ML20199L059

Request Prompt Review & Approval of Encl ISI Program Request for Relief RR-22,for Use During VEGP-2 Maint/Refueling Outage 2R6 Scheduled to Begin 980308

ML20199L059
Person / Time
Site:	Vogtle
Issue date:	01/29/1998
From:	Mccoy C SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LCV-1016-F, NUDOCS 9802090097
Download: ML20199L059 (8)

Text

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• C. K. McCoy Southern Nuclear Vice President Operating Company. Inc.

. Vogtle Project 40 invemess Center Parkway P0 Box 1295 Birmingham, Alabama 35201 Tel 205.932.7122 Fax 205 992.0403 SOUTHERN COMPANY Energy to Serve Your V' o rld" January 29, 1998 LCV-1016.F Docket Nos.: 50-424, 50-425 l

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:

t VOGTLE ELECTRIC GENERATING PLANT INSERVICE INSPECTION PROGRAM REOUEST FOR RELIEF RR-22 By letters LCV-1016-A and LCV-1016-C dated September 10, '097, and September 17, 1997, respectively, information was provided in response to the NRC letter dated August 8,1997, which requested additional information concerning the Vogtle Electric Generating Plant (VEGP), Units 1 and 2, Second Ten-Year Inservice Inspection Program.

Specifically, information was provided in response to NRC questions coc.cerning our requested use of ASME Section XI Code Cases N-533, N-544, and N-566, as discussed in Requests for Relief RR-26, RR-22, and RR-75, respectively. Included in our Septeraber 10 and 17,1997 letters were revisions to Requests for Relief RR-25 and RR-  !

26. The NRC TAC numbers associated with t'r request for additionalinformation were f

M98977 and M98978.

By letter dated October 24,1997, the NRC advised Southern Nuclear Operating Company (SNC) that Requests for Relief RR-25 and RR-26 had been reviewed and were found to b be acceptable for use. In the case of RR-26, acceptance was limited to Ciass 1 only.

Request for Relief RR-22 was denied by the NRC citing an inadequate technical basis to

( show that ASME Section XI Code Case N-544 provides an acceptable level of quality and J safety.

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[ U. S. Nuclear Regulatory Commission F '- ~LCV-1016-F

_ ; Page Two :

J On November 12,1997, SNC personnel held a conference call with the_NRC and its contractor, INEEL Research Center, to discuss Request for R lief RR-22. It was our

- understanding that the NRC and its contractor had concerns about repairs to steam ~

generator tubing, sleeves, or welded plugs used for plugging steam generator tubing if 5 ASME Section XI Code Case N-544 was to be used. The subject code case explicitly-excludes repairs to heat exchangers, sleeves, and welded plugs used to plug heat-exchanger tubing. Steam generators are nothing more than heat exchangen and would be similarly excluded although not explicitly stated in Code Case N-544. As a result, we have modified Request for Relief RR-22 which is enclosed herein to specifically make note that tubing associated with heat exchangers and steam generators, including sleeves, and welded plugs useo to plug their tubes, are excluded from the application of Code Case N-

,544 at VEGP. In addition, information is provided which is intended to resolve any concerns regarding maintaining the level of quality and safety when implementing Code Case N-544? Specifically, SNC will continue to perform repair / replacement activities for 1-inch nominal pipe size (NPS) an(. smaller items, e.g., piping, tubing, valves, and fittings, using various existing approved procedures and/or programs which establish control on the planning, work control, quality assurance / quality' control, and implementat.on of work packages to assure the level of quality and safety associated whh repairs to items 1-inch -

NPS and smaller. The enclosed version of Request for Relief RR-22 supersedes the -

original version of the subject request for relief as submitted by our letter LCV-1016 dated May 29,1997, which provided the Inservice Inspection Program, Second Ten-Year .

Interval.

Your prompt ieview and approval of the enclosed version of Request for Relief RR-22 is -

respectfully requested so that it may be used during the VEGP-2 Maintenance / Refueling Outage 2R6 which is scheduled to begin Much 8,- 1998.

A' copy of this submittal is being provided directly to Mr. M. T. Anderson of the INEEL Research Center to provide consistency with your earlier request of August 8,1997.

' Should there be any questions in this regard, please contact this office.

- Sincerely, C. K. McCoy CKM/JAE/jae o

4 U. S, Nuc) ar Regulatory Commission

' LC%1m f-

- Page Three

Enclosure:

Revision 1 to Req'pst for Relief RR-22 xc: INEEL Research Center Mr. M. T. Anderson (w/ enclosure)

Southern Nuclear Operating Company Mr. J, B. Beasley, Jr. (w/o enclosure)

Mr. W. L. Burmeister (w/o enclosure)

Mr. M. Sheibani(w/ enclosure)

NORMS (w/ enclosure)

U. S: Nuclear Regulatory Commission Mr. D. H. Jaffe, Senior Project Manager, NRR (w/ enclosure)

Mr. L. A. Reyes, Regional Administrator (w/ enclosure)

. Senior Resident Inspector, Vogtle (w/ enclosure)

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. . ENCLOSURE

' ~'

TO.

- SOUTHERN NUCLEAR OPERATING COMPANY

. LETTER LCV-1016-F d

VOGTLE ELECTkIC GENERATING PLANT

- INSERVICE INSPECTION PROGRAM REOUEST FOR RELIEF RR-22 .

Revision 1 of Request for Relief Rk-22 supersedes the similar request for relief which had l

' been submitted to the NRC in SNC letter LCV-1016 dated May 29,1997. Re dsed' Request for Relief RR-22 immediately follows this introduction. The page numbers which

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. are found in the enclosed request for relief correspond with the page numbers in the :

VEGP-1 and 2 Inservice Inspection Program-Second Ten-Year Interval which

! accompanied the SNC letter of May 29,1997.

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4 S

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SOUTIIERN NifCI EAR OPERATING COMPANY

. VOGTI.E El.ECTRIC GENERATING Pl. ANT, tiNITS I AND 2 SECOND TEN-YEAR INTERVAL, REOf f EST FOR REl lEF NO. RR-32

1. System / Component (s) for Which Reliefis Reauested,:

Each of the ASME Class 1,2, and 3 small items consisting of piping, tubing (except heat exchanger tubing, sleeves, and welded plugs used for heat exchanger tubing), valves, and fittings 1-inch and smaller nominal pipe size (NPS) subject to repair or replacement within the scope of the ISI Program. Steam generator tubing, sleeves, and welded plugs used for steam generator ,

tubing are considered by SNC to be heat exchanger tubing-related components at VEGP and are therefore excluded from the scope of this request for relief.

II. Code Reauirement:

IWA-7400 (a)(4) of the 1989 Edition of ASME Section XI exempts 1-inch NPS and smaller l replacement items and their installation from the requirements ofIWA-7000; whereas, the repairs ofitems 1-inch NPS and smaller are not similarly exempted from the requirements ofIWA-4000.

III. Code Reauirement for Which Reliefis Reauested:

Reliefis requested from the requirements ofIWA-4000 and IWA-7000 on piping, tubing, valves, I and fittings 1-inch NPS and smaller.

IV. Basis for Relief:

ASME Section XI Code Case N-544 was issued on August 24,1995 and provides an alternative l to the requirements ofIWA-4000 and IWA-7000 when a repair or replacement is performed on '

piping, valves and fittings 1-inch NPS and smaller. A copy of the code case is provided as Attachment I to this request for relief. The provisions of this code case were added to IWA-4131 and IWA-4132 in the 1995 Addenda to ASME Section XI.

V. Alternate to the Code Reauirements:

Southern Nuclear Operating Company will comply with the requirements of Code Case N-544 in lieu ofIWA-4000 and IW \-7000 except that the subject code case will not be applicable to heat exchanger tubing, sleeves, and welded plugs used for heat exchanger tubes in Class 1,2, and 3 heat exchangers, including simihr steam generator-related components.

VI. Justification for the Grantine of Relief:

The 1989 Edition of ASME Section XI Code provices an exemption for replacement items 1-inch NPS and smaller from the requirements ofIWA-7000, but repairs to such items are not similarly

, exemptu Therefore, a repair to an item is subject to mye restrictive requirements than replacing the item. Code Case N-544 allows application of the alternative requirements for replacement to all repair and replacement activities. The ASME Code Committee evaluated the 7-90 Rev.I J

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SOliTI1ERN NifCl. EAR OPERATING COMPANY VOGTI.E El ECTRIC GENERATING Pl ANT liNITS 1 AND 2 SECOND TEN-YEAR INTERVAL, REOIIEST FOR RELIEF NO, RR-22 i .

l (continued) i VI. J'istification for the Grantine of Relier(continuedh proposed alternatives contained in the code case and determined that they are acceptable for repair and replacement activities on piping (including tubing with certain exceptions), valves, and fittings 1-inch NPS and smaller. Components to which exceptions were applied are identified in Paragraphs - 1300 and - 1400 of Code Case N-544. Specifically, the exceptions include heat exchanger tubing, sleeves, and welded plugs for heat exchanger tubing for Class 1,2, and 3 g

systems. In addition, SNC considers steam generator tubing, sleet ty and welded plugs used for  ;

plugging steam generator tube , to be heat exchanger-related components. Therefore, Code Case N-544 will not be applicable to the steam generators nor to other Class I,2, and 3 heat exchanger tubing, inc.luding sleeves and welded plugs for heat exchanger tubing. The steam generator tubes will continue to be inspeued in accordance with the requirements of VEGP Tecnnical Specification 5.5.9, " Steam Generator (SG) Tube Surveillance Program", including any tube plugging required as a result ofinspections performed. Any necessary repairs of steam generator tubes or those of other Class 1,2, and 3 heat exchangers will be repaired in accordance with the requirements of the 1989 Edition of ASME Section XI. SNC has determined that implementation of the code case (with the exacotions noted herein concerning heat exchangers and steam generators) will not affect the level of quality and safety, nor decrease the me.rgin of public health and safety. To ensure that the level of quality and safety is maintained, SNC will perfcrm ,

repair / replacement activities for 1-inch NPS and smaller using various existing approved procedures and/or programs which establish control on the planning, work control, quality assurance / quality control, and implementation of work packages.

While the cost savings associated with Code Case N-544 have not been quantified as a Cost Beneficial Licensing Action item, its implementation is consistent whh the intent to eliminate nonbeneficial work activities and their asso:iated costs. Therefore, i, is requested that the proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

VII. Implementation Schedule:

This relief for request is applicable to the Second Ten-Year Interval which commenced May 31, l 1997.

7-91 key.1

SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT. UNITS 1 AND 2 SECOND TEN-YEAR INTERVAL f , REOUEST FOR RELIEF NO. RR-22 (continued)

ATTACUMENT 1 CASE N-544 i CASES or 45sts 80tLER A.*80 PRESSLRE vttsEL Coot Aeoneves Dete: August 24. toes See Arumeness sneen Sur erewonen and one ovememanen esees.

Case N.544 reactor coolant makeup systems operable from onsiae Repair /RepAmeement of Small items emergency power.

I*"I"" *TI' O I 4400 Class 2 anu 3 piping tubing teacept heat enchanger tubing, and sleeves and welded plugs used faguery: When performing repair or replacement of eachanga tu an va es. and Amngs. M p ping, valves, and Attings. NPS I and smaller, whas I "" '"

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altemative requirements may be used in lieu i .#A.

4000 for repair and (WA 7000, for replacement con. 2000 ACTTylTIES PERFORMED TO ducted in accordance with Section XI Edison and SlJmlER 1978 ADDENDA THROlJCH Addenda through me 1990 Addenda, or (WA-4000 for 1990 ADDENDA OF SECT!CN Xt repair and replacement conducted in a6cordance etth

• • *

• 2100 For the liams idanuAed in .1300 and .4400 the following requiremsnu are an alternative ao the Aept.v: It is the opinion of the Commiase mas repair *"* ' "' "' ^

• and replacement of piping vaaves, and Assings. PfPS 000' I and smaller, may be performed in accontance with 2200 liams to be used for replacement shall be the following requirements:

constructed in accordance with (WA.7210. except that possession of a Canincate of Authorization and an agreement with an Authonsed Inspection Agency are 1000 CENERAL REPAIR AND nether requWd nor prohibited.

REMmtM REQMRGENTS 2300 items to be used for repair and replacement 1100 Repair ano replacement scuvities performed in shall be obtained. installed. and documented in acco11 accordance with Secuan XI Ediuon and Addenda from ance with the provisions of (WA 1400e) and the the 1977 EJition with the Summer 19'S Addenda technical requiremems of (WA.7210. For Section !!!

through the 1939 Edition with the 1990 Addenda or- Dems. the requirements of NA.3700/NCA 3h00 need items identined iw1300 and .1400 shall satisfy the not be met, providet the Owner's Quality Assurance sequirements of 1000. Program provides measures to assure that material used 1200 Repair and replacement activities performed in ***' "

• accordance with Section XI Editions and Addrada from the 1989 Edition with the 1991 Addenda through the * * " ' * ** *" ^ *******" *** P"

• 1992 Edition with the 1994 Addenda on items identined

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in .1300 and .1400 shall .tatisfy the requirements # 8**#U ****"* "'** *

• g for instahtion of these items.

.l300 Class I piping. tubing (escept heat exchanger

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• tubing, and sleeves and we.ded plugs used for heat act n ance wi A.I 00(nl. MACO. !WA4200 eschanger tuberp. valves. Attings, and associated sup- "## '"#** N" I ""

• ports. no larger tnan the smatter of (a) or (b) below- '" *##* *' * * "' * * * * * * " "

talNPS1 E***"" I'**"*""^" ## "

Ibn A sise and design sucP w t. in the event of "#b * * '"" ' " " " '

postulated failure tunng norm .nt operating condi.

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tions, the reactor can be shut down and cooled in an 2300 If an item to be repared os replaced does not ordcrty mannet. assuming makeup is provided by normal satisfy me requirements of Secuan XI. the Owner shall 7-92 Rev.1

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$OUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT. UNITS 1 AND 2 L SECOND TEN-YEAR INTERVAL f , REOUEST FOR RELIEF NO, RR-22 (continued) l ATTACHMENT 1 (continued)

CASE (continuedl N-544 .

casts or sua er. itra aso ratsst:st vassar. coot determine the cause of unacceptatility ax mu.e ue NCA.3800 need not be met. prouded the Owner's suitability of the apair or replacement pxx te., mturning Quality Assurance program provides measures to assuse the nem to seruce. If the spect cation he we enginal that matenal used for replacement es fumished in asserd.

Item is determined to be deAcient, appropnate corrective anee with she applicable masenal spoetAcas6en and provisions shall be included in the specidention for the masenal requirernenis of Section til. A RepaireReplese.

repair or the replacement nem, meet ptan, pressure testing, services of an Aushesiand 2600 For vah es s how performance parameters sound I"*'""" # 8""*E' ** 'k

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os affected by the repair or replacement activity, a

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preseruce test shalt be .nade in accoreance enn Subsec. 3400 Repair shall be performed and documeneed in tion (WV pnot to retuming the vabe to utvice. accordance with IWA.l400 n). IWA 4l20. IWA.4200, and (WA 4300, and (WA.4133 for the 1993 Addeada 2700 For purnps whose performance paraments could and later. Weld AU:t maserial shan be obtamed le be alfmed by the repeat or_ replacement acdvity, a g ,g 4 , g_

new set of reference values shall be denateiend in pressure issong, services of an Authorised Inspeedom accordance wie Subsection (WP dunas the Arst laser. Agacy, and n of Nts.1 focus are ses so.

vice use performed after the pump la put into service. g 230f, Use of these alumative sequirsenents, including 4gg, gg , g , g, ,

specifying the site of Class 1 imms to which these h p u of h E h h M mquirernents will be applied, shall be documensed by ,,,,,,,,,,,,,,,,,,g,  ? r,;y ,,, ,,,,,,,, ,,,

the Owner and is subject to revww cy the Inspecar suienbility of the repair or repla' cement prior io ruessmane the item to service. If the speciAcanon for une original 3000 A'. TTVITIES PERFOR.%tED TO 1991 item is determined to be deAcient, appropriate conecdve ADDENDA THROt*GM 1994 ADDENDA provisions shall be included in the speciAcation for the OF SECTION XI . repair or me .y_ . ; item.

3100 For the items identined ;n l300 and .I400, 3400 For valves whose performance pararacters asuid the following requiremerts are an altamative to the be affected by the repair or realacement acdvity, a repair and replacement equirements of IWA.4000, psenervice test shall be made in accordance with Subees.

"** '* "*""'I ** ** **

3200 luent to be used for replacement shall be constructed in accordance with IWA-4t?Q. except that 3700 For pumps whow performance paramewes osuid possession of a Ceniscate of Authortaanen and an be affected by the repair or replacement activity, a agreement with an Authonted laspection Agency are new set of reference values shall be determined in neither required not prohibiud. accordance wuti Subsecuon (WP during the Arst inser.

was nned aher me pung is put inn m 3MO ltems to be used for repair and replacement shalt te obtained installed, and documented in acconi. 3800 Use of these alismative requirements. Lncludlag ance v ith the provisions of IW A.1400(n). and IWA. specifying the site of Class ! Items to which these 4132 sor the 1993 Addenda and later, and IWA.4170. requirements will be applied, shall be documeneed by Fw Secuen !!! imms, the requirements of NA.370CI the Owner and is subject to review by ttw Insporter.

7-93 'Rev.1

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