NL-05-0726, Fourth 10-Year Interval IST Program Update

Fourth 10-Year Interval IST Program Update

ML051150256
Person / Time
Site:	Hatch
Issue date:	04/20/2005
From:	Sumner H Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-05-0726
Download: ML051150256 (12)

Text

H.L Sumner, Jr. Southern Nuclear Vice President Operating Company, Inc.

Hatch Project Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7279 SOUTHERN N.

April 20, 2005 COMPANY Energy to Serve Your Worldl Docket Nos.: 50-321 NL-05-0726 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Fourth 10-Year Interval IST Program Update Ladies and Gentlemen:

Southern Nuclear Operating Company (SNC) is in the process of updating the Edwin 1.

Hatch Nuclear Plant (HNP) Unit I and 2 Inservice Testing (IST) Program in accordance with the requirements of 10 CFR 50.55a paragraphs (f)(4) and (f)(4)(ii). The present IST interval began on January 1, 1996, and ends on December 31, 2005. The purpose of this letter is to submit one relief request for early NRC review and document SNC's schedule for implementing the updated IST Program requirements.

Issue I The ASME OM Code 2001 Edition through 2003 Addenda includes requirements for additional pump testing as defined in subarticles ISTB-5123, ISTB-5223 and ISTB-5323 (i.e., Comprehensive Pump Testing (CPT)). The purpose for addition of the CPT in the Code was to ensure that each pump in the IST scope was tested at a flowrate adequate for determination of operational readiness and for monitoring degradation. Previous editions/addenda of the ASME Section XI and OM Codes did not require pump IST at substantial flow rates and allowed for testing at low flow conditions.

HNP is a BWR-4 and initial plant design included full flow test loops for all safety related pumps. As a result, every pump in the IST program is currently tested at or near design flow rate on a quarterly frequency. Therefore, SNC does not believe that the CPT requirements of subarticle ISTB-5123, 5223 and 5323 will provide any added safety benefit.

Pursuant to 10 CFR 50.55a(3)(i), SNC hereby requests NRC approval of the attached relief request RR-P-l for the 4 th IST Interval. SNC is confident that conformance with the attached alternative will provide an acceptable level of quality and safety. Therefore, RR-P-1 is warranted per 10 CFR 50.55a(3)(i).

Based upon the significance of this relief request and its potential impact on the updated IST Program, SNC requests approval by September 30, 2005.

U. S. Nuclear Regulatory Commission NL-05-0726 Page 2 Issue 2 SNC intends to use the guidance included in NUREG-1482, Revision 1,paragraph 3.3.3 for implementation of the updated IST Program. Using this guidance, SNC will phase in implementation of the updated IST Program according to the following schedule.

• The updated IST Program will be submitted to the NRC staff for review and approval no later than July 1, 2005.

• SNC will begin implementation of the updated IST Program on January 1, 2006 using a phased-in approach. Existing IST surveillances will be continued during the phase-in period until all surveillance procedures are in place to implement the updated program requirements.

• All surveillance procedures will be revised and implementation will be in complete compliance with the updated IST Program by December 31, 2006.

The existing IST Program (3rd Interval) utilized the 1990 Edition with 1990 Addenda with the exception of the 1995 Edition with 1995 Addenda for safety and relief valve IST. Per IOCFR50.55a(b)(3), the ASME OM Code 2001 Edition through 2003 Addenda is applicable for the HNP IST Program 4th Interval update. The IST Program update will not require any significant changes in scope or in actual testing techniques. However, the revision of approximately one hundred surveillance procedures is required to account for changes in administrative provisions as a minimum. Therefore, the proposed phased-in implementation, beginning on January 1, 2006, with completion by December 31, 2006, maintains the overall integrity of the HNP IST Program.

Since phased-in implementation is discussed in NUREG-1482, Revision 1, Section 3.3.3, SNC does not believe that relief or an exemption is required. SNC plans to follow the schedule as outlined above and as described in the second paragraph of "NRC Recommendations" in NUREG-1482, Revision 1, Section 3.3.3. Should the NRC Staff not agree with this implementation plan, SNC requests notification by July 1,2005 due to the significant work load associated with revising approximately one-hundred surveillance procedures prior to January 1, 2006.

This letter contains no NRC commitments. If you have any questions, please advise.

Sincerely, H. L. Sumner, Jr.

HLS/ifl/daj

Enclosure:

Relief Request RR-P-I

U. S. Nuclear Regulatory Commission NL-05-0726 Page 3 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. G. R. Frederick, General Manager- Plant Hatch RTYPE: CHAO2.004 U. S. Nuclear Regulatorv Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Hatch Mr. D. S. Simpkins, Senior Resident Inspector- Hatch

SOUTHERN NUCLEAR OPERATING COMPANY IST PROGRAM - RELIEF REQUEST PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

RR-P-1, Version 1.0 PLANT/UNIT: Edwin I Hatch Nuclear Plant (HNP)/Unit 1 and 2 INTERVAL: 4 th Interval (January 1, 2006 through December 31, 2015)

REQUEST DATE: September 30, 2005 COMPONENTS All pumps in the IST Program AFFECTED:

CODE EDITION ASME OM Code-2001 Edition with Addenda through OMb-2003 AND ADDENDA:

REQUIREMENTS: Tables ISTB-3400-1, ISTB-3500-1, ISTB-5100-1, ISTB-5200-1, ISTB-5300-1, ISTB-5300-2 and Subarticles ISTB-5123, 5223 and 5323 provide requirements for frequency, instrumentation and acceptance criteria for the Comprehensive Pump Test (CPT).

REASON FOR The CPT required by the ASME OM Code 2001 Edition through OMb REQUEST: 2003 Addenda does not provide any meaningful benefit for a nuclear power plant whose original design provided for the testing of all safety related pumps at or near design or accident required flow rates. System design at HNP included full flow test capability for all safety related pumps. Therefore, all pumps are currently tested equivalent to that for Group A pumps on a quarterly frequency per the referenced OM Code.

The attached Table 1 provides information relative to the design, accident and IST flowrate for each pump in the IST Program. This table confirms that all pumps within the IST scope are currently tested within 8% of design flowrate, which exceeds the later OM Code requirement for testing within +/- 20% of design flowrate at least once every two years.

The CPT imposes more stringent instrument accuracy requirements for measuring pressure, i.e., 0.5% versus 2% for the Group A test. All pumps in question are provided with static head suction sources (i.e., storage tanks, the suppression pool or the river). Therefore, there is no real benefit in using 0.5% accuracy gages versus 2% accuracy gages when considering the drastic difference in gage ranges for suction pressure and discharge pressure (see Pump Table 2 for details).

All permanently installed pressure instrumentation used for IST meets the +/- 2% accuracy requirement and was designed to meet the system's operating environment in which it was installed. Gages which meet a +

0.5% accuracy are typically much more sensitive to environmental and systems operating conditions and thus are unsuitable for permanent installation. Therefore, special test instruments would need to be installed for the CPT. Installation and removal of such instruments would not provide any meaningful benefit over that achieved by permanent system instrumentation and the additional man-power burden seems unwarranted.

SOUTHERN NUCLEAR OPERATING COMPANY IST PROGRAM - RELIEF REQUEST PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

RR-P-1, Version 1.0 No pumps at HNP are provided with direct indicating AP instruments and AP is determined by the difference in inlet (suction) and outlet (discharge) pressure. Therefore, use of + 0.5% accuracy suction pressure gages is of no benefit since all pumps in the IST program take suction from either a natural source (river), the suppression pool where level is controlled within a 6" band to meet Technical Specification requirements or the pumps are positive displacement type (see Attached Table 2). Use of +/- 0.5% accuracy discharge pressure instruments provides only minimal benefit considering the discharge pressures shown in Table 2 and the fact that all previous IST has been performed at or near accident required flowrates.

The CPT imposes more stringent acceptance criteria for flow and differential pressure as outlined below.

TYPE PUMP GROUP A GROUP B CPT CENTRIFUGAL 0.90- 1.10 Qr 0.90- 1.10 Qr 0.94- 1.03 Qr 0.90- 1.10 APr 0.90- 1.10 APr 0.93 - 1.03 APr VERTICAL LINE 0.95- 1.10 Qr 0.90 - 1.10 Qr 0.95- 1.03 Qr SHAFT 0.95- 1.10 APr 0.95 - 1.10 APr 0.95 - 1.03 APr POSITIVE 0.95- 1.10 Qr 0.90 - 1.10 Qr 0.95 - 1.03 Qr DISPLACEMENT 0.93 - 1.10 APr 0.90- 1.10 APr 0.93-1.03 APr However, since all pumps at HNP can be tested at or near design flow quarterly, the need for more stringent acceptance criteria is not warranted to ensure that operational readiness is maintained or for monitoring degradation.

Initial implementation of the CPT at HNP could be confusing for responsible personnel. If the existing reference values are utilized, then several pumps could be in the Alert Range for the first test. However, these pumps have been monitored for extended periods of time under the previous IST Program requirements and have been determined to be operating acceptably. For those plants where full flow testing is not practical during normal operation, initial implementation will allow establishment of new reference values for the CPT, even though the pumps are already in some state of degradation. Therefore, it is an unfair burden for plants that have been testing at or near design flow conditions for an extended time period.

Therefore, full flow testing equivalent to that required for Group A pumps on a quarterly frequency provides adequate assurance that the pump is capable of performing its required safety function and ensures that degradation that would render the pump inoperable does not go undetected.

PROPOSED All pumps in the IST Program will be tested as Group A pumps on a ALTERNATIVE quarterly frequency even though the majority are Group B or Standby AND BASIS: Pumps (see Pump Table 1).

SOUTHERN NUCLEAR OPERATING COMPANY IST PROGRAM - RELIEF REQUEST PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

RR-P-1, Vcrsion 1.0 Group A testing requires quarterly vibration monitoring which provides valuable information relative to the mechanical condition of the pump.

Monitoring and trending vibration data quarterly helps ensure continued operational readiness by providing information relative to the mechanical condition of the pump in lieu of monitoring only the hydraulic condition.

Group B (Standby Pump) testing requires only monitoring either flow or differential pressure quarterly and vibration monitoring only during the CPT. Quarterly Group A testing provides additional information to assess both hydraulic and mechanical operational readiness and allows for establishment of a more comprehensive preventative maintenance program.

Pressure instrumentation, that meets the accuracy requirements for the Group A test, provides adequate accuracy for assessing the hydraulic performance and condition of each pump. The subject pumps all have relatively low pressure suction sources when compared to discharge pressure, and the use of +/- 0.5% accuracy gages versus +/- 2% accuracy gages does not provide measurable benefit for assessing hydraulic performance or monitoring degradation. Additional information relative to suction and discharge pressure is contained in Table 2.

The OM Code allows for establishment of a new set of reference values when the first CPT is performed. However, HNP proposes to utilize the existing reference values and continue the current testing methodology, which is equivalent to Group A testing, for the 4h IST Interval. This methodology has already established the mechanical and hydraulic condition of each pump based upon the previous time at which reference values were established. Continuing to measure both hydraulic and mechanical parameters on a quarterly frequency and assessing operational readiness and continued degradation based on previous reference values provides an acceptable level of quality and safety for each pump in the IST Program.

IST during the 3rd Interval, using instrumentation equivalent to that of a Group A test (i.e., +/- 2% accuracy - OM Code 2001 Edition and 2003 Addenda) at design or near design flow rates has shown to be sufficiently accurate, repeatable and adequate for assessing operational readiness and timely detection of degradation. Therefore, SNC proposes that this alternative provides an acceptable level of quality and safety and should be granted pursuant to 10 CFR 50.55a(3)(i).

DURATION: 4h IST Interval PRECEDENTS: NA

REFERENCES:

NA STATUS: Submitted for NRC review.

I i RR-P-1 PUMP TABLE 1 - UNIT 1 MPL No./OM DESIGN DATA ACCIDENT DATA REFERENCE IST Qr REMARKS Code Group IC41-COOIA 43 gpm at 1190 psig 41.2 gpm at 21232 (1) HNP-2 FSAR 44 gpm Quarterly IST performed at 2 Accident Group B psig Table 15.4-1 required flow rate.

(2) Tech Spec SR 3.1.7.7 IC41-COOIB Same as 1C41-COOlA Same as IC41-COOlA Same as lC41-COOIA 43.1 gpm Same as IC41-COOIA Group B lEI l-COOIA 4000 gpm at 955-ft Ž 4000 gpm (1) HNP-1 FSAR 4000 gpm Quarterly IST performed at Accident Group B TDH Table 10.6-1 required flow rate.

(2) Tech Spec Bases 3.7.1 IEI1-COO1B Same as IE lI-COOIA Same as lElI -COOIA Same as lEll-COOlA 4000 gpm Same as IEl l-COOIA Group B lEl 1-COOIC Same as IEI 1-COOlA Same as lEI l-COOIA Same as lEl l-COOIA 4000 gpm Same as IEl l-COOIA Group B IEII-COOlD Same as lElI -COOIA Same as IEl l-COOIA Same as IE1 l-COOIA 4000 gpm Same as lEl I-COOIA Group B lEl l-C002A 7700 gpm at 420-ft (1) 6900 gpm (1) HNP-2 FSAR 7700 gpm Quarterly IST performed at 2 Group B TDH (2) Ž17000 gpm for 2 Table 6.2-3 individual pump Accident required pumps with RPV 2 20 (2) Tech Spec 3.5.1.7 flow rate plus Refueling Outage IST at psig a 2-pump/train flow rate of 2 17,000 gpm at AP 2 158 psid.

IEl l-C002B Same as lEl I-C002A Same as IEl l-C002A Same as IEI1-C002A 7700 gpm Same as lEl l-C002A Group B lEl l-C002C Same as lEl l-C002A Same as lEl1-C002A Same as lEl I-C002A 7700 gpm Same as IEl l-C002A Group B IEl l-COO2D Same as IEI1-C002A Same as lEl1-C002A Same as lEI I-C002A 7700 gpm Same as lEl I-CO02A Group B Page 4 of 9

RR-P-1 PUMP TABLE 1 - UNIT 1 IE21-COOIA 4700 gpm at 670-ft (1) 4625 gpm (1) HNP-2 FSAR 4250 gpm Quarterly IST performed at 92% of Group B TDH (2) 2 4250 gpm at Table 6.2-3 FSAR Accident Flow Rate.

RPV 2113 psig (2) Tech Spec 3.5.1.7 1E21-COOIB Same as IE21-COOIA Same as IE21-COOIA Same as IE21-COOIA 4250 gpm Same as lE21-COOIA Group B 1E41-COOl 4250 gpm at 2140-ft (1) 4250 gpm (1) HNP-2 FSAR 4250 gpm Quarterly IST performed at Accident Group B TDH (2) 4250 gpm, with Table 6.2-3 Required Flow Rate.

RPV 2 920 psig and (2) Tech Spec SR

<1058 psig 3.5.1.8 IP41-COOIA 8500 gpm Only I pump at > HNP-1 FSAR 10.7.5 6100 gpm Quarterly IST performed at 2 Accident Group A 4428 gpm is required and HNP-2 FSAR Required Flow Rate.

Table 9.2-1 1P41-COOlB Same as lP41-COOIA Same as IP41-COOIA Same as lP41-COOIA 6100 gpm Same as lP41-COOlA Group A IP41-COOIC Same as lP41-COOIA Same as IP41-COOIA Same as IP41-COOIA 6300 gpm Same as lP41-COOIA Group A II I IP41-COOID Same as lP41-COOIA Same as IP41-COOIA Same as lP41-COOIA 6250 gpm Same as IP41-COOIA Group A I Page 5 of 9

RR-P-1 PUMP TABLE 1 - UNIT 2 MPL No. DESIGN DATA ACCIDENT DATA REFERENCE 1IST Qr REMARKS 2C41-COOIA 43 gpm at 1190 psig 41.2 gpm at 21232 (1) HNP-2 FSAR 44.6 Quarterly IST performed at 2 Accident Group B psig Table 15.4-1 required flow rate.

(2) Tech Spec SR 3.1.7.7 2C41-COOIB Same as 2C41-COOIA Same as 2C41-COOlA Same as 2C41-COO1A 43.1 Same as 2C41-COOlA Group B 2E1 l-COOlA 4000 gpm at 955-ft 2 4000 gpm (1) HNP-1 FSAR 4000 Quarterly IST performed at Accident Group B TDH Table 10.6-1 required flow rate.

(2) Tech Spec Bases 3.7.1 2ElI-COOlB Same as 2El l-COOlA Same as 2El l-COOlA Same as 2E1 1-COOIA 4000 Same as 2El l-COOIA

- Group B 2El l-COOIC Same as 2El l-COOlA Same as 2El l-COOIA Same as 2E1 l-COOlA 4000 Same as 2El l-COOlA Group B 2E1 l-COOID Same as 2E1 l-COOlA Same as 2E1 l-COOlA Same as 2E1 l-COOlA 4000 Same as 2El l-COOlA Group B 2El l-C002A 7700 gpm at 420-ft (1) 6900 gpm (1) HNP-2 FSAR 7700 Quarterly IST performed at 2 Group B TDH (2) 217000 gpm for 2 Table 6.2-3 individual pump Accident required pumps with RPV Ž 20 (2) Tech Spec 3.5.1.7 flowv rate plus Refueling Outage IST at psig a 2-pump/train flow rate of 2 17,000 gpm at AP 2 158 psid.

2El l-C002B Same as 2E1 l-C002A Same as 2E1 I-CO02A Same as 2E1 I-C002A 7800 Same as 2E1 1-CO02A Group B 2E3 l-C002C Same as 2El l-C002A Same as 2E13 1-C002A Same as 2131 1-C002A 7700 Same as 2E1 l-CO02A Group B 2E1 l-COO2D Same as 2E1 l-C002A Same as 2131 l-C002A Same as 2E1 l-CO02A 7700 Same as 2131 l-CO02A Group B I Page 6 of 9

RR-P-1 PUMP TABLE 1 - UNIT 2 2E21-COOIA 4700 gpm at 670-ft (1) 4625 gpm (1) HNP-2 FSAR 4250 Quarterly IST performed at 92% of Group B TDH (2) 2 4250 gpm at Table 6.2-3 FSAR Accident Flow Rate.

RPV Ž113 psig (2) Tech Spec 3.5.1.7 2E21-COOIB Same as 2E21-COOIA Same as 2E21-COOIA Same as 2E21-COOIA 4250 Same as 2E21-COOlA Group B 2E41-COO1 4250 gpm at 2140-ft (1) 4250 gpm (1) HNP-2 FSAR 4250 Quarterly IST performed at Accident Group B TDH (2) 4250 gpm with Table 6.2-3 Required Flow Rate.

RPV Ž 920 psig and (2) Tech Spec SR

<__1058 psig 3.5.1.8 2P41-COOIA 8500 gpm Only I pump at > HNP-1 FSAR 10.7.5 6100 Quarterly IST performned at 2 Accident Group A 4428 gpm is required and HNP-2 FSAR Required Flow Rate.

Table 9.2-1 2P41-COOIB Same as lP41-COO1A Same as lP41-COOIA Same as lP41-COOIA 6200 Same as lP41-COOIA Group A 2P41-COOIC Same as lP41-CO01A Same as lP41-COO1A Same as lP41-COOIA 6250 Same as lP41-COOlA Group A 2P41-COOID Same as lP41-COOIA Same as IP41-COOIA Same as lP41-COO1A 6200 Same as lP41-COOlA Group A 2P41-C002 700 gpm at 231.5-ft NA - No Design HNP-2 FSAR Table 707 Quarterly IST performed at 2 Accident Group A TDH Accident Flowrate 9.2-1 Required Flow Rate.

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RR-P-1 TABLE 2 MPL No. SUCTION REFERENCE REFERENCE REMARKS SOURCE SUCTION DISCHARGE PRESSURE PRESSURE 1C41-COOIA Storage Tank N/A 1240 Positive Displacement Pump which results in harsh operating conditions for 0.5% test gages.

IC41-COOIB Storage Tank N/A 1260 Positive Displacement Pump which results in harsh operating conditions for 0.5% test gages.

IE II-COOIA River APr =400.8 380 Suction pressure is actually suction lift, therefore APr is shown.

1E1I-COOIB"' River APr= 387 365 Same as 1ElI-COOIA.

1E1I-COOIC(') River APr= 391.5 369 Same as lElI-COOlA.

IEII-COOIDI" River APr = 409 390 Same as lElI-COOIA.

IEI I-CO02A Suppression Pool APr = 166 171 Suppression Pool level is maintained within a 6" band per Technical Specification requirements. As a result, suction pressure varies by < 0.25 psig and therefore APr is shown.

IEII -CO02B Suppression Pool APr = 175 180 Same as lEII-CO02A.

IEII-CO02C Suppression Pool APr = 176 181 Same as IEI1-C002A.

IE1I-CO02D Suppression Pool APr = 180 185 Same as IEI1-CO02A.

lE21-COOIA Suppression Pool APr = 277.6 282.6 Suppression Pool level is maintained within a 6" band per Technical Specification requirements. As a result, suction pressure varies by < 0.25 psig and therefore APr is shown.

IE21-COOIB Suppression Pool APr= 268 273 Same as IE21-COOIA.

IE41-COOI Storage Tank 32.2 1247 Initial water source is Condensate Storage tank with a swap to the Suppression Pool for long term injection.

IP41-COOI A River APr = 145.8 124 Suction pressure is actually suction lift, therefore APr is shown.

IP41-COOIB River APr= 141.9 121 Same as IP41-COOIA.

1P41-COOIC(') River APr 140 118 Same as IP41-COOIA.

IP41-COOID('1 River APr= 142.5 122 Same as IP41-COOIA.

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RR-P-1 TABLE 2  ;

MPL No. SUCTION REFERENCE REFERENCE REMARKS SOURCE SUCTION DISCHARGE PRESSURE PRESSURE 2C41-COOIA Storage Tank N/A 1250 Positive Displacement Pump which results in harsh operating conditions for 0.5% test gages.

2C41-COOIB Storage Tank N/A 1240 Positive Displacement Pump which results in harsh operating conditions for 0.5% test gages.

2E1 I-COOIA ' River APr= 391.6 370 Suction pressure is actually suction lift, therefore APr is shown.

2E1I-COOIB ' River APr = 401.4 380 Same as 2E1 I-COOlA.

2E1 1-COOlIC( River APr= 407.3 388 Same as 2E1 I-COOlA.

2E1 I-COOlD ' River APr = 400.7 380 Same as 2E1 I-COOlA.

2E 1I-C0O2A } Suppression Pool APr= 184.6 189.6 Suppression Pool level is maintained within a 6" band per Technical Specification requirements. As a result, suction pressure varies by < 0.25 psig and therefore APr is shown.

2E1 I-C0O2B ' Suppression Pool APr = 180 185 Same as 2E1 l-CO02A.

2E11-C0O2C ' Suppression Pool APr = 184.9 189.9 Same as 2E11-CO02A.

2E1 I-COO2D l Suppression Pool APr = 175 180 Same as 2E lI-CO02A.

2E21-COOIA Suppression Pool APr= 327.3 332.3 Suppression Pool level is maintained within a 6" band per Technical Specification requirements. As a result, suction pressure varies by < 0.25 psig and therefore APr is shown.

2E21-COOIB Suppression Pool APr= 330 335 Same as 2E21-COOIA.

2E41-COOI Storage Tank 26.4 1175 Initial water source is Condensate Storage tank with a swap to the Suppression Pool for long term injection.

2P41-COO1I A River APr= 139.4 121 Suction pressure is actually suction lift, therefore APr is shown.

2P41-COOIB"' River APr= 141.7 121 Same as 2P41-COOlA.

2P41-COOlC ' River APr= 142.3 122 Same as 2P41-COOlA.

2P41-COO1I D River APr= 144.8 125 Same as 2P41-COO1A.

2P41-C002 ") River APr = 108.8 88 Suction pressure is actually suction lift, therefore APr is shown.

Notes;

1. Vertical line shaft pump.

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