ML053350002

Exemption MC6540, VT-3 Examination Containment Vent System

ML053350002
Person / Time
Site:	Hatch
Issue date:	01/06/2006
From:	Gratton C Plant Licensing Branch III-2
To:	Sumner H Southern Nuclear Operating Co
Gratton C, NRR/DLPM 415-1055
References
TAC MC6540, TAC MC6541
Download: ML053350002 (9)

Text

January 6, 2006Mr. H. L. Sumner, Jr.

Vice President - Nuclear Hatch Project Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, EXEMPTION FROMTHE REQUIREMENTS OF 10 CFR 50.55a(b)(2)(ix)(G) (TAC NOS. MC6540 AND MC6541)

Dear Mr. Sumner:

The Commission has approved the enclosed exemption from specific requirements of Title 10of the Code of Federal Regulations, Part 50, Section 50.55a(b)(2)(ix)(G), for the Edwin I. HatchNuclear Plant, Unit Nos. 1 and 2. This action is in response to your letter of March 30, 2005, as supplemented by letters dated August 2 and 24, 2005, that requested Southern NuclearOperating Company, Inc. (SNC), be exempted from the requirements to perform a VT-3 examination of the containment vent system. SNC proposed to continue the practice ofperforming a general visual examination for the system. A copy of the exemption has been forwarded to the Office of the Federal Register forpublication. Sincerely,/RA/Christopher Gratton, Sr. Project ManagerPlant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-321 and 50-366

Enclosure:

Exemption cc w/encl: See next page January 6, 2006Mr. H. L. Sumner, Jr.

Vice President - Nuclear Hatch Project Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, EXEMPTION FROMTHE REQUIREMENTS OF 10 CFR 50.55a(b)(2)(ix)(G) (TAC NOS. MC6540 AND MC6541)

Dear Mr. Sumner:

The Commission has approved the enclosed exemption from specific requirements of Title 10of the Code of Federal Regulations, Part 50, Section 50.55a(b)(2)(ix)(G), for the Edwin I. HatchNuclear Plant, Unit Nos. 1 and 2. This action is in response to your letter of March 30, 2005, as supplemented by letters dated August 2 and 24, 2005, that requested Southern NuclearOperating Company, Inc. (SNC), be exempted from the requirements to perform a VT-3 examination of the containment vent system. SNC proposed to continue the practice ofperforming a general visual examination for the system. A copy of the exemption has been forwarded to the Office of the Federal Register forpublication. Sincerely,/RA/Christopher Gratton, Sr. Project ManagerPlant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-321 and 50-366

Enclosure:

Exemption cc w/encl: See next pageDISTRIBUTION:PUBLICRidsNrrLAMO'Brien (Hard Copy)BWetzel, EDO RIILPL II-1R/F RidsOgcRp RidsRgn2MailCenter(MWidmann)RidsAcrsAcnwMailCenter RidsNrrPMCGrattonRidsNrrDorlDprRidsNrrDorlLplc(EMarinos)HAsharKManolyADAMS Accession Number: ML053350002 NRR-042OfficeLPL2-1/PMLPL2-1/LAEEMB/BCOGCLPL2-1/BCDORL/DNameCGrattonMO'BrienKManolyJHullEMarinosCHaneyDate12/6/051/3/06SE dated11/15/0512/8/051/3/061/6/06OFFICIAL RECORD COPY Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:

Laurence BergenOglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349Mr. R.D. BakerManager - Licensing Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295Resident InspectorPlant Hatch 11030 Hatch Parkway N.

Baxley, GA 31531Harold Reheis, DirectorDepartment of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334Steven M. JacksonSenior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684Mr. Reece McAlisterExecutive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334Arthur H. Domby, Esq.Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216ChairmanAppling County Commissioners County Courthouse Baxley, GA 31513Mr. Jeffrey T. GasserExecutive Vice President Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295Mr. G. R. Frederick, General ManagerEdwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc.

U.S. Highway 1 North P.O. Box 2010 Baxley, GA 31515Mr. K. RosanskiResident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515 7590-01-P UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSIONSOUTHERN NUCLEAR OPERATING COMPANY, INC.EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2DOCKET NOS. 50-321 AND 50-366EXEMPTION

1.0BACKGROUND

The Southern Nuclear Operating Company, Inc. (SNC, or the licensee), is the holder ofFacility Operating License Nos. DPR-57 and NPF-5 which authorizes operation of the Edwin I.Hatch Nuclear Plant, Unit Nos. 1 and 2 (Hatch 1 and 2), respectively. The license provides, among other things, that the facility is subject to all rules, regulations, and orders of the NuclearRegulatory Commission (NRC, Commission) now or hereafter in effect.The facility consists of two boiling water reactors located in Appling County, Georgia.2.0REQUEST/ACTIONTitle 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(b)(2)(ix), statesthe requirements for the examination of metal containments and liners of concretecontainments. In particular, Section 50.55a(b)(2)(ix)(G) requires, in part, that a VT-3 examination method be used to conduct examinations of Item E.20 of Table IWE-2500-1 of Section IX of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code(ASME Code). By letter dated March 30, 2005, as supplemented by letters dated August 2 and 24,2005, the licensee submitted a request for an exemption from the requirements of Section50.55a(b)(2)(ix)(G). The exemption request would allow the licensee to perform an alternative examination of the accessible surface areas of the containment vessel pressure retainingboundary vent system, in lieu of the VT-3 examination required by the rule. The licensee statedthat the alternate examination method is currently in use at Hatch 1 and 2 and has proven to besufficient to maintain the structural integrity and leak-tightness of the containment surfaces,and, therefore, serves the underlying purpose of the rule. The licensee is currently in its 3rd 10-year inservice inspection (ISI) interval. Thelicensee's code of record for the 3rd 10-year ISI interval is the 1992 edition through the 1992 addenda of the ASME Code. The code of record contains the requirement to perform a VT-3 examination of the accessible surface areas of the vent system. In Relief Request RR-MC-9submitted by letter dated July 19, 2000, the licensee requested relief from the requirement toperform a VT-3 examination on nonsubmerged, accessible pressure boundary surfaces, including the vent system, at the end of the 3rd 10-year ISI interval. The licensee explainedthat the proposed alternative to perform a general visual examination was sufficient to detectthe types of corrosion expected in the components covered by the relief. On October 4, 2000,this request was approved by the NRC staff. The licensee's 4th 10-year ISI interval is scheduled to begin in 2006. The licensee's code of record for this interval will be the 2001 edition through the 2003 addenda of the ASMECode. Modifications to the ASME Code and 10 CFR 50.55a since the beginning of the 3rd 10-year ISI interval have relocated the requirement to perform the subject VT-3 examination from the ASME Code to 10 CFR 50.55a(b)(2)(ix). As a result, licensees wanting relief from the requirement to perform a VT-3 examination for the subject structures must now request an exemption from the requirements of 10 CFR 50.55a(b)(2)(ix)(G).The licensee stated in its August 24, 2005, letter that the examination provisionspreviously authorized through Relief Request RR-MC-9 have proven to be sufficient to maintain the structural integrity and leak-tightness of the containment surfaces, and, therefore, serve theunderlying purpose of the rule. As an alternative to the VT-3 examination, SNC is proposing the examination on all nonsubmerged, accessible pressure boundary surfaces of the vent system. This general visual-type examination will be performed in accordance with the Hatch 1and 2 Qualified (N) Coatings Program. The licensee indicated that the details of this programwere provided in the October 19, 1998, response to NRC Generic Letter 98-04, "Potential forDegradation of the Emergency Core Cooling System and the Containment Spray System after a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment." The procedures and personnel qualifications applicable for the coatings program implementation are in compliance with Regulatory Guide 1.54 (1973), andthe implementation is based on the following documents: (1) ANSI N 101.2-1972, "ProtectiveCoatings (Plants) for Light Water Nuclear Reactor Containment Facilities;" (2) ANSI N101.4-1972, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities;" and (3)EPRI Report TR-109937, "Guideline on Nuclear Safety-Related Coatings." This program was approved by the NRC staff in a letter dated November 19, 1999.The licensee further noted that the Qualified (N) Coatings program examinationfrequency is equivalent to the requirements of Section XI to the ASME Code, and the program requires that when evidence of degradation is detected, a detailed examination and evaluationbe performed. The detailed visual examination would be performed in accordance with the provisions of ASME Code,Section XI, paragraph IWE-2310(c). The exterior surfaces of the vent system that connects the drywell to the suppression pool are located in the reactorbuilding. The reactor building environment does not pose adverse conditions that would promote rapid degradation of the outside pressure boundary surfaces of the vent system. Theinterior surfaces of the vent system that connect the drywell to the suppression pool and theportions of the vent system located inside the suppression pool are maintained in a nitrogen inerted environment during normal power operation in accordance with technical specificationrequirements. Operational experience and previous examinations have indicated that thisenvironment does not promote rapid degradation of the surfaces.The licensee stated that the requirements specified for a VT-3 examination weredeveloped for detecting flaws in metal components and are more stringent than those required for detecting corrosion-related degradation. Since corrosion of base metal is the primary issue of concern for containment pressure boundary surface areas, a general visual-type examination, in accordance with the Hatch 1 and 2 Qualified (N) Coatings Program, is sufficient to inspect the subject surface areas of the containment and will provide an acceptable level ofquality and safety. In summary, the licensee is proposing an exemption from the requirements of Section50.55a(b)(2)(ix)(G) to use an alternate examination method to examine Item E.20 of Table IWE-2500-1 of ASME Code,Section XI, pursuant to 10 CFR 50.12(a)(1) and 10 CFR 50.12(a)(2)(ii). The licensee stated in its application that compliance with the visual examination requirements of Section 50.55a(b)(2)(ix)(G) is not necessary for accessible surface areas of the containment vessel pressure retaining boundary Vent System to achieve the underlying purpose of the rule.

3.0DISCUSSIONPursuant to 10 CFR 50.12, the Commission may, upon application by any interestedperson or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 50 when: (1) the exemptions are authorized by law, will not present an undue risk to public healthor safety, and are consistent with the common defense and security; and (2) when special circumstances are present. Special circumstances are present whenever, in accordance with 10 CFR Part 50.12(a)(2)(ii), "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlyingpurpose of the rule..." Therefore, in determining the acceptability of the licensee'sexemption request, the NRC staff has performed the following evaluation to satisfy therequirements of 10 CFR 50.12 for granting the exemption.The underlying purpose of 10 CFR 50.55a(b)(2)(ix)(G), as it applies to Item E1.20 ofTable IWE-2500-1, is to ensure that an examination of the metal containment or the metal linerof a concrete containment is performed to identify corrosion or other degradation that couldaffect the structural or leak-tight integrity of the structure.The NRC staff examined the licensee's rationale to support the exemption request andconcluded that maintaining the integrity of the coating system applied to the Hatch 1 and 2containment vent system components is a preventive measure that would protect againstcorrosion of the coated components. As the licensee emphasizes the effectiveness of its coating program, the NRC staff believes that the general visual examination performed as partof maintaining the integrity of the coating system is a proactive action and will ensure theintegrity of the coated vent system components. The proposed alternative will provide thequality and safety level similar to the one intended by the use of VT-3 examination of the vent system components, and would meet the underlying purpose of 10 CFR Section50.55a(b)(2)(ix)(G).Based on a consideration of proposed alternatives contained in the licensee's lettersdated March 20, and August 2 and 24, 2005, the NRC staff concludes that degradation of thecontainment structure would be detected using the proposed alternative, thus meeting theunderlying purpose of the rule. Therefore, the NRC staff concludes that the proposedexemption from 10 CFR Section 50.55a(b)(2)(ix)(G) is acceptable.

4.0CONCLUSION

Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, theexemption is authorized by law, will not present an undue risk to the public health and safety,and is consistent with the common defense and security. Also, special circumstances are present. Therefore, the Commission hereby grants SNC an exemption from the requirement of 10 CFR Section 50.55a(b)(2)(ix)(G) to perform a VT-3 examination for Item E1.2 of Table IWE-2500-1, for Hatch 1 and 2, for the 4th 10-year ISI interval. Pursuant to 10 CFR 51.32, the Commission has determined that the granting of thisexemption will not have a significant effect on the quality of the human environment (70 FR 76082). This exemption is effective upon issuance.

Dated at Rockville, Maryland, this 6th day of January 2006.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Catherine Haney, DirectorDivision of Operating Reactor Licensing Office of Nuclear Reactor Regulation