ML11084A004

Safety Evaluation to Use Subsequent Edition of American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance

ML11084A004
Person / Time
Site:	Hatch
Issue date:	03/31/2011
From:	Kulesa G J Plant Licensing Branch II
To:	Ajluni M J Southern Nuclear Operating Co
Boyle, Patrick, NRR/DORL -301-415-3936
References
TAC ME4964, TAC ME4965
Download: ML11084A004 (6)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 March 31, 2011 Mr. M. J. Ajluni Nuclear licensing Director Southern Nuclear Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295, Bin -038 Birmingham, AL 35201-1295 EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, SAFETY EVALUATION TO USE SUBSEQUENT EDITION OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) CODE FOR OPERATION AND MAINTENANCE (TAC NOS. ME4964 AND ME4965)

Dear Mr. Ajluni:

By letter dated October 29, 2010, Southern Nuclear Operating Company, Inc. (SNC, the licensee), submitted a request for approval to use a portion of a later edition of the American Society of Mechanical Engineers (ASME), Gode for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (1ST) program at Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 (Hatch 1 and 2). Specifically, approval was requested to apply the requirements of Mandatory Appendix I, paragraph 1-3410, of the 2004 Edition of the ASME OM Code for testing of Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices. The licensee requested approval for the remainder of the Hatch 1 and 2 fourth 10-year 1ST interval, which began on January 1, 2006, and is scheduled to end on December 31,2015. Based on the review of the information the licensee provided, the U.S. Nuclear Regulatory Commission (NRC) staff concludes that the licensee's request to use a portion of the later edition of the ASME Code can be authorized pursuant to Title 10 of the Gode of Federal Regulations (10 CFR), Part 50, Section 55a(f)(4)(iv), for Hatch 1 and 2, for the licensee's fourth 10-year 1ST interval.

All other ASME Code,Section XI requirements for which the later code edition was not specifically requested and authorized herein by the NRC staff remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

M. Ajluni -If you have any questions, please contact the Project Manager, Patrick Boyle at 301-415-3936.

Sincerely, Gloria Kulesa, Branch Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and Safety cc w/encl: Distribution via UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO USE OF A LATER EDITION OF THE ASME OM CODE FOR INSERVICE TESTING OF CLASS 1 MAIN STEAM PRESSURE RELIEF VALVES WITH AUXILIARY ACTUATING DEVICES FOR THE FOURTH 10-YEAR INTERVAL SOUTHERN NUCLEAR OPERATING COMPANY, INC. EDWIN I. HATCH NUCLEAR PLANT UNIT NOS. 1 AND 2 DOCKET NOS. SO-321 AND SO-366

1.0 INTRODUCTION

By letter dated October 29. 2010 (Agencywide Documents Access and Management Accession No. ML 103090168), Southern Nuclear Operating Company, Inc. (SNC, the submitted a request, NL-10-1021.

for approval to use a portion of a later edition of the Society of Mechanical Engineers (ASME), Code for Operation and Maintenance ofPower Plants (OM Code) for the inservice testing (1ST) program at Edwin I. Hatch Plant, Unit Nos. 1 and 2 (Hatch 1 and 2). The licensee requested to apply the requirements Mandatory Appendix I, paragraph 1-3410 of the 2004 Edition of the ASME OM Code for of Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices in lieu of OM Code 2001 Edition through 2003 Addenda Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR). Part Section SSa(f)(4)(iv), the licensee requested in NL-10-1021.

to use portions of the 2004 of the ASME OM Code subject to the limitations and modifications listed in 10 CFR

2.0 REGULATORY EVALUATION

Section SO.SSa(f). "Inservice testing reqUirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) 1ST program intervals in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations.

In accordance with 10 CFR SO.SSa(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month 1ST program interval.

In accordance with 10 CFR SO.SSa(f)(4)(iv), 1ST 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 Nuclear Regulatory Commission (NRC) approval.

Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. NRC Regulatory Issue Summary (RIS) 2004-12, Enclosure

-"Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI", (ADAMS Accession No. ML042090436) provides guidance for use of later code editions.

3.0 TECHNICAL EVALUATION 3.1 Licensee's Request for Alternative The Hatch 1 and 2 fourth 1 1ST interval began on January 1, 2006, and ends on December 31, 2015. The applicable Code of Record for Hatch 1 and 2 is the ASME OM Code, 2001 Edition through 2003 Addenda. This Code requires, in part, that Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices that have been maintained, refurbished or removed/reinstalled be remotely actuated to verify open and close capability of the valve. The licensee requested approval to use the portion of the 2004 Edition of the ASME OM Code related to disposition after testing or maintenance of Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices. Specifically, the licensee proposes to apply the requirements of Mandatory Appendix I, paragraph 1-3410, which states: (a) Valves and accessories that comply with their respective acceptance criteria for the tests specified may be returned to service without further testing, except as required by 1-3410(d). (b) Valves and accessories that do not comply with their respective acceptance criteria shall be adjusted, refurbished, or replaced, in accordance with written procedures.

Valves shall be adjusted to meet the acceptance criteria of 1310(e). (c) Refurbished equipment shall be subjected to the test(s) specified in 1-3310, as applicable.

If disassembly includes valve disk (main) components, then valve disk stroke capability shall be verified by mechanical examination or tests. (d) Each valve with an auxiliary actuating device that has been removed for maintenance or testing and reinstalled after meeting the requirements of 0, shall have the electrical and pneumatic connections verified either through mechanical/electrical inspection or test prior to the resumption of electric power generation.

Main disc movement and set-pressure verification are not required. (e) Valves and accessories that do not comply with their respective acceptance criteria, whether the problem is associated with the component, the system, or associated equipment, shall be evaluated to determine the ability of the valve to perform its intended function until the next testing interval or maintenance opportunity.

Corrective actions shall be taken, as appropriate, to ensure valve operability.

The licensee proposes to apply these paragraphs to all Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices in the 1ST program at Hatch 1 and 2. The essential difference between the two code editions involves the testing specified in sub-paragraph (d) above for Main Steam Pressure Relief Valves With Auxiliary Actuating Devices after removal and reinstallation following maintenance or testing. Whereas the earlier code required that the

-valves be remotely actuated to verify open and close capability, the newer code allows only an inspection of the valves' electrical and pneumatic connections (Le. main valve disc movement is not necessarily required).

Federal Register (FR), Volume 73, Number 176, dated September 10, 2009 (73 FR 52730), incorporates by reference the 2004 Edition of the ASME OM Code for 1ST programs in 10 CFR 50.55a(b), subject to the limitations or modification imposed by 10 CFR 50.55a(b)(3).

There are no further limitations or modifications imposed by 10 CFR 50.55a(b)(3) on the use of paragraph 1-3410, as regards 1ST of Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices. 3.2 NRC Staff's Evaluation The licensee has requested approval to test the Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices in accordance with Mandatory Appendix I, paragraph 1-3410 of the 2004 Edition of the ASME OM Code. The NRC staff has determined that there are no further limitations or modifications imposed by 10 CFR 50.55a(b)(3) on the use of the 2004 Edition of the ASME OM Code for Mandatory Appendix I, paragraph 1-3410, with regards to 1ST of Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices. Additionally, the NRC staff has not identified any additional related requirements in the 2004 Edition of the OM Code that need to be met in order to implement Mandatory Appendix I, paragraph 1-3410. Therefore, use of the 2004 Edition of the ASME OM Code in lieu of the 2001 through 2003 Addenda for 1ST of Class 1 Main Steam Pressure Relief Valves With Auxiliary Actuating Devices per Mandatory Appendix I, paragraph 1-3410, is acceptable.

4.0 CONCLUSION

As set forth above, the NRC staff determines that the licensee's request, NL-10-1021, to use the 2004 edition of the ASME OM Code, Mandatory Appendix 1, paragraph 1-3410, for testing the Class 1 Main Steam Pressure Relief Valves with Auxiliary Actuating Devices for the remainder of the fourth 10-year 1ST interval at Hatch Unit 1 and Unit 2 is acceptable.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(f)(4)(iv), consistent with the ASME OM Code's requirements.

Therefore, the NRC staff authorizes the request, NL-10-1021, for the remainder of the Hatch 1 and 2, fourth 10-year 1ST interval which commenced on January 1, 2006, and ends on December 31,2015. Principal Contributor:

John G. Billerbeck, NRRlDCI Date: March 31, 2011 M. Ajluni If you have any questions, please contact the Project Manager, Patrick Boyle at Docket Nos. 50-321 and Safety cc w/encl: Distribution via DISTRIBUTION:

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