ML20012E976

Requests Withdrawal of Inservice Insp Relief Requests RR-45, RR-47,RR-48 & Conditional Withdrawal of RR-54 Based on Reasons Discussed in Encl,Per 900206 Conference Call

ML20012E976
Person / Time
Site:	Vogtle
Issue date:	03/27/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
MSV-00169, MSV-169, NUDOCS 9004090210
Download: ML20012E976 (6)

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sera vce bewont March 27, 1990 MSV-00169 i Nucicar Opotabont #514 i Docket No. 50-424: j U. S. Nuclear Regulatory Commission l ATTid: Document Control Desk  :

Washington D.C. 20555  ;

I i V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 l l

INSERVICE INSPECTION RELIEF REQUESTS ,

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Gentlemen:  !

o _t On February 6,- 1990, Georgia Power Company (GPC) personnel initiated a .

conference call with NRC staff and EG&G-Idaho personnel to discuss certain 1 inservice inspection (ISI) relief requests for Vogtle Electric Generating i Plant, Unit 1 (VEGP-1). Relief Requests RR-45, 47, 48 and 54 were  :

. reportedly ~'being denied by the NRC based on the recommendations of its contractor, EG&G-Idaho, and were the subject of the conference call. The purpose .of the call was to better understand the basis for the reported denial of the relief requests, determine if there were any questions about  !

- the relief requests as written, determine if additional information could be provided to better support GPC's requests for relief since certain 7

- relief was considered to be necessary to support testing to be performed during the upcoming VEGP-1 maintenance / refueling outage, and' to discuss GPC's re-evaluation of certain relief requests. The enclosure to this letter addresses each of the relief requests discussed during the 3 conference call. -}

l ' After re-evaluating each of the subject relief requests, we have determined that relief is' not required. Accordingly, GPC wishes to withdraw Relief ';

Requests RR-45, 47, 48, and 54 for the reasons discussed in the enclosure. i Relief Request RR-54 is being conditionally withdrawn, such that its *

- withdrawal does not preclude GPC's right to re-submit a similar relief -

request at a later date but on a system case-by-case basis.  ;

It is the intention of GPC to ubmit Revision 4 to the VEGP-1 ISI Program ^

to reflect the changes discussed in the enclosure. GPC expects to submit r the subject program revision to the NFC by Abril 16, 1990.

. Please be advised that relief requests similar to Relief Requests RR-45, 47, 48, and 54 for VEGP-1 were also developed for Vogtle Electric Generating Plant, Unit 2 (VEGP-2). The similar relief requests for the (

VEGP-2 ISI Program will be addressed by GPC under separate cover. GPC currently expects to make a submittal addressing the similar VEGP-2 relief request by June 15, 1990.

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c U. S. Nuclear Regulatory Commission MSV-00169 Page 2 l- March 27,1990

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Should there be any questions in this regard, please contact this office.

j Sincerely, n

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td Y./$v W. G. Hairston, III

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Enclosure:

VEGP-1 Relief Requests Discussion -

February 6, 1990 conference call.

xc: Georaia Pcwer Company Mr. C. K. McCoy i Mr. G. Bockhold, Jr.

Mr. R. M. Odom Mr. P. D. Rushton Mr. L. A. Ward -

NORMS ,

U. S. Nuclear Reaulatory Commission '

Mr. R. F. Aiello, Senior Resident inspector, Vogtle Mr. S. D. Ebneter, Regional Administrator .

L Mr. T. A. Reed, Licensing Project Manager, NRR

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l ENCLOSURE j V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 i INSERVICE INSPECTION REllEF RE0VI. SIS  :

Inservice inspection Rolief Requests RR-45, 47, 48, and 54 for Vogtle i Electric Generating Plant, Unit 1 (VEGP-1) were discussed by Georgia Power Company (GPC) personnel with NRC staff and its contractor, EG&G-Idaho, during a conference call on february 6,1990. A discussion of each relief -

request as it pertained to the conference call follows. I Relief Reouest RR-45 i

Relief Request RR-45 was written to obtain relief from performing hydrostatic and system pressure tests as required by the ASME Boiler & ,

Pressure Vessel Code,Section XI, 1983 edition with addenda through Summer 1983 (Code) on Class 2 piping systems of containment penetrations which are not required for operation to sup) ort engineered safety features (ESF) systems. Systems / penetrations whic1 are affected by this relief request are included in Table 1 to this enclosure. The subject table was developed '

from Table 6.2.4-1 in the Final Safety Analysis Report (FSAR) for Plant i Vogtle. The remaining systems / penetrations listed in the subject FSAR '

table are tested in accordance with the Code requirements where feasible.

l During the conference call with NRC staff and EG&G-Idaho personnel, GPC personnel indicated that it was GPC's intention to re-evaluate Relief Request RR-45 and revise it for re-submittal to the NRC. Subsequent to the conference call, GPC re-evaluated the need for the relief request and has determined that relief is not required. This determination is based on our position that the affected systems / penetrations listed in Table 1 do not fall under the requirements of NRC Regulatory Guide 1.26 which defines the NRC position on Quality Groups B and C (i.e., Class 2 and 3 components). Since NRC Regulatory Guide 1.26 does not apply for the listed systems / penetrations, the requirements of the Code as invoked by 10 CFR 50.55a do not apply. However, the testing requirements associated with the 1 containment are applicable per NRC Regulatory Guide 1.141. Therefore, testing will be done in accordance with the requirements of 10 CFR 50, Appendix J. Since the testing requirements for those systems / penetrations fall outside the scope of NRC Regulatory Guide 1.26 and the Code, Relief Request RR-45 is being withdrawn by GPC.

(NOTE: Relief Request RR-45 was originally submitted to the NRC in Revision 1 to the VEGP-1 ISI Program by GPC letter SL-4934 dated July 18, 1988).

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I Relief Reauest RR-47 l Relief Request RR-47 as currently written pertains to the containment )

hydrogen monitoring system and the radiation monitoring system. Relief is '

being sought from having to perform a VT-2 visual examination during system i functional or system inservice test on the aforementioned systems which contain air during system operation.

i During the conference call, GPC personnel indicated that the subject relief request would be revised to delete reference to the radiation monitoring system. The radiation monitoring system does not fall under the requirements of NRC Regulatory Guide 1.26 which defines the NRC position on Quality Groups B and C (i.e., Class 2 and 3 components). Accordingly, it  ;

is our position that the radiation monitoring system should only be tested I to the requirements of 10 CFR 50, Appendix J for reasons similar to those I discussed above for Relief Request RR-45. Further, it was indicated that GPC would re-submit Relief Request RR-47 to better address relief needed for the containment hydrogen monitoring system.

I. Subsequent to the conference call on February 6, 1990, GPC re-evaluated I Relief Request RR-47 as it pertains to the containment hydrogen monitoring i system. It is our position that the system should only be tested to the i requirements of 10 CFR 50, Appendix J since the containment hydrogen monitoring system does not fall under the requirements of NRC Regulatory l Guide 1.26. As a result, GPC is withdrawing Relief Request RR-47 in its i entirety, i (NOTE: Relief Request RR-47 was originally submitted to the NRC in I I Revision 1 to the VEGP-1 ISI Program by GPC letter SL-4934 dated July 18, i

! 1988.) l

! )

Relief Reauest RR-48 Relief Request RR-48 sought relief from the Code requirement to perform a  !

VT-2 visual examination of pressure-retaining components during a system  !

inservice test in Class 3 systems used to support the reactor shutdown j function. Relief was sought from the Code requirement that systems be in operation for at least four hours prior to the start of the VT-2 visual l examination performed during a system inservice test. Portions of the i I affected system, the Boric Acid Transfer System, are not normally in i operation for durations of at least four hours. l It was indicated by GPC personnel during the conference call that Relief l Request RR-48 had been re-evaluated and that it had been determined that relief was not necessary. The Boric Acid Transfer System can be operated for durations of at least four hours and can accommodate the Code-required  ;

testing. When Relief Request RR-48 was originally submitted, the Boric '

Acid Transfer System would have been required to re-circulate through a "mi ni-fl ow" line for five to six hours to meet inservice testing (IST) .

requirements. This could significantly degrade the Boric Acid Transfer i E-2 i

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4' pumps after several inservice tests were performed. Subsequent to the i submittal of the relief request, the Boric Acid Transfer System was  !

modified to allow the pumps to re-circulate at " full-fl ow" versus  :

" mini-flow." As a result, GPC is withdrawing Relief Request RR-48 since it  !

is longer required, j (NOTE: Relief Request RR-48 was originally submitted to the NRC in I Revision 1 to the VEGP-1 ISI Program by GPC letter SL-4934 dated July 18, 1988.)

I Relief Reauest RR-54 i Relief Request RR-54 sought relief from the Code system hydrostatic test requirements on (a) piping s l" nominal piae size (NPS) and (b) components and their connections in pi)ing $1" NPS wit 1 impracticality cited as one of the primary reasons for see(ing relief.

After re-evaluating the subject relief request, GPC personnel indicated I

during the conference call that the relief request would be withdrawn with the condition that its withdrawal would not preclude GPC's right to re-submit a similar relief request at a later date, but on a system case-by-case basis.

- (NOTE: Relief Request RR-54 was submitted to the NRC in Revision 3 to the VEGP-1 ISI Program by GPC letter MSV-00033 dated May 10, 1989.)

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Table 1 Non-NRC Regulatory Guide 1.26 Systems / Penetrations {

Associated with Relief Request RR-45

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Penetration System ,

. Number (s) Name llA Chemical Addition i 12A Chemical Addition 13A & B Containment Air Radioactivity Monitor Inlet & Outlet ,

13C Containment Pressure Detector 14A, B, & C Reactor Vessel Water Level Instrumentation  ;

15 Purification Water Supply to Refueling Cavity '

22 Demineralized Water Supply t 23 Breathing Air Supply ,

28 ACCW Supply '

29 ACCW Return 40 Fire Protection Water .

41 Accumulator Test and Drain Line  :

Nitrogen Supply to Accumulator 42 62 Pressurizer Relief Tank Sample to Waste Gas Compressor Suction and Nitrogen Supply 63 Pressurizer Relief Tank Makeup Water Supply 64A & B Spare 67C Containment Pressure Detector >

68 Containment Leak Rate Test i 69A & B Chemical Addition 69C Containment Pressure Detector 70A & B Containment Hydrogen Monitor Suction & Discharge  !

70C Containment Pressure Detector 71A & B Containment Hydrogen Monitor Suction & Discharge 71C Containment Pressure Detector 77 P,eactor Coolant Drain Tank Pump Discharge 78 Normal Containment Sump Pumps Discharge

• 79 Reactor Coolant Drain Tank Vent and ,

Hydrogen Supply  ;

i 80 Service Air and Post-LOCA Purge Air Supply l

81 Instrument Air .

L 83 Normal Containment Purge Supply and Equalizing -

l 84 Normal Containment Purge Exhaust and Equalizing 85C Containment Pressure Detector l 86A & C Post-Accident Sampling

! 87 Containment Leak Rate Test l 88A, B, & C Reactor Vessel Water Level Instrumentation l 89 Transfer Tube l- 100 Post-Accident Air Exhaust Encapsulation Vessels

• Equipment Hatch

• Personnel Locks

• l Emergency Doors

• l

• Included in table for completeness sake only.

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