ML20058J967
| ML20058J967 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/02/1986 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20058A334 | List: |
| References | |
| NUDOCS 8605150201 | |
| Download: ML20058J967 (3) | |
Text
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MEMORANDUM FOR: Danis 1 R; Muller, Lirector BWR Project Directorate No. 2 Division of BWR Licensing FROM:
Gus C. Lainas, ' Assistant Director.
for BWR bivision of BWR Licensing'
SUBJECT:
TECHNICAL POSITION REGARDING GEORGIA POWERS REQUEST-l FOR TEMP 0RARY RELIEF 0F NRC INTERPRETATION REGARDING l
SYSTEM PRESSURE TESTING
. i By "05000321/LER-1986-015, :on 860331,isolation of RHR Reactor Shutdown Cooling Suction Inboard Primary Containment Isolation Valve [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Occurred.Caused by Inadequate Procedure.Procedure 57SV-SUV-007-1S Will Be Revised|letter dated April 30, 1986]], Georgia Power Corporation requested temporary relief from the possible NRC interpretation of_ Note 5 (of-IWB-2500-1 of ASME Code Section XI) prohibiting the withdrawal of control
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Pods prior to'the system pressure testing. The licensee was in effect requesting a temporary waiver of compliance with the staff position >that" was provided_by memorandum dated April-29, 1986;_from R. Bernero to A.-
Gibson. : The position was that system pressure test (leakage and -
hydrostatic) are to be performed _before the reactor goes critical in' order to'aset the ASME Code-and regulations.: Georgia Power has-conducted these system pressure tests utilizing nuclear heating for several years using an interpretation that the plant startup is " rolling the turbine."
q The staff reiterates its position that the. testing _is to be performed as-described in our April 29, 1986 memorandum to achieve Code compliance.- We recognize, however, that this position was'not; transmitted'to the licensee
.until April 29,19C6. - We feel the testing proposed by the licensee can 1
be performed on a one-time basis without undue risk to the health andJ safety of the public. In part, our decision is predicated on past staff,
practice _which may have permitted such testing on-a case basis and on' the assurance from the licensee that they will promptly pursue an-0 official interpretation from'the ASME Boiler and Pressure Vessel Code Committee regarding tha efficacy of their position.. Further,-the licen:ee stated'that the plant did not have procedures to.perforu the testing'in a manner commensurate with our saterpretation since system pressure testing has been done for many years-using nuclear heating.
Therefore, based on the licensee's statement that'a hardship would be encountered inSerforming-the testing properly in a timely and perhaps, prudent manner, we do not feel this one time exception in testir.q is of sufficient ' safety significance to warrant the delay of four (4) to seven (7)-days in plant start-up postulated by the'Ticensee.
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Lsl Gus C. Lainas,' Assistant Director j
for BWR Division of BWR Licensing cc: see next page
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'for Hatch Unit 1 on a one time basis to perforr the required pressure test using nuclear heat as it has been doing for.a number of years. This was~.
b implemented by Region ll's exercising enforcement discretion as 'Biscussed 'in a conference call with Region-ll, NRR and GPC personnel on May 1, 1986.
Sincerely, Ce 4f A
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Daniel R. Muller, Director BWR Project Directorate *2-Divison of BWR Licensing Enciesure:
As Stated 3
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W April 10. 1987 Docket Nos. 50.321/366 1
Mr. James P. O'Reilly Senior Vice President - Nuclear Operations Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302
Dear Mr. O'Reilly:
By letter to Georgia Power Company (GPC) dated February 10. 1987, we-j reaffirmed the NRC staff position as -stated in our May-5,1986 letter that ASME Boiler and Pressure Vessel Code,Section XI system hydrostatic and system leakage pressure tests on the Hatch reactor primary coolant <
system must be performed prior to pulling control rods. GPC. by letter dated March 13,1987, expressed. disagreement with the staff position..
requested that we reconsider this position and requested an appeal meeting to discuss the issue.
The appeal meeting was held in the NRC's offices in Bethesda on April 1.1987.
At the meeting, the NRC staff discussed the bases for its position and GPC representatives' discussed the bases for GPC's' disagreement-with the staff position and for GPC's view that it should be allowed.to perform these Section A system hydrostatic and system leakage pressure tests at the Hatch plan after pulling control rods and using nuclear power to heatup and pressur.ze the primary coolant system. GPC stated that it had performed these pressure tests with the reactors critical since the initial startup of both Hatch units. GPC explained that prior to entering the i
drywell to check for leakage, during these pressure tests it carefully -
i plans and rehearses the role of each member of:the inspection team. Each-manoer of the team is assigned to look for leakage at.certain. locations on the primary coolant system.. The team then enters the drywell wearing protective clothing as necessary for the environmental condition at-assigned inspection. locations. - This preplanning minimizes the amount of time required for the team members to be inside the containment..
During the meeting, the staff requested that GPC provide information concerning the cost impact and additional visual inspection capability-that would result from performing the pressure tests with the reactor non-critical..GPC provided this infonnation by letter dated April 6,1987.
We have considered'this information together with the appeal meeting"
' discussion and all of the previous. correspondence on this issue. We are concerned that, while it may be possible to perform adequate pressure EMW!%W$M
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.. c tests with the reactor critical-at about 5' percent power, at temperatures well above the minimum required system temperatures and with the drywell I
buttoned up (i.e., as GPC described its test conditions), such drywell '
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environmental conditions.are not conducive to a thorough and deliberate l
visual inspection.
We believe that a more deliberate visuti inspection and one posing less potential danger to the inspecto.s can-better be i
performed in the cooler and less hazardous environment associated with.
reactor coolant system temperatures fesar the miniENm required test temperature.
This is, in our view, more consistent with the-intant of completing a satisfactor, boundary pressure test before resuming operations.
We have therefore concluded that the Section XI system hydrostatic and '
system leakage pressure tests for Hatch Units 1 and 2 are to be perfonned with the reactor non-critical as stated in our May 5,1986 position..
We appreciate your effort in providing your views and in quickly responding ~
to our request for information sc that we could resolve tMs issue.
Sincerely, Orig!nal signed by James H. Sniezek dames H. Sniezek, Deputy Director Office of Nuclear Reactor Regulation l
cc: See next page l
DISTRIBUTIDN Docket File JPartlow NRC PDR NThompson I
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Mr. J. P. O'Reilly Edwin 1. Hatch Nuclear Plant,-
Gecrgia Power Company Units Nos. I and 2 l
1 cc:
Bruce W. Chruchill, Esquire Shaw, Pittman. Potts & Trowbridge 2300 N Street, N.W.
Washington,- D.C.
20037-Mr. L. T. Gwcwa Engineering Departmut Georgia Power Company Post Office Box 4545 Atlanta, Georgia 30302; Nuclear Safety and Compliance Manager F.dwin 1. Hatch Nuclear Plant Georgia Power Company Post Office Box 442 Bexley, Georgia 31513 Mr. Louis B. Long
{
L Southern Company Services, Inc.
Post Office Box 2625 Birmingham, Alabama 35202 Resident inspector U.S. Nuclear C.gulatory Comission.
Route 1, Post Office Box 279 l
Baxley, Georgia 31513 Regional Administrator, Region II U.S. Nuclear Regulatory Commission, 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 Mr. Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, S.W.
Atlanta, Georgia 30334-
. Mr. J. Leonard Ledbetter, Comissioner Department of Natural Resources 270 Washington Street, N.W.
Atlanta, Georgia 30334 Chairman 1
Appling County Comissioners County Courthouse Baxley,' Georgia 31513 1
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NUCLEAR UTILITY aACKFITTING AND REFORM oROUP SW8?t400
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L April 25, 1988 I
U.S. Nuclear Regulatory Commission
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l Washington, D.C.
'20555-Attention:
Dr. Theman r. Muriev Res. Backfitting Clain Regarding Systen Pressure Testing Under ARMT cada Emetiers YT Dear Mr. Murley and Reform Group (*NURARG");gon behalf of the seabers ot clain pursuant to 10 C.F.R. 5 50.109wa hereby submit a backfitting-o j
interpretation of system pressure testing requirements under A regarding a new NRC Str.ff -
t 1/ For. purposes of this backfitting. claim, NURARG is comprise the following power reactor licensees Arkansas Power & 1.ight Company, Baltimore Gas 4 ElectricAlabam Company, Cleveland Electric Illuminating Company, Edison Company, Consolidated Edison Ccspany of New' Commonweal Detfo W Edison Company, Duke Power Compan Tork, Inc.,
Light Company Company, lan, Florida Power Corporation,y, Florida Power &-
L Georgia Power Corporation,g Esland.1.ighti'ig company, Niagara Mohawk. Power
'C6apany, PennsylvantsNwer'4'1iNortheast Utilities, Northern state
. ght cosp hy;~ Philadelphia' Electric company, Portland General Electric Company, Kochest{
Gas & Electric = Corporation, Southern California Edison
-Company, Texas Utilities Electric Company Toledo Edison Company, Washington Public Power supply sy, stem, and Yankee ~
Atomic Electric Company (representing also Public service
)
company of New Naapshire, New Naapshire Yankee Division, Ma Yankee-Atomic Power Company,'end Vermont Nuclear Power Corporation).
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l 2-Code,Section XI.
This claim is based on a changed position with, respect to_the acceptability of nuclea,s,tafft r h'ydrostatic and leakage tes. ting, h, the use of nuclear power to heat up andWssiurTse the: reactor coolant system.
This position has not been identified by the Staff as a backfit, despite the fact that this testing method has been used for a number of years and'the staff's position involves a new interpretation of pertinent regulations.
NUBARG respectfully submits that the Staff
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constitutes a.backfit under 10 C.F.R. I 50.10s.gosition.
The' Staff-should identify the position as a backfit and proceed with'the preparation of.a backfitting analysis complying with section 50.109 before Amposing its new interpretation-upon licensees.
2.
BACKCROUND section XI of the ASME Soiler and pressure vessel Code-establishes criteria for performing system pressure tests of-the reactor coolant system.
Relevant portions of sectia:
-l been incorporated by reference into_1Q.F.R. I 80.55tas part of; LEI have the NRCis*1aservice inspection program.
.,.i possure tests l
are of4:wo-kinds:91) leaka~gCtests, which are designed to identify any abnormal leakage from the. reactor coolant pressure j
boundary; and:(2) hydrostatic tests, which examine repairs en the reactor coolant pressure. boundary or related' components.
examination method required for leakage. tests is a visual The-inspection (Type VT-2).
be used'in lieu of the systen leakage test.Section XI permits' hydrostati Section XI.provides tha't 'the systen leakage-test s
shall be conducted prior to plant startup following eac(h reactor 2WB-5221) outage."3 J
should be critical during the testing.The Code does not addre With regard to the that "[rpressurising medium, section XI, Division 1, 2WB-5210(b), states-1 medium."jaactor coolant.shall be used as the pressurising L.
2/ While several seabers of NURARG are affected by the new staff position, not all NUSARG seabers utilise the nuclear pressure testing method.
However, because the Staff position does affect several members, a-joint'backfitting clain such as this is appropriate in-that it will allow a common resolution of s
the issue, and in any event, because all members have an i
important interest in seeing the backfitting rule implemented properly.
j 2/ section XI, Article TWB-5000 (System pressure Tests), Table 2Wa-2500-1 (los0 ed.).
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For a number of. years the statf har allowed leakage and hydrostatic tests using nuclear heat,- La, pulling control rods L
and'using nuclear power to heat up-and pressurite the primary i
coolant. system, as opposed to using heat generated by pumps in i
i the reactor coolant systea 'or' auxiliary systems.
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The staff has recognised that 'there is ain afforded" by the two methods.jaal difference in the safety I
and leakage testing was done with the reactor critical,. it wasWhile done at low power prigr to placing the= plant in service-following the refueling outage.
signitioant+y%the commission's regulations in 10.C.F.R.-
Part 50, App. G. clearly contemplate that the core may'he critical l
during hydrostatic and leakage testing.
Section IV.A.5 of Appendix G states as follows (emphasis added):
If there is fuel in the-reactor during systen hydrostatic pressure tests or leak tests, the requirements of paragraphs 2 or-3 of this section apply, demandine en whether the eere is critical durins the tent,"
Y
, code section XI requires-that hydrostatic-and leakage l conducted with the reactor in a noncritical strt ests be-e.
This position was referred to in a staff letter of April a
l 10, 3987 denying a technical appeal by one licensee on this issue.
The April AO, rather than backfitting-implicationst it concluded that I
of the environmental conditions (higher temperatures and'the plant at low power work, nuclear press)ure testing was'*not conducive to a and deliberate visual inspection."-
y.Esa tatter from D.R. Muller, NRC, ta 3.T.-Beckham, Georgia j
Power co., dated May 5, 19es, j
1/ Testing with the reactor critica) results in-higher. system.
temperatures than>are possible with the use of pump heat.
elevated systaa temperatures are particularly advantageous in The that pressure testing can be performed in a region where-brittle fracture-is not a consideration
)
y Paragraph 2 defines acceptable temperature limits when the p
t' core is not critical, and p
when the core is critical'. paragraph :2 defines these limits for M
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' '/2/ Intter from 3.2. Eniesek, NRC to 3.p. O'Reilly, Georgia Power company, dated April 10,.1987.
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The April 10, 1987 interpretation ofJoction XI set forth in a letter tletter made licensee dated May 5, 1986.
o the nuclear heat "for a number ofhad " permitted" the' license I
arrival of the staff position. years
- and recognised the alatas'using
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an internal 'NRC Staff memorandua dead April 29Tbg Staff position wag
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'Section X2 (Table fMS-2500-1, Note 5) that 1986.
i on of
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'#'3 systen leakage test.
startup FOT oUlfg eaf.h.ienctr.. shal1~ be' conducted. prior to plant--
- the i
4..u %,.,#*is placed in2)'took the~ view that plant startuor,,gnage." : The memora a
g o t,t [be performel,'startup/ hot standby'p r occurs when the mode switch begun."
Thus iand control rod withdrawal is 6
accord before cr}MS..teL3he memorandum,_ pressure. testing iticality is achieved.=
page 1)- also noted that the ASME Code specified that reac this to-require a watcoolant is to be used as the pressu noncondensible gases)er-solid test (h, an absence of steam and e
pressure testing.
which would effectively preclude-nuclear II.
ctg 31 Zag Under the Commission's backfitting rule. 10 C F R position interpreting the Commission rules'
... I S0.109, i
different from a previously; applicable staff positj a
The backfitting rule took effect October new or on...."
21, 1985 position was firstesting constitutes a backfit as 1 *'.
ressure sentioned above. t set forth in the:May 5,1986 corresp.109.
on 50 That In that letter had paraitted the licensee to per, form nucle ondence the-Staff noted that the Staff P.
In particular ssure testing
.was new.
licensee could continu, the 8thff,;1n concluding that theaff position the following reasons,e such testing on a one time' basis, cited L
anony others:
(1) *the past history of F y Memorandum from R.M. Bernero to A.F. Gibson 1986.
dated April 29, y NUBARG understands that the MRC is-continuing:to policy and procedures of Section 50.109 and Manual c 0514 until the new backfitting rule is finalis d i e
to the decision in Unten af cenearned scienti e ' n response F.2d 108 (D.C. - Cir.1987).
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-s-s this activity where the staff has permitted -(the licensee) to f !,,
L perform these tests using nuclear heat" -(2) *the late arrival of the staff position"4 13) the staff's
- conclusion that there is 0
\\'8' f ", minimal difference in the safety afforded by the testing--as 7 erformed by [the-licensee) using nuclear heat versus testing in accordance with the staff position on the code requirements r and a
(4) the Staff's ' desire to censider new information_ that may have a bearing on this recent staff position ~....*
Thus, the staff itself has recogr.f ted that its position is
- new or different" from the previous. 3911 cable position permitting nuclear pressv.re testing, ine position should l
,',. c therefore be identified as a backfit.
l i
The use of nuclear pressure testing has n' firm basis in the I
commission's regulations.
As noted above, section IV.A.5 of 10 C.F.R. Part 50, App.
G., expressly recognises that there any be situations:in which *the more is critica1'during the test."
The-Staff's recent interpretation, therefore, not only represents a new position, but actually conflicts with the plain language-of Appendix G.
Furthermore, the use of nuclear pressure testing is consistent with section XI of the ASME code.
On at.least two occasions the ASME Boiler and Pressure vessel committee has issued written' interpretations of code requirements'in this ares.
By letter dated February 11, 1987, the ASME committee responded to an inquiry as to whether section.X1 requires the reactor to be in a noncrit leak tests. gal state during pressure tests (hydrestatic and during pres)sure testing is not addressed by section XI, D 1."-
2n an earlier response,-dated September 18.1986 the ASME committee-agreed that the Code permits the.use a,s a-pr,essurizing medium of "& airture of steam, water, and non-condensible gases in a proportion y greater than that present-during normal j
startup....*12 This was consistent with an earlier interpretation, and indicater testing is not prohibited by ta.. Code.lhat-the use of nuclear power for L
i l
L 19/ 1stter from S. Wiensan, ASME to L.T. Sucwa, Georgia power l
1 company, dated February 11, 1987.
11/- Letter from S. Weinman, ASME to L.T. Sucwa, Georgia Power i
~ company, dated September 18, 1986.
12/ Interpretation XI-1-83-25,- dated October 27,1983.
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testing for a number of years, that the regulat e
testing with the core critical, and that the AsME has 1Eters t d e
the code-not to preclude such testing, it is clear that the st ff ee-position constitutes a backfit within the meaning of section 50.109.
a a backfit and should not be imposed until a backfittinA i
has been performed in accordance with section 30.109. g analysis NURARG appreciates the Staff's consideration of this clain pump heat.to conduct pressure tasts may ad the duration'of refueling outages and may not be a viable optio for all plants.
s The staff podhlon.may eventuall t
significant plant modifications and would result require replacement power costs.
On the other hand n substantial between the past practice and the staff's new pos 4, AEREA.-
See note An additional problem feoed by all roastor types is the inability to control ooolant temperature during testing with heat..
i pressure testing during a normal startup does not present pump
^
the same probles.
In addition, other testing requirements, such as those described in Generic 14tter 84-11 (which contemplates inspections for intergranular stress corrosion cracking in stainless steel piping in boiling water reactors), are performed l
during reactor critical conditions.
i be happy to discuss than with you.should you have any q Sincero y, i
4 Nichol f s.
synolds L
counsel to clear Utility 3 kiitting and' Reform Group cc:
Victor stallo Executive Director for Operations i
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