincerely, Christopher R. Costanzo Site Vice President St. Lucie Plant cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Nuclear Plant Ms. Cindy Becker, Florida Department of Health Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages

4. TS 4.7.9 SR Comparison to ISI Program Requirements

5. Proposed Snubber Program Plan

L-2015-164 Attachment 1 Page 1 of 5 DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90, Florida Power & Light (FP&L) is submitting a license amendment request to revise Technical Specification (TS) 3/4.7.10, "Snubbers," for St. Lucie Unit 1. The proposed change would revise the TS surveillance requirements for snubbers to conform to the revised St. Lucie Unit 1 Snubber Testing Program for the remainder of the fourth ISI interval to be made consistent with the 2004 Edition thru 2006 Addenda of the ASME OM Code, Subsections ISTA and ISTD and with similar proposed changes approved for the Snubber Testing Program at St. Lucie Unit 2.

2.0 DETAILED DESCRIPTION The St. Lucie Unit 1 Fourth 10-year ISI interval began February 11, 2008 and will continue until February 10, 2018. Currently, as described in Technical Specifications, TS 3/4.7.10 and FPL Fourth 10-Year Inspection Interval Program submittal letter L-2008-043, dated March 13, 2008, (ML080810193) snubber testing and examination are performed in accordance with the requirements of 10 CFR 50.55a(b)(3)(v), which allows the use of Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, based upon the 2001 Edition through 2003 Addenda. As allowed by 10 CFR 50.55a(g)(4)(iv),

FP&L is proposing the use of Subsection ISTD, of the ASME OM Code, 2004 Edition with 2005 and 2006 Addenda for the remainder of the St. Lucie Unit 1 Fourth 10-year ISI interval, subject to Commission approval. The proposed changes to the St. Lucie Unit 1 TS are summarized below:

• TS Surveillance Requirement (SR) 4.7.10 would be revised to remove specific surveillance requirements for demonstrating snubber operability. The current requirements would be replaced by a reference to the Snubber Testing Program."1

• A new TS Section 6.8.4.p, "Snubber Testing Program," will be added to the Administrative Controls section (Section 6.0) of TS to provide a description of the snubber program requirements.

Mark-ups of the proposed TS pages are provided in Attachment 2. Retyped TS pages reflecting the proposed changes are provided in Attachment 3. Attachment 4 contains a detailed comparison of the current TS 4.7.10 SR to the proposed snubber program requirements and justification of the changes. contains the Snubber Testing Program Plan.

3.0 TECHNICAL EVALUATION

Licensees are required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v) to perform the ISI and testing of snubbers in accordance with the ASME OM Code and the applicable addenda, except where the NRC has granted specific written relief pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

As noted in Regulatory Issue Summary 2010-06, licensees have the option to control the ASME Code-

L-2015-164 Attachment 1 Page 2 of 5 required SIl and testing of snubbers through their TS or other licensee-controlled documents. For plants using their TS to govern 151and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised 151 program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, when proposing program alternatives in accordance with 10 CFR 50.55a(3) and 10 CFR 50.55a(g)(4)(iv), licensees must submit any requested amendments to ensure their TS remain cor~isistent with the code of record or NRC- approved alternatives.

The proposed change revises the specific TS requirements for snubber examination, testing and service life monitoring with a reference to the Snubber Testing Program, thereby ensuring the TS requirements remain consistent with the revised snubber testing program.

Snubbers will continue to be demonstrated OPERABLE by performance of the Snubber Testing Program.

This program will be maintained in compliance with 10 CFR 50.55a per the proposed TS section 6.8.4(p).

The program for inspection and testing of snubbers in accordance with ASME OM Code and the applicable addenda as required by 10 CFR 50.55a(g) includes an evaluation of supported components or systems when snubbers are found to be unacceptable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements St. Lucie Unit 1 is currently operating within the fourth 10-year ISI interval, which began February 11, 2008.

Currently, snubber testing and examination are performed in accordance with the specific requirements of TS 3/4.7.10 and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, based upon the 2001 Edition through 2003 Addenda as described in St. Lucie Unit 1 Fourth 10-Year Inspection Interval Program submitted in FPL letter L-2008-043, dated March 13, 2008.

10 CFR 50.55a(g)(3)(v) states all components (including supports) may meet the requirements set forth in subsequent editions to the "Code of Record" and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to conditions listed therein. If a revised ISI program for a facility conflicts with the TS for the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TS at least six months prior to the start of the period the provisions become applicable.

Once approval is received, for the remainder of the St. Lucie Unit 1 fourth 10-year ISI interval which ends February 10, 2018, FP&L intends to adopt the 2004 Edition with Addenda through 2006 of Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in place of the ASME OM Code, 2001 Edition with 2003 Addenda and specific requirements of TS 3/4.7.10 as previously submitted in correspondence dated March 13, 2008.

The purpose of this amendment request is to revise the specific surveillance requirements for

L-2015-164 Attachment I Page 3 of 5 demonstrating snubber operability in the TS since the surveillance program will be revised to include the requirements of the 2004 Edition with Addenda through 2006 of the OM Code Subsection ISTD for the Snubber Testing Program. As such, the proposed changes to TS 3/4.7.10 are necessary to conform the TS to the revised snubber testing program.

4.2 Precedent The proposed changes are similar to those submitted for St. Lucie Unit 2 in FPL letter L-2014-027 dated January 30, 2014 (Accession No. ML14049A284) and supplemented by FPL letter L-2014-227 dated July 21, 2014 (Accession No. ML14212A395). These changes were subsequently approved by the NRC in their SER dated January 20, 2015 (Accession No. ML14342A785). The resulting changes would allow management of both snubber surveillance programs at FPL St. Lucie Units 1 and 2 to be utilizing the same ASME Code of reference year and addenda.

The changes proposed to TS 3/4.7.10 are also similar to changes submitted by Public Service Electric and Gas (PSEG) Nuclear, LLC for Salem Generating Station, Units 1 and 2 and Dominion Nuclear Connecticut (DNC), Inc. for Millstone Power Station Unit 2. The applicable references for NRC approval of these similar changes are provided below:

NRC Letter Dated August 25, 2011, Salem Nuclear Generating Station, Unit Nos. land 2 - Issuance of Amendments Re: Technical Specification Requirements for Snubbers (TAG Nos. ME4796 and ME4797),

(Accession No. ML112020359).

NRC Letter Dated June 28, 2012, Millstone Power Station, Unit 2 - Issuance of Amendment Re:

Snubber Surveillance Requirements (TAC No. ME7221) (Accession No. ML12165A220).

4.3 No Significant Hazards Consideration Determination FP&L requests adoption of an approved change to the plant specific Technical Specifications for St. Lucie Unit 1, to revise TS 3/4.7.10, "Snubbers."

As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes would revise SR 4.7.10 to conform the TS to the revised surveillance program for snubbers. Snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g).

Snubber examination, testing and service life monitoring is not an initiator of any accident previously

L-2015-164 Attachment 1 Page 4 of 5 evaluated. Therefore, the probability of an accident previously evaluated is not significantly increased.

Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives. The proposed change does not adversely affect plant operations, design functions or analyses that verify the capability of systems, structures, and components to perform their design functions therefore, the consequences of accidents previously evaluated are not significantly increased.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not involve any physical alteration of plant equipment. The proposed changes do not alter the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged. The methods governing plant operation and testing remain consistent with current safety analysis assumptions.

Therefore, it is concluded that this change. does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed changes ensure snubber examination, testing and service life monitoring will continue to meet the requirements of 10 CFR 50.55a(g). Snubbers will continue to be demonstrated OPERABLE by performance of a program for examination, testing and service life monitoring in compliance with 10 CFR 50.55a or authorized alternatives.

Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion 10 CFR 50.55a(g)(4)(iv) states that inservice examination of components may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject

L-2015-164 Attachment 1 Page 5 of 5 to limitations and modifications listed inl10 CFR 50.55a(b) and subject to Commission approval.

If a revised inservice inspection program for a facility conflicts with the TS of the facility, 10 CFR 50.55a(g)(5)(ii) requires licensees to apply to the Commission for amendment of the TS to conform the TS to the revised program.

The proposed change amends the TS surveillance requirements to conform the TS to the revised testing program for snubbers which shall meet the requirements of 10 CFR 50.55a(g) except where the NRC has granted specific written relief, pursuant to 10 CFR 50.55a(g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

In conclusion, based on the considerations discusse~d above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL EVALUATION The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

6.1 FPL letter L-2008-043, dated March 13, 2008,

Subject:

St. Lucie Unit 1, Fourth 10-Year Inspection Interval Program, (Accession No. ML080810193).

6.2 FPL letter L-2014-027, dated January 30, 2014,

Subject:

St. Lucie Unit :2_,Fourth 10-Year Inspection Interval Program, (Accession No. ML14049A284).

6.3 NRC Regulatory Issue Summary 2010-06, "lnservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)," June 1, 2010 (Accession No. ML101310338).

6.4 St. Lucie, Unit No. 1, Current Facility Operating License DPR-67, Technical Specifications, Amendment 220.

L-2015-164 Attachment 2 Page 1 of 8 Technical Specification Markups 3/4 7-29 3/4 7-29A 3/4 7-29 B 3/4 7-30 3/4 7-31 6-15g

L-2015-164 Attachment 2 Page 2 of 8 PLANT SYSTEMS 3/4.7.10 SNUBBERS LIIIGCNIINFOR OPEATION 3.7.10 All safety related snubbers shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4. (MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

With one or more safety related snubbers inoperable, within 72"hours replace or restore the inoperable snubber(s) to OPERABLE status or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7.10 Each snubber shall be deQ*f*nstrated OPERABLE by performance of the Snubbernspaeto cTyegoiessi csi o cesbedrn rsueantors operiiation. esencategrie "Each of (ncesble ora acesiuble)s may bheinm designdepndemntlyaccordringesto theo b.Vschdl yTbe473 h iual inspections

• . interval for e* category of snubber shall be determined based upon thh. teria provided in Table 4.7-3 and the first inspection "

m"itwil determined using this criteria shall be based upon the "

previous inspection interval as established by the requirements in Seffect before Amendment -"

ST. LUCIE - UNIT 1 3/4 7-29 ST.

LCIE

-UNIT1 3/47-29Amendment No. 24. 44, 8, 44.

L-2015-.164 Attachment 2 Page 3 of 8 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued')

• .aparioerbeasarsutoVisual inspections shall 1 hesubrhsn beiyta vclasified iniatosunaccpabgeand impayiereclPEAssIfIed accep, ttable metpupsfoestablioorshporing othe thetvstualur insefuctionainlv anpovdd th (ir the astenr caushen ofreetosnuclearl the etabhecop-

• " lisedt and reeieoo th atpriua snubber andhraearfnt oral onubers i snubbers irrespective of type that may be generically s Usceptible; and (ii)the affected snubber is functionally tested in fe as-found condition and determined OPERABLE per s zecifica-tions 4.7.10.e and 4.7.10.f, as applicable. All sn 'bers found connected to an inoperable common hydraulic/fluid reservoir shall

• " be counted as unacceptable for determinin~ithe next inspection

~~interval. A review and evaluation shall be/terformed and docu-

• - mented to justify continued operation wi t an unacceptable snub-

>,- ber. If continued operation cannot be* fstified, the snubber shall be declared inoperable and the'ACTION requirements shall be

• . ~met./

T /LE 4.7-3 SNUBBER VISU L INSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS Population Cal nn A Column B Column C or Category Exte fd Interval Repeat Interval Reduce Interval (Notes 1 and 2) (N: es 3 and 6) (Notes 4 and 6) (Notes 5 and 6) 2/0 40 78 1, 000Orgea/ 29 56 109

_...xNT13/4

.LUI 7-29a Amendment No.-4~-1

L-2015-164 Attachment 2 Page 4 of 8 PLANT SYSTEMS Nto de Temnthevsanext inspection interval for tat cnbeouateg nory Noe2:Iterpolatsionshl betwe poulterione orbateoysiesapnd peiumbnser-the tinitra h ubrofisprisbe.Uenx n unacceptable snubbers fown duintger

• .forthet ineval.Suebobtelmtfrs Clm ns A, Bte or Cifed thate*o tegeir acesbyineplaty uion. oe prtoa cesbeo nces-

• bl~pevioueseintervlbtntgoreae rexthan 4month seprtl. ronl.

Not 4: ofwtevnmer, ofeunacepseutmablesnu ericeualn toaordecssithn thefo.

• " a~numeinspctolun Babu greatlue thateiin the nubersin a Coumon Awhc.

• "t dtrmn tenext inspection shal interval theame casthepeviousyinter

• .Note 5: Ifntherplainumbertofnc ptabletisnbbcaegrs eqal sies tohorgreaer d tha

• oth numacpabesubersi Cl C, th inspetion mssbeUe next interalsalger two forthirdslu peimsintefrvl HoweverA,, orCif of the the ofunc t/number

>"Noe3:Ifte ume o uaceptable snub is nubri bers .~aoun less than theoo u rae

• "~ ~ hn numbh er in Column theB,next inpetoiterval shall be reducedte.

previorsitervay byt inotegrpoation that is, mothervos inera

• .Note diffe cebfwe the number of unacceptable snu o bbers fseua duringte oundes

, thme reiuinCounBbtgetervalaan the number in Column BAt difrec the ST. LUClE - UNIT 1 3/4 7-29b ST.

uci

- NITI34 729bAmendment No.--1-e;

L-2015-164 Attachment 2 Page 5 of 8 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued.__.I

d. Functionall Testeds ucinlts hl otneutln Atladdtional snbers are foundh duinoperableorn alsaetyrelsedttvape (1%o h aeyrltdsnubbers) beenncinalsavetested.,

ethereresentpatie srinaml selchtedt For fuctac estingeshall iosnclude vaiu ofiu metthe rationalt s, operatingcenvritroni sadah ag ofSpcfato4.1/"e size .1.f c apacityiof nulbbers.

and ttyeofsube sal e Sdiioa idntf ed nubbers as iEs f leorally sttoReoe'y oreinHig un pei EpsnurberZns Duigahtdwvelas beeincluddtin.th Terepresentative sample. saetyerted hydrafulictisnubbe rlsting shlinud Ine vaddiions tonthfrgur amples, snubbersgwhichnmfailed the pranevious spare snube haacteon istalleds inpaefafildsubete bohthnaieubbersd(tiifd itas rEspaiediaand Dfinstlloedoe"oanothe in Epositi on)ne spr snubber Shuton/all retestd.est as be reslt ofe thesresentativer shamll nofty r~esuteinadditoaluncinl tnberistingsdu

• e etor otereempartionstebssfromhefuctoamltsing forandivdua sbesIn adtotothesaegoriesaegulrsanted snbyeswihfie Comisononyifu the

• siabebsspforexsubemptonaspesenintaled and/leor snubberlfedstutiven aie tetnbwsprormetoe quaifydsnubber opeitisreabiityfre adisalldesign conditions Peithenor comple at othe r tionsohi faricah fntionatasbeu altstn or nt ivduate.

ST. LUCIE - UNIT 1 3t4 7-30 ST.LucE

-UNI1 /4No.

-30Amendment

,1.,44, 8-3. 44G.

L-2015-164 Attachment 2 Page 6 of 8 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued'i

e. Hrauni snubbers Funectionalr Testtionaetestin CritherifailoIu The hydraulcsebymnubb fntona tuer testg sh verifyrs iiecall that:

1.m Activain (rsubettrainingsamedfctn isahieved winthional theited.

rastetngeofrelocireety orhaccelerto indeedn both thenso drcompremnssion 2.ov frsnubbersbed nor reeaerteng wher rnctuirna istwicethinc rthe

f. Mechanlica Snubbers Functional Test Acceptnce Criteria The mehydanlica snubber functional testsall verify that:

2. Activation (restraining ation) is achieved winbthi thenspeione rangeo eoiyo ceeaini compression.

ohtnin*d

2. Snubber S Lieoorinlaertweereur*

lerie, swti h dsignatiedsrvige life commenessiando theinstaion/ admineac Concurehnithl thubefrst iunsrievuainpctionalTsaAcp nde artlerastoc eahsfet relhateda snubber shctoallb revieweda toverify that th by ore frethan 10npiortoathsfreno~ext schedue snubber srvic life ethan1%pir toten extnsrchmpeduosledssthnube sevie lpeifeeiew, theSnubber Service Life shall bereeautdnrtesubeqhl v A~b replcerd or rhecndiioned sof eachsnubr i serts tohxendat iclife

• . r~~eyondstedt wo fthe nextschedued service life reviaew. Tha emanied V result oafethe reevluationubemhay beusieedjustify to a thaneto the

/tesubrservice ofte life snub reevaluation orepleen onbbrshl lber.Ti reconditioning shall be indicated in the records.

ST. LUC1E - UNIT 1 3/4 7-31 ST.LucE

-UNI1 No./4-31Amendment 24, 44, 8,3, -140,"20"2"

L-2015-164 Attachment 2 Page 7 of 8 ADMINISTRATIVE CONTROLS fcontinued)

m. Control Room Envelope Habitability Program (continued)

c. Requirements for (i) determining the unfiltered air inleakage past the ORE boundary into the ORE in accordance with the testing methods and at the Frequencies specified in Sections 0.1 and 0.2 ot Regulatory Guide 1.197, 'Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors, Revision 0, May 2003, and (ii) assessing ORE habitability at the Frequencies specified in Sections 0.1 and 0.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the ORE pressure relative to all external areas adjacent to the ORE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 36 month assessment of the ORE boundary.

e. The quantitative limits on unfiltered air inleakage into the ORE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of ORE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 4.0.2 are applicable to the Frequencies for assessing ORE habitability, determining ORE unfiltered inleakage, and measuring ORE pressure and assessing the ORE boundary as required by paragraphs c and d, respectively.

n. Diesel Fuel Oil Testing Proqram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

(i) Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color or a water and sediment content within limits; (ii) Other properties for ASTM 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and (iii) Total particulate concentration of the fuel oil is S 10 mg/I when tested every 31 days.

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.

ST. LUCIE - UNIT 1 Amendment No. 2*, 286, *OF-

L-2015-164 Attachment 2 Page 8 of 8 Insert 1:

o. Snubber Testing Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISI) requirements for supports. The program shall be in accordance with the following:

1. This program shall meet 10 CFR 50.55a(g) ISI requirements for supports.

2. The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(b) subject to the conditions listed in 10 CFR 50.55a(b) and subject to Commission approval.

3. The program shall, as required by 10 CFR 50.55a(b)(3)(v), meet Subsection ISTA, "General Requirements" and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

4. The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10 CFR 50.55a(b)(3)(v)) subject to the conditions listed therein.

L-2015-164 Attachment 3 Page 1 of 7 Word Processed TS Pages Retyped TS Pages 3/4 7-29 3/4 7-29a 3/4 7-29b 3/4 7-30 3/4 7-31 6-15h

L-2015-164 Attachment 3 Page 2 of 7 PLANT SYSTEMS 314,7.10 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.10 All safety related snubbers shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4. (MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

With one or more safety related snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

S,.URVYEILLANCE REDUiREMENTS 4.7.10 Each snubber shall be demonstrated OPERABLE by performance of the Snubber Testing Program, ST. LUC[E - UNIT 1 3/4 7-29 ST.

LUIE-UNT 1 3/No. 2-1, 44, 83, 7-29Amendment 4

L-2015-164 Attachment 3 Page 3 of 7 PLANT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)

DELETED ST. LUC]E - UNIT 1 3/4 7-29a ST.

UCIE-UNT 1 /472S~Amendment No. 440

L-2015-164 Attachment 3 Page 4 of 7 PLANT SYSTEMS SURVEILLANCE REOUIREMENTS tContinuedt DELETED ST. LUCIE - UNIT 1 3/4 7-29b ST.

UCIE-UNT 1 14 729bAmendment No. 4-0

L-2015-164 Attachment 3 Page 5 of 7 PLANT SYSTEMS

• UlELLNEEURME*NTS (,continued)

DELETED ST. LUCIE - UNIT 1 3/4 7-30 ST.

UCIE-UIT 13/4

-30Amendment No. 24, 44, 83,44

L-2015-164 Attachment 3 Page 6 of 7 PLANT SYSTEMS SURVEILLANCE REDUIREMENTS (.Continued)

DELETED ST. LUCIE - UNIT 1 3/4 7-31 ST.LUCE 1

-UNI /4-31Amendment No. 24I,44, 83, 4140, 202

L-2015-164 Attachment 3 Page 7 of 7 ADMINISTRATIVE CONTROLS 1continued!

a. Snubber Testinq Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISI) requirements for supports. The program shall be in accordance with the following:

1, This program shall meet 10 CFR 50.55a(g) ISI requirements for supports.

2. The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(b) subject to the conditions listed in 10 CFR 50.55a(b) and subject to Commission approval.

3. The program shall, as required by 10 CFR 50.55a(b)(3)(v), meet Subsection ISTA, "General Requirements" and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

4. The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10 CFR 50.55a(b)C3)(v)) subject to the conditions listed therein.

6.9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the NRC.

STARTUP REPORT 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (1) receipt of an operating license, (2) amendment of the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal or hydraulic performance of the plant.

ST. LUCIE - UNIT 1 6-15h ST.UCIE-UNT 1 -i~hAmendment No. 20T

L-2015-164 Attachment 4 Page 1 of 8 COMPARISION OF CURRENT TS REQUIREMENTS TO REVISED ISI SNUBBER PROGRAM ASSESSMENT

L-2015-164 Attachment 4 Page 2 of 8 Current TS Surveillance Requirement Revised 1S1 Program Requirement Justification for Change 4.7.10.a Inspection Types ISTD-5252 allows for DTPG's to be established The revised SNUBBER program requirements As ued pecfictio,"

n tis ypeof nuber"based upon differences in design, application, for inspection types allow the same distinction As used i this forifiTPt's,"asySR 4.snubber shall mean snubbers of the same design and size, or type.foDTGsaSR471.

man ufacturer, irrespective of capacity.

4.7.10.b Visual Inspections Snubbers are categorized as inaccessible or ISTD-4220(a) requires all snubbers to be Use of ISTD-4200 for snubber inservice accessible during reactor operation. Each of considered one population for examination, or examination in lieu of current SR 4.7.10.b does these categories (inaccessible or accessible) alternatively, to categorize them individually not change the number of snubbers required may be inspected independently according to as accessible or inaccessible. The categories to be examined or the required examination the schedule determined by Table 4.7-3. The of accessible and inaccessible snubbers shall intervals.

visual inspection interval for each category of be considered separately for examination.

snuber dterinedbasd sallbe onthe ISTD-4220(b) requires the decision to examine criteria provided in Table 4.7-3, and the first thsnbrsaoepputinraseaae inspection interval determined using this ctgre ob aeaddcmne criteria shall be based upon the previous before the scheduled examination begins and inspection interval as established by thenochgeduigtexanto.

requirements in effect.

4.7.10.c Visual Inspection Acceptance Criteria ISTD-4210 states that inservice examination 10 CFR 50.55a(b)(3)(v) allows the use of Visalinpetios hal erfy ha () he shall be a visual examination to identify subsection ISTD for inservice examination snubber has no visible indications of damage physical damage, leakage, corrosion, or requirements.

or impaired OPERABILITY, (2) attachments to degradation. The revised Snubber program requirements the foundation or supporting structure are ISTD-4231 requires snubber installations to be will continue to examine the integrity of the functional, and (3) fasteners for the able to restrain movement and that attachments to the supporting structure.

attachment of the snubber to the component examinations shall include observations for Tervsdsubrpormrqieet and to the snubber anchorage are functional. loose fasteners, or members that are frisrieeaiainstsytevsa corroded or deformed disconnected

L-2015-164 Attachment 4 Page 3 of 8 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change components or other conditions that might inspection acceptance criteria in SR 4.7.1O.c interfere with the proper restraint of movement.

4.7.1O.c Visual Inspection Acceptance Criteria (cn)ISTD-4240 permits snubbers classified as The revised SNUBBER program requirements Snubbers which appear inoperable as a result unacceptable during inservice examination to for inservice examination is equivalent to the of visual inspections shall be classified as be tested in accordance with the visual inspection acceptance criteria in SR unacceptable and may be reclassified requirements of ISTD-5210. Results that 4.7.1O.c acceptable for the purpose of establishing the satisfy the operational. readiness test criteria next visual~inspection interval, provided that of ISTD-5210 shall be used to accept the (i) the cause of the rejection is clearly snubber, provided the test demonstrates that established and remedied for that particular the unacceptable condition did not affect snubber and for other snubbers irrespective of operational readiness.

type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as found condition and determined OPERABLE per Specifications 4.7.10.e and 4.7.10.f, as applicable.

4.7.10.c Visual inspection Acceptance Criteria ISTD-4233 requires that fluid supply or The revised SNUBBER program requirements (cont) content for hydraulic snubbers shall be for inservice examination satisfy the visual observed. If the fluid is less than the inspection acceptance criteria in SR 4.7.10.c All snubbers found connected to an inoperable common hydraulic fluid reservoir mimuaontthisaltonhllb shal abeunacepableforidentified ouned as unacceptable, unless a test determining the next inspection interval. A esalhstathepromnefte review and evaluation shall be performed and snbeiswtnspcfdlmt.

documented to justify continued operation ISTD-4270 requires that snubbers that do not with an unacceptable snubber. If continued meet examination requirements of ISTD-4230 operation cannot be justified, the snubber shall be evaluated to determine the root

L-2015-164 Attachment 4 Page 4 of 8 Current TS Surveillance Requirement Revised 151 Program Requirement Justification for Change shall be declared inoperable and the ACTION cause of the unacceptability.

requremnts hal be et.ISTD-4280 requires that unacceptable snubbers shall be adjusted, repaired, modified, or replaced.

TABLE 4.7-3 SNUBBER VISUAL INSPECTION ISTD-4252(b) requires inservice examinations Table ISTD-4252-1 is equivalent to SR Table INTERVAL to be conducted in accordance with Table 4.7-3 for population/category population ISTD-4252-1 sizes.

4.7.10.d Functional Tests ISTD-5200 requires snubber operational The-frequency of snubber testing in the mnth drin shtdonreadiness testing to be performed each fuel At ereas8 one revised program is unchanged from the At eat oceper18monhsdurngshudoncycle. Testing shall be performed during frequency specified in current TS SR 4.7.10.d.

a representative sample (10% of the safety ,

related snubbers) shall be functionally tested normal system operation, or during system or The initial sample size in the revised program either in place or in a bench test. For each plant outages. is as large as the size specified in current SR snubber that does not meet the functional ISTD-5223 and ISTD-5224 permit snubbers to 4.7.10.d.

test acceptance criteria of Specification_ be tested in their installed location or in a Threidpogapovesfrn 4.7.10.e or 4.7.10.f, an additional 10% of that bench test. expanded sample of one half the initial sample type of snubber shall be functionally tested. ISTD-5261 requires snubbers of each Defined be tested for each failed snubber when using Test Plan Group (DTPG) to be tested using the 10% test plan. Although the present either: program requires an additional sample of the same 10% for each failed snubber this is not (a)tstin he 1%

saple lanconsidered to be a reduction in safety since Funtioalcntiue estshal nti noISTD-5330 requires the snubbers of each DTPG the proposed program includes an increased addtioal nubersarefoud iopeabl or and failure mode group (FMG) to be tested as emphasis on service life monitoring, and this all safety related snubbers have been tested. required. Testing is complete when the proposed test program has been previously mathematical expressions of ISTD-5331 are approved by the regulator and is widely in use satisfied, or all snubbers in the DTPG or FMG elsewhere.

have been tested.

L-2015-164 Attachment 4 Page 5 of 8 Current TS Surveillance Requirement [ Revised 151 Program Requirement Justification for Change ISTD-5331 requires that testing shall satisfy the mathematical expressions as follows:

(a) for each DTPG N _Ž O.1n + C(0.1n/2)

(b) for each FMG NF ->CF(0.1n/2) 4.7.10.d Functional Tests (cont.) ISTD-5311 requires, as practicable, the sample The revised program provides for shall include representation from the DTPG representative selection of the initial sample The representativ)e sample selected for based on the significant features (i.e., the for functional testing to include all functional testing shall include the various various designs, configurations, operating configurations and environments.

configurations, operating environments and environments, sizes, and capacities) the range of size and capacity of snubbers.

Snubbers identified as "Especially Difficult to The revised program provides for Remove"1 or in "'High Exposure Zones During ISTD-5311 requires, as practicable, the sample representative selection of the initial sample Shutdown' shall also be included in the shall include representation from the DTPG for functional testing to include all representative sample. Safety related based on the significant features (i.e., the configurations and environments.

hydraulic snubber listings and safety related various designs, configurations, operating mechanical snubber listings may be used environments, sizes, and capacities) jointly or separately as the basis for the sampling plan Retests of failed snubber locations are ISTD-5500 requires that snubbers placed in In addition to the regular sample, snubbers required by the revised program as in SR the same location as snubbers that failed the which failed the previous functional test shall 4.7.10.d previous inservice operational readiness test be retested during the next test period. If a shall be retested at the time of next spare snubber has been installed in place of a operational readiness testing unless the cause failed snubber, then both the failed snubber

L-20 15-164 Attachment 4 Page 6 of 8 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change (if it is repaired and installed in another of the failure is clearly established and position) and the spare snubber shall be corrected.

retested. Test results of these snubbers shall not result in additional functional testing due to failure.

4.7.1O.d Functional Tests (cont.) ISTD-5271 states that snubbers that do not The revised program requires evaluations of If eletedforfuntioal ny nuber estng meet test requirements shall be evaluated to all failed snubbers and for manufacturer or If slecedfo nysnube fuctonl tstng determine the root cause of the failure. design deficiencies requires replacement or either fails to lockup or fails to move, i.e., mdfcto falsubr nteFGo frozen in place, the cause will be evaluated ISTD-5272 states that snubbers found mdfcto falsubr nteFGo additional testing until the mathematical and if caused by manufacturer or design unacceptable according to operational epeso fIT-31b sstsido l deficiency, all snubbers of the same design readiness test requirements should be epeso fIT-31b sstsido l subject to the same defect shall be assigned to FMGs unless the failure is isolated snbesithFM haeentsed functionally tested. This testing requirement or unexplained. FMGs shall include all Therefore, the revised program requirements shall be independent of the requirements unacceptable snubbers with the same failure provide adequate assurance of snubber stated above for snubbers not meeting the mode and all other snubbers with similar OEAIIYbcuealptnilyafce functional test acceptance criteria potential for similar failure.snbeswlberpadormifd;rth acceptance limit for additional testing will be As an alternative to additional testing for met, demonstrating an acceptable level of Design or Manufacturing FMGs, ISTD-5323 reliability requires no additional testing when all snubbers in the FMGs are replaced or modified in accordance with IS-rD-1600.

If replacement or modification is not performed in accordance with ISTD-5323, additional testing is required in accordance

L-2015-164 Attachment 4 Page 7 of 8 Current TS Surveillance Requirement Revised ISI Program Requirement Justification for Change with ISTD-5324. Testing is required to continue until the acceptance limit is satisfied or all snubbers in the FMG have been tested.

4.7.1O.e Hydraulic Snubbers Functional Test Acceptance Criteria ISTD-S210(a), (b) and (c) require the same The revised SNUBBER program requirements The hydraulic snubber functional test shall verification for operational readiness testing. for snubber acceptance criteria are equivalent verify that: to those of current SR 4.7.1O.e

1. Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.

2. Snubber bleed, or release rate where required, is within the specified range in -

compression or tension.

4.7.10.f Mechanical Snubbers Functional test ISTD-5210(a), (b) and (c) require the same The revised SNUBBER program requirements Acceptance Criteria verification for operational readiness testing. for snubber acceptance criteria are equivalent to those of current SR 4.7.10.f The mechanical snubber functional test shall verify that:

1. The force that initiates free movement of the snubber rod in either tension or compression is less than the specified maximum drag force.

2. Activation (restraining action) is achieved in both tension and compression

L-20 15-164 Attachment 4 Page 8 of 8 Current TS Surveillance Requirement j Revised 151 Program Requirement Justification for Change 4.7.10.g Snubber Service Life Monitoring ISTA-9310 requires the maintenance of The service life evaluation requirements in records in accordance with the Owners QA ISTD-6100 *nd ISTD-6200 are equivalent to A record of the service life of each snubber, program. the requiremnents in current TS SR 4.7.10.g.

the date at which the designated service life commences and the installation and ISTD-6100 requires initial snubber service life maintenance records on which the designed to be predicted based on manufacturer's service life is based shall be maintained. recommendation or design review.

Concurrent with the first inservice visual ISTD-6200 and ISTD-6200(c) requires service inspection and at least once per 18 months life to be evaluated at least once each fuel thereafter, the installation and maintenance cycle. If the evaluation indicates that service records for each safety related snubber shall life will be exceeded before the next be reviewed to verify that the indicated scheduled system or plant outage, the service life has not been exceeded or will not snubber shall be reconditioned such that its be exceeded by more than 10% p~ior to the service life will be extended to or beyond the next scheduled snubber service life review. If next scheduled system or plant outage the indicated service life will be exceeded by more than 10% prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review. The results of the reevaluation may be used to justify a change to the service life of the snubber. This reevaluation, replacement or reconditioning shall be indicated in the records

L-2015-164 Attachment 5 Page Ilof 6 St. Lucie Plant Unit 1 Snubber Testing Program Plan Fourth 10-Year Interval February 11, 2008 to February 10, 2018 Revision 0 Florida Power & Light Company St. Lucie Plant 6501 S. Ocean Drive Jensen Beach, FL 34957

L-2015-164 Attachment 5 Page 2 of 6 Revision Log Effective Revision Description Prepared: Date Approved: Date Date IST Snubber Engineering

_____Coordinator Manager

L-2015-164 Attachment 5 Page 3 of 6 TABLE OF CONTENTS SECTION

1.0 INTRODUCTION

2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:

3.0 EXAMINATION and TESTING METHODS:

4.0 EXAMINATION and TESTING FREQUENCY:

5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:

6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:

7.0 SCHEDULING

8.0 REPORTS AND RECORDS:

L-2015-164 Attachment 5 Page 4 of 6 INTRODUCTION:

1.1 Purpose

To provide requirements for the performance and administration of assessing the operational readiness of those quality related dynamic restraints (Snubbers) whose specific functions are required to ensure the integrity of the reactor coolant pressure boundary or any safety-related system.

1.2 Scope

The program plan was prepared to meet the requirements of the following subsections of the American Society of MechanicarlEngineers (ASME) GM Code 2004 Edition with 2005 and 2006 Addenda.

• Subsection ISTA, "General Requirements" ISTA contains the requirements directly applicable to inservice examination and testing including the Owner's Responsibility and Records Requirements.

• Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants" ISTD establishes requirements for preservice and inservice examination and testing, and the service life monitoring of Dynamic Restraints (Snubbers) in light-water reactor nuclear power plants. The snubbers covered are required to support the systems and components that are required in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

1.3 Discussion

In order to ensure the required operability of all safety related and quality related snubbers for the St. Lucie Plant during seismic or other events initiating dynamic loads, the inspection, testing and service life monitoring of these snubbers shall be implemented and performed in accordance with the requirements of the station Snubber Testing Program Requirements.

The examination boundaries for the Snubber Program shall include the snubber assembly from pin to pin inclusive. Integral and nonintegral structural attachments for snubbers, when examined, shall be examined in accordance with the requirements of the ASME Code Section XI, Article IWF-2500(a), (b), (c) and (d). Coordination with the 1S1 program owner will be required to complete the surveillance and documentation requirements for these piping and structural attachments.

The Snubber Program described in OSP-73.01 and QI-10-PR/PSL-6 adheres to the requirements of the ASME GM Code, Subsection ISTD, 2004 Edition with 2005 and 2006 Addenda, as required by 10CFR50.55a(b)(3)(v)(B).

L-2015-164 Attachment 5 Page 5 of 6 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS:

2.1 Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the extent specified within OSP-73.01, QI-10-PRIPSL-6 and referenced Surveillance Test Procedures.

2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample plan per ISTD-5300. Large equipment snubbers attached to the Steam Generators or Reactor Coolant Pumps will each comprise separate DTPG's.

2.3 The service life of all snubbers shall be monitored and snubbers evaluated, replaced, or reconditioned in accordance with OSP-73.01, QI-10-PR/PSL-6 and ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections. The replacement or reconditioning of snubbers shall be documented and records retained in accordance with St. Lucie Plant procedures.

3.0 EXAMINATION and TESTING METHODS:

3.1 Visual examinations shall be performed by individuals qualified in accordance with St.

Lucie Plant procedures. These examinations are conducted to ensure the mechanical and structural condition of the snubber support location and to observe conditions that could affect functional adequacy. Visual examinations and functional testing shall be performed to verify the requirements specified within OSP-73.01 and QI-1 0-PR/PSL-6 are met in

• accordance with Subsection ISTD.

4.0 EXAMINATION and TESTING FREQUENCY:

4.1I Visual Examinations and Functional Testing shall be performed at the frequency specified within OSP-73.01, QI-10-PR/PSL-6 and ISTD-4250 and ISTD-5240. Snubbers are categorized as inaccessible or accessible during reactor operation for visual examination. Each of these categories (inaccessible and accessible) may be examined independently according to the schedule determined by Table ISTD 4252-1.

4.2 Code Case OMN-13, which allows the extension of the visual examination interval, will be implemented for snubber inspections during this interval. Code Case OMN-13 is approved for use in Regulatory Guide 1.192 (June 2003). The Visual Examinations of Table ISTD 4252-1 may be extended in accordance with Code Case OM~N-13 once the prerequisites of the code case have been satisfied.

4.3 Visual Examinations shall be performed whenever new snubbers are installed, reinstallation of existing or swapped snubbers that were functionally tested, or after repairs, replacements or modifications.

4.4 Functional testing requirements for new installations or spares shall be equal to or more stringent than that specified within OSP-73.01 and QI-10-PR/PSL-6.

L-20 15-164 Attachment 5 Page 6 of 6 5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION:

5.1 Snubbers that do not appear to conform to the Visual Examination requirements of OSP-73.01 and QI-10-PRIPSL-6, shall be reported for evaluation and appropriate corrective action.

5.2 Snubbers that do not appear to conform to the visual examination acceptance requirements and are later confirmed as operable as a result of functional testing may be declared operable for the purpose of establishing the next visual inspection interval, providing that the unacceptable condition did not affect operational readiness.

5.3 Snubbers that do not meet the operability testing acceptance criteria in OSP-73.01 and QI-10-PR/PSL-6 shall be evaluated to determine the cause of the failure and appropriate corrective action shall be taken.

5.4 The service life of a snubber is predicted using manufacturer's input and contemporary information gained through consideration of the snubber service conditions and inservice functional test results. Service life monitoring program requirements are included in OSP-73.01 and QI-I10-PR/PSL-6.

6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS:

6.1 Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the ASME Code,Section XI.

7.0 SCHEDULING

7.1 The Visual Examinations, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with OSP-73.01, QI PR/PSL-6 and Subsection ISTD by the Snubber Engineer.

7.2 A controlled listing of snubbers included in this program is maintained and is controlled within the NAMS Equipment Data Base.

7.3 The Snubber Engineer shall identify and track expanded or additional testing and/or examinations as required by OSP-73.01, QI-10-PR/PSL-6 and Subsection ISTD.

8.0 REPORTS and RECORDS:

8.1 Reports and records for the Visual Examinations and Functional Testing shall be maintained for all snubbers included within the Snubber Program in accordance with QI-17-PSL-1, Quality Assurance Records.

8.2 Applicable records and reports, as required for Repair and Replacements, shall be maintained.

8.3 Records of the service life of all snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records shall also be maintained in accordance with QI-17-PSL-1 and QI-10-PR/PSL-6.