ND-18-1332, Preliminary Amendment Request (Par): Power Operated Relief Valve (PORV) Noise Mitigation (PAR-18-021)
| ML18292A750 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/19/2018 |
| From: | Whitley B Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| ND-18-1332, PAR-18-021 | |
| Download: ML18292A750 (8) | |
Text
B. H. Whitley Southern Nuclear Director Operating Company, Inc.
Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 October 19, 2018 Docket No.:
52-025 ND-18-1332 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 Preliminary Amendment Request (PAR):
Power Operated Relief Valve (PORV) Noise Mitigation (PAR-18-021)
Ladies and Gentlemen:
The U.S. Nuclear Regulatory Commission (NRC) issued the Vogtle Electric Generating Plant (VEGP) Unit 3 combined license (COL) (License No. NPF-91) to Southern Nuclear Operating Company (SNC) on February 10, 2012.
SNC submitted a License Amendment Request (LAR)-18-021 on August 10, 2018, by SNC letter ND-18-1037 [ADAMS Accession Number ML18222A599]. To address feedback provided by NRC Staff during the August 30, 2018 public call [ML18243A492], SNC submitted a revision to the LAR, LAR-18-021R1 [ML18284A447]. The LAR proposes to depart from plant-specific DCD Tier 2 information in UFSAR Figure 10.3.2-1 (Sheets 1 and 2) and Tables 3.9-16, 6.2.3-1, and 10.3.3-1 by relocating the power operated relief valve (PORV) branch lines upstream of the branch lines to the main steam safety valves and changing the PORV block valves from gate valves to globe valves. The requested amendment also involves related changes to plant-specific Tier 1 Figure 2.2.4-1 (Sheets 1 and 2), with corresponding changes to the associated COL Appendix C information.
SNC has determined that Unit 3 construction activities involving installation of the steam generator system (SGS) piping and valves in Rooms 12404 and 12406 of the auxiliary building beginning January 17, 2019 are impacted by this LAR. The determination of whether the NRC has any objection to SNC proceeding with installation of the subject Unit 3 SGS piping is requested on or before December 3, 2018. Delayed determination regarding this PAR could result in the delay of the completion of construction, testing and turnover of the SGS piping in the east main steam isolation valve cubicle of VEGP Unit 3.
A description of the proposed change and the reason for the change are contained in the Enclosure to this letter. This PAR has been developed in accordance with guidance provided in the most recent revision to the Interim Staff Guidance on Changes during Construction Under
U.S. Nuclear Regulatory Commission ND-18-1332 Page 2 of 4 10 CFR Part 52, COL-ISG-25 [ADAMS Accession Number ML15058A377] and corresponds accurately and technically with the above-mentioned LAR-18-021 and its revision, LAR-18-021 R1.
The technical scope of this PAR is consistent with the subject LAR. Section 7 of the Enclosure further identifies and details the scope of the "no objection" finding sought in this PAR.
Upon receipt of a No Objection Letter for PAR-18-021, SNC plans to complete installation of the SGS piping and components in their final locations pursuant to LAR-18-021.
This letter contains no regulatory commitments. This fetter has been reviewed and confirmed to not contain security-related information.
In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this LAR by transmitting a copy of this letter and its enclosures to the designated State Official.
Should you have any questions, please contact Mr. Adam Quarles at (205) 992-7031.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of October 2018.
Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company
Enclosure:
Vogtle Electric Generating Plant (VEGP) Unit 3 - Preliminary Amendment Request:
Power Operated Relief Valve (PORV) Noise Mitigation (PAR-18-021)
U.S. Nuclear Regulatory Commission ND-18-1332 Page 3 of 4 cc:
Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosure)
Mr. D. G. Bost (w/o enclosure)
Mr. M. D. Meier (w/o enclosure)
Mr. D. H. Jones (w/o enclosure)
Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosure)
Mr. T. W. Yelverton (w/o enclosure)
Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Ms. P. Reister Ms. K. Roberts Ms. P. Ridgway Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosure)
Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn
U.S. Nuclear Regulatory Commission ND-18-1332 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosure)
Mr. C. Churchman (w/o enclosure)
Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.
Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light
Southern Nuclear Operating Company ND-18-1332 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 Preliminary Amendment Request:
Power Operated Relief Valve (PORV) Noise Mitigation (PAR-18-021)
(This Enclosure consists of 4 pages, including this cover page.)
ND-18-1332 Enclosure PAR-18-021: Power Operated Relief Valve (PORV) Noise Mitigation Page 2 of 4 Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) to change the Vogtle Electric Generating Plant (VEGP) Units 3 and 4 licensing basis documents associated with Combined License Nos. NPF-91 and NPF-92, respectively.
Installation of the following VEGP Unit 3 and Unit 4 components are subject to the changes proposed in LAR-18-021:
Steam generator system (SGS) piping and valves in Rooms 12404 and 12406 of the Unit 3 auxiliary building Delayed determination regarding this Preliminary Amendment Request (PAR) could result in the delay of the completion of construction, testing and turnover of the SGS piping in the east main steam isolation valve cubicle of VEGP Unit 3. Accordingly, SNC requests the determination of whether the NRC has any objection to proceeding with installation of the subject VEGP Unit 3 components identified above, subject to the changes proposed in LAR-18-021:
PAR Request Number:
PAR-18-021 Station Name:
VEGP Unit Number(s):
3 4
PAR Request Date:
October 19, 2018
- 1. NRC PAR Notification Requested Date (see Block 7 for basis): December 3, 2018
- 2. License Amendment Request References (as applicable):
LAR submittal date and SNC Correspondence Number:
A) August 10, 2018 / ND-18-1037 B) Revision 1: October 11, 2018 / ND-18-1277 Expected LAR submittal date:
- 3. Brief Description of Proposed Change:
To reduce noise contribution to the main control room (MCR) from the power operated relief valve (PORV) block valves, the PORV block valve size is proposed to be changed from 6-inch to 12-inch.
The branch line that the PORV block valves are installed in is also proposed to be changed from 6 inches to 12 inches. These changes reduce the flow velocity to less than 200 ft/sec and as a result the noise level is reduced. The Technical Specification (TS) Bases B 3.7.10 currently states that this branch line is 6 inches. TS 3.7.10 Actions and Surveillance Requirements are not associated with the size of the branch line. Since the specific size of the branch line is not important to TS 3.7.10, the bases is revised to remove the size of the branch line that the PORV is installed in.
Changes are proposed to the PORV block valves to change the valve type from a gate valve to a globe valve. The new valve incorporates a trim which forces the flow through a tortuous path to control the pressure and velocity, reducing the noise level when compared with a similar pressure drop for other valve designs. This valve design also mitigates the potential for a Helmholtz or standing wave source developing in the valve body or seat. The globe valve is qualified for the same environmental and pressure/temperature conditions. UFSAR Table 3.9-16, Table 10.3.3-1, and Figure 10.3.2-1 (Sheets 1 and 2) are proposed to be revised to change the PORV block valves from gate valves to globe valves.
Due to layout constraints with the proposed changes, the location of the branch line that the PORV block valves are installed in is moved upstream of the main steam safety valves (MSSVs) branch
ND-18-1332 Enclosure PAR-18-021: Power Operated Relief Valve (PORV) Noise Mitigation Page 3 of 4 connections. UFSAR Table 6.2.3-1 is revised to change the pipe length from each containment penetration to valves SGS-PL-V027A and SGS-PL-V027B to 26 feet. COL Appendix C (Plant-specific Tier 1) Figure 2.2.4-1 (Sheets 1 and 2) and UFSAR Figure 10.3.2-1 (Sheets 1 and 2) are revised to show the PORV branch line upstream of the MSSVs.
For this PAR, the scope of the changes requested in LAR-18-021 is limited to the installation of the PORV branch line piping and valves.
- 4. Reason for License Amendment Request:
During testing of the PORVs in operation at another facility, the noise level in the main control room (MCR) was approximately 85 dB(A) and the noise level at the PORVs was approximately 110 dB(A).
The size and geometry of the PORV block valves cause a high flow velocity (~800 ft/sec) and Helmholtz resonance which results in an increase in noise level. Since the PORV block valves are located in rooms adjacent to the MCR, the sound from the PORV block valves is transmitted into the MCR. Changes to the PORV block valves are necessary in order to reduce the noise contribution to the MCR and improve human factors with the PORVs in operation.
The proposed change requires a change to plant-specific Design Control Document (DCD) Tier 2 information in the Updated Final Safety Analysis Report (UFSAR) Figure 10.3.2-1 (Sheets 1 and 2),
which involves a change to combined license (COL) Appendix C ITAAC Figure 2.2.4-1 (Sheets 1 and 2). Therefore, the proposed change requires NRC approval in accordance with 10 CFR 52.98(c).
- 5. Is Exemption Request Required?
Yes No If Yes, Briefly Describe the Reason for the Exemption.
10 CFR 52, Appendix D, Section III.B, requires an applicant or licensee referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certified information in DCD Tier 1. The Tier 1 information for which a plant-specific departure and exemption is being requested includes relocating the power operated relief valve (PORV) branch lines upstream of the branch lines to the main steam safety valves, which involves a change to plant-specific Tier 1 ITAAC Figure 2.2.4-1 (Sheets 1 and 2). Therefore, the proposed change requires a permanent exemption from the provisions of 10 CFR 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, to allow a departure from elements of the certification information in Tier 1 of the generic AP1000 Design Control Document (DCD).
- 6. Identify Applicable Precedents:
N/A
- 7. Impact of Change on Installation and Testing Schedules:
SNCs current requested approval date for this license amendment request is February 5, 2019 (as indicated in ND-18-1277 [ML18284A447]). This date was based on supporting completion of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) activities associated with main steam piping in the auxiliary building.
The PAR no objection determination is requested to support installation of steam generator system (SGS) piping and valves in Rooms 12404 and 12406 of the Unit 3 auxiliary building. This is currently scheduled to begin January 17, 2019 with efforts being made to begin sooner.
- 8. Impact of Change on ITAAC:
The proposed change impacts COL Appendix C (and corresponding Tier 1) ITAAC Figure 2.2.4-1 (Sheets 1 and 2), which forms part of the design description referenced in ITAAC No. 2.2.04.01.
However, there is no immediate impact to completion of ITAAC No. 2.2.04.01 because it is an as-built
ND-18-1332 Enclosure PAR-18-021: Power Operated Relief Valve (PORV) Noise Mitigation Page 4 of 4 ITAAC for which the inspection will be conducted following completion of installation of the affected systems, structures, and components.
- 9. Additional Information:
None