ML20202B788

Rev 8 to ISI-P-006, ISI Program for Gpc Vogtle Electric Generating Plant Unit 1

ML20202B788
Person / Time
Site:	Vogtle
Issue date:	12/01/1997
From:	SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML20202B775	List: ML20202B770 ML20202B788
References
ISI-P-006-R08, ISI-P-6-R8, NUDOCS 9712030176
Download: ML20202B788 (41)

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INSERVICE INSPECTION PROGRAM (ISI.P-006)'

-FOR i

GEORGIA POWER COMPANY -- 3 VOGTLE ELECTRIC GENERATING PLANT l UNIT 1 PREPARED BY i SOUTHERN NUCLEAR OPERATING COMPANY l INSPECTION AND TESTING SERVICES GROUP l l

SNC GENERALOFFICE SNC-VOG'1E '

PLANT j REV. DATE DESCRIPTION PREP'D REV'D APPV APPV. APPV. APPV. '

BY BY BY VOGTLE MGR. PLANT (ITS) (ITS) (ITS) PROJECT ENGR GEN.

i NMS SUPP. MOR.

0 9/24/86 ISSUED FORINSERVICE k / f INSPECTION f\ l / l

l.  !

7/23/87 ADDS RELIEF REQUEST k / k / k f k f k f k f FOR PRESSURE TESTS \ l \ l \ / \ / \ / \ l l lf kf 2 4/01/88 INCORPORATE NRC k kf kf k f k COMMITMENTS \ lf \l \ l \ l \ \ l i 3 1/20/89 ADDS RELIEF REQUEST kf kf kf FOR RR-52,53,54 k\ lf \l k\ l/ k\ l[ \[ \l 4 4/06/90 DELETED REllEF f .

REQUEST RR 45,47,48,54, (

REVISED RR 12,32 jg / {

5 6/10/91 INCORPORATES COMMEN TS PER GPC LTR.

MSV-00318,9/13/90 , {

6 11/5/93 INCORPORATES COMMENTS PER PCR 93-017 AND ADD GENERAL COMMENTS' 7 8/11/95 REVISED RELIEF l

\ f

, REQUESTS SECTION 8 12/1/97- REVISED RELIEF d46j"'" Fih Md j  :

REQUESTS SECTION e

- 7r gg - ,y 33g  ;

- D 4

l 9s l

., 1 VEGP 1 FIRST T5IN-YEAR INTERVAL ISI PROGRAM DOCUhiENT ISI P-006 I SUhthiARY OF CllANGES 1

l

• " Approvals" sheet revised to reflect SNC-GO and SNC Vogtle Plant sign offs  ;

(" Approvals" </neet similar to one in 2nd Interval ISI Program document),

• Summary of Changes for Rev. 8 provided,

• Revised Distribution List to change VNhtS document recipient copy from L. A.

Ward to T. V. Greene, Jr.,

e Revised List of Effective Pages to show which were Rev. 8 pages, e Revised " Introduction" to refle:t editorial changes which include, but are not limited to, notation of ficense transfer from GPC to SNC, e g., Vogtle initially noted as " Georgia Power Company (GPC)-owned Vogtle Electric Generating Plant", "GPC, the former licensee and operator of VEGP and sister company to Southern Nuclear Operating Comp. y (SNC), the current licensee and operator of VEGP",

• Added new RR-63 (RPV Upper Shell Long. Welds W12, W13, & W14) to B-A Catgy. page (IWB 2500-1)in section 2, e Revised section 6.1 to address revisions to existing relief reguests, e.g., RR-2, RR-4, and to add new RRs 63 and 64, e Revised existing RR-2 for re-submittal due to exam coverage limitations for RPV weld, coverage <90%, added figure depicting weld / limitation (s),(Note: Also involves relief from 10CFR50.55a regs for Catgy. B A welds, item No. Bl.10),

e Revised existing RR 3 for similar reason to RR 2 above, similar content, different welds, (Note: Also involves relief from 10CFR50.55a regs for Catgy. B-A welds, item No. Bl.10),

• Revised existing RR-4 to withdraw relief request since exam coverage >90%,

e Revised existing RR 5 for re-submittal due to exam coverage limitation for RPV weld; coverage (90%, added figure depicting weld / limitation (s),

• Added wc!d ll204-V6-001-WO5 to Attachment 1 in existing RR 30. VT supplemental exam performed 11/97 since surface exam limited. Also corrected item No. for Discharge Pulsation Dampener from Cl.10 to Cl.20 and added reference to Relief Request RR 62 for several welds, 1

s. ,

f, VEGP-l FIRST TEN YEAR INTERVAL ISI PROGRAh! DOCUhiENT ISI-P-006 SUhih1ARY OF CilANGES (continued) e Added new RR-63 which covers RPV Upper Shell Longitudinal Welds W12, W13 and W14. Exam coverage <90%. (Note: Also involves relief from 10CFR50.55a regs for Catgy. Il-A welds, Jtem No.111.10), and

. Added new RR-64 for piping and components <l" NPS. Pursues argument that although any repairs to 1" NPS and smaller may not have been properly documented, do not wish to provide paperwork since would not provide commensurate increase in level of safety. Also cites change in code allowing replacement criteria for all repairs and rep'acements as discussed in 1995 Addenda to ash 1E Section XI as reason not to go back and do recordkeeping for any such repairs.

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Vogtle Electric Generr!.ing Plant (VEGP-1)

Inservice Inspection (ISI) Program (ISI P-006)

Revision 8 Summary of Channes Affected ISI Program Il0Gumcallagts Changes Distribution List Changed to reflect current organization.

1 1 thm 13 Editorial changes to reflect names of current and former licensee and operator of VEGP.

22 Added applicable relief request number in table.

61 thru 6-4 RR-4 withdrawn and added references to RR-63 and RR-64.

6-6 thm 6-6b Re submittal of 10CFR50.55a(g)(6)(ii)(A)-revoked RR 2 due to examination coverage limitations for RPV lower shell to bottom head weld.

6 7 thru 6-7b Re submittal of 10CFRf 0.55a(g)(6)(ii)(A) revoked RR-3 due to examination coverage limitations for RPV lower shelllongitudinal weld.

6-8 RR-4 is withdrawn since full Code examination achieved for RPV meridional welds 11201-V6 001-W21, -W22, -

W23, and -W24.

6-9 thm 6-9b Revised examination coverage for RR-5.

6 55 and 6-56 Added weld 11204-V6-001-WOS, Be an Injection Tank vessel support pad welded attachmr 4 to RR-30.

Corrected ASME Item No. for Di charge Pulsation Dampener 11208-V4-002 WOI from Cl,10 to C1.20.

Added note to bottom of page 6-56 that the regenerative heat exchanger, excess letdown heat exchanger, letdown heat exchanger, letdown reheat heat exchanger, and the discharge pulsation dampener are exempt from examination per RR-62.

sumchgs Page1 of2

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Vogtle Electric Generating Plant (VEGP 1)

Inservice inspection (ISI) Program (ISI P-006)

Revision 8 Summary of Channes (Continued)

Affected ISI Program lheumenthgu Chango 6112 thru 6114 Relief requested for liinited examination coverage of RPV upper shelllongitudinal welds. Examination coverage less than 90% (RR-63).

6-115 thru 6-119 Relief retroactively requested from repair requirements of piping and components 1-inch nominal pipe size and smaller (RR-64).

sumchgs Page 2 of 2 T

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L -  !

n ,

VEGP-1 INSERVICE INSPECTION PROGRAM ,

(ISI P-006)

, DISTRIBUTION LIST HOLDER MANUAL NUMBER ,

L J. Chure.hwell 4 ,

Deleted 6  :

L L. Rowe 14 A. B. Cardona 18 K. G. Lowery 20 L. K. Mathews 22 4 T. V. Greene, Jr. 26 l L

Supervisor, Engineering Support 29

'distist 006 Rev 8

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VEGP-1 ISI-P-006

List of Effective Pages- )

i Distribution,- Rev. 8 -

Table of Contents, Rev. 6 .;

Introduction:

Page 1-1, Rev 8 f' Page 12, Rev.8 Page 1-3, Rev.8 -i Page 1-4, . Rev.7 Page .1-5, Rev.7 Page 1-6, Rev.7  ;

Class 1:

Page 2-1, Rev. O

_ i Page 2-2, Rev.8. l Page 2-3, Rev. 0 Page 2-4, Rev.O <

Page 2-5, Rev 0 Page 2-6, Rev.7 Page 2-7, Rev.1 Page 2 8, Rev.0 Page 2-9, Rev.O Page 2-10, Rev. O. )

Page 2-11, Rev. O i Page 2-12, Rev. 0 l Page 2-13, Rev.1 Page 2-14, Rev. O Page 2-15, Rev. 7 Page 2-15a, Rev. 7 Page 216, Rev. O Page 2-17, Rev. 0 Page 2-18, Rev. 0 -

Page 219, Rev. O Page 2-20, Rev. O Page 2-21, Rev. O Page 2 22, Rev. 7 -

Page 2-23, Rev 7-Page 2 23a, Rev. 7 Page 2 23b, Rev. 7  :

Page 2-24, Rev. 0.

Class 2i Page 3il, Rev.0 ~

l Page 3-2,- Rev.7 Page 3-3, Rev. 0

- Page 3-4, Rev.5 eH'pgs . 1of5 - 006 Rev. 8

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a i

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, Class 2 (continued):

r Page 3 5, Rev.7 Page 3 Sa, Rev. 7 Page 3-6, Rev. 5 Page 3-7, Rev.0 ,

Page 3 8, Rev.O i Page 3-9, Rev.O Page 3 10, Rev. O Page 3-11, Rev 0  :

Page 3-12, Rev. 7 -

Page 3-12a, Rev. ~

Page 3-13, Re J Class 3.

Page _4-1,- a v. O Page 4 2, Ri --7 Page 4-2a, Rev. 7 Page 4 3, Rev 7 Page 4-3a, Rev. 7 Page 4 4, Rev. 7 hge 4-4a, Rev 7 Component Supports:  ;

- Page 5-1, Rev. 0 -

Page 5-2, Rev.O Page 5-3, Rev.O Page 5-4, Rev.0 4

ReliefRequests:

Page 6-1, Rev.8 Page 6-2, Rev.8 Page 6-3, Rev. 8 Page 6-4, Rev.8 Page 6-4a, Rev. 8 Page 6-5, Rev.5 Page 6 6, Rev.8 Page 6-6a, Rev. 8 Page 6-6b, Rev 8 Page 6-7, Rev. 8 1 Page 6-7a, Rev. 8 Pagef .s, Rev.8 Page 6-8,- Rev 8

' Pa8e 6-9,- Rev.8 ~ -

Page 6-9a, Rev. 8 Page 6-9b, Rev. 8.

effpgs 2 of 5 006 Rev. 8

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ReliefRequests (continued):

1 Page 6-10, Rev.1 i Page 611, Rev. I  !

Page 6-12, Rev. I  !

Page 6-13, Rev. I  !

Page 614, Rev. 6 Page 615, Rev.1 Page 616, Rev.-1 Page 617, Rev.1 Page 6 18, . Rev. 4

- Page 619, Rev.1 Page 6 20, Rev.1 Page 6-21, Rev.1 Page 6-22, Rev.1 -

Page 6-23, Rev.1 _

Page 6 24, Rev.1 Page 6 25, Rev.1 Page 6 26, L Rev.1 Page 6 27, Rev 1 ,

Page 6 28, Rev. l' Page 6-29, Rev.1 -

Page 6 30, Rev. 5 Page 6 31, Rev.1 Page 6-32, Rev.1 Page 6-33, Rev.1 Page 6-34, Rev. Page 6-35, Rev.1 Page 6 36, Rev. 5 ,

Page 6-36a, Rev. 5 Page 6 37, Rev. 5 .

Page 6-38, Rev. 2 Page 6 39, Rev. 7 -

Page 6-40, Rev. 7 Page 6-41, Rev. 7 Page 6-41a, Rev. 7 Page 6-42, Rey,1 Page 6-43, - Rev. 7 Page 6-44, Rev.1 Page 6-45, Rev.1 >

Page 6-46, Rev. 5 Page 6-47, Rev. 5. '

Page 6-48, Revi5_ _

Page 6-49, Rev. 5 I age 6-49a, Rev. 5 Page 6 49b, Rev. 5 .i effpgs1 3 of 5 - 006 Rev. 8 l'

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i ReliefRequests (continued): l Page 6-49c, Rev. 5 [

Page 6-49d,Rev. $ .

Page 6 50, Rev.1 ,

Page 6-51, Rev.1 .

Page 6 52, Rev.1 .

Page 6 53, Rev.1 [

Page 6-54, Rev. 7 Page 6-55, Rev. 8 Page 6 56, Rev. 8 ,

Page 6-57, Rev. 5 i Page 6-57s, Rev. 5_ .

Page 6-38, Rev. 4 Page 6 58a, Rev.'4 j Page 6-59, Rev. 4 Page 6-60, -_ Rev. 2 1 Page 6 61, Rev.1 l

. Page 6-62, Rev.1 Page 6-63, Rev.1

Page 6 64, Rev.1 Page 6-65, Rev. O Page 6 66, Rev. O Page 6 67, Rev. O Pape 6-68, Rev. 0 ,

Page 6-69, Rev 0 Page 6-70, Rev. O Page 6 71, Rev. 5 Page 6-72, Rev. O Page 6-73, Rev. O Page 6 74, _ Rev. O Page 6-75, Rev. 0 Page 6-76, Fev. O Page 6-77, Rev. O Page 6 78, Rev. O Page 6-79, Rev. 0 -

Page 6 80, Rev. O Page 6-81, Rev. 2  ;

Page_6-81a. Rev. 2 Page 6-82, Rev,7 .

Page 6-82a, P.ev. 7

- Page 6-83,' Rev.1 Page 6 84, Rev.1 I Page 6-85, Rev. 4 - ,

ell'pgs 4 of 5 006 Rev. 8

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. Relief Requests (continued):

Page 6-86, Rev.1 Page 6-87, Rev. 4 Page 6-88, Rev. 4 Page 6-89, Rev. 4 Page 6-90, Rev. 6  !

Page 6 90s, Rev 6 Page 6 90b, Rev. 6 Page 6-91, Rev.1  ;

Page 6-92, Rev. 5 Page 6-93, Rev,5  :

Page 6-94, Rev. 5 Page 6-95, Rev. 3 Page 6-96, Rev. 4 ,

Page 6 97, Rev. 4 Page 6-98, Rev. 4 Page 6 99, Rev. 6 Page 6-100, Rev 7 Page 6-101, Rev. 7 Page 6-102, Rev. 7 Page 6103, Rev. 7 -

Page 6104, Rev. 7 Page 6105, Rev. 7

. Page 6-106, Rev. 7 Page 6-107, Rev. 7 Page 6-108, Rev. 7 '

Page 6-109, Rev. 7 Page 6-110, Rev. 7 Page 6111, Rev. 7 .

Page 6-112, Rev. 8 Page 6113, Rev. 8 Page 6-114, Rev. 8 Page 6-115, Rev. 8 Page 6-116, Rev. 8 Page 6-117, Rev. 8 ,

Page 6118, Rev. 8 Page 6-119, Rev. 8 effpgs 5 of 5 006 Rev. 8 r

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1.0 INIEDDJCIl0B 1.1 Geneal This document details the scope ofinservice inspections for the Georgia Power Company (GPC).

owned Vogtle Electric Generating Plant (VEGP) Unit 1 and includes the following points ofinterest:

• Frequency ofinspections.

• Identification of all areas to be examined.

• ReliefRequests.

The contents of this document are subject to change (with approval) during the course ofinsenice inspections.

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Summer 1983 Addenda is currently used for inservice inspection (ISI). The actual edition applicable to ISI is the latest edition approved by the Nuclear Regulatory Commission 12 months prior to the date ofissuance of the operating license per 10 CFR 50.55a. Additionally, inspection program B will l be used as defined by IWA 2400 of Section XI.

1.2 Sconc This document is a description of the Inservice Inspection Program for Class 1,2, and 3 components.

1.3 ComponenLUPatadiRS All plant components have been reviewed to determine the appropriate classification for insenice inspection. The classification information is given in the Line Designation List and Equipment Designaticn List located in the VEGP Unit i insenice inspection Plan, ISI-P-005. It must be noted however, that the classification of components as ISI Class 1,2, or 3 for insenice inspectir i does not imply that the components were designed or constructed in accordance with the same ASME classification requirements. The component design codes remain as stated in the VFCP Final Safety Analysis Report (FSAR).

1.4 Ilcmomibility Southern Nuclear Operating Company (SNC), the current licensee and operator of VEGP and sister company to GPC, the former licensee and operator of VEGP, bears the overall responsibility for the performance of the it.senice inspections. Certain nondestructive examinations will be performed by a qualified inspection agency. The results of such examinations will be reported to SNC for final l cvaluations and disposition.

006 intro 1-1 006 Rev. 8

i 1.5 Records

. Records and documentation of all information and inspection results, which provide the basis for evaluation and which facilitate comparison with results from subsequent inspections, will be available for the active life of the plant.

1.6 Methods of Examination The method of examination planned for each area is delineated in subsequent sections. Personnel ~

performing nondestructive examinations will be trained in accordance with the American Society for Nondestructive Testing (ASNT) and the ASME Code. ,

1.6.1 Eddy Current Eddy current examinations will be performed on the steam generator tubing in accordance with the Pre-VEGP Improved Tech *.al SpeciGcation Section 4.4.5.0 and Regulatory Guide 1.83, Rev.1. The alternative techniques used for this examination, as permitted by paragraph IWA-2240, either satisfy or exceed the requirements of Appendix IV of ASME Section XI and/or Article 8, Appendix I of ASME Section V.

1.6.2 Liquid Penetrant Dye penetrant inspections will be perfom ed whenever a surface examination is required on  ;

nonmagnetic components.

1.6.3 Magnetic Panicle Magnetic panicle tests will usually be used when surface examination of carbon steel components is required.

1.6.4 Radiographic

- Radiographic techniques may be used as an alternative method to ultrasonic examinations.

1,6.5 llllIREmis Ultrasonic examinations will be cond ated in accordance with the provisions of Articles 4 and 5 of Section V, ASME, or Appendix III of Section XI, ASME, as applicable. The reactor vessel will be examined to the requirements of Regulatory Guide 1.150, Rev, I to the extent practical.

006 intro 1-2 006 Rev. 8 gy rw - viwyw-- p- r y--- -

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$ I 1.6.6 MiEUALIfill A visual test (VT) inspection will be employed to proside evidence ofleakage or to provide a report of the general condition of the component.

A. The VT-1 inspection shall be perfortned to determine corrosion, erosion, wear, cracks, or physical damage of the part, component, or surface being inspected.

11. The VT-2 inspection shall be performed to determine and locate leakages from pressure retaining components or excessive leakage from components without leakabe collection systems.

C. The VT-3 inspection shall bc ,)erformed to determine the structural, general, and physical conditions of components or their supports.

D. The VT-4 inspection shall be performed to ensure the operability of components and their mechanical or hydraulic devices.

1.7  !!Yaluation of ExaminatioAResults Examination results are evaluated per IWA-3000, IWIl-3000, and IWF 3000 of the ASME Code,Section X!. Articles IWC 3000 and IWD 3000, " Acceptance Standards for Flaw Indications,"

are in the course of preparation and, as yet, are not available for use. Therefore, the rules of IWB-3000 may be utilized for ISI Ciass 2 and 3 components.

1.8 lispair and Replacement Procedures Repair and replacement procedures have been developed by GPC and SNC. l 1.9 LimilAliRus_ofJiuminations Certain limitations to nondestructive examination of welds due to geometric configuration or inaccessibility were identified during the Presenice Inspection. During ISI the required examination will be accomplished to the maximum cxtent possible and limitations will be documented in relief requests. Known relief requests are contained in the Relief Request section of this document. Additional rebef reguests will be submitted as necessary.

The insenice inspection program outlined in the attached tabulations have been developed as a result of a design resiew and the Presenice Inspection.

006 intro 13 006 Rev. 8

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%gste Decarw Genersong Fiaen Unis No 1 Inurssee Insen:me 006 Ree. 8 Table 1%%2500-1 Exanneauen Cmegmes B-A. PRESSURE RETAIN:NG WEI.DS IN REACTOR 1TLE1.

Fusnaand Fregnency of Exammetra Examamace Exanmaatsme Isa 2nd.3rd.4qh Reber R,-- ... .; /

Medaf'. Lserval Iritavah . Recuest Censumun hem No Peru Exammaed Tsre No ,_

Bl.10 Shell Welds C--.i; : sal IWB-2500-1 UT A!! Welds' One bekhne Bl.ll regns weid RR 2.39 LT A!I Welds' Oneleklase RR-3.39.63 l Bl.12 Imgendmal 1% % 2500-2 vegMme weld i l

1 Bl.20 Head Welds LT Accessitd Accessible RR-5.7.39 Bl.21 C-.i. a IWB-2500-3 lengthcf all length ofene welds -Hd' IWB-2500-3 LT Asxessible' Accesuble RR-4.39 Bl.22 Mendwass!

length of all Length erone

=cids weld' Bl.30 Shell.4o41ange IWB-2500-4 LT Weld Weld RR-39 Weld UT.MT Weld Weld RR 7 Bl.40 Hend W 1% % 2500-5 Weid Bl.50 Repair Welds' N/A N/A N/A N'A to VEGF.

Bl.51 Beltime Fegion IWIs-2500-1 and-2 NOTES:

(1) Masenal (base metal) weld repen where repair depth exceeds 10% nomenal of the vessel wait Beklaw repa exknds Tw the lengph e(the vessel thermal sheeld er in time abanice ef a diennel sleeld di enacine lenge er reacta fuel elemera If the loesiem of the repar is not pousively and accurately kmwn,then the individent sheE pisse, fagsig er sheB consie cesemaneg the repair dinII be incladal (2) Inchades essentia!!y 100% of the weld leng It (3) Select meld located at a desip structural dem:entassity. if any.

(4) The iratially selected welds are to be m- " dunng --ve supect on enervals.

(5) If pastial examsnauens are conducted fruen flange face, the remannng volumetric exanunsanons W to be cautected frtun vessel wall sisy be performed as er near the end efendi inspection iseerv6 (6) The examination of shell-to-flange melds may be perfened dunng the frst and tlurd werecuce gu. ads in %_6. wnh the aczzle examsnabans of Exarn. Cat. B D(Program B1. At least 50% efshell

-to-flange welds shall be examined by the end of the frst inspection period, and the remmender by the end of the thrd inspecnon pericet 2-2 000341

h.. ,'

RELIEF REOUESTS 6.0

- 6.F Scope The following relief requests have been prepared from information determined in support'of inspection activities (including preservice inspection) at VEGP Unit 1.

ReliefRcqucsLNp. Examination Area RR-1 Relief Request Withdrawn RR-2 Mechanized exam of reactor vessel lower shell-to-bottom head weld (Revoked /Re-submittal) l RR-3 Mechanized exam of reactor vessel lower shell longitudinal welds (Revoked /Re-submittal) 'l RR-4 Relief Request Withdrav.n. l ,

RR-S Mechanized exam of reactor vessel bottom head circumferential welds RR-6 Volumetric exam of reactor vessel flange ligament areas RR-7 Volumetric exam of reactor vessel closure head welds RR-8 Mechanized exam of elbow-to-reactor vessel safe-end welds RR-9 Class 1 bolting, greater than 2-in. diameter RR-10 Pressurizer integrally welded attachments RR-11 Visual exam of reactor vessel supports RR-12 Volumetric exam of pressurizer welds RR-13 Relief request withdrawn f

006rr 6-1 006 Rev. 8

)

I. .

Erlief Request No. Examinat_ ion Arta RR-14 Volumetric exam of pressurizer surge-nozzle-to-vessel weld RR-15 Volumetric exam of pressu-izer surge-nozzle inner radius RR-16 Pressurizer integrally welded atta:hments RR-17 Volumetric exam of steam generator nozzle-to-elbow welds RR-18 Section XI, Appendix Ill for austenitic and dissimilar metal piping welds RR 19 Volumetric examination of steam generator channel head-to-tube sheet weld RR-20 Volumetric exam of Class 1 piping welds RR-21 Volumetric exam of Class 1 branch pipe connection welds RR-22 Volumetric exam of cast piping and elbows RR-23 Cast piping calibration block RR-24 Volumetric exam of reactor coolant pump nozzle-to-elbow and nozzle-to-pipe welds 4 RR-25 UT calibration block for reactor coolant pump nozzle-to-pipe welds 8

RR-26 Volumetric exam of SA 376 piping welds RR-27 Visual exam of Class I pump and valve internals RR-28 Inner radius exam of steam generator outlet nozzle RR-29 Volumetric exam of steam generatcr secondary side welds RR-30 Volumetric and surface exam of Class 2 vessel welds 11R-31 Use of piping calibration blocks to examine thin-wall vessels P

006tr 6-2 006 Rev. 8

O ReliefAc.que1No Examination Area RR-32 Volumetric exam of RHR heat exchanger nozzle inner radius RR-33 Relief request withdrawn RR-34 Volumetric exam of Class 2 piping welds RR-35 Technique for volumetric exam of thin-wall piping RR-36 Volumetric exam of Class 2 thin-wall p; ping RR-37 Volumetric exam of small-diameter Class 2 piping >

RR-38 Subsection IWE RR-39 Mechanized volumetric examination of pressure-retaining shell and head walds in the reactor vessel outside the beltline region RR-40 Notch length in basic ultrasonic calibration blocks for examination of vessel welds RR-41 Calibration blocks for reactor vessel nozzle-to-safe-end welds RR-42 Volumetric examination of nozzle inner radius section for steam generator inlet and outlet nozzles RR-43 VT-4 visual examination of snubbers RR-44 Class 2 piping hydrost:tically tested to Class I requirements RR-45 Relief request withdrawn RR-46 System pressure test on Class 2 components RR-47 Relief request withdrawn 006rr 6-3 006 Rev. 8

BslisfAcquesLNo. Examination Area RR-48 Relief request withdrawn RR-49 System pressure test on Class 3 vertical pit type pumps RR-50 System pressure test on Class 3 components RR-51 Relief Request Withdrawn RR-52 Reactor Vessel integrally welded attachments RR-53 Class 3 hydrostatic test on Spent Fuel Cooling and Purification RR-54 Relief request withdrawm conditionally RR-55 Intentionally blank RR-56 Intentionally blank RR-57 Intentionally blank RR-58 Intentionally blank e RR-59 Alternative pressure test requirement for welded repairs or installation of replacement items by

. welding on Class 1,2, and 3 (Reference ASME Code Case M416-1)

RR-60 Alternative rules for 10-Year System hydrostatic testing for Class 1,2, and 3 systems (Reference ASME o

Code Case N-498-1)

RR-61 Alternative rules for the selection and examination of Class 1,2, and 3 integrally welded attachments (Reference ASME Code Case N-509)

RR-62 Selected Class 2 components be excluded from surface and volumetric examinations as ahowed by 1989 Addenda through 1992 Edition of ASME Section XI 006rr 6-4 006 Rev. 8

4

~4 Relief Request No; Egymination Area RR-63 Mechanized exam of reactor vessel upper shell longitudinal welds.

RR-64 Repair of Piping and Components 1" Nominal Pipe -

Size and Smaller, 4

006rt 6-4a 006 Rev. 8 -

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EEGPd BR-2 SynemLCompsnent.fadhiclL8cliefjJlcQUISled Reactor Pressure Vessel (RPV) lower shell to-bottom head weld 11201-V6=001-WO6.

CodelequiremcDLfedhictLRelief.is.hquested ASME Section XI, Category B-A, item No. Bl.11, as found in ASME Section XI Table IWB-2500-1, requires that a volumetric examination of the pressure-retaining circumferential welds in the RPV be performed. The applicable examination volume is shown in ASME Section XI, Figure IWB-2500-1, and includes one hundred percent (100%) of the weld length. In addition to the foregoing, reliefis requested from the regulatory requirements of 10CFR50.55a(g)(6)(ii)(A) which requires examination of more than 90% of the required examination volume of ASME Section XI Catego y B-A, Item No. Bl.11 RPV welds. It should be noted that due to the version of ASME Section XI involved and the fact that VEGP-1 was in its first ten-year inte: val, the t.ugmented examination requirements of 10CFR50.55a(g)(6)(ii)(A) had no significant impact on j VEGP-1 since 100% of the RPV welds, including their entire length, were already required to be examined. Reliefis being requested from the Code and regulatory requirements because the examination volume coverage did not exceed 90%.

RAsis for Rc]icf Six RPV core support lugs are located on the lower shell of the RPV adjacent to RPV lower shell-to-bottom head weld 11201-V6 001-WO6. These core support lugs obstruct movement of the mechanized examination equipment sled / transducer along the lower shell side (upper scan region) of this weld. As a result, obtaining the required examination coverage in the vicinity of these core support lugs is not possible when performing examinations from the inside diameter (ID) of the RPV. See Attachment I to this relief request.

Akctnale_Examina. tion Because of the physical interferences presented by the six RPV core support lugs adjacent to weld 11201-V6-001-WO6, the examination volume coverage is limited to approximately 62% of the weld length during inservice inspection of the subject weld. No supplemental examination is 006tr 6-6 006 Rev. 8

~.

c._ -

I' _ - _

. VEGP-1 --

BR-2 (continued) -

~

AlicInalt Examination (qontinued) proposedi It should be noted however that an overall, general visual examination'(VT-3) of the RPV was performed in accordance with the requirements of ASME Section XI, Category B-N-1, Item No. B13.10, during the maintenance / refueling outage in which weld 11201-V6-001-WO6 was examined volumetrically, i.e., during VEGP-1 Maintenance / Refueling Outage IR6.

i hatification for the Granting of Relief Physical interferences presented by the six RPV core support lugs in the vicinity of weld 11201-V6-001-WO6 prevent a full-Code cxamination, i.e , more than 90% of the required examination volume, as defined in ASME Section XI Code Case N-460 and as required by 10 CFR 50.55a(gX6XiiXA). A significant burden would be experienced if the required examination was attempted from the outside diameter (OD) of the RPV, particularly due to radiation dose and efforts to correlate the inner and outer diameter examination coverage plots. Examination from the OD would not result in a compensating increase in the level of safety. The volumetric examination of weld 11201-V6-001-WO6 from the ID of the RPV as performed, in conjunction with the overall, general visual examination, provides an acceptable level of quality and safety and is thereforejustified per 10CFR50.55a(aX3Xi).

Implementation Schedule This relief request is applicable to the First Ten-Year Interval on VEGP-1 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).

K 006rr 6-6a 006 Rev. 8 l

4

.YEGP.1 RR-2 (continued)

A'ITACIIM ENT I Cross Sectional View Weld WO6 4

--9.63 NOM-~ jj0

, - 60* SC AN SUPPORT LUGS AT: "

0*,60*120*,180*,

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6.38' y NUM 006rt 6-6b OJ6 Rev. 8

r VEGP-1 EE-1 System / Component for Which Reliefis Requuted Reactor Pressure Vessel (RPV) lower shell longitudinal welds 11201-V6-001-W18,11201-V6-001-W19, and 11201-V6-001-W20.

Code Requitems.ut for Which Reliefis B.tgunted ASME Section XI, Category B-A, Item No. Bl.12, as found in ASME Section XI Table IWB-2500-1, requires that a volumetric examination of the pressure-retaining longitudinal welds in the RPV be performed. The applicable examination volume is shown in ASME Section X1, Figure

IWB-2500-2, and includes one hundred percent (100%) of the weld length. In addition to the

- foregoing, reliefis requested from the regulatory requirements of 10CFR50.55a(g)(6)(ii)(A) which requires examination of more than 90% of the required examination volume of ASME Section XI Category B-A, Item No. Bl.12 RPV welds. It should be noted that due to the version of ASME Section XI involved and the fact that VEGP-1 was in its first ten-year interval, the augmented examination requirements of 10CFR50.55a(g)(6)(ii)(A) had no significant impact on VEGP-1 since 1.00% of the RPV welds, including their entire length, were already required to be examined. Reliefis being requested from the Code and regulatory requirements because the examination volume coverage did not exceed 90%.

Basis for Rdigf Core support lugs are welded over the subject longitudinal wilds in the lower shell of the RPV thereby preveniing 100% volumetric examination of their entire weld length. Examination of the affected welds underneath the core support lugs is not physically possible. See Attachment I to this relief request.

Alternat: Examination Because of the physical interferences presented by the RPV core support lugs which are welded over wc!ds 11201-V6-001-W18,11201-V6-001-W19, and 11201-V6-001-W20, the examination volume coverage is limited to approximately 75% of the weld length for each of the welds during

-inservice ir.spection. No supplemental examination is proposed. It should be noted however that an overall, general visual examination (VT-3) of the RPV was performed in accordance with the requirements of ASME Section XI, Category B-N-1, Item No. B13.10, during the 006rr 6-7 006 Rev. 8

.4..

VEGP-1 B&1 (continued)

Alternate 2xamination (continued) maintenance / refueling outage in which welds 11201-V6-001-W18,11201-V6-001-W19, and .

I1201-V6-001-W20 were examined volumetrically, i.e., during VEGP-1 Maintenance / Refueling Outage IR6; hastifLCation for the Granting of Relief Physical interferences presented by the RPV core support lugs which cover portions of RPV -

.' lower shell longitudinal welds 11201-V6-001-W18,11201-V6-001-W19, and 11201-V6-001-W20 prevent full-Code examination, i.e., more than 90% of the required examination volume, as defined in ASME Section XI Code Case N-460 and as required by 10 CFR 50.55a(g)(6)(ii)(A).

A significant burden would be experienced if the required examination was attempted from the outside diameter (OD) of the RPV, particularly due to radiation dose and efforts to correlate the inner and outer diameter examination coverage plots. Examination from the OD would not result in a compensating increase in the level of safety. The volumetric examination of welds 11201-V6 001-W18,11201-V6-001-W19, and 11201-V6-001-W20 from the ID of the RPV as performed, in conjunction with the overall, general visual examination, provides an acceptable level of quality and safety and is thereforejustified per 10CFR50.55a(a)(3)(i).

Implementation Schedule This relief request is applicable to the First Ten-Year Interval on VEGP-1 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).

' 006rr 6-7a 006 Rev. 8

4 VEGP-1 BR-3 (continued)

ATI'ACilMENT 1 Cross Sectional View Weld W18, W19 & W20

+

3m 9.63 BASE . R 96.50-j METAL TO CLAD

]

. - 60

• SCAN

- 45* SCAN l

4,82 / - 70* SC AN

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SECTION C-C I

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-n 006rr 6-7b 006 Rev. 8

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YEGP-1 RR-4 Relief Request Withdrawn 006rr 6-8 006 Rev. 8

, s.

l .

.V. EGP-1 BA-1 System / Component for Which Reliefidcqucated

. Reactor Pressure Ves:el (RPV) bottom head circumferential weld 11201-V6-001-WO7.

Code Requitement for Which Relle.f.isicquiaind ASME Section XI, Category B-A, Item No. Bl.21, as found in ASME Section XI Table IWB-2500-1, requires that a volumetric examination of the pressure-retaining circumferential welds in the RPV heads be performed. The applicable examination volume is shown in ASME Section XI, Figure IWB-2500-3, and includes one hundr- percent (100%) of the weld length. .

Basis for Relisf Twenty-nine peripheral RPV in-core flux instrumentation tubes adjacent to the RPV bottom head toms-to-bottom head dome weld restrict movement of the mechanized examination equipment sled /t:wducer along the entire length of weld 11201-V6-001-WO7. As a result, obtaining the required examination coverage in the vicinity of the instrumentation tubes is not possible when performing examinations from the inside diameter (ID) of the RPV. See Attachment I to this reliefrequest.

Ahcrnatt.Exaniination Because of the physical interferences presented by the instrumentation tubes in the proximity of the subject weld, the examination volume coverage is limited to approximately 29% of the weld length during inservice inspection. No supplemental examination is proposed. It should be noted however that an overall, general visual examination (VT-3) of the RPV was performed in accordance with the requirements of ASME Section XI, Category B-N-1, Item No. B13.10, during the maintenance / refueling outage in which weld 11201-V6-001-WO7 was volumetrically a -

- examined, i.e., during VEGP-1 Maintenance / Refueling Outage IR6.

Justification for the Granting of Relief Physical interferences presented by the twenty-nine RPV in-core flux instrumentation tubes in the vicinity of weld 11201-V6-001-WO7 prevent a full-Code examination, i.e., more than 90% of the required examination volume, as defined in ASME Section XI Code Case N-460. A significant

burden would be experienced if the required examination was attempted from the outside 006rr 6-9 006 Rev. 8

VEGP-1 E

RR-5 (continued)

Justification for the Grknting of Relief (continued) diameter (OD) of the RPV, particularly due to radiation dose and efforts to correlate the inner and outer diameter examination coverage plots. Examination from the OD would not result in a--

compensating increase in the level of safety. The volumetric examination of weld 11201-V6-001-WO7 from the ID of the RPV as performed, in conjunction with the overall, general visual examination, provides an acceptable level of quality and safety and is therefore justified per 10CFR50.55a(a)(3)(i).

Implementation Schedung This relief reguest is applicable to the First Ten-Year Interval on VEGP-1 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).

006rr 6-9a 006 Rev. 8 I,

.e,.'

i e

VEG P-1 1

BM  !

. (continued)

ATTACHMENT 1 Cross Sectional View Weld WO7 '

, -- n-4 4

R 88.16 TO CLAD

.22 NOM flVTERMOST PENETRAll0N 6 38 NOM - 60* SCAN

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- 45' SCAN

- 70* SCAN 3*I9 s s I - 0' SC

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i 006rr 6-9b 006 Rev. 8 -

1 RR-30 0i (continued)

Attachment i Minimum Item Percentage f ' Code Category hg. Description Examined Restncta Identification No.

l

• (REGENERATIVE HEAT EXCHANGER)

C1.30 Head to Tube Sheet Weld 94 % 94% Code exam done from 11208-E6-001-WOI C-A head side ofweld - weldolet Cl.30 Tube Sheet to Shell Weld 93 % 93% Code exam done from i1208-E6-001-WO2 C-A sheII side of utid -weldolet Cl.30 Tube Sheet to Shell Weld 93 % 93% Code exam done from 11208-E6-001-WO9 C-A sheII side ofutid- weldolet i

Cl.30 Tube SI.ect to Head Weld 94 % 94% Code exam done from 11708-E6-001-W10 C-A head side ofweld -weldolet l

• (EXCESS LEIDOWN HEAT EXCHANGER)

C-A Cl.20 Unit Flange to ChanncI Head Weld 45 % 45% Cu*.e exam done from 11208-E6-002-W01 channel head side ofweld -4 mstrumentation lines interfere.

l

• (LETDOWN lEAT EXCHANGER)

C-A Cl.20 Vessel Head to Head Flange 29 % 29% Code enun done from 11208-E6-003-WO3 head side - Flange bolting interferes.

l

• (LETDOWN REHEAT IEAT EXCHANGER)

C-A Cl.10 VesselFlange to Vessel Shell 84 % 84% Code exam done from 11208-E6-007-WO3 head side -welded identification plate.

6-55 006 Rev. 8 l

[

t -. .. ..

i

. a. .,

R5t-30 (costimmed)

Attachment 1 Mimmum

. Code item Percentage Identification No. Cateerv . No. Description Exanuned Restnctum ,

• (DISCHARGE PULSATION DAMPENER) l 11208-V4-002-W01 C-A Cl.20 Hemi-Head to Hemi-Head Weld 89 % Support intobu.cc l (BORON INJECTION TANK) 11204-V6-001-WOI C-B C2.21 Nozzle to Head Weld 50 % 100% Exam from 1. cad side-0%

from nozzle side i1204-V6-001-WO2 C-A . C1.20 Head to Shell Weld -38% 76*A exam from head side due te ,

supports -0% from shell side due ,

to taper i

. I1204-V6-001-WO3 C-A C1.20 Head to Shell Weld 50*4 100% exam from head side-0%

frc n shcIl side due to taper 11204-V64X)l-WO4 C-B C2.21 Nozzle to Head Weld 50 % 100% exam from head side -0%

from nozzle side 11204-V6-001-WOS C-C C3.10 Vessel Suppoit Pad 64 % Exam limited due to bracket Welded Attachment and support configuration. i

. (SAFETY !NJECTION PUMP) l1204-P6-003-WC2 C-G C6.10 Pump Casing to Snction Nnzzle Weld 66 % Pump supports prevent access to required area (CENTRIFUGAL CHARGING PUMP) a 11208-P6-002-WO3 C-C C3.30 Integrally Welded Pump Support Bracket 70 % Pump supports prennt access to required area 11208-P6-002-WO5 C-C C3.30 Integrally Welded Pamp Support Bracket 70 % Pump supports prennt access to required area

• Components exempt from examination per Request for Relief RR-62 approved in Raision 7 to ISI-P-006.

6-56 006 Rev. 8

j

's VEGP-1 RR-63 System /ComDonent fQr_Whi.cidelief.idtqusted Reactor Pressure Vessel (RPV) upper shell longitudinal welds 11201-V6-001-W12,11201-V6-001-W13, and 11201-V6-001-W14. ,

Code Requirement for Which Reliefjdcquc11td ASME.Section XI, Category B-A, item No. Bl.12, as found in ASME Section XI Table IWB-2500-1,- requires that a volumetric examination of the pressure-retaining longitudinal welds in the

RPV be performed. The applicable examination volume is shown in ASME Section XI, Figure IWB-2500-2, and includes one hundred percent (100%) of the weld length. In addition to the

- foregoing, reliefis requested from the regulatory requirements of 10CFR50.55a(g)(6)(ii)(A) which requires examination of more than 90% of the required examination volume of ASME Section XI Category B-A, item No. Bl.12 RPV welds. It should be noted that due to the version of ASME Section XI involved and the fact that VEGP-1 was in its first ten-year interval, the augmented examination requirements of 10CFR50.55a(g)(6)(ii)(A) had no significant impact on VEGP-1 since 100% of the RPV welds, including their entire length, were already required to be examined. Reliefis being requested from the Code and regula:ory requirements because the examination volume coverage did not exceed 90%. ,

BAsitfodelief Physical obstructions, e.g., surface scan interference due to nozzle center bore configuration, created by the RPV noz2.les in the proximity of the subject RPV upper shell longitudinal welds prevented 100% volumetric examination of their entire weld length. See Attachment I to this reliefrequest.

t Allemale Examination Because of the physical interferences presented by the RPV nozzles in the proximity of welds l 11201-V6-001-W12,11201-V6-001-W13, and 11201-V6-001-W14, the examination volume coverage is limited to approximately 75%,80%, and 85% of the weld length for welds 11201-V6-001-W12,11201-V6-001-W13, and i1201-V6-001-W14, respectively, during ir, service inspection. No supplemental examination is preposed. It should be noted however that an overall, general visual examination (VT-3) of the RPV was performed ir accordance with the requirements of ASME Section XI, Category B-'N-1, Item No. B13.10, during the maintenance / refueling outage in which the subject welds were volumetrically examined, i.e.,.

during VEGP-1 Maintenance / Refueling Outage IR6.

006rr 6-112 006 Rev. 8

• ~

l .,;

VEGP-1 RR-63 (continued) hstification for the Granting of Relief Physical interferences presented by the RPV nozzles in the proximity of RPV upper shell longitudir.al weld: 11201-V6-001-W12,11201-V6-001-W13, and 11201-V6-001-W14 prevent full-Code examination, i.e., more than 90% of the required examination volume, as defined in ASME Section XI Code Case N-460 and as required by 10 CFR 5's.55a(g)(6)(ii)(A). A significant burden would be experienced if the required examination was attempted from the outside diameter (OD) of the RPV particularly due to radiation dose and efforts to correlate the inner and outer diameter examination coverage plots. Examination from the OD would not result in a compensating increase in the level of safety. The volumetric examination of welds 11201-V6- .

001-W12,11201-V6-001-Wl3, and 11201-V6-001-W14 from the ID of the RPV as performed, in conjunction with the overall, general visual examination, provides an acceptable level of quality and safcty and is thereforejustified per 10CFR50.55a(a)(3)(i).

Imolementation Schedule This relief request is applicable to the First Ten-Year Interval on VEGP-1 which concluded May 30,1997, exclusive of the one year period allowed by ASME Section XI, IWA-2400(c).

006rr- 6-113 006 Rev. 8 j

l l

VEGP-1 RR-63 (continued)

NITACIIMENT 1 Plan View - RPV Unner Shell Lonnitudinal Welds W12. W13. and W14 OUTtti N-1 INtit h-2 INLLT N-3 Oultti N-4 Outttt N-5 14.[1 N-6 lit [1 N-7 DUTitt h-s PP 00* 6 7.00* 113 00* 15800* P02.00* P47 00* 29300* 33800*

O' 9,0

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[6 V[ 109 29' V B1 k-d L4 00* O tt00*

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• 1 0* 3 00*

ELD py y 12 01 tnn

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6e e Pfiis64* DQd e4r o 3er e O

j 4.,, 4, i:r o y,, ,,1, o o- 900- e7o 0-iso o-

/

006rr 6-114 006 Rev. 8

o, j 'f f .

USP-l RR-64 SysismLCommacnt.for WhichAelisfidequcitesl Each of the ASME Class 1,2, and 3 smallitems consisting of piping, valves, and fittings 1-inch and smaller nominal pipe size (NPS) subject to repair or replacement within the scope of the ISI Program.

Code Requirement for Which Reliefis Requested IWA-7400(d) of the 1983 Edition of ASME Section XI with Addenda through Summer 1983 exempts 1-inch NPS and smaller replacement items and their installation from the requirements of IWA-7000; whereas, the repairs ofitems 1-inch NPS and smaller are not similarly exempted from 16 requirements ofIWA-4000. Reliefis requested from the requirements ofIWA-4000 and IWA-7000 of the 1983 Edition with Addenda through Summer 1983 for piping, valves, ard fittings 1-inch NPS and smaller.

Ilniif9dcliff Arounu October 1996, an Authorized Nuclear Inspector (ANII) at VEGP identified a possible non-compliance with the requirements associated with recordkeeping for repairs of piping and components 1-inch NPS and smaller. Review of the VEGP Repair / Replacement Program during VEGP-2 Maintenance / Refueling Outage 2R5 in Fall 1996 confirmed the ANII's concern and revealed that repairs to piping and components 1-inch NPS and smaller were being treated similar to replacement of piping and components of that size, i.e., it was believed that repairs of piping and components 1-inch NPS and smaller were exempt, including the requirements assoc %ted with recordkeeping. As a result of this misunderstanding of the Code requiremeats for repairs, both VEGP units appear to have been in non-compliance with the repair requirements, including those associated with recordkeeping, e.g., use of ASME Form NIS-2 (Owner's Report for Re- airs and Rylacements), since the beginning of commercial operation through October 1996 .. .,; of discovery) for repairs of piping and components 1-inch NPS and smaller. The NRC was advised of this potential non-cc mpliance with the requirements of the ASME Section XI Code in Georgia Power Company (GPC) letter LCV-0932 dated January 8,1997. Complicating the issue was direction reportedly given by an ANII who preceded the ANII who identified the potential non-compliance. Reportedly, the previous ANIlindicated to plant personnel responsible for repair activities that he did not wish to witness and presumably otherwise verify repairs to piping and components 1-inch NPS and smaller. To the best of the knowledge and belief of GPC, the former licensee and operator of VEGP, and its sister company, Southern Nuclear Operatir g Company 006rr 6-115 006 Rev. 8 l

W ,

VEGP RR-64 (continued)

Basis for Relief (continued) i

~ (SNC), the current licensee and operator of VEGP, any such repairs performed to piping and '

components 1-inch NPS and smaller were technically sound and were performed in accordance J with approved procedures.

Because a significant effort would be required to review approximately fifty-two thousand l(52,000) Maintenance Work Orders (MWOs) generated for VEGP-1 for the period from May 31, 1987 (date of commercial operation) through October 1996 (time of discovery) for possible non-compliance with a recordkeeping requirement, it is our position that complying with the recordkeeping requirements, including use cf ASME Form NIS-2 for any such repairs of piping and components 1-inch NPS and smaller, wrid not provide a commensurate increase in the level of safety were the Code requirements for r dkeeping imposed. As a result, reliefis requested from the recordkeeping requirements for y <rs to piping and components 1-inch NPS and

-smaller.- Similar relief will be requested for VEGP-2 and will be submitted to the NRC for review

. and approval under separate cover as part of Revision 8 to VEGP-2 ISI Program document ISI-

P-014. Since the identification of this potential non-compliance, plard personnel responsible for .

repair activities have been instructed that repairs, irrespective of the $o e of piping and component involved, are to be properly documented. In addition, the ASME Section XI Repair / Replacement 1 Program was revised to require that repairs, irrespective of the size of the component involved, were to be properly documented. Further, in March 1997, a training course on ASME Section XI (with emphasis on repair and replacement requirements) was held and included personnel directly involved with repair and replacement activities at VEGP. To the best of our knowledge and belief, VEGP-1 has been in Code compliance with the repair requirements for piping and components 1-inch NPS and smaller since October 1996.

IWA-4130 in the 1995 Addenda to ASME Section XI allows application of alternative requirements for replacement to_g!(rc/xiir and replacement activities. The alternative requirements are specifically addressed in paragraphs IWA-4131 and IWA-4132 ofIWA-4130 and exclude Class 1,2, and 3 heat exchanger tubes, sleeves, and welded plugs for heat exchanger tubesc It is the ' position of SNC that steam generators would be similarly excluded since they are considered at VEGP_ to be heat exchangers. Had the requirements of this later addenda of the ASME Section XI Code been in effect for the period in question, the recordkeeping requirements l for piping and components 1-inch NPS and smaller would not have been required except for 006rr 6-116

• R ev. 8 a .

!oo l's o

VEGP-1

)

RR-64 (continued)

Dasis for Relief (continued) tubes, sleeves, and welded plugs for Class 1,2, and 3 heat exchangers and steam generators. As a result, it is our position that complia ice with the repair requirements of the 1983 Edition of ASME Section XI with Addenda through Summer 1983 for piping and components 1-inch NPS and smaller does not provide a commensu ate increase in the level of safety were these repair requirements to be imposed.

Akttnate Examination IWA-4130 of the 1995 Addenda to AShiE Section XI aliuxs the application of alternative requirements of replacement to.all repair and replacement activities. Although after the fact, it is believed that these have been met for VEGP-1 except possibly for piping and components 1-inch

~NPS and smaller, ash 1E Code Class 1,2, and 3 heat exchangers, and steam generators, e.g.,

steam generator level taps. Because of the numerous htWOs that would have to be reviewed for possible applicability, GPC and its successor, SNC, do not wish to backfit the recordkeeping 4 requirements of the 1983 Edition of AShiE Section XI with Addenda through Summer 1983 for any past instances involving repairs to piping and components 1-inch NPS and smaller, particularly in light of the equalization of repair and replacement requirements as found in the 1995 Addenda to the Code. ,

hutificali9Af0LLhtDrgrtting2f.Rglief The 1983 Edition of ash 1E Section XI Code with Addenda through Summer 1983 provides an exemption for replacement items 1-inch NPS and smaller from the requirements of IWA-7000, but repairs to such items are not similarly exempted. Therefore, a repair to an item is subject to more restrictive requirements than replacing them.

IWA-4130 in the 1995 Addenda to ASME Section XI allows application of alternative requirements for replacement to allrepair and replacement activities. The alternative requirements are specifically addressed in paragraphs IWA-4131 and IWA-4132 ofIWA-4130.

Heat exchanger tubing, sleeves, and welded plugs used for plugging heat exchanger tubes for Class 1,2, and 3 systems are excluded from the alternative requirements ofIWA-4130.

006rr 6-117 006 Rev. 8 1

. . _ _ _ _ _ - _ - _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ _ . - _a

po

't l.

vecc.1 RR-64 (continued) hulification for ths_ Granting of Relief (con. lings _d)

It is the position of SNC that steam generators at VEGP would be similarly excluded since they are considered to be heat exchangers.

Except for steam generator tube plugs which were welded in place at the time the VEGP steam generators were manufactured, there have been no steam generator tube plugs installed by welding. All steam generator tube plugs currently installed (except for those welded plugs installed by the steam generator manufacturer) are of the mechanical type. No steam generator -

tubes have been repaired using welding nor have any sleeves been installed using welding during plant operation for the period of time in question. While ASME Section XI provides guidance for repair activities with respect to the steam generators, plant Technical Specifications in effect c^

that time (i.e., pre-Improved Technical Specification 3/4.4.5) provided requirements which were required to be met, including those for tube inspection and tube plugging. However, during the perior' of time in question there may have been repairs matie to other piping 1-inch NPS and smaller associated with the steam generators, e.g. piping for level taps. Similarly, during the period in question, there may have been repairs conducted on piping and components 1-inch NPS and smaller in ASME Code Class I,2 and 3 heat exchangers.

In addition to the foregoing, corrective actions have occurred which will help prevent future problems in Code compliance with repairs to piping and components 1-inch NPS and smaller.

These include the following:

• Since identification of this potential non-compliance, plant personnel responsible for repair activities have been instructed that repairs, irrespective of the size of piping and components involved, are to be properly documented,

• The plant ASME Section XI Repair / Replacement Program was revised to address repairs to piping and components irrespective of the size involved, and

• A training session on ASME Section XI (with emphasis on repairs and replacements) was held. Participants included plant personnel directly responsible for repair / replacement activities and others, including, but not limited to, representatives from Quality Control, Quality Assurance, and other departments; as well as the carrent ANII.

006rr 6-118 006 Rev. 8 4 1

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VEGP-1 RR-64 (continued)

Justification for the Granting of Relief (continud -

To the best of our knowledge and belief, we have been in compliance with the Code requirements for repairs to piping and components 1-inch NPS and smaller since the potential non-compliance

- was identified and corrective actions implemented.

- Based on the foregoing information, in addition to the significant effort which would be required

to review the numerous MWOs generated for VEGP-_1 for the period from May 31,1987 (date of co.nmercial operation) through approximately October 1996 (time of discovery) for possible non-

! 5 compliance with a recordkeeping requirement, it is our position that imposing the recordkeeping requirements after the fact for any such repairs of piping and components 1-inch NPS and smaller would not provide a commensurate increase in the level of safety particularly in light of changes to the Code. ' A significant hardship.would result if the recordkeeping requirements were to be retroactively imposed. Accordingly,'it is requested that the proposed alternative be authorized pursuant to 10CFR50.55a(a)(3)(ii).

Implementation Schtduk This relief request is applicable to the First Ten-Year Interval on VEOP-1 which concluded May 30,1997, exclusive of the one year p< [3d allowed by ASME Section XI, IWA-2400(c).

006rr 6-119- 006 Rev. 8 k _ _