View source for HL-5839, Forwards Three New & One Revised Relief Requests for Third 10-year Interval ISI Program for Plant,Developed to Clarify Documentation Requirements,To Propose Alternate Exam Requirements IAW ASME Code Cases N-598 & N-573

{{Adams
| number = ML20212D029
| issue date = 09/16/1999
| title = Forwards Three New & One Revised Relief Requests for Third 10-year Interval ISI Program for Plant,Developed to Clarify Documentation Requirements,To Propose Alternate Exam Requirements IAW ASME Code Cases N-598 & N-573
| 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-5839, NUDOCS 9909220247
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 17
| project = 
| stage = Request
}}

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* Lewis Sumner               Southern Nuclear Vice President             Operating Company. Inc.
Hatch Project Support      40 Irwemess Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205 992.7279 Fax 205.992.0341 SOUTHERN h COMPANY                ,
Energy to Serve Your World"      l September 16, 1999 Docket Nos. 50-32i                                                                           HL-5839 50-366 l
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555                                                                                        l l
Edwin I. Hatch Nuclear Plant                                         l Third Ten Year Interval Inservice Inspection Program Submittal of Additional Requests for Relief 1
Ladies and Gentlemen:
1 Attached are three new and one revised Relief Requests for the Third 10-Year Interval Inservice Inspection Program for the Edwin I. Hatch Nuclear Plant. The revised Relief Request RR-9, and new Relief Requests RR-28, RR-29 and RR-30, were developed to clarify documentation requirements, to propose alternate examination requirements in accordance with ASME Code Cases N-598 and N-573, and to propose the use of alternate ultrasonic examination calibration                l blocks, respectively.
Should you have any questions in this regard, please contact this office.
Respectfully submitted, h
H. L. Sumner, Jr.
IFUeb Attachments:
: 1. Request for Relief RR-9                                                                              okg
: 2. Request for Relief RR-28
: 3. Request for Relief RR-29
: 4. Request for Relief RR-30 cc: (See next page.)
9909220247 990916          31 DR   ADOCK O

U. S. Nuclear Regulatory Commission Page 2 '
September 16, 1999 cc:   Southern Nucicar Ooerating Company Mr. P. H. Wells, Nuclear Plant General Manager       .
SNC Document Management (R-Type A02.001)
U.S. Nuclear Regulatory Commission. Washington. D.C.
Mr. L. N. Olshan, Project Manager - Hatch
                 - U.S. Nuclear Reaulatory Commission. Reaion II         j Mr. L. A. Reyes, Regional Administrator              i Mr. J. T. Munday, Senior Resident Inspector - Hatch 1
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l HL-5839                                                      l

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8   9 Attachment RELIEF REQUEST RR-9

l SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2 f
THIRD 10-YEAR INTERVAL                                      '
REQUEST FOR RELIEF NO. RR-9 I. System / component (s) for Which Reliefis Requssted: All ASME Class 1,2 and 3 piping and components included within the scope of the ISI Program.
II. Code Reauirement: ASME Section XI components require a hydrostatic pressure test after welded repairs or installation of replacement items by welding, as noted in IWA-4000.
III. Code Reauirement for Which Reliefis Requested: Reliefis requested from performing the required hydrostatic test for Section XI components after welded repairs or installation of replacement items by welding.
IV. Basis for Relief: ASME Section XI Code Case N-416-1 was issued on February 15,1994. This Code Case has been approved by the NRC staff for use at Plant Hatch and other plants, and has been formally endorsed by inclusion in NRC Regulatory Guide 1.147 Revision 12 in May 1999. It was previously approved for Plant Hatch by SERs dated 6/15/95 and 6/16/97.
V. Alternate Examinations: Southern Nuclear Operating Company (SNC) will comply with the pressure testing requirements of ASME Section XI Code Case N-416-1 for welded repairs or installation of replacement items by welding. In addition to the alternative mies of Code Case N-416-1, SNC proposes te tugment the alternative tests by performing an additional surface examination on the root pass layer of butt and socket welds on the pressure retaining boundary of Class 3 components. Plant Hatch has been granted permission to use ASME Code Case N-532 and, as a result, is not required to use the Form NIS-2. Therefore, Code Case N-416-1 will be documented in the Repair / Replacement Plan in lieu of the Form NIS-2.
VI. Justification for the Granting of Relief: The proposed alternative testing requirements have been evaluated by the ASME Code Committee and the NRC and have been deemed acceptable for determining the pressure boundary integrity of the affected components. Implementation of pressure testing in accordance with the subject Code Case will ensure an acceptable level of quality and safety, does not decrease the margin of public health and safety and is thus authorized     ,
pursuant to 10 CFR 50.55a(a)(3)(i). By implementing the alternative examinations, reduction in costs, personnel radiation dose, and outage time can be realized by    q Southern Nuclear Operating Company at Plant Hatch.                                  ;
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RR-9 Rev.6 Page1 of2

l REQUEST FOR RELIEF NO. RR-9 (Continued) 1
        , VII. Implementation Schedule: The alternative rules for post repair / installation hydrostatic testing for Class 1,2, and 3 systems in accordance with Code Case l
N-416-1 will be used for the Third 10-Year Interval.                          i I
Vill. Relief Request Status: Submitted to the NRC for approval.
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RR-9 Rev.6 Page 2 of 2 l
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Attachment  !
RELIEF REQUEST RR-28 4
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SOUTHERN NUCLEAR OPERATING COMPANY
      .   .                            PLANT HATCH, UNITS 1 AND 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-28 I.-    System / Component (s) for Which Reliefis Requested: Requirements of Tables IWB-2412-1, IWC-2412-1, IWD-2412-1, IWE-2412-1 and ASME Code Case N-491 Table -2410-2 used in selecting the maximum percentages of examinations credited for each period.
II. Code Reauirement: Tables IWB-2412-1, IWC-2412-1, IWD-2412-1 of the 1989 Edition of ASME Section XI, Table IWE-2412-1 of the 1992 Edition of ASME Section XI,1992 Addenda, and ASME Code Case N-491 Table -2410-2 require the following:
Inspection Period, l
Calendar Years of                      Minimum                      Maximum         i Plant Service                          Examinations                 Examinations Within the Interval                    Completed,%                  Completed,%
3                                 16                            34 7                                50                             67 10                                100                            100' III. Code Requirement from Which Reliefis Requested: Reliefis requested from selecting the maximum percentages of examinations credited for each period as required by Tables IWB-2412-1, IWC-2412-1, IWD-2412-1, IWE-2412-1 and ASME Code Case N-491 Table -2410-2. Reliefis also requested to use the               l exceptions found in the 1996 Addenda of the 1995 Edition of ASME Section XI,        j IWB-2412, IWC-2412, IWD-2412, IWE-2412, and IWF-2410.
IV. Basis for Religf: Code Case N-598 which was approved March 2,1998 by ASME addresses an alternative to the requirements Tables IWB-2412-1, IWC-2412-1, IWD-2412-1, IWE-2412-1, and starting with the 1990 Addenda, IWF-2410-2 This same alternative was incorporated into the 1998 Edition of ASME Section XI Code, not as an alternative, but as the code requirement. Southern Nuclear Operating Company (SNC) uses ASME Code Case N-491, which has been approved for use by Regulatory Guide 1.147, in lieu of the selection criteria found  I in IWF. Therefore ASME Code Case N-491 Table-2410-2 will be substituted for
                  . Table IWF-2410-2 referenced in the ASME Code Case N-598. A copy ofCode RR-28 Rev.6 Page1 of4

REQUEST FOR RELIEF NO. RR-28 (Continued) i 1
     , ,        Basis for Relief (Cont'dk Case N-598 is provided as an attachment to this request for relief. As for the exceptions, the 1996 Addenda of the 1995 Edition of ASME Section XI is the edition of the code included in the in the latest NRC proposed                       ,
revision to 10CFR50.55a.
                                                                                                                    ]
1 V. Alternate Examination: Southern Nuclear Operating Company will comply with the requirements of ASME Section XI, Code Case N-598 except Table IWF-2410-2 will be substituted with ASME Code Case N-491 Table -2410-2. In addition, SNC will incorporate the following exceptions:
(a) The required percentage of examinations in each Examination Category shall                      -
be completed in accordance with the table contained in ASME Code Case N-                     .
598 with the following exceptions:
(1) Examination Categories B-N-1, B-P, and B-Q; (2) examinations partially deferred to the end of an inspection interval, as allowed by Examination Categories B-A, B-D, and B-F; (3) examinatims Merred to the end of an inspection interval, as allowed by Examin..          tegories B-A, B-L-1, B-M-1, B-N-2, B-N-3, and B-0; (4) examination deferred until disassembly of a component for maintenance, repair / replacement activity, or volumetric examination, as allowed by Examination Categories B-G-1, B-G-2, B-L-2, and B-M-2; (5) welded attachments examined as a result of component support                               I deformation under Examination Categories B-K, C-C, or D-A.                              l l
(b) Ifitems or welds are added to the Inspection Program, during the service lifetime of the plant, examinations shall be scheduled as follows:
(1) When items or welds are added during the first period of an interval, at least 25% of the examinations required by the applicable Examination Category and Item Number for the added items or welds shall be performed during each of the second and third periods of that interval.
Alternatively, if deferral of the examinations is permitted for the Examination Category and Item Number, the second period                                I examinations may be deferred to the third period and at least 50% of                    l the examinations required by the applicable Examination Category and Item Number for the added items or welds shall be performed during the third period.
RR-28 Rev.6 Page 2 of 4
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                             ' REQUEST FOR RELIEF NO. RR-28 (Continued)
     ,                (2) When items or welds are added during the second period of an interval, at least 25% of the examinations required by the applicable Examination Category and Item Number for the added items or welds shall be performed during the third period of that interval.
(3) When items or welds are added during the third period of an interval, examinations shall be scheduled in accordance with (a) above.
(c)    If there are less than three items or welds to be examined in an Examination Category, the items or. welds may be examined in any two periods, or in any one period if there is only one item or weld, in lieu of the percentage requirements contained in ASME Code Case N-598.
VI. Justification for Granting Relief: ASME Code Case N-598 provides an alternative to the inspection Program B Tables in order to eliminate redundancy and provide more flexibility for scheduling examinations. This code case does not eliminate examinations and does not allow examinations to be extended past the code allowable ten year sequence, it simply allows the owner to schedule examinations more effectively. This code case has been evaluated by the ASME Code Committee and has been deemed acceptable. In addition, the proposed exceptions found in the 1996 Addenda of the 1995 Edition of ASME Section XI, IWB-2412, IWC-2412, IWD-2412, IWE-2412, and IWF-2410 are contained in the edition of the code included in the latest NRC proposed revision to 10CFR50.55a. 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 and exceptions in lieu of the Code requirements. Therefore, it is requested that the proposed alternative and exceptions be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
VII. Implementation Schedule: The proposed alternative, as noted in the code case, and the exceptions will be implemented during the Third 10-Year Interval.
VIII. Relief Reauest Status: Submitted to the NRC for review and approval.
RR-28 Rev.6 Page 3 of 4

REQUEST FOR RELIEF NO. RR-28 (Continued)
CASE j N-598  I CASES OF A8 hts DOELER AND PRRAsURE VEGERL CtME Asweeval Dece: tennA 2.1ese see kmee enden Aw nunwonen and any reenremerton desee.
Case N-898 Ahormative Ragmiressames to Required Percentaens or .       u.a _
h XI Divialen 1
                     'Japiry: What abernatives to the ._,-___             of Tables IWB-2412-1. IWC2412-1, IWD 24121.
IWE-2412-1, and, starting with the 1990 Addiada, IWF 2410 2 say be used in selecting the snanismum percentages of exarnientions crediend for each period?
Aspey: It is the opinion of the Conumines that, as an ahernative to the requireonente of Tables IWB-24121, IWC2412-1 IWD 24121, IWB-2412-1, and IWP-24142, the following table smay be used fur the unaxhamn eercentages of saarninations crediand for s=h
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c.a a., y ees a t       unumme
                    ,e              ,,,,,              .. - .
i,          v        .w          ces em AD                3                  16      So 7                  So'     TS to                 too     100 (1) It es Arm pened P= penan, ass for any e-         sessa guy eassede &st, si 4,em 16e of es sequired     shnu
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Attachment f
RELIEF REQUEST f
RR-29 4
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l SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNITS 1 AND 2 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-29 t
I. System /Compon_cnt(s) for Which Reliefis Reauested: This request for relief         I proposes an alternative to the welding and brazing procedure qualification requirements ofIWA-4000.
H. Code Requirement: The 1989 Edition of the ASME Co'de, Section XI, lWA-              i 4400(a), requires that all welding shall be performed in accordance with Welding Procedure Specifications that have been qualified by the Owner or repair organization in accordance with the requirements of the codes specified in the Repair Program in accordance with IWA-4120.
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l III. Code Requirement from Which Reliefis Requested: Reliefis requested from the         I welding and brazing procedure qualification requirements ofIWA-4000 and as an
                - alternative, it is proposed that ASME Section XI Co.h Case N-573 be utilized.      1 i
IV. Basis for Relief: ASME Code Case N-573, " Transfer of Procedure Qualification Records Between Owners," which was approved March 12,1997 by ASME provides an alternative to the welding and brazing procedure qualification           j requirements ofIWA-4000. The code case allows for the use of a welding or brazing procedure qualification record (PQR) qualified by one owner to be used by   ;
another owner for the development of the welding procedure specification (WPS).      !
The specific requirements listed in the code case shall be met by the owner that performed the procedure qualification, and by the owner intending to use the PQR.
Southern Nuclear Operating Company will comply with the requirements of Code         ,
Case N-573 in lieu ofIWA-4400(a). A copy of Code Case N-573 is provided as an         l attachment to this request for relief.
V. Alternate Examination: Southern Nuclear Operating Company will comply with the requirements of Code Case N-573 in lieu ofIWA-4000, as an alternative to the welding and brazing procedure qualification requirements. The primary application of this Code Case will be to utilize Weld Procedure Qualification Records developed by industry groups with SNC participation to mitigate or correct generic problems with plant equipment. It may also be used to utilize Weld Procedure Qualification Records from other utilities for new materials, when welding conditions are unusual such as under water or with deletion of post weld heat treatment, when equipment or process not normally used at the plant are required or similar non-standard conditions. Plant Hatch has been granted permission to use ASME Code Case N-532 and, as a result, is not required to use the Form NIS-2.
RR-29
        .Rev 6 Page1 of3 1

a REQUEST FOR RELIEF NO. RR-29 (Continued)
    ,        Alternate Examination (Cont'd): Code Case N-578 will be documented in the Repair / Replacement Plan in lieu of the Form NIS-2.
VI. Justification for Granting Relief: The .ASME Code Committee evaluated the proposed alternative contained in Code Case N-573 and determined that it is acceptable. The implementation of the code case will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity.
Therefore, it is requested the proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
VII. Implementation Schedule: This request for reliefis applicable to the Third Ten-Year Interval.
Vill. Relief Requot Status: Submitted to the NRC for review and approval.
RR-29 Rev.6 Page 2 of 3                                                                              I i

REQUEST FOR RELIEF NO. RR-29 (Continued) g N-573 casas W Anh8E DOE 3a AND PanasUng VBesel, CDon Asproves psee: aAersh 12. Wo?
                                                               $se hmerAr inden ist ea,drsNon end any reeMarmotten geens.
Case N-873                                                     Assurance Prognua that andshes the requironwoes of Transfer of Freendere W Records                                IWA 1400.
Beewasa Owaars                                                    (c)De Owaar accepting the completed PQR shall 5estima XI, DMdes 1                                            acesyt sempossibiiny for obtaimag any additional sup-posting lefossaation aseded for WPS development.
Jaguiry: What ehermedves to the welding and braz.               (4)%s Owner accepting the completed PQR shall
              )    lag procedure quali6catina requar====*a of IWA-4000            docuset, on each smlung WPS, de permeters appli-immy be usad?                                                  cable to welding. Each WPS shall be supporte i by all m PQR's.
Aspiy.' It is the opinica of the Comumseas that as             (a)he Owner accepting the completed PQR shall as sharnative to k welding and brasing prW                     accept respuasibildy for the PQR. Acceptance shall be qualiacation imparessets of IWA-4000, a prWurs                                               *" * * *
* qual *h socord (PQR) quali6sd by one Owner g
Immy be used by another Owner. When this shernative (h De Owaar accepang the completed PQR shall m, m i                      g, g gi e,,;,, og in, is W die followng sequimisses shall be inst:                   suceived PQR by coraplating s performance qualiacauan (e) %s Owner that performed die procedwe lualia-            seat using the parannsters of a resuking WPS.
casics test shall ceruty, by signing the PQR. that testing        (s)De Owner may accept and use a PQR only was performed in accordance um Secuan IX.                      when k is received directly from the Owner that cerb6ed (6) The Owner that parfanned the prunedwe qualia-           the pQR.
I canon test shall certify,in writing, that the proceshne           (h) Use of this Case shall be shown on the NIS-2 quali6 cation was conducted la accordance with a Quality       fane A            ; welding or brazing.
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1 RR-29                                                                          -
Rev.6 Page 3 of 3 1
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0 Attachment RELIEF REQUEST RR-30 l
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I SOUTHERN NUCLEAR OPERATING COMPANY PLANT HATCH, UNIT 1 & 2
{
THIRD 10-YEAR INTERVAL                                       ]
REQUEST FOR RELIEF NO. RR-30                                     {
I.      System / Component for Which Reliefis Requested: Relief from curvature requirements for ultrasonic calibration blocks as shown on the attachment. Examination Category B-F, Item B5.10.                                                                         l II. Code Requirement: Section XI,1989 Edition, Article I-2000, Paragraph I-2200, Appendix III, paragraph III-3410 requires that basic calibration blocks shall be made from material of the same nominal diameter as the pipe to be examined.
III. Code Requirement for which Reliefis Reauested: Reliefis requested to use the existing calibration blocks whose curvatures do not match that of the pipe being examined.
IV. Basis for Relief: These calibration blocks have been used throughout the plant life.
Experience performing exams has been satisfactory.
V.      Alternate Examination: Southern Nuclear Operating Company (SNC) proposes that ultrasonic examinations be conducted using the referenced calibration blocks, which contain variations to 1989 Code specified dimensions.
VI. Justification for Granting Relief: These calibration blocks have been used throughout plant life. Curvature differences between the blocks and the welds to be examined are minor, and experience performing calibrations using the blocks have been completely satisfactory. Continuing to use the blocks will permit the comparison of future data with historical data and will continue to provide an acceptable level of quality and safety. Therefore, permission to use the calibration blocks should be granted pursuant to 10 CFR 50.55a(aX3Xi).
VII.                                                                                           l ImpJgmentation Schedule: This reliefreguest is applicable for the Third Ten-Year         l Interval.                                                                               j Vill. Belief Request Status: Submitted to the NRC for review and approval.
RR-30 Rev.6 Page1of2

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4 REQUEST FOR RELIEF NO. RR-30 (Continued) l i
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     .                                           Attachment 1                                       I Il The following is a list of welds and associated calibration blocks used.                    l UNIT      CAL. BLOCK #            CAL BLOCK DIA.             WELD NUMBER        WELD DIA.
I              85-H                     12"              1B31-lRC-12AR-F-5       14" 1              85-H                     12"               1B31-lRC-12AR-G-5      14" 1              85-H                     12"              1B31-lRC-12AR-H-5       14"     l 1              85-H                     12"              1B31-lRC-12AR J-5       14" 1              85-H                     12"              1B31-lRC-12AR-K-5       14" 1              85-H                     12"              1B31-l RC-12BR-A-5      14"    ;
I              85-H                     12"              1B31-l RC-12BR-B-5      14"    l 1              85-H                     12"               1 B31-l RC-12BR-D-5    14"     l 2              78-H                 Special 13.2         2B21-lFW-12AA-10        16" 2              78-H                 Special 13.2         2B21-l FW-12AB-13       16" 2              78-H                 Special 13.2         2821-IFW-12BC-13        16"     l 2              78-H                 Special 13.2         2B21-l FW-12BD-10       16"     !
2              85-H                     12"              2B31-1RC-12AR-F-5       14" 2              85-H                     12"
                                                                                                    ]
2B31-l RC-12AR-G-5      14" 2              85-H                     12"              2B31-lRC-12AR-H 5       14" 2              85-H                     12"              2B31-lRC-12AR-J-5       14" 2              85-H                     12"              2831-lRC-12AR-K-5       14" 2              85-H                     12"              2B31-lRC-12BR-A-5       14" 2              85-H                     12"              2B31-l RC-12BR-B-5      14" 2              85-H                     12"              2B31-lRC-12BR-C-5       14"     l 2              85-H                     12"              2B31-lRC-12BR-D-5       14"    )
2              85-11                    12"              2B31-lRC-12BR-E-5       14" l
I RR-30 Rev.6 Page 2 of 2}}