NL-17-1646, Snubber Program Plan for the Fourth Ten Year Inservice Testing Interval
| ML17277A658 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/04/2017 |
| From: | Hutto J Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-17-1646 | |
| Download: ML17277A658 (7) | |
Text
~ Southern Nuclear OCT 0 4 2017 Docket Nos.: 50-424 50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 J. J. Hutto Regulatory Affairs Director Vogtle Electric Generating Plant-Units 1 and 2 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5872 tel 205 992 7601 fax jjhutto@ southernco.com NL-17-1646 Snubber Program Plan for the Fourth Ten Year lnservice Testing Interval Ladies and Gentlemen:
In accordance with American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), Subparagraph ISTA-3200(a),
Southern Nuclear is submitting for your information a copy of the Vogtle Electric Generating Plant Snubber Program.
This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.
Respectfully submitted, J. J. Hutto Regulatory Affairs Director jjh/kgl/cg
Enclosure:
Vogtle Electric Generating Plant Fourth Interval Snubber Program cc: Regional Administrator, Region II NRR Project Manager-Vogtle 1 & 2 Senior Resident Inspector-Vogtle 1 & 2 RType: CVC7000
Southern Nuclear Operating Company Vogtle Electric Generating Plant - Units 1 and 2 Snubber Program Plan for the Fourth Ten-Year lnservice Testing Interval ENCLOSURE Vogtle Electric Generating Plant Fourth Interval Snubber Program
Vogtle Electric Generating Plant 41h Interval Snubber Program INTRODUCTION Vogtle Electric Generating Plant is a pressurized water reactor that has been operating for over 25 years.
Commercial operation for Unit 1 and Unit 2 began in May 1987 and May 1989, respectively. Each unit currently produces 1,215 megawatts of electricity.
10 CFR 50.55a, "Codes and Standards," incorporates by reference which ASME Codes govern snubbers. Paragraph 50.55a(b)(3)(v)(B) requires the use of ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Subsection ISTD in lieu of ASME Code Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b), to govern inservice examination and testing of dynamic restraints (snubbers) at nuclear power plants, for plants using the 2006 Edition of Section XI, or later.
Vogtle Electric Generating Plant Units 1 and 2 (VEGP-1/2) chose to adopt the OM Code, Subsection ISTD, for its snubber program, beginning with the Vogtle 2R13 refueling outage. The initial Snubber Program document was prepared in accordance with the requirements of ASME OM Code, 2001 Edition through 2003 Addenda as endorsed in the version of 10 CFR 50.55a issued October 1, 2004. Utilizing this edition of the OM Code aligns the snubber program with the 1ST pumps and valves program.
For the fourth 1 0-year interval, this program will be updated concurrently with the lnservice Inspection (lSI) and lnservice Testing (1ST) updates. This meets 10 CFR 50.55a requirements for program updates to the latest edition and addenda of the Code that it has endorsed 12 months before the start of the plant's next 120 month interval. The third 10-Year interval for VEGP-1/2 snubbers will end on May 31, 2017. At that time, VEGP-1/2 Snubber Program will adhere to OM Code 2004 Edition, through 2006 Addenda.
The adoption of the OM Code for the snubber program does not affect VEGP-1/2's inspection and testing interval. The following table provides current and previous 10-Year Interval dates.
VEGP Unit 1 VEGP Unit 2 1st 1 0-year Interval 05/31/1987 to 05/30/1997 05/20/1989 to 05/30/1997*
2nd 1 0-year Interval 05/31/1997 to 05/30/2007 05/31/1997* to 05/30/2007 3rd 1 0-year Interval 05/31/2007 to 05/30/2017 05/31/2007 to 05/30/2017 4th 1 0-year Interval 05/31/2017 to 05/30/2027 05/31/2017 to 05/30/2027
- VEGP-2 was updated at the same time as VEGP-1 for the 2nd 10-Year Interval in order to utilize the same Code Edition for both units. Permission to establish concurrent intervals for VEGP-1 and 2 was requested via relief request RR-G-2 and granted by Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER) dated August 27, 1997.
OM Code subsection ISTA - 1100 requires the scope of the snubber program to include any snubbers having one or more of the functions listed below:
Shutting down the reactor to the safe shutdown condition Maintaining the reactor's safe shutdown condition Mitigating the consequences of an accident Ensuring the integrity of the reactor coolant pressure boundary VEGP 41h Interval Snubber Program Page 1 of 5 Version 1.0
Vogtle Electric Generating Plant 4th Interval Snubber Program The amount of snubbers at VEGP-1/2 within the scope of ISTA is listed below:
UNIT 1 I Accessible l Inaccessible I Total Grand Total I
68 I
235 I
303 UNIT2 J Accessible _I Inaccessible I Total Grand Total I
94 I
239 L
333 PSA and Anchor Darling snubbers are mechanical snubbers.
Lisega, ANVIL, and Paul-Munroe snubbers are hydraulic snubbers.
Per ISTA-3200(a), this program shall be filed with the NRC.
Detailed information for each snubber is contained within SnubbWorks, a data management program that is part of the software package lddeal Concept, Inc.
Roles, responsibilities, a site-specific procedures' list, and implementation instructions for the VEGP-1/2 snubber program are found in NMP-ES-057 and associated instructions.
TEST PLAN
- 1.
Relationship with Licensing Documents No conflicts between ASME OM Code requirements and the requirements of VEGP-1/2 Technical Specifications have been identified. As part of the process for adopting the ASME OM Code, the VEGP-1/2 Technical Requirements Manual 13.7.2 was reviewed and revised accordingly (LDCR 2008037).
- 2.
Quality Assurance Subsection ISTA of the Operation and Maintenance Code provides General Requirements.
These requirements shall be applied to snubber program activities.
The 10 CFR Part 50, Appendix B Quality Assurance Program applicable to VEGP-1/2 will be used in conjunction with the OM Code requirements.
- 3.
VEGP-1/2 Safety Class Piping VEGP-1/2 safety class piping, with the exception of turbine piping, was designed to ASME Code Section Ill Class 1, 2, and 3 requirements. Turbine piping was designed to ANSI 831.1.
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- 4.
VEGP-1/2 Snubber Classification At VEGP-1/2, snubbers falling under the scope of ISTA-1100 are classified as either safety related or safety significant. These are snubbers required to shut down/maintain shut down of a reactor, and mitigate consequences of an accident.
Safety related snubbers are attached directly to ASME Class 1, 2 or 3 piping. The Class 1, 2, or 3 safety-related scope is defined by plant piping and instrumentation diagrams (P&IDs); they are listed in the plant's lnservice Inspection (lSI) Plan.
Safety significant snubbers are snubbers needed to ensure the integrity of the reactor coolant pressure boundary.
These snubbers are located on non-class systems whose failure could jeopardize class 1, 2, or 3 piping; specifically, non-safety piping that is between the safety class valve and the first anchor point. This piping is considered safety-significant because it must be structurally sound in case of a design basis event, so that the safety-class piping is not affected.
As allowed by ISTD-4220(a), each unit's snubbers are divided into inaccessible and accessible.
Inaccessible is defined as any snubber located inside the containment building. Accessible is defined as any snubber located outside the containment building.
As allowed by ISTD-5252, VEGP-1/2's snubbers are also classified by manufacturer.
The lists in NMP-ES-057-001 also identify each snubber by piping support number (mark number); the snubber type, hydraulic (H) or mechanical (M) and model; classification regarding accessibility for examination during power operation; safety-related classification; and system classification.
- 5.
Snubber Visual Examination All snubbers at VEGP-1/2 falling under the scope of ISTA -
1100 are subjected to the requirements of ISTD - 4000, "EXAMINATION REQUIREMENTS." The snubbers installed in VEGP-1/2 that fall under the jurisdiction of ISTD - 4000 are listed in NMP-ES-057-001. Per ISTD-311 0, the visual examination must be pin-to-pin (include everything between the snubber pin attachments). In accordance with ISTD - 4200, periodic inservice visual examinations shall be performed on all snubbers in scope. The initial and subsequent frequency of 100% visual examination is determined by OM Code Table ISTD-4252-1. VEGP-1/2 adopted code case OMN-13, "Requirements for Extending Snubber lnservice Visual Examination Interval at LWR Power Plants", Revision 0, approved by Regulatory Guide 1.192, which requires 100% visual examination of Snubbers governed by OM Code within 1 0 years of the last completed 100%
visual exam. The next planned 100% visual exam shall be before conclusion of refueling outage 1 R25 for Unit 1, and 2R23 for Unit 2. The examination of snubbers will be performed by qualified examiners using VT-3 examination methods.
The visual examination frequency of non-safety related, non-safety significant snubbers is discussed in Section 8.
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- 6.
Snubber Functional (Operational Readiness) Testing All snubbers at VEGP-1/2 falling under the scope of ISTA -
1100 are subjected to the requirements of ISTD-5000, "SPECIFIC TESTING REQUIREMENTS."
In accordance with ISTD -
5100, new snubbers shall have been subjected to a preservice functional test before installation. Testing may be performed at the manufacturer's facility.
In accordance with ISTD - 5200, periodic inservice functional testing shall be performed on all snubber populations in the scope of 1ST A.
The snubbers installed in VEGP-1/2 that fall under the jurisdiction of ISTD - 5000 are listed in NMP-ES-057-001. The Defined Test Plan Groups (DTPG) are listed below:
DTPGI Pacific Scientific (PSA) Models PSA-1/4,- 1/2 DTPG II Pacific Scientific (PSA) Models PSA-1, -3,-10 DTPG Ill Pacific Scientific (PSA) Models PSA-35, -100 DTPGIV Anchor Darling Models AD-40, -70,-150,-500 DTPGV Anchor Darling Models AD-1600, -5500, -12500 DTPG VI Paul-Munroe PM-25701 DTPG VII Lisega Each refueling outage a 10% initial sample of each DTPG will be tested in accordance with ISTD-5261 (a). The initial sample plan will be selected in accordance with ISTD-5311. In the event any unacceptable snubbers are found, additional snubbers will be selected for testing during the same refueling cycle to meet the requirements of ISTD-5320.
The frequency of functionally testing non-safety related, non-safety significant snubbers is discussed in Section 8.
- 7.
Service Life and Snubber Seal Replacement Program A snubber service life program in accordance with ISTD-6000, "SERVICE LIFE MONITORING" was established for VEGP-1/2. This service life program includes the requirements of the snubber seal replacement program required by ISTD. The specifics of the program are recorded in corporate and site procedures.
- 8.
VEGP-1/2 Non-Safety Related. Non-Safety Significant Snubbers NMP-ES-057-001 VEGP-1/2 Snubber Lists contain non-safety related, non-safety significant snubbers (snubbers that are not covered under the TRM 13.7.2 scope). As a good engineering practice, each unit's non-safety related, non-safety significant snubbers will be visually examined on the same frequency as the 100% visual examination of the subsection ISTA-11 00 scope snubbers. Functional testing of non-safety related, non-safety significant snubbers may occur at the program owner's discretion. This practice began with 1 R16 for Unit 1 and 2R15 for Unit 2.
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- 9.
Plant Transient When notified of a potentially damaging transient event, an inspection shall be performed of all snubbers attached to affected systems. The visual inspection of the system(s) shall be completed as described in NMP-ES-038-004.
In addition to satisfying the visual inspection acceptance criteria, freedom-of-motion of mechanical snubbers shall be verified using at least one of the following:
Manually induced snubber movement Stroking the mechanical snubber through its full range of travel Evaluation of in-place snubber piston setting The examination, including the freedom-of-motion verification, may be performed in accordance with procedures NMP-ES-024-203, 28311-C, or 85052-C. Results shall be included with the engineering evaluation.
- 10.
Commitments The following commitments are currently active for VEGP-1/2 Snubber Program:
SNC3392 (2002360944)
SNC16753 (2009300008)
SNC16960 (2009300009)
SNC16754 (200930001 0)
SNC 16755 (2009300011)
SNC16756 (2009300012)
SNC16961 (2009300013)
SNC16757 (2009300014)
SNC13843 SNC16961 SNC312559 SNC565 SNC7100 VEGP 41h Interval Snubber Program Page 5 of 5 Version 1.0