ML20151J121
| ML20151J121 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/30/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0968-B, LCV-968-B, NUDOCS 9708050085 | |
| Download: ML20151J121 (7) | |
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C. K. McCoy -
S:uth:rn Nucirr Vice President Operating Company. Inc.
Vogtle Project 40Invemess Center Parkway P.O. Box 1295 Birmingham. Alabama 35201 Tel 205 992.7122 Fax 205.992.0403 k
SOUTHERN L COMPANY Energy:o Serve hurWorld" LCV-0968-B July 30, 1997
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Docket Nos.: 50 424, 50-425 3
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT CONTAINMENT INSPECTION RULE -
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION By letter LCV-0968 dated February 17,1997, Georgia Power Company (the former licensee and operator of Vogtle Electric Generating Plant (VEGP), Units 1 and 2, and sister company to Southern Nuclear Operating Company (SNC), the current licensee and operator of VEGP) requested an exemption from the commencement date of the Containment Inspection Rule repair and replacement requirements for a period of one year from the effective date of the rulemaking. This would make the commencement date for I
the repair and replacement a-tivities covered by the rulemaking to 10 CFR 50.55a to be September 9,1997. The exemption was requested in order to allow the licensee time to evaluate the changes necessary to implement the rule with respect to repair ud replacement activities, as well as actually making the necessary changes to affected plant programs, plans, and procedures. Subsequently, by !etter dated May 27,1997, the NRC staff requested additional information on the request for relief. The NRC questions and the SNC responses thereto are provided in the enclosure to this letter.
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Southern Nuclear Operating Company is in the process of evaluating the rule change in an effort to determine the overall impact on plant administrative and implementation Ol procedures for repair and replacement activities. Because of the complexity of these new requirements and the programs, plans, and procedures which they affect, immediate implementation can not reasonably be expected. Accordingly, the NRC staff recognized in a letter dated November 6,1996 from Gus Lainas of the NRC to Alex Marion of the 9700050005 970730 111llllllll111111lll1111111llllllllE PDR ADOCK 05000424 lil,Illil,I..ll,Illijmif mi Jidlu,illi,Il p
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U. S. Nuclear Regulatory Commission LCV-0968-B Page Two Nuclear Energy Institute that " licensees may require a period of time to develop and implement procedures for repair and replacement which meet the requirements of Subsections IWE and IWL" Further, the NRC letter of November 6,1996 indicates that "In general, relief requests from compliance with the repair and replacement requirements of Subsections IWE and IWL for a period of one year from September 9, J96 would appear to be reasonable" Based on the foregoing, relief was requested such that we be allowed a reasonable period of time to investigate, develop, and implement the necessary programs, plans, and procedures to implement any repairs and replacements as required by Subsections IWE and IWL of the 1992 Edition of the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, with 1992 Addenda.
Should there be any questions in this regard, please contact this office.
Sincerely, (1.W C. K. McCoy CKM/JAE/jae
Enclosure:
Containment Inspection Rule - Response to Request for Additional Information xc: Soul!Lern Nuclear Operating Company Mr. J. B. Beasley, Jr. (w/o enclosure)
Mr. W. L. Burmeister (w/o enclosure)
Mr. M. Sheibani (w/ enclosure)
NORMS (w/ enclosure)
U. S. Nuclear Regulatory Commission Mr. C. R. Ogle, Senior Resident Inspector, Vogtle Mr. L. A. Reyes, Regional Administrator j
Mr. L. L. Wheeler, Senior Project Manager, NRR l
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ENCLOSURE TO SOUTHERN NUCLEAR OPERATING COMPANY LETTER LCV-0968-B VOGTLE ELECTRIC GENERATING PLANT CONTAINMENT INSPECTION RULE -
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION In its letter of May 27,1997, the NRC requested that Southern Nuclear Operating Company (SNC) provide information for Vogtle Electric Generating Plant (VEGP) in response to the two NRC items which are quoted herein. The SNC response follows each of the NRC items.
NRC Item 1 "A description of the difliculties associated with the implementation of the amended mie for repair and replacement activities, compared to the procedures currently used at VEGP for these activities" SNC Response to NRC Item 1 At the time the Containment Inspection Rule was invoked by the NRC through a revision to 10 CFR 50.55a, i.e., September 9,1996, VEGP was nearing the end ofits first ten-year inservice inspection interval. With the then impending update to a later version of the ASME Section 'XI Code, activities were either being planned or were in progress for converting the Inservice Inspection (ISI) Program from the requirements of the 1983 Edition of ASME Section XI with Summer 1983 Addenda to the 1989 Edition of ASME Section XI. The ISI Program historically has included requirements for only j
Code Class 1,2, and 3 components and their supports. The classification of systems and their components is based on requirements in 10 CFR 50.55a and NRC Regulatory Guide 1.26. With the rulemaking, requirements for Code Class MC and CC components were being invoked for the first time by the NRC with respect to requirements identified in ASME Section XI. It was mandated that programs and plans also be developed for Code Class MC and CC components using an even later version of the ASME Section XI Code; specifically, the 1992 Edition with 1992 Addenda. Certain additional conditions were also applied by the NRC, especially for Code Class CC components, and are identified in 10 CFR 50.55a.
Because of the Containment inspection Rule, an additional version of the ASME Section XI Code has had to be invoked and requires review and evaluation so that they can be E-1
j VOGTLE ELECTRIC GENERATING PLANT CONTAINMENT INSPECTION RULE -
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION (continued)
SNC Response to NRC Item 1 (continued) properly incorporated into programs and plans, including those required for repair and 1
replacement of components. The immediate implementation of these additional requirements with respect to repairs and replacements, coupled with activities that were either planned or in progress for updating the VEGP ISI Program have presented a hardship due to the limited personnel resources available which are involved with both programs. As a result, it was requested that an extension of one (1) year retroactive to the date of the rulemaking be granted in order to develop and implement procedures for repair and replacement of Code Class MC and CC components. Implementation of the rule requires many activities and includes, but is not limited to, identification and re-classification ofISI boundaries for engineering, design, and planning personnel (drawing development, preparation, and issuance) and revision of applicable plant programs and procedures related to maintenance and work planning. Because there are certain aspects of the 1992 Edition of ASME Section XI with 1992 Addenda which we do not believe to be in our better interest, we have chosen not to update the repair and replacement program requirements for all code classes to that edition / addenda of ASME Section XI.
i Further, had we chosen to do so, a request for relief would have had to be submitted to the NRC for its review and approval since the use of the 1992 Edition of ASME Section XI with 1992 Addenda has not been approved by the NRC for Code Classes 1,2, and 3 components and supports. Therefore, we have found it necessary to have two separate repair and replacement programs, one for Code Class 1,2, and 3 components and supports and the other for Code Class MC and CC components. However, we may consolidate the Code Class MC repair / replacement requirements with the program for i
Code Class 1,2, and 3 components and supports but note that any necessary repairs or replacements of Code Class MC would be performed using the requirements of the 1992 Edition of ASME Section XI with 1992 Addenda. Code Class CC components would also be repaired or replaced using that same code edition / addenda. Repair and replacement of Code Class 1,2, and 3 components and their supports would Se performed using the requirements of the 1989 Edition of ASME Section XI.
Any repairs or replacements of Code Class MC and CC components prior to the invoking of the Containment inspection Rule would have been performed in accordance with the original construction code, design specification, or as directed by engineering. Fmther, the VEGP Nuclear Plant Management Information System (NPMIS), a computer-br. sed tool, is available to Maintenance personnel for the identification of special requirements E-2
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VOGTLE ELECTRIC GENERATING PLANT CONTAINMENT INSPECTION RULE -
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION (continued)
SNC Response to NRC Item 1 (continued) relative to a given component, e.g., Integrated Leak Rate Testing (ILRT), Local Leak Rate Testing (LLRT). In the case of Code Class 1,2, and 3 components and their supports, maintenance work orders are processed through the Maintenance Code and Welding Group so that any necessary ASME Section XI travelers that may be required, including documentation of repairs / replacements of code-class components, i.e., ASME Form NIS-2," Owner's Report for Repairs and Replacements", can be initiated.
It is our belief that the ILRT, LLRT, and Tendon Testing programs comply with 10 CFR 50, Appendix B requirements and can adequately identify any need for repairs and replacements which might result from any abnormal condition. Further, the containment structures at VEGP are included in the scope of the Maintenance Rule (10 CFR 50.65) as found in the VEGP Maintenance Rule Structural Monitoring Program.
Until repair and replacement procedures are in place to implement the requirements of the 1992 Edition of ASME Section XI with 1992 Addenda for Code Class MC and CC components, VEGP Maintenance Department management has been provided with a mark-up of the existing ASME Section XI Repairs / Replacements Procedure. Although marked-up to reflect the requirements of the 1989 Edition of ASME Section XI for Code Class 1,2, and 3 components and their supports, a " cautionary note" has been included alerting personnel that repairs and replacements of containment-related components that are Code Class MC and CC components are to be performed to the 1992 Edition of ASME Section XI with 1992 Addenda. In addition, the " cautionary note" indicates that for assistance with any such repairs or replacements that either Corporate VEGP Project Maintenance, Corporate Inspection and Testing Services (ITS), or the on-site ITS representative be contacted. Further, to assist in their understanding of the code edition / addenda differences, summaries obtained from an engineering firm were provided which identify the changes in repair and replacement requirements between the 1983 Winter Addenda and the 1988 Addenda, and the 1989 Addenda and 1992 Addenda of ASME Section XI.
It is our belief that the actions taken or those which are in progress meet the intent of the Containment Inspection Rule with respect to repairs and replacements. We currently expect to have the necessary procedures developed and in place to support VEGP-1 Maintencnce/ Refueling Outage IR7 scheduled to begin September 7,1997. Except for E-3
VOGTLE ELECTRIC GENERATING PLANT CONTAINMENT INSPECTION RULE -
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION (continued)
SNC Response to NRC Item 1 (continued)
LLRTs which are typically performed each maintenance / refueling outage, no containment testing, i.e., ILRTs, Tendon Testing, is planned for the upcoming outage. The first inspections required for complying with the September 9,2001 requirement of the Containment Inspection Rule are planned for the 1999 maintenance / refueling outages at the two VEGP units. Assignments have been made to develop the necessary programs and plans for the inspection of Code Class MC and CC components. These inspection programs and plans are expected to be completed by September 9,1998, in order to support the 1999 maintenance / refueling cutages.
NRC Item 2 1
"An integrated summary of the proposed alternative that would provide adequate levels of quality and safety. Describe the requirements and procedures to be used for repair and replacement activities for the containment post-tensioning system and the concrete surfaces and liner plates of the prestressed concrete containments" SNC Resnonse to NRC Item 2 No repairs or replacements of Code Class MC and CC components, including concrete, are expected prior to the commencement of VEGP-1 Maintenance / Refueling Outage IR7 currently scheduled to begin September 7,1997. In the event that any repair or replacement of components involving these code classes either prior to, during, or subsequent to the upcoming maintenance / refueling outage, they will be performed using the requirements ofIWA-4000, IWE-4000, IWE-7000, IWL-4000, and IWL-7000 found 2
in the 1992 Edition of ASME Section XI with 1992 Addenda. Further, we have available personnel who qualify as either a " Responsible Engineer" or a " Registered Professional Engineer" and are experienced in the design, inspection, and testing of containments.
Previously, should it have been necessary to perform any repair or replacement of Code Class MC and CC components prior to the invoking of the Containment Inspection Rule, it is likely that they would have been performed using the requirements of the original construction code, design specification, or as directed by a responsible engineer. Any repair / replacement activities will be performed using various procedures and/or programs which establish control on the planning, work control, quality assurance / quality control, and implementation of work packages, such as:
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1 VOGTLE ELECTRIC GENERATING PLANT CONTAINMENT INSPECTION RULE -
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION (continued)
SNC Response to NRC Item 2 (continued) 00201-C Quality Control Inspection Program, 00250-C Control of Special Processes, i
00350-C Work Request Program, 29402-C Maintenance Work Request Processmg, VEGP Quality Assurance Program, and GEN-25, Welding Program, Section 3, ASME Section XI Repairs / Replacements.
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In addition and as noted in the response to Item 1 above, VEGP Maintenance Department management has been provided a mark-up of the existing ASME Section XI Repairs / Replacements Procedure. Although marked-up to reflect the requirements of the 1989 Edition of ASME Section XI for Code Class 1,2, and 3 components and their supports, a " cautionary note" has been included alerting personnel that repairs and replacements of containment-related components that are Code Class MC and CC components are to be performed to the 1992 Edition of ASME Section XI with 1992 Addenda. In addition, the " cautionary note" indicates that for assistance with any such repairs or replacements that either Corporate VEGP Project Maintenance, Corporate Inspection and Testing Services (ITS), or the on-site ITS representative be contacted.
Further, to assist in their understanding of the code edition / addenda differences, summaries obtained from an engineering firm were provided which identify the changes in repair and replacement requirements between the 1983 Winter Addenda and the 1988 Addenda, and the 1989 Addenda and 1992 Addenda of ASME Section XI.
l These actions are believed to be adequate pending development and implementation of new or revised procedures to specifically address the repair and replacement of any containment-related components that are Code Class MC and CC.
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