ND-16-1437, Snubber Program Plan for the Fifth Ten-Year Inservice Testing Interval
| ML16237A084 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 08/24/2016 |
| From: | Wheat J Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ND-16-1437 | |
| Download: ML16237A084 (6) | |
Text
Justin T. Wheat Southern Nuclear Nuclear Licensing Manager Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242
~ Southern Nuclear Tel 205.992.5998 Fax 205.992.7601 AUG 2 4 2016 Docket Nos.: 50-321 NL-16-1437 50-366 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555-0001 Southern Nuclear Operating Company Edwin I. Hatch Nuclear Plant Units 1 and 2; Snubber Program Plan for the Fifth Ten-Year lnservice Testing Interval Ladies and Gentlemen:
In accordance with American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), Subparagraph ISTA-3200(a),
Southern Nuclear is submitting for your information a copy of the Edwin I. Hatch Nuclear Plant Snubber Program.
This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.
Respectfully submitted, Justin T. Wheat Nuclear Licensing Manager jtw/efb/lac : Edwin I. Hatch Nuclear Plant Snubber Program
U.S. Nuclear Regulatory Commission NL-16-1437 Page 2 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. Mitch Etten-Bohm, Senior Engineer Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: Hatch=CHA02.004 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Senior Project Manager - Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division
Southern Nuclear Operating Company Edwin I. Hatch Nuclear Plant Units 1 and 2 Snubber Program Plan for the Fifth Ten-Year lnservice Testing Interval ENCLOSURE 1 Edwin I. Hatch Nuclear Plant Snubber Program HNP Snubber Program .doc Page 1 of 4 Version 1.0
Edwin I. Hatch Nuclear Plant Snubber Program The Edwin I. Hatch Nuclear Plant Units 1 and 2 (HNP) Snubber Program complies with 10 CFR 50.55a(b)(3) wherein paragraph 50.55a(b)(3)(v)(B) requires the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Subsection ISTD be used to govern inservice examination and testing of dynamic restraints (snubbers) at nuclear power plants, with appropriate changes made to the Technical Specifications (TS) or licensee-controlled documents.
The Plant Hatch Fifth 10-Year Interval extends from January 1, 2016 to December 31, 2025. For this 10-year interval, the Snubber Program is updated concurrently with the lnservice Inspection (lSI) and lnservice Testing (1ST) updates. This meets 10 CFR 50.55a requirements for program updates to the latest edition and addenda of the Code that it has endorsed 12 months before the start of the plant's next 120 month interval. Therefore, the code of record for the Plant Hatch Fifth 10-Year Interval is the ASME OM Code, 2004 Edition through 2006 Addenda as endorsed in the 10 CFR 50.55a rulemaking effective on July 19, 2011. Utilizing this edition of the OM Code aligns the snubber program with the 1ST pumps and valves program .
The following table provides current and previous 10-Year Interval dates.
HNP Unit 1 HNP Unit2 1st 10-year Interval 01 /01 /1975 to 12/31/1985 09/06/1979 to 12/31/1985 2nd 10-year Interval 01 /01 /1986 to 12/31/1995 01 /01 /1986 to 12/31 /1995 3rd 10-year Interval 01 /01 /1996 to 12/31/2005 01 /01 /1996 to 12/31 /2005 4th 10-year Interval 01 /01 /2006 to 12/31 /2015 01 /01 /2006 to 12/31/2015 5th 10-year Interval 01 /01 /2016 to 12/31 /2025 01 /01 /2016 to 12/31/2025 OM Code subsection ISTA- 1100 requires the scope of the snubber program to include any snubbers having one or more of the functions listed below:
- Shutting down the reactor to the safe shutdown condition
- Maintaining the reactor's safe shutdown condition
- Mitigating the consequences of an accident
- Ensuring the integrity of the reactor coolant pressure boundary The amount of snubbers at HNP within the scope of ISTA is listed below:
UNIT1 I Accessible I Inaccessible I Grand Total Snubbers I 141 I 169 I 310 UNIT2 I Accessible I Inaccessible I Grand Total Snubbers I 187 I 110 I 357 Per ISTA-3200(a), this program shall be filed with the NRC.
Detailed information for each snubber is contained within SnubbWorks, a data management program that is part of the software package lddeal Concept, Inc.
Roles, responsibilities, a site-specific procedures' list, and implementation instructions for the HNP snubber program are found in NMP-ES-057 and associated instructions.
HNP Snubber Program.doc Page 2 of 4 Version 1.0
SNUBBER TEST PLAN
- 1. Relationship with Licensing Documents No conflicts between ASME OM Code 2004 through 2006 Addenda requirements and the requirements of HNP-1/2 Technical Specifications have been identified. As part of the process for adopting the AMSE OM Code, the HNP-1/2 Technical Requirements Manual 3.7.1 was reviewed and revised accordingly.
- 2. Quality Assurance Subsection ISTA of the 2004 Edition through 2006 Addenda provides General Requirements applicable to OM Code activities. These requirements are applied to snubber program activities.
The HNP Snubber Program activities will be conducted in accordance with the Southern Nuclear 10 CFR Part 50, Appendix 8 Quality Assurance Program Topical Report (QATR).
- 3. HNP-1/2 Safety Class Piping HNP-1 safety class piping was designed to 831.7 and 831.1 requirements with additional NDE and QA requirements. HNP-2 safety class piping was designed to ASME Section Ill Class 1, 2, and 3 requirements. In addition, certain systems important to safety that were designed to ANSI 831.1 are currently included within the scope of ASME Section XI and treated as Class 2 or 3.
- 4. HNP-1/2 Snubber Classification At HNP-1/2, snubbers falling under the scope of ISTA-11 00 are classified as either safety related or safety significant.
Safety related snubbers are snubbers required to shut down/maintain shut down of a reactor, and mitigate consequences of an accident. These snubbers are attached directly to ASME Class 1, 2 or 3 piping. The Class 1, 2, or 3 safety-related scope is defined by plant boundary diagrams. A list can be found in the plant's lnservice Inspection (lSI) Plan.
Safety significant snubbers are snubbers needed to ensure the integrity of the reactor coolant pressure boundary. These snubbers are located on non-class systems whose failure could jeopardize class 1, 2, or 3 piping; specifically, non-safety piping that is between the safety class valve and the first anchor point. This piping is considered safety-significant because it must be structurally sound in case of a design basis event, so that the safety-class piping is not affected.
As allowed by ISTD-4220(a), snubbers are divided into inaccessible and accessible for examination. Inaccessible is defined as any snubber that cannot be reached during normal operation; such snubbers are located inside the drywall and condenser bay. Accessible is defined as any snubber located outside the drywall and condenser bay. At HNP, both inaccessible and accessible snubbers are examined during the same refueling outage.
As allowed by ISTD-5252, HNP-1/2's snubbers are also classified by manufacturer, per section 6.
- 5. Snubber Visual Examination All snubbers at HNP falling under the scope of ISTA - 1100 are subjected to the requirements of ISTD - 4000. Per ISTD-3110, the visual examination must be pin-to-pin (include everything between the snubber pin attachments). The frequency of 100% visual examination is determined by OM Code Table ISTD-4252-1. HNP-1/2 current frequency is 48 months.
HNP Snubber Program.doc Page 3 of 4 Version 1.0
In accordance with ISTD - 4100, newly installed snubbers are subjected to preservice examinations. In accordance with ISTD - 4200, periodic inservice visual examinations are performed on all snubbers.
The snubbers installed in HNP-1/2 that fall under the jurisdiction of ISTD - 4000 are listed in Owner Controlled Documents. The visual examination frequency of non-safety related, non-safety significant snubbers is discussed in section 8.
- 6. Snubber Operational Readiness Testing All snubbers at HNP falling under the scope of ISTA - 1100 are subjected to the requirements of ISTD- 5000.
In accordance with ISTD - 5100, new snubbers shall have been subjected to a site preservice operational readiness test before installation. Testing may be performed at the manufacturer's facility.
In accordance with ISTD - 5200, periodic inservice operational readiness testing shall be performed on all snubbers.
The Defined Test Plan Groups (DTPG) are listed below:
DTPG I Pacific Scientific (PSA)
DTPG II Lisega and Anvil DTPG Ill Bergen Paterson _fBP}
PSA snubbers are mechanical snubbers. Lisega, Anvil, and Bergen Paterson snubbers are hydraulic snubbers.
Each refueling outage, a 10% initial sample of each DTPG will be tested in accordance with ISTD-5261 (a). The initial sample plan will be selected in accordance with ISTD-5311. In the event any unacceptable snubbers are found, additional snubbers will be selected for testing during the same refueling outage to meet the requirements of ISTD-5320.
The frequency of functionally testing non-safety related, non-safety significant snubbers is discussed in section 8.
- 7. Service Life and Snubber Seal Replacement Program A snubber service life program in accordance with ISTD-6000 has been established for HNP-1/2.
This service life program includes the requirements of the snubber seal replacement program required by ISTD. The specifics of the program are recorded in corporate and site procedures.
- 8. HNP-1/2 Non-Safety Related. Non-Safety Significant Snubbers Owner controlled documents contain non-safety related, non-safety significant snubbers (snubbers that are not covered under the TRM 3.7.1 scope). As a good engineering practice, one-third of each unit's non-safety related, non-safety significant snubbers will be visually examined on the same frequency as the 100% visual examination of the subsection ISTA-11 00 scope snubbers.