ML19035A616

COL Docs - Draft PST-ALT-02, Alternative Requirements for Preservice Testing of Class 1 Safety Valves

ML19035A616
Person / Time
Site:	Vogtle
Issue date:	02/04/2019
From:	NRC
To:	NRC/NRO/DLSE/LB4
References
Download: ML19035A616 (5)

Text

Vogtle PEmails From: Hoellman, Jordan Sent: Monday, February 4, 2019 1:39 PM To: Vogtle PEmails

Subject:

Draft PST-ALT-02, Alternative Requirements for Preservice Testing of Class 1 Safety Valves Attachments: PST-ALT-02 Presubmittal.pdf Please see the attached draft PST-ALT-02, for discussion at a future public meeting.

Jordan Hoellman Project Manager NRO / DLSE / LB2 U.S. Nuclear Regulatory Commission office: OWFN 08-C18 phone: (301) 415-5481 email: Jordan.Hoellman2@nrc.gov 1

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 413 Mail Envelope Properties (SN6PR0901MB2366012383D712FE736CEEA7D56D0)

Subject:

Draft PST-ALT-02, Alternative Requirements for Preservice Testing of Class 1 Safety Valves Sent Date: 2/4/2019 1:39:23 PM Received Date: 2/4/2019 1:39:29 PM From: Hoellman, Jordan Created By: Jordan.Hoellman2@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

Tracking Status: None Post Office: SN6PR0901MB2366.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 333 2/4/2019 1:39:29 PM PST-ALT-02 Presubmittal.pdf 682399 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

ND-19-0060 Enclosure Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -

Alternative Requirements for Preservice Testing of Class 1 Safety Valves Plant Site-Unit: Vogtle Electric Generating Plant (VEGP) - Units 3 and 4 Interval-Interval Applies to the preservice testing period.

Dates:

Requested Date Approval is requested by August 15, 2019 for Approval:

ASME Code Components ASME Class 1 Safety Valves.

Affected:

D Applicable Code R

Edition and Addenda:

ASME OM Code, 2012 012 Edition tion (c (code of re record).

AF Applicable Code ASME E OM Code, months Code I-7210 210 requ requires Class 1 safety valve testing within 6 ths before initial reactor onths reac criticality, each valve shall have its set-Set-pressure verification shall be determined by pressure verified. Set T

Requirements: pressurizing the system up to the valve set-pressure and opening the th sys valve, or the valve valv may be tested at or below normal system operating pressures with an assist device.

es wit The existing Code Requirement implies that the safety valves be tested in place. Due to the location of the valves on top of the pressurizer, this is a personnel safety issue based on the Reason for temperature environment when the valves would be tested, if the Request: assist device is used, or to install a gag on the valve not being tested.

Also, the timing requirement of within 6 months before initial criticality provides potential scheduling issues. If the 6 months expires just before initial criticality, the plant would be in a hot, pressurized condition, and would have to be cooled down and depressurized to replace the valves. Tying testing to the fuel load milestone is favorable because potential delays that push the fuel 1

ND-19-0060 Enclosure Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -

Alternative Requirements for Preservice Testing of Class 1 Safety Valves load date outside of the proposed 3 month test requirement, the plant conditions would be in a cold and depressurized condition, and the valves could be removed and replaced without having to put a thermal cycle on the plant, and the associated time delays of cooling down/depressurizing and subsequent return to normal operating temperature and pressure.

Per discussions with the Appendix I Sub-Group, the purpose of this requirement is to ensure the plant is started up with safety valves with recently verified setpoints, and to ensure that valves do not go an excessive time prior to retesting, if initial startup is prolonged. Additionally, they believe that tha I-7210, was not meant to preclude the use of pretested valves.

es. T use of pretested valves is The us allowed per I-1320 in-lieu of inn place testing te for f routine inservice testing.

AF Proposed Alternative:

ve:

Class 1 Safety Valves alves shall be replace repl replaced with Pretested valves. The pressure T

set-pressure test of the valves shall not be more than 3 months prior to the commencement ssure mmencement of Initial Fuel sure verification test.

F loading. The initial testing per I-1320, shall be no longer than 24 months from date of the set-DR Proposed Alternative and Basis for Use:

Basis s for Use:

proposed alternative provides an equivalent level of safety as it The propo ensures the beginning th safety valves setpoints will be verified recently prior to eginni of the fuel loading and subsequent initial startup activities, and that inservice valve testing is not extended past the normal frequency, even if the startup process prior to Initial Generation of Electricity by nuclear heat is prolonged. This alternative provides the additional benefit of improving personnel safety by not having personnel in a heat stress environment to perform in-place testing.

Since the proposed alternative is consistent with inservice testing requirements for replacing with pretested valves in accordance with I-1320(b) and the frequency of the first inservice test limits the amount of time between set-pressure verification test, this proposed alternative provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).

2

ND-19-0060 Enclosure Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -

Alternative Requirements for Preservice Testing of Class 1 Safety Valves Duration of Proposed Preservice testing conducted prior to commercial operation.

Alternative:

References:

None.

Status: Awaiting NRC authorization T

AF DR 3