NL-12-2110, Proposed Alternative VEGP-ISI-ALT-08 in Accordance with 10 CFR 50.55a(a)(3)(ii)

Proposed Alternative VEGP-ISI-ALT-08 in Accordance with 10 CFR 50.55a(a)(3)(ii)

ML12299A244
Person / Time
Site:	Vogtle
Issue date:	10/25/2012
From:	Ajluni M Southern Nuclear Operating Co, Southern Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-12-2110
Download: ML12299A244 (13)

Text

Mark J. Ajluni. P.E. Southern Nuclear Nuclear Licensing Director Operating Company. Inc.

40 Invern ess Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 October 25, 2012 SOUTHERN'\

COMPANY Docket No.: 50-424 NL-12-2110 U. S. Nuclear Regulatory Commission ATIN : Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Unit 1 Proposed Alternative VEGP-ISI-AL T-08 in Accordance with 10 CFR 50.55a(a)(3)(ii)

Ladies and Gentlemen:

Pursuant to 10 CFR 50.55a(a)(3)(ii), Southern Nuclear Operating Company (SNC) hereby requests NRC approval of proposed alternative to the specified ASME Boiler and Pressure Vessel Code Section XI requirements .

On October 7, 2012 during the Class 1 leakage test after the 1R 17 refueling outage, a pinhole steam leak in a seal weld on a Chemical and Volume Control System valve was identified . It was determined that the leakage is operational and is not a pressure boundary leakage. To stop steam escaping from the pinhole leak in the seal weld, a clamp with sealant was installed on October 13, 2012. After additional system heatup, the leakage reoccurred and was stopped on October 16, 2012. Subsequently, steam leakage was re-identified on October 22, 2012. Following discussion with the vendor, it was determined that the cause of the steam leak was most likely due to the sealant material being applied at a lower temperature than required to ensure the proper curing of the material.

Replacement of the clamp with a like clamp and reinjection of sealant is desired in order to stop the leak until a permanent solution can be implemented.

The details of this request are contained in the enclosure.

An expedited NRC approval by October 26, 2012 is requested to support installation of the new clamp in order to stop the leak. SNC requests an expedited approval to facilitate a prompt resolution . Currently, leakage rates remain low and personal safety is not challenged.

This letter contains no NRC commitments. If you have any questions, please contact Doug McKinney at (205) 992-5982.

U. S. Nuclear Regulatory Commission NL-12-2110 Page 2 Respectfully submitted, M. J. Ajluni Nuclear licensing Director MJAlJLS

Enclosure:

Proposed Alternative VEGP-ISI-ALT-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. E. Tynan, Vice President - Vogtle Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Fleet Mr. L. M. Cain, Senior Resident Inspector - Vogtle

Vogtle Electric Generating Plant - Unit 1 Proposed Alternative VEGP-ISI-ALT-08 Enclosure Proposed Alternative VEGP-ISI-ALT-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a}{3}{ii}

Enclosure Proposed Alternative VEGP-ISI-ALT-08 Version 1.0, in Accordance with 10 CFR 50.55a(a)(3)(ii)

Plant Site-Unit:

Vogtle Electric Generating Plant Unit 1 (VEGP-1)

Interval-Interval Dates:

Third lSI interval extending from May 31, 2007 through May 30, 2017.

ASME Code Components Affected:

The affected component is the Chemical and Volume Control System (CVCS) valve 1-1208-U4 A11 which is a Code Class 1 normally locked-open valve.

Issue

Description:

Steam was escaping through the Kerotest valve 1-1208-U4-A 11 on the 2-inch pressurizer auxiliary spray line which is the flow path for CVCS to the 6-inch pressurizer head spray line of the VEGP-1 Reactor Coolant System (RCS). This issue was discovered on October 7,2012 during the Class 1 leakage test at Mode 3 during the start-up sequence after the 1R17 refueling outage. The steam leak emanated from a pinhole on the seal weld used to provide a seal for the threaded connection joining the valve body and the valve bonnet. The affected valve is shown on drawing 1X4AR23-00072 (Attachment 1). In addition, Attachment 2 shows the valve condition during the Class 1 leakage test. This issue is documented in Vogtle Condition Report No. 530116, dated October 7, 2012.

SNC Evaluation of Valve 1-1208-U4-A11 :

Subsubarticle IWA-5250, titled Corrective Actions, of ASME Section XI, 2001 Edition with Addenda through 2003 was used for the evaluation of the leaking valve. It was determined that the leakage was not a pressure boundary leak because of its location at the fillet weld which seals the uppermost interface between the body and bonnet mechanical joint of valve 1-1208-U4-A11.

The logic to arrive at that decision is described below:

Technical SpeCifications (TS) section 1.1 defines: "c.) Pressure Boundary LEAKAGE:

LEAKAGE (except primary to secondary LEAKAGE) through a non-isolable fault in an RCS component body, pipe wall, or vessel wall."

In the case of VEGP-1, TS LCO 3.4.13 RCS Operational Leakage specifies "RCS operational LEAKAGE shall be limited to: a.) No pressure boundary LEAKAGE; ..."

Thus, the acceptability of the leak on valve 1-1208-U4-A11 hinges on whether it is pressure boundary leakage. The Basis for LCO 3.4.13 states that "no pressure boundary LEAKAGE is allowed, being indicative of an off-normal condition. LEAKAGE of this type is unacceptable as the leak itself could cause further deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the El

Enclosure Proposed Alternative VEGP-ISI-AL T-08 Version 1.0, in Accordance with 10 CFR 50.55a(a)(3)(ii)

RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE."

(emphasis added).

Given that the subject leak is located at the fillet weld which seals the uppermost interface between the body and bonnet mechanical joint of valve 1-1208-U4-A 11, it is judged to be a seal in the context of LCO 3.4.13 and its associated basis and is, therefore, not pressure boundary leakage.

As part of the SNC evaluation to determine ASME Code requirements, a review was also performed of NRC Regulatory Issues Summary (RIS) 2005-20, Revision 1. When the RIS was issued in April 2008, a revised NRC Inspection Manual, Part 9900 was included . The title of Part 9900, Technical Guidance, is "Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." Part 9900 Purpose stated "This guidance is provided to the NRC inspectors to assist their review of licensee determinations of operability and resolution of degraded and nonconforming conditions. In addition, many licensees have found this guidance useful in developing their plant-specific operability determination process." Appendix C of Part 9900 titled "Specific Operability Issues" contains paragraph C.12, "Operational Leakage from ASME Code Class 1, 2, and 3 Components." Within paragraph C.12 and on page C-11, it is stated "The operational leakage TS LCO does not permit any reactor coolant pressure boundary leakage."

Therefore, it is inferred that paragraph C.12 is directed toward pressure boundary leakage and not leaks at items such as seal welds, gaskets, etc. Therefore, the SNC initial position was that no lSI alternative was required in this situation since Class 1 pressure boundary leakage did not exist.

In discussions between the NRC and SNC on October 15,2012, the NRC accepted the SNC position that the leakage should not be considered "pressure boundary leakage"; however, there was consensus that an lSI alternative based on a hardship argument (10 CFR 50.55a(a)(3)(ii)) was a conservative approach . Based on those discussions, SNC is submitting this lSI alternative.

Requested Date for Approval and Basis:

An expedited NRC approval by October 26, 2012 is requested to support installation of the new clamp in order to stop the leak. As discussed on October 15th, a clamp with sealant has been installed and the unit is currently operating at Mode 1. Subsequent to that discuSSion, steam leakage was re-identified on October 22nd and requires replacement of the clamp with a like clamp and reinjection of sealant in order to stop the leak until a permanent solution can be implemented. The original clamp was injected with the correct sealant but at a lower temperature than required to ensure proper curing of the material. Once the replacement clamp is installed, sealant will then be applied to the clamp at normal operating temperature and pressure.

E2

Enclosure Proposed Alternative VEGP-ISI-ALT-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii)

Applicable Code Edition and Addenda

2001 through 2003 Addenda of ASME Section XI.

Although valve 1-1208-U4-A 11 does not have the typical boundary leak, SNC realized that actions would need to taken to address the Several options were evaluated and it was determined the addition of a mechanical clamp was the best option. ASME Section XI Appendix IX provides the requirements for mechanical clamping devices on Class 2 and 3 piping as in Paragraph IWA-4133. In specific case Appendix IX is being used for guidance since no other guidance exists for Class 1 non-pressure boundary leaks.

The valve is not isolable from the RCS to allow the non-pressure boundary leak issue to be resolved. The initial proposed fix was a combined peening welding effort at Mode 3 after the was found. In this case, peening stopped the however, the leak re-appeared when heat from the attempted re-welding was applied to the weld. At that time, a return to Mode 5 for repair, in addition to other options, was considered. However, because the leakage was not boundary leakage, it was determined that prior NRC approval was not needed and that the repair could be done at existing operating conditions. It was determined that the cycling of plant equipment and personnel to go to Mode S a hardship without a compensating increase in the level of quality or safety. These reasons continue to exist for the current operating condition. SNC that the clamp would an acceptable alternative for plant operation during Cycle 18.

Subsequently an engineered clamp was installed and coupled with an initial sealant injection, stopped steam however, only temporarily. After the plant heated up a leak was identified again coming from the valve, and additional sealant injection was undertaken.

additional injection proved to be unsuccessful as well. To resolve the current leakage issue, it has been determined that the existing clamp should removed from the affected valve, the exterior of valve of and that a replacement clamp the same design should be installed. That action is proposed since the sealant material that was may have been negatively impacted due to the temperature and/or pressure at which it was installed and may have resulted in a porous condition referred to as honeycombing that allowed the steam leak to continue. replacement clamp is to be fabricated with a sealant injection port closer to the area of existing leak. Following discussing with the Staff it was decided that SNC would approval from the NRC prior installing the replacement clamp.

Therefore, this alternative is submitted for approval.

E3

Enclosure Proposed Alternative VEGP-ISI-AL T-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii)

Proposed Alternative:

SNC implemented a design change that added a mechanical clamp with the injection of sealant, which offered the best available option to encapsulate the steam leak. The intention is to use a clamp for one operating cycle or until an outage of sufficient duration occurs to allow SNC to either perform a permanent repair of the valve or to replace the valve. The Basis for Use will provide the details of the VEGP-1 design change as compared to the requirements of Appendix IX.

Basis for Use:

ASME Section XI 2001 Edition with Addenda through 2003, Appendix IX, consists of six articles.

SNC has compared this clamp design to these articles and provide the following details to support the NRC review:

Article IX-1000; General The clamp is on a Class 1 component which was installed per a Vogtle design change with no repair/replacement activities needed. The clamp and the injected sealant is a leakage control device. The replacement clamp is to be installed in a similar manner and is of the same design as the original clamp but with a relocated sealant injection port.

Article IX-2000; Defect Characterization In addition to the general description of the defect under Issue Description of this alternative, SNC provides the following discussion related to defect characterization.

The leakage is through a defect in the seal weld at the body to bonnet connection of the valve. The defect is believed to be from a lack of fusion in the seal weld. A post-weld PT examination of the weld made during 1R17 showed no rejectable indications. The combination of the clamp and the sealant should prevent future leakage, thus replacing the seal weld's function.

The body and the newly installed valve bonnet are fabricated from ASME SA 182 Grade F316 Stainless Steel (reference drawing 1X4AR23-00072 in Attachment 1). Stainless steel is not readily susceptible to boric acid corrosion; therefore, no corrosion is expected to occur that would damage the valve or cause the leak to propagate. During the process of installing the new bonnet, the valve internals were inspected and no damage or issues were identified. Also, issues with the valve body threads would have been recognized when the bonnet was being threaded into the valve body. The threads of the valve body were not in a degraded condition, thus allowing the bonnet to be torqued as required.

E4

Enclosure Proposed Alternative VEGP-ISI-AL T-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii)

Article IX-3000; Design Requirements The addition of the engineered clamp to the valve and the piping system were evaluated under SNC's Minor Design Change (MDC) process. The clamp (the current clamp as well as its replacement) was designed to replace the seal weld by encasing a portion of the bonnet and body of the valve and thus completely enveloping the seal weld. An approved, vendor-supplied proprietary blend sealant is used to stop the leak while the clamp acts as a sealant retaining device. The clamp is composed of three major components: two pieces that encase the seal weld and a strongback which is located on the bottom of the valve and attaches to the top of the clamp to aid in the structural integrity of the clamp. Four studs are used to connect the three major components. The clamp design is shown in Attachment 3.

Westinghouse performed a piping analysis for SNC in order to demonstrate that the piping system would continue to operate safely with the additional weight of a clamp on valve 1-1208-U4-A11. That analysis is documented in letter LTR-PAFM-12-127, and is included as an attachment to GP-18987, Revision 1. Westinghouse will update their stress analysis, BG-01-001, to support this design change. If requested by the NRC, this stress analysis can be made available for NRC review.

As a result of the Westinghouse stress analysis, site personnel performed calculation X4CPS0351 which covers pipe supports included in the Westinghouse stress analysis.

The calculations concluded that the new loading conditions are still acceptable for the supports as designed and that there is adequate inherent reserve margin to accommodate the revised loads.

Seismic issues were addressed for the clamp installation through the design change process. Seismic concerns with the clamp alone were evaluated under the MDC.

Seismic concerns due to the additional mass added to the valve were evaluated as part of the MDC under a Documentation of Engineering Judgment (DOEJ), DOEJ VMSNC439341-C001. The DOEJ used the original valve vendor's seismic report, AX4AR23-0087, in the evaluation.

The clamp and sealant were installed on the valve under the MDC using a Vogtle site procedure and a vendor procedure. The replacement clamp is to be installed in a like manner. The site procedure, 25037-C, was provided as an in-process control measure.

Work instructions from the MDC were used in conjunction with the vendor procedure to install the clamp and inject the sealant. A similar process will be used to install the replacement clamp .

Article IX-4000; Material Requirements Article IX-4000 requirements are addressed in the discussion regarding design requirements (Article IX-3000). Specific material information related to the clamp is contained in the MDC package. In addition, a sealant approved for use on a Class 1 system was used as the injection sealant.

E5

Enclosure Proposed Alternative VEG P-ISI-ALT-OS Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii)

Article IX-5000; Pressure Testing Requirements Vogtle Condition Report 530116 documented this leak during the initial Class 1 leakage test on October 7, 2012. After the installation of the clamp and injection, it was observed that the steam leak still existed. Additional sealant was injected and the leak was stopped. Subsequent to that injection, steam leakage reappeared on October 22, 2012 and requires replacement of the clamp installed earlier and injection of sealant. This activity is deemed to be the most prudent without performing a permanent repair in order to better seal the most recent steam leak. The current clamp will be removed, the surface of the valve body cleaned of sealant injection material residue, and the clamp replaced with a clamp of like design , having a relocated sealant injection port, which would allow sealant to be injected closer to the defect.

Article IX-6000; Monitoring Requirements Article IX-6000 requires ongoing volumetric examination of the adjacent piping throughout the cycle of operation. The configuration of the valve does not permit these examinations. In addition to SNC installing a camera for weekly monitoring, a qualified VT-2 examiner will inspect the affected valve every thirty days via containment entry.

Although leakage at the valve had ceased due to the clamp and sealant injections, leakage at the valve has now reoccurred. Replacement of the existing clamp and reinjection of sealant is expected to correct the leakage problem, pending a permanent repair or replacement of the valve. With the leakage subsided, flooding concerns are not an immediate issue. The normal containment sump pumps that would be subject to collect this leakage are sized to pump 50 gallons per minute (gpm). However, in the case being considered, a leak rate of 50 gpm would not be reached since Vogtle's Technical Specification 3.4.13 for RCS Operation LEAKAGE limits "Identified RCS Operational Leakage" to 10 gpm and "Unidentified RCS Operational Leakage" to 1 gpm.

Leakage from this valve would be considered Unidentified Leakage if it were to occur as a steam leak since it would be relatively difficult to quantify the steam leak in this situation. Thus, a leakage rate of 50 gpm would not be reached since the "REQUIRED ACTIONS" for LCO 3.4.13 would require such conditions to be addressed.

If the leak returns, spraying or wetting of equipment, components and structures in the surrounding area would be of little significance. There is a limited amount of equipment in the immediate vicinity of the valve that would be negatively impacted. Items and structures located in the immediate vicinity of the valve are various pieces of structural steel (for example, pipe supports, structural beams, handrails) and cable trays and their associated cables. These items are expected to be impacted minimally by the leak due to the leakage mechanism , that is, steam . The steam is expected to condense on the surrounding material and is not expected to be a corrosion concern since the water will evaporate leaving behind dry boric acid crystals. Re-wetting of the dry residue is a possibility due to the misting steam, which could cause an increase in the boric acid concentration; however, due to the temperatures of the surrounding material expected to be well below the boiling point of borated water, the corrosion rates are expected to be negligible.

E6

Enclosure Proposed Alternative VEGP-ISI-AL T-08 Version 1.0, in Accordance with 10 CFR 50.55a(a)(3)(ii)

Also, with the monitoring plan consisting of a camera and regularly scheduled inspections, leakage from the valve can be identified in a prompt manner and actions can be taken to lessen the chances of significant boric acid corrosion.

Since there is a reasonable assurance that the structural integrity of the valve will be maintained with the addition of the engineered clamp, the use of this proposed alternative will provide an acceptable level of quality and safety. Therefore, it is requested that the NRC authorize this proposed alternative in accordance with 10 CFR SO.SSa(a)(3)(ii).

Duration of Proposed Alternative:

Until the 1R18 refueling outage in spring 2014 or until an outage of sufficient duration occurs to allow VEGP-1 to perform either a permanent repair to the affected valve or to replace the valve.

Precedents:

None. No known precedents.

Status:

Awaiting NRC approval.

List of Attachments : Valve Drawing 1X4AR23-00072 : Identified Leakage from Valve on October 7, 2012 : Mechanical Clamp Design E7

Enclosure Proposed Alternative VEGP-ISI-ALT-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii)

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Enclosure Proposed Alternative VEGP-ISI-ALT-08 Version 1.0, in Accordance with 10 CFR 50.55a{a)(3}(ii)

Attachment 2 E9

Enclosure Proposed Alternative VEGP-ISI-AL T-08 Version 1.0, in Accordance with 10 CFR SO.SSa(a)(3)(ii)

Attachment 3 8'STUD LENGTH VALVE o o STRONGBACK BAR ElO