NL-23-0019, GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI

GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI

ML23102A123
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	04/12/2023
From:	Brown R Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-23-0019
Download: ML23102A123 (1)

Text

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 tel April 12, 2023 Docket Nos.: 50-321 50-348 50-424 NL-23-0019 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Southern Nuclear Operating Company Hatch Nuclear Plant Units 1&2 Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI Ladies and Gentlemen:

In accordance with 10 CFR 50.55a, Codes and standards, paragraph (g)(4)(iv) and the guidance provided in Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI, Southern Nuclear Operating Company (SNC) hereby requests NRC approval to use a specific provision of a later edition of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (B&PV) Code,Section XI, incorporated in 10 CFR 50.55a(a)(1)(ii),

for Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2; Joseph M. Farley Nuclear Plant (FNP)

Units 1 and 2; and Vogtle Electric Generating Plant (VEGP) Units 1 and 2. Specifically, SNC requests approval to use IWA-6211(a) through IWA-6211(e) (Owners Responsibilities),

IWA-6220 (Owners Repair/Replacement Certification Record), IWA-6230 (Owners Activity Report), and Mandatory Appendix II (Owners Record and Report) of the 2019 Edition of the ASME B&PV Code,Section XI for post outage reporting requirements.

The enclosure to this letter provides the request to use portions of a later edition of the ASME B&PV Code,Section XI.

SNC requests approval of this request by August 12, 2023 to allow for additional time to submit the Owners Activity Report (OAR) following SNCs Fall 2023 outages.

This letter contains no regulatory commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.

U. S. Nuclear Regulatory Commission NL-23-0019 Page 2 of 2 Respectfully submitted, R. Keith Brown Director, Regulatory Affairs Southern Nuclear Operating Company RKB/agq/cbg

Enclosure:

Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv), GEN-ISI-ALT-2023-01 cc: Regional Administrator, Region ll NRR Project Manager - Hatch 1&2, Farley 1&2, and Vogtle 1&2 Senior Resident Inspector - Hatch 1&2, Farley 1&2, and Vogtle 1&2 Director, Alabama Office of Radiation Control State of Georgia Environmental Protection Division R-Type: CGA02.001

Southern Nuclear Operating Company Hatch Nuclear Plant Units 1&2 Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI Enclosure to NL-23-0019 Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv), GEN-ISI-ALT-2023-01

Enclosure to NL-23-0019 Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv),

GEN-ISI-ALT-2023-01 In accordance with 10 CFR 50.55a, Codes and standards, paragraph (g)(4)(iv) and the guidance provided in Reference 1, Southern Nuclear Operating Company (SNC) requests Nuclear Regulatory Commission (NRC) approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code,Section XI, for Farley Nuclear Plant Units 1 and 2, Hatch Nuclear Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 1 and 2. Specifically, SNC requests approval to use IWA-6211(a) through IWA-6211(e) (Owners Responsibilities), IWA-6220 (Owners Repair/Replacement Certification Record), IWA-6230 (Owners Activity Report), and Mandatory Appendix II (Owners Record and Report) of the 2019 Edition of the ASME B&PV Code,Section XI for post outage reporting requirements.

1. Component(s) Affected:

All Class 1, 2, 3, MC, and CC items.

2. Requested Date for Approval:

Approval is requested by August 12, 2023 to allow for additional time to submit the Owners Activity Report (OAR) following SNCs Fall 2023 outages.

3. Applicable Code Edition and Addenda

ISI INTERVAL INTERVAL PLANT EDITION INTERVAL START SCHEDULED END Farley Nuclear Plant, 5 2007 Edition, through 12/01/2017 11/30/2027 Units 1 and 2 2008 Addenda Hatch Nuclear Plant, 5 2007 Edition, through 01/01/2016 12/31/2025 Units 1 and 2 2008 Addenda Vogtle Electric 4 2007 Edition, through 05/31/2017 5/30/2027 Generating Plant, 2008 Addenda Units 1 and 2

4. Proposed Subsequent Code Edition and Addenda (or Portion):

All SNC plants listed above comply with the requirements of IWA-6000, Records and Reports. However, SNC implements Code Case N-532-5, Repair/Replacement Activity Documentation Requirements and Inservice Inspection Summary Report Preparation and Submission. N-532-5 allows for the use of an Owners Activity Report, Form OAR-1, in lieu of the Inservice Inspection Summary Report. These requirements are based on the ASME Section XI Code of Record which, at present, is the 2007 Edition through the 2008 Addenda.

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Enclosure to NL-23-0019 Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv),

GEN-ISI-ALT-2023-01 Pursuant to 10 CFR 50.55a(g)(4)(iv), SNC requests permission to use IWA-6211(a) through IWA-6211(e) (Owners Responsibilities), IWA-6220 ("Owners Repair/Replacement Certification Record"), IWA-6230 ("Owners Activity Report"), and Mandatory Appendix II

("Owners Record and Report") of the 2019 Edition of the ASME B&PV Code,Section XI for post outage reporting requirements. The 2019 Edition of the ASME B&PV Code incorporates the alternate repair/replacement activity documentation and Inservice Inspection summary report preparation and submission requirements of Code Case N-532-5 and extends the submittal time of the OAR-1 outage summary report from 90 days to 120 days.

5. Related Requirements:

10 CFR 50.55a(g)(4)(iv) states:

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 paragraph (a) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.

Section IWA-6211(a) through IWA-6211(e), IWA-6220, IWA-6230, and Mandatory Appendix II of the 2019 Edition of ASME Section XI include all related requirements in this request.

6. Duration of Proposed Request:

The duration of this request will continue for each sites Inservice Inspection interval as provided in Section 3.

7.

References:

1. NRC Regulatory Issue Summary 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM and Section XI, dated July 28, 2004.

2. Federal Register, 87 FR 65128, dated October 27, 2022.

8. Precedent:

None cited.

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