ML18212A219

ASME Section XI Inservice Inspection Program Relief Requests for Limited Coverage Examinations Performed in the First Period of the Fifth 10-Year Inservice Inspection Interval Response to Request for Additional Information

ML18212A219
Person / Time
Site:	Surry
Issue date:	07/25/2018
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk
References
Download: ML18212A219 (5)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 25, 2018 10 CFR 50.55a U.S. Nuclear Regulatory Commission Serial No.: 18-268 Attention: Document Control Desk SPS LIC/CGL: RO.

Washington, DC 20555 Docket No.: 50-280 License No.: DPR-32 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 ASME SECTION XI INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONS PERFORMED IN THE FIRST PERIOD OF THE FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated March 21, 2018 (Serial No.18-042), Virginia Electric and Power Company (Dominion Energy Virginia) submitted two relief requests for Surry Power Station Unit 1 for limited coverage component examinations for the first period of the fifth 10-year inservice inspection interval that began on December 14, 2013 and will end on October 13, 2023. The relief requests were based on the impracticality of performing the

• required examination coverages due to physical obstructions and limitations imposed by design and geometry of the subject components. On June 29, 2018, the NRC Project Manager for Surry sent Dominion a request for additional information (RAI) associated with one of the submitted relief requests. Dominion Energy Virginia's response to the RAI associated with Relief Request S1-15-LMT-P01 is provided in the attachment.

If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering Commitments made in this letter: None

Attachment:

Response to Request for Additional Information - Relief Request S1-15-LMT-P01

Serial No.18-268 Docket No. 50-280 RAJ Response - Relief Request - 1st Period 5th ISi Interval Limited Coverage Examinations Page 2 of 2 cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 Ms. K. R. Cotton Gross NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. R. Hall NRC Senior Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B-1A 11555 Rockville Pike Rockville, Maryland 20852 NRC Senior Resident Inspector Surry Power Station Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station

Serial No.18-268 Docket No. 50-280 Attachment RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST S1-15-LMT-P01 Virginia Electric and Power Company (Dominion Energy Virginia}

Surry Power Station Unit 1

Serial No.18-268 Docket No. 50-280 RAI Response - Relief Request LMT-P01 Attachment RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST S1-15-LMT-P01 SURRY POWER STATION UNIT 1 NRG Comment By letter dated March 21, 2018, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18086A029), Virginia Electric and Power Company (Dominion Energy Virginia, the licensee), submitted relief request (RR) S1-l5-LMT-P01 to request relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," 2004 Edition of ASME Section XI, regarding the examination of welds at Surry Power Station Unit 1.

The NRG has determined that the following additional information is necessary to complete its review and make a regulatory decision.

NRG RAJ Question No. 1 The Fifth 10-year ISi interval program at Surry Power Station Unit 1 is based on ASME Code,Section XI, 2004 Edition. The examinations .of the piping welds is [are]

conducted using procedures, equipment,* and personnel qualified under ASME Code Section XI Appendix VI/I. 10 CFR 50.55a(b)(2)(xv) states "Appendix VIII specimen set and qualification requirements. Licensees using editions and addenda after 2001 Edition through the 2006 Addenda shall use the 2001 Edition of Appendix VI/I, and may elect to comply with all of the provisions in paragraphs (b)(2)(xv)(A) through . (b)(2)(xv)(M) of this section, except for paragraph (b)(2)(xv)(F) of this section, which may be used at the licensee's option."

Please identify the ASME Code of record used for ASME Code Section XI Appendix VIII qualifications.

Dominion Response The ASME Code of record used for ASME Code Section XI Appendix VIII qualifications is the 2001 Edition.

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Serial No.18-268 Docket No. 50-280 RAI Response - Relief Request LMT-P01 Attachment NRC RA/ Question No. 2 Describe the risk-informed inse,vice inspection program, including the framework (ASME Code Case N-716, N-716-1, N-578, etc.) and the date adopted.

Dominion Response The purpose of a risk-informed inservice inspection (RI ISi) program is to concentrate examinations on areas that have a higher probability and consequence for failure, while eliminating less meaningful examinations on low risk components.

• The methodology utilized when* developing the 5th Interval RI ISi program for Surry was based on Code Case N-716-1, "Alternative Classification and Examination .

Requirements," which was approved by the ASME on January 27, 2013 and endorsed by the NRC in Regulatory Guide 1.147, Revision 17 effective December 5, 2014 (Federal Register Vol. 79, No. 214, November 5, 2014). A project updating the RI ISi program was completed, approved, and documented internally on February 24, 2015 (i.e., early in the 5th Interval). Scheduling was adjusted in accordance with the project document prior to the first Unit 1 refueling outage of the 5th interval, which occurred in the spring of 2015.

Although the Category in RR S1-15-LMT-P01 indicates risk-informed piping, the weld examinations were not performed to meet RI ISi requirements. The welds with limited coverage addressed in this relief request were examined to satisfy preservice requirements as they were newly constructed welds required for valve replacement.

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