ML20212A198

Safety Evaluation Denying Licensee Request for Relief from Implementation of 10CFR50.55a Requirements Re Use of 1992 Edition of ASME Code Section XI for ISI of Containments

ML20212A198
Person / Time
Site:	Hatch
Issue date:	10/16/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20212A185	List: ML20212A180 ML20212A198
References
NUDOCS 9710230180
Download: ML20212A198 (3)

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• UNITED STATES NUCLEAR REQULATORY COMMlRSION

• VAsHINGToN, D.C. 300e6 0001 1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF FROM THE IMPLEMENTATION OF 10 CFR 50.55a REQUIREMENTS RELATED TO THE USE.,QF THE 1992 EDITION OF ASME CODE SECTION XI FOR INSERVICE INSPECTION OF CONTAINMENTS

. EDWIN 1. HATCH NUCLEAR PLANT UNITS 1 AND 2 -l DOCKETS NOS. 50 321 AND 50-3G8 I

1.0 INTRODUCTION

By Federal Reaister Notice No.154, Volume 61, dated August 8,1996, the Nuclear Regulatory Commission amended its regulations to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a (the Rule), to incorporate by reference the 1992 Edition with the 1992 Addenda of Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code).

Subsectionr. lWE and IWL provide the requirements for inservice inspection (ISI) of .

Class CC (concrete containments), and Class MC (metallic containments) of the light water cooled power plants. The effective date for the amended Rule was September 9,1996, and it requires licensees to incorporate the new requirements into their ISI plans and to'-

complete the first containment inspection within 5 years, that is, by September 9,2001.

Pursuant to 10 CFR 50.55a(a)(3), proposed altamatives to the requirements may be iauthorized if an applicant demonstrates (1) the proposed alternatives would provide an

._ acceptable level of quality and safety [(a)(3)(i)] or (2) compliance with the requirement-

-would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety [(a)(3)(iill.

This evaluation addresses the merits of the relief request submitted by Southem Nucitar -

- Operating Company, Inc. (SNC, the licensee), for Edwin 1. Hatch Nuclear Plant, Units 1 and 2 (Hatch) (Ref.1).

' 2.0 RELIEF REQUEST AND PROPOSED ALTERNATIVE Considering the impracticality of immediately updating the plant repair and replacement programs to comply with the requirements of the Rule, the staff had authorized the use of a different version (i.e., the 1989 Edition) of the ASME Code,Section XI requirements for repeir and replacement activities until September 9,1997 (Refs. 2 and 3).

In its relief request dated August 8,1997, the licensee requests that "the NRC grant relief from compliance with the Rule relative to the use of ASME Gection XI,1992 Edition with the 1992 Addenda (1992 E&A) for Class MC components for Code activities other than examination requirements." The licensee contends that the requirements of the Rule can be implemented within the framework of the existing ASME Code Section XI,1989 Edition 9710230180 971016 PDR ADOCK 05000321 9 PDR

2-ISI program while maintaining an acceptable level of quality and safety. The licensee I emphasizes that it will utilize the 1992 E&A for examination of Class MC components.

j But all general requirements and requirements associated with repair and replacement activities will be implemented in accordance with the ASME Code Section XI,1989 Edition.

3.0 EVALUATION The licensee's relief request includes a table showing the differences in th6 applicable IWA

-(general requirements) provisions in the two editions (1989 and 1992) of Section XI of the ASME Code. The following is the staff's evaluation of some of the significant provisions.

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MC-1,'lWA-2210: For remote visual examination, the Rule [10 CFR 50.55a(b)(2)(x)(b)1 provides some relaxation from the 1992 E&A provision based on the validity of the public comments. 5t does not endorse the provision in the 1989 Edition of the ASME Code. For a number oi conditions, the differences in the provisions of two editions are not inconsequential as contended by the licensee. The same level of quality and safety are not apparent.

MC 1, IWA-2300: The 1992 E&A, lWA 2310 allows users (licensees) to utilize the SNT TC-1 A certified NDE personnel until recertification is required when the personnel have to be certified as per CP-189. CP-189 requires the personnel to be ratested during recertification rather than reconfirmed. Experience has dictated the need for this change.

Thus, on a permanent basis, the implementation of the 1989 Edition of the Code would

.9t provide the acceptable level of quality and safety. '

MC-2, IWE 5221: The licensee is correct in pointing out that the'10 CFR Part 50, -

Appendix J, paragraph cited in IWE 5221 is in Option A of the revised Appendix J (1995).

However, the reiteration of this paragraph in the 1995 Edition and in the 1996 Addenda

-indicates that after a major modification, the ASME Code considers this provision necessary to ensure structuralintegrity of the containment, irrespective of the option adopted. There will be a compromise in safety if this provision is not considered by the licensee.

MC-2, IWE 5240: Reference to IWA-5246 in the 1992 Addenda was corrected to IWA 5240 in the 1993 Addenda of the Subsection. In response to a comment to the draft Rule, the NRC staff had confirmed the error in the 1992 E&A of the Code and responded that the provision of IWA 5240 is applicable in the Federal Reaister notice for the final Rule. This provision requires the VT-2 examination after repair or replacement of the leakage boundary. As indicated in IWE 5210, none of the other requirements of IWA-5000 are applicable to Class MC and Class CC components. Therefore, this provision of IWA-5000 is essential for ensuring the functional requirement of the containment.

In general, the requirements of ASME Code,Section XI, and the Code incorpora~ted by references in the Rule (10 CFR Section 50.55a) are integrated for the purpose of ensuring integrity and safety of plant systems and components; and, thus, ad hoc efforts to pick and choose between individual items sacrifice their intended effectiveness. Additionally, revisions (tightening and relaxing) to this Code requirement are prompted by the users' implementation experience and comments, and reverting back to the ol der editions of the ASME Code subverts the intent of the Code and the Rule. i

4.0 CONCLUSION

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-On the basis of our review of the information provided in SNC's relief request (RR MC 1 and RR-MC-2), the staff concludes that the proposed alternative to substitute the IWA portion of the 1989 Edition of the ASME Code Section XI requirements related to the i

inservice inspection of the containments at the Hatch plant for the IWA portion of the '

1992 Edition with the 1992 Addenda of the ASME Code Section XI as endorsed by 10 CFR 50.55a (61 FR 41303), is inappropriate and unecceptable, in that it does not provide an acceptable level of quality and safety. The staff does not agree with the-licensee's contention that on a long-term basis such an approach could provide an acceptable level of quality and safety. Accordingly, the request for relief from compliance with the Rule relative to the use of Subsection IWE (and associated Subsection IWA) of ASME Code Section XI,1992 Edition with the 1992 Addenda, is denied.

Principal Contributor: H. Ashar Date: October 16, 1997 References 1.

Letter from H. L. Sumner, Jr. (SNC) to NRC, " Containment inspection Rule, Request -

for Relief," dated August 8,1997.-

2. Letter from J. T. Beckham, Jr., Georgia Power Company to NRC, " Request for Exemption," dated December 2,1996.

3. . Letter from H. N. Berkow (NRC) to H. L. Sumner, Jr., Georgia Power Company,

" Evaluation of the Request for Relief from the Requirements Related to the Repair and Replacement Activitics for Containments," dated May 16,1997.

.. 98 LETTER TO MR. H. L. SUMNER JR. DATED October 16, 1997 Distribution:

( M SWSKF PUBLIC PD 112 Rdg.

BBoger HBerkow LBerry NLe GBagchi -

OGC ACRS JJohnson, Ril PSkinner, Rll HAshar THarris (e-mail SE only)

)

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