NL-05-1372, Third and Fourth 10-Year Interval Inservice Inspection Programs, Submittal of Revised Exemption Request

Third and Fourth 10-Year Interval Inservice Inspection Programs, Submittal of Revised Exemption Request

ML052150425
Person / Time
Site:	Hatch
Issue date:	08/02/2005
From:	Sumner H Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-05-1372
Download: ML052150425 (5)

Text

H.1.Sumner. Jr. Southern Nuclear Vice President Operating Company, Inc.

Hatch Project Post Office Box 1295 Birmingham. Alabama 35201 August 2, 2005 Energy to Serve Your World '"

Docket Nos.: 50-321 NL-05-1372 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Third and Fourth 10-Year Interval Inservice Inspection Programs Submittal of Revised Exemvtion Recluest Ladies and Gentlemen:

By letter dated March 30,2005 Southern Nuclear Operating Company (SNC) submitted the Fourth 10-Year Interval Inservice Inspection (ISI) program. The submittal had nine enclosures which included one request for relief, seven requests for alternatives and an exemption request. In response to a conference call between NRC staff and SNC representatives on July 21,2004, SNC is submitting a revision to Enclosure 9 of the letter dated March 30,2005. This enclosure has been revised to indicate the paragraph of 10 CFR 50.12 to which the exemption request applies.

In accordance with 10 CFR 50.12(a)(l), SNC requests an exemption from 10 CFR 50.55a(b)(2)(ix)(G) requirements for VT-3 examination of the containment vent system. SNC proposes to continue to use the method established by Third 10-Year Interval Relief Request RR-MC-9 to implement the visual requirements.

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

Sincerely, H. L. Sumner, Jr.

Enclosure:

Revised Enclosure 9: ISI-EX-0 1, Version 2

U. S. Nuclear Regulatory Commission NL-05-1372 Page 2 cc: Southern Nuclear Operating;Company Mr. J. T. Gasser, Executive Vice President Mr. G. R. Frederick, General Manager - Plant Hatch RTYPE: CHA02.004 U. S. Nuclear Regulatorv Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Hatch Mr. D. S. Simpkins, Senior Resident Inspector -Hatch

Enclosure 9 SOUTHERN NUCLEAR OPERATING COMPANY ISI-EX-01, Version 2.0 10 CFR 50.55a EXEMPTION REQUEST Plant Site-Unit: Edwin I. Hatch Nuclear Plant-Units 1 and 2 Interval-Interval 4h IS1 Interval extending from January 1,2006 through December 3 1,2015.

Dates:

Requested Date Approval is requested by November 1,2005 to support examinations performed for Approval: during 1R22 (scheduled for February 2006)

ASME Code Accessible surface areas of the Containment Vessel pressure retaining boundary Components Vent System, requiring visual examination per ASME Section XI, Table IWE-Affected: 2500-1, Category E-A, Item Number E l .20.

Applicable Code ASME Section XI, 2001 Edition through the 2003 Addenda Edition and Addenda:

Applicable 10 CFR 50.55a(b)(2)(ix)(G) requires a VT-3 examination of components in IWE Requirements: Table 2500-1, Category E-A, Item E1.20 in lieu of the ASME Section XI required General Visual Examination (CFR dated October 4, 2004).

Reason for During the 3'* inservice inspection interval, the 1992 Code with 1992 Addenda Request: required a VT-3 examination of the accessible surface areas of the vent system.

SNC requested approval in Relief Request RR-MC-9 to use a General Visual examination in lieu of the VT-3 examination. This request was approved by the NRC. For the 4h interval, the 2001 Edition through the 2003 Addenda does not require the VT-3 examination; however in 10 CFR 50.55a(b)(2)(ix)(G), the NRC added a requirement to perform the VT-3 examinations.

SNC believes that the examination provisions established in previous Relief Request RR-MC-9 have proven to be sufficient to maintain the structural integrity and leak-tightness of the containment surfaces; therefore, SNC is requesting to continue the use of similar provisions during the 4Ihinterval.

See References for dates and TAC numbers associated with RR-MC-9.

Enclosure 9 SOUTHERN NUCLEAR OPERATING COMPANY ISI-EX-01, Version 2.0 10 CFR 50.55a EXEMPTION REQUEST Proposed In lieu of conducting the 10CFR50,55a(b)(2)(ix)(G) required visual Alternative and examination (VT-3), SNC proposes to perform a general visual type Basis for Use: examination on all non-submerged, accessible pressure boundary surfaces of the vent system. This general visual type examination will be performed in accordance with the Plant Hatch "Qualified (N) Coatings" program. The details of this program were provided in the October 19, 1998 response to NRC Generic Letter 98-04, "Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment." The procedures and personnel qualifications applicable for the coatings program implementation are in compliance with Regulatory Guide 1.54, 1973, and the implementation is based on the following documents: (1) ANSI N101.2-1972, "Protective Coatings (Plants) for Light Water Nuclear Reactor Containment Facilities;"

(2) ANSI N 101.4-1972, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities;" and (3) EPRI Report TR-109937, "Guideline on Nuclear Safety-Related Coatings." This program was approved by the NRC in a letter dated November 19, 1999.

The "Qualified (N) Coatings" program examination frequency is equivalent to that of the ASME XI Code and the program requires that when evidence of degradation is detected, a detailed examination and evaluation be performed.

The detailed visual examination would be performed in accordance with the provisions of ASME XI paragraph IWE-23 lO(c).

The exterior surfaces of the Vent System that connects the BWR Drywell to the Suppression Pool are located in the Reactor Building. The Reactor Building environment does not pose adverse conditions that would promote rapid degradation of the outside pressure boundary surfaces of the Vent System. The interior surfaces of the Vent System that connects the Drywell to the suppression pool and the portions of the vent system located inside the Suppression Pool are maintained in a nitrogen inerted environment during normal power operation in accordance with Technical Specification requirements. History and previous examinations have indicated that this environment does not promote rapid degradation of the surfaces.

The requirements specified for a VT-3 were developed for detecting flaws in metal components and are more stringent than those required for detection of degradation such as corrosion. Since corrosion of base metal is the primary issue of concern for containment pressure boundary surface areas, a general visual type examination, in accordance with the site "Qualified (N) Coatings" program, is sufficient to inspect the subject surface areas of the containment and will provide an acceptable level of quality and safety. Therefore, SNC hereby requests an exemption from the requirements of 10CFR50.55a (b)(2)(ix)(G) pursuant to 10 CFR 50.12(a)(l) since granting the exemption will not present an undue risk to the public health and safety.

Enclosure 9 SOUTHERN NUCLEAR OPERATING COMPANY ISI-EX-01, Version 2.0 10 CFR 50.55a EXEMPTION REQUEST Duration of The proposed exemption is applicable for the 4' Inservice Inspection Proposed Interval.

Alternative:

Precedents: A similar request was approved for the 3rdInservice Inspection Interval as RR-MC-9.

References:

SNC letter HL-5957, dated July 19,2000 submitting RR-MC-9.

Approval for RR-MC-9 was granted for the 3rd Interval by NRC letter dated October 04,2000 - TAC numbers MA9569 and MA9570.

Status: Awaiting NRC approval.