NL-04-1475, 10 CFR 50.55a Request for an Alternative Alignment of IWE / Iwl Inspection Program Interval with Corresponding Plant ISI Program Intervals

10 CFR 50.55a Request for an Alternative Alignment of IWE / Iwl Inspection Program Interval with Corresponding Plant ISI Program Intervals

ML042920059
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	10/13/2004
From:	Gasser J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-04-1475
Download: ML042920059 (3)

Text

Jeffrey T. Gasser Southern Nuclear Executive Vice President Operating Company, Inc.

and Chief Nuclear Officer 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7721 Fax 205.992.6165 A October 13, 2004 COMPANY Energy to Serve Your World SM Docket Nos.: 50-321 50-348 50-424 NL-04-1475 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant 10 CFR 50.55a Request for an Alternative Alignment of IWE / IWL Inspection Program Interval with Corresponding Plant ISI Program Intervals Ladies and Gentlemen:

It is a requirement of 10 CFR 50.55a(b)(2)(vi) that successive IWE and IWL 120-month interval updates be implemented in accordance with 10 CFR 50.55a(g)(4)(ii). Pursuant to 10 CFR 50.55a(a)(3), Southern Nuclear Operating Company (SNC) is requesting an alternative to the requirements of 10 CFR 50.55a(g)(4)(ii) subject to Commission approval as provided in 10 CFR 50.55a(g)(4)(iv).

On August 8, 1996, the NRC issued a rulemaking (61 FR 41303) requiring licensees to implement the first period of IWE and IWL inservice examinations by September 9, 2001. Therefore, using Table IWE-2412-1 of the 1992 Edition with the 1992 Addenda of the ASME Section XI Code, the current Class MC and Class CC interval start and end dates for all SNC nuclear plants were determined to be September 10, 1998, and September 9, 2008, respectively. These start and end dates do not coincide with any of SNC's Class 1, 2, and 3 inservice inspection (ISI) program intervals which are January 1, 1996, through December 31, 2005, for the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2; May 31, 1997, through May 30, 2007, for the Vogtle Electric Generating Plant (VEGP) Units 1 and 2; December 1, 1997, through November 30, 2007, for the Joseph M.

Farley Nuclear Plant (FNP) Unit 1; and July 30, 2001, through July 20, 201 1, for FNP Unit 2.

SNC proposes to change each of the current HNP Class MC and VEGP Class MC and Class CC inspection intervals to be consistent with the corresponding plant's Class 1, 2, and 3 ISI program interval. These Class MC and Class CC inspection program interval updates will be performed concurrently with the next Class 1, 2, and 3 ISI program interval update of each corresponding plant. In addition, SNC proposes to change the FNP Units I and 2 Class MC and Class CC inspection intervals to be consistent with the FNP Unit I Class 1, 2, and 3 ISI program interval. These Class MC and Class CC inspection program interval updates will be performed concurrently with the next

U. S. Nuclear Regulatory Commission NL 1475 Page 2 Class 1, 2, and 3 ISI program interval update of FNP Unit 1. These changes will result in a reduction in length of each plant's first and current Class MC and Class CC inspection program interval. This submittal requests NRC approval as an alternative to the regulations pursuant to 10 CFR 50.55a(a)(3)(ii) in that compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

In Federal Register Notice, Volume 67, Number 187, dated September 26, 2002, the NRC stated that they agreed with licensee comments that the final rule, dated August 8, 1996, creates a hardship when implementing 120-month interval updates required by 10 CFR 50.55a(g)(4)(ii). The final rule required licensees to implement an ISI program for Class MC and Class CC components using the 1992 Edition with the 1992 Addenda of IWE and IWL. Consequently, the schedule for 120-month interval updates for the ISI of Class MC and Class CC components and the ISI of Class 1, 2, and 3 components does not coincide. This creates a hardship because ISI programs are required to maintain two separate editions and addenda of Section XI, i.e., one edition applicable to the ISI of Class MC and Class CC components and another edition and addenda applicable to the ISI of Class 1, 2, and 3 components. The NRC also stated in the Federal Register Notice that licensees may wish to synchronize 120-month interval updates such that the same edition and addenda of Section XI apply to the ISI of Class MC and Class CC components and the ISI of Class 1, 2, and 3 components. It was further indicated that licensees wishing to synchronize their 120-month intervals may submit a request in accordance with 10 CFR 50.55a(a)(3) to obtain authorization to extend or reduce 120-month intervals. Southern Nuclear Operating Company agrees with the NRC assessment.

In addition, it is SNC's position that concurrently updating the IWE and IWL inspection programs with the ISI program for each plant will result in a more comprehensive examination being achieved, enhancing the possibility of detecting a generic problem, and will reduce the costs involved with maintaining two separate code versions should the use of different code versions be required. In addition, use of the same edition and addenda of the code for each program would help prevent possible errors associated with maintaining separate programs with different requirements.

The remaining examinations for each of the current IWE and IWL inspection program intervals will correspond with the method required by the edition and addenda of the ASME Section XI Code adopted by the applicable SNC plant's updated ISI program and will be performed using the requirements of this edition and addenda in the sequence previously established by the current IWE and IWL inspection program interval. Where the requirements of the latest edition and addenda of the ASME Section XI Code adopted by the ISI program cannot be met, relief will be requested from the NRC through the formal relief request process addressed in 10 CFR 50.55a. Any such relief requests will be submitted to the NRC in the updated ISI programs for each plant.

Southern Nuclear Operating Company hereby requests the NRC to grant an alternative to the requirements of 10 CFR 50.55a(g)(4)(ii). This alternative will allow SNC to align each of the IWE / IWL inspection program intervals with the corresponding plant's IST 120-month program interval. The proposed early updated IWE / IWL inspection program intervals are January 1, 2006, through December 31, 2015, for HNP Units I and 2;

U. S. Nuclear Regulatory Commission NL 1475 Page 3 May 31, 2007, through May 30, 2017, for VEGP Units 1 and 2; and December 1, 2007, through November 30, 2017, for FNP Units 1 and 2. SNC will carry these revised interval dates forward through the end of licensed operation for each plant and unit, and the early updates will be documented in each plant's IWE and IWL programs.

In order to apply to the first ISI program update required for an SNC plant (i.e., HNP),

NRC approval is requested by October 15, 2005.

This letter contains no NRC commitments. If you have any questions, please advise.

Sincerely, JfryT. Gasser JTG/DRG/daj cc: Southern Nuclear Operating Company Mr. L. M. Stinson, Vice President - Plant Farley Mr. H. L. Sumner, Jr., Vice President - Plant Hatch Mr. D. E. Grissette, General Manager - Plant Farley Mr. G. R. Frederick, General Manager - Plant Hatch Mr. W. F. Kitchens, General Manager - Plant Vogtle RType: CFA04.054; CHAO2.004; CVC7000; LC# 14135 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. S. E. Peters, NRR Project Manager - Farley Mr. C. Gratton, NRR Project Manager - Hatch Mr. C. Gratton, NRR Project Manager - Vogtle Mr. C. A. Patterson, Senior Resident Inspector - Farley Mr. D. S. Simpkins, Senior Resident Inspector - Hatch Mr. G. J. McCoy, Senior Resident Inspector - Vogtle