ML20153B035

Forwards Request for Addl Info Re Second 10-yr Inservice Insp Program.Response Requested within 60 Days of Ltr Receipt

ML20153B035
Person / Time
Site:	Hatch
Issue date:	07/07/1988
From:	Crocker L Office of Nuclear Reactor Regulation
To:	Hairston W GEORGIA POWER CO.
References
TAC-66527, TAC-66528, NUDOCS 8807120692
Download: ML20153B035 (9)

Text

.. . .

July 7, 1988 Docket H6s: 50-321/366 DLSTRLBUTION:

Mr. W. G. Hairston, III f aetoune- L. Crocker -

Local PDR E Jordan Senior Vice President - NRC PDR . .

B. Grimes Nuclear Operations PDII-3 Reading 'ACRS (10)

Georgia Power Company - Hatch Reading C. Y.-Cheng (9H-15)

P. O. Box 4545 S Varga -F. Litton (9H-15) ntlanta, Georgia 30302 G. Lainas D. itatthews

Dear Mr. Hairston:

M. Rood

SUBJECT:

SECOND 10-YEAR INSERVICE INSPECTION PROGRNi - HATCH UNITS 1 AND 2 (TACS66527/66528)

By letter dated September 29, 1986 we informed GPC that the staff had completed its review of the Inservice Inspection portion of the Inservice Inspection / Inservice Testing (ISI/IST) program for the second 10-year interval for the Hatch nuclear plant. We advised you that the ISI portion of the program was acceptable for implementation, although review of the IST portion j was continuing.

On September 11, 1987, you submitted a revision to the ISI/IST program. A further revision was submitted on February 24, 1988. The February 24 submittal incorporated information contained in your February 7.1986 response to our December 23, 1985 request for additional information, conclusions from the Safety Evaluation Report accompanying our September 29, 1986 letter, and new or revised requests for relief from code requirements.

Review of the February 24, 1988 submittal has revealed a number of further 1

questions regarding the ISI program. These questions are provided in the  ;

enclosed Request for Additional Information (RAI). It is requested that you '

provide a response to the RAI within 60 days following receipt of this letter j in order that we can continue the review, 1

The reporting and/or recordkeeping requirements contained in this letter affect l fewer than ten respondents; therefore. OMB clearance is not required under P.L. j 96-511.

Please contact me if you have any questions.

Sincerely, )

8807120692 080707 Original signed by:

PDR ADOCK 05000321 f PNU Lawrence P. Crocker, Project flanager Project Directorate 11-3 Division of Reactor Projects-!/II  !

I

Enclosure:

RAI cc: See next pag l PM:PDI! 3 0.PDII-3 LAPDjI-3 HRh6'd 7 / 7 /88 LCrocker:pw 9 /<f/88 Driatthews g/g/88 gd j I

s July 7, 1988 Docket tros: 5'0-321/366 DISTRIBUTION:

Docket File L. Crocker Mr. W. G. Hairston, III Local PDR E. Jordan l Senior Vice President - NPC PDR B. Grimes l Nuclear Operations PDII-3 Reading ACRS (10)

Georgia Power Company Hatch Reading C. Y. Cheng (9H-15)

P. O. Box 4545 S. Varga F. Litton (9H-15)

Atlanta, Georgia 30302 G. Lainas D. Platthews

Dear Mr. Hairston:

M. Rood

SUBJECT:

SECOND 10-YEAR INSERVICE INSPECTION PROGRAli - HATCH UNITS 1 AND 2 (TACS 66527/66528)

By letter dated September 29, 1986 we informed GPC that the staff huo completed its review of the Inservice Inspection portion of the Inservice l l

Inspection / Inservice Testing (ISI/IST) program for the second 10-year interval for the Hatch nuclear plant. We advised you that the ISI portion of the program was acceptable for implementation, although review of the IST portion was continuing.

On September 11, 1987, you submitted a revision to the ISI/IST program. A further rc"ision was submitted on February 24, 1988. The February 24 submittal incorporated information contained in your February 7,1986 response to our December 23, 1985 request for additional information, conclusions from the Safety Evaluation Report accompanying our September 29, 1986 letter, and new or revised requests for relief from code requirements.

Review of the February 24, 1988 submittal has revealed a number of further questions regarding the ISI program. These questions are provided in the enclosed Request for Additional Information (RAI). It is requested that you provide a response to the RAI within 60 days following receipt of this letter in order that we can continue the review.

The reporting and/or recardkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Please contact me if you have any questions.

Sincerely, Original signed by:

Lawrence P. Crocker, Project Manager Project Directorate 11-3 Division of Reactor Projects-I/II

Enclosure:

RAI ,

cc: See next page LA:0NI-3 PM:PDII 3 D.PDII-3 M'Rd6'd ' LCrocker:pw DMatthews

'// 7/88 7/ 7/88 y1/88

l Mr. W. G. Hairston, III Edwin I. Hatch Nuclear Plant, i Georgia Power Company Units Nos. 1-and 2 l l

cc:

G. F. Trowbridge, Esq. Mr. R. P. Mcdonald Shaw, Pittman, Potts and Trowbridge Executive Vice President -  !

2300 N Street, H. W. Nuclear Operations Washington, D.C. 20037 Georgia Power Company P.O. Box 4545 Mr. L. T. Gucwa Atlanta, Georgia 30302 Engineering Department Georgia Power Company l P. 0. Box 4545  ;

Atlanta, Georgia 30302 '

Nuclear Safety and Compliance Manager ,

Edwin I. Hatch Nuclear Plant Georgia Power Company P. O. Box 442 Baxley, Georgia 31513 1

Mr. Louis B. Long Southern Company Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 Resident Inspector U.S. Nuclear Regulatory Commission Route 1, Box 725 Baxley, Georgia 31513 Regional Administrator, Regica II U.S. Nuclear Regulatory Commission an a e r ga 303

{

Mr. Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, S.W.

Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Commissioner Department of Natural Resources 270 Washington Street, N.W.

Atlanta, Georgia 30334 ,

Chairman Appling County Commissioners County Courthouse Baxley, Georgia 31513 4

ENCLOSURE GEORGIA POWER COMPANY EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2, ,

DOCKET NUMBERS 50-321 AND 50-366 l l

MATERIALS ENGINEERING BRANCH DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY Reouest for Additional Information - Second 10-Year Interval Inservice Inspection Proaram Plan

1. Scoce/ Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which  ;

I are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Clas; 1, Class 2, and Class 3 meet the .

requirements, except 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 or construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection l intervals shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein. Based on the start date of January 1,1986, for the second 10-year interval, the Inservice Inspection (ISI) Program Plan has been prepared to meet the requirements of the 1980 Edition, Winter 1981 L Addenda (80W81) of the ASME Code Section XI except that the extent of examination for Code Class 2 piping welds in Residual Heat Removal (RHR)

Systems, Emergency Core Cooling (ECC) Systems, and Containment Heat Removal (CHR) Systems has been determined by the 1974 Edition through Sumer 1975 Addenda (74S75).

1

As required by 10 CFR 50.55a(g)(5), if the Licensee determines that certain Code examination requirements are impractical and relief is requested, the Licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination.

The staff has reviewed the available information in the Edwin I. Hatch Nuclear Plant, Units 1 and 2, Second 10-Year Interval ISI Program, Revision 2, as submitted February 24, 1988. This revision incorporated the Licensee's February 7, 1986, response to the NRC request for additional information, dated December 23, 1985, and conclusions of the September 29, 1986, Safety Evaluation Report (SER). This document also includes new and revised requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.

2. Additional Information/ Clarification Repuired Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program Plan:

A. Provide isometric drawings showing the welds, components, and supports which the ASME Code requires to be examined during the second 10-year interval.

B. Provide an itemized listing of the components subject to examination during the second 10-year interval. The requested listing, along with the isometric drawings, will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.

C. Provide a list of the nondestructive examination procedures that are to be used during the second inspection interval.

2 1

F D. Section 1.4 of the ISI Program states, in part: "

... the i classification of components as ASME Class 1, 2, or 3 '

equivalent for this Program does not imply that the components were designed in accordance with ASME requirements."

Section 1.9 states: "The acceptance standards for Class 1, 2, and 3 components will be either Article IW8-3000 or the Section III construction code for the plant, as applicable.

....The acceptance standards for Class 1, 2, and 3 component supports will be either IWF-3000 or the Section III construction Code for the plant, as applicable".

Provide clarification on the above statements, asSection XI ISI examinations should be evaluated to Articles IW8-3000, Acceptance Standards for Flaw Indications, and IWF-3000, Standards for Examination Evaluations. -

E. Augmented examinations have been established by the NRC when added assurance of structural reliability is deemed necessary. Examples of documents which may require augmented examination are- 0 1

(1) High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, Branch Technical Position ASB 3-1; (2) Regulatory Guide 1.150, Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations; (3) NUREG-0619, BWR Feedwater Nozzle and CRD Return Line Nozzle Cracking; l

(4) NUREG-0803, Integrity of BWR Scram System Piping; and (5) Generic letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping (ref NUREG-0313).

Address the degree of compliance with each of the above and discuss any other augmented examination (s) which are being incorporated in the Edwin I. Hatch Nuclear Plant, Units 1 and 2, Second 10-Year Interval ISI Program.

F. Section 3.0 of the ISI Program states that, based on the 74S75 Code Section XI, the pressure / temperature exemption will not be used for welds in the RHR, Core Spray (CS), and High Pressure Coolant 3

1

. Injection (HPCI) Systems. The control of water chemistry to  ;

minimize stress corrosion is not an acceptable basis for exempting i components from examination because practical evaluation, review, l and acceptance standards cannot be defined. Verify that the chemistry control exclusion of 74S75 paragraph IWC-1220(c) will not l

be used.

G. Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the RHR, ECC, and CHR systems be examined; these systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220. Later editions and addenda of the Code require volumetric examination of Class 2 welds in piping with greater than or equal to' 3/8-inch nominal wall thickness and greater than 4-inch nominal pipe size (NPS). The staff has previously determined that a 7.5%

augmented volumetric sample constitutes an acceptable resolution at similar plants. Verify that volumetric examination will be performed on at least a 7.5% sample of the Class 2 piping welds in I these systems.

H. Relief Request 2.1.1 includes discussion of performing the Code-required volumetric examination on Reactor Pressure Vessel closure head welds (Examination Category B-A, Items 81.21 and Bl.22) as well as beltline region welds (Items B1.11 and B1.12). Specific relief is being requested for the beltline region welde however, in I toe justification for the closure head welds it is indicated that relief from the Code-required volumetric examination may not be required and it is stated that: "If it is found during examinations that 100% coverage cannot be obtained, specific relief will be requested at that time".

Based on the above, the Licensee should delete reference to the Reactor Pressure Vessel closure head welds (Items 81.21 and 81.22) in Relief Request 2.1.1 as relief is not being requested for these welds at this time.

4

}

. 1 I. Relief Request 3.1.2 requests relief from performing the Code-required surface examination of the welded attachments on RHR, CS, HPSI, and RCIC suction lines to the torus. As an alternative, the Licensee proposes performing a visual examination (VT-1) of the subject welds at Unit 2 and performing a best effort magnetic particle (MT) examination of the subject welds at Unit 1.

The SER, dated September 29, 1986, granted relief for two of the l welds (lE51 and IE41) at Unit 1 based on a significant percentage ,

(80-100%) of the weld surface receiving a Code-required surface )

examination (MT). For the remaining welds at Unit I and all of the subject welds at Unit 2, relief was denied based on the fact that  ;

the paint on these welds precludes not only dye penetrant surface l 1

examination, but also visual examination. Also, the Licensee had I not given sufficient justification (man-hours and radiation exposure) that removal of the paint and performance of a dye penetrant examination is impractical.

Relief Request 3.1.2, as submitted February 24, 1988, does not appear to contain any information different from that evaluated in the SER, dated September 29, 1986. Therefore, provide further technical justifications as to why relief should be granted for those welds for which relief was previously denied in the ,

September 29, 1986 SER. l l

J. General Relief Request 8.1.1 requests relief from the requirements of Section XI, Appendix III, which delineates the requirements for design and fabrication of basic calibration blocks used for ultrasonic examination of Class 1 and 2 piping systems. The Licensee's justification for relief states, in part:

"Correlation of ultrasonic data with previous examinations as required by Subarticle IWA-1400 of Section XI makes it necessary that these basic calibration blocks be used so future examination results can be correlated with past results."

Discuss the impact of obtaining appropriate calibration blocks made 5

from material of the same nominal diameter, nominal wall thickness or pipe schedule, and material specifications as the pipe to be l examined. Also discuss why the Code-required calibration blocks j could not .% used in conjunction with the ones used during previous examinations to provide correlations with the previous examination data.

1 K. Provide a list of the ultrasonic calibration standards being used during the second 10-year intervals at Hatch, Units 1 and 2. This list should include the calibration standard identifications, material specifications, and sizes.

The schedule for timely completion of this review requires that the Licensee provide, by the requested date, the above requested informttion and/or clarifications with regard to the Edwin I. Hatch, Units 1 and 2, '

Second 10-Year Interval ISI Program.

6

- - , . . _ _ _ __