ML073100435

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Third 10-Year Interval, Inservice Program Relief Request RR-V-1 (Tac Nos. MD5409 and MD5410)
ML073100435
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/15/2007
From: Lingham S
NRC/NRR/ADRO/DORL/LPLII-1
To: Tynan T
Southern Nuclear Operating Co
Lingam, Siva NRR/DORL 415-1564
References
TAC MD5409, TAC MD5410
Download: ML073100435 (4)


Text

November 15, 2007 Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, THIRD 10-YEAR INTERVAL INSERVICE PROGRAM RELIEF REQUEST RR-V-1 (TAC NOS. MD5409 AND MD5410)

Dear Mr.Tynan:

By letter dated April 16, 2007, as supplemented by letter dated September 20, 2007, Southern Nuclear Operating Company, Inc. (the licensee), submitted Relief Request RR-V-1 for Vogtle Electric Generating Plant, Units 1 and 2. The relief request proposed an alternative to the requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 50.55a (10 CFR 50.55a), concerning a requirement in the American Society of Mechanical Engineers, Operation and Maintenance of Nuclear Power Plants Code (ASME OM Code). The proposed alternative involves the elimination of the ASME OM Code required 5-minute test interval between successive setpoint tests for liquid service pressure relief valves.

The Nuclear Regulatory Commission (NRC) staff has reviewed the licensees analysis in support of its relief request. The NRC staff has concluded that the elimination of the 5-minute test interval required by the ASME OM Code would provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the elimination of the 5-minute test interval for liquid service pressure relief valves.

Sincerely,

/RA/

Siva P. Lingam, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosure:

Safety Evaluation cc w/encl: See next page

November 15, 2007 Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, THIRD 10-YEAR INTERVAL INSERVICE PROGRAM RELIEF REQUEST RR-V-1 (TAC NOS. MD5409 AND MD5410)

Dear Mr.Tynan:

By letter dated April 16, 2007, as supplemented by letter dated September 20, 2007, Southern Nuclear Operating Company, Inc. (the licensee), submitted Relief Request RR-V-1 for Vogtle Electric Generating Plant, Units 1 and 2. The relief request proposed an alternative to the requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 50.55a (10 CFR 50.55a), concerning a requirement in the American Society of Mechanical Engineers, Operation and Maintenance of Nuclear Power Plants Code (ASME OM Code). The proposed alternative involves the elimination of the ASME OM Code required 5-minute test interval between successive setpoint tests for liquid service pressure relief valves.

The Nuclear Regulatory Commission (NRC) staff has reviewed the licensees analysis in support of its relief request. The NRC staff has concluded that the elimination of the 5-minute test interval required by the ASME OM Code would provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the elimination of the 5-minute test interval for liquid service pressure relief valves.

Sincerely,

/RA/

Siva P. Lingam, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION: Public RidsAcrsAcnwMailCenter LPL2-1 R/F SCampbell, EDO Rgn II RidsNrrDorlLpl2-1 (EMarinos) RidsNrrDciCptb (JMcHale)

RidsNrrPMSLingam (hard copy) RidsRgn2MailCenter (SSchaefer)

RidsNrrLAMO=Brien (hard copy) RidsNrrDciCptb (RWolfgang)

RidsOgcRp RidsNrrDciCptb (MOrenak)

ADAMS ACCESSION NO.: ML073100435 *memo transmitting SE dated.

NRR/DCI/CPTB/B OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA C OGC NRR/LPL2-1/BC NAME SLingam MO=Brien JMcHale KSexton EMarinos DATE 11/5/07 11/5/07 11/1/07* 11/13/07 11/15/07 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE THIRD 10-YEAR INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST NO. RR-V-1 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425 INTRODUCTION By letter dated April 16, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071080463), as supplemented by letter dated September 20, 2007 (ADAMS Accession No. ML072640100), Southern Nuclear Operating Company. Inc. (the licensee), submitted Relief Request RR-V-1 for Vogtle Electric Generating Plant (VEGP), Units 1 and 2. The relief request proposed an alternative to the requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 50.55a (10 CFR 50.55a), concerning a requirement in the American Society of Mechanical Engineers, Operation and Maintenance of Nuclear Power Plants Code (ASME OM Code). The proposed alternative involves the elimination of the ASME OM Code required 5-minute test interval between successive setpoint tests for liquid service pressure relief valves.

REGULATORY EVALUATION Section 50.55a requires that inservice testing (IST) of certain ASME Boiler and Pressure Vessel Code (ASME Code) Class 1, 2, and 3 pumps and valves be performed in accordance with the ASME OM Code and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Nuclear Regulatory Commission (NRC) pursuant to paragraphs (a)(3)(i),

(a)(3)(ii), or (f)(6)(i) of 10 CFR 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. Section 50.55a allows the NRC to authorize alternatives and to grant relief from ASME OM 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, Revision 1.

Enclosure

TECHNICAL EVALUATION By letter dated April 16, 2007, as supplemented by letter dated September 20, 2007, the licensee submitted relief request RR-V-1 for the VEGP, Units 1 and 2. Relief request RR-V-1 requested relief from the ASME OM Code, Appendix I, Section I-8000, requirement for a 5-minute hold time between successive setpoint tests for liquid service pressure relief valves. The Code of record is the 2001 edition with addenda through OMb - 2003. A description of the relief request and the NRC staffs evaluation are as follows.

Code Requirements Appendix I, Section I-8000 of ASME OM Code contains test methods for ASME Code, Class 2 and 3 relief valves in liquid systems. Paragraph I-8130(g) requires a minimum of 5 minutes shall elapse between successive openings.

Licensees Basis for Requesting Relief IST programs require that the testing meets the ASME OM Code of record. Specifically, the Code requires performing a minimum of two consecutive valve actuations to determine the setpoint of the pressure relief valve. Under the ASME OM Code, Appendix I, the minimum elapsed time between valve openings is 5 minutes.

Eliminating this 5-minute hold time will minimize test performance and system outage times, resulting in a more timely return to service.

At VEGP, Units 1 and 2, pressure relief valves in ASME Code, Class 2 and 3 liquid systems are bench tested at ambient conditions using water as the test medium. The setpoint testing is performed in a shop environment with the test medium and valve in thermal equilibrium. There is no thermal source introduced during the test that could result in a thermal imbalance or reduced accuracy of the test. Repeated valve actuations are conducted in a controlled environment under steady-state conditions.

Licensees Proposed Alternative Testing The licensee proposes the elimination of the 5-minute hold time for ASME Code, Class 2 and 3 setpoint tests for liquid service pressure relief valves.

Technical Evaluation The ASME OM Code 5-minute hold time requirement is based on the assumption that the test medium temperature is different from the valve temperature. Setpoint testing with different valve and test medium temperatures would cause the temperature of the valve to change; therefore, the setpoint would be affected. The NRC staff finds that the ASME Code, Class 2 and 3 liquid system pressure relief valves are in thermal equilibrium under the ambient test temperature conditions. Thermal stabilization is achieved with no hold time; consequently, the setpoint is unaffected. Thus, the NRC staff finds that the proposed no hold time between setpoint tests of the ASME Code, Class 2 and 3 system liquid service pressure relief valves provides an adequate method of accurately and repeatedly determining setpoints.

Conclusion The NRC staff concludes that the licensees proposed alternative to the above discussed ASME OM Code testing requirement for ASME Code, Class 2 and 3 liquid service pressure relief valves in RR-V-1 is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the proposed alternative testing provides an acceptable level of quality and safety. The elimination of the hold time between consecutive setpoint tests should not impair the valves operational readiness.

Principal Contributor: Michael D. Orenak Date: November 15, 2007

Vogtle Electric Generating Plant, Units 1 & 2 cc:

Mr. Tom E. Tynan Vice President - Vogtle Arthur H. Domby, Esquire Vogtle Electric Generating Plant Troutman Sanders 7821 River Road Nations Bank Plaza Waynesboro, GA 30830 600 Peachtree Street, NE Suite 5200 Mr. N. J. Stringfellow Atlanta, GA 30308-2216 Manager, Licensing Southern Nuclear Operating Company, Resident Inspector Inc. Vogtle Plant P.O. Box 1295 8805 River Road Birmingham, AL 35201-1295 Waynesboro, GA 30830 Mr. Jeffrey T. Gasser Office of the County Commissioner Executive Vice President Burke County Commission Southern Nuclear Operating Company, Waynesboro, GA 30830 Inc.

P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Mr. Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Mr. Laurence Bergen Oglethorpe Power Corporation 2100 East Exchange Place P.O. Box 1349 Tucker, GA 30085-1349