ML20245C331
| ML20245C331 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/21/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20245C334 | List: |
| References | |
| SL-3321, NUDOCS 8710270209 | |
| Download: ML20245C331 (15) | |
Text
.
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' Georgia Ibwer Company.
333 Piedmont Avenue Atlanta. Georgia 30308 Telephone 404 526 6526 Mailing Address:-
Fbst Office Box 4545 Atfanta, Georgia 30302 L'
Georgia Power l
L T. Gucwa tN sout'revn eu#c system Manager Nuclear Safety and Licensing SL-3321-0541m X7GJ17-V770 October 21, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk g
-Washington, D.C.
20555 a
8c v1 52 1
PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 3.5 y- '
OPERATING LICENSE NPF-68
?
ADDITIONAL INFORMATION ON THE
> c 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. 0ffice 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 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 radiation 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 Qg LibLs$ ~%
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Georgia Power h U. S. Nuclear Regulatory Commission October 21,.1987 Page Two examine a number of welds or components either less than or greater that that specified in the plan for a given outage.
The code requirement is to examine the appropriate percentage of welds or components during each of the ; three 40-month inspection periods which comprise the ~ 10-year (120-month) inservice inspection interval.
As-discussed in our telephone i
conversation of September 24, 1987, we request that this condition should be noted ' in the Safety Evaluation Report (SER) to preclude a possible future misinterpretation relative to conformance with the Inservice Inspection Plan.
Additionally, it should be noted that in the response to several NRC questions. pertaining to relief requests, GPC is requesting NRC review and 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 1
wording can be incorporated into the SER, GPC withdraws the requests for relief.
Should you have any questions, nMse contact my office at any time.
Sincerely, v
kl.T.Gucwa PAH/lm
Enclosures:
1.
Additional Information on the Inservice Inspection Program 2.
Vogtle Unit 1-Inservice Inspection Plan document (s) c:
(see next page) i 4
1
__-__---_______-_---__n
k Georgia Power L U. S. Nuclear Regulatory Commission October 21, 1987 Page Three c: Georaia Power Comoany Mr. R. E. Conway (w/o encl.)
Mr. J. P. O'Reilly (w/o encl.)
Mr. G. Bockhold, Jr.
Mr. J. F. D' Amico (w/o encl.)
Mr. C. H. Hayes (w/o encl.)
GO-NORMS Southern Cnmpany Services Mr. R. A. Thomas (w/o encl.)
Mr. J. A. Bailey (w/o encl.)
Shaw. Pittman. Potts & Trowbridge Mr. B. W. Churchill, Attorney-at-Law (w/o encl.)
Troutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law (w/o encl.)
U2 S. Nuclear Regulatory 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 I
0541m l
7t0775
1 Georgia Power d 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 request. for' additional information on the Inservice Inspection Program I
.for. Vogtle - Unit 1.
A response was requested by October 15, 1987.
l Transcription of each of the NRC questions precedes GPC's response.
A.
NRC Ouestion J
"The "Line 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).
Will 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 performed during the first 10-year interval will nieet the applicable regulations and Code requirements."
GPC Response No.
All of the welds on the lines identified for examination are not being examined.
There is no ASME Section XI Code requirement for M of the welds on G of the lines to be examined.
The program, as submitted, meets Code requirements.
The itemized listing of I
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.
l l
0541m E-1 10/21/87 SL-3321
Georgia Power d ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE l
INSERVICE INSPECTION PROGRAM i
l 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."
~
i GPC Response Isometric and/or component drawings showing the Class I and _ II welds, components' and supports which are required to be examined by Section XI. of the ASME Code are in the Inservice Inspection Plan.
A copy of the Inservice Inspection Plan is enclosed.
Class III components are shown on design drawings, which are available for review at the 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 l
was annulled November 20, 1981.
Regulatory Guide 1.147, Revision 5 states:
" Code Cases that were endorsed by the NRC in a prior version l
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 annulment."
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."
I GPC ResDonse As specified in paragraph 1.9.147 of the Plant Vogtle - Final Safety i
Analysis Report (FSAR), GPC is committed to Regulatory Guide 1.147, i
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, 1
as submitted, complies with Revision 4.
At this time, our Inservice 0541m E-2 10/21/87 L
SL-3321 i
a
k Georgia Power s ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM Inspection Plan does not utilizo 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 the time we prepare our second 10-year ISI program 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 Peactor Pressure Vessel (RPV) studs, it is noted that Section XI, Paragraph IWA-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 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?"
Ct_C_Rgip2nie P
n 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 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.
0541m E-3 10/21/87 SL-3321 rwm
k Georgia Power z.
ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE INSERVICF._ INSPECTION PROGRAM E.
NRC Ouestion
" Request for Relief RR-13:
Hith regards to ultrasonic calibration blocks used for Pressurizer nozzio-to-safe and examinations, the following is reported in NUREG-1137, "SP fety Evaluttion Report Related to the Operation of Vogtle Electric Generating flan, Unit 1,
" Supplement 4, Appendix R:
"The staff review of RR-13, including the drawings of the subject safe-end welds and the materials of fabrication (316N stainless steel on the piping side and 316L 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_RPJip.ollift After additional review, GPC has decided to withdraw Request for Relief RR-13.
F.
NRC Ouestion
" Request for Relief RR-15:
Verify that the Pressurizer surge nozzle inner radius section identification number is 11201-V6-002-IR06.
The identification number was listed as 11201-V6-IR16 for PSI."
GPC Resoonse 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 for nominal pipe size 4 inches and greater in Class 1 systems, the staff 0541m E-4 10/21/87 SL-3321 700775
4 k
Georgia Power n ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAE l
has recently noted significant improvements in the techniques being I
used for volumetric examinations from the branch connection side of the welds.
Discuss what efforts Georgia Power Company has made to perform the Code-required volumetric examination from the branch connection side of the subject welds listed in RR-21."
GPC Respanie 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.
We understand that the "significant improvements" refers to recent calibration standards (or blocks) and examination techniques utilized at another nuclear plant.
GPC will contact this other plant owner to determine if their recent advancements can be incorporated into our ISI program.
At this time, GPC still requires NRC approval of Request for Relief RR-21.
If it is determined that the advant.cs incorporated by the other plant owner are applicable for use at Plant Vogtle, GPC may elect to formally withdraw Request for Relief RR-21.
H.
NRC Ouestion
" Request for Relief RR-33:
This relief request states:
"The pressure retaining studs of Safety Injection Pumps are inaccessible fe volumetric examination while in place under tension.
An ultrasonic examination on the pump studs would require removal of the 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 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 Resgonie After additional review, GPC has decided to withdraw Request for Relief RR-33.
l l
0541m E-5 10/21/87 l
SL-3321
'~m w _ _-__
k Georgia Power n ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE JFSERVICE INSPECTION PROGRAM I.
tLR_C Ouestion l
" Request for Relief RR-35:
For the augmented volumetric examination of thin-walled (less than 0.5 inch wall thickness) and small diameter Clasr 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 that toe 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 calibration blocks shall contain circumferential and longitudinal notches whose sides are perpendicular to the surface, at least 1.0 inch long on the 0.D. and I.D. surfaces.
The following is reported in NUREG-1137, " Safety Evsluation Report Related to the Operation of Vogtle Electric Generating Plant, Unit 1," Supplement 4, Appendix R:
"RR-35:
Although the staff has found this relief request acceptable for PSI, the Applicant should obtain I
appropriate calibration standards which meet the requirements of ASME Code Section XI, Paragraphs III-3410 and III-3430 for all future ISI examinations."
At present, the staff has not reason to
ge its position as stated in SSER 4."
GPC Resoonse He will modify Request for Relief RR-35 to delete the request for relief from calibration block requirements.
GPC will obtain appropriate calibration star.dards.
J.
MRC 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 sizes."
GPC Resoonse 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 I
SL-3321 L-
'* " 5
,=
k Georgia Power h 4
ll ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM q
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."
GPC Resoonse Part 50.55a of Title 10 of the Code of Federal Regulations requires compliance with Section XI of the ASME
- Code, which includes l
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 i
relief request although it is generally known that the NRC has exempted Subsection IHE 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 i
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 equivalent or superior to those of the specified method.
Based on the above, provide additional information with regards to why relief 1
is being requested."
l l
GPC Response GPC agrees that we could invoke paragraph IHA-2240, however, GPC requests that the NRC approve our Request for Relief RR-41 in order I
to preclude any future interpretational difference that may occur between GPC and NRC regional inspectors.
If appropriate wording can l
be incorporated into the SER of the Inservice Inspection Program,
]j then GPC would voluntarily withdraw this relief request.
0541m E-7 10/21/87 SL-3321 j
i 2
1 700775
k
(
Georgia Power h l
ENCLOSURE (Continued)
ADDITIONAL INFORMATION ON THE INSERVICE INSPECTION PROGRAM H.
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 l
examinations, on the subject nozzle inner radius sections."
l GPC Respanie The steam generator primary side nozzles are integrally cast as a part of the channel head; therefore, no welds exist which reauire l
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 high ultrasoc.ic 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 l
cladding) 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 ASHE Section XI, Figure IHB-2500 to the extent practical.
A section drawing of the steam generator primary inlet and outlet coolant nozzle has been provided.
N.
NRC Ouestion
" Request for Relief RR-43:
This relief request states that the alternative testing program for hydraulic and mechanical type snubbers, based on the Plant Technical Specifications, is designed to demonstrate the functional integrity of the snubbers and is, as least, equivalent to the requirements of Article IWF-5000.
- Briefly, describe how the proposed alternative testing program meets or exceeds the requirements of IHF-5000."
0541m E-8 10/21/87 SL-3321 L.
tam
k Georgia Power L ENCLOSURE (Continued) j ADDITIONAL INFORMATION ON THE JXSERVICE INSPECTION PROGRAM GPC RRIDDnie Snubber functional testing will be conducted in accordance with VEGP-1 Technical Specification 3/4.7.8.
The testing that is required by technical specification is equivalent to that required by IWF-5000.
j 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 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 IWF-5400.
No code relief is required for this type of snubber.
{
The Paci fic Scientific snubbers are not being sampled in the percentages required by paragraph IWF-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 Anchor-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.
I The Anchor-Darling snubbers, model AD4,600 thru AD12,500, are being l
sampled per Technical Specification requirements.
Code relief is required for this group of snubbers.
l 1
i 0541m E-9 10/21/87 l
SL-3321 i
i N75
____U
k Georgia Power h ENCLOSURE (Continued)
ADDITIONAL.INFORMATION ON THE 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 based on the number of failures within a snubber type, and in no case less than one-half of the initial sample size.
Code relief will be l
required to allow testing per the Technical Specifications requirements.
1 Code relief will also be. requested from the examination method of Table 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 personnel.
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 4
VT-4, not as a separate unit.
To qualify testing personnel who do not 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 unnecessary certification.
Therefore, in the Hinter 1984 addenda it was removed.
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Georgia Power Company 333 Piecmont Avenue Atlanta. Georg4a 30308 Telephone 404 526 6526 Maihng Address.
Post office Box 4545 Atf aNa. Georgia 30302 L
Georgia Power
[
L. T. Gucwa Manager Nuclear Safety and Licensing SL-3321 0541m X7GJ17-V770 October 21, 1987 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 ADDITIONAL INFORMATION ON THE JNSERVICE INSPECTION PROGRAM Gentlemen:
l 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 i 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 i
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 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 radiation 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 necetsary to y ;/0 M d /q
_ _ - - _ _ _ _ _ -. -. _. - _. _ _ _ _ _