HL-5449, Requests Relief from Compliance w/10CFR50.55a Relative to Use of ASME Section XI

Requests Relief from Compliance w/10CFR50.55a Relative to Use of ASME Section XI

ML20217H816
Person / Time
Site:	Hatch
Issue date:	08/08/1997
From:	Sumner H SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-5449, TAC-M93918, TAC-M93919, NUDOCS 9708130252
Download: ML20217H816 (13)

Text

_. ._ .

Lewis Sumnst Southws Nul::t

%ce hesident operating Company. inc.

Hatch Project Support

' 40invemess Parkway Post Off(e Box 1?95 Dirmim/mm. Alabama 35?01 101205 T21219 iex 205932 0341 SOUTHERN A COMPANY Ewgy to Serve 1*our Werid*

Docket Nos. 50 321 IIL 5449 50 366 TAC Nos. M93918 M93919 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 l

Edwin I. llatch Nuclear Plant Containment _ltupection Rule. Ikgyestfor Relief l

l Gentlemen:

Southern Nuclear Operating Company (SNC) is currently in the process of developing a containment inspection program for Plant IIatch. In the course of this development, it has been determined that we should request relief from several requirements resulting from the Containment inspection Rule which will become effective for SNC on September 9,1997.

Pursuant to the provisions of 10CFR50.55a(a)(3)(i), SNC is hereby submitting the enclosed requests for relief from the requirements of 10CFR50.55a (61 Federal Register 41303). SNC requests that the NRC grant relief from compliance with the Rule relative to the use of ASME Section XI,1992 Edition with 1992 Addenda for Class MC components for Code activities other than examination requirements.

Relief Request RR MC-1 is the result of an extensive review of the requirements of ASME Section XI,1992 Edition with 1992 Addenda as compared to ASME Section XI, 1989 Edition with respect to Class MC components. It is our assessment that ASME

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47 Section XI, Subsection IWE,1992 Edition with 1992 Addenda may be implemented within the framework of the existing ASME Section XI,1989 Edition ISI Program while maintaining an acceptable level of quality and safety. By letter dated May 16,1997, the NRC approved a similar request for relief for a 1 year period ending September 9,1997 for repair and replacement activities.

In the process of preparing to implement the requirements of the Rule, it has become apparent that creating and maintaining two separate ASME Code version programs does not provide a compensating increase in the level of quality and safety for Class MC components. Two separate ASME Code programs increase the likelihood of error, hence could lead to a degradation of quality. The existing ASME Section XI,1989 Edition ISI Program has been found acceptable by the NRC (ref. SER dated 6/16/97, TAC M93918 lM" 188n ?J8888u P

Kl[I!!,lil]ill1:1 tl Hll PDR ,

U.S. Nuclear Regulatory Commission Page 2 August 8, 1997 and TAC h193919) for Class 1,2, and 3 components and is readily adaptable to Class htC for all requirements other than examination. The AShiE Section XI,1992 Edition with 1992 Addenda will be used to detemiine examination requirements applicable to Class hic components, but all general requirements and requirements associated with repair /

replacement activities will be implemented per the AShiR Section XI,1989 Edition.

Relief Request RR htC-2 requests relieffrom AShiE Section XI, Subsection IWE-5221

! and IWE 5240,1992 Edition with 1992 Addenda requirements for pressure testing of Class hic components. These two sections of the AShiE Code appear to reference inappropriate portions of 10CFR50 and other sections of the AShfE Code.

l The enclosed requests are the only ones we have identified which have immediate impact due to the requirement to implement repair / replacement activities on Class hic components in accordance with AShiE Section XI,1992 Edition with 1992 Addenda by September 9,1997. Your assistance in responding to these requests is appreciated.

Should you have any questions in this regard, please contact this oflice.

Sincerely, 9 SW

11. L. Sumner, Jr.

IFUeb Attachments:

1. Relief Request RR-htC-1

2. ReliefRequest RR-htC-2 cc: Southern Nuclear Operating Com;tmv hir. P. II. Wells, Nuclear Plant General hianager NOlGIS U.S. Nuclear Reentatory Commission. Washington. D.C.

hir. N. B. Le, Project hianager - liatch U.S. Nuclear Reentatory Commission. Begion H hir. L. A. Reyes, Regional Administrator hir. B. L.11olbrook, Senior Resident inspector - 11atch IIL 5449

Attachment 1 Edwin I IIntch Nuclear Plant Relief Request RR-MC-1 i

RELIEF REQUEST RR MC-1 I. System / Component (s) for Which Reliefis Requested; ASME Code Class MC Components II. Code Requirement By reference in the latest version (8/7/96) u 10CFR50.55a paragraph (b)(2), the ASME Section XI Code,1992 Edition with 1992 Addenda is applicable, subject to limitations listed g

in paragraph (b)(2)(vi) and modifications listed in paragraphs (b)(2)(ix) and (b)(2)(x) of ,

10CFR50.55a, for the examination, repair, and replacement of Class MC components.

/

Ill. Code Requirement from Which Reliefis Reqqm Reliefis requested from the requirements of all paragraphs referenced in Subsection IWE of the ASME Section XI Code,1992 Edition with 1992 Addenda which are not a part of Subsection IWE.

See Table 2 for a complete listing of the references in the ASME Section XI Code,1992 Edition with 1992 Addada Subsection IWE, to other paragraphs in the Code which are not part of Subsection IWE.

IV. Ilasis for Relief: '

The ASME Section XI ISI Program for Plant Hatch which has been approved by the NRC as applicable for all ASME Code Cir.ss 1,2, and 3 components meets the requirements of the ASME Section XI Code 1989 Edition.

The differences between the requiiements of applicable Section XI Subsections of the 1992 Edition with 1992 Addenda and the 1989 Edition for Class MC Components are relatively minor (See Table I for a summary of the Section XI Subsections for which the 1992 Edition with 1992 Addenda and 1989 Edition have different requirements). However, the creation and administrative maintenance of a program which implements all 1992 Edition with 1992 Addenda requirements for Code Class MC components in addition to the existing program for Class 1,2, and 3 components (which meets the requirements of the 1989 Edition of Section XI) poses a substantial long term burden to the licensee without a compensating increase in the level of quality and safety. By implementing the proposed alternatives listed below, substantial savings in administrative costs and lessened probability of error can be realized by SNC. The intent of this reliet e previously granted for repair and replacement activities for a one year period endiag September 9,1997 (Berkow to Sumner, May 16, 1997).

RELIEF REQUEST l RR-MC-1 (Cont.)

)

f Additionally, ash 1F, Dection XI 1992 Edition with 1992 Addenda paragraph IWA-4170(a) requires that; 'The Edition and Addenda of Section XI used for the repair / replacement program shall correspond with the Edition and Addenda identified in the inservice inspection

program applicable to the inspection interval." The 1989 Edition of AShiE XI contains this same requirement in paragraph IWA-4120(b). Therefore, the program for control of repair and replacement of Code components at Plant Hatch was developed to comply with the requirements of the 1989 Edition of AShiE XI which is the Code of Record for the 3rd ISI interval.

V. Alternate Examinations:

SNC proposes that, in lieu of the 1992 Edition with 1992 Addenda requirements of all AShiE Section XI Subsections other than Subsection IWE, that the AShfE Section XI 1989 Edition requirements of the same or corresponding Subsections (and commensurate commitments a...

relief requests) be utilized with the exception ofIWA-4700 of the 1989 Edition which does not give guidance for Class hic pressure testing.

Alternatives, restrictions, cr enhancements stipulated by 10CFId0.55a to Section XI 1992 Edition with 1992 Addenda Subsections with regard to Class htC Components will be applicable to the same 1989 Edition Subsections or comparable 1989 Edition Subsections (and commensurate commitments and relief requests).

VI. Justification for the Granting of Relief; The current ISI Code of Record, AShT Section XI 1989 Edition, contains adequate general and repair / replacement requirements for assuring the structural integrity of Class h1C components. The enclosed Table I provides a comparison of the major differences between the 1992 with 1992 Addenda and the 1989 Edition of AShfE Section XI. Review ofTable 1 does not indicate any significant safety enhancements that have been incorporated into the later Code.

Use of the 1992 Edition with 1992 Addenda AShiE XI Code entirely for IWE requirements would require the Licensee to develop and maintain a separate program for general and repair / replacement requirements for Class h. : components than is utilized for AShiE Class 1, 2 and 3 components. This would impose an additional administrative burden with no identifiable benefit from a safety perspective. The use of Subsection IWE only from the 1992 i Edition with 1992 Addenda AShfE XI Code in conjunction with the administrative and general requirements of the 1989 Code provides adequate assurance for the integrity of Class MC components at Plant Hatch and provides for consistency in the implementation of these requirements for all ISI components Since the current ISI Program has been determined to be acceptable for the 3rd ISI Interval at Plant Hatch, then the application of the general and repair / replacement requirements of the 1989 ASME XI Code for Class htC components does not endanger life or property or the common defense and security and is otherwise in the public interest when considering the burden upon the licensee that could result if the requirements were imposed on the facility.

.__ . , RELIEF REQUEST RR-MC-1 (Cont.)

i VII. Imolementation Schedule -

The subject alternatives will be implemented in accordance with the expedited examination schedule for Class MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI Interval.

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s, n

l 4

Table 1 (Sheet 1 of 3) 1989 Edition IWA vs.1992 Edition with 1992 Addenda IWA Significant Differences Regarding Class h1C Subsection Content Discussion -

IWA-1400(p) 92/92A Defines an owners responsibility Does not exist in 89E, but is considered to record regions where flaws included in the requirements ofIWA-exceeding the acceptance criteria 6000 89E and IWE-3112(b) 92/92A.

have been evaluated by analysis to allow continued operation.

Table IWA-1600-1 Referenced Standards and Specs. 92/92A references a newer date for some standards and includes some additional standards inconsequential to Class hic components. Only significant difference is ASNT SNT-TC-1 A is replaced with ANSI /ASNT CP-189 for personnelqualifications. SeeIWA-2300 discussion.

IWA-2200(b) 92/92A Nonmandatory Appendix D may Appendix D applies only to Class 1 and be used for surface preparation for 2 weld surface exams.

NDE.

IWA-2216 39E Cleaning This paragraph regarding cleaning standards for visual exams does not exist in 92/92A. 92/92A gives no additional guidance for cleaning for visual exams.

IWA-2210 Visual Examinations 92/92A references Article 9 of Section V with supplemental requirements for procedure demonstration and alternatives to distance and illumination requirements. The differenc:s are inconsequential for Class hic components as evidenced by 10CFR50.55a(b)(2)(x)(B) which allows the requirements of Table IWA-2210-1 92/92A to be relaxed.

IWA-2300 Qualifications of NDE Personnel 92/92A references ANSI /ASNT CP-139 while 89E references SNT-TC-1 A for qualification and certification. The differences are inconsequential for Class hic components as evidenced by IWA-2310 92/92A which states that

" Certifications based on SNT-TC-1 A are valid until recertification is required"

Table 1 (Sheet 2 of 3)

Subsection Content Discussion IWA-4000 92/92A Repair and Replacement IWA-7000 89E requirements for Procedures were combined and replacement are essentially retained in I WA-7000 92/92A has been IWA-4000 92/92A.

deleted.

IWA-4120 92/92A Alternative Requirements for These alternative requirements are not Replacement of Small items contained in IWA-4000 89E or IWA-7000 89E, however, they are not applicable to Class hic components.

lWA-4110 92/92A Repair and Replacement Program Combines the requirements ofIWA-IWA-4130 92/92A and Plan, Scope, Responsibilities, 4100 89E and IWA-7200 89E. The "

IWA-4140 92/92A and Code Applicability. 92/92A definition of a Program is IWA-4150 92/92A essentially the same as 89E definition of IWA-4160 92/92A a Plan.

lWA-4170 92/92A IWA-4180 92/92A Material shall conform to the Additional guidance which is not requirements of the original generally applicable to Class MC l

Design Specification or Section components is provided for materials III. and repair of materials.

IWA-4220 92/92A Welding and Welder Qualification Requirements are the same as IWA-4400 89E for repairs and meet IWA-7320 89E for replacements IWA-4400 92/92A Repair of Heat Exchanger Tubing Not contained in 89E and not applicable to Class MC components.

IWA-4500 92/92A Alternative Repair Welding Comparable requirements are contained Methods in 89E.

IWA-4500(b) 92/92A For the repair of base materials IWA-4120(a)(4) 89E references IWE-and welds used for Class MC 4000 89E for alternative requirements components, the requirements of for Class MC components. IWE-4000 IWA-4540 92/02A may be used 89Eis identical to IWA-4540 92/92A (Temperbead without Post Weld and would be the appropriate reference, Heat Treat). ifrequired.

IWA-4510 Repair Welding by Half Bead IWA-4540 92/92A and IWE-4000 89E Welding Technique without Post both reference IWA-4510 as an Weld Heat Treat. alternative. IWA-4510 92/92A is more restrictive than IWA-4510 89E.

However, IWA-4510 89Eis endorsed by 10CFR50.55a for repairs of Class 1,2, and 3 components. Furthermore, Post Weld Heat Treat was not required in the original construction for Class MC components at Plant Hatch.

Table 1 (Sheet 3 of 3)

Subsection - Content Discussion :-

IWA-4600 92N2A Installation of Replacements Same requirements for welding as IWA-7510 89E. Includes additional requirements for mechanicaljoints on Class 1 pping systems.

IWA-4720 92N2A Pressure Tests 92N2A provides for pressure testing of Class MC components in accordance with IWE-5000 92N2A following repair or replacement. 89E does not.

92/92A will be applied for pressure testing.

IWA-5000 System Pressure Tests IWE-5210 92N2A and IWE 5240 92N2A state that the requirements of i

IWA-5000 are not applicable to Class MC components except forIWA-5246 92N2A.

IWA-5246 92N2A Does Not Exist. 92N2A does not contain this paragraph.

The reference in IWE-5240 92N2A to IWA-5246 92N2A must be an error in the Code.

IWA-6000 Records and Reports IWE-3112 92N2A and IWE-3122.1 92N2A reference IWA-6220 92N2A which contains requirements for preparation of abstract of examination required by Form NIS-1. This does not exist in IWA-6000 89E. RR-14 of the -

Third IntervalISI Program uses Code Case N532 to define reports alternative to NIS-I and NIS-2.

1 Table 2 I Proposed Alternate Reference COLUMN 1 COLUMN 2 IWE 92/92A (1) COLUMN 3 92/W A Reference (2) Proposed 89E Reference (3)

P E-3112(a)

IWA-1400(h)

JVE-3122.1 IWA-1400(h)

IWA-1400(h)

IWE-3111 IWA-1400(h)

IWA-2200 IWE 3114 IWA-2200 IWA-2200 lWE-3124 IWA-2200 IWA-2200 IWE-2500(a) IWA-2200 IWA-2240

_ lWE-3200 I_WA-2240 IWA-2240 IWE-2411(b) IWA-2240 IWA-2430(c)

IWE-2412(b) IWA-2430(c)

IWA-2430(d)

IWE-2200(e) IWA-2430(d)

IWA-4000 IWA-4000 (repair) IWA-7000 IWE-3114 (replace)

IWA-4000 IWA-4000 (repair) IWA-7000 IWE-3124 (replace)

IWA-4000 IWA-4000 (repair)lWA-7000 IWE-4100 (replace)

IWA-4000 l IWE-7100 IWA-4000 I IWA-4000 lWA-7000

!WE-5210 IWA-5000 IWE-5240 IWA-5000 IWA-5246 IWA-5246 IWE-2200(c)(2) IWA-6000 IWE-2200(f)(3) IWA-6000 IWA-6000 IWE-3112(a) IWA-6000 IWA-6220 IWE-3122.1 IWA-6000 IWA-6220 IWE-2200(e) IWA-6000 IWB-2000 IWE-2200(e) IWB-2000 IWC-2000 ME 2200(e) IWC-2000 IWD-200 IWE-2500-1, Cat. E-A, IWD-2000 Section III, NE-4435 Note 5 0 Section III, NE-4435 IWE-2200(c) e Section III, NE-5000 Section III, NE-5000 IWE-2500(c)(2)

• Section V, T-544 Section V, T-544 (1)

Paragraphs in the 92/92A ASME XI Code Subsection IWE which reference other paragraphs in other Subsections of the Code.

(2) Paragraphs referenced by those listed in Column 1.

(3)

Proposed Column 2. paragraph in 1989 Edition of ASME XI Code to be used in lieu of those lis The references of these subsections to Section 111 and Section V completeness. Neither the CFR nor the ASME Code clearly address which Edition and Addenda are to be used.

Attachment 2 i Edwin I. IIntch Nuclear Plant Relief Request RR-MC-2 1

I

RELIEF REQUEST RR-MC-2 I. System / Component (s) for Which Reliefis Requested; AShiE Code Class hic Components II. Code Requirement:

AShiE Section XI,1992 Edition with 1992 Addenda paragraphs IWE-5221 and IWE-5240 for Pressure Testing and Visual Examination during Pressure Testing.

III. Code Requirement for Which Reliefis Requested.

1. IWE-5221 requires that pressure tests be conducted on Class hic components following repair or replacement in accordance with 10CFR50 Appendix J, Paragraph IV.A.

2. IWE-5240 references IWA-5246 for visual examinations conducted in conjunction with pressure testing.

IV. Basis for Relief

1. 10CFR50 Appendix J paragraph IV.A is contained in Option A of Appendix J only. The NRC revised 10CFR50, effective October 26,1995, and approved Option B of Appendix J which is a performance based leakrate testing program. The NRC issued Regulatory Guide 1.163 which endorsed the Nuclear Energy Institute (NEI) Guideline NEI 94-01 for the implementation of Appendix J Option B. NEI 94-01 paragraph 9.2.4 contains guidelines for leakrate testing after containment repairs and modifications. Plant Hatch amended its Technical Specifications and adopted Appendix J, Option B, in 1995.

Therefore, the guidance contained in NEI 94-01 is applicable for leakrate testing after containment repairs and modifications.

2. AShfE Section XI,1992 Edition with 1992 Addenda does not contain a paragraph IWA-5246. Therefore, SNC assumes this to be a typographical error and provides a basis for not applying paragraph IWA-5240. IWA-5240 is applicable to ASME Section XI system leakage tests per Tables IWB/IWC/IWD-2500-1 where visual examination, VT-2, identifies the source of fluid leakage. However, leakrate testing per Appendix J requires precise measurement of the leakrate from each test boundary and visual examination, VT-2, for leakage is not appropriate. Table IWE-2500-1, Examination Category E-P, references 10CFR50 Appendix J for the Examination Method for pressure testing, not IWA-5240 as does the IWB, IWC and IWD-2500-1 Tables. 10CFR50 Appendix J leakrate testing does not require visual examination for leakage during the performance of leakrate testing. The reference to IWA-5246 in IWE-5240 appears to be inappropriate

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o

,, RELIEF REQUEST R.R-MC-2 (Cont.)

L and inconsistent with the examination method referenced in Table IWE-2500-1, Examination Category E-P since visual examination is not appropriate for leakrate testing

- where instrumentation provides measurement of the leakrate.

V. - Alternate Examinations

1. Pressure testing of Class MC components will be performed per the guidance provided in NEI 94-01, paragraph 9.2.4,'for any containment repairs or modifications at Plant Hatch.

All such pressure testing will be performed in accordana with 10CFR50 Appendix J.

2. Pressure testing of Class MC components will be performed in accordance with 10CFR50 Appendix J, which does not include visual examination requirements.

VI. Justifcation for the Granting of Relief 10CFR50 Appendix J, Option B, had not been approved for use when the 1992 with 1992 Addenda ASME XI Code was issued. However, the NRC endorsed the use of Appendix J, Option B and the guidance in NEI 94-01 via Regulatory Guide 1.163. NEI 94-01 includes requirements for leakrate testing of containment repairs and replacements to assure the leakrate integrity of containment structures and penetrations. Therefore, the Commission has previously determined that the use of 10CFR50 Appendix J, Option B, with the guidance of.

NEI 94-01, provides adequate assurance for leakrate integrity of containment components and does not endanger life or property or the common defense and security and is otherwise in the public interest.

The Licensee has amended its Technical Specifications and developed administrative and implementation procedures to apply leakrate testing in accordance with Appendix J,  !

Option B. This application agrees with the latest approved regulatory positions relative to containment leakrate testing and thus should take precedence over the requirements of a previously issued version of the ASME XI Code.

VII. Imolementation Schedule The subject alternatives will be implemented in accordance with the expedited examination schedule for Class MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI Interval.

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