ML13137A313

Proposed License Amendment Request Regarding Relocation of Snubber Surveillance Requirements from Technical Specification 4.17 to Snubber Program

ML13137A313
Person / Time
Site:	Surry
Issue date:	05/13/2013
From:	Grecheck E Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-271
Download: ML13137A313 (75)

Text

{{#Wiki_filter:POWER COMPANY 10 CFR 50.90 VIRGINIA ELECTRIC AND RICHMOND, VIRGINIA 23261 May 13, 2013 U.S. Nuclear Regulatory Commission Serial No. 13-271 Attention: Document Control Desk SPS LIC/CGL RO Washington, D.C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 PROPOSED LICENSE AMENDMENT REQUEST REGARDING RELOCATION OF SNUBBER SURVEILLANCE REQUIREMENTS FROM TECHNICAL SPECIFICATION 4.17 TO SNUBBER PROGRAM Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests license amendments, in the form of changes to the Technical Specifications (TS) to Facility Operating License Numbers DPR-32 and DPR-37, for Surry Power Station Units 1 and 2, respectively. The proposed amendments request revision of TS 4.17, "Shock Suppressors (Snubbers)," and the TS 4.17 Bases, as well as addition of TS 6.4.T, "Inservice Examination, Testing, and Service Life Monitoring Program for Snubbers." The proposed change will revise the TS surveillance requirements for snubbers to be in accordance with ASME OM Code, Subsection ISTD, and will relocate the surveillance requirements to the Surry Units 1 and 2 Inservice Examination, Testing, and Service Life Monitoring Program Plans for Snubbers. provides a description and evaluation of the proposed change. The marked-up and proposed pages for the TS and TS Bases are provided in Attachments 2 and 3, respectively. The TS Bases changes are provided for NRC information only. We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for this determination is included in Attachment 1. We have also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change. The proposed TS change has been reviewed and approved by the Facility Safety Review Committee.

4 Serial No. 13-271 Docket Nos. 50-280/281 Page 2 of 3 Dominion requests NRC approval of the proposed license amendments by April 30, 2014 with a 60-day implementation period. If you have any questions or require additional information, please contact Mr. Gary Miller at (804) 273-2771. Respectfully, S&: A t&;3Qý-ý E. S. Grecheck Vice President - Nuclear Engineering and Development Attachments:

1. Discussion of Change

2. Marked-up Technical Specifications and Bases Pages

3. Proposed Technical Specifications and Bases Pages

4. Comparison of Surry Technical Specification 4.17 to ASME Code Subsection ISTD

5. Inservice Examination, Testing, and Service Life Monitoring Program Plan for Snubbers - Surry Unit 1

6. Inservice Examination, Testing, and Service Life Monitoring Program Plan for Snubbers - Surry Unit 2 Commitments made in this letter: None VICKI L.HULL*

Notary Public Commonwealth of Virginia 140542 COMMONWEALTH OF VIRGINIA ) My Commission Expir May 31. 2014 COUNTY OF HENRICO ) The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by E. S. Grecheck, who is Vice President - Nuclear Engineering and Development, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief. Acknowledged before me this X,. day of i I& V 2013. My Commission Expires: ' 31. 2O,/-4. i - rx Notary Public

Serial No. 13-271 Docket Nos. 50-280/281 Page 3 of 3 cc: Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street, Suite 730 Richmond, Virginia 23219 Ms. K. R. Cotton NRC Project Manager Surry U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station

Serial No. 13-271 Docket Nos. 50-280/281 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program ATTACHMENT 1 DISCUSSION OF CHANGE VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY POWER STATION UNITS 1 AND 2

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 1 of 8 DISCUSSION OF CHANGE

1.0 INTRODUCTION

In accordance with the provisions of 10 CFR 50.90, Virginia Electric and Power Company (Dominion) is submitting a license amendment request to revise the Surry Units 1 and 2 Technical Specifications (TS). Specifically, TS 4.17, "Shock Suppressors (Snubbers)," and the TS 4.17 Bases will be revised and TS 6.4.T, "Inservice Examination, Testing, and Service Life Monitoring Program for Snubbers," will be added. The proposed change will revise the TS surveillance requirements for snubbers to be in accordance with ASME OM Code, Subsection ISTD, and will relocate the surveillance requirements to the Surry Units 1 and 2 Inservice Examination, Testing, and Service Life Monitoring Program Plans for Snubbers.

2.0 PROPOSED CHANGE

The proposed TS revisions are summarized below:

• TS 4.17 will be revised to replace the specific surveillance requirements for demonstrating snubber operability with a reference to the "Surry Units 1 and 2 Inservice Examination, Testing, and Service Life Monitoring Program Plans for Snubbers." In addition, the TS 4.17 Bases will be revised.

" TS 6.4.T, "Inservice Examination, Testing, and Service Life Monitoring Program for Snubbers," will be added to the Administrative Controls Section 6.4, "Unit Operating Procedures and Programs," to provide a description of the snubber program. Marked-up TS and TS Basis pages and typed proposed pages are provided in Attachments 2 and 3, respectively. Note that the TS Basis revisions are provided to the NRC for information. A comparison of the current Surry TS 4.17 surveillance requirements to the requirements of the American Society of Mechanical Engineers (ASME) OM Code, Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants, and justification of the changes is provided in Attachment 4. The Surry Units 1 and 2 Inservice Examination, Testing, and Service Life Monitoring Program Plans for Snubbers meet the requirements of Subsection ISTD and are provided in Attachments 5 and 6, respectively, for the NRC's information.

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 2 of 8

3.0 BACKGROUND

The current snubber visual examinations and functional testing are performed as part of the Surry Units 1 and 2 ASME Section Xl Inservice Inspection (ISI) Programs for the fourth 10-year ISI interval (Interval 4). As requested by Dominion in Relief Requests CS-001 for Surry Units 1 and 2, the NRC authorized use of TS 4.17, along with sections from ISTD, for Interval 4 rather than the requirements contained in the 1998 Edition, through the 2000 Addenda, of ASME Boiler and Pressure Vessel (BPV) Code, Section Xl, Articles IWF-5200(a), 5200(b), 5300(a) and 5300(b) (References 8.1 and 8.2). Relief Requests CS-001 will not be included in the Surry ISI programs for the next 10-year ISI interval (i.e., Interval 5). Instead, snubbers will be examined and tested to the requirements of the Surry Units 1 and 2 Inservice Examination, Testing, and Service Life Monitoring Program Plans for Snubbers during Interval 5. The schedule for subsequent 10-year updates to the Surry snubber program will coincide with the schedule for 10-year updates to the Surry ISI program. The current Surry Units 1 and 2 fourth ISI Intervals for snubber testing are scheduled to end on December 13, 2013 and May 9, 2014, respectively. The program plans for snubbers meet the requirements of ASME OM Code, Subsection ISTD. For snubbers examined and tested in accordance with either the ASME OM Code or the ASME Section Xl Code, the requirement to perform a 10-year IST program update is found in 10 CFR 50.55a(g)(4)(ii). For the current Section Xl snubber testing program, 10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of the 120-month inspection interval. If a revised ISI program for a facility conflicts with the TS for 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. 10 CFR 50.55a(b)(3)(v)(A) allows licensees to use the ASME OM Code Subsection ISTD rather than the requirements for snubbers in the editions and addenda up to the 2005 Addenda of the ASME B&PV Code, Section Xl, Articles IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their TS or licensee-controlled documents. 10 CFR 50.55a(b)(3)(v)(A) also states that preservice and inservice examinations must be performed using the VT-3 visual examination method described in Article IWA-2213. As such, the proposed changes to TS 4.17 are required to conform the TS to the revised snubber program. Dominion has submitted Relief Requests S1-15-1SI-01 and S2-15-ISI-01 for Surry Units 1 and 2 to allow ISI Interval 5 to be conducted to the requirements of the 2004 Edition of the ASME Section Xl Code, instead of the 2007 Edition with 2008 Addenda, which are the latest edition and addenda approved by 10CFR50.55a (Reference 8.3). Upon approval of the relief requests, ISI Interval 5 will be conducted to the requirements of the 2004 Edition of the ASME Section Xl Code.

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 3 of 8 As identified above, Relief Requests CS-001 granted relief from the requirements contained in the 1998 Edition, through the 2000 Addenda, of ASME BPV Code, Section Xl, Articles IWF-5200(a), 5200(b), 5300(a) and 5300(b) for ISI Interval 4 since the use of TS 4.17 along with sections from ISTD provided an acceptable level of quality and safety. With the adoption of ISTD, the requirements of Articles IWF-5200(a), 5200(b), 5300(a) and 5300(b) will be met for snubbers. The examination requirements of ASME BPV Code, Section Xl, Articles IWF-5200(c) and IWF-5300(c) for integral and non-integral attachments for snubbers will continue to be addressed within the ISI program.

4.0 TECHNICAL ANALYSIS

Licensees are required to perform the inspection and testing of snubbers in accordance with ASME BPV Code, Section Xl, or the OM Code and the applicable addenda as required by 10 CFR 50.55a(g) or 10 CFR 50.55a(b)(3)(v), 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). 10 CFR 50.55a(a)(3) states that licensees may use alternatives to the requirements of 10 CFR 50.55a(g) when authorized by the NRC if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. As noted in Regulatory Issue Summary 2010-06 (Reference 8.4), licensees have the option to control the ASME Code-required ISI and testing of snubbers through their TS. For plants using their TS to govern ISI and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4), licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRC-approved alternative used in lieu of the code requirements. The TS governing the snubber ISI and testing program do not eliminate the 10 CFR 50.55a requirements to update the program at 120-month intervals, in accordance with 10 CFR 50.55a(g)(4), or to request and receive NRC authorization for alternatives to the code requirements, when appropriate. The proposed change to TS 4.17 replaces the specific TS requirements for snubber examination, testing, and service life monitoring with a reference to the program for examination, testing, and service life monitoring for snubbers in accordance with the OM Code, Subsection ISTD and relocation of the requirements into the snubber program, thereby ensuring the TS are consistent with the revised snubber program.

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 4 of 8 The proposed change to TS 4.17 retains the reference to the required actions described in TS 3.20, "Shock Suppressors (Snubbers)," in cases where a snubber is declared inoperable. The operability requirements and required actions in TS 3.20 are not impacted by this proposed change to TS 4.17. The program for inspection and testing of snubbers in accordance with ASME BPV Code, Section Xl, or the OM Code and the applicable addenda as required by 10 CFR 50.55a(b) is required to include evaluation of supported components/systems when snubbers are found to be unacceptable.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a margin of safety. Dominion has evaluated if a significant hazards consideration (SHC) is involved with the proposed change. A discussion of these standards as they relate to this change request is provided below.

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

Response: No. The proposed change revises TS 4.17 to conform the TS to the revised snubber program and relocates the surveillance requirements to the Inservice Examination, Testing, and Service Life Monitoring Program for Snubbers. Snubber examination, testing and service life monitoring will meet the requirements of the ASME OM Code Subsection ISTD as allowed by 10 CFR 50.55a(b)(3)(v). Snubber examination, testing, and service life monitoring are not initiators of any accident previously evaluated. Therefore, the probability of an accident previously evaluated is not significantly increased. Snubber operability will continue to be demonstrated by performance of a program for examination, testing, and service life monitoring in compliance with 10 CFR 50.55a. Therefore, 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. The consequences of accidents previously evaluated are not significantly increased.

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 5 of 8 Therefore, the proposed 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 change does not involve any physical alteration of plant equipment. The proposed change does not change 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, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No. The proposed change ensures snubber examination, testing, and service life monitoring will meet the requirements of the ASME OM Code Subsection ISTD as allowed by 10 CFR 50.55a(b)(3)(v). 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. The schedule for subsequent 10-year updates to the Surry snubber program will coincide with 10-year updates to the Surry IST program. The need to perform the 10-year update for the Surry snubber program is required by 10 CFR 50.55a(g). Therefore, the proposed changes do not involve a significant reduction in a margin of safety. Based on the above, Dominion concludes that the proposed changes do not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c). 5.2 Applicable Regulatory Requirements/Criteria 10 CFR 50.55a(b)(3)(v)(A) allows licensees to use the ASME OM Code Subsection ISTD in place of the requirements for snubbers in the editions and addenda up to the 2005 Addenda of the ASME B&PV Code, Section Xl, Articles IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their TS or licensee-controlled

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 6 of 8 documents. 10 CFR 50.55a(b)(3)(v)(A) also states that preservice and inservice examinations must be performed using the VT-3 visual examination method described in Article IWA-2213. As described above, the Surry snubber program is included in the fourth 10-year ISI program subject to the requirements of 10 CFR 50.55a(g). 10 CFR 50.55a(g)(4)(ii) requires that inservice examination of components conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of the 120-month inspection interval. If a revised snubber 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 to conform the TS to the revised snubber program. The proposed change amends the TS surveillance requirements to conform the TS to the revised snubber program that meets the requirements of 10 CFR 50.55a(b)(3)(v)(A) and 10 CFR 50.55a(g)(5)(ii). Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be 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.

6.0 ENVIRONMENTAL CONSIDERATION

This license amendment request meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) as follows: (i) The amendment involves no significant hazards consideration. As described above, the proposed license amendment request does not involve a significant hazards consideration. (ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed license amendment request revises TS 4.17 to conform the TSs to the revised snubber program and does not affect the types or amounts of effluents that may be released offsite. Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. (iii) There is no significant increase in individual or cumulative occupational radiation exposure.

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 7 of 8 The proposed license amendment request revises TS 4.17 to conform the TSs to the revised snubber program and does not affect individual or cumulative occupational radiation exposure. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure. Based on the above assessment, Dominion concludes that the proposed change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.22 relative to requiring a specific environmental assessment or impact statement by the Commission. 7.0 PRECEDENTS The proposed change to TS 4.17 is similar to the license amendment request submitted by Dominion Nuclear Connecticut, Inc. (DNC) for Millstone Power Station Unit 2. The applicable references for these changes are provided below: 7.1 DNC Letter 11-354, Millstone Power Station Unit 2, License Amendment Request to Revise Snubber Surveillance Requirements, dated September 21, 2011. 7.2 DNC Letter 12-086, Millstone Power Station Unit 2, Response to Request for Additional Information Regarding License Amendment Request to Revise the Snubber Technical Specification Surveillance Requirements (TAC No. ME7221), dated February 24, 2012. 7.3 NRC Letter dated June 28, 2012, Millstone Power Station Unit 2, - Issuance of Amendments Re: Snubber Surveillance Requirements (TAC No. ME7221). The following differences were noted between the license amendment request for Surry Units 1 and 2 and the request submitted for Millstone Unit 2: 0 The following surveillance requirements from the existing Surry TS 4.17 are not held in common with the Millstone Unit 2 TS:

1) TS 4.17.B.1.d: in those locations where snubber movement can be manually induced without disconnecting the snubber, that the snubber has freedom of movement and is not frozen up.

2) TS 4.17.B.2, last sentence: When hydraulic snubbers which have uncovered fluid ports are tested for operability, the test shall be performed by starting with the piston at the as-found setting and extending the piston rod in the tension mode direction.

3) TS 4.17.C.3: At least 25% of the snubbers in the representative sample shall include snubbers from the following three categories:

a) the first snubber away from each reactor vessel nozzle,

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 1 Page 8 of 8 b) snubbers within 5 feet of heavy equipment (valve, pump, turbine, motor, etc), and c) snubbers within 10 feet of the discharge from a safety relief valve.

4) TS 4.17.C.7: For snubbers of 50 kips and above that are extremely difficult to remove or in high radiation zones that fail the functional testing, an engineering evaluation is required to determine the failure mode. If the failure is determined to be non-generic, an additional 10% of that type will be tested during the next functional test period.

5) TS 4.17.D.1.b, last sentence: For snubbers specifically required to not displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

6) TS 4.17.E.1.c: Snubber release rate, where required, is within the specified range in compression and tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified.

• In accordance with Millstone Unit 2 TS 4.7.8.d, for each snubber that does not meet the test acceptance criteria, an additional 5% of that type of snubber shall be functionally tested. For Surry TS 4.17.C.6, an additional 10% is required.

" Surry TS 4.17.C.5 requires retest during the next test period of failed snubbers that are repaired and installed in another position. Millstone Unit 2 TS 4.7.8.d does not contain this requirement, and it is not required by ISTD-5500. However, ISTD-1520 requires repaired snubbers to be tested before they are returned to service.

8.0 REFERENCES

8.1 NRC letter dated April 5, 2004 -

Subject:

Surry Power Station, Unit 1, RE: ASME Section Xl Subsection IWF, Inservice Inspection (ISI) Program Relief Request CS-001 (TAC No. MB7764) 8.2 NRC letter dated May 18, 2004 -

Subject:

Surry Power Station, Unit 2, RE: ASME Section Xl Subsection IWF, Inservice Inspection (ISI) Program Relief Request CS-001 (TAC No. MC0869) 8.3 Virginia Electric and Power Company (Dominion) letter Serial No. 12-191, dated April 25, 2012, Surry Power Station Units 1 and 2, ASME Section Xl Inservice Inspection (ISI) Program, Request for Alternative - Fifth 10-Year Inservice Inspection Interval ASME Section Xl Code of Record, Relief Requests Sl-15-ISI-01 and S2-15-ISI-01 8.4 NRC Regulatory Issue Summary 2010-06, "Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)," June 1, 2010 (Accession No. ML101310338)

Serial No. 13-271 Docket Nos. 50-280/281 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATIONS AND BASES PAGES (BASES CHANGES FOR NRC INFORMATION ONLY) VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY POWER STATION UNITS I AND 2

TS 4.17-1 4.17 SHOCK SUPPRESSORS (SNUBBERS) Applicability Applies to all hydraulic and mechanical shock suppressors (snubbers) which are required to protect the Reactor Coolant System and other safety-related systems. Snubbers excluded from this inspection are those installed on non-safety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system. Obiective To specify the minimum frequency and type of surveillance to be applied to the hydraulic and mechanical snubbers required to protect the Reactor Coolant System and other safety-related systems. Eah suber shall bedemonstratdOEAL ypromn h olwn umne of the the requirementsyeomn nbr ins etionb prograt andtdOEAL inserviee srvice inspecd n Program.--a hfloigumne As used thi specificoin, "type of s bber" sha,,l ean snubbers ohe same design A.Vsa n tions 1." ubesu In a tia re ca r ized as ina ssbe or acce l drn reaooprtion. Eac ofur aeore cesil nacs ibe maea isect indepe. ntly according. the scheduled ermined by Table.1.7-1., vhei ual insation interval of*ach category of s bber shall be dfabe.7."ete ffined basedyýon the IM *gRT PAPAýRq gpR 4 r PA ae -r5 4.17-3 3 xohs+..r ,a,' *'i*t Service_. L(Ce_.

 -{'*-      Sy awbe~r-s.

TS 4.17-2

                                                                                            .-05-O4- B. Visual Inspecti n Accetanc Criteria./                                                         ------

1. Visu inspections shall yeni that:

the snubber has n isible indications of age or impaired o ility,

b. attachments the foundation or s porting structure are ctional,

c. fasten s for the attachmen of the snubber to t component and to the s ber anchorage are ctional, and in those locations ere snubber move nt can be manually id d without disconnecting e snubber, that the nubber has freedom of ovement and is not frozen

2. Snubber which appear in erable as a result q visual inspections shall class ied as unaccepta e and may be reclass'.ed acceptable for the purose of b!ishing the fex isual inspection in al, provided that:

a. the cause the rejection is cle y established and remedi for that particular snubb and for other snu ers irrespective of type at may be generically s ptible, and the affected sn ber is functionally tes in the as-found ndition and determined BRABLE per Specific on 4.17.D or E.

When draulic snubbers whi have uncovered fl.

• ports are tes for ope ility, the test shall be formed by starting w, the piston at t as-found tting and extending th iston rod in the tensio ode direction.

3. All snubbers foun -connected to an inopera le common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval.

Amendment Nos. i56"and-IovE THIS PA*RACRAPH TO PAG)e Ts 4.17- TS4.17-3 A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the action requirements of Specification 3.20 shall be met. C. Functional Teist

1. Onc per 18 months, representative ple of 10% of total of each type ubber used in th lant shall be fu ctionally tested u g either an in-place st machine or a b ch test.

2. The repr entative sample ected for functi al testing shall includ e variops confl urations, opera g environments nd the range of size d capacity of s bbers, This rep sentative sample all not, to the extent acticable, include those snubbers sted in a previous presentative sample.

3. At least  % of-the.snub~bers n the representative sa pile shall include snubb s from e following three egories:

the first snubbe, ay from each reactor v sel nozzle,

b. snubbers w in 5 feet of heavy equi ent (valve, pump, turie, motor, etc),

and

c. snu ers within 10 feet of the discharge from a safety rdlief valve.

Amendment Nos. e

TS 4.17-4 ai-22-9S.

4. Snubb identified as "Especi ly Difficult to Remove" or in "High Radiation e During Shutdown" 11 also be include n the representative san .*

5. In addition to the gular sample, snu ers which failed the evious functional test shall be tested during th ext test period. If - are snubber has been installe n place of a failed ubber, then both th iled snubber (if it is repaired an installed in anoth position) and the s re snubber shall be retested. Test results of these ,n ers may not be in ded for the resampling.

6. For each ubber that does ot meet the functional acceptanc riteria of Speci ation 4.17.D 1)o 4. E, an additional 10% of that type snubber shall be f etionally, tested.

7. For snubbers 50 kips and above that are ex ely difficult to remove or in high radiatio ones that fail the function testing, an engineering evaluation is re 'red to determine the fail e mode. If the failure is dete ned to be on-generic, an additio 10% of that type will be tes during the next functional test perio

8. If any snubb *selected for fufnctional tes'tin her fails: to lockup or fails to move, i.e., fr n in place, the cause will b aluated and if caused by nufacturer or ign deficiency all snubbers the same design subject e same defect shall be functionally tested. is testing requiremen r . be independent of... ,.

requirements stat above for snubbers not ting the functional test acceptance

• ermanent or other exe tions from functional testingf individual snubbers in these categories may be gra by the Commission only if 'ustifable basis for exemption is presented and/or sn er life destructive testing was p ormed to qualify snubber operability for all design conditions ateither the completion of their fabrication or at a subsequent date.

Amendment Nos.444-e7---1"-t*

TS 4.17-5 performed Zef this ted by the s) in order e designed

                 /;0 range of I range in t displace d without
                 /

s;t n the Amendment Nos. 443amd+72

TS 4.17-6

                                                                                                     -064-1.98

c. Snubber release rate, where required, is within the specified range in corn ssion and tension. F snubbers specific y-required not to displace

                          .ercontinuous load          e abi*lity of the s     ber to withstand load without I

F Snubber Service Li Monitoring

1. A record f the service life o ,ach snubber, the dat at which the designated servi life commences, an the installation and ntenance records on which the signated service ,f is based shall be ma' tained as required by the Virginia Electric and Po r Company Operatiol Quality Assurance Progr Topical

2. Concu ent with the first i ervice visual inspecti and at least once per 1 onths thereafter, th nstallation and maint ance records for each snubber shall be reviewed to rify that the indicate ervice life has not been ceeded or will not be exc ded prior to the next eduled snubber service fe review. If the indicated vice life will be exc ded prior to the next sc uled snubber service life r lew, the snubber se ce life shall be reevalud or the snubber shal e laced or reconditio so as to extend its servic ife beyond the dAte o e next scheduled servic ife review. This reevalun on,replacement or conditioning shall be indicated in the records.

. *.s*..' C.. Amendment Nos. ,,4,,id-24-3

TS 4.17-7 Bases All snubbers are required operable to ensure that the structural integrity of the reactor coolant system and all other safety-related systems is maintained during and following a seismic or other event initiating dynamic loads. Snubbers excluded from this inspection program are those installed on non-safety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system. The visual inspect n frequency is.ýbad upon maintaining constant level of snubber protection to systems. Th efore, the require inspection interval v ies inversely with the served snubber failures an is determined by e number of inop ,ble snubbers found ring an inspection. Inspect ns performed bef e that interval has apsed may be used a a new reference point to dete nethenext insp tion. However, the sults of such early in ections performed before the o ginal required ti interval has elaps (nominal time less  %) may not be used to lengthen the required inspn lion interval. Any ' spection whose resu require a shorter inspecti interval will override e previous schedu When th cause of the rejec n of a snubber isci ly established and'remed* d for that snubber and f rany other snub ers that may be ge rically susceptible, an erified by inservice fu tional testing, th snubber may be ex pted from being counte s inoperable. Generically usceptible- snub rs are those which e of a specific make or del and have the same de ' n features direc related to rejectio f the snubber by visual in ection, or are similarlylo ted or exposed t he same environme tal conditions such as ter rature, radiation, and vi tion. Whe a snubber is found* operable, an engineering valuation is performedij addition to the d ermination of the nubber mode of failure, order to determine any safety-related component or sysm. has been adversely a cted by the inoperabi ty of the snubber. The engineering ev ation shall determine whet r or not the snubber m de of failure has imparted a significant e ect or degradation on the supported component or system. Amendment Nos. 156 2u,4 1.55

TS 4.17-8

                -064R-9.8-Amendment Nos. 444d-

TS 4.17-9 5-e5.e+91-

                                .                   . TABLE 4,17-1 SNrBBE VISUAL INSPE                            ON INTERVAL Popula n                       CCm A                                    olumn B1                       olumn C or C egory                       xtend Interval                       Repeat Interval        /       Reduce Interval (Nes and 2)                    (Noe)                                  (Notes 4 and 6)                (Notes 5 and 6) 00                                                         1 80                            ,                                                                        2

/ 1n n/ - A 1o0 3 8 00 2 5 300 5 12 25 400 8 18 36

  /          750 500..                            2012" /40                              24   .        /                78 48 1000 or grea r                        29                                     56                             109om Note 1:        Te next visual inspection interval for a snubber populatiotr category size shall be Noetermined based upon eprevious inspection intervalnd the number of unacceptable Tsnubbes ispri dusinbehat intervalr               Snubbers are cat ofized, based upon their o cestlint             iurdmower operation, as acessiblu e inaccessible. These categoriesthat/              may be document the     nsee must make and lIt However, or jointly. and'shall Note 3:tdechision      befor any inspection examndeaay                                              seql at.decisoon as the basis upon Chiumn A l o            Sdeterm inspe tin inap    t            ybtioceiterval fobutat categooay.t                           h Note 2:        Interpol on bet weeo   n population or c igory sizes and the number of un eptable snObut s is permissible.

or .fthat integer includes a t Use next I*onal integer e value offor thervalue ofsnu unacceptable the efs asfordetermined beColumns A,bya, Note 3: If the number of unaccept le snubber s equal to or leat nthe number in Column A, the next inspection int al mal be twir the o previoui al but not greater than 48 the pevia. .ntrval N e If-he-number u4: u of nacceptabl e snubbers is equal or less than the number in Columter t but greaterth thein Column er rol shall be val byl theao tas Note 5: If the -r fu a c p al nb e q a oo g e t rtan the Liu rt r in Colum n C, th e np ci n ne vls alb e othiso f h p eio site rval,, owever, ifthan the nu be fu a cp ab es ub r slest ah um e nC! .,but g reter the is, the previous interval sh be reduced by a factor that is one ird of the ratio of the difference between then' ber of inacceptable. snubbers fod during the previous i rval and the number in Co mn B to the fferenct in the num rs in Columns B and Note 6: The provisions of Specification 4.0.2 are applicable fo all inspection intervals p to and including 48 months. Amendment Nos.A46--ad 5-5

TSI ;/6 10 7

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AM1en/nt N/$i4 I 7"nd/07 i

TS 6.4-15

4. Measurement, at designated locations, of the MCRIESGR envelope pressure relative.t9 all external areas adjacent to the MCR/ISGR:envelope boundary during the pressurization mode of operation by one train of the MCRIESGR EVS, operating at the flow rate required by TS 4.20, at a Fr..quency of 18 months on a STAGGERED TEST BASIS. The results shall be trended aand used as part of the assessment of the MCRIESGR envelope boundary.

5. The quantitative limits on unfiltered air inleakage into the MCR/ESGR envelope.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph 3. 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 MCR/ESGR envelope occupants to these hazards will be within the assumptions in the licensing basis.

6. The provision.s of SR 4.0.2 are..applicable to . the FIrequencies for assessing MCRIESGR envelope habitability, determining MCRIESGR envelope unfiltered inleakage, and measuring MCR/ESGR envelope pressure and assessing the MCR/ESGR envelope boundary as required by paragraphs 3 and 4, respectively.

S. Surveillance Frequency Control Program (SFCP) This.program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specification are performed at interval sufficient to assure the associated Limiting Conditions for Operation are met.

a. The. Surveillance Frequency Control Program shall contain a list of Frequencies of those- Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control Of Surveillance Frequiencies," Revision 1.

c. The provisions of Surveillance Requirements 4k0.2 and 4.0,3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

 .S E P-T C.                   T--                            PAJe(-

Amendment Nos. ndm2t2

TS 6.4.T INSERT FOR PAGE TS 6.4-16: T. Inservice Examination, Testing., and Service Life Monitoring Program for Snubbers 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:

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

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

c. The program shall, as allowed by 10 CFR 50.55a(b)(3)(V), meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME BPV Code ISI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a (including 10 CFR 50.55a(b)(3)(V)) subject to the limitations and modifications listed therein.

Serial No. 13-271 Docket Nos. 50-280/281 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS AND BASES PAGES (BASES CHANGES FOR NRC INFORMATION ONLY) VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY POWER STATION UNITS I AND 2

TS 4.17-1 4.17 SHOCK SUPPRESSORS (SNUBBERS) Applicability Applies to all hydraulic and mechanical shock suppressors (snubbers) which are required to protect the Reactor Coolant System and other safety-related systems. Snubbers excluded from this inspection are those installed on non-safety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system. Objective To specify the minimum frequency and type of surveillance to be applied to the hydraulic and mechanical snubbers required to protect the Reactor Coolant System and other safety-related systems. Specification Each snubber shall be demonstrated OPERABLE by performance of the Units 1 and 2 Inservice Examination, Testing, and Service Life Monitoring Program Plans for Snubbers. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the action requirements of Specification 3.20 shall be met. Amendment Nos.

TS 4.17-2 Bases All snubbers are required operable to ensure that the structural integrity of the reactor coolant system and all other safety-related systems is maintained during and following a seismic or other event initiating dynamic loads. Snubbers excluded from this inspection program are those installed on non-safety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system. Amendment Nos.

TS 6.4-15

4. Measurement, at designated locations, of the MCR/ESGR envelope pressure relative to all external areas adjacent to the MCRIESGR envelope boundary during the pressurization mode of operation by one train of the MCR/ESGR EVS, operating at the flow rate required by TS 4.20, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the MCR/ESGR envelope boundary.

5. The quantitative limits on unfiltered air inleakage into the MCR/ESGR envelope.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph 3. 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 MCR/ESGR envelope occupants to these hazards will be within the assumptions in the licensing basis.

6. The provisions of SR 4.0.2 are applicable to the Frequencies for assessing MCR/ESGR envelope habitability, determining MCR/ESGR envelope unfiltered inleakage, and measuring MCR/ESGR envelope pressure and assessing the MCR/ESGR envelope boundary as required by paragraphs 3 and 4, respectively.

S. Surveillance Frequency Control Program (SFCP) This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specification are performed at interval sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

T. Inservice Examination, Testing, and Service Life Monitoring Program for Snubbers 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: Amendment Nos.

TS 6.4-15a

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

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

c. The program shall, as allowed by 10 CFR 50.55a(b)(3)(V), meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME BPV Code 1SI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a(a)(3).

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a (including 10 CFR 50.55a(b)(3)(V)) subject to the limitations and modifications listed therein.

Amendment Nos.

Serial No. 13-271 Docket Nos. 50-280/281 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program ATTACHMENT 4 COMPARISON OF SURRY TECHNICAL SPECIFICATION 4.17 TO ASME CODE SUBSECTION ISTD VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY UNITS 1 AND 2

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 COMPARISON OF SURRY TS 4.17, "SHOCK SUPPRESSORS (SNUBBERS)," TO ISTD, "PRESERVICE AND INSERVICE EXAMINATION AND TESTING OF DYNAMIC RESTRAINTS (SNUBBERS)" Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change 4.17 Specification ISTD-5252 states that the total snubber population Each unit has three DTPGs, which are: may be considered one Defined Test Plan Group As used in this specification, "type of snubber" (DTPG), or alternatively, differences in design, 1) large bore hydraulic snubbers shall mean snubbers of the same design and application, size, or type may be considered in 2) small bore hydraulic snubbers and manufacturer, irrespective of capacity. establishing DTPGs. Additional DTPG requirements 3) mechanical snubbers. are described in ISTD-5253 for snubbers attached to the steam generator and the reactor coolant pumps. 4.17. A. 1 Visual Inspections According to ISTD-4220, Table ISTD-4252-1 is identical to TS Table 4.17-1 for population/category Snubbers are categorized as inaccessible or (a) All of the snubbers shall be categorized as one sizes less than or equal to 1000. accessible during reactor operation. Each of population for examination or they may be these categories (inaccessible and accessible) categorized as accessible and inaccessible Use of ISTD-4200 for snubber inservice may be inspected independently according to populations. examination in lieu of current TS the schedule determined by Table 4.17-1. The 4.17.A.1 does not change the number of visual inspection interval for each type of (b) The decision to categorize the snubbers as one snubbers required to be examined or snubber shall be determined based upon the population or as separate populations may be the required examination intervals. criteria provided in Table 4.17-1. made during or after the examination. Note 1 to TS Table 4.17-1 states that snubber (c) If combining accessible and inaccessible categories may be examined separately or populations into one population, the shorter jointly, interval shall be used for subsequent examination. Per ISTD-4252, examinations schedules are determined according to Table 4252-1. Table ISTD-4252-1 is identical to TS Table 4.17-1 for population/category sizes less than or equal to 1000. Page 1 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement [ ISTD Snubber Testing Program Requirement Justification for Change 4.17. B.1 Visual Inspection Acceptance Criteria ISTD-4210 states that inservice examination shall be 10 CFR 50.55a(b)(3)(v) allows the use a visual examination to identify physical damage, of subsection ISTD for inservice Visual inspections shall verify that: leakage, corrosion, or degradation that may have examination requirements. Preservice

a. the snubber has no visible indications of been caused by environmental exposure or operating and inservice examinations are required damage or impaired operability conditions; and external characteristics that may to be performed using the VT-3 visual

b. attachments to the foundation or indicate operational readiness of the snubber shall be examination method described in IWA-supporting structure are functional, examined. 2213.

c. fasteners for the attachment of the ISTD-4231 requires that examinations shall include snubber to the component and to the The ISI program and ISTD program observations for the following and the conditions shall snubber anchorage are functional, and requirements for inservice examination be evaluated when found:

d. in those locations where snubber do not differ significantly from the visual movement can be manually induced (a) loose fasteners, or members that are corroded or inspection acceptance criteria in TS without disconnecting the snubber, that the deformed 4.17.1B.1.

snubber has freedom of movement and is not frozen up. (b) disconnected components or other conditions that might interfere with the proper restraint of movement. ISTD-4232 requires that examinations verify snubbers do not restrain thermal movement to an extent that unacceptable stresses could develop in the snubber, the pipe, or other equipment that the snubber is designed to protect or restrain. ISTD-4233 requires that examinations verify snubbers are free of defects that may be generic to particular designs as may be detected by visual examination. ASME Code Section Xl, Articles IWF-5200(c) and IWF-5300(c) require integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of Subsection IWF. The TS requirement to verify freedom of movement in locations where snubber movement can be manually induced does not appear word for word in ISTD. Page 2 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TSRequirement Snubber Surveillance ISTD Snubber Testing Program Requirement Justification for Change However, ISTD-4232 appears to require the same type of verification. 4.17. B.2 Visual Inspection Acceptance Criteria ISTD-4240 permits snubbers classified as The ISI program and ISTD program unacceptable during inservice examination to be requirements for inservice examination Snubbers which appear inoperable as a result tested in accordance with the requirements of ISTD- do not differ significantly from the visual of visual inspections shall be classified as 5210. Results that satisfy the operational readiness inspection acceptance criteria in TS unacceptable and may be reclassified test criteria of ISTD- 5210 shall be used to accept the 4.17. B.2. acceptable for the purpose of establishing the snubber, provided the test demonstrates that the next visual inspection interval, provided that: unacceptable condition did not affect operational

a. the cause of the rejection is clearly readiness.

established and remedied for that particular snubber and for other snubbers ISTD-4270 requires that snubbers that do not meet irrespective of type that may be generically examination requirements of ISTD-4230 shall be susceptible; and evaluated to determine the cause of the

b. the affected snubber is functionally tested unacceptability.

in the as-found condition and determined OPERABLE per Specification 4.17.D or E. ISTD-4280 requires that unacceptable snubbers shall be adjusted, repaired, modified, or replaced. When hydraulic snubbers which have uncovered fluid ports are tested for operability, According to ISTD-4233, snubbers shall be free of the test shall be performed by starting with the defects that may be generic to particular designs as piston at the as-found setting and extending may be detected by visual examination. For example, the piston rod in the tension mode direction. fluid supply or content for hydraulic snubbers shall be observed. An observation that the fluid level is equal to or greater than the minimum specified amount that is sufficient for actuation at its operating extension is considered to satisfy this requirement. If the fluid is less than the minimum amount, the installation shall be identified as unacceptable, unless a test establishes that the performance of the snubber is within specified limits. Tests shall be performed in accordance with para. ISTD-5210. ISTD-5221 requires that snubbers be tested for operability in their as-found condition regarding parameters to be tested to the fullest extent practical, Page 3 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change which includes cases of hydraulic snubbers with uncovered fluid ports tested for operability. 4.17. B.3 Visual Inspection Acceptance Criteria The ISI program and ISTD program requirements for inservice examination All snubbers found connected to an inoperable According to ISTD-4233, snubbers shall be free of do not differ significantly from the visual common hydraulic fluid reservoir shall be defects that may be generic to particular designs as inspection acceptance criteria in TS counted as unacceptable for determining the may be detected by visual examination. For example, 4.17.B.3. next inspection interval. A review and fluid supply or content for hydraulic snubbers shall be evaluation shall be performed and documented observed. An observation that the fluid level is equal to justify continued operation with an to or greater than the minimum specified amount that unacceptable snubber. If continued operation is sufficient for actuation at its operating extension is cannot be justified, the snubber shall be considered to satisfy this requirement. If the fluid is declared inoperable and the action less than the minimum amount, the installation shall requirements of Specification 3.20 shall be be identified as unacceptable, unless a test met. establishes that the performance of the snubber is within specified limits. Tests shall be performed in accordance with para. ISTD-5210. ISTD-4270 requires that snubbers that do not meet examination requirements of ISTD-4230 shall be evaluated to determine the cause of the unacceptability. ISTD-4280 requires that unacceptable snubbers shall be adjusted, repaired, modified, or replaced. Page 4 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change 4.17. C.1 Functional Tests ISTD-5200 requires snubber operational readiness The frequency of snubber testing in testing to be performed each fuel cycle. Testing shall ISTD is similar to the frequency Once per 18 months, a representative sample be performed during normal system operation, or specified in current TS 4.17.C.1. The of 10% of the total of each type snubber used during system or plant outages. readiness testing is performed every in the plant shall be functionally tested using fuel cycle which is approximately every either an in-place test machine or a bench test. ISTD-5240 states that snubber testing may begin no 18 months. earlier than 60 days before a scheduled refueling outage. The revised program provides greater flexibility in permitting testing to be According to ISTD-531 1, the initial sample shall be performed during modes other than 10% of the DTPG. shutdown. However, as noted in Generic Letter 91-04: ISTD-5300 describes a 10% testing sample plan and ISTD-5400 describes a 37 snubber testing sample The staff concludes that the TS need plan. Either plan can be used per ISTD. Surry will use not restrict surveillances as only the 10% sample plan. being performed during shutdown. Nevertheless, safety dictates that ISTD-5223 and 5224 allow for either in-place testing when refueling interval surveillances or bench testing. are performed during power operation, licensees give proper regard for their effect on the safe operation of the plant. If the performance of a refueling interval surveillance during plant operation would adversely affect safety, the licensee should postpone the surveillance until the unit is shut down for refueling or is in a condition or mode that is consistent with the safe conduct of that surveillance. Surry assesses and manages risk in accordance with 10 CFR 50.65(a)(4) prior to performing maintenance and surveillance activities both at power and during shutdown. Activities are Page 5 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance I Requirement ISTD Snubber Testing Program Requirement Justification for Change scheduled to minimize outage times for TS required equipment. The initial sample size required by ISTD-5311 is the same as in TS 4.17.C.1. ISTD-5300 describes a 10% testing sample plan which is the sample plan Surry will use for the next 10 year interval. 4.17. C.2 Functional Tests According to ISTD-531 1, the initial sample shall be The representative sample 10% of the DTPG, composed according to either requirements are similar between TS The representative sample selected for subpara. ISTD-531 1(a) or ISTD-531 1(b). 4.17.C.2 and ISTD-5311. functional testing shall include the various configurations, operating environments and the (a) As practicable, the sample shall include range of size and capacity of snubbers. This representation from the DTPG based on the representative sample shall not, to the extent significant features (i.e., the various designs, practicable, include those snubbers tested in a configurations, operating environments, sizes, and previous representative sample. capacities) and based on the ratio of the number of snubbers of each significant feature, to the total number of snubbers in the DTPG. Selection of the representative snubbers shall be random. (b) The sample shall be generally representative as specified in subpara. ISTD-5311(a), but may also be selected from snubbers concurrently scheduled for seal replacement or other similar activity related to service life monitoring. The snubbers shall be tested on a generally rotational basis to coincide with the service life monitoring activity. 4.17. C.3 Functional Tests The representative sample requirements in ISTD- ISTD does not have the 25% 5311 do not require that 25% of the snubbers include requirement described in TS 4.17.C.3. At least 25% of the snubbers in the the three categories described in TS 4.17.C.3. However, ISTD-5251 requires that the representative sample shall include snubbers DTPGs shall include all snubbers from the following three categories: I except replacement snubbers and Page 6 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change

1. the first snubber away from each reactor snubbers repaired or adjusted as a vessel nozzle, result of not meeting the examination

2. snubbers within 5 feet of heavy equipment acceptance requirements.

(valve, pump, turbine, motor, etc), and

3. snubbers within 10 feet of the discharge from a safety relief valve.

4.17. C.4 Functional Tests ISTD-5251 requires that the DTPGs shall include all The ISTD-5251 requirement for the snubbers except replacement snubbers and snubbers DTPG to include all snubbers would Snubbers identified as "Especially Difficult to repaired or adjusted as a result of not meeting the require the DTPG to include "Especially Remove" or in "High Radiation Zone During examination acceptance requirements. Difficult to Remove" or in "High Shutdown" shall also be included in the Radiation Zone During Shutdown" representative sample.* ISTD-5225 allows for testing of subcomponents snubbers. However, "When snubber size, test equipment limitations, or examination/testing of subcomponents

• Permanent or other exemptions from inaccessibility prevents use of methods in paras. that control the parameters to be functional testing for individual snubbers in ISTD-5223 and ISTD-5224, snubber subcomponents verified is allowed by ISTD-5225.

these categories may be granted by the that control the parameters to be verified shall be Commission only if a justifiable basis for examined and tested in accordance with Owner-exemption is presented and/or snubber life approved test methods." No exemptions from the destructive testing was performed to qualify Commission would be required in these cases. snubber operability for all design conditions at either the completion of their fabrication or at a subsequent date. 4.17. C.5 Functional Tests ISTD-5500 requires that snubbers placed in the same The requirements to retest snubbers or location as snubbers that failed the previous inservice spare snubbers placed in locations of a In addition to the regular sample, snubbers operational readiness test shall be retested at the previous failure are similar between TS which failed the previous functional test shall time of next operational readiness testing unless the 4.17.C.5 and ISTD. be retested during the next test period. If a cause of the failure is clearly established and spare snubber has been installed in place of a corrected. As to a failed snubber being repaired failed snubber, then both the failed snubber (if and installed in another location, ISTD-it is repaired and installed in another position) Any retest in accordance with this paragraph shall not 1520 requires the repaired snubber to and the spare snubber shall be retested. Test be considered a part of inservice operational be tested before return to service. results of these snubbers may not be included readiness testing sample selection. for the resampling. According to ISTD-1520, Post-Maintenance or Repair Examination and Testing, snubbers that are Page 7 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change maintained or repaired by removing or adjusting a snubber part that can affect the results of tests required by ISTD-5120 shall be examined and tested in accordance with the applicable requirements of ISTD-5120 before return to service. 4.17. C.6 Functional Tests ISTD-5271 requires snubbers that do not meet test The ISTD-5331 10% sample plan requirements specified in ISTD-5210 or ISTD-5230 to compared to the TS 4.17.C.6 plan For each snubber that does not meet the be evaluated to determine the root cause of the requires fewer additional snubbers to be functional acceptance criteria of Specification failure. tested per failure for all values of C up 4.17.D or 4.17.E, an additional 10% of that to the total number of snubbers in the type of snubber shall be functionally tested. ISTD-5312 requires that additional samples required DTPG. Surry will use the 10% sample by ISTD-5320 shall be at least one-half the size of the plan in ISTD-5331. initial sample from that DTPG ISTD-5330 requires the snubbers of each DTPG and failure mode group (FMG) to be tested as required. Testing is complete when the mathematical expressions of ISTD-5331 are satisfied, or all snubbers in the DTPG or FMG have been tested. Either ISTD-5300 or ISTD-5400 can be used to determine additional samples. The mathematical expressions for ISTD-5331, ISTD-5431 and TS 4.17.C.6 are compared below. The mathematical expression for each DTPG in ISTD-5331 is: N > 0.1n + C(O.1n/2) Where N = total number of snubbers tested that were selected from the DTPG n = number of snubbers in the DTPG C = total number of unacceptable snubbers found in the DTPG Page 8 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change The mathematical expression for each DTPG in ISTD-5431 is: N > 36.49 +18.8C The mathematical expression from TS 4.17.C.6 is: N > 0.1n + C(0.1n) Surry Unit 1 has 128 small bore hydraulic snubbers so the number of snubbers in the DTPG is n = 128. Comparing the three sample plans for 1, 2, 3 and 4 failures gives the following results. C ISTD-5331 ISTD-5431 TS 4.17.C.6 1 20 56 26 2 26 75 39 3 32 93 52 4 39 112 65 For the Surry DTPG of 128 snubbers, the sample plan in ISTD-5331 is the preferred plan. For plants with a large number of snubbers in the DTPG (> 400), the plan in ISTD-5431 would be the preferred plan. The ISTD-5331 plan compared to the TS 4.17.C.6 plan requires fewer additional snubbers to be tested per failure for all values of C up to the total number of snubbers in the DTPG. 4.17. C.7 Functional Tests There is no requirements in ISTD that are similar to There are no requirements in ISTD that the specific requirements in TS 4.17.C.7. are similar to the requirements in TS For snubbers of 50 kips and above that are 4.17.C.7. However, the ISTD extremely difficult to remove or in high However, according to ISTD-5271 snubbers that do requirements provide adequate radiation zones that fail the functional testing, not meet test requirements shall be evaluated to assurance of snubber OPERABILITY an engineering evaluation is required to determine the cause of the failure. because all potentially affected snubbers will be replaced or modified; Page 9 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change determine the failure mode. If the failure is ISTD-5272 states that snubbers found unacceptable or the acceptance limit for additional determined to be non-generic, an additional according to operational readiness test requirements testing will be met, demonstrating an 10% of that type will be tested during the next should be assigned to FMGs unless the failure is acceptable level of reliability. functional test period, isolated or unexplained. FMGs shall include all unacceptable snubbers with the same failure mode and all other snubbers with similar potential for similar failure. As an alternative to additional testing for Design or Manufacturing FMGs, ISTD-5323 requires no additional testing when all snubbers in the FMGs are replaced or modified in accordance with ISTD-1600. If replacement or modification is not performed in accordance with ISTD-5323, additional testing is required in accordance with ISTD 5324. Testing is required to continue until the acceptance limit is satisfied or all snubbers in the FMG have been tested. 4.17. C.8 Functional Tests ISTD-5271 states that snubbers that do not meet test ISTD requirements for manufacturer or requirements shall be evaluated to determine the design deficiencies require replacement If any snubber selected for functional testing cause of the failure. or modification of all snubbers in the either fails to lockup or fails to move (i.e., FMG or additional testing until the frozen in place), the cause will be evaluated ISTD-5272 states that snubbers found unacceptable mathematical expression of ISTD-and if caused by manufacturer or design according to operational readiness test requirements 5331(b) is satisfied or all snubbers in deficiency all snubbers of the same design should be assigned to FMGs unless the failure is the FMG have been tested. This may subject to the same defect shall be functionally isolated or unexplained. FMGs shall include all result in fewer snubbers being tested tested. This testing requirement shall be unacceptable snubbers with the same failure mode after a test failure. independent of the requirements stated above and all other snubbers with similar potential for similar for snubbers not meeting the functional test failure. However, the ISTD requirements acceptance criteria, provide adequate assurance of snubber As an alternative to additional testing for Design or OPERABILITY because all potentially Manufacturing FMGs, ISTD-5323 requires no affected snubbers will be replaced or additional testing when all snubbers in the FMGs are modified; or the acceptance limit for replaced or modified in accordance with ISTD-1600. additional testing will be met, Page 10 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change demonstrating an acceptable level of If replacement or modification is not performed in reliability. accordance with ISTD-5323, additional testing is required in accordance with ISTD 5324. Testing is required to continue until the mathematical expression of ISTD-5331(b) is satisfied or all snubbers in the FMG have been tested. 4.17. C.9 Functional Tests ISTD-1 800 requires that an evaluation shall be The ISTD requirements for supported performed of the system(s) or components of which component(s) or system evaluation are For the snubber(s) found inoperable, an an unacceptable snubber is a part, for possible equivalent to those of current TS4.17. engineering evaluation shall be performed on damage to the supported system or component. C.9. the components which are supported by snubber(s). The purpose of this engineering evaluation shall be to determine ifthe components supported by the snubber(s) were adversely affected by the inoperability of the snubber(s) in order to ensure that the supported component remains capable of meeting the designed service. Page 11 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change 4.17.D Hydraulic Snubbers Functional Test ISTD-5210(a) and (b) require the same verification for The ISTD requirements for hydraulic Acceptance Criteria operational readiness testing. snubber acceptance criteria are equivalent to those of current TS According to ISTD-52110, Snubber operational 4.17. D.1.

1. The hydraulic snubber functional test shall readiness tests shall verify the following:

verify that:

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

velocity or acceleration in both tension and compression. (b) release rate, when applicable, is within the specified

b. Snubber bleed, or release rate, where range in tension and in compression. For units required, is within the specified range specifically required not to displace under continuous in compression and tension. For load, ability of the snubber to withstand load without snubbers specifically required to not displacement.

displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified. Page 12 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change 4.17.E Mechanical Snubbers Functional Test According to ISTD-5210, snubber operational The ISTD requirements for mechanical Acceptance Criteria readiness tests shall verify the following: snubber acceptance criteria are equivalent to those of current TS

1. The mechanical snubbers functional test (a) activation is within the specified range of velocity or 4.17. E.1.

shall verify that: acceleration in tension and in compression.

a. The drag force of the snubber in both tension and compression is less than (b) release rate, when applicable, is within the specified the specified maximum drag force. range in tension and in compression. For units

b. Activation (restraining action) is specifically required not to displace under continuous achieved within the specified range of load, ability of the snubber to withstand load without velocity in both tension and displacement.

compression. (c) for mechanical snubbers, drag force is within

c. Snubber release rate, where required, specified limits, in tension and in compression.

is within the specified range in compression and tension. For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement shall be verified. Page 13 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change 4.17.F.1 Snubber Service Life Monitorinq ISTD-6100 requires initial snubber service life to be The service life evaluation requirements predicted based on manufacturer's recommendation in ISTD-6100 are equivalent to the A record of the service life of each snubber, or design review. requirements in current TS 4.17.F. 1. the date at which the designated service life commences, and the installation and maintenance records on which the designated service life is based shall be maintained as required by the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report. 4.17.F.2 Snubber Service Life Monitoring ISTD-6200 requires service life to be evaluated at The service life evaluation requirements least once each fuel cycle. If the evaluation indicates in ISTD-6200 are equivalent to the Concurrent with the first inservice visual that service life will be exceeded before the next requirements in current TS 4.17.F.2. inspection and at least once per 18 months scheduled system or plant outage, one of the thereafter, the installation and maintenance following actions shall be taken: records for each snubber shall be reviewed to verify that the indicated service life has not (a) the snubber shall be replaced with a snubber for been exceeded or will not be exceeded prior to which the service life will not be exceeded before the next scheduled snubber service life review, the next scheduled system or plant outage. Ifthe indicated service life will be exceeded prior to the next scheduled snubber service life (b) technical justification shall be documented for review, the snubber service life shall be extending the service life to or beyond the next reevaluated or the snubber shall be replaced scheduled system or plant outage. or reconditioned so as to extend its service life beyond the date of the next scheduled service (c) the snubber shall be reconditioned such that its life review. This reevaluation, replacement or service life will be extended to or beyond the next reconditioning shall be indicated in the records. scheduled system or plant outage. Page 14 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change TS Table 4.17-1 Table ISTD-4252-1 is identical to TS Table 4.17-1. Table ISTD-4252-1 is identical to TS Snubber Visual Inspection Interval Table 4.17-1. Table 4.17-1, Note 1 Subsequent visual (examination) intervals are The requirements and categories in The next visual inspection interval for a subject to the requirements of ISTD-4252, which ISTD-4252 and Table 4252-1 are similar snubber population or category size shall be invoke the requirements of Table ISTD-4251-1. The to those in Table 43.17-1, Note 1. determined based upon the previous inspection requirements and categories in ISTD-4252 and Table interval and the number of unacceptable 4252-1 are similar to those in Table 43.17-1, Note 1. snubbers found during that interval. Snubbers are 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. Table 4.17-1, Note 2 Table ISTD-4252-1, Note 1 is similar to Table 4.17-2, Table ISTD-4252-1, Note 1 is similar to Interpolation between population or category Note 2 Table 4.17-2, Note 2 sizes and the number of unacceptable snubbers is permissible. Use next lower integer (1) Interpolation between population or category for the value of the limit for Columns A, B, or C sizes and the number of unacceptable snubbers is if that integer includes a fractional value of permissible. The next lower integer shall be used unacceptable snubbers as determined by when interpolation results in a fraction. interpolation. Table 4.17-1, Note 3 Table ISTD-4252-1, Note 3 is similar to Table 4.17-2, Table ISTD-4252-1, Note 3 is similar to If the number of unacceptable snubbers is Note 3 Table 4.17-2, Note 3 equal to or less than the number in Column A, the next inspection interval may be twice the (3) If the number of unacceptable snubbers is equal previous interval but not greater than 48 to or less than the number in Column A, then the months. next examination interval may be increased to twice the previous examination interval, not to exceed 48 months. In that case, the next examination according to the previous interval may be skipped. Page 15 of 16

Serial No 13-271 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program Attachment 4 Current TS Snubber Surveillance Requirement ISTD Snubber Testing Program Requirement Justification for Change Table 4.17-1, Note 4 Table ISTD-4252-1, Note 4 is similar to Table 4.17-2, Table ISTD-4252-1, Note 4 is similar to If the number of unacceptable snubbers is Note 4 Table 4.17-2, Note 4 equal to or less than the number in Column B, but greater than the number in Column A, the (4) If the number of unacceptable snubbers exceeds next inspection interval shall be the same as the number in Column A, but is equal to or less than the previous interval, the number in Column B, then the next visual examination shall be conducted at the same interval as the previous interval. Table 4.17-1, Note 5 Table ISTD-4252-1, Notes 5 and 6 are similar to Table ISTD-4252-1, Notes 5 and 6 are If the number of unacceptable snubbers is Table 4.17-2, Note 5 similar to Table 4.17-2, Note 5 equal to or greater than the number in Column C, the next inspection interval shall be two- (5) Ifthe number of unacceptable snubbers exceeds thirds of the previous interval. However, if the the number in Column B, but is equal to or less than number of unacceptable snubbers is less than the number in Column C, then the next examination the number in Column C, but greater than the interval shall be decreased to two-thirds of the number in Column B, the next interval shall be previous examination interval or, in accordance with reduced proportionally by interpolation, that is, the interpolation between Columns B and C, in the previous interval shall be reduced by a proportion to the exact number of unacceptable factor that is one-third of the ratio of the snubbers. difference between the number of unacceptable snubbers found during the (6) Ifthe number of unacceptable snubbers exceeds previous interval and the number in Column B the number in Column C, then the next examination to the difference in the numbers in Columns B interval shall be decreased to two-thirds of the and C. previous interval. Table 4.17-1, Note 6 Table ISTD-4252-1, Note 2 is similar to Table 4.17-2, Table ISTD-4252-1, Note 2 is similar to The provisions of Specification 4.0.2 are Note 6 Table 4.17-2, Note 6, and TS 4.0.2. applicable for all inspection intervals up to and including 48 months. (2) The basic interval shall be the normal fuel cycle up to 24 months. The examination interval may be as TS 4.0.2 applies a + 25% grace period, great as twice, the same, or as small as fractions of the previous interval as required by the following notes. The examination interval may vary + 25% of the current interval. Page 16 of 16

Serial No. 13-271 Docket Nos. 50-280/281 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program ATTACHMENT 5 INSERVICE EXAMINATION, TESTING, AND SERVICE LIFE MONITORING PROGRAM PLAN FOR SNUBBERS - SURRY UNIT 1 (UNIT I PLAN FOR NRC INFORMATION ONLY) VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY UNITS 1 AND 2

VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY POWER STATION UNIT 1 INSERVICE EXAMINATION, TESTING AND SERVICE LIFE MONITORING PROGRAM PLAN FOR SNUBBERS FIFTH INSPECTION INTERVAL DECEMBER 14, 2013 - OCTOBER 13, 2023 REVISION 0 COMMERCIAL OPERATION: DECEMBER 22, 1972 ADDRESSES: VIRGINIA ELECTRIC AND POWER COMPANY P. 0. BOX 26666 RICHMOND, VIRGINIA 23261 SURRY POWER STATION 5570 HOG ISLAND RD SURRY, VIRGINIA 23883 PLAN: U1 SNUB PROG PLAN INTERVAL 5

TABLE OF CONTENTS INSERVICE EXAMINATION, TESTING AND SERVICE LIFE MONITORING PROGRAM PLAN FOR SNUBBERS

1.0 INTRODUCTION

1.1 Purpose 1.2 Scope 1.3 Discussion 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS 2.1 Snubber Inservice Testing Plan Description 2.2 DTPG Description 2.3 Service Life Monitoring 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 9.0 ATTACHMENTS Revision 0 S1SNUBI5

1.0 INTRODUCTION

This Examination. Testing and Service Life Monitoring Program Plan for Snubbers is applicable to the Surry Power Station Unit 1 which received its construction permit on June 25, 1968 and began commercial operation on December 22, 1972. Surry Power Station Unit 1 is a Pressurized Water Reactor located in Surry County, Virginia. The plant employs a Westinghouse Electric Corp. Nuclear Steam System. 1.1 Purpose To provide requirements for the performance and administration of assessing the operational readiness of those dynamic restraints (Snubbers) whose specific functions are required to perform one of the following three functions or, to ensure the integrity of the reactor coolant pressure boundary.

• Shutdown the reactor to the safe shutdown condition
• Maintain the reactor in the safe shutdown condition
• Mitigate the consequences of an accident 1.2 Scope The program plan was prepared to meet the requirements of the following subsections of the American Society of Mechanical Engineers (ASME)

Code Section Xl 2004 Edition and (ASME) OM Code 2004 Edition, 2005 and 2006 Addenda.

                " Subsection ISTA, "GeneralRequirements" ISTA contains the requirements directly applicable to inservice examination and testing including the Owner's Responsibility and Records Requirements.
                " Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants" ISTD establishes 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 Page 1 of 11 Revision 0 S1 SNUBI5

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.

• Section Xl Article IWA-2213, "VT3 Examination" IWA-2213 establishes method for examination of snubbers in accordance with ISTD.

1.3 Discussion In order to ensure the required operability of all safety related snubbers for Unit 1 during a seismic or other events initiating dynamic loads, the examination, testing, and the service life monitoring of these snubbers shall be implemented and performed in accordance with the written test and examination instructions and procedures as required by ISTA-1500. The examination boundaries shall include the snubber assembly from pin to pin inclusive. Coordination with the ISI program owner will be required to complete the surveillance requirements for piping and structural attachments. (Integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of the ASME Code Section Xl, Article IWF-5200(c) and IWF-5300(c) within the ISI program.) 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS 2.1 Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the requirements of the ASME OM Code, Subsection ISTD. 2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) by design type, in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample ISTD-5300. The snubbers attached to the Steam Generators are listed as a separate DTPG as required by ISTD-5253. 2.3 DTPGs at Surry Unit 1 include large bore hydraulic snubbers as DTPG 1 which includes all Steam Generator snubbers, small bore hydraulic snubbers as DTPG 2, and mechanical snubbers as DTPG 3. The individual snubbers included in the each specific DTPG are listed in Attachments 9.1, 9.2 and 9.3 of this plan. 2.4 The service life of all snubbers shall be monitored and snubbers replaced, reconditioned or evaluated in accordance with ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections. The Page 2 of 11 Revision 0 S1SNUBI5

replacement or reconditioning shall be documented and records retained in accordance with Surry procedures. 3.0 EXAMINATION and TESTING METHODS 3.1 Visual Examinations shall be performed by qualified individuals using the VT-3 method as described in ASME Section Xl, IWA-2213. Visual Examinations and Functional Testing shall be performed to verify the requirements specified within Surry written procedures are met in accordance with ISTD. 4.0 EXAMINATION and TESTING FREQUENCY 4.1 Visual Examinations and Functional Testing shall be performed at the frequency specified in ISTD. Accessible and inaccessible snubber visual examinations are performed as one group with the frequency shown in Table ISTD 4252-1. 4.2 The Visual Examinations of Table ISTD 4252-1 may be extended in accordance with Code Case OMN-1 3 once the prerequisites of the code case have been met. 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 in ISTD-5000. 5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION 5.1 Snubbers that do not appear to conform to the Visual Examination requirements of ISTD-4230 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 in accordance with ISTD-4240. 5.3 Snubbers that do not meet the operability testing acceptance criteria in ISTD-5210 shall be evaluated to determine the cause of the failure and appropriate corrective action taken. Page 3 of 11 Revision 0 SlSNUBI5

5.4 The service life of a snubber is evaluated using manufacturing input and engineering information gained through consideration of the snubber service conditions and inservice functional test results in accordance with ISTD-6000. 6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS 6.1 Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the ASME Code, Section Xl, IWA-4000. 7.0 SCHEDULING 7.1 The Visual Examinations, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with ISTD by the IST Snubber Coordinator. 7.2 The IST Snubber Coordinator shall identify and track expanded or additional testing and/or examinations as required by 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. 8.2 Applicable records and reports, as required for Repair and Replacements, shall be maintained for snubbers. 8.3 Records of the service life of all hydraulic and mechanical snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records will be maintained. 9.0 ATTACHMENTS 9.1 DPTG 1 - Large Bore Hydraulic Snubbers 9.2 DPTG 2 - Small Bore Hydraulic Snubbers 9.3 DPTG 3 - Mechanical Snubbers Page 4 of 11 Revision 0 S1 SNUBI5

ATTACHMENT 9.1 DPTG 1 - Large Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class 1-RC-HSS-138 RC Paul Munroe Hydraulics Inc 12.0 1 1-RC-HSS-140 RC Paul Munroe Hydraulics Inc 12.0 1 1-RC-HSS-142 RC Paul Munroe Hydraulics Inc 12.0 1 1-RC-HSS-144 RC Paul Munroe Hydraulics Inc 12.0 1 1-RC-HSS-146 RC Paul Munroe Hydraulics Inc 12.0 1 1-RC-HSS-148 RC Paul Munroe Hydraulics Inc 12.0 1 Page 5 of 11 Revision 0 SISNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 1-BD-HSS-2 BD Grinnel 1.5 2 1-BD-HSS-3 BD Grinnel 1.5 2

     *1-CC-HSS-330      CC     Grinnel                    2.5      3 1-CC-HSS-331      CC     Grinnel                    2.5      3 1-CC-HSS-340A     CC     Grinnel                    2.5      3 1-CC-HSS-341      CC     Grinnel                    2.5      3 1-CC-HSS-60A      CC     Grinnel                    1.5      3 1-CH-HSS-301      CH     Grinnel                    1.5      2 1-CH-HSS-302      CH     Grinnel                    1.5      2 1-CS-HSS-1        CS     Grinnel                    1.5      2 1-FW-HSS-1        FW     Grinnel                    2.5      2 1-FW-HSS-10       FW     Grinnel                    4.0      2 1-FW-HSS-11       FW     Grinnel                    4.0      2 1-FW-HSS-12       FW     Grinnel                    4.0      2 1-FW-HSS-13       FW     Grinnel                    4.0      2 1-FW-HSS-14       FW     Grinnel                    4.0      2 1-FW-HSS-141A     FW     Grinnel                    1.5      2 1-FW-HSS-141B     FW     Grinnel                    1.5      2 1-FW-HSS-142      FW     Grinnel                    1.5      2 1-FW-HSS-143B     FW     Grinnel                    1.5      2 1-FW-HSS-15        FW     Grinnel                    2.5      2 1-FW-HSS-16        FW     Grinnel                    2.5      2 1-FW-HSS-17       FW      Grinnel                    2.5      2 1-FW-HSS-18       FW      Grinnel                   3.25     NC 1-FW-HSS-2        FW      Grinnel                    2.5      2 1-FW-HSS-20       FW      Grinnel                   3.25     NC 1-FW-HSS-21A      FW      Grinnel                    2.5     NC 1 -FW-HSS-21B     FW      Grinnel                    2.5     NC 1-FW-HSS-22       FW      Grinnel                   3.25     NC 1-FW-HSS-3        FW      Grinnel                    2.5      2 1-FW-HSS-4        FW      Grinnel                    2.5      2 1-FW-HSS-6        FW      Grinnel                    2.5      2 1-FW-HSS-8        FW      Grinnel                    2.5      2 1-FW-HSS-9        FW      Grinnel                    2.5      2 1-MS-HSS-10       MS      Grinnel                    8.0      2 Page 6 of 11 Revision 0 SlSNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code 1 Snubber No System Manufacturer (inches) Class( ) 1-MS-HSS-11 MS Grinnel 8.0 2 1-MS-HSS-12 MS Grinnel 8.0 2 1-MS-HSS-13A MS Grinnel 4.0 2 1-MS-HSS-14A MS Grinnel 4.0 NC 1-MS-HSS-14B MS Grinnel 4.0 NC 1-MS-HSS-1A MS Grinnel 5.0 NC 1-MS-HSS-1B MS Grinnel 5.0 NC 1-MS-HSS-21 MS Grinnel 4.0 NC 1-MS-HSS-22 MS Grinnel 4.0 NC 1-MS-HSS-23 MS Grinnel 4.0 NC 1-MS-HSS-24 MS Grinnel 4.0 NC 1-MS-HSS-25 MS Grinnel 4.0 NC 1-MS-HSS-26 MS Grinnel 4.0 NC 1-MS-HSS-27 MS Grinnel 6.0 2 1-MS-HSS-28 MS Grinnel 6.0 2 1-MS-HSS-29 MS Grinnel 6.0 2 1-MS-HSS-2A MS Grinnel 5.0 2 1-MS-HSS-2B MS Grinnel 5.0 2 1-MS-HSS-30 MS Grinnel 6.0 2 1-MS-HSS-31 MS Grinnel 6.0 2 1-MS-HSS-32 MS Grinnel 6.0 2 1-MS-HSS-33A MS Grinnel 6.0 2 1-MS-HSS-33B MS Grinnel 6.0 2 1-MS-HSS-34A MS Grinnel 6.0 2 1-MS-HSS-34B MS Grinnel 6.0 2 1-MS-HSS-35A MS Grinnel 6.0 2 1-MS-HSS-35B MS Grinnel 6.0 2 1-MS-HSS-36 MS Grinnel 1.5 2 1-MS-HSS-37 MS Grinnel 1.5 2 1-MS-HSS-38 MS Grinnel 1.5 2 1-MS-HSS-39 MS Grinnel 1.5 2 1-MS-HSS-3A MS Grinnel 3.25 2 1-MS-HSS-3B MS Grinnel 3.25 2 1-MS-HSS-4A MS Grinnel 3.25 2 1-MS-HSS-4B MS Grinnel 3.25 2 1-MS-HSS-5A MS Grinnel 2.5 2 Page 7 of 11 Revision 0 SlSNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(') 1-MS-HSS-5B MS Grinnel 2.5 2 1-MS-HSS-6A MS Grinnel 2.5 2 1-MS-HSS-6B MS Grinnel 2.5 2 1-MS-HSS-7 MS Grinnel 8.0 2 1-MS-HSS-8 MS Grinnel 8.0 2 1-MS-HSS-9 MS Grinnel 8.0 2 1-RC-HSS-102 RC Grinnel 1.5 1 1-RC-HSS-103 RC Grinnel 1.5 1 1-RC-HSS-104 RC Grinnel 1.5 1 1-RC-HSS-105 RC Grinnel 1.5 1 1-RC-HSS-106 RC Grinnel 1.5 1 1-RC-HSS-107 RC Grinnel 1.5 1 1-RC-HSS-108 RC Grinnel 1.5 1 1-RC-HSS-110 RC Grinnel 1.5 1 1-RC-HSS-111 RC Grinnel 1.5 NC 1-RC-HSS-112 RC Grinnel 1.5 NC 1-RC-HSS-113 RC Grinnel 1.5 NC 1-RC-HSS-114 RC Grinnel 1.5 NC 1-RH-HSS-10 RH Grinnel 1.5 2 1-RH-HSS-100 RH Grinnel 1.5 NC 1-RH-HSS-101A RH Grinnel 1.5 2 1-RH-HSS-101B RH Grinnel 1.5 2 1-RH-HSS-102 RH Grinnel 1.5 1 1-RH-HSS-103 RH Grinnel 2.5 1 1-RH-HSS-104 RH Grinnel 2.5 1 1-RH-HSS-105 RH Grinnel 1.5 2 1-RH-HSS-11 RH Grinnel 1.5 2 1-RH-HSS-12 RH Grinnel 1.5 2 1-RH-HSS-13 RH Grinnel 1.5 2 1-RH-HSS-14 RH Grinnel 1.5 2 1-RH-HSS-15 RH Grinnel 1.5 2 1-RH-HSS-19 RH Grinnel 1.5 1 1-RH-HSS-20 RH Grinnel 1.5 1 1-RH-HSS-21 RH Grinnel 1.5 2 1-RH-HSS-23 RH Grinnel 1.5 1 1-RH-HSS-24 RH Grinnel 1.5 2 Page 8 of 11 Revision 0 SlSNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 1-RH-HSS-25 RH Grinnel 1.5 2 1-RH-HSS-26 RH Grinnel 1.5 2 1-RH-HSS-27 RH Grinnel 1.5 2 1-RH-HSS-28 RH Grinnel 1.5 2 1-RH-HSS-29 RH Grinnel 1.5 1 1-RH-HSS-9 RH Grinnel 1.5 2 1-SI-HSS-107 SI Grinnel 3.25 2 1-SI-HSS-100 SI Grinnel 2.5 2 1-SI-HSS-101 SI Grinnel 2.5 2 1-SI-HSS-19A SI Grinnel 5.0 1 1-SI-HSS-19B SI Grinnel 5.0 1 1-SI-HSS-20 SI Grinnel 8.0 1 1-SI-HSS-22A SI Grinnel 5.0 1 1-SI-HSS-22B SI Grinnel 5.0 1 1-SI-HSS-23 SI Grinnel 8.0 1 1-SI-HSS-24A SI Grinnel 4.0 1 1-SI-HSS-24B SI Grinnel 4.0 1 1-SI-HSS-25 SI Grinnel 8.0 1 1-SI-HSS-26 SI Grinnel 8.0 1 1-SI-HSS-84 SI Grinnel 1.5 2 1-SI-HSS-85 SI Grinnel 1.5 2 Note 1: NC is non-Code Class Page 9 of 11 Revision 0 S1SNUBI5

ATTACHMENT 9.3 DPTG 3 - Mechanical Snubbers Size Code Snubber No System Manufacturer (Ibf/10) Class(1 ) 1-BD-MSS-10 BD dynA/Damp 71R 2 1-BD-MSS-100 BD dynA/Damp 71 2 1-BD-MSS-11 BD dynA/Damp 71R 2 1-BD-MSS-13 BD dynA/Damp 71R 2 1-BD-MSS-14A BD dynA/Damp 71R 2 1-BD-MSS-14B BD dynA/Damp 71 2 1-BD-MSS-15A BD dynA/Damp 501 2 1-BD-MSS-15B BD dynA/Damp 71R 2 1-BD-MSS-18A BD dynA/Damp 41 2 1 -BD-MSS-21 BD dynA/Damp 71R 2 1-BD-MSS-23 BD dynA/Damp 501 2 1-MS-MSS-50 MS dynA/Damp 151 2 1-MS-MSS-51A MS dynA/Damp 5501 NC 1 -MS-MSS-51B MS dynA/Damp 5501 NC 1-MS-MSS-52A MS dynA/Damp 5501 NC 1-MS-MSS-52B MS dynA/Damp 5501 NC 1-MS-MSS-53A MS dynA/Damp 5501 NC 1-MS-MSS-53B MS dynA/Damp 5501 NC 1-MS-MSS-59A MS dynA/Damp 501 2 1-MS-MSS-59B MS dynA/Damp 501 2 1-MS-MSS-60A MS dynA/Damp 501 2 1-MS-MSS-60B MS dynA/Damp 501 2 1-MS-MSS-61A MS dynA/Damp 501 2 1-MS-MSS-61B MS dynA/Damp 501 2 1-RC-MSS- 115A RC dynA/Damp 1601 NC 1-RC-MSS-115B RC dynA/Damp 1601 NC 1-RC-MSS-116A RC dynA/Damp 1601 NC 1-RC-MSS-116B RC dynA/Damp 1601 NC 1-RC-MSS-117A RC dynA/Damp 1601 NC 1-RC-MSS-117B RC dynA/Damp 1601 NC 1-RC-MSS-218 RC dynA/Damp 151 NC 1-RC-MSS-219 RC dynA/Damp 71R 1 1-RC-MSS-220 RC dynA/Damp 71R 1 Page 10 of 11 Revision 0 .SlSNUB15

ATTACHMENT 9.3 DPTG 3 - Mechanical Snubbers Size Code Snubber No System Manufacturer (Ibf/10) Class(1 ) 1-RC-MSS-221 RC dynA/Damp 501 1 1-RC-MSS-222 RC dynA/Damp 501 1 1-RH-MSS-120A RH dynA/Damp 501 1 1-RH-MSS-120B RH dynA/Damp 501 1 1-RS-MSS-115A RS dynA/Damp 501 2 1-RS-MSS-115B RS dynA/Damp 501 2 1-RS-MSS-116A RS dynA/Damp 501 2 1-RS-MSS-116B RS dynA/Damp 501 2 1-RT-MSS-1OC RT dynA/Damp 41 2 1-RT-MSS-11A RT dynA/Damp 151 2 1-RT-MSS-12C RT dynA/Damp 41 2 1-RT-MSS-14C RT dynA/Damp 41 2 1-RT-MSS-1A RT dynA/Damp 151 2 1-RT-MSS-1B RT dynA/Damp 151 2 1-RT-MSS-I C RT dynA/Damp 151 2 1-RT-MSS-23B RT dynA/Damp 41 2 1-RT-MSS-2A RT dynA/Damp 41 2 1-RT-MSS-2B RT dynA/Damp 41 2 1-RT-MSS-2C RT dynA/Damp 41 2 1-SW-MSS-2 SW dynA/Damp 71R 3 Note 1: NC is non-Code Class Page 11 of 11 Revision 0 SlSNUBI5

Serial No. 13-271 Docket Nos. 50-280/281 Relocation of Snubber Surveillance Requirements from TS 4.17 to Snubber Program ATTACHMENT 6 INSERVICE EXAMINATION, TESTING, AND SERVICE LIFE MONITORING PROGRAM PLAN FOR SNUBBERS - SURRY UNIT 2 (UNIT 2 PLAN FOR NRC INFORMATION ONLY) VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY UNITS 1 AND 2

VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) SURRY POWER STATION UNIT 2 INSERVICE EXAMINATION, TESTING AND SERVICE LIFE MONITORING PROGRAM PLAN FOR SNUBBERS FIFTH INSPECTION INTERVAL MAY 10, 2014 - MAY 09, 2024 REVISION 0 COMMERCIAL OPERATION: MAY 1, 1973 ADDRESSES: VIRGINIA ELECTRIC AND POWER COMPANY P. O. BOX 26666 RICHMOND, VIRGINIA 23261 SURRY POWER STATION 5570 HOG ISLAND RD SURRY, VIRGINIA 23883 PLAN: U2 SNUB PROG PLAN INTERVAL 5

TABLE OF CONTENTS INSERVICE EXAMINATION, TESTING AND SERVICE LIFE MONITORING PROGRAM PLAN FOR SNUBBERS

1.0 INTRODUCTION

1.1 Purpose 1.2 Scope 1.3 Discussion 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 9.0 ATTACHMENTS Revision 0 S2SNUBI5

1.0 INTRODUCTION

This Examination. Testing and Service Life Monitoring Program Plan for Snubbers is applicable to the Surry Power Station Unit 2 which received its construction permit on June 25, 1968 and began commercial operation on May 1, 1973. Surry Power Station Unit 2 is a Pressurized Water Reactor located in Surry County, Virginia. The plant employs a Westinghouse Electric Corp. Nuclear Steam System. 1.1 Purpose To provide requirements for the performance and administration of assessing the operational readiness of those dynamic restraints (Snubbers) whose specific functions are required to perform one of the following three functions or, to ensure the integrity of the reactor coolant pressure boundary.

               "   Shutdown the reactor to the safe shutdown condition

• Maintain the reactor in the safe shutdown condition

               "   Mitigate the consequences of an accident 1.2    Scope The program plan was prepared to meet the requirements of the following subsections of the American Society of Mechanical Engineers (ASME)

Code Section Xl 2004 Edition and (ASME) OM Code 2004 Edition, 2005 and 2006 Addenda.

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

0 Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants" ISTD establishes 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 Page 1 of 11 Revision 0 S2SNUBI5

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. Section Xl Article IWA-2213, "VT3 Examination" IWA-2213 establishes method for examination of snubbers in accordance with ISTD. 1.3 Discussion In order to ensure the required operability of all safety related snubbers for Unit 2 during a seismic or other events initiating dynamic loads, the examination, testing, and the service life monitoring of these snubbers shall be implemented and performed in accordance with the written test and examination instructions and procedures as required by ISTA-1500. The examination boundaries shall include the snubber assembly from pin to pin inclusive. Coordination with the ISI program owner will be required to complete the surveillance requirements for piping and structural attachments. (Integral and nonintegral attachments for snubbers shall be examined in accordance with the requirements of the ASME Code Section Xl, Article IWF-5200(c) and IWF-5300(c) within the ISI program.) 2.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING REQUIREMENTS 2.1 Visual Examinations, Functional Testing, and Service Life requirements shall be performed to the requirements of the ASME OM Code, Subsection ISTD. 2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) by design type, in accordance with ISTD-5252. Each DTPG will be tested using the 10% sample ISTD-5300. The snubbers attached to the Steam Generators are listed as a separate DTPG (DTPG-1) as required by ISTD-5253. 2.3 DTPGs at Surry Unit 2 include large bore hydraulic snubbers as DTPG 1 which includes all Steam Generator snubbers, small bore hydraulic snubbers as DTPG 2, and mechanical snubbers as DTPG 3. The individual snubbers included in the each specific DTPG are listed in Attachments 9.1, 9.2 and 9.3 of this plan. 2.4 The service life of all snubbers shall be monitored and snubbers replaced, reconditioned or evaluated in accordance with ISTD-6200 to ensure that the service life is not exceeded between surveillance inspections. The Page 2 of 11 Revision 0 S2SNUBI5

replacement or reconditioning shall be documented and records retained in accordance with Surry procedures. 3.0 EXAMINATION and TESTING METHODS 3.1 Visual Examinations shall be performed by qualified individuals using the VT-3 method as described in ASME Section Xl, IWA-2213. Visual Examinations and Functional Testing shall be performed to verify the requirements specified within Surry written procedures are met in accordance with ISTD. 4.0 EXAMINATION and TESTING FREQUENCY 4.1 Visual Examinations and Functional Testing shall be performed at the frequency specified in ISTD. Accessible and inaccessible snubber visual examinations are performed as one group with the frequency shown in Table ISTD 4252-1. 4.2 The Visual Examinations of Table ISTD 4252-1 may be extended in accordance with Code Case OMN-1 3 once the prerequisites of the code case have been met. 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 in ISTD-5000. 5.0 EXAMINATION, TESTING AND SERVICE LIFE MONITORING EVAUATION 5.1 Snubbers that do not appear to conform to the Visual Examination requirements of ISTD-4230 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 in accordance with ISTD-4240. 5.3 Snubbers that do not meet the operability testing acceptance criteria in ISTD-5210 shall be evaluated to determine the cause of the failure and appropriate corrective action taken. Page 3 of 11 Revision 0 S2SNUBI5

5.4 The service life of a snubber is evaluated using manufacturing input and engineering information gained through consideration of the snubber service conditions and inservice functional test results in accordance with ISTD-6000. 6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS 6.1 Repairs, Replacements and Modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the ASME Code, Section Xl, IWA-4000. 7.0 SCHEDULING 7.1 The Visual Examinations, Functional Testing schedules, and Service Life Replacements shall be established, tracked and maintained in accordance with ISTD by the IST Snubber Coordinator. 7.2 The IST Snubber Coordinator shall identify and track expanded or additional testing and/or examinations as required by 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. 8.2 Applicable records and reports, as required for Repair and Replacements, shall be maintained for snubbers. 8.3 Records of the service life of all hydraulic and mechanical snubbers listed in this program, including the date at which the service life commences or expires, and associated installation and maintenance records will be maintained. 9.0 ATTACHMENTS 9.1 DPTG 1 - Large Bore Hydraulic Snubbers 9.2 DPTG 2 - Small Bore Hydraulic Snubbers 9.3 DPTG 3 - Mechanical Snubbers Page 4 of 11 Revision 0 S2SNUBI5

ATTACHMENT 9.1 DPTG 1 - Large Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class 2-RC-HSS-138 RC Paul Munroe Hydraulics Inc 12.0 1 2-RC-HSS-140 RC Paul Munroe Hydraulics Inc 12.0 1 2-RC-HSS-142 RC Paul Munroe Hydraulics Inc 12.0 1 2-RC-HSS-144 RC Paul Munroe Hydraulics Inc 12.0 1 2-RC-HSS-146 RC Paul Munroe Hydraulics Inc 12.0 1 2-RC-HSS-148 RC Paul Munroe Hydraulics Inc 12.0 1 Page 5 of 11 Revision 0 S2SNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 2-BD-HSS-1 BD Grinnel 1.5 2 2-BD-HSS-2 BD Grinnel 1.5 2 2-BD-HSS-4A BD Grinnel 1.5 2 2-BD-HSS-4B BD Grinnel 1.5 2 2-BD-HSS-5 BD Grinnel 1.5 2 2-BD-HSS-6A BD Grinnel 1.5 2 2-BD-HSS-6B BD Grinnel 1.5 2 2-BD-HSS-7A BD Grinnel 1.5 2 2-BD-HSS-7B BD Grinnel 1.5 2 2-BD-HSS-8A BD Grinnel 1.5 2 2-BD-HSS-8B BD Grinnel 1.5 2 2-CC-HSS-356A CC Grinnel 2.5 3 2-CC-HSS-356B CC Grinnel 1.5 3 2-CC-HSS-357 CC Grinnel 1.5 3 2-CC-HSS-358 CC Grinnel 2.5 3 2-CC-HSS-359 CC Grinnel 1.5 3 2-CC-HSS-361 CC Grinnel 1.5 3 2-CH-HSS-303 CH Grinnel 1.5 2 2-CH-HSS-304 CH Grinnel 1.5 2 2-CH-HSS-305 CH Grinnel 1.5 1 2-CH-HSS-306A CH Grinnel 1.5 1 2-CH-HSS-306B CH Grinnel 1.5 1 2-CH-HSS-307 CH Grinnel 1.5 1 2-FW-HSS-1 FW Grinnel 2.5 2 2-FW-HSS-10 FW Grinnel 4.0 2 2-FW-HSS-1 1 FW Grinnel 2.5 2 2-FW-HSS-12 FW Grinnel 2.5 2 2-FW-HSS-13 FW Grinnel 2.5 2 2-FW-HSS-14 FW Grinnel 2.5 NC 2-FW-HSS-140 FW Grinnel 1.5 2 2-FW-HSS-141 FW Grinnel 1.5 2 2-FW-HSS-142 FW Grinnel 1.5 2 2-FW-HSS-143 FW Grinnel 1.5 2 2-FW-HSS-15 FW Grinnel 3.25 NC 2-FW-HSS-16 FW Grinnel 3.25 NC Page 6 of 11 Revision 0 S2SNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 2-FW-HSS-17 FW Grinnel 3.25 NC 2-FW-HSS-18 FW Grinnel 2.5 NC 2-FW-HSS-2 FW Grinnel 2.5 2 2-FW-HSS-3 FW Grinnel 2.5 2 2-FW-HSS-4 FW Grinnel 2.5 2 2-FW-HSS-5 FW Grinnel 2.5 2 2-FW-HSS-6 FW Grinnel 2.5 2 2-FW-HSS-7 FW Grinnel 4.0 2 2-FW-HSS-8 FW Grinnel 4.0 2 2-FW-HSS-9 FW Grinnel 4.0 2 2-MS-HSS-10 MS Grinnel 8.0 2 2-MS-HSS-11 MS Grinnel 8.0 2 2-MS-HSS-12 MS Grinnel 8.0 2 2-MS-HSS-13A MS Grinnel 4.0 2 2-MS-HSS-14A MS Grinnel 4.0 NC 2-MS-HSS-14B MS Grinnel 4.0 NC 2-MS-HSS-15 MS Grinnel 5.0 NC 2-MS-HSS-16 MS Grinnel 5.0 NC 2-MS-HSS-17 MS Grinnel 5.0 NC 2-MS-HSS-18 MS Grinnel 5.0 NC 2-MS-HSS-19 MS Grinnel 5.0 NC 2-MS-HSS-1A MS Grinnel 5.0 NC 2-MS-HSS-1B MS Grinnel 5.0 NC 2-MS-HSS-20 MS Grinnel 5.0 NC 2-MS-HSS-21 MS Grinnel 4.0 NC 2-MS-HSS-22 MS Grinnel 4.0 NC 2-MS-HSS-23 MS Grinnel 4.0 NC 2-MS-HSS-24 MS Grinnel 4.0 NC 2-MS-HSS-25 MS Grinnel 4.0 NC 2-MS-HSS-26 MS Grinnel 4.0 NC 2-MS-HSS-27 MS Grinnel 6.0 2 2-MS-HSS-28 MS Grinnel 6.0 2 2-MS-HSS-29 MS Grinnel 6.0 2 2-MS-HSS-2A MS Grinnel 5.0 2 2-MS-HSS-2B MS Grinnel 5.0 2 2-MS-HSS-30 MS Grinnel 6.0 2 Page 7 of 11 Revision 0 S2SNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 2-MS-HSS-31 MS Grinnel 6.0 2 2-MS-HSS-32 MS Grinnel 6.0 2 2-MS-HSS-33A MS Grinnel 6.0 2 2-MS-HSS-33B MS Grinnel 6.0 2 2-MS-HSS-34A MS Grinnel 6.0 2 2-MS-HSS-34B MS Grinnel 6.0 2 2-MS-HSS-35A MS Grinnel 6.0 2 2-MS-HSS-35B MS Grinnel 6.0 2 2-MS-HSS-36A MS Grinnel 1.5 2 2-MS-HSS-36B MS Grinnel 1.5 2 2-MS-HSS-3A MS Grinnel 3.25 2 2-MS-HSS-3B MS Grinnel 3.25 2 2-MS-HSS-40 MS Grinnel 2.5 NC 2-MS-HSS-41 MS Grinnel 2.5 NC 2-MS-HSS-42 MS Grinnel 2.5 NC 2-MS-HSS-4A MS Grinnel 3.25 2 2-MS-HSS-4B MS Grinnel 3.25 2 2-MS-HSS-51 MS Grinnel 1.5 NC 2-MS-HSS-5A MS Grinnel 2.5 2 2-MS-HSS-5B MS Grinnel 2.5 2 2-MS-HSS-6A MS Grinnel 2.5 2 2-MS-HSS-6B MS Grinnel 2.5 2 2-MS-HSS-7 MS Grinnel 6.0 2 2-MS-HSS-8 MS Grinnel 6.0 2 2-MS-HSS-9 MS Grinnel 8.0 2 2-RC-HSS-100 RC Grinnel 1.5 1 2-RC-HSS-101 RC Grinnel 1.5 1 2-RC-HSS-102 RC Grinnel 1.5 1 2-RC-HSS-103 RC Grinnel 1.5 1 2-RC-HSS-104 RC Grinnel 1.5 1 2-RC-HSS-105 RC Grinnel 1.5 1 2-RC-HSS-106 RC Grinnel 1.5 1 2-RC-HSS-107 RC Grinnel 1.5 1 2-RC-HSS-108 RC Grinnel 1.5 1 2-RC-HSS-110 RC Grinnel 1.5 1 2-RC-HSS-112 RC Grinnel 3.25 NC Page 8 of 11 Revision 0 S2SNUBI5

ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 2-RC-HSS-113 RC Grinnel 1.5 NC 2-RC-HSS-114 RC Grinnel 1.5 NC 2-RC-HSS-115 RC Grinnel 1.5 NC 2-RC-HSS-116 RC Grinnel 1.5 NC 2-RC-HSS-117 RC Grinnel 1.5 NC 2-RC-HSS-118 RC Grinnel 3.25 NC 2-RC-HSS-119 RC Grinnel 3.25 NC 2-RC-HSS-184 RC Grinnel 1.5 1 2-RC-HSS-186 RC Grinnel 1.5 1 2-RC-HSS-187 RC Grinnel 1.5 NC 2-RC-HSS-188A RC Grinnel 2.5 NC 2-RC-HSS-188B RC Grinnel 2.5 NC 2-RC-HSS-189A RC Grinnel 4.0 NC 2-RC-HSS-189B RC Grinnel 4.0 NC 2-RH-HSS-10 RH Grinnel 1.5 2 2-RH-HSS-101 RH Grinnel 1.5 1 2-RH-HSS-102 RH Grinnel 1.5 2 2-RH-HSS-1 1 RH Grinnel 1.5 2 2-RH-HSS-12 RH Grinnel 1.5 2 2-RH-HSS-13 RH Grinnel 1.5 2 2-RH-HSS-14 RH Grinnel 1.5 2 2-RH-HSS-15 RH Grinnel 1.5 2 2-RH-HSS-17 RH Grinnel 2.5 1 2-RH-HSS-18 RH Grinnel 2.5 1 2-RH-HSS-19 RH Grinnel 2.5 1 2-RH-HSS-20 RH Grinnel 2.5 1 2-RH-HSS-21 RH Grinnel 1.5' 2 2-RH-HSS-22 RH Grinnel 1.5 2 2-RH-HSS-25 RH Grinnel 1.5 2 2-RH-HSS-26 RH Grinnel 1.5 2 2-RH-HSS-27 RH Grinnel 2.5 2 2-RH-HSS-28 RH Grinnel 1.5 2 2-RH-HSS-29 RH Grinnel 2.5 2 2-RH-HSS-30 RH Grinnel 1.5 2 2-RH-HSS-31 RH Grinnel 2.5 2 2-RH-HSS-32 RH Grinnel 2.5 1 Page 9 of 11 Revision 0 S2SNUBI5

S 4. ATTACHMENT 9.2 DPTG 2 - Small Bore Hydraulic Snubbers Size Code Snubber No System Manufacturer (inches) Class(1 ) 2-RH-HSS-33A RH Grinnel 1.5 NC 2-RH-HSS-33B RH Grinnel 1.5 NC 2-RH-HSS-34 RH Grinnel 1.5 2 2-RH-HSS-35 RH Grinnel 2.5 2 2-RH-HSS-36A RH Grinnel 1.5 2 2-RH-HSS-36B RH Grinnel 1.5 2 2-RH-HSS-37 RH Grinnel 1.5 2 2-RH-HSS-38 RH Grinnel 1.5 2 2-RH-HSS-39 RH Grinnel 1.5 2 2-RH-HSS-40 RH Grinnel 2.5 2 2-RH-HSS-9 RH Grinnel 1.5 2 2-RS-HSS-101 RS Grinnel 1.5 2 2-RS-HSS-102 RS Grinnel 1.5 2 2-RS-HSS-103 RS Grinnel 1.5 2 2-RS-HSS-104 RS Grinnel 1.5 2 2-SI-HSS-1A SI Grinnel 2.5 2 2-SI-HSS-1B SI Grinnel 2.5 2 2-SI-HSS-100 SI Grinnel 2.5 2 2-SI-HSS-101 SI Grinnel 2.5 2 2-SI-HSS-103 SI Grinnel 1.5 2 2-SI-HSS-104A SI Grinnel 2.5 2 2-SI-HSS-104B SI Grinnel 2.5 2 2-SI-HSS-19A SI Grinnel 5.0 1 2-SI-HSS-19B SI Grinnel 5.0 1 2-SI-HSS-20 SI Grinnel 8.0 1 2-SI-HSS-22A SI Grinnel 5.0 1 2-SI-HSS-22B SI Grinnel 5.0 1 2-SI-HSS-23 SI Grinnel 8.0 1 2-SI-HSS-24 SI Grinnel 6.0 1 2-SI-HSS-25 SI Grinnel 8.0 1 2-SI-HSS-26 SI Grinnel 8.0 1 2-SI-HSS-27 SI Grinnel 6.0 1 Note 1: NC is non-Code Class Page 10 of 11 Revision 0 S2SNUBI5

4 I-) j ATTACHMENT 9.3 DPTG 3 - Mechanical Snubbers Size Code Snubber No System Manufacturer (Ibf/10) Class(') 2-CH-MSS-1 CH dynA/Damp 501 1 2-CH-MSS-2 CH dynA/Damp 501 1 2-CH-MSS-3 CH dynA/Damp 151 1 2-MS-MSS-1 MS dynA/Damp 501 2 2-MS-MSS-2 MS dynA/Damp 503 2 2-MS-MSS-3 MS dynA/Damp 503 2 2-MS-MSS-4 MS dynA/Damp 501 2 2-MS-MSS-5 MS dynA/Damp 501 2 2-MS-MSS-6 MS dynA/Damp 501 2 2-RC-MSS-1 RC dynA/Damp 503 NC 2-RC-MSS-2 RC dynA/Damp 503 NC 2-RC-MSS-5 RC dynA/Damp 71 1 2-RC-MSS-6 RC dynA/Damp 41 1 2-RC-MSS-7 RC dynA/Damp 71 R 1 2-RH-MSS-1 RH dynA/Damp 151 1 2-RH-MSS-2 RH dynA/Damp 501 2 2-RT-MSS-15B RT dynA/Damp 41 2 2-RT-MSS-15C RT dynA/Damp 41 2 2-RT-MSS-16B RT dynA/Damp 41 2 2-RT-MSS-1A RT dynA/Damp 151 2 2-RT-MSS-1B RT dynA/Damp 151 2 2-RT-MSS-1C RT dynA/Damp 151 2 2-RT-MSS-2A RT dynA/Damp 41 2 2-RT-MSS-2B RT dynA/Damp 41 2 2-RT-MSS-2C RT dynA/Damp 151 2 Note 1: NC is non-Code Class Page 11 of 11 Revision 0 S2SNUBI5}}