View source for ND-18-1401, Request for Alternative: Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01)

{{Adams
| number = ML18333A356
| issue date = 11/29/2018
| title = Request for Alternative: Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01)
| author name = Whitley B
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRO
| docket = 05200025, 05200026
| license number = 
| contact person = 
| case reference number = ND-18-1401, VEGP 3&amp;4-PST-Alt-01
| document type = Inservice/Preservice Inspection and Test Report, Letter type:ND
| page count = 8
}}

=Text=
{{#Wiki_filter:B. H. Whitley              Southern Nuclear Director            Operating Company, Inc.
Regulatory Affairs  3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 November 29, 2018 Docket Nos.: 52-025                                                                     ND-18-1401 52-026                                                              10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for Alternative:
Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01)
Ladies and Gentlemen:
Pursuant to 10 CFR 50.55a(z)(1), Southern Nuclear Operating Company (SNC) hereby requests NRC authorization to use an alternative to the requirements of the ASME OM Code, 2012 Edition (Code of Record) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. The proposed request for alternative is applicable to testing of charges associated with explosively actuated valves.
The details of the 10 CFR 50.55a(z)(1) request are contained in the Enclosure to this letter.
Approval is requested by May 30, 2019 to support preservice testing of the squib valves charges scheduled for June 2019.
SNC facilitated a presubmittal meeting on November 15, 2018 with the NRC staff on the proposed Code alternative.
This letter contains no regulatory commitments. This letter has been reviewed and confirmed to contain no security-related information. Should you have any questions, please contact Mr. Corey Thomas at (205) 992-5221.

U.S. Nuclear Regulatory Commission ND-18-1401 Page 2 of 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th of November 2018.
Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company

==Enclosure:==
Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Ait-01)

U.S. Nuclear Regulatory Commission ND-18-1401 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 Mr. E. Riffle Ms. K. Roberts 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-18-1401 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 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-18-1401 Enclosure Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01)
(This Enclosure consists of 4 pages, including this cover page)

ND-18-1401 Enclosure Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01)
Vogtle Electric Generating Plant (VEGP) - Units 3 and 4 Plant Site-Unit:
Interval-Interval Applies to the preservice testing period.
Dates:
Requested Date for       Authorization is requested by May 30, 2019.
Approval:
ASME Code Components       ASME Class 1 and 3 Explosively Actuated Valves.
Affected:
Applicable Code Edition     ASME OM Code, 2012 Edition (Code of Record).
and Addenda:
ASME OM Code, ISTC-3100(d)(2) requires that for post-2000 plants, Category D explosively actuated valves shall be preservice tested as follows:
Applicable      Select a sample of at least 20% of the pyrotechnic charges in all valves Code         to be tested. Test each selected charge either in the valve, or a qualified Requirements:     test fixture to confirm the capability of each sampled charge to provide the necessary motive force to operate the valve to perform its intended function without damage to the valve body or connected piping. The sampling must include at least one explosively actuated valve from each redundant safety train.
Based on the ASME OM Code definition of preservice test, which states test performed after completion of construction activities Reason for      related to the component, and the statement in ISTC-3100(d)(2)
Request:       that Pyrotechnic charges in all valves, it is implied that the charges must be installed in the valves, and the valves be installed in the system, prior to selection of the charges for testing. Handling of explosive charges exposes personnel to significant risks. Since the charges are fabricated and shipped separately, and the testing will be 2 of 4

ND-18-1401 Enclosure Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01) done by the vendor or another offsite test facility, the current requirements would involve shipping of the charges to the site, installation of the charges in the valves (which would be installed in the piping, in containment), removal of the charges, and shipment of the charges back to the vendor or other test facility.
To minimize handling and transportation of explosive charges, it is proposed to select the charges after fabrication and retain for testing at the vendor, or in the worst case, ship them from the vendor to a separate facility for testing.
Proposed Alternative:
In lieu of the requirements of ISTC-3100(d)(2), perform the following:
Select a sample of pyrotechnic charges, following fabrication for testing; this may include charges used for qualification of the batch. The sample shall include a quantity of charges equal to at least 20% of the number of charges of each size installed in the plant and shall include at least one from each manufacturer batch. A description of SNCs planned testing relative to the Code requirements is shown in Table 1 below. Each selected charge shall be tested in a qualified test fixture to confirm the capability of each sampled charge to provide the necessary motive force to operate the valve to perform its intended function without damage to the valve body or connected piping.
Proposed Alternative and Basis for Use:
Basis for Use:
The proposed alternative provides an equivalent level of safety as it ensures the charges are tested to the same criteria, and that the charges are tested from each batch (manufacturer, lot and size). The allowance of crediting the qualification samples is equivalent to or better than ISTC-5260(d), which only requires test firing of one charge per batch prior to installation as a replacement charge.
The requirement regarding inclusion of one test sample from each train is not applicable, because the charges are selected for testing prior to installation in the valve. However, the selection of charges for installation in valves of each train is random; therefore, the level of testing is equivalent.
3 of 4

ND-18-1401 Enclosure Alternative Requirements for Preservice Testing of Explosively Actuated Valves (VEGP 3&4-PST-Alt-01)
The proposed alternative provides improved personnel safety by minimizing the transportation and handling of explosive charges.
Because the proposed alternative tests an equivalent number of pyrotechnic charges to the same criteria, this proposed alternative provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).
Duration of Proposed         Preservice testing conducted prior to commercial operation.
Alternative:

==References:==
None.
Status:         Awaiting NRC authorization Table 1: Vogtle 3&4 Planned Explosively Actuated Valve Charge Testing per Purchase Specification Number in plants (number Charge         per unit x        IST         IST      Number to      Number Batch          size            units)       (20%)      (1/train)   be Tested    Fabricated A        14 valves         8 (4 x 2)        2           4            8            16 B        8 valves -       12 (6 x 2)        3           6            8            20 high C        8 valves -        4 (2 x 2)        1           2            8            12 low Notes:
: 1. Each charge size is a single batch
: 2. There are two sizes of charges for the 8 explosively actuated valves, high energy and low energy 4 of 4}}