ML040340729
| ML040340729 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/03/2004 |
| From: | Tilda Liu NRC/NRR/DRIP/RLEP |
| To: | Stinson L Southern Nuclear Operating Co |
| Liu T, NRR/DRIP/RLEP, 415-1315 | |
| References | |
| Download: ML040340729 (12) | |
Text
February 3, 2004 Mr. L. M. Stinson Vice President Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION
Dear Mr. Stinson:
By letter dated September 12, 2003, Southern Nuclear Operating Company, Inc. (SNC or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commissions (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review. Specifically, the enclosed requests for additional information (RAIs) are from Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant System; Section 3.2, Aging Management of Engineered Safety Features, Section 3.3, Aging Management of Auxiliary Systems; Section 3.4, Aging Management of Steam and Power Conversion Systems; Section 3.5, Aging Management of Containments, Structures, and Component Supports, and Appendix B, Aging Management Programs and Activities.
These RAIs, in a draft format, have been provided to Mr. Jan Fridrichsen of your staff on December 12 and 16, 2003, and January 12, 2004. The NRC staff has discussed draft versions of these RAIs, via telephone conferences, to provide clarifications to the SNC staff on January 21, 22, and 23, 2004. Your responses to these RAIs are requested within 30 days from the date of this letter. Mr. Fridrichsen has agreed to this request. If needed, the NRC staff is willing to meet or discuss with SNC again prior to the submittal of the applicants responses to provide clarifications to the staffs RAIs.
If you have any questions, please contact me at 301-415-1315 or e-mail tyl1@nrc.gov.
Sincerely,
/RA/
Tilda Liu, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
As stated cc w/encl: See next page
February 3, 2004 Mr. L. M. Stinson Vice President Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION
Dear Mr. Stinson:
By letter dated September 12, 2003, Southern Nuclear Operating Company, Inc. (SNC or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commissions (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review. Specifically, the enclosed requests for additional information (RAIs) are from Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant System; Section 3.2, Aging Management of Engineered Safety Features, Section 3.3, Aging Management of Auxiliary Systems; Section 3.4, Aging Management of Steam and Power Conversion Systems; Section 3.5, Aging Management of Containments, Structures, and Component Supports, and Appendix B, Aging Management Programs and Activities.
These RAIs, in a draft format, have been provided to Mr. Jan Fridrichsen of your staff on December 12 and 16, 2003, and January 12, 2004. The NRC staff has discussed draft versions of these RAIs, via telephone conferences, to provide clarifications to the SNC staff on January 21, 22, and 23, 2004. Your responses to these RAIs are requested within 30 days from the date of this letter. Mr. Fridrichsen has agreed to this request. If needed, the NRC staff is willing to meet or discuss with SNC again prior to the submittal of the applicants responses to provide clarifications to the staffs RAIs.
If you have any questions, please contact me at 301-415-1315 or e-mail tyl1@nrc.gov.
Sincerely,
/RA/
Tilda Liu, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: See next page Accession No: ML040340729 C:\\ORPCheckout\\FileNET\\ML040340729.wpd OFFICE LA:RLEP PM:RLEP SC:RLEP NAME YEdmonds TLiu SLee DATE 2/2/04 2/2/04 2/3/04 OFFICIAL RECORD COPY
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PUBLIC J. Craig D. Matthews F. Gillespie R. Barrett C. Grimes RidsNrrDe E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski S. Black B. Boger D. Thatcher G. Galletti C. Li J. Moore M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy B. Jain Y. (Renee) Li RLEP Staff C. Julian (R-II)
R. Fanner (R-II)
C. Patterson (R-II)
S. Peters L. Whitney D. Cummings/M. Lemoncelli (OGC)
Enclosure JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION (RAI)
Section 3.1: Aging Management of Reactor Vessel, Internals, and Reactor Coolant System RAI 3.1-1 LRA Table 3.1.1, item 3.1-37 states:
The FNP AMR results are consistent with the intent of this summary item, with the exception that SNC applies a higher threshold value for neutron fluence effects on stainless steels than does NUREG-1801.
However, this exception is not specifically discussed in Section B.5.1.3 of LRA Appendix B.5.1, Reactor Vessel Internals Program. Please confirm that this exception is applicable to Appendix B.5.1, identify the higher threshold value for neutron fluence effects, and justify the use of this higher value for the LRA of Farley.
RAI 3.1-2 LRA Table 3.1.1, items 3.1.1-42 and 3.1.1-48 indicate that as part of the FNP Reactor Vessel Internals Program:
SNC commits to continued participation in industry initiatives intended to clarify the nature and extent of this aging effect. FNP will incorporate the results of these industry initiatives into the program inspection requirements and acceptance criteria.
SNC also indicated this commitment in Table 3.1.1, item 3.1.1-11, by reference to Section 3.1.2.2.6. The aging effects being managed are the loss of preload due to stress relaxation and changes in dimension due to void swelling.
However, this commitment is not contained in the UFSAR supplement presented in LRA Appendix A, nor is it included in the recently submitted LRA supplement letter, NL-03-2418, dated December 5, 2003, Enclosure 2, License Renewal Future Action Commitment List.
Please confirm that with respect to the aging effects of loss of preload due to stress relaxation and changes in dimension due to void swelling, SNC will incorporate the results of industry initiatives into the inspection requirements and acceptance criteria for the FNP Reactor Vessel Internals Program. Please also confirm that SNC will submit a summary of the planned inspection activities to the NRC prior to the period of extended operation, and that this commitment will be contained in its License Renewal Future Action Commitment List.
RAI 3.1-3 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
Section 3.2, Aging Management of Engineered Safety Features RAI 3.2-1 There are no question associated with this RAI. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.2-2 LRA Table 3.2.2-3 states that loss of material in an oil environment was determined not to be an aging effect requiring management for the carbon steel oil cooler shell and the copper alloy tubes for the high head safety injection pump in the emergency core cooling system. The GALL report recommends a plant-specific aging management program for loss of material due to general, pitting, and crevice corrosion and microbiologically induced corrosion (MIC) in carbon steel components exposed to lubricating oil that may be contaminated with water.
Similar aging effects (except general corrosion) are possible for copper alloy. The NRC staff considers a periodic inspection program appropriate to manage this aging effect. For the oil cooler shell and tubes in the emergency core cooling system exposed to an oil environment, the applicant is requested to provide aging management for loss of material due to general (carbon steel), pitting, and crevice corrosion and MIC, or provide justification for not managing this aging effect.
RAI 3.2-3 LRA Table 3.2.2-3 states that the copper alloy oil cooler tubes for the high head safety injection pump in a closed cycle cooling water environment will be managed for loss of material using the Water Chemistry Control Program and the One-Time Inspection Program. For this material type and environment, the staff considers selective leaching to be aging effects requiring management. The applicant is requested to clarify whether selective leaching is considered to be an aging mechanism rather than an aging effect for the tubes. If so, describe the type of inspections used by the One-Time Inspection Program to detect selective leaching in the tubes.
Also, list any other aging mechanisms for this item and discuss if the One-Time Inspection Program provides verification that the aging effect is not occurring.
RAI 3.2-4 The GALL report recommends further evaluation of programs to manage the loss of material due to pitting and crevice corrosion to verify the effectiveness of the Water Chemistry Control Program. A one-time inspection of select components at susceptible locations is an acceptable method to determine whether an aging effect is occurring or is progressing very slowly so that the intended function will be maintained during the period of extended operation. LRA Tables 3.2.2-1, 3.2.2-2, and 3.2.2-3 list various stainless steel components in a borated water environment with the aging effect being loss of material. The aging management program for these components is the Water Chemistry Control Program; however, the One-Time Inspection Program is not credited to verify the effectiveness of the Water Chemistry Control Program.
The applicant is requested to explain why a one-time inspection is not performed to determine the effectiveness of the Water Chemistry Control Program. Also, state the aging mechanisms for the loss of material.
RAI 3.2-5 LRA Table 3.2.2-3 lists loss of material for the carbon steel encapsulation vessel in an air and gas (wetted) environment as being managed by the One-Time Inspection Program. Section 3.0.4 of the LRA defines an air and gas (wetted) environment as containing significant amounts of moisture where condensation or water pooling may occur and such components in this environment include cooling units and non-dried air system low points. The GALL report recommends a one-time inspection in cases where either 1) an aging effect is not expected to occur but there is insufficient data to completely rule it out, or 2) an aging effect is expected to occur very slowly. The staff does not consider a one-time inspection appropriate to manage this aging effect for a carbon steel component. The applicant is requested to provide a periodic inspection aging management program for this component or to provide adequate basis for performing a one-time inspection.
RAI 3.2-6 LRA Table 3.2.2-3 lists loss of material and cracking as aging effects requiring management for the flow orifice/element, but does not list erosion. The staff considers erosion a possible aging effect requiring management for flow orifice/elements. The applicant is requested to describe the flow orifice/element, its location in the system, and why erosion is not considered to be an aging effect requiring management.
Section 3.3: Aging Management of Auxiliary Systems RAI 3.3-1 There are no question associated with this RAI. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.3-2 There are no question associated with this RAI. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.3-3 Loss of material and fouling are listed in LRA Table 3.3.2-5 as aging effects that require aging management for the open-cycle cooling water system components listed below. Fouling is generally an aging effect for components with intended function of heat transfer, not pressure boundary. Explain how fouling is related to the pressure boundary intended function of these components. Identify and describe the program that is credited for detection, prevention, and monitoring of the aging effect due to fouling for these components.
CCW heat exchangers channel head and tube sheet Containment and ESF room coolers channel heads Air compressor lube oil coolers tubesheet and channel head Air compressor intercooler and aftercooler and bleed-off air coolers shells, tubesheet, and channel head RAI 3.3-4 Column 8 of Table 2 (LRA Tables 3.3.2-x), refers to Item 3.3.1-29 of Table 1 for many auxiliary system components with loss of material aging effects due to selective leaching of carbon steel, copper alloy (brass), and stainless steel materials. The discussion column of Table 1, Item 3.3.1-29 addresses only CCW pumps fabricated from carbon steel. Provide additional information on how selective leaching is addressed for copper alloy (brass) and stainless steel materials in the components of the auxiliary systems (OCCW, CCW, EDG, etc.) Further, describe the credited FNP program for the detection of the selective leaching of materials and compare it with GALL AMP X1.M33 for consistency determination.
RAI 3.3-5 Equipment frames and housings (crankcase ventilation) is defined in LRA Table 3.3.2-15 as being consistent with GALL (item VII.H2.4-a) for material, environment, aging effects and aging management program. However, the GALL item is for a different component. The material of the EDG equipment frames and housings in LRA Table 3.3.2-15 is cast iron in a wetted air environment. The material for GALL item VII.H2.4-a is carbon steel in an environment with hot diesel engine gases containing moisture and particulate. Therefore, the material and environment for the equipment frames and housings are different from the GALL (item VII.H2.4-a) material and environment. Please justify the conclusion of being consistent with GALL, determine whether the One-Time Inspection Program is applicable to the equipment frames and housings, and make any necessary changes to the Table, if required.
Section 3.4, Aging Management of Steam and Power Conversion Systems RAI 3.4-1:
For various stainless steel components in LRA Table 3.4.2-x (a)
Cracking is identified as the aging effect for various stainless steel components in steam or treated water environments. The applicant credits the Water Chemistry Control Program to manage this aging effect. Since stainless steels are susceptible to cracking in these types of environments, the applicant is requested to justify why the Water Chemistry Control Program without an inspection program to verify that cracking is not occurring is adequate to manage this aging effect, or to provide an inspection program.
(b)
Loss of material is identified as the aging effect for various stainless steel components in treated water environments. The applicant credits the Water Chemistry Control Program to manage this aging effect. Stainless steels are susceptible to loss of material in this type of environment and the GALL report recommends that, for loss of material due to pitting and crevice corrosion, the effectiveness of the Water Chemistry Control Program should be verified to ensure that significant degradation is not occurring. The applicant is requested to perform a one-time inspection to verify the effectiveness of the Water Chemistry Control Program or to provide justification for not performing a one-time inspection.
RAI 3.4-2 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.4-3 LRA Table 3.4.2-1 identifies loss of material as an aging effect for alloy steel steam/fluid traps in a steam and treated water environment. The applicant credits the Water Chemistry Control Program to manage this aging effect. The GALL report recommends Water Chemistry Control and a one-time inspection to manage loss of material for carbon/alloy steel components in a treated water environment. The applicant is requested to perform a one-time inspection to verify the effectiveness of the Water Chemistry Control Program or to provide justification for not performing a one-time inspection.
RAI 3.4-4 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.4-5 LRA Table 3.4.1-4 states that loss of material was determined not to be an aging effect requiring management for the auxiliary feedwater (AFW) system turbine oil cooling system.
Table 3.4.2-4 identifies no aging effects requiring management for carbon and stainless AFW components in an oil environment. For AFW oil cooler tubes, Table 3.4.2-4 only identifies fouling as an aging effect requiring management. The GALL report recommends a plant-specific aging management program for loss of material due to general (carbon steel only),
pitting, and crevice corrosion and MIC in carbon and stainless steel components exposed to lubricating oil that may be contaminated with water. The staff considers a periodic inspection program appropriate to manage these aging effects. Industry operating experience indicates that moisture in oil has caused degradation in these types of components. For the filters, flow orifice/element, oil cooler shell, oil cooler channel head, oil cooler tube sheet, oil cooler tubes, piping, pump casings, and valve bodies in the AFW system exposed to an oil environment, the applicant is requested to provide aging management for loss of material due to general (carbon steel only), pitting, and crevice corrosion and MIC, or to provide justification for not managing this aging effect.
RAI 3.4-6 LRA Table 3.4.2-4 identifies fouling as an aging effect for the AFW oil cooler tubes in both an oil and treated water environment and the oil cooler tube sheet in a treated water environment.
The applicant credits the One-Time Inspection Program to verify this aging effect is not occurring, or that the aging effect is occurring slowly enough to not affect the component intended function during the period of extended operation. The applicants One-Time Inspection Program scope in Section B.5.5.5 of the LRA identifies specific components included in the sample population. This sample population does not include the oil cooler tubes or tube sheet, and the items identified in the list do not appear to bound the aging effect of fouling on the oil cooler tubes or tube sheet. The applicant is requested to explain why the One-Time Inspection Program sample population does not contain inspection criteria for the tubes.
RAI 3.4-7 LRA Table 3.4.1-11 states that the External Surfaces Monitoring Program will manage loss of material of the external surfaces of the condensate storage tanks, and that the program is consistent with the intent of NUREG-1801 Volume 2 (GALL), XI.M29, Aboveground Carbon Steel Tanks aging management program. The staff has the following comments regarding this item: 1) The applicant is requested to clarify the meaning of the phrase intent of. If External Surfaces Monitoring Program is not consistent with NUREG-1801, describe any differences between the two programs; 2) For tanks supported on earthen or concrete foundations, the GALL program XI.M29, Aboveground Carbon Steel Tanks, recommends a thickness measurement of the tank bottom surface as verification that unacceptable degradation is not occurring from the exterior. The External Surfaces Monitoring Program does not contain a thickness measurement of the tank bottom. Describe how the applicant will manage aging on the exterior bottom of the condensate storage tank; and 3) For tanks listed in LRA Table 3.4.2-5, describe if any of these carbon steel tanks have inaccessible tank bottoms and, if so, how these aging effects will be managed.
Section 3.5, Aging Management of Containments, Structures, and Component Supports RAI 3.5-1 In discussing Item Number 3.5.1-3 (Table 3.5.1) of the LRA, the applicant asserts that the FNP AMR results are consistent with NUREG-1801. NUREG-1801 under item A3.1 (page II A3.6) recommends further evaluation regarding the stress corrosion cracking of containment bellows.
The applicant is requested to provide additional information regarding the containment pressure boundary bellows at FNP, relevant operating experience, and method(s) used to detect their age related degradation. In many cases, VT-3 examination of IWE, and Type B, Appendix J testing cannot detect such aging effects (See NRC Information Notice 92-20).
RAI 3.5-2 For seals and gaskets related to containment penetrations, in Item Number 3.5.1-6 of the LRA, containment ISI and containment leak rate testing have been stated as the aging management programs. For equipment hatches and air-locks at FNP, the staff agrees with the applicants assertion that the leak rate testing program will monitor aging degradation of seals and gaskets, as they are leak rate tested after each opening. For other penetrations with seals and gaskets, the applicant is requested to provide information regarding the adequacy of Type B leak rate testing frequency to monitor aging degradation of seals and gaskets at FNP.
RAI 3.5-3 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.5-4 In discussion of Item 3.5.12 in Section 3.5.2.2.4, the applicant notes that the moisture barrier is monitored under IWE for aging degradation. The industry experience indicates that the moisture barrier degrades with time, and any moisture accumulation in the degraded barrier corrodes the steel liner. The applicant is requested to provide information regarding the operating experience related to the degradation of moisture barrier and the containment liner plate at FNP. Please include a discussion of acceptable liner plate corrosion before it is reinstated to the nominal thickness.
RAI 3.5-5 With reference to LRA Item 3.5.1-15, the following information is requested:
In 1985, the incident of post-tensioning anchor-head failures had occurred at FNP, Unit
- 2. The event is partially documented in NRC Information Notices 85-10 and its Supplement 1. Please provide a description of the subsequent actions taken, together with the operating experience as to the effectiveness of the corrective actions taken.
Also, indicate, if any other actions are (and will be) continued in addition to the IWL tendon inspections to ensure the integrity of the tendon anchor-heads.
RAI 3.5-6 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.5-7 With respect to the AMR result provided in Table 3.5.2-2 of the LRA (page 3.5-40) for compressible joints and seals, discuss past FNPs operating/inspection experience pertaining to change in material properties and cracking of elastomers to justify that the inspection frequency adopted in the Structural Monitoring Program is adequate to ensure proper functioning of the FNPs compressible joints and seals.
RAI 3.5-8 For the following two items, the applicant is requested to discuss the key characteristics of FNPs outside environment, its past operating/inspection experience with respect to aging management of the components listed, and justify its position that no AMP is needed for the components.
(a)
Regarding the stainless steel penetration sleeves listed on Table 3.5.2-2 (page 3.5-43) of the LRA that are exposed to outside environment, no AMP is credited to manage aging of these components. Depending on the plant site specific parameters that define the outside environment, some stainless steel components exposed to sustained, aggressive outside environment might still be subjected to appreciable loss of material aging effect.
(b)
Table 3.5.2-9, (page 3.5-64) of the LRA indicates that FNP cable trays, conduits, ducts, and tube tracks that are made of aluminum and stainless steel and exposed to inside and outside environment have no applicable aging effect requiring management and, therefore, no AMP is credited to manage their aging. Sustained exposure to a chemically aggressive or acidic outside environment might result in aging of these components.
RAI 3.5-9 Table 3.5.2-3 (page 3.5-45) of the LRA indicates that the compressible joints and seals consisting of fiber, foams and ceramics used in FNP Diesel Generator Building that are exposed to below grade environment have no applicable aging effect requiring management and, therefore, no AMP is credited to manage aging of the same. Since sustained exposure to an aggressive below grade environment might result in aging of these components, FNP is requested to discuss key characteristics of its below grade environment as well as its past operating/inspection experience with respect to aging management of these components and justify its position that no AMP is needed for the listed components.
RAI 3.5-10 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
RAI 3.5-11 There are no question associated with this RAI number. It is intentionally left as a placeholder for tracking purpose. The numbering scheme was used for the draft RAI.
Appendix B: Aging Management Programs and Activities RAI B.5.3-1 The GALL report recommends that acceptance criteria for inspections be in accordance with the ASME Code. The applicant is requested to explain if inspection criteria for the external surfaces monitoring program will be in accordance with the ASME Code. In cases where the ASME Code is not applicable, explain what criteria will be used to determine acceptability during these inspections.
Joseph M. Farley Nuclear Plant cc:
Mr. Don E. Grissette General Manager - Plant Farley Southern Nuclear Operating Company Post Office Box 470 Ashford, AL 36312 Mr. B. D. McKinney Licensing Manager Southern Nuclear Operating Company 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201-1295 Mr. Stanford M. Blanton, esq.
Balch and Bingham Law Firm Post Office Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. J. B. Beasley, Jr.
Executive Vice President Southern Nuclear Operating Company 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201 Dr. D. E. Williamson State Health Officer Alabama Department of Public Health The RSA Tower 201 Monroe Street, Suite 1500 Montgomery, AL 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, AL 36302 Mr. William D. Oldfield SAER Supervisor Southern Nuclear Operating Company Post Office Box 470 Ashford, AL 36312 Mr. Charles R. Pierce Manager - License Renewal Southern Nuclear Operating Company 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201 Mr. Fred Emerson Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319