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| | number = ML13032A106 | | | number = ML13032A106 |
| | issue date = 02/07/2013 | | | issue date = 02/07/2013 |
| | title = Vogtle Electric Generating Plant, Unit 1 - Safety Evaluation of Relief Request VEGP-ISI-ALT-08, Version 1, Regarding Installation of a Mechanical Clamp on a Class 1 Valve - Fourth 10-Year Interval (TAC No. ME9850) | | | title = Safety Evaluation of Relief Request VEGP-ISI-ALT-08, Version 1, Regarding Installation of a Mechanical Clamp on a Class 1 Valve - Fourth 10-Year Interval |
| | author name = Pascarelli R J | | | author name = Pascarelli R |
| | author affiliation = NRC/NRR/DORL/LPLII-1 | | | author affiliation = NRC/NRR/DORL/LPLII-1 |
| | addressee name = Pierce C R | | | addressee name = Pierce C |
| | addressee affiliation = Southern Nuclear Operating Co, Inc | | | addressee affiliation = Southern Nuclear Operating Co, Inc |
| | docket = 05000424, 05000425 | | | docket = 05000424, 05000425 |
| | license number = NPF-068, NPF-081 | | | license number = NPF-068, NPF-081 |
| | contact person = Martin R E | | | contact person = Martin R |
| | case reference number = TAC ME9850, VEGP-ISI-ALT-08 | | | case reference number = TAC ME9850, VEGP-ISI-ALT-08 |
| | document type = Code Relief or Alternative, Letter, Safety Evaluation | | | document type = Code Relief or Alternative, Letter, Safety Evaluation |
| | page count = 7 | | | page count = 7 |
| | project = TAC:ME9850 | | | project = TAC:ME9850 |
| | | stage = Approval |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 February 7, 2013 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc. Post Office Box 1295 / Bin 038 Birmingham, AL 35201-1295 VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 -SAFETY EVALUATION OF RELIEF REQUESTVEGP-ISI-ALT-08, VERSION 1.0, REGARDING INSTALLATION OF A MECHANICAL CLAMP ON A CLASS 1 FOURTH 10-YEAR INTERVAL (TAC NO. ME9850) | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 7, 2013 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc. |
| | Post Office Box 1295 / Bin 038 Birmingham, AL 35201-1295 |
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| ==Dear Mr. By letter to the U.S. Nuclear Regulatory Commission (NRC),== | | ==SUBJECT:== |
| dated October 25,2012, supplemented by letter dated October 29, 2012, Southern Nuclear Operating Company, (SNC, the licensee) proposed an alternative (VEGP-ISI-AL T-08, Version 1.0) to Appendix IX Section XI of the American Society of Mechanical Engineer's Boiler and Pressure (ASME) Code to allow installation of a mechanical clamp on a non-pressure boundary leak a Class 1 Chemical and Volume Control valve 1-1208-U4-A 11 for the Vogtle Electric Plant, Unit 1 On November 1, 2012, pursuant to Title 10 Code of Federal Regulations, Part Section 50.55a(a)(3)(ii)), the NRC staff verbally authorized the use of the VEGP-ISI-AL T-08, Version 1.0. This safety evaluation documents the technical basis of verbal The NRC staff determines that the proposed alternative provides reasonable assurance structural integrity and leak tightness of the subject components and that complying with specified requirement would result in a hardship or unusual difficulty without a increase in the level of quality and safety. Accordingly, the NRC staff concludes that licensee has adequately addressed all of the regulatory requirements set forth 10 CFR 50.55a(a)(3)(ii), and is in compliance with requirements of the ASME Code, Section for which relief was not requested. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii) NRC authorizes use of the licensee's proposed alternative, VEGP-ISI-AL T-08, Version 1.0, VEGP-1 until the 1 R 18 refueling outage in the spring of C. Pierce -All other requirements in ASME Code, Section XI, and 10 CFR 50.55a for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
| | VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 - SAFETY EVALUATION OF RELIEF REQUESTVEGP-ISI-ALT-08, VERSION 1.0, REGARDING INSTALLATION OF A MECHANICAL CLAMP ON A CLASS 1 VALVE FOURTH 10-YEAR INTERVAL (TAC NO. ME9850) |
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| Sincerely,Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-424
| | ==Dear Mr. Pierce:== |
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| ===Enclosure:===
| | By letter to the U.S. Nuclear Regulatory Commission (NRC), dated October 25,2012, as supplemented by letter dated October 29, 2012, Southern Nuclear Operating Company, Inc. |
| Safety Evaluation cc w/encl: Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUESTVEGP-ISI-ALT-08, VERSION 1.0, REGARDING INSTALLATION OF A MECHANICAL CLAMP ON A CLASS 1 VALVE -FOURTH 10-YEAR INTERVAL SOUTHERN NUCLEAR OPERATING COMPANY, INC. VOGTLE ELECTRIC GENERATING PLANT. UNIT 1 DOCKET NO. 50-424 1.0 INTRODUCTION By letter dated October 25,2012 (Agencywide Documents Access and Management System (ADAMS Accession No. ML 12299A244), as supplemented by letter dated October 29,2012 (ADAMS Accession No. ML 12305A421), Southern Nuclear Operating Company, Inc., the licensee, proposed an alternative (VEGP-ISI-ALT-08, Version 1.0) to Appendix IX of Section XI of the American Society of Mechanical Engineer's Boiler and Pressure Vessel (ASME) Code to allow installation of a mechanical clamp on a non-pressure boundary leak from a Class 1 Chemical and Volume Control valve 1-1208-U4-A 11. The licensee proposes this alternative during the current 2012 operating cycle at the Vogtle Electric Generating Plant, Unit 1 (VEGP-1 ). The licensee states that the mechanical clamp will only be in place until the 1 R18 outage in the spring of 2014 or until an outage of sufficient duration to allow VEGP-1 to either a permanent repair to the affected valve or replace the valve. The licensee also information on the hardship involved with performing a plant shutdown and cooldown to Mode which the licensee assessed as an option. Therefore the licensee requested authorization their proposed alternative under the requirements of Title 10 of the Code of Regulations, Part 50 (10 CFR 50) On November 1, 2012, pursuant to 10 CFR 50.55a(a)(3)(ii)), the NRC staff verbally the use of the Alternative VEGP-ISI-AL T-08, Version 1.0 (ADAMS Accession ML 12307 A411). This safety evaluation documents the technical basis of the 2.0 REGULATORY EVALUATION In this relief request the licensee requests authorization of an alternative to the requirements ASME Code, Section XI, Appendix IX pursuant to 10 CFR 50.55a(a)(3)(ii).
| | (SNC, the licensee) proposed an alternative (VEGP-ISI-AL T-08, Version 1.0) to Appendix IX of Section XI of the American Society of Mechanical Engineer's Boiler and Pressure Vessel (ASME) Code to allow installation of a mechanical clamp on a non-pressure boundary leak from a Class 1 Chemical and Volume Control valve 1-1208-U4-A 11 for the Vogtle Electric Generating Plant, Unit 1(VEGP-1). |
| | On November 1, 2012, pursuant to Title 10 Code of Federal Regulations, Part 50, Section 50.55a(a)(3)(ii)), the NRC staff verbally authorized the use of the Alternative VEGP-ISI-AL T-08, Version 1.0. This safety evaluation documents the technical basis of the verbal authorization. |
| | The NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components and that complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with requirements of the ASME Code, Section XI for which relief was not requested. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii) the NRC authorizes use of the licensee's proposed alternative, VEGP-ISI-ALT-08, Version 1.0, at VEGP-1 until the 1R 18 refueling outage in the spring of 2014. |
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| -Section 50.55a(g)(4) of 10 CFR, states that ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and preservice examination requirements, set forth in the ASME Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that lSI of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a{b) twelve months prior to the start of the 120-month interval, subject to the conditions listed therein. Section 50.55a(a){3) states, in part, that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Based on the above analYSiS, the staff finds that regulatory authority to authorize an alternative to the ASME Code requirement, as requested by the licensee, exists. 3.0 TECHNICAL EVALUATION 3.1 Applicable Code Edition and Addenda The applicable ASME Code, Section XI of record for the third 10-year lSI interval at VEGP-1 is the 2001 Edition through 2003 Addenda. 3.2 Reason for Request On October 7,2012, while performing the VEGP-1 Class 1 leakage test during start-up from the 1 R 17 refueling outage, a steam leak was observed on the Kerotest valve 1-1208-U4-A 11 on the 2-inch pressurizer auxiliary spray line. The steam leak emanated from a pinhole on the seal weld between the threaded connection joining the valve body and bonnet. Because the leakage was occurring at the seal weld, it was determined that the leakage was operational leakage and not reactor coolant pressure boundary leakage. SNC realized that actions would need to be taken to address the leakage. In order to stop steam from escaping through the pinhole in the seal weld a mechanical clamp with sealant was installed on October 13, 2012. Subsequently, steam leakage was re-identified on October 22, 2012. Discussions with the vendor determined that the most likely cause of the recurrence of the leakage was that the sealant had been injected at a temperature lower than that required to ensure proper curing of the material. Replacement of the clamp with a similar clamp and reinjection of the sealant is desired to prevent leakage until a permanent solution can be implemented. 3.3 Licensee's Proposed Alternative Section XI, Appendix IX provides rules for the installation of mechanical clamps on Class 2 and 3 pressure boundary leakage. The licensee proposed to use the rules of Appendix IX as guidance for installation of a mechanical clamp on the Class 1 non-pressure boundary leakage. The replacement clamp is the same design as the original clamp except with a relocated sealant injection port. The clamp and the sealant will encapSUlate the leak and will replace the seal | | C. Pierce - 2 All other requirements in ASME Code, Section XI, and 10 CFR 50.55a for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. |
| -weld's function. In lieu of the Appendix IX, Article IX-6000 required ongoing volumetric examination to monitor adjacent piping throughout the operating cycle the licensee proposed ongoing remote video camera observations and VT-2 examinations for leakage. 3.4 NRC Staff's Evaluation The staff evaluated the technical aspects of proposed Alternative VEGP-ISI-AL T -08, Version 1.0 against the criteria contained in 10 CFR 50.55a(3)(ii), the existence of a hardship or unusual difficulty without a compensating increase in quality or safety. The staff finds the first criterion, hardship or unusual difficulty, to be met if the licensee can demonstrate the requirement would necessitate things such as a need to enter multiple Technical Specification action statements, radiation ALARA concerns, hardware changes, or creating significant hazards to plant equipment or personnel, etc. The staff finds that the second criterion can be met if the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components. Without the proposed alternative, the licensee stated that in order to stop the leakage they would need to return the plant to Mode 5. The licensee stated the activities associated with the shutdown and startup processes would cause an additional estimated radiation dose of approximately 400-500 mREM. The licensee also cited the inherent risk associated with a shutdown transient and the extra cycles of thermal and pressure stresses for plant components. The unit startup and shutdown activities also present otherwise unnecessary challenges to personnel safety_ The staff finds the radiological dose and risk associated with these startup and shutdown evolutions, to be significantly larger than that expected to be associated with the installation of the mechanical clamping device to resolve the non-pressure boundary leakage concern associated with valve 1-1208-U4-A 11. Therefore the staff finds the licensee has identified sufficient hardship under 10 CFR 50.55a(a)(3)(ii). The licensee proposed to install a mechanical clamp at the degraded body to bonnet seal weld on valve 1-1208-U4-A11 to encapsulate the steam leak. The mechanical clamp is designed using Appendix IX of the ASIVIE Code, Section XI, as guidance with two exceptions, use of the device on a Class 1 valve under Article IX-1000(c)(1) and monitoring requirements under Article IX-6000(a). The staff reviewed the licensee's Minor Design Change 439341 and its associated worksheets, and found the licensee's design meets the requirements of Appendix IX in that all of the calculated stresses were below the code allowable stresses. The licensee had a piping analysis done to demonstrate that the piping system would continue to operate safely with the additional weight of a clamp on Valve 1-1208-U4-A 11. The licensee performed calculation X4CPS0351 which concluded the new loading conditions are still acceptable and there is adequate inherent reserve margin to accommodate the increased loads from the clamp. Therefore, the staff finds the licensee's design will provide reasonable assurance of structural integrity. To support the leakage integrity of the degraded seal weld, the licensee proposed to inject a sealant into the mechanical clamp enclosure to minimize the leakage. The licensee stated that the sealant is approved for use on a Class 1 system. The staff finds that the use of a sealant that has low concentration of halogens along with the temporary nature of the application will limit the potential for stress corrosion cracking of the stainless steel piping and valve, and is therefore acceptable in this time limited application.
| | Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-424 |
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| -The licensee proposed not to perform ultrasonic examination of the clamp area in accordance with Article IX-6000(a). In this specific case, the NRC staff finds this deviation acceptable based on the configuration of the valve and the clamp installation. Due to the temporary nature of this application and its conservative design, the staff finds the required ultrasonic examination is not necessary as any potential degradation mechanism should not affect the structural integrity of the system and clamping device. In addition, the licensee has committed to perform visual monitoring of the valve and the temporary clamp for leakage on a daily basis for seven days. If after the initial seven days no leakage is observed, a monitoring schedule of weekly remote observations along with monthly VT-2 visual examinations will be implemented to ensure the structural and leakage integrity of the temporary repair. On the basis of the above evaluation, the NRC staff finds that the proposed alternative provide reasonable assurance that the structural integrity and leakage integrity of the seal weld on valve 1-1208-U4-A 11 will be maintained until the next refueling Therefore, given the hardship presented by the licensee, the temporary nature of the proposed alternative, and the staffs review of the design of the mechanical clamping device, the NRC staff concludes that the licensee has provided sufficient technical basis to find that compliance with the limitation of Appendix IX Article XI-1000(c)(1) and required exams of Article IX-6000(a) would cause an unnecessary hardship without a compensating increase in the level of quality and safety 4.0 CONCLUSIONS As set forth above, the NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components and that complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR SO.SSa(a)(3)(ii), and is in compliance with requirements of the ASME Code, Section XI for which relief was not requested. Therefore, in accordance with 10 CFR SO.SSa(a)(3)(ii) the NRC authorizes use of the licensee's proposed alternative, VEGP-ISI-AL 08, Version 1.0, at Vogtle Electric Generating Plant, Unit 1, until the 1 R 18 refueling outage in the spring of 2014. All other ASME Code, Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. Principal Contributor: Keith M. Hoffman Date: February 7,2013 C. Pierce -2 All other requirements in ASME Code, Section XI, and 10 CFR 50.55a for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
| | ==Enclosure:== |
| | Safety Evaluation cc w/encl: Distribution via Listserv |
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| Sincerely,IRA! Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-424
| | UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUESTVEGP-ISI-ALT-08, VERSION 1.0, REGARDING INSTALLATION OF A MECHANICAL CLAMP ON A CLASS 1 VALVE - FOURTH 10-YEAR INTERVAL SOUTHERN NUCLEAR OPERATING COMPANY, INC. |
| | VOGTLE ELECTRIC GENERATING PLANT. UNIT 1 DOCKET NO. 50-424 |
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| ===Enclosure:=== | | ==1.0 INTRODUCTION== |
| Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION: PUBLIC LPL2-1 R/F RidsNrrDorlDpr Resource RidsNrrDorlLpl2-1 Resource RidsNrrDeEpnb (TLupold) RidsNrrLASFigueroa Resource RidsRgn2MailCenterResource RidsNrrPMVogtle Resource RidsNrrDirsStsb Resource RidsAcrsAcnw_MailCTR Resource, VMcree, RA R-II KHoffman, NRR ADAMS Accession No ML 13032A 106 | | |
| * E-mail transmitted SE dated OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/EPNB/BC* NRR/LPL2-1/BC NAME RMartin SFigueroa TLupold RPascarelli DATE 2/6/13 2/4/13 1/17113 2/7/13 OFFICIAL RECORD COpy}} | | By letter dated October 25,2012 (Agencywide Documents Access and Management System (ADAMS Accession No. ML12299A244), as supplemented by letter dated October 29,2012 (ADAMS Accession No. ML12305A421), Southern Nuclear Operating Company, Inc., the licensee, proposed an alternative (VEGP-ISI-ALT-08, Version 1.0) to Appendix IX of Section XI of the American Society of Mechanical Engineer's Boiler and Pressure Vessel (ASME) Code to allow installation of a mechanical clamp on a non-pressure boundary leak from a Class 1 Chemical and Volume Control valve 1-1208-U4-A 11. The licensee proposes this alternative during the current 2012 operating cycle at the Vogtle Electric Generating Plant, Unit 1 (VEGP-1 ). |
| | The licensee states that the mechanical clamp will only be in place until the 1R18 refueling outage in the spring of 2014 or until an outage of sufficient duration to allow VEGP-1 to perform either a permanent repair to the affected valve or replace the valve. The licensee also provided information on the hardship involved with performing a plant shutdown and cooldown to Mode 5, which the licensee assessed as an option. Therefore the licensee requested authorization of their proposed alternative under the requirements of Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50) 50.55a(a)(3)(ii). |
| | On November 1, 2012, pursuant to 10 CFR 50.55a(a)(3)(ii)), the NRC staff verbally authorized the use of the Alternative VEGP-ISI-ALT-08, Version 1.0 (ADAMS Accession No. ML12307A411). This safety evaluation documents the technical basis of the verbal authorization. |
| | |
| | ==2.0 REGULATORY EVALUATION== |
| | |
| | In this relief request the licensee requests authorization of an alternative to the requirements ASME Code, Section XI, Appendix IX pursuant to 10 CFR 50.55a(a)(3)(ii). |
| | |
| | - 2 Section 50.55a(g)(4) of 10 CFR, states that ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and preservice examination requirements, set forth in the ASME Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that lSI of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a{b) twelve months prior to the start of the 120-month interval, subject to the conditions listed therein. |
| | Section 50.55a(a){3) states, in part, that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. |
| | Based on the above analYSiS, the staff finds that regulatory authority to authorize an alternative to the ASME Code requirement, as requested by the licensee, exists. |
| | |
| | ==3.0 TECHNICAL EVALUATION== |
| | |
| | 3.1 Applicable Code Edition and Addenda The applicable ASME Code, Section XI of record for the third 10-year lSI interval at VEGP-1 is the 2001 Edition through 2003 Addenda. |
| | 3.2 Reason for Request On October 7,2012, while performing the VEGP-1 Class 1 leakage test during start-up from the 1R 17 refueling outage, a steam leak was observed on the Kerotest valve 1-1208-U4-A 11 on the 2-inch pressurizer auxiliary spray line. The steam leak emanated from a pinhole on the seal weld between the threaded connection joining the valve body and bonnet. Because the leakage was occurring at the seal weld, it was determined that the leakage was operational leakage and not reactor coolant pressure boundary leakage. SNC realized that actions would need to be taken to address the leakage. In order to stop steam from escaping through the pinhole in the seal weld a mechanical clamp with sealant was installed on October 13, 2012. Subsequently, steam leakage was re-identified on October 22, 2012. Discussions with the vendor determined that the most likely cause of the recurrence of the leakage was that the sealant had been injected at a temperature lower than that required to ensure proper curing of the material. |
| | Replacement of the clamp with a similar clamp and reinjection of the sealant is desired to prevent leakage until a permanent solution can be implemented. |
| | 3.3 Licensee's Proposed Alternative Section XI, Appendix IX provides rules for the installation of mechanical clamps on Class 2 and 3 pressure boundary leakage. The licensee proposed to use the rules of Appendix IX as guidance for installation of a mechanical clamp on the Class 1 non-pressure boundary leakage. |
| | The replacement clamp is the same design as the original clamp except with a relocated sealant injection port. The clamp and the sealant will encapSUlate the leak and will replace the seal |
| | |
| | - 3 weld's function. In lieu of the Appendix IX, Article IX-6000 required ongoing volumetric examination to monitor adjacent piping throughout the operating cycle the licensee proposed ongoing remote video camera observations and VT-2 examinations for leakage. |
| | 3.4 NRC Staff's Evaluation The staff evaluated the technical aspects of proposed Alternative VEGP-ISI-ALT -08, Version 1.0 against the criteria contained in 10 CFR 50.55a(3)(ii), the existence of a hardship or unusual difficulty without a compensating increase in quality or safety. The staff finds the first criterion, hardship or unusual difficulty, to be met if the licensee can demonstrate the requirement would necessitate things such as a need to enter multiple Technical Specification action statements, radiation ALARA concerns, hardware changes, or creating significant hazards to plant equipment or personnel, etc. The staff finds that the second criterion can be met if the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components. |
| | Without the proposed alternative, the licensee stated that in order to stop the leakage they would need to return the plant to Mode 5. The licensee stated the activities associated with the shutdown and startup processes would cause an additional estimated radiation dose of approximately 400-500 mREM. The licensee also cited the inherent risk associated with a shutdown transient and the extra cycles of thermal and pressure stresses for plant components. |
| | The unit startup and shutdown activities also present otherwise unnecessary challenges to personnel safety_ The staff finds the radiological dose and risk associated with these startup and shutdown evolutions, to be significantly larger than that expected to be associated with the installation of the mechanical clamping device to resolve the non-pressure boundary leakage concern associated with valve 1-1208-U4-A 11. Therefore the staff finds the licensee has identified sufficient hardship under 10 CFR 50.55a(a)(3)(ii). |
| | The licensee proposed to install a mechanical clamp at the degraded body to bonnet seal weld on valve 1-1208-U4-A11 to encapsulate the steam leak. The mechanical clamp is designed using Appendix IX of the ASIVIE Code, Section XI, as guidance with two exceptions, use of the device on a Class 1 valve under Article IX-1000(c)(1) and monitoring requirements under Article IX-6000(a). The staff reviewed the licensee's Minor Design Change 439341 and its associated worksheets, and found the licensee's design meets the requirements of Appendix IX in that all of the calculated stresses were below the code allowable stresses. The licensee had a piping analysis done to demonstrate that the piping system would continue to operate safely with the additional weight of a clamp on Valve 1-1208-U4-A11. The licensee performed calculation X4CPS0351 which concluded the new loading conditions are still acceptable and there is adequate inherent reserve margin to accommodate the increased loads from the clamp. |
| | Therefore, the staff finds the licensee's design will provide reasonable assurance of structural integrity. |
| | To support the leakage integrity of the degraded seal weld, the licensee proposed to inject a sealant into the mechanical clamp enclosure to minimize the leakage. The licensee stated that the sealant is approved for use on a Class 1 system. The staff finds that the use of a sealant that has low concentration of halogens along with the temporary nature of the application will limit the potential for stress corrosion cracking of the stainless steel piping and valve, and is therefore acceptable in this time limited application. |
| | |
| | - 4 The licensee proposed not to perform ultrasonic examination of the clamp area in accordance with Article IX-6000(a). In this specific case, the NRC staff finds this deviation acceptable based on the configuration of the valve and the clamp installation. Due to the temporary nature of this application and its conservative design, the staff finds the required ultrasonic examination is not necessary as any potential degradation mechanism should not affect the structural integrity of the system and clamping device. In addition, the licensee has committed to perform visual monitoring of the valve and the temporary clamp for leakage on a daily basis for seven days. If after the initial seven days no leakage is observed, a monitoring schedule of weekly remote observations along with monthly VT-2 visual examinations will be implemented to ensure the structural and leakage integrity of the temporary repair. |
| | On the basis of the above evaluation, the NRC staff finds that the proposed alternative will provide reasonable assurance that the structural integrity and leakage integrity of the degraded seal weld on valve 1-1208-U4-A 11 will be maintained until the next refueling outage. |
| | Therefore, given the hardship presented by the licensee, the temporary nature of the proposed alternative, and the staffs review of the design of the mechanical clamping device, the NRC staff concludes that the licensee has provided sufficient technical basis to find that compliance with the limitation of Appendix IX Article XI-1000(c)(1) and required exams of Article IX-6000(a) would cause an unnecessary hardship without a compensating increase in the level of quality and safety |
| | |
| | ==4.0 CONCLUSION== |
| | S As set forth above, the NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components and that complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR SO.SSa(a)(3)(ii), and is in compliance with requirements of the ASME Code, Section XI for which relief was not requested. Therefore, in accordance with 10 CFR SO.SSa(a)(3)(ii) the NRC authorizes use of the licensee's proposed alternative, VEGP-ISI-ALT 08, Version 1.0, at Vogtle Electric Generating Plant, Unit 1, until the 1R 18 refueling outage in the spring of 2014. |
| | All other ASME Code, Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. |
| | Principal Contributor: Keith M. Hoffman Date: February 7,2013 |
| | |
| | C. Pierce -2 All other requirements in ASME Code, Section XI, and 10 CFR 50.55a for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. |
| | Sincerely, IRA! |
| | Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-424 |
| | |
| | ==Enclosure:== |
| | Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION: |
| | PUBLIC LPL2-1 R/F RidsNrrDorlDpr Resource RidsNrrDorlLpl2-1 Resource RidsNrrDeEpnb (TLupold) RidsNrrLASFigueroa Resource RidsRgn2MailCenterResource RidsNrrPMVogtle Resource RidsNrrDirsStsb Resource RidsAcrsAcnw_MailCTR Resource, VMcree, RA R-II KHoffman, NRR ADAMS Accession No ML13032A106 |
| | * E-mail transmitted SE dated OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/EPNB/BC* NRR/LPL2-1/BC NAME RMartin SFigueroa TLupold RPascarelli DATE 2/6/13 2/4/13 1/17113 2/7/13 OFFICIAL RECORD COpy}} |
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Acceptance Review - Vogtle Units 1 and 2 - Proposed LAR and Relief Request to Revise TS 3.4.14.1 and IST ALT-VR-02 (EPIDs L-2023-LLA-0061 and L-2023-LLR-0023)
ML23095A2962023-04-14014 April 2023
Alternative Inspection Requirements for Steam Generator Nozzle to Reactor Coolant Pump Casing Welds (Vegp 3&4-Isi1- Alt-17)
ML22259A1822022-09-22022 September 2022
Request for Proposed Inservice Testing Alternative ALT-VR-01
ML22118A0762022-05-13013 May 2022
Cover Letter for Vogtle Electric Generating Plant, Units 3 and 4 Request for Alternative Requirements for Inservice Test Interval Code Edition (VEGP 3&4-IST-ALT-01R2)
ML22021A0012022-01-24024 January 2022
Relief Request for Proposed Alternative Requirements for the Repair of Reactor Vessel Head Penetrations for the Fourth 10-Year Inservice Inspection Interval, VEGP-ISI-ALT-04-05, Version 1.0
ND-21-0392, Enclosure 3 - Vogtle Electric Generating Plant (VEGP) Unit 3 CB&I Procedure Qualification Record 14163 (VEGP 3-ALT-16)2021-06-0303 June 2021
Enclosure 3 - Vogtle Electric Generating Plant (VEGP) Unit 3 CB&I Procedure Qualification Record 14163 (VEGP 3-ALT-16)
ML21154A2132021-06-0303 June 2021
Enclosure 2 - Vogtle Electric Generating Plant (VEGP) Unit 3 CB&I Procedure Qualification Record 14162(VEGP 3-ALT-16)
ML21154A2122021-06-0303 June 2021
Enclosure 1 - Vogtle Electric Generating Plant (VEGP) Unit 3 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1): Alternative Requirements for ASME Section III Remediation of Containment Vessel Unistrut Welding (VEGP 3-ALT-16)
ML21040A1652021-02-0909 February 2021
(Vegp), Units 3 and 4, Revision to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2): Alternative Requirements for ASME Section XI Examination Coverage of Weldolet Branch Connection Welds
ML20352A1552021-01-11011 January 2021
Proposed Relief Request for Alternative VEGP-ISI-ALT-04-04 to the Requirements of the ASME Code
ML20307A1412020-11-12012 November 2020
Relief Request for Deferral of ASME Boiler and Pressure Vessel Code, Section XI, Required Summary Report Submittal
NL-20-1262, Submission of Proposed Alternative to Submitting Vogtle Unit 2 Inservice Inspection Summary Report within 90 Days of Outage Completion2020-10-30030 October 2020
Submission of Proposed Alternative to Submitting Vogtle Unit 2 Inservice Inspection Summary Report within 90 Days of Outage Completion
ML20216A3992020-08-0606 August 2020
Relief Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI
ML20143A2332020-06-0303 June 2020
Relief Request for Deferral of ASME Boiler and Pressure Vessel Code, Section XI, Required Summary Report Submittal (EPID L-2020-LLR-0074 (COVID-19))
ML20132A1532020-05-14014 May 2020
ASME Code Alternative - May 14, 2020 Presubmittal Technical Exchange for Preservice Inspection (PSI) Alternative
ML20034E8942020-02-11011 February 2020
Relief Request Gen-ISI-ALT-2019-01 for Proposed Alternative to Use of ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1
ND-20-0083, Revision to Request for Alternative: Alternative Requirements for Inservice Test Interval Code Edition, Unit 4 (VEGP 3&4-IST-ALT-01R1)2020-02-0606 February 2020
Revision to Request for Alternative: Alternative Requirements for Inservice Test Interval Code Edition, Unit 4 (VEGP 3&4-IST-ALT-01R1)
ND-19-1294, Request for Alternative: Alternative Requirements for Inservice Test Interval Code Edition, Unit 4 (VEGP 3&4-IST-ALT-01)2019-10-31031 October 2019
Request for Alternative: Alternative Requirements for Inservice Test Interval Code Edition, Unit 4 (VEGP 3&4-IST-ALT-01)
ML18320A0192018-11-30030 November 2018
Relief Request Regarding Examination Coverage for Certain ASME Code Class 2 Category Welds (VEGP-ISI-RR-05)
ML18296A7172018-10-31031 October 2018
Relief Request Regarding Examination Coverage for Certain Pressurizer and Steam Generator Welds (VEGP-ISI-RR-03)
ND-18-1158, Revision to Request for Alternative: Alternative Requirements for Preservice Examination Volumetric Surface Configuration Requirements (VEGP 3&4-PSI/ISI-ALT-10R1)2018-08-30030 August 2018
Revision to Request for Alternative: Alternative Requirements for Preservice Examination Volumetric Surface Configuration Requirements (VEGP 3&4-PSI/ISI-ALT-10R1)
NL-18-0428, Withdrawal of Proposed Alternative GEN-ISI-ALT-2017-001 Implementation of Code Case N-786-12018-04-0909 April 2018
Withdrawal of Proposed Alternative GEN-ISI-ALT-2017-001 Implementation of Code Case N-786-1
ML18054A0652018-03-0505 March 2018
Cover Letter - Vogtle Electric Generating Plant - Request for Alternative (ALT-9)
ML17171A1022017-06-27027 June 2017
Inservice Inspection Alternative Regarding Category B-N-2 and B-N-3 Welds (VEGP ISI ALT 13)
ML17061A2022017-03-17017 March 2017
Request for Alternative RR-PR-03 Regarding Nuclear Service Cooling Water Pump Instrument Accuracy
ML17037D0502017-02-17017 February 2017
and 2; Request to Use Asme Code Case OMN-18 as an Alternative to Inservice Testing Requirements (CAC Nos. MF8188 and MF8189)
NL-17-0101, Proposed Alternative VEGP-ISI-AL T-13 in Accordance with 10 CFR 50.55a(z)(2) to Extend B-N-2 and B-N-3 Inservice Inspection Examinations Schedule2017-01-26026 January 2017
Proposed Alternative VEGP-ISI-AL T-13 in Accordance with 10 CFR 50.55a(z)(2) to Extend B-N-2 and B-N-3 Inservice Inspection Examinations Schedule
ML17006A1092017-01-26026 January 2017
Alternative to Inservice Inspection Regarding Reactor Pressure Vessel Threads Inflange Inspection
ML16326A0442016-12-0808 December 2016
Alternative for Pump and Valve Inservice Testing Program
ML16264A3212016-10-14014 October 2016
Alternatives for Pumps and Valves Inservice Testing Program
ML14030A5702014-03-20020 March 2014
Request for Alternatives VEGP-ISI-ALT-06
ML13123A1602013-05-0707 May 2013
(VEGP) - Safety Evaluation of Relief Request VEGP-ISI-ALT-09, Version 2.0, Regarding Leakage Tests for Reactor Coolant Pressure Boundary Components
ML13032A1062013-02-0707 February 2013
Safety Evaluation of Relief Request VEGP-ISI-ALT-08, Version 1, Regarding Installation of a Mechanical Clamp on a Class 1 Valve - Fourth 10-Year Interval
ML1009001292010-06-11011 June 2010
Relief Requests VEGP-ISI-ALT-04 (Units 1 and 2) and VEGP-ISI-RR-01 (Unit 2) Inservice Inspection Alternatives for Third and Subsequent Inservice Inspection Intervals (TAC Nos. ME2226, ME2227, and ME1134)
ML1012000882010-04-30030 April 2010
Acceptance of Vogtle Relief Request (VEGP-ISI-ALT-03) Dated April 7, 2010
NL-09-1410, VEGP-ISI-RR-01, Version 1.0, Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)2009-09-0909 September 2009
VEGP-ISI-RR-01, Version 1.0, Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)
ML0731004352007-11-15015 November 2007
Third 10-Year Interval, Inservice Program Relief Request RR-V-1 (Tac Nos. MD5409 and MD5410)
ML0627703592006-09-29029 September 2006
Evaluation of Relief Request ISI-GEN-ALT-06-02
NL-06-1713, Proposed Alternative for Application of Pressurizer Nozzle Full-Structural Weld Overlays2006-08-10010 August 2006
Proposed Alternative for Application of Pressurizer Nozzle Full-Structural Weld Overlays
ML0510301992005-04-25025 April 2005
RR, ISI Program Intervals for Alternative Alignment of Iwe/Iwl Inspection Program (Tac No. MC4870, MC4871, MC4872, MC4873, MC4874, MC4875)
ML0332800372003-11-21021 November 2003
Safety Evaluation Re. Request to Use ASME Code Case N-661
ML0225904572002-09-16016 September 2002
Code Relief, Relief Request for the Second Ten-Year Interval Inservice Testing Program
2024-07-19
[Table view]
Category:Letter
MONTHYEARNL-24-0385, Request for Action Matrix Deviation Due to Recent Events Impacting the Unplanned Scram with Complications Performance Indicator2024-10-31031 October 2024
Request for Action Matrix Deviation Due to Recent Events Impacting the Unplanned Scram with Complications Performance Indicator
IR 05000424/20240032024-10-30030 October 2024
– Integrated Inspection Report 05000424/2024003 and 05000425/2024003
NL-24-0392, Response to Requests for Additional Information Related to Proposed Alternative GEN-ISI-AL T-2024-0022024-10-28028 October 2024
Response to Requests for Additional Information Related to Proposed Alternative GEN-ISI-AL T-2024-002
NL-24-0386, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks Response to Request for Additional Information2024-10-28028 October 2024
License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks Response to Request for Additional Information
NL-24-0366, Core Operating Limits Report, Cycle 26, Version 12024-10-25025 October 2024
Core Operating Limits Report, Cycle 26, Version 1
ML24297A6482024-10-23023 October 2024
5 to the Updated Final Safety Analysis Report, Technical Specification Bases Changes, Technical Requirements Manual Changes, Summary Report and Revised NRC Commitments Report
ML24269A2502024-09-26026 September 2024
Acknowledgement of the Withdrawal of the Requested Exemption and License Amendment Request to Remove Tier 1 and Tier 2* Requirements
NL-24-0369, Withdrawal of License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2 Requirements2024-09-25025 September 2024
Withdrawal of License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2 Requirements
NL-24-0350, Core Operating Limits Report, Cycle 24, Version 22024-09-25025 September 2024
Core Operating Limits Report, Cycle 24, Version 2
ML24243A0072024-09-10010 September 2024
– Correction of Amendment Nos. 223 and 206 Regarding Revision to Technical Specifications to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483
ML24102A2642024-09-0909 September 2024
– Exemption Request Regarding Final Safety Analysis Report Update Schedule (EPID L-2024-LLE-0013) - Letter
NL-24-0337, Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program2024-09-0909 September 2024
Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program
ML24249A2942024-09-0606 September 2024
Correction of Amendment Nos. 218 and 201 Regarding Revision to Technical Specifications to Use Online Monitoring Methodology
05200025/LER-2024-002, Manual Reactor Protection System and Automatic Safeguards Actuation Due to an Unexpected Change in Position of a Main Feedwater Pump Minimum Flow Control Valve2024-09-0505 September 2024
Manual Reactor Protection System and Automatic Safeguards Actuation Due to an Unexpected Change in Position of a Main Feedwater Pump Minimum Flow Control Valve
IR 05000424/20240052024-08-26026 August 2024
Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 and 2 - Report 05000424/2024005 and 05000425/2024005
ML24235A1952024-08-22022 August 2024
Updated Inspection Plan for Vogtle Electric Generating Plant, Units 3 and 4 - Report 05200025/2024005 and 05200026/2024005
IR 05000424/20244012024-08-15015 August 2024
4 - Security Baseline Inspection Report 05000424-2024401, 05000425-2024401, 05200025-2024402, and 05200026-2024403 - Cover Letter
NL-24-0299, Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information2024-08-14014 August 2024
Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information
05000425/LER-2024-001, Manual Actuation of the Reactor Protection System Due to a Rod Control Fuse Opening Causing a Misaligned Shutdown Rod2024-08-0909 August 2024
Manual Actuation of the Reactor Protection System Due to a Rod Control Fuse Opening Causing a Misaligned Shutdown Rod
ML24218A1842024-08-0707 August 2024
Examination Report and Cover Letter
05200026/LER-2024-001, Manual Reactor Protection System Actuation Due to Procedure Not Optimally Sequenced to Reset the Rapid Power Reduction Signal2024-08-0606 August 2024
Manual Reactor Protection System Actuation Due to Procedure Not Optimally Sequenced to Reset the Rapid Power Reduction Signal
ML24212A1442024-08-0101 August 2024
Integrated Inspection Report 05200025/2024002 and 05200026/2024002
IR 05000424/20240022024-07-29029 July 2024
Integrated Inspection Report 05000424/2024002 and 05000425/2024002
IR 05000424/20244042024-07-26026 July 2024
Material Control and Accounting Program Inspection Report 05000424/2024404 and 05000425/2024404 (Cover Letter)
NL-24-0282, License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements2024-07-25025 July 2024
License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements
NL-24-0126, – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.62024-07-25025 July 2024
– Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.6
ML24204A0722024-07-23023 July 2024
Issuance of Amendment No. 225, Regarding LAR to Revise TS 3.7.9 for a one-time Change to Support Nuclear Service Cooling Water Transfer Pump Repairs - Emergency Circumstances
NL-24-0286, Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair2024-07-20020 July 2024
Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair
NL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024
10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023
ML24191A4562024-07-19019 July 2024
Request for Relief and Alternative Requirements for Squib (Explosively Actuated) Valves First Test Interval
ML24194A0342024-07-12012 July 2024
Review of the Refueling Outage 1R24 Steam Generator Tube Inspection Report
ML24191A3792024-07-10010 July 2024
– Initial Test Program and Operational Programs Inspection Report 05200026/2024011
NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024
Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)
NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024
Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown
NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024
Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in
NL-24-0087, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks2024-06-21021 June 2024
License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks
NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024
Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)
NL-24-0243, Registration of Spent Fuel Cask Use2024-06-18018 June 2024
Registration of Spent Fuel Cask Use
ML24163A0632024-06-12012 June 2024
2024 Licensed Operator Re-qualification Inspection Notification Letter Vogtle, Units 3 & 4
ML24155A1772024-06-0505 June 2024
Regulatory Audit in Support of Review of the LAR to Revise Emergency Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, Surveillance Requirements
NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024
SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations
ML24141A0482024-05-17017 May 2024
EN 56958_1 Ametek Solidstate Controls, Inc
ML24094A1402024-05-16016 May 2024
Staff Response to Request for Revision to NRC Staff Assessment of Updated Seismic Hazard Information and Latest Understanding of Seismic Hazards at the Vogtle Plant Site Following the NRC Process for the Ongoing Assessment of Natural Hazard
ML24130A2412024-05-13013 May 2024
Integrated Inspection Report 05200025/2024001 and 05200026/2024001
ML24120A1812024-05-13013 May 2024
Request for Withholding Information from Public Disclosure Responses to NRC Request for Additional Information for Refueling Outage IR24 Steam Generator Tube Inspection Report – Enclosure 2
ML24101A2112024-05-11011 May 2024
Expedited Issuance of Amendment No. 198 Change to Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP)
NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024
Annual Radiological Environmental Operating Reports for 2023
ML24127A2372024-05-0909 May 2024
Initial Test Program and Operational Programs Inspection Report 05200026/2024010
NL-24-0194, Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1)2024-05-0707 May 2024
Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1)
ML24120A2832024-04-30030 April 2024
Project Manager Reassignment
2024-09-09
[Table view]
Category:Safety Evaluation
MONTHYEARML24243A0932024-08-30030 August 2024
Non-concurrence Text No Annotations
ML24204A0722024-07-23023 July 2024
Issuance of Amendment No. 225, Regarding LAR to Revise TS 3.7.9 for a one-time Change to Support Nuclear Service Cooling Water Transfer Pump Repairs - Emergency Circumstances
ML24191A4562024-07-19019 July 2024
Request for Relief and Alternative Requirements for Squib (Explosively Actuated) Valves First Test Interval
ML24101A2112024-05-11011 May 2024
Expedited Issuance of Amendment No. 198 Change to Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP)
ML24030A9092024-04-10010 April 2024
Issuance of Amendment Nos. 224 and 207, Regarding Revision to Technical Specification 3.4.14 (Reactor Coolant System) Pressure Isolation Valve Leakage Surveillance Requirement 3.4.14.1
ML23317A2072023-12-22022 December 2023
Issuance of Amendments 223 and 206 Regarding Revision to Technical Specifications to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-1448
ML23243B0492023-12-19019 December 2023
VEGP Units 3 and 4, Safety Evaluation, LAR-22-002, TS 3.8.3 Inverters Operating, Completion Time Extension - Enclosure 3
ML23335A1232023-12-19019 December 2023
Safety Evaluation Final Integrated Plan
ML23310A2922023-12-0707 December 2023
Issuance of Amendment for Exception to Regulatory Guide 1.163, LAR 23 007
ML23326A1362023-11-28028 November 2023
Safety Evaluation for Amendment 195 & 192 for TS 3.1.9 More Restrictive Action
ML23268A0572023-11-0707 November 2023
Issuance of Amendments 194 & 191 Request for License Amendment Relocation of Technical Specification 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)
ML23263A9852023-10-12012 October 2023
Issuance of Amendments Nos. 221 and 204, Regarding Technical Specification 5.5.11.C, Acceptance Criteria for Charcoal Filter Testing
ML23202A1122023-08-0202 August 2023
Units, 1 and 2; and Vogtle Units 1 and 2 - Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI
ML23093A0282023-08-0101 August 2023
Issuance of Amendments Nos. 220 and 203, Regarding Use of Accident Tolerant Fuel Lead Test Assemblies
ML23159A1022023-07-31031 July 2023
Safety Evaluation - Vogtle Electric Generating Plant, Unit 3 Amendment No. 192 (LAR 23-001)
ML23158A0182023-07-31031 July 2023
Issuance of Amendments Nos. 219 and 202, Regarding Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490
ML23158A2062023-07-19019 July 2023
LAR-23-005 U/4 Amd 189 Timing of TS Effectiveness Prior to Initial Criticality Safety Evaluation
ML23115A1492023-06-15015 June 2023
Issuance of Amendments No. 218 and 201 Regarding Revision to Technical Specifications to Use Online Monitoring Methodology
ML23109A0702023-05-0404 May 2023
Enclosure - Safety Evaluation for VEGP3&4 ISI1-ALT-18
ML23072A2742023-05-0101 May 2023
Enclosure 3 - LAR 22-005 Safety Evaluation
ML23095A2962023-04-14014 April 2023
Alternative Inspection Requirements for Steam Generator Nozzle to Reactor Coolant Pump Casing Welds (Vegp 3&4-Isi1- Alt-17)
ML23095A2972023-04-14014 April 2023
Enclosure - VEGP 3&4-ISI1-ALT-17 Safety Evaluation
ML23037A0912023-02-0808 February 2023
Safety Evaluation - Vogtle Unit 3 Amendment No. 190, Tech Spec Exceptions for In-Containment Refueling Water Storage Tank Operability Prior to Initial Criticality (Exigent Circumstances)
ML23013A2202023-01-13013 January 2023
Safety Evaluation for License Amendment No. 189 Tech Spec Limiting Conditions for Operability Reqs for Auto Depressurization System Stage 4 Flow Paths Prior to Initial Criticality
ML22284A1332022-11-22022 November 2022
LAR-22-003 U4 Electrical ITAAC Consolidation Amendment Safety Evaluation
ML22286A1252022-11-16016 November 2022
Issuance of Amendments Nos. 217 & 200 Regarding Revision to Technical Specifications to Adopt TSTF-283-A, Revision 3, Modify Section 3.8 Mode Restriction Notes
ML22259A1822022-09-22022 September 2022
Request for Proposed Inservice Testing Alternative ALT-VR-01
ML22249A0922022-09-14014 September 2022
Enclosure - Safety Evaluation the Requirements of the ASME Code for Main Turbine System Valve Testing, VEGP 3&4-IST-ALT-02
ML22116A0842022-07-0505 July 2022
Issuance of Amendment Nos. 215 and 198, Regarding Revision to Technical Specification 3.7.2, Main Steam Isolation Valves (Msivs)
ML22118A0772022-05-13013 May 2022
Safety Evaluation Regarding Request for Alternative Requirements for Inservice Test Interval Code Edition (VEGP 3&4-IST-ALT-01R2)
ML22069A0042022-04-27027 April 2022
Issuance of Amendments Revision to TSs to Adopt TSTF-269-A, Rev. 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves
ML21349A5182022-02-0202 February 2022
Issuance of Amendments Regarding Revision to Technical Specifications to Adopt TSTF-554, Revise RCS Leakage
ML21344A0032022-01-26026 January 2022
Issuance of Amendments Regarding Revision to Use Beacon Power Distribution Monitoring System
ML21316A0552022-01-0505 January 2022
1 & 2, and Vogtle Electric Generating Plant, 1 & 2 - Issuance of Amendments Regarding Revision to Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections (EPID L-2021-LLA-0163
ML21314A1502021-12-0707 December 2021
Issuance of Amendment Nos. 210 and 193, Regarding Revision to Technical Specification 3.3.5, 4.16 (Kilovolt) Kv (Engineered Safety Feature) Esf Bus Loss of Power (LOP) Instrumentation (EPID L 2021-LLA-0054
ML21270A0862021-11-18018 November 2021
Issuance of Amendments Regarding Revision to Technical Specifications 5.7, High Radiation, Administrative Controls
ML21237A2402021-10-15015 October 2021
Safety Evaluation for Amendment No. LAR-21-001: Clarification of ITAAC Regarding Invessel Components
ML21217A0912021-09-21021 September 2021
SNC Fleet, Issuance of Amendments Regarding Revision to Emergency Plan to Change Staffing and Extend Staff Augmentation Times for Emergency Response Organization Positions
ML21217A0282021-09-17017 September 2021
Safety Evaluation for Vogtle Electric Generating Plant Units 3 and 4 Regarding Request to Revise the Emergency Plan to Change Staffing and Extend Staff Augmentation Times for Emergency Response Organization Positions
ML21068A0822021-07-30030 July 2021
Issuance of Amendment Nos. 206 and 189, Regarding a License Amendment Request for a Risk-Informed Resolution to GSI-191
ML20268A0702021-07-30030 July 2021
Safety Evaluation - Vogtle GSI-191 LAR
ML21167A3152021-07-30030 July 2021
Issuance of Amendments Regarding Revision to Technical Specifications to Adopt TSTF-541, Rev.2, Add Exceptions to Surveillance Requirements for Valves & Dampers Locked in Actuated Position
ML21161A2012021-06-22022 June 2021
Associated Independent Spent Fuel Storage Facilities - Reduction in Commitment to the Quality
ML21090A2472021-04-0909 April 2021
Safety Evaluation by the Office of Nuclear Reactor Regulation Regarding Proposed ASME Code Alternative Requirements for ASME Section XI Examination Coverage of Weldolet Branch Connections
ML20352A1552021-01-11011 January 2021
Proposed Relief Request for Alternative VEGP-ISI-ALT-04-04 to the Requirements of the ASME Code
ML20314A0162020-12-0707 December 2020
Safety Evaluation Vacuum Relief Valve Technical Specification Changes (LAR 20-005)
ML20307A1412020-11-12012 November 2020
Relief Request for Deferral of ASME Boiler and Pressure Vessel Code, Section XI, Required Summary Report Submittal
ML20269A4002020-10-27027 October 2020
Interim Staff Evaluation for Vogtle Electric Generating Plant, Units 3 and 4 Regarding Implementation of Mitigating Strategies Related to Order EA-12-049
ML20247J4642020-10-14014 October 2020
Safety Evaluation Report for Vogtle Electric Generating Plant for Amendments 185/183 (LAR 20-004)
ML20237F4952020-09-24024 September 2020
Safety Evaluation for Vogtle Electric Generating Plant Units 3 and 4 Amendment Nos. 184/182 (LAR 20-003)
2024-08-30
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 7, 2013 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc.
Post Office Box 1295 / Bin 038 Birmingham, AL 35201-1295
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 - SAFETY EVALUATION OF RELIEF REQUESTVEGP-ISI-ALT-08, VERSION 1.0, REGARDING INSTALLATION OF A MECHANICAL CLAMP ON A CLASS 1 VALVE FOURTH 10-YEAR INTERVAL (TAC NO. ME9850)
Dear Mr. Pierce:
By letter to the U.S. Nuclear Regulatory Commission (NRC), dated October 25,2012, as supplemented by letter dated October 29, 2012, Southern Nuclear Operating Company, Inc.
(SNC, the licensee) proposed an alternative (VEGP-ISI-AL T-08, Version 1.0) to Appendix IX of Section XI of the American Society of Mechanical Engineer's Boiler and Pressure Vessel (ASME) Code to allow installation of a mechanical clamp on a non-pressure boundary leak from a Class 1 Chemical and Volume Control valve 1-1208-U4-A 11 for the Vogtle Electric Generating Plant, Unit 1(VEGP-1).
On November 1, 2012, pursuant to Title 10 Code of Federal Regulations, Part 50, Section 50.55a(a)(3)(ii)), the NRC staff verbally authorized the use of the Alternative VEGP-ISI-AL T-08, Version 1.0. This safety evaluation documents the technical basis of the verbal authorization.
The NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components and that complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with requirements of the ASME Code,Section XI for which relief was not requested. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii) the NRC authorizes use of the licensee's proposed alternative, VEGP-ISI-ALT-08, Version 1.0, at VEGP-1 until the 1R 18 refueling outage in the spring of 2014.
C. Pierce - 2 All other requirements in ASME Code,Section XI, and 10 CFR 50.55a for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-424
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUESTVEGP-ISI-ALT-08, VERSION 1.0, REGARDING INSTALLATION OF A MECHANICAL CLAMP ON A CLASS 1 VALVE - FOURTH 10-YEAR INTERVAL SOUTHERN NUCLEAR OPERATING COMPANY, INC.
VOGTLE ELECTRIC GENERATING PLANT. UNIT 1 DOCKET NO. 50-424
1.0 INTRODUCTION
By letter dated October 25,2012 (Agencywide Documents Access and Management System (ADAMS Accession No. ML12299A244), as supplemented by letter dated October 29,2012 (ADAMS Accession No. ML12305A421), Southern Nuclear Operating Company, Inc., the licensee, proposed an alternative (VEGP-ISI-ALT-08, Version 1.0) to Appendix IX of Section XI of the American Society of Mechanical Engineer's Boiler and Pressure Vessel (ASME) Code to allow installation of a mechanical clamp on a non-pressure boundary leak from a Class 1 Chemical and Volume Control valve 1-1208-U4-A 11. The licensee proposes this alternative during the current 2012 operating cycle at the Vogtle Electric Generating Plant, Unit 1 (VEGP-1 ).
The licensee states that the mechanical clamp will only be in place until the 1R18 refueling outage in the spring of 2014 or until an outage of sufficient duration to allow VEGP-1 to perform either a permanent repair to the affected valve or replace the valve. The licensee also provided information on the hardship involved with performing a plant shutdown and cooldown to Mode 5, which the licensee assessed as an option. Therefore the licensee requested authorization of their proposed alternative under the requirements of Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50) 50.55a(a)(3)(ii).
On November 1, 2012, pursuant to 10 CFR 50.55a(a)(3)(ii)), the NRC staff verbally authorized the use of the Alternative VEGP-ISI-ALT-08, Version 1.0 (ADAMS Accession No. ML12307A411). This safety evaluation documents the technical basis of the verbal authorization.
2.0 REGULATORY EVALUATION
In this relief request the licensee requests authorization of an alternative to the requirements ASME Code,Section XI, Appendix IX pursuant to 10 CFR 50.55a(a)(3)(ii).
- 2 Section 50.55a(g)(4) of 10 CFR, states that ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that lSI of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a{b) twelve months prior to the start of the 120-month interval, subject to the conditions listed therein.
Section 50.55a(a){3) states, in part, that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Based on the above analYSiS, the staff finds that regulatory authority to authorize an alternative to the ASME Code requirement, as requested by the licensee, exists.
3.0 TECHNICAL EVALUATION
3.1 Applicable Code Edition and Addenda The applicable ASME Code,Section XI of record for the third 10-year lSI interval at VEGP-1 is the 2001 Edition through 2003 Addenda.
3.2 Reason for Request On October 7,2012, while performing the VEGP-1 Class 1 leakage test during start-up from the 1R 17 refueling outage, a steam leak was observed on the Kerotest valve 1-1208-U4-A 11 on the 2-inch pressurizer auxiliary spray line. The steam leak emanated from a pinhole on the seal weld between the threaded connection joining the valve body and bonnet. Because the leakage was occurring at the seal weld, it was determined that the leakage was operational leakage and not reactor coolant pressure boundary leakage. SNC realized that actions would need to be taken to address the leakage. In order to stop steam from escaping through the pinhole in the seal weld a mechanical clamp with sealant was installed on October 13, 2012. Subsequently, steam leakage was re-identified on October 22, 2012. Discussions with the vendor determined that the most likely cause of the recurrence of the leakage was that the sealant had been injected at a temperature lower than that required to ensure proper curing of the material.
Replacement of the clamp with a similar clamp and reinjection of the sealant is desired to prevent leakage until a permanent solution can be implemented.
3.3 Licensee's Proposed Alternative Section XI, Appendix IX provides rules for the installation of mechanical clamps on Class 2 and 3 pressure boundary leakage. The licensee proposed to use the rules of Appendix IX as guidance for installation of a mechanical clamp on the Class 1 non-pressure boundary leakage.
The replacement clamp is the same design as the original clamp except with a relocated sealant injection port. The clamp and the sealant will encapSUlate the leak and will replace the seal
- 3 weld's function. In lieu of the Appendix IX, Article IX-6000 required ongoing volumetric examination to monitor adjacent piping throughout the operating cycle the licensee proposed ongoing remote video camera observations and VT-2 examinations for leakage.
3.4 NRC Staff's Evaluation The staff evaluated the technical aspects of proposed Alternative VEGP-ISI-ALT -08, Version 1.0 against the criteria contained in 10 CFR 50.55a(3)(ii), the existence of a hardship or unusual difficulty without a compensating increase in quality or safety. The staff finds the first criterion, hardship or unusual difficulty, to be met if the licensee can demonstrate the requirement would necessitate things such as a need to enter multiple Technical Specification action statements, radiation ALARA concerns, hardware changes, or creating significant hazards to plant equipment or personnel, etc. The staff finds that the second criterion can be met if the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components.
Without the proposed alternative, the licensee stated that in order to stop the leakage they would need to return the plant to Mode 5. The licensee stated the activities associated with the shutdown and startup processes would cause an additional estimated radiation dose of approximately 400-500 mREM. The licensee also cited the inherent risk associated with a shutdown transient and the extra cycles of thermal and pressure stresses for plant components.
The unit startup and shutdown activities also present otherwise unnecessary challenges to personnel safety_ The staff finds the radiological dose and risk associated with these startup and shutdown evolutions, to be significantly larger than that expected to be associated with the installation of the mechanical clamping device to resolve the non-pressure boundary leakage concern associated with valve 1-1208-U4-A 11. Therefore the staff finds the licensee has identified sufficient hardship under 10 CFR 50.55a(a)(3)(ii).
The licensee proposed to install a mechanical clamp at the degraded body to bonnet seal weld on valve 1-1208-U4-A11 to encapsulate the steam leak. The mechanical clamp is designed using Appendix IX of the ASIVIE Code,Section XI, as guidance with two exceptions, use of the device on a Class 1 valve under Article IX-1000(c)(1) and monitoring requirements under Article IX-6000(a). The staff reviewed the licensee's Minor Design Change 439341 and its associated worksheets, and found the licensee's design meets the requirements of Appendix IX in that all of the calculated stresses were below the code allowable stresses. The licensee had a piping analysis done to demonstrate that the piping system would continue to operate safely with the additional weight of a clamp on Valve 1-1208-U4-A11. The licensee performed calculation X4CPS0351 which concluded the new loading conditions are still acceptable and there is adequate inherent reserve margin to accommodate the increased loads from the clamp.
Therefore, the staff finds the licensee's design will provide reasonable assurance of structural integrity.
To support the leakage integrity of the degraded seal weld, the licensee proposed to inject a sealant into the mechanical clamp enclosure to minimize the leakage. The licensee stated that the sealant is approved for use on a Class 1 system. The staff finds that the use of a sealant that has low concentration of halogens along with the temporary nature of the application will limit the potential for stress corrosion cracking of the stainless steel piping and valve, and is therefore acceptable in this time limited application.
- 4 The licensee proposed not to perform ultrasonic examination of the clamp area in accordance with Article IX-6000(a). In this specific case, the NRC staff finds this deviation acceptable based on the configuration of the valve and the clamp installation. Due to the temporary nature of this application and its conservative design, the staff finds the required ultrasonic examination is not necessary as any potential degradation mechanism should not affect the structural integrity of the system and clamping device. In addition, the licensee has committed to perform visual monitoring of the valve and the temporary clamp for leakage on a daily basis for seven days. If after the initial seven days no leakage is observed, a monitoring schedule of weekly remote observations along with monthly VT-2 visual examinations will be implemented to ensure the structural and leakage integrity of the temporary repair.
On the basis of the above evaluation, the NRC staff finds that the proposed alternative will provide reasonable assurance that the structural integrity and leakage integrity of the degraded seal weld on valve 1-1208-U4-A 11 will be maintained until the next refueling outage.
Therefore, given the hardship presented by the licensee, the temporary nature of the proposed alternative, and the staffs review of the design of the mechanical clamping device, the NRC staff concludes that the licensee has provided sufficient technical basis to find that compliance with the limitation of Appendix IX Article XI-1000(c)(1) and required exams of Article IX-6000(a) would cause an unnecessary hardship without a compensating increase in the level of quality and safety
4.0 CONCLUSION
S As set forth above, the NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject components and that complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR SO.SSa(a)(3)(ii), and is in compliance with requirements of the ASME Code,Section XI for which relief was not requested. Therefore, in accordance with 10 CFR SO.SSa(a)(3)(ii) the NRC authorizes use of the licensee's proposed alternative, VEGP-ISI-ALT 08, Version 1.0, at Vogtle Electric Generating Plant, Unit 1, until the 1R 18 refueling outage in the spring of 2014.
All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Keith M. Hoffman Date: February 7,2013
C. Pierce -2 All other requirements in ASME Code,Section XI, and 10 CFR 50.55a for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Sincerely, IRA!
Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-424
Enclosure:
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