ML20217B112

Application for Amends to Licenses NPF-68 & NPF-81,to Revise TS 5.5.6 Incorporating Exceptions to Reg Guide 1.35,rev 2,as Described in FSAR Section 3.8.1.7.2

ML20217B112
Person / Time
Site:	Vogtle
Issue date:	10/04/1999
From:	Beasley J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217B117	List: ML20217B112 ML20217B122
References
RTR-REGGD-01.035 LCV-1378, NUDOCS 9910120160
Download: ML20217B112 (7)

Text

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J.11ernie Biasley Jr., P.E. Southern Nuclear

-Vice President Operating Company lac.

Vogtle Project 40 invemess Center Parkway P0. Box 1295 Birminghan*. Alabama 35201 Tel 205.992.7110 Fax 205.992.0403 SOUTHERN COMPANY Energy to Serve hur%rld" j l

October 4, 1999 LCV-1378 1 Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 j Ladies and Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT i REQUEST TO REVISE TECHNICAL SPECIFICATIONS l PRESTRESSED CONCRETE CONTAINMENT I TENDON SURVEILLANCE PROGRAM I I

in accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company i (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical SpeciGcations (TS). The proposed change would revise TS 5.5.6, Prestressed Concrete Containment Tendon Surveillance Program. Presently, TS 5.5.6 includes the following statement:

"The Tendon Surveillance Program, inspection frequencies, and acceptance criteria l shall be in accordance with Regulatory Guide 1.35, Revision 2,1976." l The proposed change would incorporate exceptions to Regulatory Guide (RG) 1.35, Revision 2,1976, as described in FSAR section 3.8.1.7.2. Specifically, the proposed change would revise the above statement in TS 5.5.6 as follows:

"The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Regulatory Guide 1.35, Revision 2,1976, with the following exceptions:

1. Number of Tendons Detensioned - Only one vertical and one horizontal tendon are detensioned on Unit I cach time lift-offs are performed on Unit i f

f per figun 5.5.6-1. Only one vertical or one horizontal tendon is detensioned on Unit 1 each time lift-offs are performed on Unit 2 per figure 5.5.6-1.

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2. Concrete inspection - The concrete adjacent to the vertical tendons cannot be inspected due to steel plating covering the concrete. p}

9910120160 991004 PDR ADCCK 05000424

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l 3. The areas adjacent to the tendons are inspected during the tendon surveillance instead of during the ILRT.

Only the Unit I containment is subject to the complete surveillance program. Unit 1 is equ l: conta,ipped with selected tendons specifically designed for detension,mg. The Unit 2 mment has permanent anchorage assemblies (nondetensionable)."

l The basis for the proposed change is provided in Enclosme 1. Pursuant to 10 CFR 50.92, an evaluation that demonstrates that the proposed change does not involve a significant hazard

consideration is provided in Enclosure 2. The proposed change is marked on the affected TS l pages provided in Enclosure 3. In addition, clean typed TS pages are provided in Enclosure j- 4.

SNC requests approval of the proposed change by February 29,2000, to facilitate the performance of containment tendon surveillances for Unit 2.

Mr. J. B. Beasley, Jr. states that he is a Vice President of Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Opera:ing Company and that, to the best of his knowledge and belief, the facts set forth in this letter are

. true.

SOUTHERN NUCLEAR OPERATING COMPANY i

By: ~m /

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'J.'B. B(asleff .

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[ Sworn to andst:bscribed before me this day of , 1999.

% w e.jpa u

, Notary PubMc My commission expires:

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. JBB/NJS Enclosure 1 - Basis for Proposed Changes Enclosure 2 - Significant Hazards Consideration Evaluation Enclosure 3 -Marked-up TS Pages Enclosure 4-Clean Typed TS Pages l

U[S.Nuctect Regulatory Commission LCW1378 Page 3

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xc:- Southern Nuclear Operating Company Mr. J. T. Gasser Mr. M. Sheibani SNC Document Management U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. R. Assa, Project Manager, NRR Mr. John Zeiler, Senior Resident inspector, Vogtle i

. State of Georgia .

Mr. L. C. Barrett, Commissioner, Department of Natural Resources  ;

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Erclosure 1 Vogtle Electric Generating Plant Request to Rev.tse Technical Specifications i

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Prestressed Concrete Containment Tendon Surveillance Program -

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Basis for Proposed Changes Proposed Changes The proposed change would suise TS 5.5.6, Prestsed Concrete Containment Tirndon Surveillance Program. Presently, TS 5.5.6 includes the following statement-  !

I "The Tendon Surveillance Program, inspection frequencies, t ad acceptance criteria shall be in accordance with Regulatory Guide 1.35, Revision 2,1976." l The proposed change would incorporate exceptions to Regulatory Guide (RG) 1.35, Revision 2,1976, as described in FSAR sectica 3.8.1.7.2. Specifically, the proposed change would r-vise the above stater ent in TS 5.5.6 as follows:

"The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Regulatory Guide 1.35, Revision 2,1976, with the following exceptions:

1. Number of Tendons Detensioned - Only one vertical and one horizontal tendon are detensioned on Unit 1 each time litt-offs are performed on Unit 1 per figure 5.5.6-1. Only one vertica'. or one horizontal tendon is detensioned on Unit I each time lift-offs are perfonned on Unit 2 per figure 5.5.6-1.

2. Concrete Inspection - The concrete adjacent to the vertical tendons cannot be inspected due to steel plating covering the concrete.

3. The areas adjacent to the tendons are inspected during the tendon surveillar.ce instead of during the ILRT.

Only the Unit I containment is subject to the complete surveillance program. Unit 1 is equipped with selected tendons specifically designed for detensioning. The Unit 2 contamment has permanent anchorage assemblies (nondetensionable)."

Basis The containments for VEGP each consist of a prestressed reinforced concrete cylinder and hemispherical dome supported on a flat, conventionally reinforced concrete bassmat with a central cavity and instrumentation tunnel to house the reactor vessel. The inside face of the containment is lined with steel plates which are welded together to form a leak-tight barrier and which are anchored to the concrete. The VEGP post-tensioning systems were designed, constructed, and licensed so that no tendons on Unit 2 and only a sample on Unit I can be detensioned without creating voids in the sheathing filler material.

Prior to conversion to the NUREG-1431-based improved Technical Specifications, containment tendon surveillance requirements for VEGP were specified in detail in NUREG-0452-based TS 3/4.6.1.6. The exceptions listed above were approved by the NRC with Amendments 23 (Unit 1) and 4 (Unit 2) on September 12,1989, in their September 12,1989 Safety Evaluativ Rmort (SER), the NRC staff had the following to say about the exceptions. With regard to the numbe: of tenhs to be detensioned, the staff noted that complete detensioning cf a sample tendon is not necessary to due mine if a tendon is defective El-1'

r-I Enclos ra 1 Vogtle Electric Generating Plant Request to Revise Technica! Specifications

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Prestretsed Concrete Cop %inment Tendon Surveillance Program Basis for Proposed Changes and that dismantling and retensioning causes potential damage to the tendon and therefore should be minimized. Therefore, the original requirement to detension all tendons was revised to require that only one tendon of each type be detensioned. At the time that the SER was written, the staff noted that this was reflected in the current draft Revision 3 of RG 1.35, and it is consistent with Revision 3 of RG 1.35 as it wra issued in July 1990. The staff also noted that for Unit 2 tendons, lift-off testing can be done, but detensioning to take strand samples and subsequent retensioning would be very difficult. As stated above, the original design was that tendon surveillance for Unit I would involve the lift-off and detensioning of tendons whereas tendon surveillance for Unit 2 would only involve visual inspection. To resolve this, VEGP agreed to perform lift-off testing on Unit 2 (in accordance with the requirements as shown in figure 5.5.6-1), and detension one tendon on Unit I and remove a strand sample for material te . ting.

With regard to concrete inspection, the survei3ance requirements as approved with Amendments 23 and 4 required that the concrete adjacent to only the hoop tendon anchorages be inspected. The vertical tendon {

anchorages cannot be inspected because they are covered by steel plating. Concrete inspection for large spall, severe scaling, D-cracking, etc., was revised to be performed during tendon surveillance rather than Type A testing. It was noted that internal pressure during the Type A test will not rignificantly affect the condition at end anchoranges and adjacent surfaces. Therefore, it does not justify the additional cost to perform the inspection during the Type A test rather than at tendon surveillance. The concrete inspection requirements are also consistent with Revision 3 of RG 1.35.

These exceptions were reflected in the VEGP TS until implementation of the Improved Technical Specifications The improved Technical Specifications were approved by the NRC with Amendments 96 i and 74 on September 25,1996, and they were implemented at VEGP on January 23,1997. With the implementation of the Improved Technical Specifications, the explicit containment tendon surveillance requirements of old TS 3/4.6.1.6 (reflecting the above exceptions) were moved to the Prestressed Concrete Containment Tendon Surveillance Program required by TS 5.5.6. However, the reference to RG 1.35, Revision 2, as it appears in TS 5.5.6, was not qualified by the above exceptions.' The Bases for Surveillance Requirement (SR) 3.6.1.2 provides for approved exceptions to the Regulatory Guide.

Therefore, SNC intends to perform containment tendon surveillances in accordance with the requirements that were once located in the old TS (including the previously approved exceptions) and have now been moved to the program required by TS 5.5.6. 1 l

Conclusion i

The intent of the implementation of the Improved Technical Specifications was not to change containment tendon surveillance requirements at VEGP, but rather to move the existing requirements to a  ;

program. The containment tendon surveillance requirements had been previously reviewed and approved by the NRC staff with the issuance of Amendments 23 and 4. Therefore, the existing tendon surveilkmce requirements represent current licensing bash, and SNC views this proposed change as a clarification to prevent confusion in the future.

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E :cloure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications t .' Prestressed Concrete Containment Tendon Surveillance Program i

Significant Hazards Consideration Evaluation Proposed Changes The proposed chan;;e would revise TS 5.5.6, Prestressed Concrete Containment Tendon Surveillance i J

Program.- Presently, TS 5.5.6 includes the following statement: i "The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in ,

accordance with Regulatory Guide 1.35, Revision 2,1976." l The proposed change would incorporate exceptions to Regulatory Guide (RG) 1.35, Revision 2,1976, as 3 described in FSAR section 3.8.1.7.2. Specifically, the proposed change would revise the above statement i in TS 5.5.6 as follows:

"The Tendon Surveillance Program, inspection frege:ncies, and acceptance criteria shall be in accordance with Regulatory Guide 1.35, Revision 2,1976, with the following exceptions:

1. Number of Tendons Detensioned - Only one vertical and one horizontal tendon are detensioned on Unit I each time lift-offs are performed on Unit 1 per figure 5.5.t>-1. Only one vertical or one horizontal tendon is detensioned on U iit 1 each time lift-offs are i performed on Unit 2 per figure 5.5.6-1.

2. Concrete Inspection - The concrete adjacent to the vertical'endons cannot be inspected due to steel plating covering the concrete.

3. The areas adjacent to the tendons are inspected during the tendon surveillance instead of during the ILRT.

Only the Unit I containment is subject to the complete surveillance program. Unit 1 is equipped with selected tendons specifically designed for detensioning. The Unit 2 contamment has permanent anchorage assemblies (nondetensionable)."

- Evaluation

'he proposed change has been evaluated against the criteria of 10 CFR 50.92 as follows:

1. Does the proposed change involve a significant increase in the probability or consequences of ar.

accident previously evaluated?

No. The proposed change only clarifies TS requirements for the containment tendon surveillance program. The proposed clarification has been previously reviewed and approved by the NRC staff with Amendments 23 and 4, and it is consistent with current regulatory guidance. As such, the proposed change is essentially administrative in nature. The containment tendon surveillance program has no impact on the probability of any accident initiators, and it will continue to ensure containment structural integrity. Therefore, the proposed change does not involve a significant increase in the consequences of any accident previously evaluated.

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Eccl:svre 2 Vogtic Electric Generating Plant Request to Revise Technical Specifications

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Prestressed Concrete Containment Tendon Surveillance Program Significant Hazards Consideration Evaluation

2. Does the proposed change create the possibility of a new or different kind of accident from any l- previously evaluated?  ;

. No. The proposed change only clarifies TS requirements for the containment tendon surveillance l program. The proposed clarification h ss been previously reviewed and approved by the NRC staff with Amendments 23 and 4, and it is consistent with current regulatory guidance. As such, the proposed change is essentially administrative in nature. Plant design and operation will not be l

changed, and no other safety related or important to safety equipment is affected by the proposed  !

^change. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

No. The proposed change only clarifies TS requirements for the containment tendon surveillance program. The proposed clarification has been previously reviewed and approved by the NRC staff with Amendments 23 and 4, and it is consistent with current regulatory guidance. As such, the proposed change is essentially administrative in nature. The containment prestressing system will continue to perform its function to ensure containment structural integrity. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Conclusion j 1

Based on the above evaluation, the proposed change does not involve a significant hazard as defined in 10 CFR 50.92.

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