View source for NOC-AE-05001853, Revised Steam Generator Tube Inservice Inspection Plan for the Second Inspection Interval at Plant

{{Adams
| number = ML050690200
| issue date = 03/03/2005
| title = Revised Steam Generator Tube Inservice Inspection Plan for the Second Inspection Interval at Plant
| author name = Jordan T
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number = NPF-076, NPF-080
| contact person = 
| case reference number = NOC-AE-05001853
| document type = Inservice/Preservice Inspection and Test Report, Letter type:NOC
| page count = 38
}}

=Text=
{{#Wiki_filter:Nuclear Operating Company SohTec Pro/d Ektric  crz6at/nfS5tnPOx28S9 Bew.a  Ttr 7743 March 3, 2005 NOC-AE-05001853 10CFR50.55a U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50498 and STN 50499 Revised Steam Generator Tube Inservice Inspection Plan for the Second Inspection Interval at South Texas Proiect Units 1 and 2 Attached are four copies of the revised "Inservice Inspection Plan for the Second Interval of the South Texas Project Electric Generating Station, Units 1 and 2, Steam Generator Tubing." This inspection plan has been revised due to steam generator Technical Specification changes approved by the NRC on November 24, 2004. The Technical Specification change adopted an industry generic licensing change package developed by EPRI and NEI in conjunction with the NRC. The revised inspection plan now refers to Technical Specification Section 6.8.3 rather than Section 4.4.5, which was deleted as part of the change.
The steam generator tubing inservice inspection during the second interval will be performed in accordance with the requirements of the 1989 Edition of the ASME Section XI Code, "Rules for Inservice Inspection of Nuclear Power Plant Components." Utilization of this edition of Section XI is in compliance with the requirements of 10CFR50.55a. Additional bases for the inservice inspection plan are referenced and discussed within the plan.
There are no commitments in this letter.
If there are any questions regarding this revision, please contact John Conly at (361) 972-7336 or me at (361) 972-7902.
Vice President, Engineering jtc                                                                                                A04-7

==Attachment:==
Inservice Inspection Program Plan for the Second Interval of the South Texas Project Electric Generating Station, Units 1 and 2, Steam Generator Tubing STI: 31845399

NOC-AE-05001853 Page 2 of 2 cc:
(paper copy)                              (electronic copy)
Bruce S. Mallett                          A. H. Gutterman, Esquire Regional Administrator, Region IV         Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400           David H. Jaffe Arlington, Texas 76011-8064               U. S. Nuclear Regulatory Commission C. M. Canady                              R. L. Balcom City of Austin                            Texas Genco, LP Electric Utility Department 721 Barton Springs Road                   C. A. Johnson Austin, TX 78704                          AEP Texas Central Company Richard A. Ratliff                        C. Kirksey Bureau of Radiation Control               City of Austin Texas Department of State Health Services 1100 West 49th Street                    Jon C. Wood Austin, TX 78756-3189                     Cox Smith Matthews Jeffrey Cruz                              J. J. Nesrsta U. S. Nuclear Regulatory Commission       R. K. Temple P. 0. Box 289, Mail Code: MN116           E. Alarcon Wadsworth, TX 77483                       City Public Service

INSERVICE INSPECTION PROGRAM PLAN for the SECOND INTERVAL of the SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2, STEAM GENERATOR TUBING Prepared by:
R. L. Baker
                                               .2 Steam Generator Engineer Reviewed by:
J. E *uber               Date ISI rogram Engineer 2 ,a Supervisory Review:
M.J.Berg                 Date Testing and Pr ams Engineering Manager Revision I

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing TABLE OF CONTENTS SECTION                      DESCRIPTION                                   PAGE Revision Summary Sheet                                                ii 1.0  Introduction and Plan Description                                     1-1 1.1          Overview                                                     1-1 1.2          Basis of Inservice Inspection Plan                           1-1 1.3          Augmented Inservice Inspection Requirements                  1-2 2.0  Inservice Inspection Summary                                         2-1 2.1          Summary                                                      2-1 3.0  Alternative Requirements to ASME Section XI Code                     3-1 3.1          Adoption of Code Cases                                       3-1 3.2          Use of Subsequent Editions of ASME Section XI                3-3 3.3          Inservice Inspection Relief Requests                         3-3 i
Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing REVISION 

==SUMMARY==
SHEET SECTION EFFECTIVE PAGE(S)    REVISION           DATE 1.0           1-1              0            9/25/00 1.1           1-1              0            9/25/00 1.2       1-1 to 1-2           1            11/30/04 1.3           1-2              0            9/25/00 2.0          2-1               0            9/25/00 2.1          2-1               0            9/25/00 3.0          3-1               0            9/25/00 3.1       3-1 to 3-3           0            9/25/00 3.2          3-3               0            9/25/00 3.3          3-3               0            9/25/00 ii Revision I

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 

==1.0 INTRODUCTION==
AND PLAN DESCRIPTION 1.1 Overview 1.1.1   This Inservice Inspection (ISI) Plan outlines the requirements for the examination of steam generator tubing at the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2.
1.1.2   This ISI Plan will be effective from September 25, 2000, through September 24, 2010 for Unit 1, and October 19, 2000, through October 18, 2010 for Unit 2, which represents the second ISI interval for the South Texas Project.
1.1.3  The key features of this plan are as follows:
* Introduction and Plan Description ISI Summary
* Alternative Requirements to ASME Section XI including:
* Code Cases
                . Relief Requests 1.2 Basis of Inservice Inspection Plan 1.2.1  The commercial service dates for STPEGS, Units 1 and 2, were August 25, 1988, and June 19, 1989, respectively.
1.2.2 During their first inservice inspection intervals, STPEGS Units 1 and 2 were out of service continuously for periods of 13 and 16 months, respectively. The end dates of the intervals were extended for equivalent periods. The Unit 1 first interval was also extended an additional one (1) year, so that the STPEGS, Units 1 and 2 second intervals are essentially concurrent. These extensions are permitted by IWA-2400(c) of the American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components".
1.2.3  This ISI Plan was developed in accordance with the requirements of the version of 10CFR50.55a that became effective on November 22, 1999.
1.2.4 This ISI Plan was developed in accordance with the 1989 Edition of the ASME Code Section XI, Subsection IWA, Subsection IWB, and Appendix IV "Eddy Current Examination of Nonferromagnetic Steam Generator Heat Exchanger 1-1                                         Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Tubing". The Plan implements inspection intervals as defined in IWA-2432, "Inspection Program B." During the second interval, the South Texas Project will implement the criteria of the 1989 Edition of Section XI, except as described below.
1.2.4.1 As allowed by ASME Section XI, IWB-2413, the extent, frequency, and acceptance standards for steam generator tubing inspection and testing will be in accordance with the STPEGS Technical Specifications, in particular Section 6.8.3.
1.2.5   Alternative requirements to ASME Section XI are set forth in Section 3.0 of this ISI Plan. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
1.3 Augmented Inservice Inspection Requirements Augmented inservice inspection requirements are those examinations that are specified by documents other than the ASME Section XI Code. Typically, these augmented examinations are at the request of the Nuclear Regulatory Commission through such mechanisms as Bulletins, Notices and Regulatory Guides. The augmented examinations addressed by the South Texas Project ISI Program during the second inspection interval are as follows:
1.3.1   The steam generator tube inspection program meets positions C.1 and C.2 of U. S.
Nuclear Regulatory Commission Regulatory Guide 1.83 "Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes" Revision 1. The STPEGS Technical Specifications address the scopes of positions C.3 through C.8 of this guide. This partial exception to the guide is taken as defined in Table 3.12-1 "Regulatory Guide MATRIX" of the STPEGS Updated Final Safety Analysis Report.
1-2                                       Revision 1

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 2.0 INSERVICE INSPECTION 

==SUMMARY==

2.1 Summary Steam generator tube examination requirements are defined by Section XI Examination Category B-Q Item No. B16.20 listed in Table IWB-2500-l. Examination Category B-Q requires examination by the volumetric examination method. The extents,'frequency, acceptance standards of examination are governed by the STPEGS Technical Specifications.
2-1 Revision 0

STPEGS Units 1 and 2 Second Interval Inseriice Inspection Plan Steam Generator Tubing SECTION 3.0 ALTERNATIVE REQUIREMENTS TO ASMIE SECTION XI CODE This section lists the alternative requirements to the 1989 Edition of the ASME Section XI Code, being adopted for the second ISI interval at STPEGS, Units 1 and 2. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
3.1     Adoption of Code Cases This section addresses the adoption of Code Cases during the Second Inservice Inspection Interval at STPEGS, Units 1 and 2. Code Cases adopted for Inservice Inspection use during the Second Interval are listed in Tables 3.1.1 and 3.1.2 of this ISI Plan. In all cases, the use and adoption of Code Cases will be in accordance with ASME Section XI, IWA-2440 and 10CFR50.55a. Code Cases that have already been incorporated into 1989 Edition of ASME Section XI, will be implemented via application of the Code. The methodology for adopting Code Cases is divided into the four categories clarified below.
3.1.1   Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in Regulatory Guide 1.147, Revision 12, will be adopted for use during the Second Inservice Inspection Interval by listing them in Table 3.1.1 of this Inservice Inspection Plan. All conditions or limitations delineated in Regulatory Guide 1.147 for a particular Code Case will apply.
3.1.2   Adoption of Code Cases Not Listed for Generic Use in Regulatory Guide 1.147 via Submittal of Relief Requests Adoption of Code Cases that have been approved by the Board of Nuclear Codes and Standards, but that have not been listed for generic use in Regulatory Guide 1.147, may be submitted in the form of a Relief Request in accordance with 10CFR50.55a(a)(3). Once approved, these Relief Requests will be available for use by the South Texas Project.
Table 3.1.2 lists those Code Cases that are not listed for generic use in Regulatory Guide 1.147 for which Relief Requests have been submitted. In addition to the requirements stated in the Code Cases, criteria may be stipulated in the Relief Request or may be agreed upon through subsequent correspondence with the NRC. The South Texas Project will implement these additional requirements as applicable.
3-1 Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Table 3.1.1 Adopted Code Cases Approved in Regulatory Guide 1.147 Code                                                                    Affected Case                       Code Case Title                              Program Number                                                                      Area N-489     Alternative Rules for Level III NDE Qualification           NDE Personnel Examinations                                                 Qualifications N-490-1   Alternative Vision Test Requirements for                    NDE Personnel Nondestructive Examiners                                     Qualifications N-503     Limited Certification of Nondestructive                     NDE Personnel Examination Personnel                                        Qualifications Table 3.1.2 Code Cases Submitted Through Relief Requests Code                                         (1) Relief Request No.              Affected Case             Code Case Title             (2) Correspondence No.              Program Number                                         (3) Relief Request Date              Area None                   None                             None                       None 3.1.3 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 But Subsequently Annulled by ASME Section XI Under certain circumstances, it may be necessary to adopt a Code Case that has been listed for generic use in Regulatory Guide 1.147, but subsequently annulled by ASME Section XI. Therefore, the South Texas Project endorses all revisions of Regulatory Guide 1.147 from Revision 12 up to and including the most recent revision. Endorsement of these revisions of Regulatory Guide 1.147 does not commit the South Texas Project to all Code Cases listed therein, but rather allows for selection of a previously accepted Code Case. The purpose of this endorsement is to identify all Code Cases that could potentially be incorporated into this Inservice Inspection Plan in accordance with IWA-2441.
3-2 Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing 3.1.4   Adoption of Code Cases Issued Subsequent to the Filing of this Inservice Inspection Plan Code Cases issued by ASME Section XI subsequent to the filing of this Inservice Inspection Plan will be proposed for use in amendments to this Plan in accordance with ASME Section XI, IWA-2441 (d).
3.2  Use of Subsequent Editions of ASME Section XI In accordance with 10CFR50.55a(g)(4)(iv), inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions of the Code and addenda which are incorporated by reference in IOCFR50.55a(b), subject to the limitations and modifications listed therein and subject to NRC approval. This Section of the Inservice Inspection Plan provides for the documentation of alternative requirements from approved subsequent Code editions that may be adopted during the Second Inservice Inspection Interval. Should the South Texas Project elect to adopt a subsequent edition and addenda of Section XI code approved by NRC in 10CFR50.55a(b), NRC approval will be requested in accordance with 10CFR50.55a(g)(4)(iv). Once NRC approval is obtained, the Inservice Inspection Plan will be amended for adoption of the subsequent Code rules and the revised portions submitted to NRC and the State of Texas for their information.
3.3 Inservice Inspection Relief Requests Table 3.3 provides a listing of additional Relief Requests, not associated with a Code Case, that have been written in accordance with 10CFR50.55a(g)(5) when specific ASME Section XI requirements for inservice inspection are considered impractical. If examination requirements are determined to be impractical during the course of the interval, relief requests shall be submitted in accordance with 10CFR50.55a(g)(5).
Table 3.3 Relief Requests Not Associated With A Code Case (I) Relief Request No.             Affected Relief Request Subject               (2) Correspondence No.             Program (3) Relief Request Date              Area None                                  None                      None 3-3 Revision 0

INSERVICE INSPECTION PROGRAM PLAN for the SECOND INTERVAL of the SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2, STEAM GENERATOR TUBING Prepared by:                                   2 /0*
R. L. Baker              Date Steam Generator Engineer Reviewed by:
J. - "auber              Date ISI rogram Engineer 2 2&A/s, Supervisory Review:
M.J.Berg                 Date Testing and P   ams Engineering Manager Revision 1

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing TABLE OF CONTENTS SECTION                      DESCRIPTION                                   PAGE Revision Summary Sheet                                                ii 1.0  Introduction and Plan Description                                    1-1 1.1          Overview                                                     1-1 1.2          Basis of Inservice Inspection Plan                           1-1 1.3          Augmented Inservice Inspection Requirements                  1-2 2.0  Inservice Inspection Summary                                         2-1 2.1          Summary                                                      2-1 3.0  Alternative Requirements to ASME Section XI Code                     3-1 3.1          Adoption of Code Cases                                       3-1 3.2          Use of Subsequent Editions of ASME Section XI                3-3 3.3          Inservice Inspection Relief Requests                         3-3 r
i Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing REVISION 

==SUMMARY==
SHEET SECTION EFFECTIVE PAGE(S)    REVISION          DATE 1.0           1-1             0             9/25/00 1.1           1-1             0            9/25/00 1.2       1-1 to 1-2          1            11/30/04 1.3           1-2             0            9/25/00 2.0          2-1              0            9/25/00 2.1          2-1              0            9/25/00 3.0          3-1              0            9/25/00 3.1        3-1 to 3-3          0            9/25/00 3.2          3-3              0            9/25/00 3.3           3-3              0            9/25/00 ii Revision I

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 

==1.0 INTRODUCTION==
AND PLAN DESCRIPTION 1.1 Overview 1.1.1  This Inservice Inspection (ISI) Plan outlines the requirements for the examination of steam generator tubing at the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2.
1.1.2 This ISI Plan will be effective from September 25, 2000, through September 24, 2010 for Unit 1, and October 19, 2000, through October 18, 2010 for Unit 2, which represents the second ISI interval for the South Texas Project.
1.1.3  The key features of this plan are as follows:
* Introduction and Plan Description
* ISI Summary
* Alternative Requirements to ASME Section XI including:
* Code Cases
* Relief Requests 1.2 Basis of Inservice Inspection Plan 1.2.1  The commercial service dates for STPEGS, Units 1 and 2, were August 25, 1988, and June 19, 1989, respectively.
1.2.2  During their first inservice inspection intervals, STPEGS Units 1 and 2 were out of service continuously for periods of 13 and 16 months, respectively. The end dates of the intervals were extended for equivalent periods. The Unit 1 first interval was also extended an additional one (1) year, so that the STPEGS, Units 1 and 2 second intervals are essentially concurrent. These extensions are permitted by IWA-2400(c) of the American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components".
1.2.3  This ISI Plan was developed in accordance with the requirements of the version of 10CFR50.55a that became effective on November 22, 1999.
1.2.4  This ISI Plan was developed in accordance with the 1989 Edition of the ASME Code Section XI, Subsection IWA, Subsection IWB, and Appendix IV "Eddy Current Examination of Nonferromagnetic Steam Generator Heat Exchanger 1-1 Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Tubing". The Plan implements inspection intervals as defined in IWA-2432, "Inspection Program B." During the second interval, the South Texas Project will implement the criteria of the 1989 Edition of Section XI, except as described below.
1.2.4.1 As allowed by ASME Section XI, IWB-2413, the extent, frequency, and acceptance standards for steam generator tubing inspection and testing will be in accordance with the STPEGS Technical Specifications, in particular Section 6.8.3.
1.2.5   Alternative requirements to ASME Section XI are set forth in Section 3.0 of this ISI Plan. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
1.3 Augmented Inservice Inspection Requirements Augmented inservice inspection requirements are those examinations that are specified by documents other than the ASME Section XI Code. Typically, these augmented examinations are at the request of the Nuclear Regulatory Commission through such mechanisms as Bulletins, Notices and Regulatory Guides. The augmented examinations addressed by the South Texas Project ISI Program during the second inspection interval are as follows:
1.3.1   The steam generator tube inspection program meets positions C.1 and C.2 of U. S.
Nuclear Regulatory Commission Regulatory Guide 1.83 "Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes" Revision 1. The STPEGS Technical Specifications address the scopes of positions C.3 through C.8 of this guide. This partial exception to the guide is taken as defined in Table 3.12-1 "Regulatory Guide MATRIX" of the STPEGS Updated Final Safety Analysis Report.
1-2                                       Revision 1

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 2.0 INSERVICE INSPECTION 

==SUMMARY==

2.1 Summary Steam generator tube examination requirements are defined by Section XI Examination Category B-Q Item No. B16.20 listed in Table IWB-2500-l. Examination Category B-Q requires examination by the volumetric examination method. The extents, frequency, acceptance standards of examination are governed by the STPEGS Technical Specifications.
2-1 Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 3.0 ALTERNATIVE REQUIREMENTS TO ASME SECTION XI CODE This section lists the alternative requirements to the 1989 Edition of the ASME Section XI Code, being adopted for the second ISI interval at STPEGS, Units 1 and 2. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
3.1     Adoption of Code Cases This section addresses the adoption of Code Cases during the Second Inservice Inspection Interval at STPEGS, Units 1 and 2. Code Cases adopted for Inservice Inspection use during the Second Interval are listed in Tables 3.1.1 and 3.1.2 of this ISI Plan. In all cases, the use and adoption of Code Cases will be in accordance with ASME Section XI, IWA-2440 and 10CFR50.55a. Code Cases that have already been incorporated into 1989 Edition of ASME Section XI, will be implemented via application of the Code. The methodology for adopting Code Cases is divided into the four categories clarified below.
3.1.1   Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in Regulatory Guide 1.147, Revision 12, will be adopted for use during the Second Inservice Inspection Interval by listing them in Table 3.1.1 of this Inservice Inspection Plan. All conditions or limitations delineated in Regulatory Guide 1.147 for a particular Code Case will apply.
3.1.2   Adoption of Code Cases Not Listed for Generic Use in Regulatory Guide 1.147 via Submittal of Relief Requests Adoption of Code Cases that have been approved by the Board of Nuclear Codes and Standards, but that have not been listed for generic use in Regulatory Guide 1.147, may be submitted in the form of a Relief Request in accordance with 10CFR50.55a(a)(3). Once approved, these Relief Requests will be available for use by the South Texas Project.
Table 3.1.2 lists those Code Cases that are not listed for generic use in Regulatory Guide 1.147 for which Relief Requests have been submitted. In addition to the requirements stated in the Code Cases, criteria may be stipulated in the Relief Request or may be agreed upon through subsequent correspondence with the NRC. The South Texas Project will implement these additional requirements as applicable.
3-1 Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Table 3.1.1 Adopted    Code   Cases  Approved   in Regulatory Guide 1.147 Code                                                                    Affected Case                       Code Case Title                              Program Number                                                                       Area N-489     Alternative Rules for Level III NDE Qualification           NDE Personnel Examinations                                                 Qualifications N-490-1   Alternative Vision Test Requirements for                    NDE Personnel Nondestructive Examiners                                     Qualifications N-503     Limited Certification of Nondestructive                     NDE Personnel Examination Personnel                                        Qualifications Table 3.1.2 Code Cases Submitted Through Relief Requests Code                                         (1) Relief Request No.              Affected Case             Code Case Title             (2) Correspondence No.              Program Number                                         (3) Relief Request Date              Area None                   None                             None                       None 3.1.3 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 But Subsequently Annulled by ASME Section XI Under certain circumstances, it may be necessary to adopt a Code Case that has been listed for generic use in Regulatory Guide 1.147, but subsequently annulled by ASME Section XI. Therefore, the South Texas Project endorses all revisions of Regulatory Guide 1.147 from Revision 12 up to and including the most recent revision. Endorsement of these revisions of Regulatory Guide 1.147 does not commit the South Texas Project to all Code Cases listed therein, but rather allows for selection of a previously accepted Code Case. The purpose of this endorsement is to identify all Code Cases that could potentially be incorporated into this Inservice Inspection Plan in accordance with IWA-2441.
3-2 Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing 3.1.4   Adoption of Code Cases Issued Subsequent to the Filing of this Inservice Inspection Plan Code Cases issued by ASME Section XI subsequent to the filing of this Inservice Inspection Plan will be proposed for use in amendments to this Plan in accordance with ASME Section XI, IWA-2441 (d).
3.2 Use of Subsequent Editions of ASME Section XI In accordance with 10CFR50.55a(g)(4)(iv), inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions of the Code and addenda which are incorporated by reference in 10CFR50.55a(b), subject to the limitations and modifications listed therein and subject to NRC approval. This Section of the Inservice Inspection Plan provides for the documentation of alternative requirements from approved subsequent Code editions that may be adopted during the Second Inservice Inspection Interval. Should the South Texas Project elect to adopt a subsequent edition and addenda of Section XI code approved by NRC in IOCFR50.55a(b), NRC approval will be requested in accordance with 10CFR5O.55a(g)(4)(iv). Once NRC approval is obtained, the Inservice Inspection Plan will be amended for adoption of the subsequent Code rules and the revised portions submitted to NRC and the State of Texas for their information.
3.3 Inservice Inspection Relief Requests Table 3.3 provides a listing of additional Relief Requests, not associated with a Code Case, that have been written in accordance with IOCFR50.55a(g)(5) when specific ASME Section XI requirements for inservice inspection are considered impractical. If examination requirements are determined to be impractical during the course of the interval, relief requests shall be submitted in accordance with 10CFR50.55a(g)(5).
Table 3.3 Relief Requests Not Associated With A Code Case (1) Relief Request No.            Affected Relief Request Subject                (2) Correspondence No.            Program (3) Relief Request Date              Area None                                  None                     None 3-3 Revision 0

INSERVICE INSPECTION PROGRAM PLAN for the SECOND INTERVAL of the SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2, STEAM GENERATOR TUBING Prepared by:
R. L. Baker              Date Steam Generator Engineer Reviewed by:
J. E, 'auber ISI 1ro6gram Engineer Supervisory Review:
2 P2/?
M. J. Berg PQ            Date Testing and Proams Engineering Manager Revision 1

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing TABLE OF CONTENTS SECTION                       DESCRIPTION                                  PAGE Revision Summary Sheet                                                ii 1.0  Introduction and Plan Description                                    1-1 1.1           Overview                                                    1-1 1.2          Basis of Inservice Inspection Plan                           1-1 1.3          Augmented Inservice Inspection Requirements                  1-2 2.0  Inservice Inspection Summary                                         2-1 2.1          Summary                                                      2-1 3.0  Alternative Requirements to ASME Section XI Code                     3-1 3.1          Adoption of Code Cases                                       3-1 3.2          Use of Subsequent Editions of ASME Section XI                3-3 3.3          Inservice Inspection Relief Requests                         3-3 i
Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing REVISION 

==SUMMARY==
SHEET SECTION EFFECTIVE PAGE(S)    REV1SION          DATE 1.0           1-1             0             9/25/00 1.1           1-1             0             9/25/00 1.2       1-1 to 1-2          1            11/30/04 1.3           1-2             0             9/25/00 2.0           2-1              0             9/25/00 2.1           2-1              0            9/25/00 3.0          3-1              0            9/25/00 3.1        3-1 to 3-3          0            9/25/00 3.2           3-3              0            9/25/00 3.3           3-3              0            9/25/00 ii Revision I

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 

==1.0 INTRODUCTION==
AND PLAN DESCRIPTION 1.1 Overview 1.1.1  This Inservice Inspection (ISI) Plan outlines the requirements for the examination of steam generator tubing at the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2.
1.1.2   This ISI Plan will be effective from September 25, 2000, through September 24, 2010 for Unit 1, and October 19, 2000, through October 18, 2010 for Unit 2, which represents the second ISI interval for the South Texas Project.
1.1.3   The key features of this plan are as follows:
* Introduction and Plan Description
* ISI Summary
* Alternative Requirements to ASME Section XI including:
* Code Cases
* Relief Requests 1.2 Basis of Inservice Inspection Plan 1.2.1  The commercial service dates for STPEGS, Units 1 and 2, were August 25, 1988, and June 19, 1989, respectively.
1.2.2  During their first inservice inspection intervals, STPEGS Units 1 and 2 were out of service continuously for periods of 13 and 16 months, respectively. The end dates of the intervals were extended for equivalent periods. The Unit I first interval was also extended an additional one (1) year, so. that the STPEGS, Units 1 and 2 second intervals are essentially concurrent. These extensions are permitted by IWA-2400(c) of the American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components".
1.2.3  This ISI Plan was developed in accordance with the requirements of the version of I OCFR50.55a that became effective on November 22, 1999.
1.2.4 This ISI Plan was developed in accordance with the 1989 Edition of the ASME Code Section XI, Subsection IWA, Subsection IWB, and Appendix IV "Eddy Current Examination of Nonferromagnetic Steam Generator Heat Exchanger 1-1                                        Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Tubing". The Plan implements inspection intervals as defined in IWA-2432, "Inspection Program B." During the second interval, the South Texas Project will implement the criteria of the 1989 Edition of Section XI, except as described below.
1.2.4.1 As allowed by ASME Section XI, IWB-2413, the extent, frequency, and acceptance standards for steam generator tubing inspection and testing will be in accordance with the STPEGS Technical Specifications, in particular Section 6.8.3.
1.2.5    Alternative requirements to ASME Section XI are set forth in Section 3.0 of this ISI Plan. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
1.3 Augmented Inservice Inspection Requirements Augmented inservice inspection requirements are those examinations that are specified by documents other than the ASME Section XI Code. Typically, these augmented examinations are at the request of the Nuclear Regulatory Commission through such mechanisms as Bulletins, Notices and Regulatory Guides. The augmented examinations addressed by the South Texas Project ISI Program during the second inspection interval are as follows:
1.3.1 The steam generator tube inspection program meets positions C.1 and C.2 of U. S.
Nuclear Regulatory Commission Regulatory Guide 1.83 "Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes" Revision 1. The STPEGS Technical Specifications address the scopes of positions C.3 through C.8 of this guide. This partial exception to the guide is taken as defined in Table 3.12-1 "Regulatory Guide MATRIX" of the STPEGS Updated Final Safety Analysis Report.
1-2                                         Revision 1

STPEGS Units 1 and 2 Second Interval Inser-ice Inspection Plan Steam Generator Tubing SECTION 2.0 INSERVICE INSPECTION 

==SUMMARY==

2.1 Summary Steam generator tube examination requirements are defined by Section XI Examination Category B-Q Item No. B16.20 listed in Table IWB-2500-1. Examination Category B-Q requires examination by the volumetric examination method. The extents, frequency, acceptance standards of examination are governed by the STPEGS Technical Specifications.
2-1 Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 3.0 ALTERNATIVE REQUIREMENTS TO ASME SECTION XI CODE This section lists the alternative requirements to the 1989 Edition of the ASME Section XI Code, being adopted for the second ISI interval at STPEGS, Units 1 and 2. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
3.1     Adoption of Code Cases This section addresses the adoption of Code Cases during the Second Inservice Inspection Interval at STPEGS, Units I and 2. Code Cases adopted for Inservice Inspection use during the Second Interval are listed in Tables 3.1.1 and 3.1.2 of this ISI Plan. In all cases, the use and adoption of Code Cases will be in accordance with ASME Section XI, IWA-2440 and 10CFR50.55a. Code Cases that have already been incorporated into 1989 Edition of ASME Section XI, will be implemented via application of the Code. The methodology for adopting Code Cases is divided into the four categories clarified below.
3.1.1   Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in Regulatory Guide 1.147, Revision 12, will be adopted for use during the Second Inservice Inspection Interval by listing them in Table 3.1.1 of this Inservice Inspection Plan. All conditions or limitations delineated in Regulatory Guide 1.147 for a particular Code Case will apply.
3.1.2   Adoption of Code Cases Not Listed for Generic Use in Regulatory Guide 1.147 via Submittal of Relief Requests Adoption of Code Cases that have been approved by the Board of Nuclear Codes and Standards, but that have not been listed for generic use in Regulatory Guide 1.147, may be submitted in the form of a Relief Request in accordance with 10CFR50.55a(a)(3). Once approved, these Relief Requests will be available for use by the South Texas Project.
Table 3.1.2 lists those Code Cases that are not listed for generic use in Regulatory Guide 1.147 for which Relief Requests have been submitted. In addition to the requirements stated in the Code Cases, criteria may be stipulated in the Relief Request or may be agreed upon through subsequent correspondence with the NRC. The South Texas Project will implement these additional requirements as applicable.
3-1 Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Table 3.1.1 Adopted Code Cases Approved in Regulatory Guide 1.147 Code                                                                    Affected Case                       Code Case Title                              Program Number                                                                      Area N-489     Alternative Rules for Level III NDE Qualification           NDE Personnel Examinations                                                 Qualifications N-490-1   Alternative Vision Test Requirements for                    NDE Personnel Nondestructive Examiners                                     Qualifications N-503     Limited Certification of Nondestructive                     NDE Personnel Examination Personnel                                        Qualifications Table 3.1.2 Code Cases Submitted Through Relief Requests l  Code                                         (1) Relief Request No.               Affected Case             Code Case Title             (2) Correspondence No.              Program Number                                         (3) Relief Request Date               Area None                   None                             None                       None 3.1.3 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 But Subsequently Annulled by ASME Section XI Under certain circumstances, it may be necessary to adopt a Code Case that has been listed for generic use in Regulatory Guide 1.147, but subsequently annulled by ASME Section XI. Therefore, the South Texas Project endorses all revisions of Regulatory Guide 1.147 from Revision 12 up to and including the most recent revision. Endorsement of these revisions of Regulatory Guide 1.147 does not commit the South Texas Project to all Code Cases listed therein, but rather allows for selection of a previously accepted Code Case. The purpose of this endorsement is to identify all Code Cases that could potentially be incorporated into this Inservice Inspection Plan in accordance with IWA-2441.
3-2 Revision 0

STPEGS Units 1 and 2 Second Interval Inse rvice Inspection Plan Steam Generator Tubing 3.1.4    Adoption of Code Cases Issued Subsequent to the Filing of this Inservice Inspection Plan Code Cases issued by ASME Section XI subsequent to the filing of this Inservice Inspection Plan will be proposed for use in amendments to this Plan in accordance with ASME Section XI, IWA-2441 (d).
3.2 Use of Subsequent Editions of ASME Section XI In accordance with 10CFR50.55a(g)(4)(iv), inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions of the Code and addenda which are incorporated by reference in IOCFR50.55a(b), subject to the limitations and modifications listed therein and subject to NRC approval. This Section of the Inservice Inspection Plan provides for the documentation of alternative requirements from approved subsequent Code editions that may be adopted during the Second Inservice Inspection Interval. Should the South Texas Project elect to adopt a subsequent edition and addenda of Section XI code approved by NRC in 10CFR50.55a(b), NRC approval will be requested in accordance with 10CFR50.55a(g)(4)(iv). Once NRC approval is obtained, the Inservice Inspection Plan will be amended for adoption of the subsequent Code rules and the revised portions submitted to NRC and the State of Texas for their information.
3.3 Inservice Inspection Relief Requests Table 3.3 provides a listing of additional Relief Requests, not associated with a Code Case, that have been written in accordance with 10CFR50.55a(g)(5) when specific ASME Section XI requirements for inservice inspection are considered impractical. If examination requirements are determined to be impractical during the course of the interval, relief requests shall be submitted in accordance with IOCFR50.55a(g)(5).
Table 3.3 Relief Requests Not Associated With A Code Case (1) Relief Request No.             Affected Relief Request Subject                (2) Correspondence No.             Program (3) Relief Request Date              Area None                                  None                      None 3-3 Revision 0

INSERVICE INSPECTION PROGRAM PLAN for the SECOND INTERVAL of the SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2, STEAM GENERATOR TUBING Prepared by:                                    .2 R. L. Baker              Date Steam Generator Engineer Reviewed by:
J. E fauber              Date ISI rogram Engineer Supervisory Review:
2 )"   ,/Sy M. J. Berg               Date Testing and Pr ams Engineering Manager Revision I

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing TABLE OF CONTENTS SECTION                       DESCRIPTION                                  PAGE Revision Summary Sheet                                                ii 1.0  Introduction and Plan Description                                     1-1 1.1           Overview                                                     1-1 1.2          Basis of Inservice Inspection Plan                           1-1 1.3          Augmented Inservice Inspection Requirements                  1-2 2.0  Inservice Inspection Summary                                         2-1 2.1          Summary                                                      2-1 3.0  Alternative Requirements to ASME Section XI Code                     3-1 3.1          Adoption of Code Cases                                       3-1 3.2          Use of Subsequent Editions of ASME Section XI                3-3 3.3          Inservice Inspection Relief Requests                         3-3 i
Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing REVISION 

==SUMMARY==
SHEET SECTION EFFECTIVE PAGE(S)    REVISION          DATE 1.0           1-1              0            9/25/00 1.1           1-1              0            9/25/00 1.2       1-1 to 1-2           1           11/30/04 1.3           1-2             0             9/25/00 2.0          2-1              0             9/25/00 2.1          2-1              0             9/25/00 3.0          3-1              0             9/25/00 3.1        3-1 to 3-3          0             9/25/00 3.2           3-3              0             9/25/00 3.3           3-3              0             9/25/00 ii Revision 1

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 

==1.0 INTRODUCTION==
AND PLAN DESCRIPTION 1.1 Overview 1.1.1 This Inservice Inspection (ISI) Plan outlines the requirements for the examination of steam generator tubing at the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2.
1.1.2  This ISI Plan will be effective from September 25, 2000, through September 24, 2010 for Unit 1, and October 19, 2000, through October 18, 2010 for Unit 2, which represents the second ISI interval for the South Texas Project.
1.1.3  The key features of this plan are as follows:
* Introduction and Plan Description
* ISI Summary
* Alternative Requirements to ASME Section XI including:
* Code Cases
* Relief Requests 1.2 Basis of Inservice Inspection Plan 1.2.1  The commercial service dates for STPEGS, Units 1 and 2, were August 25, 1988, and June 19, 1989, respectively.
1.2.2  During their first inservice inspection intervals, STPEGS Units I and 2 were out of service continuously for periods of 13 and 16 months, respectively. The end dates of the intervals were extended for equivalent periods. The Unit 1 first interval was also extended an additional one (1) year, so that the STPEGS, Units 1 and 2 second intervals are essentially concurrent. These extensions are permitted by IWA-2400(c) of the American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components".
1.2.3  This ISI Plan was developed in accordance with the requirements of the version of 10CFR50.55a that became effective on November 22, 1999.
1.2.4 This ISI Plan was developed in accordance with the 1989 Edition of the ASME Code Section XI, Subsection IWA, Subsection IWIB, and Appendix IV "Eddy Current Examination of Nonferromagnetic Steam Generator Heat Exchanger 1-1                                        Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Tubing". The Plan implements inspection intervals as defined in IWA-2432, "Inspection Program B." During the second interval, the South Texas Project will implement the criteria of the 1989 Edition of Section XI, except as described below.
1.2.4.1 As allowed by ASME Section XI, IWB-2413, the extent, frequency, and acceptance standards for steam generator tubing inspection and testing will be in accordance with the STPEGS Technical Specifications, in particular Section 6.8.3.
1.2.5   Alternative requirements to ASME Section XI are set forth in Section 3.0 of this ISI Plan. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and 10CFR50.55a, as applicable.
1.3 Augmented Inservice Inspection Requirements Augmented inservice inspection requirements are those examinations that are specified by documents other than the ASME Section XI Code. Typically, these augmented examinations are at the request of the Nuclear Regulatory Commission through such mechanisms as Bulletins, Notices and Regulatory Guides. The augmented examinations addressed by the South Texas Project ISI Program during the second inspection interval are as follows:
1.3.1   The steam generator tube inspection program meets positions C.1 and C.2 of U. S.
Nuclear Regulatory Commission Regulatory Guide 1.83 "Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes" Revision 1. The STPEGS Technical Specifications address the scopes of positions C.3 through C.8 of this guide. This partial exception to the guide is taken as defined in Table 3.12-1 "Regulatory Guide MATRIX" of the STPEGS Updated Final Safety Analysis Report.
1-2                                        Revision I

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 2.0 INSERVICE INSPECTION 

==SUMMARY==

2.1 Summary Steam generator tube examination requirements are defined by Section XI Examination Category B-Q Item No. B16.20 listed in Table IWB-2500-1. Examination Category B-Q requires examination by the volumetric examination method. The extents, frequency, acceptance standards of examination are governed by the STPEGS Technical Specifications.
2-1 Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing SECTION 3.0 ALTERNATIVE REQUIREMENTS TO ASME SECTION Xi CODE This section lists the alternative requirements to the 1989 Edition of the ASME Section XI Code, being adopted for the second ISI interval at STPEGS, Units 1 and 2. The alternative requirements identified in this ISI Plan meet the rules for the use of alternate requirements that are defined in the 1989 Edition of the ASME Code Section XI and IOCFR50.55a, as applicable.
3.1     Adoption of Code Cases This section addresses the adoption of Code Cases during the Second Inservice Inspection Interval at STPEGS, Units 1 and 2. Code Cases adopted for Inservice Inspection use during the Second Interval are listed in Tables 3.1.1 and 3.1.2 of this ISI Plan. In all cases, the use and adoption of Code Cases will be in accordance with ASME Section XI, IWA-2440 and 10CFR50.55a. Code Cases that have already been incorporated into 1989 Edition of ASME Section XI, will be implemented via application of the Code. The methodology for adopting Code Cases is divided into the four categories clarified below.
3.1.1   Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in Regulatory Guide 1.147, Revision 12, wvill be adopted for use during the Second Inservice Inspection Interval by listing them in Table 3.1.1 of this Inservice Inspection Plan. All conditions or limitations delineated in Regulatory Guide 1.147 for a particular Code Case will apply.
3.1.2 Adoption of Code Cases Not Listed for Generic Use in Regulatory Guide 1.147 via Submittal of Relief Requests Adoption of Code Cases that have been approved by the Board of Nuclear Codes and Standards, but that have not been listed for generic use in Regulatory Guide 1.147, may be submitted in the form of a Relief Request in accordance with IOCFR50.55a(a)(3). Once approved, these Relief Requests will be available for use by the South Texas Project.
Table 3.1.2 lists those Code Cases that are not listed for generic use in Regulatory Guide 1.147 for which Relief Requests have been submitted. In addition to the requirements stated in the Code Cases, criteria may be stipulated in the Relief Request or may be agreed upon through subsequent correspondence with the NRC. The South Texas Project will implement these additional requirements as applicable.
3-1 Revision 0

STPEGS Units I and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing Table 3.1.1 Adopted Code Cases Approved in Regulatory Guide 1.147 Code                                                                   Affected Case                      Code Case Title                              Program Number                                                                      Area N-489    Alternative Rules for Level III NDE Qualification           NDE Personnel Examinations                                                 Qualifications N-490-1  Alternative Vision Test Requirements for                    NDE Personnel Nondestructive Examiners                                     Qualifications N-503    Limited Certification of Nondestructive                     NDE Personnel Examination Personnel                                        Qualifications Table 3.1.2 Code Cases Submitted Through Relief Requests Code                                        (1) Relief Request No.              Affected Case            Code Case Title             (2) Correspondence No.              Program Number                                        (3) Relief Request Date              Area None                  None                             None                       None 3.1.3 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 But Subsequently Annulled by ASME Section XI Under certain circumstances, it may be necessary to adopt a Code Case that has been listed for generic use in Regulatory Guide 1.147, but subsequently annulled by ASME Section XI. Therefore, the South Texas Project endorses all revisions of Regulatory Guide 1.147 from Revision 12 up to and including the most recent revision. Endorsement of these revisions of Regulatory Guide 1.147 does not commit the South Texas Project to all Code Cases listed therein, but rather allows for selection of a previously accepted Code Case. The purpose of this endorsement is to identify all Code Cases that could potentially be incorporated into this Inservice Inspection Plan in accordance with IWA-2441.
3-2 Revision 0

STPEGS Units 1 and 2 Second Interval Inservice Inspection Plan Steam Generator Tubing 3.1.4   Adoption of Code Cases Issued Subsequent to the Filing of this Inservice Inspection Plan Code Cases issued by ASME Section XI subsequent to the filing of this Inservice Inspection Plan will be proposed for use in amendments to this Plan in accordance with ASME Section XI, IWA-2441 (d).
3.2  Use of Subsequent Editions of ASME Section XI In accordance with IOCFR50.55a(g)(4)(iv), inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions of the Code and addenda which are incorporated by reference in 10CFR50.55a(b), subject to the limitations and modifications listed therein and subject to NRC approval. This Section of the Inservice Inspection Plan provides for the documentation of alternative requirements from approved subsequent Code editions that may be adopted during the Second Inservice Inspection Interval. Should the South Texas Project elect to adopt a subsequent edition and addenda of Section XI code approved by NRC in 10CFR50.55a(b), NRC approval will be requested in accordance with 10CFR50.55a(g)(4)(iv). Once NRC approval is obtained, the Inservice Inspection Plan will be amended for adoption of the subsequent Code rules and the revised portions submitted to NRC and the State of Texas for their information.
3.3 Inservice Inspection Relief Requests Table 3.3 provides a listing of additional Relief Requests, not associated with a Code Case, that have been written in accordance with 10CFR50.55a(g)(5) when specific ASME Section XI requirements for inservice inspection are considered impractical. If examination requirements are determined to be impractical during the course of the interval, relief requests shall be submitted in accordance with 10CFR50.55a(g)(5).
Table 3.3 Relief Requests Not Associated With A Code Case (1) Relief Request No.            Affected Relief Request Subject               (2) Correspondence No.            Program (3) Relief Request Date              Area None                                   None                     None 3-3 Revision 0}}