ND-19-0310, Supplement to Request for Alternative: Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2)

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Supplement to Request for Alternative: Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2)
ML19095B590
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/05/2019
From: Whitley B
Southern Nuclear Operating Co
To:
Document Control Desk, Office of New Reactors
Shared Package
ML19095B589 List:
References
ND-19-0310
Download: ML19095B590 (17)
v • d • e


Text

B. H. Whitley Southern Nuclear Director Operating Company, Inc.

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 April 5, 2019 Docket Nos.: 52-025 ND-19-0310 52-026 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Supplement to Request for Alternative:

Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2)

Ladies and Gentlemen:

By letter dated October 19, 2018, Southern Nuclear Operating Company (SNC) submitted a request for an alternative to the requirements of Section XI, IWB-2500, of the ASME Boiler and Pressure Vessel (B&PV) Code, 2007 Edition through 2008 Addenda (code of record) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 in accordance with 10 CFR 50.55a

[ML18292A789]. The proposed request for alternative is applicable to preservice and inservice inspection (PSI/ISI) of specific valve-to-pipe welds listed in Section XI Table IWB-2500-1 Examination Category B-J and Table IWC-2500-1 Examination Category C-F-1, and ASME Class 3 valve-to-pipe welds treated as Class 2 due to leak-before-break (LBB) criteria. On December 13, 2018, the Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI) [ML18347B589]. SNC provided the additional information requested on January 28, 2019 [ML19028A449].

SNC has identified four (4) welds that were inadvertently omitted from the original alternative request. This supplement adds the four (4) welds to the scope of the code alternative and a note that differentiates the location where a weld was made between units. This supplement does not impact the technical basis for the original Code alternative. Additionally, as included in the cover letter for the additional information provided on January 28, 2019, the duration of the proposed Alternative is revised to include the Second Inservice Inspection Internal. The revised duration of the request includes ASME Section XI Preservice Examinations and the First and Second Inservice Inspection Intervals. Finally, the requested approval date is changed from April 18, 2019 to May 3, 2019 to provide additional time for review of these changes. contains information that is considered proprietary; therefore, Enclosure 6 is requested to be withheld from disclosure to the public under 10 CFR 2.390. contains the non-proprietary version of Enclosure 6.

U.S. Nuclear Regulatory Commission ND-19-0310 Page 2 of 4 provides the SNC affidavit for withholding proprietary information contained in . provides the Westinghouse affidavit for withholding proprietary information contained in Enclosure 6.

This letter contains no regulatory commitments. Should you have any questions, please contact Mr. Corey Thomas at (205) 992-5221 .

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 51h day of April 2019.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

~~w.~~

Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company Enclosures 1 - 4: (previously submitted with the original code alternative, VEGP 3&4-PSI/ISI-ALT -06, in SNC letter ND-18-1185) : (previously submitted with supplement 1 to the original code alternative, VEGP 3&4-PSI/ISI-ALT-06S1, in SNC letter ND-19-0007) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Request for Alternative (Proprietary): Preservice and lnservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2) (Withheld Information) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Supplement to Request for Alternative (Non-Proprietary): Preservice and lnservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2) (Publicly Available Information) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (VEGP 3&4-PSI/ISI-ALT-06S2) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Westinghouse Authorization Letter CAW-19-4880, Affidavit, Proprietary Information Notice and Copyright Notice (VEGP 3&4-PSI/ISI-ALT-06S2)

U.S. Nuclear Regulatory Commission ND-19-0310 Page 2 of 4 provides the SNC affidavit for withholding proprietary information contained in . provides the Westinghouse affidavit for withholding proprietary information contained in Enclosure 6.

This letter contains no regulatory commitments. Should you have any questions, please contact Mr. Corey Thomas at (205) 992-5221.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th day of April 2019.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company Enclosures 1 - 4: (previously submitted with the original code alternative, VEGP 3&4-PSI/ISI-ALT-06, in SNC letter ND-18-1185) : (previously submitted with supplement 1 to the original code alternative, VEGP 3&4-PSI/ISI-ALT-06S1, in SNC letter ND-19-0007) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Request for Alternative (Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2) (Withheld Information) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Request for Alternative (Non-Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI/ISI-ALT-06S2) (Publicly Available Information) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (VEGP 3&4-PSI/ISI-ALT-06S2) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Westinghouse Authorization Letter CAW-19-4880, Affidavit, Proprietary Information Notice and Copyright Notice (VEGP 3&4-PSI/ISI-ALT-06S2)

U.S. Nuclear Regulatory Commission ND-19-0310 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)

Mr. D. G. Bost (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)

Mr. T. W. Yelverton (w/o enclosures)

Mr. B. H. Whitley Ms. C. A. Gayheart (w/o enclosure 6)

Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn (w/o enclosure 6)

U.S. Nuclear Regulatory Commission ND-19-0310 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 6)

Ms. A. Whaley (w/o enclosure 6)

Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 6)

Mr. S. M. Jackson (w/o enclosure 6)

Dalton Utilities Mr. T. Bundros (w/o enclosure 6)

Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. C. Churchman (w/o enclosures)

Mr. M. Corletti Mr. M. L. Clyde Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc. (w/o enclosure 6)

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 6)

Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 6)

Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 6)

Mr. K. C. Greene, Troutman Sanders (w/o enclosure 6)

Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 6)

Mr. S. Franzone, Florida Power & Light (w/o enclosure 6)

Southern Nuclear Operating Company ND-19-0310 Enclosure 7 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Request for Alternative (Non-Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI-ALT-06S2)

(Publicly Available Information)

(Enclosure consists of 3 pages, including this cover page.)

ND-19-0310 Supplement to Request for Alternative (Non-Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI-ALT-06S2)

The following are changes to the original Code alternative submittal submitted October 19, 2018 [ML18292A789]. This change adds four (4) additional welds that were inadvertently omitted in the scope of the alternative, adds Note 2, and changes the duration of the request and the requested approval date.

Replace Table 2 of Enclosure 2 (page 20) to add four (4) new welds and note 2 as follows:

Category 2 Wrought Austenitic Valve to Wrought Austenitic Pipe Welds Table 2 Line (a,c)

Safety

  1. Description Line # Size Weld (1) Comments Class (inch)

Pressurizer Spray Valve V110Ato 1 RCSPLL212A 1 4 FW8 Pipe PipetoPressurizer Spray Valve 2 RCSPLL110A 1 4 FW9 V110A Pressurizer Spray Valve V110Bto 3 RCSPLL212B 1 4 FW6 Pipe PipetoPressurizer Spray Valve 4 RCSPL110B 1 4 FW7 V110B 5 PipetoCheck Valve V016A PXSPLL018A 1 8 FW4 Upstream weld 6 PipetoCheck Valve V016B PXSPLL018B 1 8 FW3 Upstream weld 7 PipetoCheck Valve V017A PXSPLL018A 1 8 SW1/FW1(2) Upstream weld 8 PipetoCheck Valve V017B PXSPLL018B 1 8 FW6 Upstream weld 9 PipetoCheck Valve V016A PXSPLL018A 1 8 FW3 Downstream weld 10 PipetoCheck Valve V016B PXSPLL018B 1 8 FW1 Downstream weld 11 PipetoCheck Valve V017A PXSPLL018A 1 8 FW6 Downstream weld 12 PipetoCheck Valve V017B PXSPLL018B 1 8 FW5 Downstream weld Note 1: SW denotes a weld performed in the shop and FW denotes a weld performed in the field. The location of where the welds are performed may change.

Note 2: If both SW and FW are listed for the weld type, then the location where the weld was performed is different between the two units.

2 of 3

ND-19-0310 Supplement to Request for Alternative (Non-Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI-ALT-06S2)

Replace 18th full paragraph of Reason for Request of Enclosure 2 (page 5) as follows:

(a,c)

There are six (6) valves in Category 2 with a total of twelve (12) welds for each unit. The valves and the associated welds are identified in Table 2. The nominal pipe size for these valve-to-pipe welds are NPS 4and NPS 8.

Replace Interval - Interval Dates of Enclosure 2 (page 2) as follows:

Applies to Preservice Inspection and the First and Second Inservice Inspection Intervals Replace Requested Date for Approval of Enclosure 2 (page 2) as follows:

Approval is requested by May 3, 2019 to support performance of the ASME Section XI Preservice and Inservice Inspection weld examinations.

Replace Duration of Proposed Alternative of Enclosure 2 (page 10) as follows:

The duration of the proposed Alternative is the Section XI Preservice Examinations and for the First and Second Inservice Inspection Intervals.

3 of 3

Southern Nuclear Operating Company ND-19-0310 Enclosure 8 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (VEGP 3&4-PSI-ALT-06S2)

(This Enclosure consists of 3 pages, including this cover page.)

ND-19-0310 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (VEGP 3&4-PSI-ALT-06S2)

Affidavit of Brian H. Whitley

1. My name is Brian H. Whitley. I am the Regulatory Affairs Director of Southern Nuclear Operating Company (SNC). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNC.
2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commissions regulations, and in conjunction with SNCs filing on dockets52-025 and 52-026, Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for Alternative (Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI-ALT-06S2). I have personal knowledge of the criteria and procedures used by SNC to designate information as a trade secret, privileged or as confidential commercial or financial information.
3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosure 6 of SNC letter ND-19-0310 for Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for Alternative (Proprietary): Preservice and Inservice Inspection Requirements for Specific Valve-to-Pipe Welds (VEGP 3&4-PSI-ALT-06S2).
4. The following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
a. The information sought to be withheld from public disclosure has been held in confidence by SNC and Westinghouse Electric Company.
b. The information is of a type customarily held in confidence by SNC and Westinghouse Electric Company and not customarily disclosed to the public.

2 of 3

ND-19-0310 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (VEGP 3&4-PSI-ALT-06S2)

c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC and/or Westinghouse Electric Company.
d. Other reasons identified in Enclosure 9 of SNC letter ND-19-031 0 for Vogtle Electric Generating Plant Units 3 and 4, Westinghouse Authorization Letter CAW-19-4880, Affidavit, Proprietary Information Notice and Copyright Notice.
5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with the Westinghouse Electric Company regarding proprietary information.

SNC is contractually obligated to seek confidential and proprietary treatment of the information.

6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
7. To the best of my knowledge and belief, the information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method.

I declare under penalty of perjury that the foregoing is true and correct.

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Brian H. Whitley Executed on tf/ 'It~

Date 3 of 3

Southern Nuclear Operating Company ND-19-0310 Enclosure 9 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Westinghouse Authorization Letter CAW-19-4880, Affidavit, Proprietary Information Notice and Copyright Notice (VEGP 3&4-PSI/ISI-ALT-06S2)

(This Enclosure consists of 6 pages, including this cover page.)

ND-19-0310 Westinghouse Authorization Letter CAW-19-4880, Affidavit, Proprietary Information Notice and Copyright Notice (VEGP 3&4-PSI-ALT-06S2)

Enclosed is:

CAW-19-4880, which includes: the Affidavit, Proprietary Information Notice, Copyright Notice The enclosure contains information proprietary to Westinghouse Electric Company LLC (Westinghouse), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission (Commission) and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commissions regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commissions regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-19-4880 and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.

2 of 6

SVP_SV0_005446 Westinghouse Non-Proprietary Class 3 CAW-19-4880 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1) I, Zachary S Harper, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of APP-GW-GEF-850245 Revision 0 as submitted by Southern Nuclear Operating Company Letter ND-19-0310 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

SVP_SV0_005446 Westinghouse Non-Proprietary Class 3 CAW-19-4880 Page 2 of 3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached submittal contains proprietary information throughout, for the reasons set forth in Sections 5 (a) and (c) of this Affidavit. Accordingly, a redacted version would be of no value to the public.

SVP_SV0_005446 Westinghouse Non-Proprietary Class 3 CAW-19-4880 Page 3 of3 AFFIDAVIT I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

Zachary SHarper, Manager Structural and Mechanical Licensing

SVP_SV0_005446 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commissions regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

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