ML20196E522
| ML20196E522 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/01/1998 |
| From: | SOUTHERN NUCLEAR OPERATING CO. |
| To: | |
| Shared Package | |
| ML20196E513 | List: |
| References | |
| ISI-P-014-R08, ISI-P-14-R8, NUDOCS 9812040032 | |
| Download: ML20196E522 (48) | |
Text
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INSERVICEINSPECTION PROGRAM (ISI-P-014)
FOR' GEORGIA POWER COMPANY VOGTLE ELECTRIC GENERATING PLANT l
UNIT 2 PREPARED BY SOUTHERN NUCLEAR OPERATING COMPANY INSPECTION AND TESTING SERVICES GROUP l
I
^
REV
.DATE DESCRIPTION -
PREP'D REV'D APPV.
.APPV.
APPV.
APPR l
BY BY BY VEGP MGR.
GEN.
(ITS)
(ITS)
(ITS)
PROJECT ENGRG.
MGR.
i NMS SUPP.
I 0~
10/25/88 ORIGINAL ISSUE 1
4/10/89 ALL REL. REQ'S
/
j g
./
l 54,55,56 2
5/18/89 SED RE REQ'S 3
/
l RR-45,47,48,54, REV RR-32
\\
/
l mCOWRAE 4
6/10/91 l
COMMENTS PER i
GPC LTR MSV-00318,
)
9/13/90 INCORPORATE
/12/93
/
l 5
a COMMENTS PER PCR-92-009 & 93 005 j
INCORPORATE l
6 11/5/93 COMMENTS PER PCR 93-018 & ADD
GENERAL COMMENT
S j
REVISED RELIEF -
7 11/8/95 j
REQUESTS l
SECTION i
p=/ug Ahv Jil SEenON l
9812040032 981130 PDR ADOCK 05000425 ",
G pm i
VEGP-2 ISI-P-014 List ofEffective Pages Distribution List, Rev. 8 Table of Contents, Rev. 6
Introduction:
Page 1-1, Rev.8
{
Page 1-2, Rev. 7 Page 1-3, - Rev. 8 Page 1-4, Rev.7 Page 1-5, Rev.7 Page 1-6, Rev.7 Class 1:
Page 2-1, Rev.0 Page 2-2, Rev.O Page 2-3, Rev.0 f
Page 2-4, Rev. O Page 2-5, Rev. O Page 2-6, Rev.0 Page 2-7, Rev. 0 Page 2-8, Rev. 0 Page 2-9, Rev.7 Page 2-10, Rev. O Page 2-11, Rev. O
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Page 2-12, Rev. 0 Page 2-13. Rev. C Page 2-14, Rev. O Page 2-15, Rev. O Page 2-16, Rev. O Page 2-17, Rev. O Page 2-18, Rev. 0 -
Page 2-19, Rev. O Page 2-20, Rev. O Page 2-21, Rev. 7 Page 2-22, Rev. O Page 2-23, Rev.1 Page 2-24, Rev. O Page 2-25, Rei. O Page 2-26, Rev. 0
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Page 2-27, Rev. O Page 2-28, Rev. 0 Page 2-29, Rev. O Page 2-30, Rev. 0 Page 2-31, Rev. 0 Page 2-32, Rev. 7 Page 2-33, Rev. 7 4
1 of 5 P014 Rev. 8 i
Class 1 (continued):
l Page 2-34, R:v. 7 Page 2-34a, Rev. 7 Page 2-35, Rev. 0 Class 2:
Page 3-1, Rev. 0 Page 3-2, Rev. 7 Page 3-3, Rev.0 i
Page 3-4, Rev. 2
' Page 3-5, Rev. O Page 3-6, Rev. 7 i
Page 3-7, Rev. O Page 3-8, Rev.O Page 3-9, Rev.O Page 3-10, Rev. O Page 3-11, Rev. 0 Page 3-12, Rev. 0 3
Page 3-13, Rev. 0 Page 3-14, Rev. 0 Page 3-15, Rev. 0
- Page 3-16, Rev. 7 l
Page 3-17, Rev. 7
[
Page 3-18, Rev. 7 j
Class 3:
j Page 4-1, Rev. 0 i
Page 4-2, Rev.7 i
Page 4-3, Rev. 7 Page 4-4, ' Rev. 7 Page 4-5, Rev. 7 Page 4-6, Rev.7 Page 4-7, Rev. 7 Component Supports:
Page 5-1, Rev. 0
(
Page 5-2, Rev. 0 1
Page 5-3, Rev. 3 Page 5-4, Rev. 3 Page 5-5, Rev.O Page 5-6, Rev. 0 L
' Page 5-7, Rev. O i
ReliefRequests:
Page 6-1, Rev. 8
]
l Page 6-2, Rev. 8 Page 6-3, Rev. 8 i
Page 6-4, Rev. 8 Page 6-4a Rev.8
. Page 6-5,'
Rev. O i
Page 6-6, Rev.8 e
2 of 5 P014 Rev. 8
, RGliefRequests(continued):
I Page 6-6a, Rev. 8 Page 6-6b, Rev. 8 Page 6-6c. Rev. 8 Page'6-7, Rev. O Page 6-8, Rev, 8 j
Page. 6-9, Rev.8 Page 6-9a, Rev. 8 Page 6-9b, Rev. 8 Page 6-9c, Rev. 8 Page 6-10, Rev. 8 Page 6-ll, Rev. 0 Page 6-12, Rev. O Page 6-13, Rev. 0 Page 6-14, Rev. 5 Page 6-15, Rev. O Page 6-16, Rev. 5 Page 6-17, Rev. 0 Page 6-18, Rev. O Page 6-19, Rev.1 Page 6-20, Rev. 5 Page 6-21, Rev. 0 Page 6-22, Rev. O Page 6-23, Rev.1 -
Page 6-24, Rev. 0 j
1 Page 6-25, Rev. 0 Page 6-26, Rev. O Page 6-27, Rev. 0 1
Page 6-28, Rev 0 Page 6-29, Rev. 8 Page 6-30, Rev. 8 Page 6-31, Rev. 4 4
Page 6-32, Rev. 4 Page 6-33, Rev,4 Page 6-34, Rev. 0 Page 6-35, Rev. 7 Page 6-36, Rev. 7 Page 6-37, Rev. 7 Page 6-38, Rev. 7 Page 6-39,. Rev. 0 l
Page 6-40, Rev. 7 Page 6-41, Rev. 0 l
Page 6-42, Rev. O Page 6-43, Rev. 4 i
Page 6-44, Rev. 4 Page 6-45, Rev. 7 Page 6-46, Rev. 7 5
i 3 of 5 P014 Rev. 8
4.......
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d883 9-S#' W8A'8 d883 9-SS' M8A'8 dv83 9-g9' yaA' 0 d888 9-54' M3A' 0 yaA" 0 dv80 9-gs' yaA g d888 9-56' d883 9-568' W8A' E d888 9-90' W8A' E d8889-9I W8^~ 0 dv83 9-gg yaA' 8 d883 9-9E' M3A'8 d880 9-9#' M3^*0 dv8a 9-gg' yaA' 8 d883 9-99' W8A' 8 dv8a 9-9t' yaA'8 dv8a 9-gg' yaA g.
d883 9-96' WaA' 8 dv82 9-to' yaA' g d883 9-Ll' M3A' 8 dv83 9-Lt' M3A' 8 d880 9-LE' yaA' 0 d883 9-L#' M3A' 0 4
dv8a 9-tg' yaA' 0 dv83 9-t9' yaA' 0 d888 9-LL' W8A' 0 d888 9-tg' yaA' 0 d880 9-L6' yaA' 0 d883 9-80' M3^* 0 dv83 9-st' yaA' 0 d888 9-8Z' M3A' 0 dv88 9-gE' yaA' 0 d888 9-8#' M3A' 0 yaA' t dv88 9-gg' yaA t dv88 9-gga' yaA' 0 dv88 9-89' f
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Reli:fRequ;sts (continued):
- Pcge 6-88, Rev. 3
- Page 6-89, Rev. O Page 6-90, Rev. 3 Page 6-91, Rev. 3 Page 6-92, Rev. 3 Page 6-93, Rev. 6 Page 6-93a, Rev. 6 Page 6-93b, Rev. 6 Page 6-94, Rev. 5 Page 6-95, Rev. 4 Page 6-96, Rev. 4 t
Page 6-97, Rev. 4 Page 6-98, Rev. 0 t
Page 6-99, Rev. 3 Page 6-100,Rev.1 Page 6-101, Rev.1
. Page 6-102, Rev. 5 1
Page 6-103, Rev. 5 Page 6-104, Rev. 5 Page 6-105, Rev. 5 Page 6-106, Rev. 7 Page 6-107, Rev. 7 Page 6-108, Rev. 7 Page 6-109, Rev. 7 Page 6-110, Rev,7 Page 6-111, Rev. 7 Page 6-112, Rev. 7 l
Page 6-113, Rev. 7
]
Page 6-114, Rev. 7 Page 6-115, Rev. 7 Page 6-116, Rev. 7 Page 6-117, Rev. 7 Page 6-118, Rev. 7 Page 6-119, Rev. 7 Page 6-120, Rev. 7 Page 6-121, Rev. 7 Page 6-122, Rev. 8 Page 6-123, Rev. 8 Page 6-124, Rev. 8 Page 6-125, Rev. 8 Page 6-126, Rev. 8 Page 6-127, Rev. 8 J
Page 6-128, Rev. 8 Page 6-129, Rev. 8 5of5 P014 Rev. 8 l
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1 Vogtle Electric Generating Plant (VEGP-2)
Inservice Inspection (ISI) Program l
(ISI-P-014)
R_ evision 8 Summary of Changes p
i Affected ISI Program Document Pages Changes Distribution List Changed to reflect cmrent organization.
1-1,1-3 Editorial changes to reflect names of current and former licensee and operator of VEGP. Changed to reflect edition of code used.
6-1 thni 6-4a RR-2 revised, RR-4 withdrawn, RR-5 revised, RR-6 withdrawn, and added references to RR-63 i
and RR 64.
6-6 thru 6-6c Re-submittal of 10 CFR 50.55a(g)(6)(ii)(A)-
revoked RR-2 due to examination coverage
(
limitations for RPV lower shell to bottom head weld.
6-8 RR-4 is withdrawn since full-Code examination i
achieved for RPV meridional welds 2-1201-V6-001-W21, -W22, -W23, and -W24.
6-9 thru 6-9c Revised examination coverage for RR-5.
6-10 RR-6 is withdrawn since full-Code examination achieved for RPV flange ligaments 21201-V6-001 LO! through L54.
i 6-29 and 6-30 Added implementation schedule and welds 21204-024-16;21204-025-21; 21204-025-22; 21204-044-1; 21204-044-13; 21204-045-1; 21204-045-28 for RR-20.
l sumchgs Page 1 of 2 014 Rev. 8
1 Vogtle Electric Generating Plant (VEGP-2) l Inservice inspection (ISI) Program (ISI-P-014)
Revision 8 Summary of Changes (continued)
Affected ISI Program Document Pages Changes 6-54 and 6-55 Added implementation schedule and welds 21205-E6-002-WO4 and -WOS for RR-30.
6-62 and 6-63 Added implementation schedule and welds 21204-006-2;21204-122-6; 21208-137-13;21208-139-13; 21208-411-24 for RR-34.
6-65 thru 6-72 Added welds 21202-216-59; 21202-225-1; 21202-229-2 for RR-36.
6-122 thru 6-124 Relief requested for limited examination coverage of RPV outlet nozzle-to-shell welds 21201-V6-001-W25, -W28, -W29, and -W32. Examination coverage less than 90% for RR-63.
6-125 thru 6-129 Relief retroactively requested from repair requirements of piping and components 1-inch nominal pipe size and smaller for RR-64.
002824 Page 2 of 2 014 Rev. 8
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VEGP-2 INSERVICE INSPECTION PROGRAM (ISI-P-014)
DISTRIBUTION LIST IIOLDER MANUAL NUMBER l
l l
l T. V. Greene, Jr.
1 L.
Deleted 2
l A. E. Cardona 5
i' i
Deleted 6
L. K. Mathews 8
J. J. Churchwell 9
K. G. Lowery 10 1
' Deleted 11 Deleted 12 l
l
.Vogtle Team Leader 13 l
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i 002824 P014 Rev. 8 i
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I le0 INTRODUCTION j
l 1
1.1 General i
l This document details the scope ofinservice inspections for the Georgia Power Company (GPC)-
owned Vogtle Electric Generating Plant (VEGP) Unit 2 and includes the following points of interest.
l Frequency ofinspections.
Identification of all areas to be examined.
J 1
Relief Requests.
l The contents of this document are subject to change (with approval) during the course ofinservice inspections.
The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section X1,1983 Edition through Summer 1983 Addenda is currently used for inservice inspection (ISI).
l The actual edition applicable to ISI is the latest edition approved by the Nuclear Regulatory l
Commission 12 months prior to the date ofissuance of the operating license per 10 CFR 50.55A.
Additionally, Inspection Program B will be used as defined by IWA-2400 of Section XI. During Outage 2R6, examinations were performed in accordance with the 1989 Edition of ASME Section XI as authorized by the NRC.
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1.2 Scope This document is a description of the Inservice Inspection Program for Class 1,2, and 3 i
components.
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1.3 Component Upgrading l
l All plant components have been reviewed to determine the appropriate classification for inservice inspection. The classification information is given in the Line Designation List and Equipment Designation List located in the VEGP Unit 2 Inservice Inspection Plan, ISI-P-013. It must be noted, however, that the classification of components as ISI Class 1,2, or 3 for inservice inspection does not imply that the components were designed or constmeted in accordance with the same ASME classification requirements. The component design codes remain as stated in the VEGP Final Safety Analysis Report (FSAR).
1.4 Responsibility I
Southern Nuclear Operating Company (SNC), the current licensee and operator of VEGP and sister company to GPC, the former licensee and operator of VEGP, bears the overall responsibility for the performance of the inservice inspections. Certain nondestmetive examinations will be performed by a qualified inspection agency. The results of such examinations will be reported to SNC for l
final evaluation and disposition.
001165 1-1 014 Rev. 8
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1 a
o 1.6.6 Visual Tests t
1 l
A visual test (VT) inspection will be employed to provide evidence ofleakage or to provide a repon of the general condition of the component.
A.
The VT-1 inspection shall be performed to determine corrosion, erosion, wear, cracks, or physical damage of the pan, component, or surface being inspected.
l B.
The VT-2 inspection shall be performed to determine and locate leakages from pressure retaining components or excessive leakage from components without leakage collection systems.
C.
The VT-3 inspection shall be performed to determine the structural, general, and physical conditions of components or their supports.
D.
The VT-4 inspection shall be performed to ensure the operability of components and their nechanical or hydraulic devices.
1.7 Evaluation of Examination Results l
Examination results are evaluated per IWA-3000, IWB-3000, and IWF-3000 of the ASME Code,Section XI. Articles IWC-3000 and RVD-3000, " Acceptance Standards for F!aw Indications", are in the course of preparation and, as yet, are not available for use. Therefore, the rules of nVB-3000 may be utilized for ISI Class 2 and 3 components.
l Repair and Re_ lacement Procedures 1.8 o
Repair and replacement procedures have been developed by GPC and SNC.
l 1.9 Limitations of Examinations Certain limitations to nondestructive examination of welds due to geometric configuration or inaccessibility were identified during the Preservice Inspection. During ISI the required examination will be accomplished to the maximum extent possible and limitations will be documented in relief requests. Known relief requests are contained in the Relief Request section of this document.
Additional relief requests will be submitted as necessary.
The inservice inspection program outlined in the attached tabulations have been developed as a result of a design review and the Preservice Inspection.
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001165 1-3 014 Rev. 8
6.0 RELIEF REQUESTS 6.I'
-Scope The following ISI relief requests have been prepared from infonnation determined in support of inspection activities (including preservice inspection) at VEGP Unit 2.
Relief Request No.
Examination Area RR-1 Intentionally blank RR-2 Mechanized exam of reactor vessel lower shell-to-bottom head weld (Revoked / Resubmitted) l 1
RR-3 Intentionally blank RR-4 Relief Request withdrawn l
RR-5 Mechanized exam of reactor vessel bottom head l
circumferential welds (Revoked / Resubmitted) l l
RR-6 Relief Request withdrawn l
RR-7 Volumetric exam of reactor vessel closure head welds RR-8 Mechanized exam of elbow-to-reactor vessel safe-end welds RR-9 Volumetric exam of the reactor vessel closure l
head studs RR-10 Pressurizer support skirt integrally welded attachments RR-11 Visual exam of reactor vessel supports RR-12 Volumetric exam of prenurizer welds RR-13 Intentionally blank i
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001163 6-1 014 Rev. 8 i
4
Relief Request No.
Examination Area RR-14 Volumetric exam of pressurizer surge-nozzle-to-vessel weld i
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RR-15 Volumetric exam of pressurizer surge-nozzle inner radius RR-16 Pressurizer integrally welded i
attachments RR-17 Volumetric exam of steam generator nozzle-to-elbow welds i
J RR-18 Section XI, Appendix III for austenitic and dissimilar metal piping welds j
l RR-19 Volumetric exam of steam generator channel head to tube sheet welds I
RR-20 Volumetric exam of Class 1 piping welds l
RR-21 Volumetric exam of Class 1 branch pipe l
l connection welds i
RR-22 Volumetric exam of cast piping and elbows RR-23 Cast piping calibration block RR-24 Volumetric exam of reactor coolant pump nozzle-to-elbow and nozzle-to-pipe welds.
RR-25 UT calibration block for reactor coolant pump nozzle-to-pipe welds RR-26 Volumetric exam of SA 376 piping welds l
RR-27 Visual exam of Class 1 pump and valve mternal smfaces l
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l 001163 6-2 014 Rev. 8 1
i
Relief Request No.
Examination Area RR-28 Volumetric examination of Steam Generator outlet nozzle inner radius RR-29 Volumetric examination of Steam Generator secondary side welds RR-30 Volumetric and surface exam of Class 2 vessel welds RR-31 Use of piping calibration blocks to examine thin-wall vessels RR-32
. Surface exam of RHR heat exchanger reinforcing plates to nozzle welds RR-33 Intentionally blank RR-34 Volumetric exam of Class 2 piping welds RR-35 Technique for volumetric exam of thin-wall piping RR-36 Volumetric exam of Class 2 thin-wall piping RR-37 Volumetric exam of small-diameter Class 2 piping RR-38 ASME Section XI; Subsection IWE RR-39 Mechanized volumetric examination of pressure-retaining shell and head welds in reactor vessel outside the beltline region RR-40 Notch length in Basic Ultrasonic Calibration Blocks for examination of vessel welds 001163 6-3 014 Rev. 8 e
r
+
'M
I Relief Request No.
Examination Area l
i RR-41 Use of a centrifugally-cast stainless steel (SA-351 CF8A) piping calibration block for the mechanized examination of i
the reactor vessel nozzle to safe-end 1
welds l
RR-42 Volumetric examination of nozzle inner i
l radius section for steam generator inlet and outlet nozzles l
RR-43 VT-4 visual examination of snubbers l
RR-44 Class 2 piping hydrostatically tested i
to Class 1 requirements l
I RR-45 Relief Request withdrawn RR-46 System pressure test on Class 2 components RR-47 Relief Request withdrawn f
l L
RR-48 Relief Request with' drawn j
RR-49 System pressure test on Class 3 vertical pit type pumps.
j RR-50 System pressure test on Class 3 component RR-51 Relief Request withdrawn
)
i RR-52 Reactor Vessel integrally welded attachments j
RR-53 Class 3 hydrostatic test on Spent Fuel Cooling & Purification RR-54 Relief Request withdrawn conditionally RR-55 Pressurizer Safety Relief Valve Piping L
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01163 6-4 014 Rev. 8 t
.I
Relief Request No.
Examination Area RR-56 Auxiliary Feedwater Integrally Welded Attachments and Associated Component Supports.
RR-57 Remote Mechanized Volumetric and/or Surface Examination of Pressure Retaining Reactor Vessel Outlet Nozzle-to-Shell Welds, Inner Radius, and Reactor Vessel Outlet Nozzle-to-Safe End Welds.
RR-58 Steam Generator Manway Cover repair.
RR-59 Alternative pressure test requirement for welded repairs or installation of replacement items by welding on Class 1,2, and 3 (Reference ASME Code Case N-416-1.)
i RR-60 Alternative rules for 10-Year System hydrostatic testing for Class 1,2, and 3 systems (Reference AShE Code Case N-498-1.)
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RR-61 Alternative rules for the selection and examination of Class 1,2, and 3 integrally welded attachments (Reference AShE Code Case N-509.)
I RR-62 Selected Class 2 components be excluded from surface and volumetric examinations as allowed by the 1989 Addenda thru 1992 Edition of AShE Section XI i
l RR-63 Mechanized exam of reactor vessel upper shell longitudinal l
r RR-64 Repair of piping and components 1" nominal pipe size i
and smaller.
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001163 6-4a 014 Rev. 8
l VEGP-2 RR-2 System / Component for Which Reliefis Requested Reactor Pressure Vessel (RPV) lower shell-to-bottom head weld 21201-V6-001-WO6.
.Cqd.e_ Requirement for Which Reliefis Requts. tad AShE Section XI, Category B-A, Item No. Bl.11, as found in ASME Section XI Table IWB-2500-1, requires that a volumetric examination of the pressure-retaining circumferential welds in the RPV be performed. The applicable examination volume is shown in ASME Section XI, Figure IWB-2500-1, and includes one hundred percent (100%) of the weld length. Reliefis being requested from the Code requirements because the examination volume coverage was limited.
Basis for Relief Six RPV core support lugs are located on the lower shell of the RPV adjacent to RPV lower shell-to-bottom head weld 21201-V6-001-WO6. These core support lugs (see Attachment I to this relief request) obstructed movement of the mechanized examination equipment sled / transducer along the lower shell side (upper scan region) of this weld. As a result, examination coverage of this non-beltline weld from the inside diameter (ID) of the RPV was limited to approximately sixty-one percent (61%) of the weld length. Complete coverage from the inside diameter (ID) ofthe RPV would necessitate redesign and modification of the RPV which is not practical.
Performance of supplemental examinations from the RPV outside diameter (OD) was evaluated as a possible means ofincreasing coverage. These evaluations concluded that supplemental OD examinations could increase the total coverage to that required by AShE Section XI; however, such coverage was considered impractical due to the large radiation exposure (estimated as approximately 7.75 Rem (R)). This conclusion was based on the following:
(1) General area dose rates at the bottom of the vessel (as measured for VEGP-2 during Maintenance / Refueling Outage 2R6) are estimated to be approximately 200 mr/hr with contact dose rates at the insulation surface approximately 1 R/hr.
(2) Non-Destructive Examination (NDE) personnel would need to perform thirteen UT scans for each area receiving the supplemental examinations. It is calculated that the dose to the NDE personnel in performing these examinations would be approximately 3.25R.
6-6 014 Rev. 8
1 V.EOP-2 RR-2 (Contirtusd)
Basis fgLRelief.(c.gntinutdj (3) Prior to performing examinations, personnel would need to erect any necessary scaffolding, remove insulation, and perform any required weld preparation in the high radiation field.
This effort is further exacerbated by the fact that much of the RPV insulation used at VEGP was designed using rivets and screws and does not lend itself to easy removal and replacement. ARer examinations were completed, any scaffolding would need to be removed and insulation would need to be replaced. The actual number of person-hours spent in the vicinity of the RPV would not be known until such an effort was completed; however, the dose is estimated to be approximately 4.5 R.
(4) NDE personnel would need to locate and mark the areas where the supplemental examinations need to be performed. When performing ID examinations, limitations are located in respect to the core support lugs ar.d the RPV flange, using indexing providing by the automated inspection tool. Translating these locations to the OD with a high degree of confidence would be an extremely diflicult task while working in a high radiation field.
Alternate Examination No supplemental examination is proposed. However, it should be noted that an overall, general visual examination (VT-3) of the RPV was performed in accordance with the requirements of ASME Section XI, Category B-N-1, Item No. B13.10, during the maintenance / refueling outage in which weld 21201-V6-001-WO6 was examined volumetrically, i.e., during VEGP-2 Maintenance / Refueling Outage 2R6.
Justific_ align for the Granting of Rdie_f This weld is a non beltline area weld; therefore, radiation embrittlement is not a factor. This weld had a complete ultrasonic examination performed from the OD in the Tabrication shop, as a conservative measure, to ensure that no unacceptable flaws were present that would require evaluation during preservice examinations. A review of data indicates that no indications were observed in the areas not receiving ID inservice coverage.
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Compliance with Code coverage requirements would necessitate refabrication of the RPV to perform complete Code examinations from the ID or it would necessitate performance of supplemental examinations from the OD. Refabrication of the RPV to perform the Code required examinations from the ID is not practical and supplemental OD examinations have been evaluated by VEGP as impractical due to radiation exposure considerations. Fabrication shop examinations indicate that no indications were observed in the areas not receiving ID inservice coverage; therefore, there is little likelihood of a crack propagating from a fabrication defect.
6-6a 014 Rev. 8
VEGP-2 RR-2 i
(Continued)
Justification for the Granting of Relief (continued)
Examinations performed from the ID, combined with good fabrication shop examination results i
and lower embrittlement rates (of a non-beltline area) should provide reasonable assurance of the operational readiness of this weld and the RPV. Denial of this relief request would cause an excessive burden to VEGP; therefore, approval should be granted pursuant to 10 CFR 50.55a(g)(6)(i).
l i
Impismentation Schedule This relief request is applicable to the First Ten-Year ISI Interval on VEGP-2 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).
The 1989 Code edition was used for 2R6 exams instead of 1983/S1983, due to the early update of the VEGP-2 ISI Program as authorized by the NRC.
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L 6-6b 014 Rev. 8 i
VEGP-2 EE-2 (continued) l 1
ATTACRMENT I Cross Sectional View Weld WO6 l
- -4
-323.86 b
- D TDP 'PERP 342.81 REF TO TOP OF VESSEL D TDP PARALLEL 334.9 1-i 325.50 REF f'
}
4.' 2 TO TOP g
Of VESSEL l
R2 1.03
[5*
p 73*
D Bot Perp.
VESSEL E
= 88.16 to clad 6.3 NDM l
6-6c 014 Rev. 8 l
\\
VEGP-2 RR-4 l
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~ RELIEF REQUEST WITHDRAWN 1
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6-8 014 Rev. 8
VEGP-2 RR-5 System / Component for Which Reliefis Request Vogtle Electric Ger. rating Plant (VEGP) Reactor Pressure Vessel (RPV) bottom head circumferential weld 21201-V6-001-WO7.
Code Re.quirement for Which Reliefis Requested Table nVB-2500-1, Examination Category B-A, Item No. Bl.21 as found in the 1989 Edition of ASME Section XI with No Addenda, requires that a volumetric examination of the pressure-retaining circumferential welds in the RPV heads be performed. The applicable examination volume is shown in ASME Section XI, Figure BVB-2500-3, and includes one hundred percent (100%) of the weld length. As a result of an early update of the inservice inspection program on VEGP-2 as authorized by the NRC, the 1989 edition of ASME Section XI was used instead of the 1983 edition with addenda through summer 1983.
Basis for Relief This " dollar plate" weld was examined from inside the RPV in 1998 at the end of the first 10-year intervi. using remote " contact" techniques and the Westinghouse inside diameter (ID) inspection tool. There werg.no_tecordable indicatipons. The composite examination volume coverage using this technique was limited to approximately seventy-five (75%) of the examination volume. As seen in Attachments 1 and 2 to this relief request, approximately thirty (30) peripheral in-core flux instrumentation tubes are located within about 18 inches of the centerline of the subject weld.
The Westinghouse ID inspection tool used for the examination utilized a transducer sled in contact with the surface of the head. This sled was manipulated around the instrument tubes 19 achieve maximum practical coverage for this tool. However, this tool had a limited degree of motion, which, when combined with the curved geometry of the bottom head and the limitations posed by the instmment tubes, had limited ability to perform complete Code examinations. The most recent Westinghouse inspection tool designs (which have more advanced robotics with j
multiple degrees of motion) were used to perform the 1998 VEGP-2 examinations.
Alternalg Examination Because of the physical interference presented by the instrumentation tubes in the proximity of the subject weld, no supplemental examination is proposed. It should be noted, however, that an overall, general visual examination (VT-3) of the RPV was performed in accordance with the requirements of ASME Section XI, Category B-N-1, Item No. B 13.10, during the maintenance / refueling outage in which weld 21201-V6-001-WO7 was volumetrically examined, i.e., during VEGP-2 Maintenance / Refueling Outage 2R6.
6-9 014 Rev. 8
l VEGP-2 RR-5 (Continued)
Justification for Granting Relief l
The ID coverage of weld 21201-V6-001-WO7 during the 10-year inservice examinations was
(
limited during the first 10-year interval examinations, but was done to the extent practical, as j
allowed by the existing equipment. An option to increase this coverage was evaluated by SNC, but j
was determined to represent an extreme hardship. This option was:
Supplemental OD Examinations -If outside diameter (OD) examinations were to be performed, they would have to be performed on the entire accessible length of the weld, because correlation of the numerous ID limitations to a corresponding location on the OD would be impractical. To perform the examination from the OD, personnel would need to erect scaffolding; remove the insulation; perform any required weld preparation; ultrasonically examine the weld; re-install the insulation; and remove the scaffolding.
General area dose rates at the bottom of the RPV (as measured for Unit 2 during this sixth maintenance / refueling outage) are approximately 220mr/hr, with a contact dose rate at the insulation surface of approximately 1 R/hr. It was conservatively calculated that the dose to perform the weld examinations from the OD of the vessel would be in excess of 11.5 R. A i
radiation dose of this magnitude, to perform examin'ation of one weld, is contrary to the principles of as low as reasonably achievable (ALARA) and is considered by SNC to be an extreme hardship. Even ifit was practical to perform such an examination, Code coverage l
would be improved, but it is unlikely that Code coverage of greater than ninety percent (90%) could be obtained due to the proximity of the instrument tubes.
l l
Weld 21201-V6-001-WO7 was ultrasonically examined (manually) during the shop fabrication of l
the RPV at Combustion Engineering, using 0,45, and 60-degree transducers. These examinations were performed from both the inside and the outside of the vessei to assure that no unacceptable l
flaws were present. A review of the data for this weld indicates that no recordable indications were l
found in the weld or in the adjacent base material.
l SNC has demonstrated there is adequate assurance that the stmetural integrity of weld 21201-V6-001-WO7 is being maintained and that compliance with the Code requirements would result in a hardship without a compensating increase in the level of quality or safety. Therefore, relief should be granted pursuant to the requirements of 10 CFR 50.55a(a)(';)(ii).
Implementation Schedule This relief request is applicable to the First Ten-Year ISI Interval on VEGP-2 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c). The 1989 Code edition was used for 2R6 exams instead of 1983/S1983, due to the early update of the VEGP-2 ISI Program as authorized by the NRC.
6-9a 014 Rev. 8 l
l r
RR-5 (continued)
ATTACHMENT 1 Cross Sectional View Weld WO7 I
11 P
4 R 88.16 TO CLAD
.22 OM 6.3 NOM
- 60* SCAN
- 45' SCAN
- 70* SCAN f
- 0* SC
/
- 0* SCAN
- 70* SCAN
- 45' SCAN
- 60* SCAN G
c5 nn l
l 014rr 6-9b 014 Rev. 8 l
I
VEGP-2 RR-5 (continued)
ATTACHMENT 2 I
In-Core Flux Instrumentation Tubes j
PENETRATION No.
DISTANCE FROM DISTANCE FROM (1.50 IN. NOM)
VESSEL CL GN.)
WELD WO7 CL (IN.)
32,33 49.36 18.17 34,35 50.80 16.73 36,37 51.50 16.03 38,39,40 53.54 13.99 41,42 54.21 13.32 43,44 59.26 8.27
{
45,46,47 59.86 7.67 48,49 61.05 6.48 50,51 61.63 5.90 i
53,54 64.48 3.05
$5,56,57,58 66.12 1.45 52 64.43 3.0 Section-RPV Bottom Head o
l Y
a.
Weld WO7 821
.i g
i3 9
l 55 g4 59 32 43 O
O O
d' O
O O
0
$3 tro ts o
o o
4 0
0 3V c ro ---
-mad- -- S-o-O---o - + -o --0---o U- -sca-
- - 8 lO 0
.3 O
O tO O
O-0 0
0 as 9-
<g a 11 O
O
q*,.
i 112 3 s
t
=
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100*
014rr 6-9c 014 Rev. 8 t
l l
\\
VEGP-2 RR-6 i
i I
RELIEF REQUEST WITHDRAWN i
J 1
i 6-10 014 Rev 8
l VEGP-2 l
KR-20 Component or Relief Area i
Examination of pressure-retaining welds in Class 1 piping excluding areas covered in RR-21, RR-
{
24, RR-25, and RR-26.
Reauirement from which Reliefis Requested Item No. B9.11, Category B-J, Table IWB-2500-1 of ASME Section XI requires a volumetric and surface examination ofwelds in Class 1 piping of nominal size 4-inches and greater. The applicable examination areas are shown in Figure IWB-2500-8. Reliefis requested for those examinations where the total examination coverage was less than required. The examination l
numbers, extent of coverage and reason for limitations are listed in Attachment 1.
Basis for Relief i
Physical limitations due to geometric configuration of the welded areas, support obstructions, etc., do not permit a complete coverage of the welds as required by ASME Section XI. The Code required surface examination will be performed.
Alternate Examination None i
[m_plementation Schedule This relief request is applicable to the First Ten-Year ISI Interval on VEGP-2 which concluded May 30,1997, exclusive of the one year period allowed by AShE Section XI, IWA-2400(c).
The 1989 Code edition was used for 2R6 exams instead of 1983/S1983, due to the early update of the VEGP-2 ISI Program as authorized by the NRC.
~
l 6-29 014 Rev. 8
VEGP-2, RR-20 ATTACHMENT I Identification No.
Code Category Description Percentage Examined Restriction l
21201-036-21 B-J 12" Pipe to Valve 83% - UT 50% OV/CCW scans due to 100% - PT Geometry of Valve 21201-059-12 B-J 6" Tee to Pipe 95% - PT Welded pipe support 100% - UT interferes with PT Exam 21201-060-1 B-J 6" Tee to Pipe 95% - PT Welded pipe support 100% - UT interferes with PT Exam 21204-024-15 B-J 6" Pipe to Valve 87.5% - UT 75% CW/CGV scans due to 100% - PT Geometry of Valve 21204-024-16 B-J 6" Valve to Pipe 87.5% - UT 75% CW/CGV scans due to 100% - PT Geometry of Valve 21204-025-21 B-J 6" Pipe to Valve 75% - UT 50% GV/CGV scans due to 100% - PT Geometry of Valve i
21204-025-22 B-J 6" Valve to Pipe 87.5% - UT 75% GV/CGV scans due to 100% - PT Geometry ofValve 21204-044-1 B-J 6" Valve to Pipe 87.5% - UT 75% CW/CCW scans due to 100% -PT Geometry of Valve 21204-044-13 B-J 6" Pipe to Tec 87.5% - UT 75% GV/CCW scans due to 100% - PT Geometry of Tee 21204-045-1 B-J 6" Valve to Pipe 81.5% - UT 63% GV/COV scans due to 100% - PT Geometry of Valve 21204-045-28 B-J 6" Pipe to Tee 87.5% - UT 75% CW/COV scans due to 100%- PT Geometry ofTee 6-30 014 Rev. 8
)
VEGP-2 RR-30 Comoonent or Relief Area Volumetric and/or surface examination of pressure-retaining welds in Class 2 vessels (or components). Specific examination identifications are shown in Attachment I to this relief request.
Reauirement from which Reliefis Requested Item Nos. C1.10, C1.20, and C1.30, Category C-A, Table IWC-2500-1 of ASME Section XI require volumetric examination ofpressure-retaining welds in Class 2 pressure vessels.
Applicable examination volumes are shown in Fig. IWC-2500-1 and -2 and includes 100% of the weld length. Item No. C2.21, Category C-B, requires volumetric and surface examination of pressure-retaining nozzle welds in Class 2 vessels. Applicable examination volume and area are shown in Fig. IWC-2500-4 and includes 100% of the weld length. Item No. C3.30, Category C-C, requires surface examination of pressure-retaining integrally welded attachments in Class 2 pumps. Item No. C6.10, Categosy C-G, requires surface examination of pressure-retaining welds in Class 2 pumps. The examination area is shown in Fig. IWC-2500-5 and IWC-2500-8 and includes 100% of the weld length. Actual examinations and their extent of coverage are listed in. (See RR-31)
Basis for Relief Access limitations are due to geometric configuration of the welded areas. Flanges and supports restrict coverage ofrequired examination volume and areas. The actual restriction for each weld is shown in Attachment 1.
The maximum percentage possible of the required ultrasonic examination will be performed. The Code-required surface examination will be performed to the extent possible on the Safety Injection Pump.
Alternate Examination None Imolementation Schedule This relief request is applicable to the First Ten-Year ISI Interval on VEGP-2 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).
The 1989 Code edition was used for 2R6 exams instead of 1983/S1983, due to the early update of the VEGP-2 ISI Program as authorized by the NRC.
6-54 014 Rev. 8
- _ _ _ _ _ _ _ _ _ _.. ~., - - _ _ _ - - - _ _ _ _ _ - - _ _ -
_ _ _ _ _ = _ _
VEGP-2 BB-M (costlaued)
Attechment I Muumum Code Item Percentage identification No.
CatenoV Hg.
Rescnotica Examned Restnctmn i
(EXCESS LETDOWN HEAT EXCHANGER) 21208-E6-002-WD1 C-A Cl.20 Unit Flange to Channel Head Weld 50 %
50% Code exam done from' channel head side ofweld-4 branch connections interfere (LETDOWN HEAT EXCHANGER) 21208-E6-003-WO3 C-A Cl.20 Vessel Head to Head Flange 30 %
30% Code exam done from l
head side due to flange bolt
- interference C
f (DISCHARGE PULSATION DAMPENER) 21208-V4-002-WOI C-A Cl.20 Hemi-Head to Hemi-Head Weld 90 %
SupportInterference from nozzle side -
t (SAFETYINJECTION PUMP) i i
21204-P6 003-WO2 C-G C6.10 Pump Casing to Suction Nozzle Weld 68 %
Panp supports prevent access -
i to required aree (CENTRIFUGAL CHARGING PUMP) 21208-P6-002-WO3 C-C C3.30 Integrally Welded Pump Support Bracket 70 %
Pump supports prevent access to gW e 21208-P6-002-WOS C-C C3.30 Integrally Welded Pump Support Bracket 70 %
Pump supports prevent access to required area t
(RHR HEAT EXCHANGER) 21205-E6-002-WO4 C-B C2.21 Nozzle to Shell Welds
. 50%
Limited exam due to component configurauon 1
21205-E6-002-WOS C-B C2.21 Nozzle to Shell Welds 50 %
1.imited exam due to component configuration I
6-55 014 Rev. 8
[
- - -.. - ~.. -.
i VEGP-2 i
RR-34 Component or Relief Area l
Volumetric examination of pressure-retaining piping welds in Class 2 systems except those listed in RR-36 and RR 37.
1 Reautrement from which Reliefis Reauested Item No. C5.21, Category C-F, Table IWC-2500-1 of ASME Section XI requires surface and volumetric examination ofpressure-retaining welds in Class 2 piping. Applicable examination l
volumes are shown in fig. IWC-2500-7 and includes 100% of the weld length. The examination areas and the extent ofvolumetric coverage are listed in Attachment 1.
Basis for Relief i
l Physicallimitations due to geometric configuration of the welded areas. Support obstructions, inaccessibility etc. restrict coverage of examination volume as required by fig. IWC-2500-7, l
The Code Required ultrasonic examination will be performed to the extent possible. The Code required surface examination will be performed.
l Alternate Examination None Implementation Schedule This relief request is applicable to the First Ten-Year ISI Interval on VEGP-2 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).
The 1989 Code edition was used for 2R6 exams instead of 1983/S1983, due to the early update of the VEGP-2 ISI Program as authorized by the NRC.
i l
l 6-62 014 Rev. 8 j
i 1
l l
l l
l x,
y
~
y VEGP-2, RR-34 ATTACHMENT 1 l
Identification No.
Code Category Description Percentage Examined Restriction 21204-006-2 C-F-1 24" Valve to Elbow 78.5 %
57% CW/CCW scans due to j
geometry ofvalve 21204-122-6 C-F-1 10" Pipe to Valve 35%
40% fmm pipe side due to
[
. welded box restraint located 3.3" of weld centerline.
l 0% from valve side, -
50% CW/CCW scans due to geometry ofvalve s
21208-137-13 C-F-1 8" Valve to Pipe 87.5 %
75% CW/CCW scans due to geometry ofvalve 21208-139-13 C-F-1 6" Valve to Pipe 87.5% ~
75% CW/CCW scans due to geometry ofvalve j
l 21208-411-24 C-F-1 6" Pipe to Valve 87.5 %
75% CW/CCW scans due to geometry ofvalve j
21301-004-10 C-F 29.5" Pipe to Valve 85 %
0% from valve side,85% from pipe side due to taper.
21301-004-13 C-F 29.5" Pipe to Valve 85 %
0% from valve side,85% from i
I pipe side due to taper.
21305-062-7 C-F 16" Valve to Pipe 86 %
0% from valve side,86% from pipe side due to lug r
I 6-63 014 Rev 8
. -. =
VEGP-2 RR-36 Comnonent or Relief Area Volumetric examination of pressure-retaining we'ds in Class 2 engineered-safety systems (Containment Heat Removal, Emergency Core Cooling, and Residual Heat Removal Systems).
This Relief Request covers thin-walled piping (less than 0.5 inch wall thickness) greater than four-inch diameter. These systems are not required to operate above a pressure of 275 psig or above a temperature of 200*F and are normally exempt per ASME Section XI, IWC 1220(b). However, as a condition oflicensing, Georgia Power Company agreed to perform volumetric examinations on a percentage of these welds.
Reauirement from which Reliefis Recuested Reliefis requested for those examinations where the examination volume was less than 100% of the total weld volume. The technique for accomplishing these examinations is presented in RR-35.
The affected welds are listed in Attachment 1.
Basis for Relief Physical limitations due to geometric configuration of the ivelded areas; flanges, fittings, support obstructions, and etc. prevent complete coverage.
An ultrasonic examination will be performed to the extent possible. A surface examination will also be performed. (See Attachment I for exceptions). Specific details are listed in Attachment 1.
l Alternate Examination None r
l I
6-65 014 Rev. 8
. ~..
VEGP 't, RR-36 Attadunent 1 I
Identification No.
Description Percentage Examined Restriction l
1 21202-001-55 8" Pipe to Flued Head 50 %
100% Exam frompipe side 0% Exam from flued head side
~I 21202-141-1 6" Flange to Pipe 50 %
100% Exam frompipe side 0% Exam from flange side 21202-188-1 8" Flange to Pipe 50 %
100% Exam from pipe side -
l 0% Exam from flange side 21202-188-4 8" Flued Head to Pipe 50 %
100% Exam from pipe side 0% Exam from Flued Head side 21202-188-43 6" Pipe to Flange 50 %
100% Exam frompipe side 0% Exam from Flange side f
21202-189-2 6" Pipe to Valve 50 %
100% Exam from pipe side L
0% Exam from Valve side 21202-189-3 6" Valve to Pipe 50%,
100% Exam fmm pipe side 0% Exam from Valve side p
i 21202-189-14 6" Pipe to Flange 50 %
100% Exam from pipe side l
0% Exam fmm Flange side i
21202-192-42 8" Pipe to Flhed Hend 50 %
100% Exam fmm pipe side f
0% Exam from Flued Head side 21202-192-44 Neck Extension to 8" Pipe 83 %
66% Exam frompipe side 100% Exam from Neck Extension side 21202-l % -4 Flued Head to 8" Pipe 50 %
100% Exam from pipe side 0% Exam from Flued Head side 6-66 014 Rev. 8 k
VEGP-2, RR-36
~
Attachment I Identification No.
Description Percentar,e Examined Restriction l
21202-196-6 8" Elbow to Valve 50 %
100% Exam from Elbow side 0% Exam from Valve side 21202-204-15 6" Valve to Pipe 50 %
100% Exam from pipe side 0*/. Exam from Valve side 21202-205-1 6" Flange to Pipe 50 %
100% Exam from pipe side 0% Exam fmm Flange side 21202-205-14 6" Pipe to Valve 50 %
100% Exam from pipe side 0% Exam from Valve side 21202-209-4 Flued Head to 8" Pipe 50 %
100% Exam from pipe side 0% Exam fmm Flued Head side 21202-209-7 8" Pipe to Valve 50 %
100% Exam from pipe side 0% Exam from Valve side 21202-209-27 6" Pipe to Valve 50%.
100% Exam from pipe side 0% Exam from Valve side 21202-209-28 6" Valve to Pipe 50 %
100% Exam from pipe side 0% Exam from Valve side 21202-209-39 6" Pipe to Ffange 50 %
100% Exam from pipe side 0% Exam from Flange side 21202-212-34 8" Pipe to Flued Head 50 %
100% Exam frompipe side 0% Exam from Flued Head side 6-67 014 Rev. 8
VEGP-2, RR-36 Attadtment 1 Identification No.
Desaiption Percentage Examined Restriction l
21202-216-1 8" Flange to Pipe 50 %
100*/. Exam from pipe side 0% Exam from Flange side 21202-216-2 8" Pipe to Neck Extension 70 %
100% Exam from pipe side 40% Exam from Neck Extension side Restricted Access due to Hanger 21202-216-4 Flued Head to 8" Pipe 45 %
89% Exam from pipe side 0% Exam from Neck Extension side Restricted Access due to Drain Valve 21202-216-40 6" Pipe to Valve 50 %
100% Exam from pipe side 0% Exam from Valve side 21202-216-41 6" Valve to Pipe 50 %
100% Exam from pipe side 0% Exam from Valve side 21202-216-59 6" Pipe to Flange 50*4 100% Exam from pipe side 0% Exam fmm flange side (Surface exam will be performed in 2R7) 21202-218-1 6" Valve to Pipe 50% -
100% Exam from pipe side 0% Exam from Valve side 21202-218-19 6" Pipe to Range 50 %
100% Exam from pipe side 0% Exam from Flange side 21202-218-A 6" Reducer to Valve 50 %
100% Exam from Reducer side 0% Exam from Vahc. side 21202-220-53 8" Pipe to Flued Head 50 %
100% Exarn from pipe side 0% Exam from Flued Head side 21202-223-2 8" Pipe to Neck Extension 70 %
40% Exam from pipe side 100% Exam from Neck Extension side Restricted Access due to Hanger 6-68 014 Rev. 8
VEGP-2, RR-36 Identification No.
Description Percentage Examined Restriction l
21202-223-4 Flued Head to 8" Pipe 50 %
100% Exam from pipe side 0% Exam from Flued Head side 21202-225-1 6" Flange to Pipe 50 %
100% Exam from pipe side 0% Exam from flange side (Surface exam will be performed in 2R7) 21202-225-47 8" Pipe to Flued Head 50 %
100% Exam fmm pipe side 0% Exam from Flued Head side 21202-225-49 Neck Extension to 8" Pipe 83 %
66% Exam from pipe side 100% Exam from Neck Extasion side Restricted access due to Hanger 21202-229-1 8" Flange to Pipe 50 %
100% Exam from pipe side 0% Exam from Flange side 21202-229-2 8" Pipe to Neck Extension 50 %
100% Exam from pipe side 0% Exam from neck extension side (Surface exam will be performed in 2R7) 21202-229-4 Flued Head to 8" Pipe 50 %
100% Exam from pipe side 0% Exam fmm Flued Head 21202-231-62 8" Pipe to Flued Head 50 %
100% Exam from pipe side 0% Exam from Flued Head side 21202-231-64 Neck Extension to 8" Pipe 70 %
100% Exam frompipe side 40% Exam from Neck Extension side Restricted access due to Hanger 21202-231-65 8" Pipe to Flange 50 %
100% Exam from pipe side 0% Exam from Flange side 21204-006-01 24" Nozzle to Valve 50 %
100% Exam fmm Nozzle side 0% Exam from Valve side 6-69 014 Rev. 8
VEGP-2, RR-36 Identification No.
Description Percentage Examined Restriction l
21204-006-2 24" Valve to Elbow 50 %
100% Exam from Elbow side 0% Exam from Valve side 21204-008-1 8" Branch Connection to Pipe 50 %
100% Exam fmm pipe side 0% Exam from Branch side 21204-019-1 6" Tee to Pipe 83 %
100% Exam from pipe side 67% Exam from Tee side 21204-011-8 6" Pipe to Valve 50 %
100% Exam fmm pipe side 0% Exam from Valve side 21204-038-1 14" Branch Connection to Pipe 50 %
100% Exam frompipe side 0*/. Exam from Branch side 21204-038-17 10" Elbow to Valve 50 %
100% Exam from pipe side 0% Exam fmm Valve side 21204-177-13 8" Pipe to Valve 50%,
100% Exam frompipe side 0% Exam from Valve side 4
21205-003-60 14" Pipe to Pump 50 %
100% Exam from pipe side 0% Exam from Pump side 21205-004-47 14" Pipe to Pump Suction 50 %
100% Exam from pipe side 0% Exam from Pump side 21205-005-1 8" Nozzle to Pipe 50 %
100% Exam frompipe side 0% Exam from Pump side 1
6-70 014 Rev. 8 i
i P
- m..
i VEGP-2, RR-36
~
Attachment I Identification.
No.
Description Percentage Examined Restriction l
21205-005-29 14" Pipe to Nozzle 50 %
100% Exam from pipe side '
0% Exam fmm Nozzle side i
21205-006-1 8" Nozzle to Pipe 50 %
100% Exam frompipe side 0% Exam fmm Nozz' J le i
21205-006-2 8" Pipe to Valve 50 %
100% Exam from pipe side 0% Exam fromvalve side 21205-006-15 8" Pipe to Tee 87*4 100% Exam from pipe side 75% Exam from tee side 21205-006-29 14" Pipe to Nozzle 50 %
100% Exam from pipe side 0% Exam from Nozzle side I
5 21205-007-1 14" Nozzle to Pipe 50 %
100% Exam from pipe side 0% Exam from Nozzle side i-21205-008-1 8" Nozzle to Pipe 50%,
100% Exam frompipe side i
0% Exam from nozzle side j
i 21205-008-23 8" Pipe to Tee 94 %
100*4 Exam from pipe side t
88% Exam fromTee side l
k 21205-009-1 8" Valve to Pipe 50 %
100% Exam from pipe side
[
0% Exam from Valve side 21205-039-8 12" Pipe to Tee 86 %
100% Exam from pipe side 72% Exam from Tee side
{
r L
6-71 014 Rev. 8 l
v f
VEGP-2, RR-36 Identification No.
Description Percentage Examined Restriction l
21206-001-29 12" Pipe to Elbow 100% Exam from pipe side 92% Eum from Elbow side Restricted Access due to Branch Connection 21206-001-37 10" Reducer to Flange 50 %
100% Exam from reducerside 0% Exam from Flange side J
21206-004-4 10" Valve to Reducer 50 %
'100% Exam from reducer side 0% Exam from Valve side
{
f i
21206-004-11 12" Flange to Reducer 50 %
100% Exam from reducerside l
0% Exam from Flange side i
[
21206-004-12 10" Reducer to Flange 50 %
100% Exam from reducer side t
0% Exam from Flange side
[
i 21206-005-1 8" Flange to Pipe 50 %
100% Exam from pipe side
+
0% Exam from Flange side 1
21206-006-1 8" Flange to Pipe 50 %
100% Exam from pipe side 0% Exam from Flange side l
21208-137-12 8" Pipe to Valve 50 %
100% Exam from pipe side 0% Exam from Valve side
{
i 21208-411-2 8" Pipe to Valve 50 %
100% Exam from pipe side l
0% Exam from Valve side j
i 21208-411-48 8" Pipe to Tee 83 %
100% Exam frompipe side 65% Exam from Tee side j
6-72 014 Rev. 8 h
t h
I
. - ~ -
_ ~ - -. -
l l
VEGP-2 RR-63 System / Comp _QDsnt for Which Reliefis Requested Reactor Pressure Vessel (RPV) outlet nozzle-to-shell welds 21201-V6-001-W25, W28, W29 and W32.
I-l Code Requirme_nt for Which Reliefjdeqqcsic11 Item No. B3.90, Category B-D, Table IWB-2500-1 of ASME Section XI requires a volumetric examination of reactor pressure vessel (RPV) nozzle-to-vessel welds. The applicable examination volume is shown in Figure IWB-2500-7(a) for the outlet nozzles. Ti.e examination volume includes one hundred percent (100%) ofthe weld length. In addition, ASME Section XI, Paragraph IWA-2232, requires that ultrasonic examination be conducted in accordance with Appendix I which states vessel welds greater than 2 inches in thickness be conducted in accordance with ASME Code,Section V, Article 4. This paragraph requires two-directional coverage, wherever feasible.
Typically, vessel welds are examined with a combination of 0,45,60 and 70 transducers to meet the examination volume requirements. However, due to the special configurations involved in some welds, including the nozzle-to-vessel welds from the nozzle bore, AShE Section V, Article 4. Paragraph T-441.3.2.2 permits the use of other examination angles. Additional requirements are:
Reflectors Parallel to the Nozzle-To-Vessel Weld - T-441.3.2.6 requires that search units be directed perpendicular to the weld so that the angle beams pass through the entire volume of the weld metal. The adjacent base metal is required to be completely scanned by two angle beams; however, it is not necessary to scan from both directions.
l l
Reflectors Transverse to the Nozzle-To-Vessel Weld - T-441.3.2.7 requires that search units be l
directed parallel to the axis of the weld such that the angle beams pass through all of the examination volume. Scanning is required to be done in two directions,180-degrees to each other, except that, for those areas blocked by geometric conditions scanning is required in at least one direction.
l Code Reauirement for Which Reliefis Reauested i
1 Reliefis requested from meeting the required coverage for the subject welds.
j l
l l'
l 1
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6-122 014 Rev. 8
r l
l EG_._M.
I RR-63 (continued)
Dasis for Relief He required exanunation volume and associated weld configuration (barrel type nozzle with a protruding inner mdius) for the out!ct nozzles is shown in ASME Section XI, Figure IWB-2500-7(a). Covemge and limitations for this configuration (see Attachment 1) are listed below:
(1)
Reflectors Parallel to the Outlet Nozzle-To-Vessel Weld - Ultsasonic exammations will be performed from the nozzle bore using scans as allowed by T-441.3.2.2. Coverage from this direction is 100%.
)
(2)
Reflectors Transverse to the Outlet Nozzle-To-Vessel Weld - Ultrasonic exanunations will be performed on the ID of the vessel wall and accessible portions of the adjoining nozzle using scans, directed clockwise and counterclockwise. He protmding inner radius (nozzle boss) limits scanning on the nozzle due to scanner interference's. Coverage from this direction is estimated at approximately forty percent (43%).
Composite Coverage - Composite coverage is calculated as seventy-two percent (72%) based on the average of the parallel and transverse scans listed above.
l Alternate Examination Ultrasonic examination of these welds will be performed to the maximum extent practical from the nozzle bore and from the RPV ID surface. No other examination will be conducted.
Lugification for Granting Relief Various techniques have been evaluated including the use of additional angles and outside diameter (OD) examinations; however, it was concluded that the techniques described above permit the maximum practical coverage to be obtained. Compliance with Code coverage requirements would necessitate refabrication of the RPV nozzles, which is impractical. The 100% coverage from the nozzle bore will assure that circumferential cracking existing in the weld would have been detected. Coverage limitations existed only for the detection of axially oriented cracking, which has less safety significance. Therefore, the examinations performed will provide reasonable assurance of the operational readiness of the welds and the RPV. Denial of this relief request would cause an excessive burden to VEGP; therefore, approval of this relief request should be granted pursuant to 10CFR 50.55a(g)(6)(i).
ImplementationJShgMe This relief request is applicable to the First Ten-Year ISI Interval on VEGP-2 which concluded May 30,
[
1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c). The 1989 Code edition was used for 2R6 exams instead of 1983/S 1983, due to the early update of the VEGP-2 ISI i
l Program as authorized by the NRC.
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m-l VEGP-2 i
RR-63 (continued)
ATTACHMENT 1 i
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m VEGP-2 RR-64
- System / Component for Which Reliefis Requested Each of the ASME Class 1,2, and 3 small items consisting of piping, valves, and fittings 1-inch and smaller nominal pipe size (NPS) subject to repair or replacement within the scope of the ISI Program.
Code Requirement for Which Reliefis Requested
- IWA-7400(d) of the 1983 Edition of ASME Section XI with Addenda through Summer 1983 exempts 1-inch NPS and smaller replacement items and their installation from the requirements of IWA-7000; whereas, the repairs ofitems 1-inch NPS and smaller are not similarly exempted from the requirements ofIWA-4000. Reliefis requested from the requirements ofIWA-4000 and IWA-7000 of the 1983 Edition with Addenda through Summer 1983 for piping, valves, and fittings 1-inch NPS and smaller.
I
- Basis for Relief I
Around October 1996, an Authorized Nuclear Inspector (ANII) at VEGP identified a possible non-compliance with the requirements associated with rec' rd keeping for repairs of piping and o
components 1-inch NPS and smaller. Review of the VEGP Repair / Replacement Program during VEGP-2 Maintenance / Refueling Outage 2RS in Fall 1996 confirmed the ANII's concern and 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 believed that repairs of piping and components 1-inch NPS and smaller were exempt, including the requirements associated with record keeping. As a result of this misunderstanding of the Code requirements for repairs, both l
VEGP units appear to have been in non-compliance with the repair requirements, including those associated with record keeping, e.g., use of ASME Form NIS-2 (Owner's Report for Repairs and Replacements), since the beginning of commercial operation through October 1996 (time of discovery) for repairs of piping and components 1-inch NPS and smaller. The NRC was advised i
l of this potential non-compliance with the requirements of the ASME Section XI Code in Georgia L
Power Company (GPC) letter LCV-0932 dated January 8,1997. Complicating the issue was i
L direction reportedly given by an ANII who preceded the ANII who identified the potential non-compliance. Reportedly, the previous ANII indicated to plant personnel responsible for repair b
activities that he did not wish to witness and presumably otherwise verify repairs to piping and components 1-inch NPS and smaller. To the best of the knowledge and belief of GPC, the former licensee and operator-of VEGP, and its sister company, Southern Nuclear Operating Company i
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l VEGP-2 RR-64 (continued)
Bni foddlef(continued) i I
(SNC), the current licensee and operator of VEGP, any such repairs performed to piping and components 1-inch NPS and smaller were technically sound and were performed in accordance with approved procedures.
1 Because a significant effort would be required to review approximately thirty-one thousand (31,000) Maintenance Work Orders (MWOs) generated for VEGP-2 for the period from May 20, 1989 (date of commercial operation) through October 1996 (time of discovery) for possible non-compliance with a record keeping requirement, it is our position that complying with the record 4
keeping requirements, including use of ASME Form NIS-2 for any such repairs of piping and components 1-inch NPS and smaller, would not provide a commensurate increase in the level of safety if the Code requirements were imposed for record keeping. As a result, reliefis requested from the record keeping requirements for repairs to piping and components 1-inch NPS and smaller. Similar relief was requested for VEGP-1 and was submitted to the NRC for review and approval as part of Revision 8 to VEGP-1 ISI Program document ISI-P-006. Since the identification of this potential non-compliance, plant persohnel responsible for repair activities have been instructed that repairs, irrespective of the size of piping and component involved, are to be properly documented. In addition, the AShE Section XI Repair / Replacement Program was revised to require that repairs, irrespective of the size of the component involved, were to be properly documented. Further, in March 1997, a training course on AShE Section XI (with emphasis on repair and replacement requirements) was held and included personnel directly involved with repair and replacement activities at VEGP. To the best of our knowledge and belief, VEGP-2 has been in Code compliance with the repair requirements for piping and components 1-inch NPS and smaller since October 1996.
IWA-4130 in the 1995 Addenda to AShE Section XI allows application of alternative requirements for replacement to.allrepair and replacement activities. -The alternative requirements are specifically addressed in paragraphs IWA-4131 and IWA-4132 ofIWA-4130 and exclude Class 1,2, and 3 heat exchanger tubes, sleeves, and welded plugs for heat exchanger tubes. It is the position of SNC that steam generators would be similarly excluded since they are considered at VEGP to be. heat exchangers. Had the requirements of this later addenda of the AShE Section XI Code been in effect for the period in question, the record keeping requirements for piping and components 1-inch NPS and smaller would not have been required except for tubes, sleeves, and welded plugs for Class 1,2, and 3 heat exchangers and steam generators.
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o VEGP-2 RR-64 (continued)
Basis for Relief (continued)
As a result, it is our position that compliance with the repair requirements of the 1983 Edition of AShE Section XI with Addenda through Sununer 1983 for piping and components 1-inch NPS and smaller does not provide a commensurate increase in the level of safety if these repair requirements were imposed.
Alternate ExaminatiDD IWA-4130 of the 1995 Addenda to ASME Section XI allows the application of alternative requirements of replacement to all! repair and replacement activities. Although after the fact, it is believed that these have been met for VEGP-2 except possibly for piping and components 1-inch NPS and smaller, ASNE Code Class 1,2, and 3 heat exchangers, and steam generators, e.g.,
steam generator level taps. Because of the numerous MWOs that would have to be reviewed for possible applicability, GPC and its successor, SNC, do not wish to backfit the record keeping requirements of the 1983 Edition of ASME Section XI with Addenda through Summer 1983 for any past instances involving repairs to piping and components 1-inch NPS and smaller, particularly in light of the equalization of repair and replacement requirements as found in the 1995 Addenda to the Code.
Luslification [quhdranting_of Relief The 1983 Edition of AShE Section XI Code with Addenda through Summer 1983 provides an exemption for replacement items 1-inch NPS and smaller from the requirementn ofIWA-7000, but repairs to such items are not similarly exempted. Therefore, a repair to an item is subject to more restrictive requirements than replacing them.
IWA-4130 in the 1995 Addenda to AShE Section XI allows application of alternative requirements for replacement to aLirepair and replacement activities. The alternative requirements are specifically addressed in paragraphs IWA-4131 and IWA-4132 ofIWA-4130.
Heat exchanger tubing, sleeves, and welded plugs used for plugging heat exchanger tubes for Class 1,2, and 3 systems are excluded from the alternative requirements ofIWA-4130.
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a
.Y_E_QP3 RR-64 (continued)
Inslif1CaliQaf_oLthe_Qranting of Relief _(continued)
It is the position of SNC that steam generators at VEGP would be similarly excluded since they are considered to be heat exchangers.
Except for steam generator tube plugs which were welded in place at the time the VEGP steam generators were manufactured, there have been no steam generator tube plugs installed by welding. All steam generator tube plugs currently installed (except for those welded plugs installed by the steam generator manufacturer) are of the mechanical type. No steam generator tubes have been repaired using welding nor have any sleeves been installed using welding during plant operation for the period of time in question. While ASME Section XI provides guidance for repair activities with respect to the steam generators, plant Technical Specifications in effect at that time (i.e., former Technical Specification 3/4.4.5) provided requirements which were required to be met, including those for tube inspection and tube plugging. However, during the period of time in question, there may have been repairs made to other piping 1-inch NPS and smaller associated with the steam generators, e.g., piping for level taps. Similarly, during the period in question, there may have been repairs conducted on piping' and components 1-inch NPS and smaller in ASME Code Class 1,2 and 3 heat exchangers.
In addition to the foregoing, corrective actions have occurred which will help prevent future problems in Code compliance with repairs to piping and components 1-inch NPS and smaller.
These include the following:
Since identification of this potential non-compliance, plant personnel responsible for repair activities have been instructed that repairs, irrespective of the size of piping and components involved, are to be properly documented, The plant ASME Section XI Repair / Replacement Program was re0ised to address repairs to piping and components irrespective of the size involved, and A training session on ASME Section XI (with emphasis on repairs and replacements) was e
held. Participants included plant personnel directly responsible for repair / replacement activities and others, including, but not limited to, representatives from Quality Control, Quality Assurance, and other departments; as well as the current ANII.
j To the best of our knowledge and belief, we have been in compliance with the Code requirements for repairs to piping and components 1-inch NPS and smaller since the potential non-compliance was identified and corrective actions implemented.
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VEGP-2 RR-64 (continued) l Justification for the Granting of Relieficontinued) l l
Imposing the requirements of the 1983 Edition of ASME Section XI with Summer 1983 Addenda
{
retroactively to any repairs conducted to piping and components 1-inch NPF and smaller for the period from May 20,1989 until October 1996 when the subject non-compliance was confirmed and remedied would present an undue hardship in light of changes in the Code. Without l
reviewing each of the approximately thirty-one thousand (31,000) maintenance work order packages, the exact number of potential non-compliances cannot be quantified. All repair and I
replacement requirements are believed to have been met except possibly the record keeping requirements,i.e., completion of an AShE Form NIS-2," Owner's Report for Repairs and Replacements", for piping and components 1-inch NPS and smaller. It is our belief that the l
number of any such occurrences of repairs to items 1" NPS and smaller are relatively few and are ofminor safety significance. There are no other areas of non-compliance associated with this l
particular issue to the best of our knowledge and belief. We acknowledge that cost is not considered a burden in complying with the Code requirements. However, we do not believe that record keeping requirements should be retroactively imposed in this instance since no similar l
record keeping requirement exists for replacements 1-inch'NPS and smaller. No commensurate increase in the level of quality and safety would be achieved if we were to administratively backfit any repairs to items 1-inch NPS and smaller that are within the scope of the VEGP-2 ISI Program. Nor would there be a decrease in the margin of public health and safety if this administrative function, i.e., completion of an AShE Form NIS-2, " Owner's Report for Repairs l
and Replacements", was not performed. AShE has concluded that the repair requirements for items 1-inch NPS and smaller should be similar to those for replacements which do not require similar actions for small items 1-inch NPS and smaller. This is documented in AShE Section XI l
Code Case N-544 whose provisions were incorporated into the 1995 Addenda to AShE Section l
XI. Any repairs would have been performed using various existing approved procedures and/or programs as required by 10 CFR 50, Appendix B, which established control on the planning, work control, quality assurance / quality control, and implementation of work packages. As a result, it is requested that the proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that an undue hardship would be imposed if the Code requirements were retroactively imposed for the period in question.
Implementation Schedule This relief request is applicable to the First Ten-Year Interval on VEGP-2 which concluded May l
30,1997, as authorized by the NRC with the early update of the VEGP-2 ISI Program.
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