ML20136A765

Forwards Request for Addl Info Re Inservice Insp Program for Second 10-yr Interval.Response Requested within 30 Days of Ltr Receipt

ML20136A765
Person / Time
Site:	Hatch
Issue date:	12/23/1985
From:	Rivenbark G Office of Nuclear Reactor Regulation
To:	Beckham J GEORGIA POWER CO.
References
TAC-56049, TAC-59542, NUDOCS 8601020268
Download: ML20136A765 (15)

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,k Docket No.: 50-321 366 Mr. J. T. Beckham, Jr. DEC 2 31985 Vice President, Nuclear Generation Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION INSERVICE-INSPECTION PROGRAM Re: Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 We are reviewing the Inservice Inspection Program for the second ten year interval of operation of Hatch Units 1 and 2 that was submitted by your letter dated July 25, 1985. In order to complete this review, we need the additional information described in the enclosure. You are requested to provide a written response, submitting the requested information, within 30 days of receipt of this letter.

The reporting and recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under.P.L.96-511.

Sincerely, o

. OriginnI signeny George Rivenbark, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Enclosure:

Request for Additional Information cc: See next page DISTRIBUTION:

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PD Plant-specife (Hatch 1 & 2)

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Mr. J. T. Beckham, Jr. ~

Edwin I. Hatch Nuclear Plant,

, . Georgia Power Company -

Units Nos. I and 2 cc:

G. F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge

, 1800 M Street, N.W.

, Washington, D.C. 20036 Mr. L. T.~ Gucwa

-Engineering Department Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr. H. C. Nix, Jr. , General Manager Edwin I. Hatch Nuclear Plant Georgia Power Company P. O. Box 442 i Baxley, Georgia 31513 Mr. Louis B. Long li Southern Company Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 4

Resident Inspector U.S. Nuclear Regulatory Commission Route 1.- P. O. Box 279 Baxley, Georgia 31513

Regional Administrator, Region II U.S. Nuclear Regulatory Commission, 101 Marietta Street, Suite 3100 Atlanta, Georiga 30303 Mr. Charles H. Badger Office of Planning and Budget Room 610 c 270 Washington Street, S.W.

Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Commissioner Department of Natural Resources 270 Washington Street, N.W.

Atlanta, Georgia 30334 Chairman Appling County Commissioners County Courthouse Baxley, Georgia 31513 i:

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ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM i

EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 By letter dated June 25,1985,(1) from L. T. Gucwt (Georgia Power) to J. F.

Stolz (NRC), you submitted your latest proposed insarvice inspection (ISI) program for Edwin I. Hatch Nuclear Plant Units 1 r.nd 2 second 10 year inspection interval. We will be evaluating your relief requests accompanying your ISI program and using documents referenced in it and other documents (see attached document review list). If there are any additional relief requests i

or supporting information you wish to be considered, please provide us with copies. If they have been previously furnished to the NRC, please document

.by reference.

Fourteen of the following 15 questions address tha second 10 year interval relief requests for Edwin I. Hatch Nuclear Plant Units 1 and 2. The fifteenth question requests information regarding fulfillment of the first 10 year interval examination requirements.

1. You have requested relief (ISI Plan Section 2.1.1) from the requirements of performing a 100% volumetric examination of reactor pressure vessel and closure head welds, item numbers Bl.11, Bl.12, B1,.21, and 81.22 of Table IWB-2500-1. The contents of your relief request indicate that you may be attempting to examine the accessible portions of all vessel and head welds.

The 1980 Edition with Addenda through Winter 1981 requires that only one weld from each of the Code Item Numbers listed above be volumetrically i

examined during the second inspection interval.

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Please prov.ide the following information:

(a) Identify one weld for each code item number to be examined; also specify the percentage of the weld accessible for examination.

Give a complete description of the reason why 100% of the weld length cannot be examined (i.e. , describe physical limitations).

(b) For welds listed in (a) above that will not receive a 100% exam-ination, define additional welds of the same code item number (B1.11 and 81.12 must be beltline welds) that can be examined as an alternative to the code requirement. Choose enough welds such that the total weld length examined, to the extent of available welds, equals the length of the weld defined in (a) above.

(c) If enough welds are not available for a given Code item, identify additional similar welds (i.e., shell welds outside of bel'tline region, or closure head welds in place of bottom head welds) that can be examined to the extent that (1) either the length of examined welds equals the length of the weld requiring examination or (2) there are no more accessible portions of similar welds available.

2. You have requested relief (ISI Plan Section 2.1.2) from the requirement of performing an ultrasonic examination using a straight-beam transducer on the reactor pressure vessel and closure head welds'. Subparagraph

, T-441.4.3 of Article 4 of ASME Section V requires that, prior to the angle beam examination, the base material through which the angle beam will travel shall be scanned with a straight-beam transducer to detect laminar reflectors which might affect the angle beam results. Yourjustification that the size of the laminar reflectors will not change from preservice

examination and that the scans will result in additional radiation exposure requires clarification. Please supply the following information:

(a) Provide analyses or studies of the laminar indications, which justify your statement that the laminar reflectors will not change.

(b) Confirm that the laminar reflectors were scanned and recorded during preservice inspectiot: 'n accordance with the procedure consistent with that required by the 1980 Edition with Addenda through Winter 1981.

(c) Provide an estimate of the personnel radiation exposure for the straight beam scan. Also provide an estimate of the radiation ex-posure for the 45- and 60-degree scans.

3. You have requested relief (ISI Plan Section 2.1.3) from the requirement of performing a 100% volumetric examination of certain nozzle-to-vessel welds and nozzle inside radius sections. Please provide the following informa-tion:

(a) For each nozzle weld or inside radius section requiring relief, give the estimated percentage of the volume that will be examined.

(b) Provide sketches of the nozzles for which relief is requested, with enough dimensional detail, including ultrasonic transducer dimensions, to enable verification of the interference causing the examination difficulty.

(c) Address scan heads and alternative scan angles to enable a more complete examination.

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4. You have requested relief (ISI Plan Section 2.1.5) from performing a surface examination on the inside surface of the reactor vessel support skirt weld. Your relief justification, physical access restricted by high radiation and.CRD housing obstructions, requires clarification.

(a) Provide an estimate of the total radiation exposure for the exam-ination for which relief is requested.

(b) Provide sketches that show the physical obstructions preventing the surface examination of the weld. Include enough dimensional detail to enable a complete evaluation of the interference.

5. You have requested relief (ISI Plan Section 2.1.6) from performing the required surface examination of certain reactor pressure vessel (RPV) nozzle-to-safe end welds. In order for us to evaluate the relief request, please provide a description, sketches where applicable, of the inter-ference affecting their examination. This information is not needed for the 2-in. RPV bottom head drain nozzle-to-safe end weld since it is exempted from examination.

6. You have requested relief (ISI Plan Section 2.1.8) from performing visual examination of the internal pressure boundary of Class 1 pumps and valves. Your basis for relief states that "during routine maintenance, the valve body and the pump casing internal surfaces hre usually examined.

Many of the valves, particularly the containment isolation valves are dis-assembled for maintenance of leak-tightness." Please provide the fol-lowing information:

(a) Identify the Class 1 pumps and valves that do not have routine maintenance.

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(b) Of.the other pumps and valves, identify which do have routine maintenance and at what frequency.

(c) Does the routine maintenance of any of the above valves require off-loading the core and draining the RPV prior to disassembly?

Enumerate these.

(d) Provide an estimate of the number of man-rems required to perform routine maintenance or required inspections on various types of pumps and valves.

7. You have requested relief (ISI Plan Section 2.1.9) from performing the required volumetric or surface examination of the pressure retaining welds in 10% of the peripheral control rod drive housings. For us to evaluate the possibility of these welds meeting the Code exemption criteria of IWB-1220(a), please provide the following information for both Hatch units:

(a) The maximum leakage rate under normal plant operating conditions resulting from a CRD housing failure.

(b) The total capacity of makeup systems which are operable from on-site emergency power.

8. You have requested relief (ISI Plan Section 3.1.1) from the requirements of performing a 100% volumetric examination of the residual heat removal (RHR) heat exchanger Class 2 vessel shell, head, and tubesheet-to-shell circumferential welds. Please provide the following information:

(a) Define the percentage of the volumetric examination for each weld that will receive a partial volumetric examination.

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(b) Of,the other pumps and valves, identify which do have routine maintenance and at what frequency.

(c) Does the routine maintenance of any of the above valves require off-loading the core and draining the RPV prior to disassembly?

Enumerate these.

(d) Provide an estimate of the number of man-rems required to perform routine maintenance or required inspections on various types of pumps and valves

7. You have requested relief (ISI Plan Section 2.1.9) from performing the required volumetric or surface examination of the pressure-retaining welds in 10% of the peripheral control rod drive housings. For us to evaluate the possibility of these welds meeting the Code exemption criteria of IWB-1220(a), please provide the following information for both Hatch units:

(a) The maximum leakage rate ~ under normal plant operating conditions resulting from a CR0 housing failure.

(b) The total capacity of makeup systems which are operable from on-site emergency power.

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8. You have requested relief (ISI Plan Section 3.1.1) from the requirements of performing a 100% volumetric examination of the residual heat removal (RHR) heat exchanger Class 2 vessel shell, head, and tubesheet-to-shell circumferential welds. Please provide the following information:

(a) Define the percentage of the-volumetric examination for each weld that will receive a partial volumetric examination.

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(a) The Code allows surface examinations of Class 2 pump casing welds to be performed from the inside or outside surface of the pump.

Is there a reason why the examination can not be performed from the outside surface?

(b) If the examination cannot be performed from the outside, you should provide an estimate of the total radiation exposure received in performing the required examination from the inside surface of the pump.

11. You have requested relief (ISI Plan Section 4.1.2) from the requirements of performing pressure testing on Class 3 buried piping. You justified 4 ,

this relief request because the service water systems were designed with-out including provisions for testing buried piping as required by Para-graph IWA-5244 of the Code. Please provide the following information:

(a) Define which service water systems require relief, including their Table IWD-2500-1 examination category.

(b) Provide a system description of each system from (a) above, with enough detail (include P& ids) to evaluate your relief request.

(c) Paragraph IWA-5244 allows testing methods for three different con-figurations of buried piping,.i.e., (a) non-redundant-isolable, (b) redundant-nonisolable, and (c) non redundant non-isolable.

State the configuration for each system for which relief is requested.

(d) Address any alternatives other than system functional testing that would enable testing of buried components.

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12. You have requested relief (ISI Plan Section 4.1.3) from the requirement of performing a hydrostatic test of portions of the plant service water system that require isolation using 10 in. or larger butterfly valves.

Please provide the following information:

(a) Provide a marked P&ID of the plant service water system showing the portions of the system for which relief is requested.

(b) Address any alternate test that would allow testing of the service water system at greater than normal operating pressure.

13. You have requested relief (ISI Plan Section 5.1.1) from the requirement of subparagraph IWF-3410(a)(5), that spring supports and snubbers operate only with proper hot or cold positions. Your relief justification, that there are no exact design positions on the scales of the spring and snubber supports, needs further clarification. It is recognized that component standard spring and snubber supports will not have exact hot or cold design positions marked for your particular application. However, these design positions should be available from the piping stress analysis reports. Where the hot or cold positions are not available, please pro-vide the reason why they are not.

14. You have requested relief (ISI Plan Section 8.1.2) to move up the start date of the second 10 year interval for Hatch 2 to January 1,1986. Your relief request states that the Hatch 2 second inspection period (80 months) ends January 5, 1986. You stated that this will nearly coincide with the start date of the second 10 year interval for Hatch 1. Please address the following concerning Hatch 1 and 2 interval dates:

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(a) By. letter dated November 10, 1981,2 you requested an extension for the inservice inspection interval for Unit 1. Approval of this request was given by the NRC on November 23, 1981,3 resulting in the Unit 1 interval extending to May 5, 1986. If there has been subsequent NRC-GP correspondence concerning the Hatch-1 interval re-verting back to January 1, 1986, please provide references.

(b) Your letter dated June 25, 1985,1 transmitting Hatch Units 1 and 2 second interval ISI plans, states that the first 10 year interval for Hatch 2 will end in September 1989. This interval end date would result in a second inservice inspection period (80 months end date of May 1986, rather than January 1986, as stated in the plan relief request. Please address the difference in interval dates for Hatch Unit 2 as given in the Reference 1 letter and the plan relief request.

15. Under the terms of subparagraph 10 CFR 50.55a(g)(5)(iv), where an exam-ination or test is determined to be impractical by the licensee but has not been previously included in the ISI program, the basis for such determinations shall be demonstrated to the satisfaction of the NRC not later than 12 months after the expiration of the interval. Please review your first-interval submittals (ir -luding Reference 4) with this require-ment in mind and submit relief requests as necessary.

References ,

1. L. T. Gucwa (GPC) to J. F. Stolz (NRC); Submittal of Second ISI Interval for Hatch Units 1 and 2, June 25, 1985.

2. J. T. Beckham (GPC) to Director NRR (NRC); ISI Period Extension Request, Hatch Nuclear Station, Unit 1, November 10, 1981.

3. J. F. Stolz (NRC) to J. T. Beckham (GPC); Approval of ISI Extension Request, Hatch Nuclear Station, Unit 1, November 23, 1981.

4. L. T. Gucwa (GPC) to J. F. Stolz (NRC), Hatch Unit 1 Inservice Inspection Relief Requests, NED-85-508, July 18, 1985.

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• g REVIEW DOCUMENT RECORD .

Unit (s) Hatch 1 and 2 (Page1) .

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_. 10 Msmber and Date Author - Recipient Type ,

Subject Matter Mi s'c.

Advises of intention to develop first interval ,

11/15/76 GPC to NRC Ltr ISI program ,

11/26/76 Lear (NRC) to Mit.chell (GPC) Ltr Guidance _

1/7/77 NBC to GPC Ltr Guidance _

5tatus of first interva) 151 program and 6/7/77 Whitmer (GPC) to Stolz (NRC) Ltr request for preservice inspection i Rejects request for " reduction in preservice 7/7/77 Stolz (NRC) to Whitmer (GPC) Ltr 1 r,spection" RAI Preservice and first interval inservice questior s 12/19/77 Stolz (NRC) to Whitmer (GPC)

- First interval 151 and IST program ..

8/3/78 Whitmer (GPC) to NRR (NRC) Subm. submitted (74575 Code) for Unit 1-First interval 151 program (submitted with

, 9/21/78 GPC to NRC Subn. FSAR) for Unit 2 t Lyon (PNL) to Cheng (NRC) RAI RAI Initial questions on 8/3/78 submittal j 10/12/78 .

1/24/79 Whitmer (GPC) to'NRR (NRC) Ltr Change Sprina'79 inspection 2nd 40-month oeriod Ippolito (NRC) to Whitmer (GPC) Ltr First interval IS! Mtg (2/22/79) summary ~

3/28/79 6/06/79 Whitmer (GPC) to NRR (NRC) - Subm. First interval ISI program Amendment #1 8/28/79 Lyon (PNL) to NRC SER Draft SER ,

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Eisenhut to Schroeder (NRC) Hemo Recommends DOR Review Units 1 and 2 together 9/14/79 _

1/31/80 Taylor (PNL) to Johnson (NRC) SER 8f f8 e va Widner (GPC) to Director NRR (NRC) Subm. Additional information and relief requests 5/1/80

• First Interval Unit 1 ISI program Amendment #2 1/2'7/81 Widner (GPC) to NRR (NRC) Subm. (replaces 6/6/79) 74575 Code 2/3'/81 PNL to Kennedy (NRC) RAI Request for additional information 11/10/81 Beckham (GPC) to NRC Ltr Request to extend first interval ISI - Unit 1

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REVIEW DOCUMENT RECORD ..

I Unit (s) Hatch I and 2 (Page 2) ,.

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ID Mimber and Misc.

Author - Recipient Type Subject Matter Date , _

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Request f or extension of examination period 11/18/81 Beckham (GPC) to NRC Ltr for supports .

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Ltr Relief request

! 11/18/81 Beckham (GPC) to Director (NRC) 11/23/81 Stolz (NRC) to Beckham (GPC) Ltr Grants extension of First Interval ISI - Unit 1 f First interval 151 of Class 1,2,3 Supports for

! 3/2/82 Beckham (GPC) to NRC Ltr Unit 2 Ltr Request-for relief from hydrostatic test requirenents 3/11/82 Widner (GPC) to NRC

! 3/12/82 Stolz (NRC) to Beckham (GPC) RAI First Interval ISI - RAI on Unit 1 1

4/6/82 Stolz (NRC) to Beckham (GPC) RAI First. Interval ISI - RAI on Unit 2 Stolz (NRC) to Beckham (GPC) Ltr Hydrostatic test on procedure relief .

4/7/82 Widner (GPC) to NRC Ltr Response to RAI on First Interval ISI - Units 1 and 2 i

. 6/11/82 Technical Evaluation Report of Hatch Units 1 and 2; 9/2/82 SAIC to NRC TER First Interval ISI Gucwa (GPC) to Stolz (NRC) Ltr Delay of updating ISI program to 1980 Edii. ion 1/7/83

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Blake (NRC) to GPC Report I&E inspection report

6/24/83 Transmittal of SER on first interval ISI for l 7/29/83 Stolz (NRC) to Beckham (GPC) Ltr Hatch Units 1 and 2 Beckham (GPC) to Stolz (NRC) Ltr Second interval ISI for Hatch Units 1 and 2 8/12/83

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Gucwa (GPC) to Stolz (NRC) Ltr Notifying mid-January update to 1980 Edition j 1/9/84

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Blake (.RC) to GPC Report I&E inspection report 10/30/84 N ,

l Blake (NRC) to GPC Report I&E inspection report l 11/15/84 Ltr Submittal of Unit I report on IGSCC 12/10/84 Gucwa (GPC) to Stolz (NRC) j _._

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REVIEW DOCUMENT RECORD .

Unit (s) Hatch 1 and 2 (Page 3) l 10 kmber and Date Author - Recipient Type

• Subject Matter Mfss.

i' 4/22/85 Blake (NRC) to GPC Report ISE Inspection Report 6/25/85 Gucwa (GPC) to Stolz (NRC) Ltr. Revised 2nd Interval ISI for Hatch Units 1 and 2 7/18/85 Gucwa (GPC) to Stolz (NRC) Ltr. Hatch Unit 1 ISI relief requests 8/5/85 Rivenbark (NRC) to Beckham (GPC) Ltr. License Amendments Re: Snubber TS i

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