View source for HL-5814, Forwards New Relief Requests for Third 10-year Interval Inservice Insp Program for Ei Hatch Nuclear Plant.New Relief Requests Were Developed to Propose Alternate Insps & to Allow Use of ASME Code Cases N-605,N-508-1,N-323-1 & N-528

{{Adams
| number = ML20210G362
| issue date = 07/30/1999
| title = Forwards New Relief Requests for Third 10-year Interval Inservice Insp Program for Ei Hatch Nuclear Plant.New Relief Requests Were Developed to Propose Alternate Insps & to Allow Use of ASME Code Cases N-605,N-508-1,N-323-1 & N-528
| author name = Sumner H
| author affiliation = SOUTHERN NUCLEAR OPERATING CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000321, 05000366
| license number = 
| contact person = 
| document report number = HL-5814, NUDOCS 9908030076
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 34
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:. ..
Imwis Sumner                       Southern Nuclear Vice President                     Operating Company,Inc.
Hatch P.oject Support -            40 inverness Parkway Post Office Box 1295 Binningharn Alabama 35201 Tel 205.992.7279 Fax 205.992.0341 SOUTHERN h COMPANY Energy to Serve nurWorld*
July 30, 1999 Docket Nos. 50-321                                                                                liL-5814 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin 1.11atch Nuclear Plant Third Ten Year Inte. .al Inservice Inspection Program Submittal of Additional Reauests for Relief Ladies and Gentlemen:
Attached are new Relief Requests for the Third 10-Year Interval inservice Inspection Program for the Edwin I.11atch Nuclear Plant. The new Relief Requests were developed to propose alternate inspections and to request relief from certain administrative requirements and to allow the use of ASME Code Cases N-605, N-508-1, N-323-1, and N-528.
Should you have any questions in this regard, please contact this ofTice.
Respectfully submitted, M                       M
: 11. L. Sumner, Jr.
IFUeb Attachments: Requests for Relief RR-MC-1, RR-MC-2, RR-MC-3, RR-MC-4, RR-MC-5, RR-MC-6, RR-23, RR-24, and RR-27 cc: (See next page.)
9900030076 990730
                                                                                                                  )           j PDR    ADOCK 05000321 G                                 PM

F*
I
!  - U. S. Nuclear Regulatory Commission Page 2 July 30, 1999 cc:    Southern Nuclear Operatina Company Mr. P. H. Wells, Nuclear Plant General Manager SNC Document Management (RIfype A02.001)
U.S. Nuclear Regulatory Commission. Washincton. D.C.
Mr. L. N. Olshan, Project Manager - Hatch U.S. Nuclear Regulatory Commission. Region 11 Mr. L. A. Reyes, Regional Administrator Mr. J. T. Munday, Senior Resident inspector - Hatch  j 1
l l
l HL-5814

Attachment RELIEF REQUEST RR-MC-1 l
l-

SOUTHERN ' NUCLEAR OPERATING COMPANY PLA.NT HATCH, UNIT 1 & 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-MC-1
: 1. System / Component (s) for Which Reliefis Requested: Seals (including 0-rings) and gaskets of Class MC pressure retaining components, Examination Category E-D, Item Numbers E5.10 and E5.20.
This request for relief applies to the following components that incorporate seals and gaskets as the containment pressure boundary:
* Electrical penetrations.
* Two personnel airlock doors with seals, including door operating mechanism penetrations that are part of the containment pressure boundary, and two containment equipment hatches.
* Containment penetrations whose design incorporates retilient seals or gaskets.
II. Code Requirement: The 1992 Edition, with 1992 Addenda of ASME Section XI, Table IWE-2500-1, Examination Category E-D, Items E5.10 and E5.20, require seals and gaskets on airlocks, hatches, and other devices that are required to assure containment leak-tight integrity to be visually examined once each interval.
III. Code Requirement for which Reliefis Requested: Reliefis requested from performing the Code-required VT-3 visual examination of the above identified containment seals and gaskets.
IV. Rasis for Relief: Maintenance personnel, trained in the installation of seals and gaskets and the proper assembly of these closure devices, examine the seals and/or gaskets as well as the mating surfaces during the assembly process. Appendix J leak rate testing afler re-assembly then provides a positive confirmation ofleak tight integrity. In all practicality, a VT-3 visual examination of these seals and gaskets would then require these joints to be disassembled since many of the associated surfaces are normally inaccessible. The ASME Code Committee has recognized that disassembly of the joints in order to perform visual examinations was not warranted, and the 1998 Edition of ASME Section XI removed this examination requirement.
The proposed alternate examination (Appendix J, Option B) provides a periodic, non-intrusive test method which will ensure that the integrity of the seals and gaskets is being maintained. As noted in 10 CFR 50, Appendix J, the pr.rpose of the testing is to ensure that leakage of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with seal assemblies remains below established limits. Damage to seals of gaskets, which could afTect containment integrity, is best detected with this type test and will be performed as follows:
l RR-MC-1 Rev.6 Page1of3                                                                                               i

Electrical Penetrations And Containment Penetrations W hose Design Incorporates Resilient Seals, Gaskets, Or Sealant Compounds Those penetrations that are not disassembled during the 10-year interval will receive an Appendix J, Option B test at least once in the 10-year interval. For those penetrations that are disassembled or opened, an Appendix J test is required upon final assembly prior to start-up. Additionally, if a seal (including 0-rings or gaskets) is reinstalled or replaced, it will be visually inspected by maintenance personnel before re-assembly or closure. These tests and inspections will assure the leak tightness of primary containment and provide an acceptable level of quality and safety.
Airlocks and Containment Equipment flatches The personnel airlocks are opened as needed during maintenance outages and refueling outages. Prior,to final closure, the accessible portions of gaskets and the door sealing faces are inspected for damage that could afTect the leak tightness of the seal. If gasket reinstallation is performed or replacement is necessary, the existing or new gasket will be visually inspected by maintenance personnel before re-assembly or closure. Door seals will be tested, as required by Technical Specifications, in       I accordance with Appendix J within seven days of opening and once every 30 days           I during periods of frequent opening.
l The containment equipment hatch is normally removed during refueling outages. If         I gasket replacement is necessary, the new gasket will be visually inspected by maintenance pe sonnel before re-assembly or closure.               Prior to establishing containment integrity following the refueling outage, the containment equipment hatch is leak rate tested in accordance with Appendix J.
These tests and inspections will assure the leak tightness of primary containment and provide an acceptable level of quality and safety.
V. Alternate Examination: Leak-tightness of the seals (including 0-rings) and gaskets will be confirmed in accordance with 10 CFR 50, Appendix J as described above. If a seal (including 0-rings) or gasket is replaced, it will be visually inspected by maintenance personnel before re-assembly or closure. Also, an as-left Appendix J leakage test will be performed after installation to ensure leak-tightness.
VI. Justification for Granting Relief: Functionality of containment penetration seals and gaskets (including those of electrical penetrations) will continue to be verified by Appendix J testing as required by 10 CFR 50, Appendix J. All containment devices that have seals or gaskets, and are bolted type connections, fall within the scope of the Plant Hatch Appendix J leak-rate testing program, and Option B requires testing at least every 5-years and afler re-assembly if disassembled. The alternative RR-MC-1 Rev.6 Page 2 0f 3

f I
l examinations are adequate to ensure integrity of containment penetration seals and gaskets, and will provide an acceptable level of quality and safety. Therefore, relief should be granted per 10 CFR 50.55a(a)(3)(i).
VII. Implementation Schedule: This relief request will be implemented in accordance with the expc.iited examination schedule for MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI Interval.
VIII. Relief Reauest Status: Submitted to NRC for review and approval.
l l
\
l l
i RR-MC-1 Rev.6 Page 3 of 3

1 l
l l
l l
Attachment  l RELIEF REQUEST RR-MC-2

p SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-MC-2
   . I. System / Component (s) for Which Relief is Requested: All Class MC, Subarticle IWE-              ,
2200(g), preservice exammation requirements of reapplied painted or coated containments.
f
                                                                                                          ] -
1 II. Code Requirement: The 1992 Edition, with 1992 Addenda of ASME Section XI, Subsection IWE-2600(b), requires that reapplied paint and coatings systems shall be examined ni
!.        accordance with IWE-2200(g). lWE-2200(g) requires that when paint or coatings are j         reapplied, the condition of the new paint or coating shall be documented in the preservice l         examination records.                                                                            ,
l    111. C_ ode Requirement for Which Reliefis Requested: Reliefis requested from the requirement to perform a preservice inspection of new paint or coatings.
IV. Basis for Relief: The paint and coatings on the containment boundary were not subject to l         Code rules when they were originally applied and are not subject to ASME Section XI rules        l
!         for repair or replacement in accordance with IWA-4111(b)(5). The HNP coatings program,           I l
which is controlled in accordance with a quality assurance program which meets the l         requirements of 10 CFR 50, Appendix B, verifies the adequacy of the applied coatings.
l         Recording the condition of reapplied coatings in the preservice record does not substantiate l
the containment structural integrity. However, SNC acknowledges that the quality and integrity of applied coatings is relevant to the containment's functional integrity. This i         assurance is best accomplished by visually inspecting the coating, which is accomplished l         through the HNP " Protective Coatings Program" Should deterioration of the coating in the reapplied area occur, the area would require additional evaluation regardless of the preservice record. Recording the condition of new paint or coatings in the preservice record does not increase the level of quality and safety of the containment.
In NRC SECY 96-080 dated April 17,1996 the Commission responded to Comment 3.2, which involves IWE-2200(g), by stating, "In the NRC's opinion, this does not mean that a visual examination must be performed with every application of a paint or coating. A visual     J l         examination of the topcoat' to determine the soundness and the condition of the topcoat
!         should be sufficient." That visual examination is currently accomplished through the HN'P
          " Protective Coats Program. "
V. Alternate Examination: Reapplied paint and coatings on the containment vessel will be examined in accordance with the HNP _" Protective Coatings Program." If degradation of coatings is identified, additional measures will be applied to determine if the containment pressure boundary is affected. Although repairs to paint or coatings are not subject te the repair / replacement niles of ASME Section XI based on the Code's response to Inquiry 9'i-22, repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules.
RR-MC      Rev.6                                                                                                  i
    -Page 1 of 2

l VI. Justification for Granting Relief; Coatings inspection programs                  i    currently restor to its original condition thereby providing adequate ass f          alternative provides an acceptable level of quality and safety.
f 1
This relief request will be implemented in accordance with the       '
VII. Implementation Schedule _;                                                       i (B) expedited examination schedule for MC components as specified in 10CFR during the Third Ten-Year ISI Interval.
Submitted to NRC for review and approval.
VIII. Relief Request Status:
RR-MC-2                                                                                          ,
Rev.6 Page 2 0f 2
  ~                                ~~                 _

F i
Attachment RELIEF REQUEST l
RR-MC-3

SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-MC-3 I. System /Comoonent(s) for Which Relief is Requested: All Class MC, Subarticle IWE-2500(b), visual examination per Table IWE-2500-1 of painted or coated containment components prior to removal of paint or coatings.
II. Code Requirement: The 1992 Edition, with 1992 Addenda of ASME Section XI, Subarticle IWE-2500(b), requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal.
III. Code Requirement for Which Reliefis Requestegi: Reliefis requested from Subarticle IWE-2500(b), which requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal.
IV. Basis for Relief: 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303) to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when performing containment examinations. Paint and coatings are not part of the containment pressure boundary under current Code rules because they are not associated with the pressure-retaining function of the component. The interiors of containments are painted to prevent corrosion and to aid in contamination removal efforts. Paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME Section XI mies for repair or replacement in accordance with IWA-4111(b)(5). Deterioration of the paint or coating materials, e.g.,
flaking, scaling, etc., on containment would be an indicator of potential degradation of the containment pressure boundary. Additional measures would be employed to determine the nature and extent of any degradation, if present. The application of ASME Section XI rules for removal of paint or coatings when unrelated to an ASME Section XI repair or replacement activity, does not provide a compensating increase in the level of quality and safety.
i V. Alternate Examination: Paint and coatings on the containment vessel will be examined in accordance with the HNP " Protective Coatings Program." If degradation of coatings is        j identified, additional measures will be applied to determine if the containment pressure boundary is affected. Although repairs to paint or coatings are not subject to the repair /
replacement rules of ASME Section XI based on the Code's response to Code Interpretation:
XI-1-98-14, repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules.
t l
l 1
RR-MC-3                                                                                            l Rev.6 Page1of2

VI. Justification for Granting Relief: Coatings inspection programs currently restore the coating to its original condition thereby providing adequate assurance of the integrity of the coating.
As a result, relief should be granted under 10 CFR 50.55a(a)(3)(i) because the proposed alternative provides an acceptable level of quality and safety.
VII. Implementation Schedule: This relief request will be implemented in accordance with the expedited examination schedule for MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI Interval.
VIII. Relief Request Statuj: Submitted to NRC for review and approval.
RR-MC-3 Rev.6 Page 2 of 2

Attachment RELIEF REQUEST RR-MC-4 i
c O
I

l l                        SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2
!                                   THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-MC-4 l
I. System /CompAnfnt(s) for Which Relief is Requested: All Class MC, Paragraphs IWE-
)       2420(b) and IWE-2420(c), successive examination requirements for components found acceptable for continued service.
II. Code Requirement: The 1992 Edition, with 1992 Addenda of ASME Section XI, requires
!       that when component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs in accordance with Anicle IWE-3000, and the component is found to be acceptable for continued service, the area containing such flaws, degradation, or repairs shall be reexamined during the next inspection period.
III. Code Requirement for Which Reliefis Requested: Reliefis requested from the requirements of Paragraphs IWE-2420(b) and IWE-2420(c) to perform successive examination of camponents that have been repaired.
IV. Basis for Relief: The purpose of a repair is to restore the component to an acceptable condition for continued service in accordance with the acceptance standards of Article IWE-3000. When making repairs, paragraph IWA-4150 requires the owner to conduct an evaluation of the suitability of the repair including consideration of the cause of failure.
Successive examinations afler repair do not provide an additional safety benefit.
Repairs are performed in accordance with IWA-4000, the intent of which is to use the construction code to restore the component to its original condition where practical. If a repair has restored the component to an acceptable condition, successive examinations are not warranted. If the repair was not suitable, then the repair does not meet Code requirements and the component is not acceptable for continued service; further repair work would be       ,
necessary. No similar requirement is found for ASME Class 1,2, or 3 Section XI repairs.
Conducting successive examinations on components that have been repaired would result in hardship without a compensating increase in the level of quality and safety. Additionally, if the repair area is subject to accelerated degradation, the repair would require augmented examination in accordance with Table IWE-2500-1, Examination Category E-C.
V. Alternate Examination: Repairs will be performed in accordance with IWA-4000 to restore the component to its original condition and successive examinations as required by IWE-2420(b) and (c) will not be performed. Successive examinations will continue to be done on those flaws or areas of degradation which have been accepted for continued service by evaluation.
l 1
l RR-MC-4 Rev. 6 Page 1 of 2 L

VI. Justification for Granting Relief: Repairing components to restore the component to its original condition provides adequate assurance of the integrity of the repair. Compliance with the specified requirements of this section would result in hardship or unusual difliculty without a compensating increase in the level of quality and safety; therefore, relief should be granted under 10 CFR 50.55a(a)(3)(ii).
VII. Imolementation Schedule: This relief request will be implemented in accordance with the expedited examination schedule for MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI Interval.
VIII. Relief Request Status: Submitted to NRC for review and approval.
l l
RR-MC-4 Rev.6 Page 2 of 2

r l
l l
l l    Attachment RELIEF REQUEST l l                l
;     RR-MC-5 l
l I
i i
l i

SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2 THIRD 10-YEA'R INTERVAL REQUEST FOR RELIEF NO. RR-MC-5
: 1. System / Component (s) for Which Reliefis Reauested: All Class MC, Subsection IWE-1241 surface areas requiring augmented examinations per Category E-C, Item Number E4.12, in accordance with IWE-2500 (c).
II. Code Requirement: The 1992 Edition, with 1992 Addenda of ASME Section XI, Subarticle IWE-2500 (c)(3) requires one foot grids be used when ultrasonic thickness measurements are performed on augmented surface areas. Subarticle IWE-2500 (c)(4) requires that the minimum wall thickness within each grid be determined and the location marked such that periodic reexamination of the location can be performed.
III. Code Requirement for Wiich Reliefis Requested: Reliefis requested from using one foot grids exclusively for augmented examination areas, the requirement to determine the minimum wall thickness within each grid, and to mark the location such that periodic reexamination of the location can be performed.
IV, . Basis for Relief: A griding si7e of exclusively one foot square is not sufficiently flexible to accommodate the various surface con 6gurations listed in Subarticle IWE-1241 (a) and IWE-1241 (b). Also, the methods described in IWE-2500 (c)(3) and IWE-2500 (c)(4) will produce single point thickness readings. Numerous readings would be required to identify the ininiinw thickness point within each grid and periodic re-examination would only monitor that single point. This single point may not be the area most susceptible to accelerated degradation. The Flow Accelerated Corrosion programs presently in place in the nuclear industry have proven that thickness readings taken at grid intersections are efTective in condition monitoring of balance-of-plant piping. Also, taking numerous ultrasonic thickness readings within a grid, which has not exhibited evidence of degradation, would cause an undue hardship without a compensating increase in the level of quality and safety.
V. Alternate ExaminationE ASME Code Case N-605 will be used for examination of all areas requiring augmented examination. Copy attached for reference.
l VI. Justi0catig_n for the Granting of Relief: The condition monitoring approach detailed in ASME      j Code Case N-605 will provide a superior indication of overall component degradation and         l has been approved by the ASME as an acceptable alternative to IWE-2500 (c) for augmented        !
examination of surface areas.                                                                   !
l I
I l
I RR-MC-5 Rev.6 Page1 of2

VII. Imolementation Schedule:       The subject alternatives will be implemented in accordance with the expedited examination schedule for Class MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI In*< rval.
VIII. Relief Request Status: Submitted to NRC for review and approval.
RR-MC-5 Rev.6 Page 2 of 4

i CASE N-605 Casas OF AshtE BOILER AND PILE $NORE VFJER CODE Approves poen: ammesh a, toes Gee Numeric Jndes ser expiretion end any reeNemaefan detes Case N405 Altsemative to the Requiremsets of IWE.2906(c) for Augmented Esaadaniles of Sustace Areas Secties XI. Divinies I Wry: What akernative to the requirements of IWB-2500(c)imay be used for augmented emanunation of swface areas?
Reply: It is the opinion of the Comminee that the following requirements may be used as an ahernative to the requirements of IWE-2500(c) fur augmented esamination of surface areas.
(a) Areas accessible frorn both sides shall be visually examined on both sides using VT-1 Visual Examination Method.
(b) Areas accessible from one side only shall be examined for wall thinning using an ultrasonic thickness enessurement method in acconlance with T-544.
(c) When ultramnic thickness enessurenrats are per-formed, grids shall be used. Orid line spacing shall comply with the seguirements of Table -2500-2. The nurnber and location of the gnds shall be deterrnined by the Owner. brations of grid line intersections to be exarni ed may be marked on containment surfaces in lieu of enarking grid lines.
(d) Ultrasonic thickness enessurements shall be per-formed to determine the minimum wall thicknesses at locations specifwd in Table -2500 2, Minimum wall thickness locations and locations of examined grid line intersections shall be marked such that periodic reenamination of these locations can be performed in accordance with the requirements of Table IWE-2500-1 Examination Category EC.
l l
l 1037 I
RR-MC-5                                                                       l Rev.6 Page 3 of 4                                                                   ;
i j

i L
l l
i i
CASE (continuedi l           N-605 CASES OF AShdE IKWAM AND FlumWRE WEstiEL CO!)E I
[                                                                       TABLE -2500-2 ULTRASONIC THICKNESS MEASUREMENTS FOR AUGMENTED EXAMINATIONS Augmenled Area Size (Contiguous)                                    Examination Requirements 5100 square feet                                  100% of Grid Line Interwctionst e, n A s l                                         a100 square feet                                  100% of Grid Line intersections , ie, e, a 6 NOTE 3:
(1) The nuniher, location, and size of areas to be esammed shall be determmed by ths Dener.
(2) Grid line spacing shall not escoed 12 in, and need not be isss than 2 in.
(3) Grid lire spacing shall be wiected such that a mimmum of 100 rwasurements are ot>tained from within each augmented esamination area, unless this requires selecting a grid line spacmg of less than 2 in.
(4) in 16eu of examining 100% of the grid line Interwctions within the augmented esamination area, an
,                          alternate esamination plan tnay be dewtoped as follows:
tal A sample area from within the augmented esamination area may be selected for esamination. Tim locaGen and size of the sample area shall be determined by the Owner, but shall consisl of was subsect to the most severe service conditions within the larger augmented examination ma. 300%
of the grid line interwctions within the sample area shah be esamined. and cred line spacing shall be selected such that a minimum of 100 memurements are obtaired from withm the sample area.
(b) If the sample area escaed6100 contiguous square fret, the Owner may dewtos a sampimg plan for examination of grid line internestions within the sample area. Locations of ultrasonk thckness measurements to be taken at grid ime intersections shall tw selected at randorn throughout the sample area. Tiw mmimum numter of rneasurements shall be 100 or shall be sufficient to ensure at least a g'A% confidente level that the tNcknrst of the baw metal 6s reduced by no more than 10% of the normnal plate thickness at 95% of thi grid hne intersecteorG within the sample area, wNehever is greater, (c) If any ultrasomt thackerst measurements withm the sample area reveal that the thickness of the base swtal is reduced by more than 10% of the nommat plate thickness, all remaining 9.o line intersect 6 ens within the sampie area stall be enemined, and additional UT esaminations from outside of the sample avea shall be required. These additional UT esaminations shall be performed on l
another area from within the larger augmented examination area that is at lent as large as the          j infinal sample area. If any of thew sutneguent esaminations eeveal that the thickness of the baw        '
l                                metal is reduced by more than 10% of the nominal plate thkhness, addttional areas from withm j                                the larprt msgmented examination area shall be examined until subsequent esaminations of additional areas rewal no pesurements where metal loss entseds 10% af tte nominal plate tNckness, or until the ent6re augmented esamination area has been esammed.
(5) When an ultrahome thochress armurement performed at a grid ime intersection rewals that lie thkkness of the bau metal na reduced by more than 10% of the nommal plate tMckness, the mmimum wall l
l thickness shah be determered and located within each edioining gr6d (6) hiessurements need not be obtamed at locations where obstructions 6nterfere with prid ime intersections.
1038 RR-MC-5 Rev.6 Page 4 of 4

Attachment RELIEF REQUEST R R-MC-6

SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-MC-6 I. System / Component (s) for Which Relief is Requested: All Class MC pressure retaining I
bolting requiring visual examination (VT-1) per Category E-G, item Number E8.10, in accordance with Subarticle IWE-3515.1.
H. Code Reauirement: The 1992 Edition, with 1992 Addenda of ASME Section XI, Subsection IWE-3515.1 requires that bolting material be examined in accordance with the material specification for defects which may cause the bolted connection to violate either leak-tight or structural integrity.
III. Code Requirement for Which Reliefis Requested; Reliefis requested from the requirement to perform visual examination (VT-1) in accordance with the bolting material specification.
IV. Basis for Relief: The bolting material specifications provide guidance relative to base material properties and related fabrication discontinuities.       For inservice bolting, examination guidelines and acceptance criteria must be specific to inservice discontinuities which are relevant to continued service.                                                                        1 V. Alternate Examination: Bolting material will be examined in accordance with the inservice standards of the 1992 Edition, with 1992 Addenda of ASME Section XI, Subarticle IWB-3517.1 Standards for Examination Category B-G-1, Pressure Retaining Bolting Greater Than 2 in. in Diameter, and Examination Category B-G-2, Pressure Retaining Bolting 2 in. and               i Less in Diameter.
VI. Justification for Grantina Relief: Since IWB-3517.1 is a standard specific to inservice discontinuities and presently used for visual examination of Class 1 pressure retaining bolting, it is more than adequate for examination of Class MC pressure retaining bolting. This standard is also one that p! ant personnel are presently fa niliar with. As a result, relief should be granted under 10 CFR 50.55a(a)(3)(i) because the proposed alternative provides an acceptable level of quality and safety.
VII. Implementation Schedule: This relief request will be implemented in accordance with the expedited examination schedule for MC components as specified in 10CFR50.55a(g)(6)(ii)(B) during the Third Ten-Year ISI Interval.
VIII. Relief Request Status: Submitted to NRC for review and approval.
RR-MC-6 Rev.6 Page1 ofI

i f
1 Attachment  l l
RELIEF REQUEST i RR-23 1
I

SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2                                             l THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-23                                           i l
I. System / Component (s) for Which Relief is Requested: Rotation of Serviced Snubbers and Pressure Relief Valves within the scope of the ISI Program for the purpose of testmg.           i l
II. Code Requiremen_1: Article IWA-7000 of the 1989 Edition of ASME Section XI contains             l the requirements for replacement activities including the completion of Form NIS-2,             I
         " Owner's Report for Repairs or Replacements".                                                  l l
III. Code Requirement from Which Relief is Requested:                 Relief is requested from the requirements ofIWA-7000.
IV. Basis foi Relief:        ASME Code Case N-508-1 provides an acceptable alternative to              l IWA-7000.
V. Altemate Examination: Southern Nuclear Operating Company will comply with the                   ;
requirements of Code Case N-508-1 in lieu of IWA-7000. Copy of Code Case N-508-1 is             1 attached for reference.
VI. Justification for Granting Relief: The ASME Section XI Committee evaluated the proposed            ;
alternatives contained in Code Case N-508-1 and determined that they are acceptable for         '
replacement activities involving snubbers and relief valves that are rotated from stock and installed on components for the purpose of testing. The implementation of Code Case N-508-1 is administrative and will not affect the level of quality and safety, nor decrease the margin of public health and safety. Therefore, it is requested that the proposed alternative    j be authorized pursuant to 10 CFR 50.55a(a)(3)(i). While the cost savings associated with Code Case N-508-1 have not been quantified as a Cet Beneficial Licensing Action item, its implementation is consistent with the intent to elimmate nonbeneficial work activities and their associated costs.
VII. Implementation Schedule: The relief request is applicable for the Third 10-Year ISI Interval.
VIII. Relief Reauest Status: Submitted to the NRC for approval.
l i
l i
l RR-23                                                                                                  1 Rev 6 Page 1 of 2

o CASE N-508-1 CASES Or A5asE 80tLA N AND PREaSURE VESSEL ODDE Approval Date: May 11, 1994 See Numene kuten 66r espirecion and any reemm& deres.
Case N-508-1                                                    (a)Iteans being removed and installed shall be of Rotaties of Servleed Seebbers and Fransure                   the uma design and consouction; Rausf Valves for the PurPase of Testing                         (6) Items being removed shall have no evidence of Eare8== XI, Division 1                                       failure at the tirne of renwval; (c) Items being rotated shall be removed and instatied only by mechanical means; Inedry: What ahernative rules to those stated in             (4) leems being installed s'nan previously have been IWA-4000 (TWA-7000 for Editions and Addenda prior            in service; to the 1991 Addenda) may be used when, fur the                  (a) Preservice inspectioas and pressure tests shall be purpose of testing, snubbers and pressure relief valves      performed as nquired by IWA-4000 (IWA-7000 for are rotated from stock and installed on components           Editions wid Addenda prior to the 1991 AMenda);
(including piping systems) within the Section XI .               (/) De Owner shall maintain a method of tracking      j boundary?                                                    the items to ensure traceability of inservice inspection  I and testing records; l
(g) Use of an NIS-2 form is not required eacept as Reply: It is the opinion of the Comunittee that, as       provided in (i) below; an ahernative to the provisions of IWA-4000                     (A) Testing of removed snubbers and pressure rehef (IWA-7000 for Editions and Addenda prior to the             valves, includmg required sample expannons, shall be 1991 Addenda) and for the purpose of testing, snub-          perfarned in accordance with the Owner's test program; bers and relief valves may be rotated from stock and             (i) Repair or replacement of removed items, when installed on components (including piping systems)          required, shall be performed in accordane with within the Section XI boundary provided the following        IWA-4000 (1WA-4000 or IWA 7000 for Editions and requirements are met                                        Addenda prior to the 1991 Addenda).
i 739 l
l RR-23                                                                                                                            j Rev,6                                                                                                                            i Page 2 of 2 I
I

l l
l I
l l
Attachment  .
1                  1 J
RELIEF REQUEST RR-24 I
i I
J 1
l I
1 i
i
: t.                l

SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNITS 1 AND 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-24 I.      System / Component (s) for Which Relief is Reauested:            RPV Support Skirt Weld Examination Category BeH, Item B8.10 for RPV Integrally Welded Attachments.
II. Code Reauirement: Table IWB-2500-1 of the 1989 Edition of ASME Section XI, Examination Category B-H, Item B8.10 requires a volumetric or surface examination, as applicable, per footnote 4 of Examination Category B-H. Footnote 4 allows a volumetric examination in lieu of a surface examination for the configuration shown in figure IWB-2500-14 of the code.
l III. Code Reauirement from Which Relief is Reauested: Reliefis requested from performing the
        . Code-required surface examination of the RPV Support Skirt weld.
IV. Basis for Relief: Code Case N-323-1 which was approved December 31,1996, by ASME l
addresses an alternative to tne requirements of Examination Category B-H when only one side of the weld is accessible for examination. This same alternative was incorporated into the 1997 Addenda of ASME Section XI Code, not as an alternative, but as the code requirement listed in Table IWB-2500-1, Code Category B-K, Item B10.10 for Pressure Vessel Welded Attachments. A copy of Code Case N-323-1 is provided as an attachment to this request fm relief.
; V.      Alternate Examination: Southern Nuclear Operating Company will comply with the l
requirements of ASME Section XI, Code Case N-323-1 for the configuration shown in figure 1 of the code case.
VI. Justification for Grantine Relief: At both Hatch units, examination area C-D of figure IWB-2500-13 is not accessible for meaningful examination because of location and geometric configuration of welded areas. Hatch Unit I has no access through the support skirt; therefore, the inside surface of the reactor vessel support skirt is totally inaccessible.
For Hatch Unit 2, physical access by the examiner is restricted because of high radiation and obstruction due to CRD housings and its support system. Magnetic particle techniques cannot be used due to the space restrictions. The use of dye penetrant would require a very thorough cleaning of the weld and adjacent base material to remove rust and scale. The preparation of the weld would potentially have to be performed using techniques such as wire brushes since power tools may not fit into the limited area. In a previous Hatch Unit 2 outage, Health Physics indicated that a dose rate in this area was approximately 180 mr/ hour; however, it is very difficult to quantify the total exposure for an examination. The combination of these factors prevents these welds from being examined from inside the
(        support skirt.
RR-24 l Rev.6 Page 1 of 5 i

VI. Justification for Grantina Relief (continued):
The proposed alternative testing requirements have been evaluated by the ASME Code Committee and have been deemed technically acceptable. Thus an acceptable level of quality and safety will have been achieved and public health and safety will not be endangered by allowing the proposed alternative examination in lieu of the Code requirements. Therefore, it is requested that the proposed alternative examinations be authorized pursuant to 10 CFR 50.55a(a)(3)(i). By impicmenting the alternative examinations; cost savings, personnel radiation dose, and outage time can be realized by Southern Nuclear Operating Company at Plant Hatch.
VII. Implementation Schedule: The proposed alternative examinations, as noted in the Code Case, will be performed during the Third 10-Year ISI Interval.
Vill. Relief Request Status: Submitted to the NRC for review and approval.
RR-24 Rev.6 Page 2 of 5

7 i-CASE N-323-1 CASES OF ASME BOBLER AND PItt34LmE VBAARL(X)DE Approwel Deco: December 31, 1998 goe keeric huhrs kw espirerian and any reemrmeren deren.
Case M1 Akaramuse Fra-alm a a=       for Welded Ash to Pressure Vesamis 5arelma XI Diduire 1 hiqudry: Mat ahermative to the regererneess of Ex-
               ==ie Category B-K of the 1995 AMaada or Es-anunsmon Category B-H from 25 Winner 1931 Ad-danda, through the 1995 twoon inay be performed for welded enachments to pres =re ve mis as shown in Figs. I and 2 when ordy ons side of the anachrnent weld is accessible for enarmnation?
Aeply? It la the opinion of the Comnuttee that as an alternative to the requirementa of Emanunation Cat-egury B-K of the 1995 Addenda or Examination Case-gory B-H fann W' mier 1991 Addenda to the 1995 Ednon:
(a) for the con 6guranon shown la Mgs. I and 2, a surface esamination from the accessible side of the attachancat $ weld may be performed or, (6) for the coe6guration shown in lig. 2, a volurnstric examinatium of Volume A-B C-D from the ac==ible side of the attachment weki may be performed.
l                                          m RR-24 Rev.6 Page 3 of 5

CASE (continued)
N-323-1 CASES OF A3Mg BOILF.R AND PBSeming vaango crujer, N
                                                                                      'N            .
l I
g       l l88 -
l ol
                                                          ,77 6/
Ib >Y         ,
C       0                        Da *
                   '                                      '''*-            ~ ,        ,..
u, (m.
_ ~ . ~
                                                   -w.w FIG.1 WELDED ATTACHMENT m
RR-24 Rev.6 Page 4 of 5

1
                                                                                             \
l CASE (continued)
N-323-1 CAMS OF ASME SOELSE AMD FIRSABURS VEmuRL ODDE                              l g
                    /                                                  '
                  /                                                                          1
                /                                                                            1 I<
l l
                                                                 % Cast,fo'Oed. er weld butt up alischment 1
                                                                      /3in.
C                9
* 6Wk
                '               Comumlerentel                           f weld                                 f f                         g f IW9 Soundery 1
                                                           .s
                                      .-u,a i
FIG. 2 WELDED ATTACHMENT m
l l
l I
1 RR-24
! Rev.6 Page 5 of 5

l i
i Attachment RELIEF REQUEST
               )
RR-27 1

\                                                                                                         )
i SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNITS 1 AND 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-27 l
I. System / Component (s) for Which Reliefis Requested: This request for relief proposes an alternative to the requirements of IWA-7000 when material meeting the definition in IWA-9000 is purchased, exchanged, or transferred between nuclear plant sites.
l II. Code Reauirement: Article IWA-7000 of the 1989 Edition of ASME Section XI contains l          the requirements for Code applicability of replacement items.
l   III    Code Requirement from Which Relief is Reauested:                Relief is requested from the requirements ofIWA-7000 and as an alternative it is proposed that ASME Section XI Code Case N-528 be utilized.
IV. Basis for Relief: ASME Code Case N-528 provides an alternative to the administrative requirements of Section III imposed by IWA-7210. SNC has reviewed the code case and has determined its implementation will substantially reduce nonbeneficial work activities required by IWA-7000.
V. Alternate Examination: Southern Nuclear Operating Company will comply with the requirements of Code Case N-528 in lieu ofIWA-7000.
VI. .lustification for Granting Relief: The ASME Code Committee evaluated the proposed alternatives contained in Code Case N-528 and determined that they are acceptable for           4 replacement activities invoking material meeting the definition of IWA-9000. The implementation of Code Case N-528 will not affect the level of quality and safety, nor decrease the margin of public health and safety. Therefore, it is requested that the proposed   I alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i). While the cost savings           )
as sociated with Code Case N-528 have not been quantified as a Cost Beneficial Licensing Action item, it's implementation is consistent with the intent to eliminate nonbeneficial work activities and their associated costs.
VII. Imolementation Schedule: This request for reliefis applicable to the Third Ten-Year ISI Interval.
VIII. Relief Reauest Status: Submitted to NRC for review and approval.
I I
!   RR-27 Rev.6 Page 1 of 2
;                                                                                                          1 t                                                                                                         ;

I CASE N-528 CASES OF A$ME DOtLEM AND PRESSURE VFDEX CtNME Approvat Date: Deeseber it 1994 See Numerec Jndes hw expiren'on and any reeMirmation deren.
Case N 528                                                          (b) Since n:ceipt by the supplying plant, the material Purchama, haang. . er Transfer of Material                      was not placed in service, welded, brazed, no subjected Between Nacient Plasd Sites                                     to any operation that might affect the mechanical proper-Secties XI, Diviales 1                                          ties of the material (e.g., heat treatment or fanning).
(c) Documentation required by NA 3700/NCA-3800 inquiry: As an thernative to the administrative re-         shall be provided to the receiving plant with the material.
quirements of Section m' imposed by IWA-4170                        (d) When the material is fabricated in accordance (IWA 7210 in Editions and Addenda prior to the 1991             with specine dimensional requirements in addition to Addenda), what requirements apply to Owners when                those provided in a national standard (e.g., nonwelded material meetmg the dennition in IWA-9000 is pur-               valve bonnet or nonwelded pump casing), the evaluation chased, exchanged, or transferred between nuclear               of suitability required by IWA-4150 (IWA-7220 in plant sites provided the following requirements are             Editions and Addenda prior to the 1991 Addenda) shall rnett                                                           include an evaluation of the material for its intended application, including any differences that might affect Reply. It is the opinion of the Conumuse that, as fwm, 6t, w function.
an alternative to the administrative requirements of                (c) Tbc receiving plant shall obtain certification for Section III imposed by IWA-4170 (IWA-7210 in Edi-               the following:
tions and Addenda prior to the 1991 Addenda), mate-                    . f) h supplying plant purchased the material in accordance with NA-3700/NCA 3800 and maintained rial enseting the de6nition in IWA-9000 may be pur-it in accordance with their Quality Anurance Program.
chased, exchanged, or transferred between nuclear plant sites, provided the following requirements are              . (2) Since receipt by the supplymg plant, the mate-g                                                               nal was not placed in service, welded, brazed, nor subjected to any operation that rnight affect the mechani-(a) Materials shall have been furnished to the supply-cat            ca    the snatW (e.g., heat trentrnent w lag plant in accurdance with NA-3700/NCA 3800.                  forming).
(/) Use of this Cane shall be documented on the
            ' Aanumsamive seguu nmaa eer., ei pm as. et a certisc.= et     NIS-2 for repaar or replacement using material obtained Authorizadan er Quainy $yunn Cortdam Materiald                  in accordance With the provisions of this Case.
4 1
not i
l I
RR-27 Rev,6 Page 2 cf 2

Jl l
                                                  /_,j b l
u               l1' \-l f                  /I/                                l       f af!
J                                                                                    a_
N
                                                                                                                                                   -                                   .                                         M                                        .
N               N                 N O                 O                              B      .                                         E                                      :
N                    N                   O               O                 I I                               S                                               T                                      S
:                             N                  O                    O                                   I                                    T                                        _
S                                      D N               N               O                                                           I T                 T P                 P                              O     .
O              O               I I
T I
T T
P                P                 I I
R Y                                      I I              I T
T                  P                    P                  I I
R                  C                                                                              S                                      A T                               P                   I                   I                   R                R                 C P             P                I                                                                            C                                   S R                   R                   C                                   S I
R I
R                R C                  C                    C                  S                S E                  E                 E D
S C             C                S                   S                   S                   E                C                  D                                                       ;                                       T S             S E
E D
E D
E D
D N
E D             D                                                                                                                                                                                                               E 2                2 7
F 2
F M
U                                          u8 t8 2
2                 2 F
2 F
F                 F K
C                                                /
2 O                                                           m 2                                 F                                                                                             K                                                                                                                                        .
F             F                                                                                             K                                     S                                                                                                                            z K                 S                  S                  A                                     .
D K                K                    K                S                                    A                                                                                                                                        . _    /
K                                    S                    S                A                 A                  T                  T                                                                                                                            6 K                                  S                 A                   A                                  T                                                                            . _
S              S A
A                 T                   T T                                                                                                                                  R                                         :       0 A
T             T T
T                  T K
T K                                     .                                   A                                         N S                                                             T                   T T
K                 K                  D                  D                                                                          E                                        I 2
E                       T T
K                K                   K                  D                D                                                                            .
L                                         M T             K                                     D                    D                                                                                                                                                   C                                                   s D         K D                   D                                                                                           A                   A R
                                                                                                                                                                                                    .                                                                            D       ;
O         D A                   A A                A R                  R                                                                                            U                                          A i
P A                                                      R                                                                                              .
N C          A             A                    R                  R                  R                                                                         A R                                                                                            A                   A                   A         _                           .
R W                                                               A                   A A
A                 A            _A                                             _
A                                     A E                        A                                                                                                                                                                           .
A                                   A A              A                                                                                                                                                                                                                                                                 _
N                                                                                                                                                                                                     .                                                                   -        _
F                                       .
F                  C F               F                   C F                  F                 C                C                                                                             .
F                                      C L          F C
F C                   C                  C R                   R                  R D                                       .                      C D
t e
                                                                                                                                                                                                                                                                                                 ^
I R                 R               O                   D                  P                                                              D          e         P A                                               R                   R                 D                 D                P                  P                                                           .                                n         O R               R                   D                   D                  P                P                                                                                                                                a         R V           D               D P                   P                   P                                                                                                                                   .
C                    P A          P a                                                            Q          r3 a                                                          .                               i a                a                a_                                                                                    3                       l          F C
a                   a                   a                                                                                                                                   t F             R          g m
a                                                                                                                                                                                                                E                               l X            w                   i E            e       R           f D          r i        D            e N                    P R
S E
a                    I t
e a
m         t
                                                                                                                                                                     ._                                                                                 l           o G                                                                                     ._               .
                                                                                                                                                                                                              .                                 r e       i           N A                                                _                .-                                                                                                                                                                    n       f o
P           _             .
e          e        D i                   a                                                                         G         R 2                     -                                                           .
2                 2 i
L                                      S a                                                                        .                                                                                 .
C        a i
                                                                                                                                                                      ._                     E                                      N A         .
i
                                                                                                                                 ._                                                           V                    .                 O P                               _
E                                      I F        ._               .
2                       L                  .
E          T
                                                                                                                 .                 2                 a                                          /                   .F               C 2                  a                                                                       .
U                                -
i_                                                      .
N                                                                     n a                                                                          .                                                                       ._
O                                     A                               a P
U
                     .               a_                    .
I T                  i_                T S                     o         P a
                                       .                                                                                                                                                                                                                     f S         ._
i                 a_                      A                   .
N                      n         t C                                   I                     I           u 2                a
                                                                                                                                                                          .                                            .                                                 o a
O                                   L         l p        d
                                                                                                  .                                                                        .                        L                  .
A           e          o        l o
I         b           r         F E                  .                           a         P
                                                                                                                                                          .                                                                   1          C          L                      s L                  . F          E                     s n
I w          n F                                   P          e         i          i a
S         N           a          t Y                  ,                /
e t
n          n R                                   S         t           o           o a         C          C
                                                                                                                                                                              .                         A                                  E
                                                                                                                                          .                                                                                . N            T         r e                     i
                                                                                                      .                                                                       .                         M                       E                     n i
c            c
                                                                                                                                                              .                                          I                                   O        e           n            n         _     _
                                                                                                                                                                               .                         R C            N G                 E           E
_                      P                  .F D            .
N                               .
A           ._}}