ML20217N981

Safety Evaluation for Third 10-year Pump & Valve Inservice Testing Program,Southern Nuclear Operating Co,Inc,Hatch, Units 1 & 2

ML20217N981
Person / Time
Site:	Hatch
Issue date:	08/21/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217N964	List: ML20217N959 ML20217N981
References
NUDOCS 9708260400
Download: ML20217N981 (4)

Text

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p* M00 y 4 UNITES STATES

• I ]' NUCLEAR REGULATORY COMMISSION J WASHINGTON, D.C. 30446-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR THE THIRD 10-YEAR Pi)MP AND VALVE INSERVICE TESTING PROGRAM SOUTHERN NUCLEAR OPERATING COMPANY. INC.

HATCH. UNITS 1 AND 2 QQQ(ET NOS. 50 321 AND 50 366

1.0 INTRODUCTION

Title 10 of the Code of Federal Reaulations (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 are performed in accordance with ASME OM Code 1990 Edition, except where relief has been requested and granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a(f)(6)(i), (a)(3)(i), or (a)(3)(ii). In order to obtain authorization or relief, the licensee must demonstrate that: (1) conformance is impractical for its facility; (2) the proposed attemative providas an acceptable level of

- quality and safety; or (3) compliance would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Section 50.55a(f)(4)(iv) provides that inservice tests of pumps and valves may meet the

, requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to Commission approval. NRC guidance contained in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," provided attematives to the Code requirements determined to be acceptable to the staff and authorized the use of the alte matives in Positions 1,2,6,7,9, and 10 provided the licensee follows the guidance delineated in the applicable posi'. ion. When an attemative is proposerl that is in accordance with GL 89-04 guidance and is documented in the inservice testing (IST) program, no further evaluation is required; however, implementation of the attemative is subject to NRC inspection.

In a letter dated September 15,1995, Georgia Power Company (GPC), licensee for the Edwin 1. Hatch Nuclear Power Plant, Units 1 and 2, submitted its Third 10 Year Interval IST Program for Pumps and Valves. The licensee's submittal included several proposed relief requests, deferred test justifications, and other sections of the licensee's IST program developed according to the requirements of the ASME OM Code 1990 Edition for pump and valve testing, with the exception of safety relief valves. Safety relief valve testing was written to the reouirements of the ASME OM Code 1995 Edition in its sub*nittal, the licensee stated that the reactor core isolation system (RCIC) is not required to be included in the IST program but that testing would be performed as close as practical to ASME OM Code test requirements.

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2-By letter dated April 12,1996, the NRC transmitted a Safety Evaluation (SE) that provided the staffs review of the licensee's IST program, in addition to addressing other IST issues, the staff stated its disagreement with the licensee's information pertaining to the exclusion of the RCIC system from the IST program. In a letter dated June 4,1996, GPC addressed the several SE ltems including the staffs disagreement with the licensee's plans regarding testing of th6 RCIC system. The staff discusses its review of the RCIC system with respect to the IST program below.

2.0 LICENSEE'S POSITION ON RCIC SYSTEM in a submittal dated September 15,1995, the licensee provided its position on the applicability of the RCIC system to the IST program at Hatch in severallocations. In the scope discuss!on in Section 3.0," Inservice Testing of Pumps," the licensee states that no credit is taken in any of the accident analyses for the RCIC system and, therefore, the RCIC pumps have been included in the IST program only to provide a readily accessible, documented method of testing. The licensee further stated that the RCIC pump testing will be performed in a manner similar to the OM Code testing and should adequately detect  !

degradation. In the scope discussion in Section 8.0, " Inservice Testing of Valves," the licensee stated that the RCIC valves that do not perform a containment isolation function are still considered to be important and thus require a certain level of testing and have, therefore, been included in the IST program. The licensee further stated that this RCIC valve testing will be performed in a manner similar to the OM Code testing and should adequately detect degradation. The licensee also stated that the testing of these valves is included in the IST program only to provide a readily accessible, documented method of testing. The licensee also repeated this position on the RCIC system in Valve Notes applicable to the RCIC system, in the SE attached to the letter dated April 12,1996, the staff indicated its disagreement with the licensee's position on the applicability of the RCIC system to the IST program at Hatch.

For example, the staff noted that Table 3.21 of the Hatch Final Safety Analysis Report (FSAR) listed RCIC pumps and most of the valves in the RCIC system as Quality Group Classification B, which corresponds to ASME Class 2. Further, the staff noted that the RCIC valves identified in Table 3.21 as " isolation and within" are listed as Quality Group Classification A, which corresponds to ASME Class 1. These ASME classes are within the scope of the IST program as defined in 10 CFR 50.55a. The staff notes that the plant Technical Specifications (TS) at Hatch require the RCIC systern to be operable or that the plant be shut down if not restored to operable status within 14 days. The staff concluded that the RCIC system was within the licensing basis of Hatch and specific components have a required safety function to bring the reactor to the cold shutdown condition as specified in scope statements of ASME OM Code 1990 Edition. The staff stated that tho RCIC pumps and applicable system valves should be included within the scope of the licensee's IST program and that the licensee should revise the IST program os appropriate and begin testing the applicable components in accordance with Code requirements.

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l 3-In its letter dated June 4,1996, the licensee stated that, after extensive review of the Hatch ,

Unit 1 and 2 design-basis records, it had determined that the RCIC system (other than the containment isolation function) should not be included in the IST program established by the scope statements of the ASME OM Code, subsection ISTB or ISTC,1990 Edition. The licensee stated that the RCIC system is not required to bring the reactor to the cold shutdown condition, maintain the cold shutdown condition, or mitigate the consequences of an accident.

The licensee noted that the RCIC system design requirements ensure the criteria of 10 CFR Part '50, Appendix A, General Design Criterion 33, are satisfied. The licensee also acknowledged that the system is utilized in the Appendix R Safe Shutdown analyses, Station Blackout analyses, and the Emergency Operating Procedures (EOPs). The licensee stated that the FSAR, TS, System Evaluation Document, and General Electric SAFER /GESTR -

LOCA analysis indicate no credit for RCIC is taken in the evaluation of any design basis accident.

The licensee noted in TS Bases B3.5.3 that the RCIC system is included in the TS because of its contribution to the reduction in overall plant risk and because of this importance to safety, the licentee reiterated its position that it has included the RCIC system in "an augmented testing program within the IST program." The licensee also clarified how its augmented testing of the RCIC system will ensure that components necessary for RCIC operation are tested in a manner similar to that required by the ASME Code (i.e., scope, frequency, method, acceptance criteria, and data retention).

3.0 g. VALUATION The staff has recognized the importance of the RCIC system to the overall safe operation of Boiling Water Reactor (BWR) plants. For example, plant TS include requirements for the operabfty of the RCIC system. Further, in NRC Bulletin 85-03, " Motor-Operated Valve Common Mode Failures During Plant Trarsients due to improper Settings," the NRC staff requested that licenseos ensure that motor-operated valves (MOVs) in certain high pressure systems (including RCIC systems for BWR plants) that are required to be tested for operational readiness in accordance with 10 CFR 50.55a(g) are set and maintained properly.

The staff considered the expansion of the scope of Bulletin 85-03 to all safety related systems in GL 8910, " Safety Related Motor-Operated Valve Testing and Surveillance," to encompass the RCIC system for BWR plants. The staff provided recommendations for long-term MOV programs in GL 96-05, " Periodic Verification of Design Basis Capability of Safety.

Related Motor-Operated Valves."

, The licensee recognized the importance of the proper performance of the RCIC system in its reference to the design requirements of 10 CFR Part 50, Appendix A, General Design Criterion 33. The licensee also acknowledged that the system is assumed available in the Appendix R Safe Shutdown analyses, Station Blackout analyses, and the Hatch EOPs. The licensee did not indicate any disagreement with the classification of certain RCIC system valves in FSAR tables as Quality Group Class A or B.

With respect to the GL 8910 program at Hatch, the licensee requested, in a Program Reevaluation|letter dated February 3,1994]], NRC staff review of a revised scope ofits GL 8910 program including revisions of the assumed safety functions for certain RCIC system valves. For example, the licensee proposed to delete the assumed active safety function to close RCIC injection Valve

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E51-F013, but to retain the active safety function to open because this normally closed valve must open to allow RCIC injection. In a letter dated October 16,1995, the staff agreed with the licensee's plan to retain the open safety function for E51 F013 and the licensee's proposal to delete the close safety function (pending licensee review of any containment isolation function). In a letter dated October 21,1996, the licensee stated that in response to its review of the staffs evaluation all addressed MOVs (including the RCIC valves) were added to the scope of the GL 8910 program, in a letter dated March 17,1997, the licensee stated that the scope of its long term MOV program in response to GL 96-05 will be the same as its GL 8910 program.

4.0 CONCLUSION

The staff recognizes that some plants do not rely on the RCIC systems in their design basis accident analyses and, therefore, the RCIC system might not be encompassed by the specific scope of the IST program. However, the staff considers the proper performance of the RCIC system to be important for the overall safe operation of BWR nuclear power plants as evidenced by plant TS, licensee commitments in response to the Maintenance Rule and Station Blackout concems, and NRC generic regulatory guidance. Where a licensee does not include its RCIC system within the scope of the IST program, the licensee v.ill be expected to demonstrate by some acceptable equivalent means that this system is, and will continue to be, capable of performing its intended function consistent with licensing commitments, such as associated with the Maintenance Rule, Station Blackout concems, GL 8910, and GL 96-05.

Based on the above evaluation, the staff finds the removal of the RCIC system from the IST program to be acceptable on the basis that the licensee will maintain the RCIC system in an

" augmented program" for testing and in the GL 89-10 and GL 96-05 programs at Hatch, Units 1 and 2. The licensee is expected to revise its FSAR to reflect the revision of the classification of its RCIC system.

Principal Contributors: J. Colaccino T. Scarbrough G. Golub Date: August 21, 1997