ML20141H919
| ML20141H919 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 08/01/1997 |
| From: | Ngoc B NRC (Affiliation Not Assigned) |
| To: | Sumner H SOUTHERN NUCLEAR OPERATING CO. |
| References | |
| TAC-M97478, TAC-M97479, NUDOCS 9708040075 | |
| Download: ML20141H919 (6) | |
Text
August 1,1997 Mr. H. L. Sumn:r, Jr.
Vice President - Hatch Project Southern Nuclear Operating Company, Inc.
P. O. Box 1295 Birmingham, Alabama 35201-1295
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF-EDWIN 1. HATCH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M97478 AND M97479)
Dear Mr. Sumner:
The NRC staff with assistance from its contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the third 10-year interval inservice inspection program plan and associated requests for relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI requirements for the Hatch Nuclear Plant, Units 1 and 2. Additionalinformation is required from you in order for the staff to complete its review.
The staff requests that you respond to the attached list of questions within 30 days to meet the staff's inservice inspection program plan review sche'Jule. In addition to expedite the review process, please send a copy of the your resporise to the NRC's contractor, INEEL, at the following address:
Michael T. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 If you have any questions on this matter, please contact me at (301) 415-1458.
Sincerely, ORIGINAL SIGNED BY:
Ngoc B. (Tommy) Le, Project Manager Project Directorate ll-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366 DISTRIBUTION
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l' Mr. H. L. Sumner, Jr.
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Vice President - Hatch Project Southem Nuclear Operating Company, Inc.
P. O. Box 1295 Birmingham, Alabama 35201-1295
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF-EDWIN 1. HATCH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M97478 AND M97479)
Dear Mr. Sumner:
The NRC staff with assistance from its contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the third 10-year interval inservice inspection program plan and associated requests for relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI requirements for the Hatch Nuclear Plant, Units 1 and 2. Additional information is required from you in order for the staff to complete its review.
The staff requests your response to the attached list of questions within 30 days to meet the staffs inservice inspection program plan review schedule. In addition, to expedite the review process, please send a copy of the your response to the NRC's contractor, INEEL, at the following address:
Michael T. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 ff you have any quest ons on this matter, please contact me at (301) 415-1458.
Sincerely, Ngoc B. (Tommy) Le, Project Manager Project Directorate ll-2 Division of Reactor Projects - 1/Il Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
Enclosure:
As stated cc w/ encl: See next page
2 4
Edwin 1. Hatch Nuclear Plant Units 1 and 2 cc:
i Mr. Emest L. Blake, Jr.
Charles A. Patrizia, Esquire Shaw, Pittman, Potts and Trowbridge Paul, Hastings, Janofsky & Walker 2300 N Street, NW.
10th Floor a
Washington, DC 20037 1299 Pennsylvania Avenue Washington, DC 20004-9500 Manager, Licensing
_ Chairman 3'
Southem Nuclear Operating.
Appling County Commissioners Company, Inc.
County Courthouse P. O. Box 1295 Baxley, Georgia 31513 Birmingham, Alabama 35201-1295 Mr. W. G. Harr!ston, lll Resident inspector President and Chief Executive U.S. Nuclear Regulatory Commission Officer 11030 Hatch Parkway North Southem Nuclear Operating Baxley, Georgia 31513 Company, Inc.
P. O. Box 1295 Regional Administrator, Region ll Birmingham, Alabama 35201-1295 U.S. Nuclear Regulatory Commission i
Atlanta Federal Center Mr. J. D. Woodard l
61 Forsyth Street, S.W., Suite 23T85 Executive Vice President Atlanta, Georgia 30303 Southem Nuclear Operating Company, Inc.
Mr. Charles H. Badger
. P. O. Box 1295 i
Office of Planning and Budget Birmingham, Alabama 35201-1295 Room 610 270 Washington Street, SW.
Mr. P. W. Wells Atlanta, Georgia 30334 General Manager, Edwin I. Hatch Nuclear Plant Harold Rebels, Diredor Southem Nuclear Operating Department of Natural Resources Company, Inc.
I 205 Butler Street, SE., Suite 1252 P. O. Box 439 Atlanta, Georgia 30334 Baxley, Georgia 31513 Steven M. Jackson Senior Engineer - Power Supply
- Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, Georgia 30328-4684
2 i
REQUEST FOR ADDITIONAL INFORMATION 1
j REGARDING THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM '
AND ASSOCIATED REQUESTS FOR RELIEF EDWIN 1. HATCH NUCLEAR PLANT. UNITS 1 AND 2 i
DOCKET NOS. 50-321 AND 50-366
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Request for Additional Information - Third 10-Year Interval Requests for Relie1 RR-18 through j
RR-22.
i i
Scoce/ Status of Review 1
The Nuclear Regulatory Commission (NRC) is responsible for the review and disposition of I
licensee submittals relating to inservice inspection (ISI) requirements contained in Title 10 of 1
the Code of Federal Reaulations (10 CFR) Section 50.55a, and the American Society of
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Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (ASME Code),Section XI.
Included within a submittal, licensees are required to provide both a regulatory basis (by
.4 citing the appropriate section of 10 CFR 50.55a), and a technical discussion, to support the i
request. This information is used to establish the context of each evaluation.
The staff has reviewed the available information submitted by Southem Nuclear Operating
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l Company, Inc. (Southem Nuclear) in a letter dated December 17,1996, requesting review and approval of ISI Relief Requests RR-18, RR-19, RR-20, RR-21, and RR-22 for the third 10-year.lSI interval.
AdditionalInformation Reauired The licensee must state the specific paragraph of the regulations under which each proposed altamative or request for relief is submitted. The licensee should review the current submittal and provide the required references to ensure that each proposed attemative or request for relief is evaluated in accordance with the appropriate criteria, as discussed below.
i A licensee may propose an attemative to 10 CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii). When submitting a proposed attemative, the licensee must specify the appropriate regulatory basis.
Under 10 CFR 50.55a(a)(3)(i), the proposed attemative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in terms of quality and safety. Under 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimal increases in examination coverage.
Enclosure
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i
- t in accordance with 10 CFR 50.55a(g)(5)(iii), a licensee may submit a request for relief from j
ASME Code requirements if a licensee determines that conformance with certain ASME Code requirements is impractical for its facility, the licensee shall notify the Commission and
' submit, as specified in Section 50.4, information to support that determination. When a licensee determines that an inservice inspection requirement is impractical, e.g., the system
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would have to be redesigned or a component would have to be replaced to enable j
inspection, the licensee should cite this part of 10 CFR to support the criteria for evaluation.
4 The NRC may, giving due consideration to the burden placed on the licensee, impose an altemative examination requirement.
Southem Nuclear's submittal is unclear as to which interval the relief (s) apply. Relief requests and/or proposed attematives are approved for a specific interval. Although the -
cover letter and titles for the requests for relief indicate they are applicable to the third 10-year inspection interval, Section Vll "imolementation Schedule" for RR-19, RR-20, RR-21, and RR-22, states "The relief request is applicable for the Third 10-Year Interval and close-out of the Second 10-Year Interval." Please provide clarification regarding this statement, and describe tne action Southem Nuclear proposes.
The cover letter states that "[c)omparisons of third interval Relief Request RR-18 and second interval Relief Request 2.1.3 indicates higher coverage during the second interval, however, this variance is essentially due to a more conservative manner of determining coverage, not an actual change in coverage."
Review of NRC Safety Evaluations dated September 29,1986, and June 22,1989, show that Relief Request 2.1.3 was granted based on Southem Nuclear's commitment to i
examine a minimum of 85% of the Code-required volume for the subject reactor pre'ssure vessel nozzle welds. If actual coverages did not meet or exceed Southem Nuclear's commitment for the second 10-year interval, then Southem Nuclear is required to resubmit for relief, if Southem Nuclear's commitment was met for the second 10-year interval, the staff would expect that with improved state-of-the-art examination techniques that a minimum of 85% of the Code-required volume should be inspected during the third 10-year iriterval.
It is also noted that for the second 10-year interval, relief was granted for sixteen (16)
Examination Category B-D nozzles; fourteen (14) on Unit 1 and two (2) on Unit 2. For the third 10-yest interval, relief is being requested for forty-eight (48) Examination Category B-D nozzles; twenty-eight (28) on each unit.
Please provide clarification on the above observations.
. ~ - - -
. Request for relief RR-18 through RR-21 are all regarding examinations of reactor
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pressure vessel components. Provide the staff with the status of the augmented reactor pressure vessel examinations required by 10 CFR 50.55a(g)(6)(ii)(A) e#ective September 8,1992 (Note: plants with greater than 40 months remaining in the interval of the effective date of the rule, were required to perform the augmented examination in that interval) and provide a technical discussion describing how the regulation was implemented at the Edwin 1. Hatch Nuclear Plant, Units 1 and 2. The results of these examinations may provide additional information regarding justification for the granting of relief for adjacent components.
Southem Nuclear has submitted several requests for relief based on estimated examination coverages, i.e., approximately_40 to 50% of the required examination volume is scanned from one side." Code-required coverage is generally based on examination from two directions using multiple examination angles. For each relief request and component for which relief is being requested, provide the staff with the total percentage of the Code-reouired coversoe that can and will be obtained. The Code requires that all examinations be performed to the maximum extent practical. This may require a combination of manual and automated examinations. Providing the staff with the obtainable Code-required coverage that will be performed will also allow the staff to compare the coverage with other plants of like design.
It should be noted that, for requests being evaluated prior to performance of the examinations, if the actual coverages do not meet or exceed the estimated coverages, Southem Nuclear will be required to resubmit for relief. As such, Southem Nuclear may want to consider submittal of reliefs following the actual examinations. Describe the j
action Southem Nuclear proposes to take regarding examination coverages.
The schedule for timely completion of this review requires that Southem Nuclear provMs, by i
the requested date, the above requested information and/or clarification regarding the Edwin 1. Hatch Nuclear Plant, Units 1 and 2, third 10-year interval requests for relief RR-18, l
RR-19, RR-20, RR-21, and RR-22.
'l