ML20212E602
| ML20212E602 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/23/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| SL-1684, NUDOCS 8701050371 | |
| Download: ML20212E602 (4) | |
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e Georgia Fbwer Company 333 Piedmont Avenue Atfanta, Georgia 30308 Telephone 404 526-6526 Mailing Address:
Post Office Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucws the southem estnc system Manager Nuclear Safety and Licensing 0961C December 23, 1986 U.S. Nuclear Regulatory Comission c
ATTN: Document Control Desk Washington, D. C.
20555 NRC DOCKET 50-424 CONSTRUCTION PERMIT CPPR-108 V0GTLE ELECTRIC GENERATING PLANT UNIT 1 POSITION ON SUBMITTAL OF ASME CODE, SECTION XI, NIS-1 REPORT FOR PRESERVICFINSPECTION Gentlemen:
Paragraph IWA-6230 of the ASME Code,Section XI,1980 Edition with Addenda through Winter 1980, to which Georgia Power Company's (GPC)
Vogtle Unit 1 preservice inspection was conducted requires that an inservice inspection summary report be filed with the enforcement and regulatory authorities having jurisdiction at the plant site.
As indicated by the Code, the subject report is required to be filed "within 90 days of the completion of the inservice inspection conducted during a refueling outage."
While the term " inservice inspection," as cited in Subparagraph IWA-2110(c) of the Code, includes preservice requirements (unless distinction is made in the text of the Code), it is our position, as recently discussed with the NRC Region II staff, that an inservice inspection sumary report, i.e.,
"0wner's Data Report for Inservice Inspection" (Form NIS-1),
does not need to be submitted for the preservice inspection conducted at Vogtle Unit 1.
Our position is based upon an interpretation of a Code inquiry and additional discussion provided herein.
This letter is to be directed to NRC Region II for review in lieu of NRC NRR, because inservice inspection sumary reports are submitted by GPC to the NRC Region II office.
A copy of this letter and enclosure is also being submitted to NRC NRR.
The ASME Code,Section XI, Interpretation XI-1-83-15, which was issued on April 19, 1983, indicates that it was not the intent of the Code to require filing of the inservice inspection sumary report, i.e.,
"0wner's Data Report for Intervice Inspection" (Form NIS-1),
when performing the preservice inspection.
A copy of the subject Code interpretation is enclosed for your information.
While the edition and the addenda of the Code to which the Vogtle Unit 1 preservice inspection was conducted are not specifically identified in the Code inquiry and subsequent Code interpretation, there are no substantive changes in the reporting requirements of Paragraph IWA-6230 between the 1974, 1977, and 1980 editions of the Code and their respective NRC-approved addenda.
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4 Georgia Power A U. S. Nuclear Regulatory Commission December 23, 1986 Page Two Therefore, it is our opinion that ASME Code,Section XI, Interpretation XI-1-83-15 should also envelop the edition and the addenda of the Code to which the Vogtle Unit 1 preservice inspection was conducted.
Accordingly, it is our desire not to submit an inservice inspection summary report for the Vogtle Unit 1 preservice inspection.
We have reviewed the Vogtle Final Safety Analysis Report and the Preservice Inspection Program documents and have found no specific requirement for the submittal of an inservice inspection sumary report for the Vogtle Unit 1 preservice inspection.
In addition, we are of the opinion that a relief request, as allowed by 10 CFR 50.55a, from the requirements of the ASME Code,Section XI is not appropriate, since no specific requirement for the reporting of preservice inspection activities exists in the 1980 Edition of the ASME Code,Section XI, with Addenda through Winter 1980.
We are bringing this matter to your attention because:
(1) the terminology used in the aforementioned-edition and addenda of the Code does not specifically address "preservice inspection" relative to reporting requirements, and (2) 10 CFR 50.55a requires conformance to the Code unless the requirements are demonstrated to be impractical, thus requiring relief from the Code.
For the reasons discussed herein, Georgia Power Company requests your concurrence with our position that the submittal of an inservice inspection summary report for the Vogtle Unit 1 preservice inspection is unnecessary.
At your earliest convenience, please advise us of the results of your review.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, cpr:r & s,
a L. T. Gucwa JAE/lc Enclosure c: Georgia Power Company Mr. R. E. Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
GO-HORMS 0961C ram
4 Georgia Power d U. S. Nuclear Regulatory Commission December 23, 1986 Page Three c:- Georgians Against Nuclear Energy (GANE)
Mr. D. Feig Ms. C. Stangler Shaw, Pittman, Potts and Trowbridge Mr. B. W. Churchill Southern Company Services Mr. J. A. Bailey Troutman, Sanders, Lockerman and Ashmore Mr. J. E. Joiner U.S. Nuclear Regulatory Comission Dr. J. N. Grace, Regional Administrator Mr. H. Livermore, Senior Resident Inspector - Construction, Vogtle Ms. M. A. Miller, Project Manager Mr. J. Rogge, Senior Resident Inspector - Operations, Vogtle Mr. B. J. Youngblood, Project Director 0961C
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e ENCLOSURE Seoen XI - eneerpretations No.13 2814314. EM4315 g g.,pretation: XM4M4 Subject Section XI, Division 1, IWV-3200, Performance Testing of Temporarily Repaired Valves Date issued:
April 4,1983 File:
OC82-626 Question (1): When performing temporary repairs of valves utilizing a high pressure sealing substance (i.e., furmanite), may the repair be exempted from the requirements of IWV 3200 of the 1980 Edition of Sectson XI until the permanent repairs are madet Reply (1): No, the requirements of IWV-3200 must be met.
Question (2): DoesSection XI differentiate between temporary and permanent repairst Reply (2): No.
Interpretation: XI-143-15
Subject:
Section XI,' Division 1, IWA-6230, Use of Inservice inspection Summary Report When Performing Preservice Inspection Date issued April 19,1983 File:
OC82 610 Question (1): Is it a requirement of the 1974 Edition of Section XI, with Addenda up to and
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including the Summer 1975 Addenda, and the 1977, Edition with the Summer 1978 Addenda and e
m subsequent Addenda, that an Inservice inspection Summary Report (IWA 6230) be submitted to the enforcement and regulatory authorities when performing preservice inspection?
Reply (1): No, it is not the intent of Section XI to require filing of the inservice inspection l
Summary Report when performing the preservice inspecten.
Question (2): If the answer to Question (1) is yes, when must the Inservice Inspection Summary Report be submitted for the preservice inspection?
Reply (2): Not applicable.
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