ML20196E507
| ML20196E507 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/30/1998 |
| From: | Beasley J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20196E513 | List: |
| References | |
| LCV-1280, NUDOCS 9812040029 | |
| Download: ML20196E507 (6) | |
Text
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t J. Bernie Beesley, Jr., P.E.
Southern Nuclear Vice President Operating Company,Inc.
Vogtle Project 40 invemess Conter Parkway PD. Box 1295 Birmingham. Alabama 35201 Tel 2059921110 Fax 205.992 0403 SOUTHERN COMPANY Energy to Serve YourWorld' November 30, 1998 LCV-1280 Docket No.: 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,DC 20555 i
Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REVISION 8 TO FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM Southern Nuclear Operating Company (SNC), the licensee and operator of the Georgia Power Company (GPC)-owned Vogtle Electric Generating Plant (VEGP), submits herein ten copies of Revision 8 to the inservice inspection (ISI) program for VEGP Unit 2 (VEGP-2) for its first ten-year inservice inspection interval. The first ten-year inservice inspection interval would have been for the period from May 20,1989 through May 19, 1999, excluding a one year grace period allowed by 10 CFR 50.55a for completion of all
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required examinations. The enclosure provides Revision 8 to VEGP-2 ISI Program document ISI-P-014. The program in effect for the first ten-year inservice inspection interval was written to the requirements of the 1983 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, with gulfk f
Addenda through Summer 1983 except as noted below and where relief had been granted by the NRC. The enclosed document supersedes pc< as of the original ISI program previously submitted to the NRC.
By letter LCV-0861 dated August 16,1996, GPC, the former licensee for VEGP and sister company to SNC, the current licensee and operator of VEGP, requested NRC concurrence to update the VEGP-2 ISI Program for the Second Ten-Year Interval approximately two years ahead of schedule. The early update of the VEGP-2 ISI program coincided with the update for VEGP-1 and allowed the ISI programs for the two VEGP units to be performed to the same edition of the ASME Section XI Code, i.e., the 1989 Edition. In its November 27,1996 response to the GPC letter, the NRC indicated its concurrence with the early update for VEGP-2 so that the 1989 Edition of ASME
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9812040029 981130 PDR ADOCK 05000425 G
U. S. Nuclear Regulatory Commission LCV-1280 Page Two Section XI was acceptable for the ISI program during the adjusted interval for VEGP-2.
Because of the early update, the Spring 1998 maintenance / refueling outage at VEGP-2 became the first outage of the Second Ten-Year Interval for that particular unit.
Ilowever, since there are seven maintenance / refueling outages scheduled for the Second Ten-Year Interval between May 31,1997 and May 30,2007, none of the examinations performed during the subject outage were counted toward the Second Ten-Year examination requirements, except in the case of ASME Code Categories B-G-1, B-G-2, I
B-L-2, and B-M-2. The examination of those particular Code category components is I
required only once during the inspection interval when a component, e.g., a pump or valve, is disassembled for maintenance or repair. All of the remaining examinations and tests performed during the Spring 1998 maintenance / refueling outage at VEGP-2 were performed using the 1989 Edition of ASME Section XI and were credited to the First Ten-Year Interval thereby completing the examination and testing requirements for that interval. The results of those examinations performed during the Spring 1998 maintenance / refueling outage were reported to the NRC in our letter LCV-1222 dated July 13,1998.
The Revision 8 changes to VEGP-2 ISI Program document ISI-P-014 include the following:
Modification of existing Relief Requests RR-2, RR-5, RR-20, RR-30, RR-34, and RR-36, Withdrawal of Relief Requests RR-4 and RR-6, Addition of new Relief Requests RR-63 and RR-64, and e
Minor editorial changes.
e Relief Request RR-2 was previously approved by the NRC but approval was later revoked through rulemaking to 10 CFR 50.55a since they concerned ASME Section XI Category B-A, Item No.1.10 reactor pressure vessel (RPV) welds. The subject relief request is being re-submitted to the NRC for review and approval because full-Code examination coverage greater than ninety percent (90%)is not possible. A full-Code examination is considered to be one where examination coverage is greater than 90% as discussed in ASME Section XI Code Case N-460. The NRC has approved Code Case N-460 for use as documented in Regulatory Guide 1.147. Relief frorn both the Code requirements (addressed by this letter) and the regulatory requirements of 10 CFR 50.55a(g)(6)(ii)(A) are required for the RPV lower shell-to-bottom head weld addressed in Relief Request RR-2. Relief fmm the regulatory requirements is being submitted to the NRC under separate cover for review since the NRC staff has previously considered Code and regulatory issues as two separate issues.
U. S. Nuclear Regulatory Commission LCV-1280 Page Three Relief Request RR-4, which was previously reviewed and approved by the NRC, is withdrawn. This relief request involved ASME Section XI Category B-A, Item No.1.22 welds; specifically, RPV meridional welds 21201-V6-001-W21, W22, W23, and W24.
During inservice inspection activities, each of these welds had examination coverage greater than 90% thereby constituting a full-Code examination. As a result, the subject relief request is withdrawn.
Relief Request RR-5, which was previously reviewed and approved by the NRC, is revised to address examination limitations for RPV bottom head circumferential weld 21201-V6-001-WO7. This is an ASME Section XI Category B-A, item No.1.21 weld.
Examination coverage for this weld was limited such that greater than 90% coverage could not be achieved and therefore does not constitute a full-Code examination. This RPV bottom head circumferential weld is physically obstructed due to in-core flux instrumentation tubes. No alternate examination is practical.
Relief Request RR-6, which was previously reviewed and approved by the NRC, is withdrawn. This relief request involved ASME Section XI Category B-G-1, Item No.
B6.40; specifically, the volumetric examination of threads in the RPV flange. During inservice inspection activities, examination coverage of greater than 90% was achieved for the flange ligament examinations thereby constituting a full-Code examination. As a result, the subject relief request is withdrawn.
Relief Request RR-20 has been revised to add seven Class 1 piping welds from the Safety Injection System. Each weld is ASME Section XI Category B-J, Item No. B9.11 and i ncl udes, 21204-024-16, 21204-025-21, 21204-025-22, 21204-044-1, 21204-044-13, 21204-045-1, and 21204-045-28. Examination coverage for these welds was limited during their volumetric examination (ultrasonic) such that greater than 90% coverage could not be achieved and, therefore, does not constitute a full-Code examination. The surface examination that was performed resulted in no recordable indications being observed for any of the seven welds. In addition, Relief Request RR-20 was revised due to an increase in the examinatior, coverage for weld 21204-024-15 and to better address the restriction when it was ultrasonically examined inservice.
Relief Request RR-30 has been revised to add two Class 2 heat exchanger nozzle-to-shell welds from the Residual Heat Removal System. Each weld is ASME Section XI Category C-B, Item No. C2.21 and includes 21205-E6-002-WO4 and 21205-E6-002-WO5. Examination coverage for these welds was limited during their volumetric (ultrasonic) examination such that greater than 90% coverage could not be achieved and, therefore, does not constitute a full-Code examination. The surface examination that was performed resulted in no recordable indications being observed for the two welds.
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U. S. Nuclear Regulatory Commission LCV-1280 Page Four 4
Relief Request RR-34 has been revised to add five additional Class 2 piping welds from the Safety Injection and Chemical and Volume Control systems. Each weld is ASME Section XI Category C-F-1, Item No. C5.11 and includes 21204-006-2,21204-122-6, 21208-137-13,21208-139-13, and 21208-411-24. Examination coverage for these welds was limited during their volumetric examination (ultrasonic) such that greater than 90%
coverage could not be achieved and, therefore, does not constitute a full-Code examination. The surface examination that was performed resulted in no recordable indications being observed for any of the five welds.
Relief Request RR-36 has been revised to add three additional Class 2 piping welds from the Nuclear Service Cooling Water System. Each weld is greater than 4 inches in diameter but has a wall thickness less than 0.5 inch. Normally, such welds are exempt from examination per ASME Section XI,IWC-1220(b). However, as a condition for licensing, GPC agreed to perform volumetric (ultrasonic) and surface examinations on a percentage of these type welds. During ultrasonic examination of welds 21202-216-59, 21202-225-1, and 21202-229-2, physical limitations prevented examination coverage greater than 90%. No surface examination was performed at the time the affected three welds were ultrasonically examined. Although there is no Code requirement that these welds be examined, SNC will examine welds 21202-216-59,21202-225-1, and 21202-l 229-2 by surface means during the Fall 1999 maintenance / refueling outage which is currently scheduled to begin in October 1999.
New Relief Request RR-63 requests relief from the examination coverage requirements for RPV welds 21201-V6-001-W25,21201-V6-001-W28,21201-V6-001-W29, and l
21201-V6-001-W32 which are RPV vessel-to-outlet nozzle welds. These welds are l
ASME Section XI Category B-D, Item No. B3.90. In each case, examination coverage was limited to less than 90% due to physical obstructions created by the RPV nozzles thereby preventing a full-Code examination. No alternate examinations are practical.
New Relief Request RR-64 has been added resulting from a concern identified by the l
Authorized Nuclear Inservice inspector (ANil) who found that any repairs or piping and l
components 1-inch nominal pipe size (NPS) and smaller may not have been properly l
documented, e.g., use of ASME Form NIS-2, " Owner's Report for Repairs and l
Replacements", due to a misunderstanding of the ASME Section XI Code requirements.
l This concern was previously reported to the NRC in GPC letter LCV-0932 dated January 8,1997. Our review indicated that both VEGP units appear to have been in non-compliance for any such repairs since the beginning of commercial operation through October 1996 when the problem was identified and corrected. A similar relief request was submitted for VEGP-1 by our letter LCV-1124 dated December 1,1997. It is our position that no compensating increase in the level of quality or safety would be achieved
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o U. S. Nuclear Regulatory Commission LCV-1280 Page Five if the Code requirements were imposed retroactively for the period of time in question especially in light of changes to the Code which equalize the repair and replacement requirements for small items. Subsequent to the identification of this potential non-compliance, plant personnel responsible for repair activities have been instructed that repairs, irrespective of the size of the piping and components involved, were to be properly documented (including use of ASME Form NIS-2), the repair / replacement procedure was revised, and a training course was held.
The remaining changes in Revision 8 to the VEGP-2 ISI Program for the First Ten-Year ISI Interval are editorial in nature. Specifically, these include, but are not limited to, changing references, where appropriate, from GPC to SNC due to the transfer of the plant operating licenses in 1997. Incorporation of the editorial changes does not change the intent and scope of the ISI Program for VEGP-2 for the First Ten-Year ISI Interval.
Please refer to the enclosed ISI program revision for details on the changes described herein. A summary of changes resulting from Revision 8 to the VEGP-2 ISI Program is provided in the enclosure and precedes the affected document pages.
The NRC is requested to review and grant approval of the enclosed ISI program revision in accordance with the requirements of 10 CFR 50.55a as detailed in the affected relief requests. The subject changes do not affect public health and safety.
Should there be any questions in this regard, please contact this of fice.
Sincerely, b
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6v
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.( B. Beasley%
, Jr.
j JBB/JAE/jac i
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Enclosure:
Revision 8 to VEGP-2 First Ten-Year Interval ISI Program document ISI-P-014 xc: (See next page for distribution) i i
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U. S. Nuclear Regulatory Commission
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xc: Southern Nuclear Operating Company Mr. W. L. Burmeister (w/o enclosure) -
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Mr. J. T. Gasser (w/o enclosure) l l
Mr. M. Sheibani (w/ enclosure) l i:
SNC Document Management (w/ enclosure) t I
t U. S. Nuclear Regulatory Commission j
i' Mr. D. H. JafTe, Senior Project Manager, NRR (w/ enclosure)
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Mr. L. A. Reyes, Regional Administrator (w/ enclosure)
Mr. J. Zeiler, Senior Resident Inspector, Vogtle (w/ enclosure) i I
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