HL-5539, Forwards Rev 2 to Relief Request RR-14 as Result of Containment Insp Rule,Which Became Effective on 960909.Util Would Like to Utilize Relief Requested in RR-14,Rev 2 for IWE Repair & Replacement Activities

Forwards Rev 2 to Relief Request RR-14 as Result of Containment Insp Rule,Which Became Effective on 960909.Util Would Like to Utilize Relief Requested in RR-14,Rev 2 for IWE Repair & Replacement Activities

ML20197A692
Person / Time
Site:	Hatch
Issue date:	12/15/1997
From:	Sumner H SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-5539, NUDOCS 9712230134
Download: ML20197A692 (5)

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- Herxh Prr,ia-t Support 40 Imamor.s Padway Post OMce Box 1295 Dimegham, Nabama 35201 Tot 205L27279 f 6x 2059920341 SOUTHERN L COMPANY Energ *SmvhurWorld" December 15, 1997 Docket Nos. 50 321 HL-5539 50 366 U.S; Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin I, Hatch Nuclear Plant Third 10-Yea; Interval Inservice inspection Program Bevised ReliefRequest Gentlemen:

By letter dated April 5,1996, Georgia Power Company (GPC) submitted Third 10-Year Interval Inservice Inspection Program Relief Request RR-14, Revision 0 for NRC staff review Revision 0 applied to ASME Class 1,2, and 3 pret.sure-retaining components and their supports. By letter dated June 16,1997, NRC granted the reliefrequested in RR-14.

Subsequent to submitting RR 14, the Operating License for Plant Hatch was transferrM from GPC to Southern Nuclear Operating Company (SNC), RR-14, Revision I was issued to reflect this change and to update the status of the relief request. These were considered to be administrative changes and were not submitted for NRC review.

The Containment Inspection Rule, which became effective on September 9,1996, requires that ASME Class MC components comply with the requirements of ASME Section XI, Subsection IWE for inspection and repair and replacement (R&R). As a result, the attached revision of RR-14 (Revision 2) has been written to include Class MC components and is hereby submitted for NRC review, SNC would like to utilize the relief requested in RR-14, Rey, 2 for IWE repair and replacement activities performed during the IR17 outage,just completed. Therefore, expedited review by NRC staffis requested.

If you have any questions on this subject, please contact this office Sincerely, f,l lI lll.lll ll ll M

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Y PDR ADOCK 05000321 H. L. Sumner, Jr.

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December-15. - 1997-L

Attachment:

Relief Request No RR-14, Revision 2 -

cc:. Southern Nuclear Operally Company Mr. P. H. Wells, Nuclear Plant General Manager NORMS 4

LLS. NuclearBerulatorv Commission. Washington. D.C.

Mr. L. N. Olshan, Project Manager - Hatch LLS Nuclear Rerulatorv Commission. Region H Mr. L. A. Reyes, Regional Administrator Mr. B. L. Holbrook, Senior Resident Inspector - Hatch 4

4 HL-5539

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4 Attachment Relief Request No. RR-14 Revision 2

Southern Nuclear Operating Company Edwin I. Hatch Nuclear Plant Third 10-Year Interval Inservice Inspection Program BrQuest for Relief No. RR-14 I.

Sulsect for Which Rcliefis Requested: Administrative change to the documentation and reporting requirements oflWA 6000 for Class 1,2, and 3 pressure-retaining components and their supports and for Class MC pressure retaining components and their integral attachments.

11.

Code Requirement:

IWA-6000 requires the preparation and submittal of insenice inspection summary reports within 90 days of the completion of the inservice inspection conducted during each refueling outage. Form NIS 1, " Owner's Report for Insenice Inspection," and Form NIS-2, " Owner's Report for Repairs or Replacements," are integral ponions of the summary reports.

III.

Code Rtquiremsnt for Which Reliefis Requcited: Relief from preparing the NIS-1 and NIS 2 forms and submitting the inservice inspection summary report within the 90-day time limit is requested.

IV.

Basis for Relief: ASME Code Case N-532, " Alternate Requirements to Repair and Replacement Documentation Requirements and Inseaice Inspection Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,' provides an alternative to the repair and replacement documentation and regulatory reporting requirements. Southern Nuclear Operating Company (SNC) reviewed Code Case N-532 and determined its implementation will substantially reduce the administrative burden required by IWA-6000. Since Code Case N 532 will not be included in Revision 12 of Regulatory Guide 1.147, relief from the requirements ofIWA-6000 is necessary.

V.

Alternate to the Code Requirements: SNC will comply with the requirements of Code Case N-532, with the following clarification regarding reporting of corrective measures.

Code Case N-532, paragraph 2.0(c), requires an abstract for repairs, replacements, and corrective measures required due to an item contr.ining a flaw or relevant condition exceeding the acceptance criteria of ASME Code Section XI. According to Section XI, the term " corrective measures" has two applications. One application involves repair and replacement activities on pressure-retaining components (e.g., metal removal and welding). The other application involves maintenance-type activities, such as tightening of bolting, replacing gaskets / packing, cleaning surface corrosion products, and adjusting coraponent supports.

For Code Case N-532 reporting, SNC considers " corrective measures" to involve only repair and replacement activities.

VI.

Jus;ification for the_Dranting of Relief: Previously, SNC submitted voluminous NIS-1 Owner's Data Reports fer Inservice Inspections. The process of preparing, reviewing, and submitting the reports within the 90-day time requirement often resulted in difficulties for the SNC staff. With the update to the 1989 Edition to the Code for Class 1,2 and 3 components and the requirement to implement Subsection IWE for Class MC

components, the NIS-2 Owner's Reports for Repairs and Replacements are required, thereby, significantly increasing the administrative burden. Implementation of the Code Case N-532 allows the submittal of abstracts versus the reports required by the ASME Code Section XI. Additionally, the implementation of the Code Case is consistent with the NRC's philosophy found in SECY-94-093, dated May 10,1995. Per SECY-91-093, the NRC is to take a proactive role through its representatives in the ASME Code to modify reponing requirements and to eliminate the need to submit inservice inspection reports following each refueling outage.

The ASME Code Committee evalmted the proposed alternative reporting requirements and determined the requirements are acceptable for replacing the existing documentation and reporting requirements. Since Code Case N-532 only affects documentation and reporting requirements, its implementation will not affect the level of quality and safety, or decrease the margin of public health and safety. While the cost savings associated with Code Case N 532 have not been quantified as a Cost Benefit Licensing Action item, its implementation is consistent with the intent to eliminate neabeneficial work activities and their associated costs.

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Implementa1jon Schedule: SNC requests to implement Code Case N 532 for the entire 3rd 10 year inspection interval applicable for Cess 1,2 and 3 pressure retaining components and their supports.

The requirements of Subsection IWE of the ASME Section XI Code,1992 Edition with 1992 Addenda, became effective on September 9,1996. Therefore, SNC requests to implement Code Case N-532 applicable for all Cicss MC pressure retaining components and their integral attachments beginning September 9,1996.

Vili. Relief Requnt Status: Relie e, ranted by June 16,1997 SER or until Code Cases are published in R.G.1.147. Revision 2 submitted for NRC review in December,1997.