ML20296A667

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ASME Section XI Inservice Inspection Program Proposed Inservice Inspection Relief Request N1-I4-LMT-003 Response to Request for Additional Information
ML20296A667
Person / Time
Site: North Anna Dominion icon.png
Issue date: 10/22/2020
From: Mark D. Sartain
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
N1-I4-LMT-003, RO 20-343
Download: ML20296A667 (6)


Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 22, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Serial No.:

NRA/ENC:

Docket No.:

License No.:

20-343 RO 50-338 NPF-4 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

NORTH ANNA POWER STATION UNIT 1 ASME SECTION XI INSERVICE INSPECTION PROGRAM PROPOSED INSERVICE INSPECTION RELIEF REQUEST N1-I4-LMT-003 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated April 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20121A119), Virginia Electric and Power Company (Dominion Energy Virginia) requested relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, requirements for certain inservice inspections (ISi) of component welds for North Anna Power Station Unit

1. Specifically, pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion Energy Virginia requested relief from certain ASME Code inspection requirements and submitted Relief Request N 1-I4-LMT-003 on the basis that these requirements were impractical. The requested relief applies to ASME Code inspections that were attempted during the fourth ISi interval.

In a September 16, 2020 e-mail from Mr. Ed Miller (NRC Senior Project Manager) to Ms.

Diane Aitken (Dominion Energy Virginia Corporate Licensing), the NRC technical staff requested additional information regarding the Relief Request by October 22, 2020.

Dominion's response to the NRC request for additional information is provided in the enclosure to this letter.

The Enterprise Project Identifier (EPID) referenced for this request is L-2020-LLR-0071.

Please contact Erica N. Combs at 804-273-3386 if you have any questions regarding this submittal.

Mark D. Sartain Vice President - Nuclear Engineering & Fleet Support

Serial No.: 20-343 Docket No.: 50-338 RAI Response - Relief Request N1-I4-LMT-003 Page 2 of 3

Enclosure:

Response to NRC Request for Additional Information Proposed lnservice Inspection Relief Request N1-I4-LMT-003 Commitments made by this letter: None

References:

1. Letter from Dominion Energy Virginia to NRC, "North Anna Power Station Unit 1, ASME Section XI lnservice Inspection Program, Relief Request N1-I4-LMT-003, Fourth Interval Period Three Limited Examinations," dated April 30, 2020. [ADAMS Accession No. ML20121A119]
2. Email from Ed Miller to Diane Aitken, dated September 16, 2020 12:42 PM,

Subject:

North Anna Unit-1 Request for Relief N1-I4-LMT-003 (EPID: L-2020-LLR-0071 ).

cc:

Regional Administrator, Region II Serial No.: 20-343 Docket No.: 50-338 RAI Response - Relief Request N1-I4-LMT-003 Page 3 of 3 U. S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, Georgia 30303-1257 Mr. G. E. Miller Senior Project Manager - North Anna Power Station U. S. Nuclear Regulatory Commission Mail Stop 09 E-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Boulevard, Suite 300 Glen Allen, Virginia 23060 NRC Senior Resident Inspector North Anna Power Station

ENCLOSURE Response to NRC Request for Additional Information Proposed lnservice Inspection Relief Request N1-I4-LMT-003 Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Unit 1

Serial No.20-343 Docket No. 50-338 Enclosure Page 1 of 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION PROPOSED INSERVICE INSPECTION RELIEF REQUEST N1-I4-LMT-003 By letter dated April 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20121A119), Virginia Electric and Power Company (Dominion Energy Virginia) requested relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, requirements for certain inservice inspections (ISi) of component welds for North Anna Power Station Unit

1. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(g)(5)(iii), Dominion Energy Virginia requested relief from certain ASME Code inspection requirements and submitted Relief Request N1-14-LMT-003 on the basis that these requirements were impractical.

The requested relief applies to ASME Code inspections that were attempted during the fourth ISi interval.

In a September 16, 2020 e-mail from Mr. Ed Miller (NRG Senior Project Manager) to Ms.

Diane Aitken (Dominion Energy Virginia Corporate Licensing), the NRG technical staff requested additional information regarding the proposed Relief Request by October 22, 2020. Dominion's response to the NRG request for additional information is provided in the enclosure to this letter.

The Enterprise Project Identifier (EPID) referenced for this request is L-2020-LLR-0071.

RAI 1

Issue:

ASME Code,Section XI, 2004 Edition, Mandatory Appendix I, Article 1-2120, requires that ultrasonic examination of vessels other than reactor vessels greater than 2 inches in thickness shall be conducted in accordance with Section V, Article 4. Section B1 of the Relief Request states that two Examination Category C-B, Item C2.21 welds were examined by UT to the extent possible and proposed that examinations already completed at the reduced coverage be counted as meeting the Code requirements.

Section B1 of the Relief Request also states that these two welds were nominally 2.5 inches thick. However, Section B1 of the Relief Request does not state whether the ultrasonic examination of these two welds was performed in accordance with Section V, Article 4, as required by the ASME Code.

Request:

Serial No.20-343 Docket No. 50-338 Enclosure Page 2 of 2 Discuss whether the Examination Category C-8, Item C2.21 welds were examined in accordance with ASME Code,Section V, Article 4, as required by Section XI, Article 1-2120. If not, please provide justification.

Response

The weld examinations for the two Examination Category C-B, Item C2.21 welds in Section B1 of the Relief Request [1] were conducted in accordance with Article 4 of Section V, as supplemented by Table 1-2000-1. This was determined by a review of the applicable examination records provided in Enclosure B1 of the April 30, 2020 Relief Request, which identified Revision 4 of procedure ER-AA-NDE-UT-702 [2] was used to perform the weld examinations. ER-AA-NDE-UT-702 is the Dominion Energy procedure that provides the process to accurately detect, locate, and dimension discontinuities within the specified examination volume applying ultrasonic examination techniques for ferritic vessel welds greater than 2.0" in thickness.

REFERENCES

1. Letter from Dominion Energy Virginia (S/N: 20-056) to NRC, "North Anna Power Station Unit 1, ASME Section XI lnservice Inspection Program, Relief Request N1-I4-LMT-003, Fourth Interval Period Three Limited Examinations," dated April 30, 2020.

[ADAMS Accession No. ML20121A119]

2. ER-AA-NDE-UT-702, "Ultrasonic Examination of Ferritic Vessel Welds Greater than 2.0" in Thickness," Revision 4.