ND-19-0060, Request for Alternative: Alternative Requirements for Preservice Testing of Class 1 Safety Valves (VEGP 3&4-PST-ALT-02)
| ML19064B385 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/05/2019 |
| From: | Whitley B Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| ND-19-0060 | |
| Download: ML19064B385 (8) | |
Text
B. H. Whitley Southern Nuclear Director Operating Company, Inc.
Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 March 5, 2019 Docket Nos.: 52-025 ND-19-0060 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 Class 1 Safety Valves (VEGP 3&4-PST-ALT-02)
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 ASME Operation and Maintenance of Nuclear Power Plants (OM) Code, I-7210, 2012 Edition (code of record) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. The proposed request for alternative is applicable to the location and timing for preservice testing of Class 1 safety valves.
SNC facilitated a presubmittal meeting on February 21, 2019 with the NRC staff on the proposed alternative request.
The details of the 10 CFR 50.55a(z)(1) request are contained in Enclosure 1 to this letter.
Approval is requested by September 6, 2019 to support planning activities associated with preservice testing.
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-19-0060 Page 2 of 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th day of March 2019.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Brian H. Wh1tley Director, Regulatory Affairs Southern Nuclear Operating Company : Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1)- Alternative Requirements for Preservice Testing of Class 1 Safety Valves
U.S. Nuclear Regulatory Commission ND-19-0060 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 Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. J. Andrews Mr. C. Pendleton 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 Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley
U.S. Nuclear Regulatory Commission ND-19-0060 Page 4 of 4 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)
T. Rubenstein (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-19-0060 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -
Alternative Requirements for Preservice Testing of Class 1 Safety Valves (This enclosure consists of 3 pages, not including this cover page.)
ND-19-0060 Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -
Alternative Requirements for Preservice Testing of Class 1 Safety Valves 1
Plant Site-Unit:
Vogtle Electric Generating Plant (VEGP) - Units 3 and 4 Interval-Interval Dates:
Applies to the preservice testing period.
Requested Date for Approval:
Approval is requested by September 6, 2019 ASME Code Components Affected:
ASME Class 1 Safety Valves.
Applicable Code Edition and Addenda:
ASME OM Code, 2012 Edition (code of record).
Applicable Code Requirements:
ASME OM Code, I-7210 requires Class 1 safety valve testing. Within 6 months before initial reactor criticality, each valve shall have its set-pressure verified. Set-pressure verification shall be determined by pressurizing the system up to the valve set-pressure and opening the valve, or the valve may be tested at or below normal system operating pressures with an assist device.
Reason for Request:
The existing Code requirement implies that the safety valves be tested in place. The valves are located on top of the pressurizer. Due to the temperature environment of this location, testing of the safety valves presents a personnel safety issue to personnel performing the testing as it involves activities such as use of an assist device and installation of a gag on the valve not being tested.
Also, the timing requirement of within 6 months before initial criticality provides potential scheduling issues. If the 6 months expires just before initial criticality, the plant would be in a hot, pressurized condition and would have to be cooled down and depressurized to replace the valves. Tying testing to the fuel load milestone is favorable since, for potential delays that push the fuel load date
ND-19-0060 Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -
Alternative Requirements for Preservice Testing of Class 1 Safety Valves 2
outside of the proposed 3 month test requirement, the plant would be in a cold and depressurized condition, and the valves could be removed and replaced without having to put a thermal cycle on the plant with the associated time delays of cooling down/depressurizing and subsequent return to normal operating temperature and pressure.
Per discussions with the Appendix I Sub-Group, the purpose of this requirement is to ensure that the plant is started up with safety valves with recently verified setpoints and to ensure that valves do not go an excessive time prior to retesting if initial startup is prolonged. Additionally, they believe that I-7210 was not meant to preclude the use of pretested valves. The use of pretested valves is allowed per I-1320 in lieu of in place testing for routine inservice testing.
Proposed Alternative and Basis for Use:
Proposed Alternative:
In lieu of performing setpoint testing with the valve installed in the system within 6 months before initial criticality in accordance with I-7210, Class 1 Safety Valves shall be replaced with Pretested valves.
The set-pressure test of the valves shall not be more than 3 months prior to the commencement of Initial Fuel loading. The initial testing per I-1320, shall be no longer than 24 months from the date of the set-pressure verification test.
Basis for Use:
The Class 1 safety relief valves are Crosby, model number HB-BP-86.
This manufacturer and model have been commonly used in the nuclear industry in this application and have a history of acceptable performance with regards to setpoint drift.
The proposed alternative provides an equivalent level of safety as it ensures that the safety valves setpoints will be verified recently prior to beginning of fuel loading and subsequent initial startup activities, and that inservice valve testing is not extended past the normal frequency, even if the startup process prior to Initial Generation of Electricity by nuclear heat is prolonged. This alternative provides the additional benefit of improving personnel safety by not having personnel in a heat stress environment to perform in-place testing.
If the schedule of startup activities begins to challenge a testing frequency of 24 months following the preservice test, SNC will evaluate
ND-19-0060 Proposed Alternative VEGP 3&4-PST-ALT-02 in Accordance with 10 CFR 50.55a(z)(1) -
Alternative Requirements for Preservice Testing of Class 1 Safety Valves 3
additional setpoint testing prior to startup or performance of a mid-cycle shutdown to ensure inservice testing is performed at the required inservice testing interval. A review was performed of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) 2.1.02.08a.ii for testing and analysis of safety relief valves in accordance with ASME Section III. This proposed Code alternative does not have any impact on the ITAAC.
Since the proposed alternative is consistent with inservice testing requirements for replacing with pretested valves in accordance with I-1320(b) and the frequency of the first inservice test limits the amount of time between set-pressure verification tests, this proposed alternative provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).
Duration of Proposed Alternative:
Preservice testing conducted prior to commercial operation.
References:
None.
Status:
Awaiting NRC authorization