ML20133H030
| ML20133H030 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/08/1997 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20133H032 | List: |
| References | |
| LCV-0932, LCV-932, NUDOCS 9701170027 | |
| Download: ML20133H030 (5) | |
Text
I Georgia Power Company 40 inverness Center Parkway l
Post Ottce Box 1295
, Birmingham, Alabama 35201 Telephone 205 877 7122 m
Georgia Power C.K.McCoy Vce President. Nuclear Vogtle Project the southem Mrtnc sgtem January 8, 1997 l
LCV-0932 Docket No.: 50-425 U. S. Nuclear Regulatory Commission j
ATTN: Document Ccntrol Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT INSERVICE INSPECTION
SUMMARY
REPORT Enclosed is the " Owner's Report for Inservice Inspection (Form NIS-1)" for inservice inspection (ISI) activities conducted at Vogtle Electric Generating Plant, Unit 2 (VEGP-2) during its Fall 1996 maintenance / refueling outage. The enclosed report is required by Paragraph IWA-6230 of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI,1983 Edition with Addenda through Summer 1983. Also included therein are the " Owner's Reports for Repair a-Replacements (Form NIS-2)" for repairs and/or replacements of piping and components 1 inch nominal pipe size (NPS) and larger which were documented at VEGP-2 from the end of the previous maintenance / refueling outage through the Fall 1996 maintenance / refueling outage. The supporting documentation, e.g., examination records, equipment and material certifications, etc., from which the enclosed " Owner's Report for Inservice Inspection (Form NIS-1)" was compiled is available for review upon request at the plant site.
With regard to the NIS-2 reports on repairs and/or replacements, only the completed NIS-2 forms are being submitted. Any attachments, e.g., code data reports, etc., that are I
referenced in the completed NIS-2 forms will be made available for review upon request at the plant site.
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As a result of a concern identified by the Authorized Nuclear Inservice Inspector (ANII),
Q' h7 it appears that any repairs of piping and components 1 inch NPS and smaller may not have
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l been properly documented using Owner's Reports for Repairs and Replacements (ASME I
l Form NIS-2). Review of the VEGP Repair / Replacement Program during VEGP-2 Outage 2R5 revealed that repairs to piping and components 1 inch NPS and smaller were being treated similar to replacement of piping and components of that size, i.e., it was Lt n,annt o
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GeorgiaPower1 U. S. Nuclear Regulatory Commission LCV-0932 Page Two believed that repairs of piping and components 1 inch NPS and smaller were exempt, including the requirements associated with recordkeeping. As a result of this misunderstanding of the Code requirements for repairs, both VEGP units appear to have been in non-compliance since the beginning of commercial operation for repairs of piping and components 1 inch NPS and smaller. It is the belief of Georgia Power Company (GPC) that any such repairs performed were technically sound and met Code requirements except for the documentation thereof using ASME Form NIS-2 (Owner's Report for 1
Repairs and Replacements). Completion of ASME Forra NIS-2 for any such repairs of piping and components 1 inch NPS and smaller would not provide a commensumte increase in the level of safety were the Code requirements for recordkeeping imposed for any such past repairs of piping and components 1 inch NPS and smaller. As a result, for
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any past instances where compliance with the recordkeeping requirements for repairs to piping and components 1 inch NPS and smaller was not met, it is the intention of GPC to pursue relief from the Code requirements for documenting such repairs on an ASME Form NIS-2 using ASME Code Case N-544 as a basis. Such relief will be submitted to the NRC under separate cover for review and approval. Since the identification of this potential non-compliance, plant personnel responsible for repair activities have been instructed that repairs, irrespective of the size of piping and component involved, are to be properly documented on ASME Form NIS-2.
Included in the enclosed VEGP-2 " Owner's Report for Inservice Inspection (Form NIS-1)" is a discussion on the inspection of steam generator tubes performed during the Fall 1996 maintenance / refueling outage. That discussion constitutes the Special Report required by VEGP Technical Specification 4.4.5.5.b to be submitted to the NRC within 12 months following completion of the steam generator tube inspections. As a result, there will not be a separate submittal made to the NRC on the inspection of the steam generator tubes performed during the subject outage. By copy of this letter, the appropriate NRC Regional Administrator is being provided copies of the enclosed report; thus, compliance with the requirements of VEGP Technical Specification 6.8.2 for submittal of Special Reports to the appropriate NRC Regional Administrator is met.
Please note that several steam generator tubes were required to be plugged during the Fall 1996 maintenance / refueling outage at VEGP-2. Pursuant to the requirements of VEGP Technical Specification 4.4.5.5.a and 6.8.2, a Special Report was submitted to the NRC within 15 days of the completion of the steam generator tubing inspections and identified the number of steam generator tubes which required plugging during the subject outage.
That Special Report was submitted to the NRC by GPC letter LCV-0892 dated
l GeorgiaPower1 U. S. Nuclear Regulatory Commission LCV-0932 Page Three l
October 10,1996. Details on which tubes were plugged are included in the discussion provided in the enclosed report.
Please note that three welds (21202-216-59,21202-225-1, and 21202-229-2) in the Nuclear Service Cooling Water System had limited volumetric coverage during their ultrasonic examinations because of physical limitations due to the geometric configuration of the welded areas. In order for adequate ASME Section XI Code-required examination coverage to be attained, ninety percent (90%) or more of the required volume must be examined as addressed in ASME Section XI Code Case N-460. The subject code case has bva approved in NRC Regulatory Guide 1.147 for use. It is impractical to achieve the ASME Section XI Code-required coverage due to the geometric configuration of the welded areas. Relief from the ASME Section XI Code requirements will be requested from the NRC for the affected welds during a future ISI program revision for VEGP-2 as allowed by 10 CFR 50.55a.
1 Georgia Power Company acknowledges that new rulemaking regarding 10 CFR 50.55a went into effect on September 9,1996 with the NRC invoking the requirements of ASME Section XI Code, Subsections IWE and IWL, which involve Class MC and CC components, respectively. The requirements of these two Code subsections were not previously required by the NRC to be invoked. No inspections of Class MC and CC components were planned for Fall 1996 maintenance / refueling outage at VEGP-2. Based on our experience with previous 10 CFR 50.55a rule changes, and through their typical implementation through the normal 10-year ISI update process, we did not interpret the mie change to be immediately applicable to repair and replacement activities for Class MC and CC components. It was later learned through an NRC letter dated November 6,1996 to the Nuclear Energy Institute (NEI) that repairs and replacements were to be performed to the requirements of the 1992 Edition of the ASME Section XI Code with Addenda through 1992 as of the effective date of the rule change. To the best of our knowledge and belief, no repairs or replacements were performed to Class MC and CC components during the Fall 1996 maintenance / refueling outage at VEGP-2. Should we determine otherwise, GPC will advise the NRC of any such instances and will provide any such information through an addenda to this submittal, including the enclosed Owner's Report for ISI. The containment structure for VEGP-2 is subjected to the testing of 10 CFR Appendix J, the structures are included within the scope of the NRC Maintenance Rule, and there have been no significant incidents which would indicate any safety concern over its structural ability or ability to perform its intended function.
GeorgiaPower1 U. S. Nuclear Regulatory Commission LCV-0932 Page Four Five copies of the " Owner's Report for Inservice Inspection (Form NIS-1)" for ISI activities conducted during the Fall 1996 maintenance / refueling outage at VEGP-2 are provided for your review. Two copies of the subject report are being provided to the Regional Administrator for NRC Region II.
Should there be any questions in this regard, please contact this office.
Sincerely, f.hf C. K. McCoy CKM/JAE/jae
Enclosure:
" Owner's Report for Inservice Inspection (Form NIS-1)" for VEGP-2 Fiflh Maintenance / Refueling Outage (2RS), Fall 1996 xc: Georgia Power Company Mr. J. B. Beasley, Jr. (w/o encl.)
Mr. W. L. Burmeister (w/o encl.)
Mr. M. Sheibani (w/o encl.)
NORMS (w/ encl.)
U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator (w/ encl.)
Mr. C. R. Ogle, Senior Resident Inspector, Vogtle (w/ encl.)
Mr. L. L. Wheeler, Licensing Project Manager, NRR (w/ encl.)