ML022100091
| ML022100091 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/26/2002 |
| From: | John Nakoski NRC/NRR/DLPM/LPD2 |
| To: | Sumner H Southern Nuclear Operating Co |
| References | |
| TAC MB4086, TAC MB4087 | |
| Download: ML022100091 (7) | |
Text
July 26, 2002 Mr. H. L. Sumner, Jr.
Vice President - Nuclear Hatch Project Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, Alabama 35201-1295
SUBJECT:
RELIEF REQUEST FOR THE THIRD 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM RE: EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MB4086 AND MB4087)
By [[letter::HL-6185, Request for Relief, Elimination of ASME OM Code & ASME Section XI Code Requirements for Anii Involvement in Third Ten-Year Inservice Testing (IST) Interval|letter dated February 13, 2002]], you submitted a relief request for the third 10-year interval inservice testing program for pumps and valves for Edwin I. Hatch Nuclear Plant, Units 1 and 2.
The relief request, RR-G-4, requests elimination of the requirements and duties for the Authorized Nuclear Inservice Inspector.
We have reviewed RR-G-4 and the associated proposed alternative testing method against the requirements of ASME OM Code, 1995 Edition and the 1996 Addenda, which are incorporated by reference in 10 CFR 50.55a. Our findings are provided in the enclosed Safety Evaluation.
Pursuant to 10 CFR 50.55a(a)(3)(i), relief request RR-G-4 is authorized based on an acceptable level of quality and safety that will be provided by the alternative.
Sincerely,
/RA/
John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
Enclosure:
As stated
- See previous concurrence
- No major changes to SE OFFICE PDII-1/PM PDII-1/LA PDII-1/SC OGC**
EMEB/SC*
NAME LOlshan CHawes JNakoski RHoefling DTerao DATE 7/25/02 7/25/02 7/25/02 7/17/02 6/28/02
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THIRD 10-YEAR INTERVAL INSERVICE TESTING PROGRAM SOUTHERN NUCLEAR OPERATING COMPANY, INC.
EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366
1.0 INTRODUCTION
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (the Code) and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of Section 50.55a. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility. 10 CFR 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME code requirements upon making the necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the Code requirements that are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants.
By [[letter::HL-6185, Request for Relief, Elimination of ASME OM Code & ASME Section XI Code Requirements for Anii Involvement in Third Ten-Year Inservice Testing (IST) Interval|letter dated February 13, 2002]], Southern Nuclear Operating Company, Inc., licensee for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, submitted a relief request for its third 10-year interval IST program for pumps and valves. The staff has reviewed the relief request and associated proposed alternative testing method against the requirements of ASME OM Code, 1995 Edition and the 1996 Addenda, which are incorporated by reference in 10 CFR 50.55a, and is providing the following evaluation.
2.0 RELIEF REQUEST RR-G-4 The licensee has requested elimination of the requirements and duties for the Authorized Nuclear Inservice Inspector (ANII) as identified in OM Code ISTA 2.1 pertaining to IST of pumps and valves.
2.1 Licensees Basis for Requesting Relief The licensee states:
The requirements for independent inspection have been deleted in the ASME OM Code 1998 Edition. Additionally, the ASME Section XI deleted reference to independent inspection for IST on pumps and valves from subsection IWA-2110 in the 2000 Addenda.
The ANII review of the IST Program required by the ASME OM Code, 1990 and 1995 Edition, is less comprehensive than the review required by the ASME Section XI Code for Inservice Inspection (ISI) activities. The 1998 Edition, and subsequent editions, of the ASME OM Code have eliminated reference for ANII duties entirely. Section IWA-2110 of the ASME XI Code (2000 Addenda) specifies the duties of the ANII related to the IST performed for pumps and valves and component supports as simply verifying that inservice tests have been performed and the results recorded. In general, ANIIs do not have the training or background experience to make determinations about pump and valve safety functions in order to verify program scope, or to assess the operational readiness of pumps and valves based on test results. Consequently, the ANII review provides little if any benefit.
SNC, at Plant Hatch, maintains a multi-layered review process that accomplishes the same results as expected by the earlier versions of the ASME XI and OM Code. IST is typically performed by Operations, Maintenance, or Engineering Department personnel with extensive experience in Code requirements applicable for IST of pumps and valves. Test procedures contain detailed instructions for performance of tests and all data is reviewed by a minimum of two independent personnel (typically an Operations Shift Supervisor (SRO) and the IST engineer). The IST Program scope is reviewed by regulatory authorities against Code and regulatory guidance to ensure that components required to be tested are included. The IST program documents, surveillance procedures, and test data are also subject to the SNC quality assurance program which provides an equivalent, or greater level of quality and safety than those required by ANII involvement specified in the Code. Therefore, there is no quality or safety related benefit in the ANII duplication of review and oversight of IST implementation at Plant Hatch.
Therefore, the proposed alternative, in conjunction with continued review and oversight by knowledgeable and experienced SNC personnel will provide an acceptable level of quality and safety and thus this request for relief is justified pursuant to 10 CFR 50.55a(a)(3)(i).
2.2 Alternative Testing The licensee states:
The ASME OM Code requirements specifying the duties of the ANII described in subsection ISTA 2.1 will be eliminated from the IST program.
3.0 EVALUATION The 1995 Edition with the 1996 Addenda of the OM Code requires that IST activities be verified by an ANII. It is the ANIIs duties to verify that inservice tests on pumps, valves, and component supports have been completed and that the results have been recorded. The licensee proposes to eliminate from the IST program these specific requirements for the duties of the ANII.
As stated by the licensee, utilities have a multi-layered review process that accomplishes the same results as expected by the OM Code. IST is typically performed by Operations, Maintenance, or Engineering Department personnel with extensive experience in Code requirements that are applicable to IST of pumps and valves. The staff finds that the licensees review processes for the IST program provide a level of quality and safety equivalent to or higher than that required by the Code. Since ANIIs generally do not have the training or background experience to make determinations about the scope of the IST program or to assess the operational readiness of pumps and valves based on inservice test results, the requirements for the ANII have been removed in the 1998 Edition/2000 Addenda of the OM Code.
4.0 CONCLUSION
The alternative to eliminate specific requirements for duties of the ANII from the Hatch, Units 1 and 2 IST program is authorized pursuant to 10 CFR 50.55a(a)(3)(i) based on an acceptable level of quality and safety that will be provided by the alternative.
Principal Contributor: Y. S. Huang Date: July 26, 2002
Edwin I. Hatch Nuclear Plant cc:
Mr. Ernest L. Blake, Jr.
Shaw, Pittman, Potts and Trowbridge 2300 N Street, NW.
Washington, DC 20037 Mr. D. M. Crowe Manager, Licensing Southern Nuclear Operating Company, Inc.
P. O. Box 1295 Birmingham, Alabama 35201-1295 Resident Inspector Plant Hatch 11030 Hatch Parkway N.
Baxley, Georgia 31531 Mr. Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, SW.
Atlanta, Georgia 30334 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, Georgia 30334 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, Georgia 30328-4684 Charles A. Patrizia, Esquire Paul, Hastings, Janofsky & Walker 10th Floor 1299 Pennsylvania Avenue Washington, DC 20004-9500 Chairman Appling County Commissioners County Courthouse Baxley, Georgia 31513 Mr. J. D. Woodard Executive Vice President Southern Nuclear Operating Company, Inc.
P. O. Box 1295 Birmingham, Alabama 35201-1295 Mr. P. W. Wells General Manager, Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc.
U.S. Highway 1 North P. O. Box 2010 Baxley, Georgia 31515 Mr. L. M. Bergen Resident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P. O. Box 2010 Baxley, Georgia 31515