ML051640350

From kanterella
Jump to navigation Jump to search

RR, Later Code Edition and Addenda Use for ISI Interval
ML051640350
Person / Time
Site: Hatch Southern Nuclear icon.png
Issue date: 06/15/2005
From: Marinos E
NRC/NRR/DLPM/LPD2
To: Gasser J
Southern Nuclear Operating Co
Gratton C, NRR/DLPM, 415-1055
References
TAC MC6524
Download: ML051640350 (6)


Text

June 15, 2005 Mr. J. Gasser Vice President Southern Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT 1 RE: APPROVAL TO USE LATER CODE EDITION AND ADDENDA FOR THE THIRD 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MC6524)

Dear Mr. Gasser:

By letter dated March 30, 2005, Southern Nuclear Operating Company, Inc. (the licensee) submitted Relief Request ISI-CODE-1 for Edwin I. Hatch Nuclear Plant, Unit 1 (Hatch 1). The request pertains to the use of a later Edition and Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code than is currently required.

Specifically, the licensee requested to use ASME Section XI 2001 Edition through the 2003 Addenda in lieu of the 1989 Edition for the remainder of examinations for the third 10-year inservice inspection (ISI) interval scheduled to be completed during the Hatch 1 refueling outage No. 22.

The Nuclear Regulatory Commission (NRC) staff finds the proposed alternative acceptable and approves the use of ASME Section XI 2001 Edition through the 2003 Addenda in lieu of the 1989 Edition for the remainder of examinations for the third 10-year ISI interval. The NRC staffs Safety Evaluation is enclosed.

Please note that eight additional licensing actions were requested in the March 30, 2005, letter to the NRC. Those licensing actions are currently under review and will be addressed in a separate letter. If you have any questions regarding the status of the licensing actions in your March 30, 2005, letter, please contact the Hatch project manager.

Sincerely,

/RA/

Evangelos Marinos, Section Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-321

Enclosure:

As stated cc w/encl: See next page

ML051640350 NRR-028 OFFICE PDII-1/PM PDII-1/LA OGC DE/EMCB PDII-1/SC NAME CGratton CHawes KCyr TLChan EMarinos DATE 06/06/05 06/06/05 06/13/05 5/23/05 06/15/05

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THIRD AND FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION (ISI)

REQUEST FOR RELIEF ISI-CODE-1 EDWIN I. HATCH NUCLEAR PLANT, UNIT 1 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

DOCKET NO. 50-321

1.0 INTRODUCTION

By a letter dated March 30, 2005 (Agencywide Documents Access and Management System, Accession No. ML050940210), Southern Nuclear Operating Company, Inc. (the licensee) submitted relief request ISI-CODE-1 for Edwin I. Hatch Nuclear Plant, Unit 1 (Hatch 1). The request pertains to certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code). Specifically, the licensee requested to use ASME Section XI 2001 Edition through the 2003 Addenda in lieu of the 1989 Edition for the remainder of examinations for the third 10-year ISI interval scheduled to be completed during Hatch 1 refueling outage No. 22 (1R22).

The request for relief is to support the 1R22 ISI activities scheduled to begin in February 2006.

2.0 REGULATORY EVALUATION

The ISI of ASME Code Class 1, Class 2, and Class 3 components is performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(I). 10 CFR 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if the licensee demonstrates that: (I) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the 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 of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The Code of record for the third 10-year ISI interval at Hatch 1 is the 1989 Edition. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein and subject to Commission approval.

3.0 TECHNICAL EVALUATION

FOR RELIEF REQUEST ISI-CODE-1, VERSION 1.0 3.1 Components for Which Relief is Requested All Class 1, 2, and 3 components inspected during 1R22 as part of the third 10-year ISI interval inspections.

3.2 Applicable Code Requirements The current inservice inspection program for the third 10-year ISI interval is based on the ASME Code,Section XI, 1989 Edition with no Addenda.

3.3 Licensees Proposed Alternative and Basis for Use The third 10-year ISI interval for Hatch 1 will end on December 31, 2005. It is the intent of the licensee to complete the remaining third 10-year interval examinations and pressure tests during 1R22, which is currently scheduled to begin in February 2006 (just after the scheduled end of the third 10-year ISI interval). This is allowed per IWB-2412 of the 1989 Edition of Section XI and per IWA-2430 in more recent editions of the Section XI Code.

Additionally, the licensee intends to begin the fourth ISI interval examinations during 1R22.

Therefore, both third and fourth interval examinations will be performed during 1R22. In no case, will an examination performed during 1R22 be used to satisfy the requirements of both intervals.

Third 10-year interval ISI examinations are currently required to be performed to the 1989 Edition of Section XI and the fourth ISI interval examinations are required to be performed to the 2001 Edition of ASME Section XI through the 2003 Addenda (with specific NRC limitations and modifications defined in 10 CFR 50.55a).

To optimize the outage inservice inspection work activities, pursuant to 10 CFR 50.55a(g)(4)(iv), the licensee is requesting to use the 2001 Edition of ASME Section XI through the 2003 Addenda subject to the limitations and modifications defined in 10 CFR 50.55a(b)(2) for examinations, system pressure tests, and repair/replacement activities performed during 1R22.

3.5 NRC Staffs Evaluation 10 CFR 50.55a(g)(4)(ii) requires inservice examination of components and system pressure tests be performed in accordance with the requirements of the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the 120-month inspection interval subject to the limitations and modifications listed therein. 10 CFR 50.55a(g)(4)(iv) states in part that inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b) and subject to Commission approval. NRC Regulatory Issue Summary 2004-16: Use of Later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities, clarifies that 10 CFR 50.55a(g)(4)(iv) also covers repair/replacement activities. The edition of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the third 10-year ISI interval for Hatch 1 is the 1989 Edition with no addenda. The NRC staff finds that the licensee may use the 2001 Edition of ASME Section XI through the 2003 Addenda because it was endorsed by a subsequent amendment to 10 CFR 50.55a published in the Federal Register on October 1, 2004 (69 FR 58804), and became effective on November 1, 2004, subject to the modifications and limitations listed therein. The NRC staff finds that the use of this later Edition and Addenda of the Code is acceptable because it will not change the number of required examinations nor will any examinations performed be credited for both the third and the fourth 10-year ISI intervals.

4.0 STAFF CONCLUSION The NRC staff concludes that the licensees request to use the 2001 Edition of ASME Section XI through the 2003 Addenda, subject to the modifications and limitations listed in 10 CFR 50.55a(b), for examinations required for the third 10-year ISI interval is acceptable because it provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the NRC staff approves the use of the 2001 Edition of ASME Section XI through the 2003 Addenda, subject to the modifications and limitations listed in 10 CFR 50.55a(b), for examinations required for the Hatch 1 third 10-year ISI interval. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: Andrea Keim, DE Date: June 15, 2005

Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:

Laurence Bergen Oglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Mr. R.D. Baker Manager - Licensing Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295 Resident Inspector Plant Hatch 11030 Hatch Parkway N.

Baxley, GA 31531 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Arthur H. Domby, Esq.

Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295 Mr. G. R. Frederick, General Manager Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc.

U.S. Highway 1 North P.O. Box 2010 Baxley, GA 31515 Mr. K. Rosanski Resident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515