ML20236C471

Forwards Addl Info on Inservice Insp Program,In Response to NRC 870814 Request.Nrc Should Note That Inservice Insp Plan Dynamic Document That May Change in Content & Scope from Outage to Outage

ML20236C471
Person / Time
Site:	Vogtle
Issue date:	10/21/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-3321, NUDOCS 8710270209
Download: ML20236C471 (14)

Text

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[

' Georgia rower Company e

333 Pi:dmont Avenue Atlanta, Georgia 30308 f

Telephone 404 526 6526 Mailing Address:

Fbst office Box 4545 Atlanta. Georgia 30302 L

Georgia Power L.T.Oucwa Ihmulheto CWI'C system Manager Nuclear Safety and Ucensing SL-3321 0541m X7GJ17-V770 October 21, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk g

Washington, D.C.

20555 a

R c-PLANT V0GTLE - UNIT 1 52

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NRC DOCKET 50-424 3 55 y'

OPERATING LICENSE NPF-68

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ADDITIONAL INFORMATION ON THE

> a i

INSERVICE INSPECTION PROGRAM g

Gentlemen:

C The enclosed information is submitted by Georgia Power Company (GPC) in response to the NRC letter dated August 14, 1987 which requested additional information concerning the Plant Vogtle - Unit 1 first 10-year interval Inservice Inspection Program.

In response to your broad requests for additional information identified in the referenced letter as "A",

"B",

and "J", GPC feels it necessary to submit a copy of our complete Inservice Inspection Plan.

Five copies of this submittal and its enclosures should be forwarded to the Office of Nuclear Reactor Regulation.

A copy of this submittal has been forwarded to NRC Region II.

It should be noted that the Inservice Inspection Plan is a dynamic document that may change in content and scope from outage to outage.

The plan is a guidance document that indicates what categories and quantities 1

of welds and components will be examined during the ten-year interval to meet the requirements of the ASME Boiler and Pressure Vessel Code,Section XI.

Typically, welds or components of an examination category are scheduled for examination.

However, due to situations such as inaccessibility, or high radiction areas, a specified weld or component may not always be examined.

Generally, another weld or component of the same examination category is examined. At times, it may be necessary to j

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Georgia Power b U. S. Nuclear Regulatory Commission October 21, 1987

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examine a number of welds or components either less than or greater than that specified in the plan for a given outage.

The code requirement is l

to examine the appropriate percentage of welds or components during each

{

of the three 40-month inspection periods which comprise the 10-year j

(120-month) inservice inspection interval.

As discussed in our telephone conversation of September 24, 1987, we request that this condition should i

be noted in the Safety Evaluation Report (SER) to preclude a possible i

future misinterpretation relative to conformance with the Inservice Inspection Plan.

l Additionally, it should be noted that in the response to several NRC l

questions pertaining to relief requests, GPC is requesting NRC review and i

approval to minimize the number of. future interpretational differences that arise between NRC inspection personnel and the methods utilized by GPC to perform certain Code-required examinations.

If appropriate wording can be incorporated into the SER, GPC withdraws the requests for relief.

Should you have any questions, pleasa contact my office at any time.

Sincerely, fkeAb2v L. T. Gucwa PAH/im

Enclosures:

1.

Additional Information on the Inservice Inspection Program 2.

Vogtle Unit 1 Inservice Inspection Plan document (s) c:

(see next page)

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.c (Icorgia P'cnver AbL U.'S. Nuclear Regulatory Commission October 21, 1987-Page.Three l

c: 'Georaia Power Company:

I Mr..R. E. Conway-(w/o encl.)

.Mr..J. P. O'Reilly (w/o encl.)'

3 Mr.'G.,Bockhold, Jr.

r Mr. J. F. D'Amico (w/o encl.)

~

-Mr. C. H. Hayes (w/o' encl-)<

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.G0-NORMS Southern'Comoany Services Mr. R. A. Thomas (w/o encl.)

l LMr. J. A. Bailey (w/o encl.)

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-Shaw. Pittman. Potts & Trowbridae Mr.fB. H. Churchill, Attorney-at-Law (w/o encl.)

Troutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law.(w/o encl.)

l U. S. Nuclear Reaulatory Commission Dr. J. N. Grace, Regional Administrator Ms. M. A. Miller, Licensing Project Manager, NRR -(2 copies).

Mr.'J. F. Rogge, Senior Resident. Inspector-0perations, Vogtle EG&G Idaho Mr. Boyd Brown 4

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-l Georgia Power n ENCLOSURE ~

PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 ADDITIONAL-INFORMATION ON THE INSERVICE INSPECTION PROGRAM On August:14, 1987,- the NRC submitted to Georgia Power _ Company (GPC)-

a urequest for additional ~information on the Inservice, Inspection Program for Vogtle

-s unit 1.

A response was requested by October 15, 1987.

Transcription-of each of the NRC questions precedes GPC's response. _

J 1

'A.

NRC Ouestion "The " Lina Designation List" (Section 7.0) lists the lines within the scope of the ASME Code Section XI.

The tables identify the lines by system,- line number,-

size, Code class, -temperature,. pressure, examination method (s)

required, and basis for exemption.(if applicable).

Hill' all of the welds on the lines identified for examination receive ISI examinations during the first 10-year-interval?. If not, provide the staff with an itemized-listing of the components, by. system, which will be~ subject to examination during the first'.10-year interval.

The requested -listing is necessary to permit the staff - to determine' if the extent of ISI examinations l

per_ formed during the first 10-year interval will meet the applicable regulations and Code requirements."

GPC Resoonse No.

All of the welds on the lines identified for examination are not 5

being examined.

There is no ASME Section XI Code requirement for M of the welds on 6 of the lines to' be examined.

The program, as submitted, meets Code requirements.

The itemized listing of d

components, by system, which will be subject to examination during the first 10-year interval is contained in the Inservice Inspection Plan. A copy of the plan is enclosed.

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ENCLOSURE (Continued)

ADDITIONAL. INFORMATION ON THE INSE0VICE INSPECTION PROGRAM I

B.

NRC Ouestion

" Provide isometric and/or component. drawings showing the welds, components, and supports which are required to be examined by.Section XI of the ASME Code."

1 GPC Response Isometric and/or component drawings showing the Class I and II welds, I

components. and supports which are ' required to be examined by -Section

.I XI of the ASME Code -are in the Inservice Inspection Plan.

A copy of i

. the Inservice Inspection ' Plan is enclosed.

Class III components are shown : on design ' drawings, which are available for review at the l

site.

C.

NRC Ouestion.

" Paragraph 1.12 of the ISI Program Plan identifies the Code Cases to be used during.ISI.

Code Case N-34 " Inservice Inspection of Helds on-Nuclear Components,Section XI," as listed in the ISI-Program Plan j

was-annulled-November. 20, 1981.

Regulatory Guide 1.147, Revision 5 states:

" Code Cases that were endorsed by the NRC in a prior version of this guide and were later annulled by action of the ASME Council should be considered as deleted from the list of acceptable Code

-Cases as of the date of the ASME Council action that approved the i

annulment."

I 1

It -is also noted that Code Cases N-236, N-307, and N-335, as listed in the ISI Program Plan, have been superseded by Code Cases N-236-1, N-307-1 and N-335-1.

The Licensee should upgrade to these later revisions."

GPC Response 1

As specified in paragraph 1.9.147 of the Plant Vogtle - Final Safety Analysis Report (FSAR), GPC is committed to Regulatory Guide 1.147, Revision 4, and not Revision 5 as the NRC question states.

Revision 4-endorses code cases N-34, N-236, N-307, and N-335 and our program, as submitted : complies with Revision 4.

At this time, our Inservice 1

0541m E-2 10/21/87 SL-3321 i

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Georgia Power A ENCLOSURE-(Continued)

ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM Inspection Plan d'oes not' utilize Code case N-34.

Inservice inspection (ISI). activities associated with-Code Case N-307 (ultrasonic testing of class 1 bolting) will 'be performed utilizing N-307 as referenced in Revision 4 of Regulatory Guide 1.147.

Georgia Power Company does not plan, at this time, to upgrade to these later code revisions contained in Regulatory Guide 1.147 Revision 5.

At i

the time we prepare our second 10-year ISI progra'm and plan, we'will-review applicable document revisions and determine what, if any, changes are required to our-Inservice Inspection Program and Plan.

In order to eliminate confusion, specific references to code cases will be deleted from Section 1.12 and a statement added that.GPC may choose to utilize code cases in accordance with Regulatory Guide 1.147, Rev 4.

D.

NRC Ouestion

" Request for Relief RR-9:

Hith regards to the ISI examination of the

. Reactor Pressure Vessel (RPV) studs, it is noted that Section XI, Paragraph IHA-240 permits the use of alternative examination methods, combination of methods, or newly developed techniques, provided the Inspector is satisfied that the results are demonstrated to be equivalent or _ superior to those of the specified method.

During PSI examinations,

.the Utility verified that the subject bolting examination was based on Code Case N-307-1.

If the ISI examinations I

of the RPV studs are also being performed in accordance with approved Code Case N-307-1, then relief would not be required.

Verify that this Code Case is being used for ISI and, if so, why is relief

]

required?"

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GPC Resoonse The reference to Code Case N-307-1 is not appropriate.

Preservice Inspection examination of RPV studs was performed utilizing Code Case N-307 (see SER Amendment 4, pg. 7).

He agree that Paragraph IHA-240 permits the use of alternative examination methods and could be utilized.

However, in order to preclude future interpretation differences that may occur between GPC and regional inspectors auditing our compliance to the ISI plan, we request that the NRC l

approve our relief request.

If appropriate words could be inserted in the Safety Evaluation Report of the ISI plan, then Georgia Power Company would voluntarily withdraw this relief request.

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Georgia Power L ENCLOSURE (Continued) l l

ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM E.

NRC Ouestion

" Request for Relief RR-13:

Hith regards to ultrasonic calibration blocks used for Pressurizer nozzle-to-safe and examit:ations, the following is reported in NUREG-1137,

" Safety Evaluation Report Related to the Operation of Vogtle Electric 'ienerating Plan, Unit 1

" Supplement 4, Appendix R:

"The staff revian of RR-13, including the drawings of the subject safe-end welds and the materials of l

fabrication (316N stainless steel on the piping side and 316L l

stainless steel on the safe-end side), found no reason why the appropriate calibration blocks should be not obtained and utilized."

"The staff considers inservice examinations of the pressure-retaining dissimilar metal welds such as the subject safe-end welds crucial to plant safety and, therefore, will require that proper calibration blocks be obtained and utilized for all future ISI examinations." At present, the staff has no reason to change its position as stated in SSER 4."

GPC Resoonse i

After additional review, GPC has decided to withdraw Request for l

Relief RR-13.

F.

NRC Ouestion i

" Request for Relief RR-15:

Verify that the Pressurizer surge nozzle I

inner radius section identification number is ll201-V6-002-IR06.

The identification number was listed as 11201-V6-IR16 for PSI."

j GPC Resggnie The pressurizer surge nozzle inner radius section identification number is 11201-V6-002-IR06, not IR16.

G.

NRC Ouestion

" Request for Relief RR-21:

With regards to the volumetric examination of pressure retaining branch pipe connection welds fcr nominal pipe size 4 inches and greater in Class 1 systems, the staff 0541m E-4 10/21/87 SL-3321 t

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' ENCLOSURE (Continued)

ADDITIONAL INFORMATION ON THE INSERVICE' INSPECTION PROGRAM ~

I has recently ~ noted c significant. improvements in the techniques being used for volumetric examinations-from.the branch connection side of

~ the welds.. Discuss what efforts ' Georgia Power Company has made to i

perform theu Code-required volumetric examination from the branch l

Lconnection side of the subject welds listed in~RR-21."

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GPC Resoonse.

GPC and ~our associate company, -Southern Company Services, participate

.in industry-sponsored Non-Destructive Examination (NDE) programs. and make! every attempt - to remain informed of advancements in NDE.

He understand that the. "significant improvements"~ refers to recent calibration'standardsL(or blocks) and examination techniques utilized

at another nuclear. plant.- GPC will contact:this other plant owner to 1

determine if theiri recent. advancements can be incorporated into our.

-ISI program.

At: Lthis ' time, GPC still. requires NRC approval of-1 Request for-Relief RR-21.

If-it is determined that the advances

. incorporated.by the other plant _ owner are applicable for use at Plant i

Vogtle, GPC.may elect to formally withdraw Request for Relief RR-21.

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.H.

NRC Ouestion

" Request' 'for Relief RR-33:

This relief request states:

"The

. pressure retaining studs of Safety Injection Pumps are inaccessible l{

for volumetric. examination while in place under tension.

An l

ultrasonic examination on the pump studs would require removal of the l

cap. nuts.

Removal of the' cap nuts to perform an examination is unwarranted due to the extensive detensioning and retorquing that would be' required on the cap nuts and studs."

The relief request does not provide. adequate technical justification for not performing the code-required examination.

Provide further information with l

l regards to why removal of the cap nuts, in order to perform the Code-required volumetric examination, would cause undue hardship or unusual difficulties without a compensating increase in the level of quality and safety."

GPC Resoonse S

After additional review, GPC has decided to withdraw Request for

-Relief RR-33.

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ENCLOSURE (Continued)

I ADDITIONAL INFORMATION ON THE l

INSERVICE INSPECTION PROGRAM I.

NRC Ouestion

" Request for: Relief RR-35:

For the augmented volumetric examination of thin-walled (less'than 0.5 inch wall thickness) and small diameter

. Class 2 piping welds in the Engineered Safety Systems, Georgia Power Company - has - requested relief from using calibration standards as' required by Section XI, Article III.

Paragraph III-3410 requires l

.that the basic. calibration block shall be made from material of the same nominal diameter and nominal wall thickness or pipe schedule as the. pipe to' be examined.

Paragraph III-3430 requires that basic 1

calibration blocks shall contain circumferential and longitudinal a

notches whose sides are perpendicular to the surface, at least 1.0 inch long on the 0.D. and I.D. surfaces.

i The following is reported in NUREG-1137, " Safety Evaluation Report Related.to the Operation of Vogtle Electric Generating Plant, Unit 1," Supplement 4, Appendix R:

"RR-35:

Although the staff has found I

this relief request acceptable for PSI, the Applicant should obtain appropriate calibration standards which meet the requirements of ASME l

Code Section XI, Paragraphs III-3410 and III-3430 for all future ISI examinations."'

At present, the staff has not reason to change its position as stated in SSER 4."

GPC Response He will modify Request for Relief RR-35 to delete the request for relief from calibration block requirements.

GPC will obtain appropriate calibration standards.

J.

NRC Ouestion

" Provide a list of the calibration standards being used during the first 10-year interval ISI at Vogtle.

This list should include the calibration standard identifications, material specifications, and l

sizes."

l GPC Response The list of calibration standards being used during the first 10-year interval can be found in the ISI Plan document.

0541m E-6 10/21/87 SL-3321 700775

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! Georgia Power h ENCLOSURE (Continued)

ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM p

K.

NRC Ouestion

" Request for Relief RR-38:

Based on information submitted in RR-38 with regards to Subsection IHE, it appears that relief is not required.

Therefore, the Licensee should -provide clarification with regards to the requirement for which relief is requested or consider withdrawing RR-38."

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p GPC Resoonse Part 50.55a of Title 10 of the Code of Federal Regulations requires compliance with Section XI of the ASME Code, whir.:

includes 3

Subsection IHE.

Federal Register, Vol. 48, No. 28 Monday, February 7,

1983, Page 5532 indicates that Subsection IHE is not required since this subsection is, at the current time, under evaluation.

Nevertheless, GPC still believes that we are required to submit a relief. request although it is generally known that the NRC has exempted Subsection INE from being incorporated into other ISI plans and programs.

L.

NRC Ouestion

" Request for Relief-RR-41:

Based on the PSI evaluation of RR-41 in NUREG-1137, " Safety. Evaluation Report Related to the Operation' of Vogtle Electric Generating Plan, Unit 1". Supplement 4, Appendix R, it was. determined that relief was not required.

This was determined based on the PSI review of RR-41 and Code Section XI, paragraph IHA-240, which permits the use of alternative examining methods, a combination of methods, or newly developed techniques, provided the Inspector is satisfied that the results are demonstrated to be t

j equivalent or superior to those of the specified method.

Based on I

the above, provide additional information with regards to why relief I

is being requested."

GPC Resoonse GPC agrees that we could invoke paragraph IHA-2240, however, GPC requetts that the NRC approve our Request for Relief RR-41 in order to preciuoc any future interpretational difference that may occur I

between GPC and NRC ngional inspectors.

If appropriate wording can be incorporated bio the SER of the Inservice Inspection Progra'n, then GPC would voluntarily withdraw this relief request.

0541m E-7 10/21/87 SL-3321

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- Georgia Power A ENCLOSURE.(Continued)

ADDITIONAL INFORMATION ON THE-1 INSERVICE INSPECTION PROGRAM l

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NRC Ouestion

" Request for Relief RR-42:

Hith regards to the Steam Generator inlet and outlet nozzles listed in RR-42, provide drawings or sketches-showing the typical--configuration of the nozzle inner radius sections and discuss ' efforts. that Georgia Power Company has made to perform the code-required volumetric. examination, or any limited volumetric examinations, on the subject nozzle inner radius sections."

GPC Resoonse' The -steam generator primary side nozzles are integrally cast as a part of the channel head; therefore, no welds exist which require volumetric examination.

The steam generator nozzle inner radiused section cannot be ' volumetrically. examined from the outside of the nozzle or channel head because the rough, as-cast contact surface is not suitable for ultrasonic

coupling, and the geometrical

' configuration requires an excessively long test metal distance resulting ~ in L high - ultrasonic attenuation.

The inside of the nozzle and channel head areas are covered with cladding in the "as-welded" condition; therefore, meaningful volumetric examination cannot be performed from the "as-welded" surface.

Even with proper preparation of ~the inside surface for volumetric examination, an adequate examination of. the area of interest (base metal just below the claddi_ ng) could not be-achieved due to the resulting ultrasonic response at the clad-to-base metal interface.

The inside surface of each steam generator primary side nozzle inner radiused section will be visually examined to the extent practical.

The examination area will include the inner radius surface region shown in ASME Section XI, Figure IHB-2500 to the extent practical. A i

section drawing of the steam generator primary inlet and outlet i

coolant nozzle has been provided.

l N.

NRC Ouestion

" Request for Relief RR-43:

This relief request states that the alternative testing program for hydraulic and mechanical type snuhers, based on the Plant Technical Specifications, is designed to i

demonstrate the functional integrity of the snubbers and is, as l

1 east, equivalent to the requirements of Article INF-5000.

Briefly, l

describe how the proposed alternative testing program meets or j

exceeds the requirements of IHF-5000."

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Georgia Power s ENCLOSURE (Continued) 1 ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM l

x GPC Resoonse l

Snubber functional testing will be conducted in accordance with

{

VEGP-1 Technical Specification 3/4.7.8.

The testing that is required

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by technical specification is equivalent to that required by IHF-5000.

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GPC has divided the snubbers into four (4) types as follows:

1.

Paul Monroe Functional Test Per 4.7.8.e.1 2.

Pacific Scientific Functional Test Per 4.7.8.e.3 3.

Anchor Darling Model AD40-AD500 Functional Test Per 4.7.8.e.3 4.

Anchor Darling Model AD1600 - AD 12,500 Functional Test Per 4.7.8.e.1 j

The Paul Monroe snubbers are greater than 50 kips and, as such, would revert to paragraph IWF-5300.

Since this paragraph is being proposed, it was decided to test these snubbers per the sampling requirements of paragraph INF-5400.

No code relief is required for this type of. snubber.

The Pacific Scientific snubbers are not being sampled in the percentages required by paragraph IHF-5400, however, the snubbers are being sampled per the requirements of the Plant Vogtle - Unit 1 Technical Specifications.

Therefore, code relief will be required to sample these snubbers in the requirements of the Technical Specification.

The armnor-Darling snubbers, model AD40 thru AD500, are also being sampled per the requirements of the Plant Vogtle - Unit 1 Technical Specifications, and not the sample requirement by paragraph IWF-5400 in the ASME Section XI code.

Code relief will also be required for this group of snubbers.

The Anchor-Darling snubbers, model AD4,600 thru AD12,500, are being sampled per Technical Specification requirements.

Code relief is required for this group of snubbers.

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ENCLOSURE (Continued)

ADDITIONAL INFORMATION ON THE i

INSERVICE INSPECTION PROGRAM l

The. ASME Section XI Code requires an. additional 10% sample if a snubber fails.

The Technical Specification requires that additional samples are l

based on-the number of failures within a snubber type, and in no case l

1ess than one-half of the initial sample' size.

Code relief will be required to allow testing per the Technical Specifications requirements.

J Code -relief will also be requested from the examination method of Table 1

IWF-2500-1, Item F3.50 which requires a VT-4 examination to be performed on snubbers.

As stated in RR-43, the functional testing will be i'

conducted in accordance with Technical Specification 3/4.7.8.

This testing will utilize personnel trained in the proper use of the test apparatus'using an approved GPC procedure, not VT-4 qualified personnt i.

!a The VT-4 methodology is usually taught by the EPRI NDE center (and others) as part of an overall VT program including VT-1. VT-2, VT-3, and VT-4, not as a separate unit.

To qualify testing personnel who do not 1

normally perform VT-1, VT-2, and VT-3 examination is an unnecessary expense.

In addition, it has been recognized by ASME that this is an i

unnecessary certification.

Therefore, in the Hinter 1984 addenda it was i

removed.

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