Text

Response to Request for Additional Information for Alternative HNP-ISI-ALT-5-01
	ML15350A365
Person / Time
Site:	Hatch
Issue date:	12/16/2015
From:	Pierce C; Southern Nuclear Company, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-2270
	Download: ML15350A365 (12)
	v • d • e

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Binningham, AL 35201 SOUTHERN . \

Tel 205.992.7872 Fax 205.992.7601 NUCLEAR DEC 16 2015 A SOUTHERN COMPANY Docket Nos.: 50-321 NL-15-2270 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant- Units 1 & 2 Response to Request for Additional Information for Alternative HNP-ISI-ALT-5-01 Ladies and Gentlemen:

By letter dated July 16, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15197A174), Southern Nuclear Operating Company (SNC) requested relief to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code {B&PV Code) at the Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2. Based on subsequent discussion with the Nuclear Regulatory Commission (NRC) staff, additional information is needed for the NRC staff to complete their review. The Enclosure provides the SNC response to the NRC requests.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Respectfully submitted,

~/(f!p.

C. A. Pierce Regulatory Affairs Director CRP/RMJ

Enclosure:

SNC Response to NRC Requests

U. S. Nuclear Regulatory Commission NL-15-2270 Page2 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager - Hatch RTYPE: CHA02.004 U.S. Nuclear Regulatory Commission Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch

Edwin I. Hatch Nuclear Plant - Units 1 & 2 Response to Request for Additional Information for Alternative HNP-ISI-ALT-5-01 Enclosure SNC Response to NRC Requests

Enclosure NL-15-2270 SNC Response to NRC Requests NRC RAI No.1 The licensee states that prior to the end of the period from December 31, 2015 to November 30,2017, they will request approval from the NRC to update their Section XI activities to the latest ASME Code edition incorporated by reference in 10 CFR50.55a for the entire fleet. Please discuss which portions of the Section XI ASME Code will be updated. Will just the sections that have currently been requested to be retained at the 2001 E/2003A be updated to the latest edition, or will all sections be updated to the latest ASME Code edition incorporated by reference in 10 CFR 50.55a twelve months prior to November 30, 2017?

SNC Response to NRC RAI-1 To clarify our request for alternative, Hatch is not requesting that the interval be extended. Hatch has developed the fifth Interval lSI Plans with examination selections to meet the 2007E/2008A of ASME Section XI with the applicable conditions as required by 10 CFR 50.55a. Hatch is requesting for the duration stated in the request, that nondestructive examination (NDE), pressure testing, and repair/replacement activities continue to be performed using the 2001 E/2003A. This alternative will enable the SNC fleet to use the same ASME Section XI Edition/Addenda for all six operating units for NDE, pressure test, and repair/replacement. Southern Nuclear (SNC) is providing additional details in this response to help describe how the two Section XI Editions are being used. This alternative has no impact to the lSI interval dates for Hatch but is being implemented to maximize fleet processes and minimize errors for our personnel working on multiple sites. The approach of using the same edition and addenda of the ASME Code has been successively implemented in the present lSI interval for our six operating units. As Southern updates the other operating units and the NRC works toward 10 CFR 50.55a rulemaking, it is our intent to try to use the same edition and addenda for all of our operating units.

The SNC operating fleet is currently utilizing the 2001 E/2003A for each site's current Ten Year lSI Interval. Information received at recent industry meetings suggest that 10 CFR 50.55a will show the 2007E/2008A as being the most recently approved Code edition and addenda until at least the middle of 2016.

SNC is very interested in having the entire SNC fleet implement the 2007E/2008A of ASME Section XI once each site updates their respective Ten Year lSI Program based on the discussion above. Due to the potential for rulemaking to change within the timeframe of the Ten Year lSI updates for Vogtle 1 and 2 Units and the Farley units, SNC may need to make additional submittals to keep the SNC fleet on the same Code Edition and addenda.

In 2017, the sections of the ASME Code called out in the proposed alternative that are requested to be retained at the 2001 E/2003A will be updated to the 2007E/2008A per 10 CFR 50.55a. If at that time, the remainder of the SNC operating fleet is required to decide upon a Code of Record for the next Ten Year lSI Interval and a Code edition other than the 2007E/2008A is listed in 10 CFR 50.55a, then SNC plans on making additional submittals to utilize the 2007E/2008A of ASME Section XI. If approval is not received, then SNC will utilize the latest ASME Code edition incorporated by 10 CFR 50.55a.

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Enclosure to NL-15-2270 SNC Response to NRC Requests Note that the start of the interval is January 1, 2016 and not December 31, 2015.

NRC RAJ No.2 The licensee has requested to extend their current 10-year interval from December 31, 2015 to November 30, 2017. This request could be interpreted as a request to extend the current 10 year lSI interval from December 31, 2015 to November 30, 2017. Please clarify whether this is the case.

SNC Response to NRC RAI-2 SNC's intent with this proposed alternative is not to extend the current 4th Ten Year lSI Interval to November 30, 2017. SNC intentions are to continue compliance with the inspection interval requirements outlined in IWA-2430{d)(1}

of the 2001 EI2003A of ASME Section XI and IWA-2430(c)(1) of the 2007E/2008A of ASME Section XI. The proposed alternative is requesting to maintain only the referenced sections of the code to the 2001 E/2003A of ASME Section XI. This will allow the use of common procedures, personnel training, and personnel qualification applicable to Repair/Replacement, NDE and pressure testing across SNC's fleet.

NRC RAJ No.3 Identify and provide the approximate date of the refueling outages in which the lSI activities will be based on the 2001 Edition through 2003 Addenda in lieu of the 2007 Edition through 2008 Addenda.

SNC Response to NRC RAI-3 The proposed alternative will impact two refueling outages, they are as follows:

- February 2016, Unit One, Refueling Outage 27

- February 2017, Unit Two, Refueling Outage 24 NRC RAJ No.4 In Footnote 5 of the attachment to the relief request, the licensee stated, "planar surface flaws in UNS N06600, N06682 or WB6182 materials or austenitic stainless steels."

a. Please clarify whether there is a typographical error in quoting UNS N06682 and whether the correct material type is UNS N06082; or

b. provide description of UNS N06682 material, state where it is used at HNP Units 1 and 2.

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Enclosure to NL-15-2270 SNC Response to NRC Requests SNC Response to NRC RAI-4 This was an inadvertent typographical error. The correct material type is indeed UNS N06082.

NRC RAI No.5 Discuss which edition and addenda of the ASME Code,Section XI, will be used for the non-mandatory appendices during December 31,2015 through November 30, 2017 and provide justification.

SNC Response to NRC RAI-5 Non mandatory Appendices provide information or guidance to assist in the use of ASME Section XI. Their use is not mandatory and with one exception, they are each referenced within the body of the Code where appropriate. The Edition/Addenda of the Nonmandatory Appendix to be used by HNP, when referenced in the body of the Code is determined by the paragraph of the Code making the reference. For example, Nonmandatory Appendix A is referenced by IWB-361 O(a) and the table on page A-1 of HNP-ISI-ALT-5-01 indicates that IWB-3000 will be to the 2001 Edition/2003 Addenda. Therefore, Nonmandatory Appendix A is also to the 2001 Edition/2003 Addenda.

The below table identifies the Non mandatory Appendix, its reference source from the Code and the Edition/Addenda of the Nonmandatory Appendix that will be used. With the exception of Nonmandatory Appendices that were issued after the 2001 Edition through the 2003 Addenda, the Edition/Addenda of the Nonmandatory Appendix corresponds with the Edition/Addenda of the Code paragraph as referenced in the table shown on page A-1 of HNP-ISI-ALT-5-01.

Non mandatory Appendices added to the Code after the 2001 Edition through the 2003 Addenda to and including the 2008 Addenda have been accepted by the NRC in 10 CFR 50.55a (some with conditions). For all Non mandatory Appendices, if used, they will be implemented as written including any conditions of 10 CFR 50.55a(b).

ASME Section XI 2001 2007 2001 Edition/

Non mandatory Section XI Reference Edition/2003 Edition/2008 Addenda Appendix Addenda Addenda A IWB-361 O(a) X B (See Note 1) N/A N/A N/A c IWB-3641 X IWC-3641 IWD-3641 D IWA-2200 X E IWB-3720(b) X G (See Note 2) 10 CFR 50 Appendix G X H IWB-3641 X IWC-3641 IWD-3641 E-3

Enclosure to NL-15-2270 SNC Response to NRC Requests J IWA-4120(g) X K IWB-3730(b) X L IWB-3740 X M Mandatory Appendix I, X 1-211 O(d)

N (See Note 3) Not Referenced X 0 (See Note 4) IWB-3662(f) N/A N/A N/A P (See Note 5) IWA-1700(g) in 2004 X Edition and later Q (See Note 6) IWA-4411 (h) 2007 X Edition and later R (See Note 7) IWB-2500(c) N/A N/A .N/A IWC-2500(c)

1. Nonmandatory Appendix B provides forms associated with PWR steam generator tube repairs and examinations which are not applicable to HNP.

2. Nonmandatory Appendix G is not related to lSI, NDE, Repair/Replacement or Pressure Test. Nonmandatory Appendix G is used as specified by 10 CFR 50 Appendix G and will be to the 2007 Edition with the 2008 Addenda.

3. Nonmandatory Appendix N was added in 2004 and is not referenced in the body of the Code. If needed, the 2007 Edition with the 2008 Addenda will be used.

4. Nonmandatory Appendix 0 is applicable to PWRs only and is not applicable to HNP.

5. Nonmandatory Appendix P was added in the 2004 Edition. If needed, the 2007 Edition with 2008 Addenda will be used.

6. Nonmandatory Appendix Q was added in the 2007 Edition. If needed, the 2007 Edition with the 2008 Addenda will be used.

7. Non mandatory Appendix R, as conditioned by 10 CFR 50.55a(b)(xxix) cannot be used without NRC authorization. HNP will be implementing Code Case N-716-1 as approved in Regulatory Guide 1.147 Revision 17 as an alternative to Nonmandatory Appendix R.

8. Nonmandatory Appendix S was added in the 2008 Addenda. If needed, the 2007 Edition with 2008 Addenda will be used.

NRC RAI No.6 On page E-5 of HNP-ISI-ALT-5-01, the licensee stated, in part, that, "The requests to be extended are:

Request /SI-AL T-08-02 (Units 1 and 2), authorized on June 24, 2009 and is associated with the RIR program for preemptive overlays, [ADAMS Accession No. ML090340017].

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Enclosure to NL-15-2270 SNC Response to NRC Requests Based on HNP comments, a revised SER was issued on May 26, 2011

[ADAMS Accession No. ML11139A438]." Regarding ISI*ALT-08*02:

a. On page 15 of Relief Request ISI-ALT-08-02 (Section 2.1, "Procedure qualifications," paragraph (g), the licensee stated that, "The average lateral expansion value of the heat affected zone (HAZ)

Charpy V-notch specimens shall be equal to or greater than the average lateral expansion value of the three unaffected base metal specimens.

However, if the average lateral expansion value of the HAZ Charpy V-notch specimens is less than the average value of the unaffected base metal specimens and the procedure qualification meets all the other requirements of the Appendix 1 of the submittal, either of the following shall be performed:

a. The welding procedure shall be requalified.

b. An Adjustment Temperature for the procedure qualification shall be determined in accordance with the applicable provisions of NB-4335.2 of Section Ill, 2001 Edition with 2002 Addenda. The RTNor or lowest service temperature of the materials for which the welding procedure will be used shall be increased by a temperature equivalent to that of the Adjusted Temperature."

Based on the above information, the NRC staff requests that the licensee provide the following information:

i. Identify whether aforementioned option (a) or option (b) was used in the temperbead weld qualification for Hatch Units weld overlays that were performed under Relief Request ISI-ALT-08*02.

ii. If the welding procedure specification (WPS) was qualified with option (b), provide the value for the new Adjusted Temperature for the vessel component (where temperbead structural overlay was applied). Identify if this Adjusted Temperature value was considered in the evaluation of the vessel integrity analyses (e.g.,

pressure-temperature curves-if applicable).

SNC Response to NRC RAI-6i:

lSI Alternative ISI-ALT-08-02 was used for the installation of two full-structural weld overlays at Hatch Unit-2 in two separate outages after NRC approval was received. The documentation was reviewed for these two weld overlays and it showed that the procedure qualification coupon testing resulted in impact samples that exhibited average lateral expansion in the HAZ greater than in the base material. Therefore, an adjustment to the RTNor or lowest service temperature of the materials affected by the welding procedure was not required.

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Enclosure to NL-15-2270 SNC Response to NRC Requests No full-structural weld overlays have been installed at Hatch Unit-1 using this alternative.

SNC Response for RAI Question No. 6ii:

Based on the response to RAI No. 6i, this question does not apply.

NRC RAI No.7 In reference to footnote (6) on page A-2 of HNP-ISI-ALT-5-01 states that

" ... snubber pre-service and inservice inspection and testing requirements are implemented in Subsection ISTD of the ASME OM Code, 2004 Edition through 2006 Addenda in its entirely. " The SNC submitted snubber program on October 31, 2014 (ADAMS Accession No. ML14349A471) for fourth 10-year interval, which is based on "Code of Record," ASME OM Edition 2001 through 2003 Addenda. Please explain the discrepancy between the ASME Code Editions.

SNC Response to NRC RAI-7 As referenced on page 1 of 5 in Enclosure 2 of ADAMS accession No.

ML14349A471, the current 4th interval snubber pre-service and inservice inspection and testing requirements are implemented in Subsection ISTD of the ASME OM Code, 2001 edition through the 2003 addenda. Enclosure 2 goes on to state that for the fifth 10-year interval, the snubber program will be updated concurrently with the lnservice Inspection (lSI) and lnservice Testing (1ST}

updates. All of these updates will meet 10 CFR 50.55a requirements for program updates to move to the latest edition and addenda of the Code which has been endorsed 12 months before the start of the plants next 120 month interval. In the case of snubbers, the endorsed Code edition and addenda is the 2004 edition through the 2006 addenda of the OM Code.

For clarification, please note that the current 4th Interval of the lnservice Inspection, lnservice Testing and Snubber program plans end December 31, 2015. The use of the subject Relief Request is desired to begin January 1, 2016.

These interval start/end dates are common amongst the IST/ISI and snubber programs at the Hatch site.

NRC RAI No.8 Footnote 2 on page A-2 of HNP-ISI-ALT-5-01 states that " ... HNP is proposing to use IWA-21 00, 2200, 2300 and 2600 from the 2001 Edition/2003 Addenda for requirements applicable to authorized inspection, examination methods, qualification of NDE personnel and the weld reference system.

However, HNP will use the 2007 Edition/2008 Addenda when using IWA-2400 and 2500 for the selection, planning and scheduling of ISI/CII examinations and tests .... "

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Enclosure to NL-15-2270 SNC Response to NRC Requests Provide the reason why two separate editions/addenda of the ASME Code will be used for the same IWA-2000 section.

SNC Response to NRC RAI-8 As described in HNP-ISI-ALT-5-01, the lSI program is being updated to the 2007 Edition with the 2008 Addenda, and it is proposed that the NDE, Repair/Replacement and Pressure Test programs be maintained to the 2001 Edition through the 2003 Addenda.

The lSI program is a site specific program that is developed to meet ASME Section XI requirements based on individual plant design, configuration, license basis, and design basis. The lSI Plan and Schedule as described in IWA-2400 is site specific and is not shared or used by multiple sites.

However, unlike the lSI program, the NDE, Repair/Replacement and Pressure Test programs are not site specific and are managed by procedures that are common to Southern Nuclear Operating Company.

For this reason, HNP-ISI-ALT-5-01 divides IWA-2000 into requirements that affect the lSI Plan and Schedule and requirements that affect NDE, Repair/Replacement, and Pressure Test.

IWA-21 00 provides general requirements for the Authorized Inspector (AN II) and Authorized Inspection Agency (AlA). While the ANI I and AlA provide oversight of all ASME Section XI programs, it is important to not divide their Code requirements into varying Edition/Addenda that would depend on the program. Keeping HNP to the 2001 Edition with the 2003 Addenda for IWA-2100 allows the ANII and AlA to provide oversight to all of SNC using common procedures with common requirements which also simplifies their sharing of resources.

IWA-2200 provides requirements for examination methods; therefore, for SNC to maintain common NDE procedures for its fleet, it is necessary for HNP to maintain its use of the 2001 Edition through the 2003 Addenda of IWA-2200.

IWA-2300 provides requirements for qualification of NDE personnel; therefore, for SNC to maintain a common NDE personnel qualification program and share NDE resources between sites, it is necessary for HNP to maintain its use of the 2001 Edition through the 2003 Addenda of IWA-2300.

IWA-2600 provides requirements for a weld reference system. The weld reference system is used in the performance of NDE and is implemented in the NDE program procedures. Therefore for SNC to maintain common NDE procedures for the weld reference system, it is necessary for HNP to maintain its use of the 2001 Edition through the 2003 Addenda of IWA-2600.

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Enclosure to NL-15-2270 SNC Response to NRC Requests

IWA-2400 provides requirements for the Inspection Program with specific requirements for the Inspection Plan and Inspection Schedule. These documents are unique to each site and are based on Code requirements, site configuration, license bases, and design bases. The documents, programs, and plans that result from the requirements of IWA-2400 are not shared among the sites. Therefore, the requirements of IWA-2400 from the 2007 Edition with the 2008 addenda will be used as part of the requirements for the updated HNP site specific lSI program.

IWA-2500 defines the extent of examination required by the lSI Program to clarify that the lSI Plan only applies to welds that join items and not welds correcting flaws in base materials, unless otherwise noted. The requirements of IWA-2500 are related to the lSI Program and do not affect NDE, Repair/Replacement, or Pressure Testing. Therefore IWA-2500 of the 2007 Edition with the 2008 Addenda will be used for the updated HNP site specific lSI Program.

In summary, the separation of the IWA-2000 requirements in HNP-ISI-ALT-5-01 identifies those portions of IWA-2000 that are associated with other than the lSI Program and those that are associated with the lSI Program. Code requirements that affect NDE, Repair Replacement, Pressure Testing, and the ANII/AIA are to be maintained to the 2001 Edition with the 2003 Addenda to support the use of common procedures, training, and the sharing of resources among Southern Nuclear Operating Company.

NRC RAI No.9 The table on page A-1 of HNP-ISI-ALT-5-01 shows that IWB, IWC, IWD, IWE, and IWF-1 000 and -2000 of the 2007 edition and 2008 addenda will be used in the fifth lSI interval. Discuss why IWA-1000 of the 2007 edition and 2008 addenda will not be used in the fifth lSI interval?

SNC Response to NRC RAI-9 The content of IWA-1 000 provides for Scope and Responsibility and is addressed in administrative procedures that are common to Southern Nuclear Operating Company. From the 2004 Edition to and including the 2008 Addenda, there have been 18 changes made to IWA-1 000.

IWA-11 00 was revised in the 2005 Addenda to add "fabrication" into the scope of ASME Section XI. This was a clarification of changes made in the 1997 revision to IW A-4143( a).

IWA-1320(d) was revised in the 2006 Addenda to delete reference to ASME Section Ill when describing containment vessel penetrations. This change was for clarification as the reader could be misled to believe that Section Ill provides classification criteria.

IWA-1400(q) is added in the 2007 Edition requiring Owners QA programs to describe methods of certification other than written signatures. Owner's QA programs have been providing for electronic document processing long E-8

Enclosure to NL-15-2270 SNC Response to NRC Requests before the 2007 Edition of Section XI. This change to Section XI does not provide new requirements for HNP.

IWA-1600, Table IWA-1600-1 is revised in 2004 to replace reference to SNT-TC-1 A with CP-189. This was an editorial change to update the table to be consistent with other Code text. IWA-231 0 was changed in the 1992 Addenda to require compliance with CP-189.

IWA-1600, Table IWA-1600-1 is revised in the 2006 Addenda to delete reference to OM (Part 4). This change has no impact to the lSI program that is being updated to the 2007 Edition with 2008 Addenda.

IWA-1700 was added in the 2004 Edition with 12 subsequent changes occurring between the 2006 Addenda and the 2007 Edition. IWA-1700 provides requirements addressing the use of Customary or Sl units. IWA-1700 permits the use of Customary, Sl, or any local customary units to obtain compliance with Section XI. It also provides requirements for unit conversions when used in aspects of design. The requirements of IWA-1700 do not impact the lSI Program that is being updated to the 2007 Edition with the 2008 Addenda.

Maintaining the HNP implementing procedures to the 2001 Edition through the 2003 Addenda for NDE, Repair/Replacement, and Pressure Test allows for the use of common procedures, training, and sharing of resources. Changes to IWA-1000 do not affect the lSI Program (as defined in IWA-2400). Therefore maintaining compliance with IWA-1000 of the 2001 Edition through the 2003 Addenda allows for the common programs while not affecting the lSI Program that is being updated to the 2007 Edition with the 2008 Addenda.

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