ML041380394
| ML041380394 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/17/2004 |
| From: | Tilda Liu NRC/NRR/DRIP/RLEP |
| To: | |
| Liu T, NRR/DRIP/RLEP, 415-1315 | |
| References | |
| TAC MC0774, TAC MC0775 | |
| Download: ML041380394 (14) | |
Text
May 17, 2004 LICENSEE:
Southern Nuclear Operating Company FACILITY:
Joseph M. Farley Nuclear Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCES ON APRIL 21, 26, AND 30, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE SOUTHERN NUCLEAR OPERATING COMPANY CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION ON JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC0774 AND MC0775)
The U.S. Nuclear Regulatory Commission staff and representatives of Southern Nuclear Operating Company (SNC or the applicant) held telephone conferences on April 21, 26, and 30, 2004, to discuss the applicants responses/questions to the requests for additional information (RAIs) that were issued by the staff concerning the Joseph M. Farley Nuclear Plant (FNP) license renewal application.
The conference calls were useful in clarifying the intent of the staffs questions. On the basis of the discussion, the applicant was able to better understand the staff's questions. No staff decisions were made during the telephone conferences. In some cases, the applicant agreed to provide revised or supplemental information for clarification. provides a list of the telephone conference participants. Enclosure 2 contains a listing of the RAIs, or questions/clarifications discussed with the applicant, including a brief description on the status of the items. The applicant has had an opportunity to review and comment on this summary.
/RA/
Tilda Y. 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
Enclosures:
As stated cc w/enclosures: See next page
May 17, 2004 LICENSEE:
Southern Nuclear Operating Company FACILITY:
Joseph M. Farley Nuclear Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCES ON APRIL 21, 26, AND 30, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE SOUTHERN NUCLEAR OPERATING COMPANY CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION ON JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC0774 AND MC0775)
The U.S. Nuclear Regulatory Commission staff and representatives of Southern Nuclear Operating Company (SNC or the applicant) held telephone conferences on April 21, 26, and 30, 2004, to discuss the applicants responses/questions to the requests for additional information (RAIs) that were issued by the staff concerning the Joseph M. Farley Nuclear Plant (FNP) license renewal application.
The conference calls were useful in clarifying the intent of the staffs questions. On the basis of the discussion, the applicant was able to better understand the staff's questions. No staff decisions were made during the telephone conferences. In some cases, the applicant agreed to provide revised or supplemental information for clarification. provides a list of the telephone conference participants. Enclosure 2 contains a listing of the RAIs, or questions/clarifications discussed with the applicant, including a brief description on the status of the items. The applicant has had an opportunity to review and comment on this summary.
/RA/
Tilda Y. 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
Enclosures:
As stated cc w/enclosures: See next page DISTRIBUTION: See next page Accession No: ML041380394 Document Name:C:\\MYFILES\\Copies\\ConfCall-Summary 4-21 thru 4-30-04.wpd OFFICE LA:RLEP CO-OP:RLEP PM:RLEP SC:RLEP NAME YEdmonds DChen TLiu SLee DATE 5/13/04 5/13/04 5/17/04 5/17/04 OFFICIAL RECORD COPY
DISTRIBUTION: Note to Licensee: Southern Nuclear Operating Co., Re: Joseph M. Farley Date: May 17, 2004 Accession No: ML041380394 HARD COPY RLEP RF T. Liu (PM)
D. Chen J. Strnisha P.Y. Chen D. Jeng E-MAIL:
PUBLIC D. Matthews F. Gillespie C. Grimes RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair S. Black B. Boger D. Thatcher R. Pettis G. Galletti C. Li M. Itzkowitz R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff C. Julian (R-II)
C. Patterson (R-II)
R. Fanner (R-II)
S. Peters R. Hoefling (OGC)
OPA B. Jain L. Whitney LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCES ON CLARIFICATION FOR THE REQUESTS FOR ADDITIONAL INFORMATION RESPONSES APRIL 21-30, 2004 April 21, 2004 Participants Affiliation Tilda Liu U.S. Nuclear Regulatory Commission (NRC)
David Chen NRC Jim Strnisha NRC Jan Fridrichsen Southern Nuclear Operating Company (SNC)
Mike Macfarlane SNC April 26, 2004 Participants Affiliation Tilda Liu NRC P. Y. Chen NRC Shiu-Wing Tam Argonne National Laboratory (ANL)
Jan Fridrichsen SNC Mike Macfarlane SNC Chuck Pierce SNC Lou Bohn SNC Bill Evans SNC Danny Stephens SNC April 30, 2004 Participants Affiliation Tilda Liu NRC David Chen NRC David Jeng NRC Mike Macfarlane SNC Partha Ghosal SNC Danny Stephens SNC Bill Evans SNC Chuck Pierce SNC Jan Fridrichsen SNC REVIEW OF LICENSE RENEWAL APPLICATION (LRA) FOR FARLEY UNITS 1 AND 2 CLARIFICATION OF REQUESTS FOR ADDITIONAL INFORMATION (RAI) RESPONSES April 21, 2004 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.
The applicants provided the following response for this RAI via letter dated March 5, 2004.
LRA Table 3.4.2-1 applies to components in the Main Steam System.Section VIII.B1, Main Steam System (PWR), of NUREG-1801 recommends Water Chemistry to manage loss of material for carbon steel components in a steam environment. A one-time inspection is not specified. LRA Table 3.4.1 Item Number 3.4.1-7 is the NUREG-1801 (GALL) aging management evaluation summary item that applies to these Main Steam System components. FNP conservatively managed alloy steel the same as carbon steel. The GALL report summary item that recommends water chemistry control and a one-time inspection to manage loss of material for the steam and power conversion systems (LRA Table 3.4.1 Item Number 3.4.1-2) excludes the main steam system.
A one-time inspection is not necessary for Main Steam System components because the very low oxygen concentration and the ultra-high purity of the steam exiting the steam generators precludes significant corrosion of the carbon steel and alloy steel components in this system. While the steam traps will be exposed to treated water (condensed steam) as well as steam, there is not sufficient oxygen or contaminants in the condensed steam to promote significant corrosion of alloy steel components. This position is supported by FNP operating experience. This is consistent with LRA Table 3.4.1, Summary of Aging Management Evaluations for Steam and Power Conversion Systems in Chapter VIII of NUREG-1801, Item Number 3.4.1-7.
Discussion: The staff stated that a one-time inspection is necessary because the purified steam had a low moisture content that would result in corrosion of the carbon alloy steel pipes.
The applicant indicated that a one-time inspection program will be put in place for the steam traps in the Main Steam System. The applicant stated that the supplemental response for this RAI will be sent to the staff for further review.
REVIEW OF LICENSE RENEWAL APPLICATION (LRA) FOR FARLEY UNITS 1 AND 2 CLARIFICATION OF REQUESTS FOR ADDITIONAL INFORMATION (RAI) RESPONSES April 26, 2004 RAI 3.3-6 In several systems (including the control room area ventilation system, the auxiliary and radwaste area ventilation system, and the liquid waste and drains system), the applicant credited the One-Time Inspection Program for managing the aging effects of loss of materials, change in material property, and cracking for elastomers components. However, the One-Time Inspection Program is intended for use as a verification AMP to check the degree of aging of components when significant aging is not expected, while periodic inspections are more appropriate if aging effects can reasonably be expected to occur. The degradation of elastomers depends upon the service loads and environmental conditions, including temperature, radiation level, and presence of aggressive chemicals. The applicant is requested to provide additional information on the service loads and environment of the components to justify the use of One-Time Inspection Program for managing the aging effects of elastomers.
The applicants provided the following response for this RAI via letter dated April 5, 2004.
Background on Environmental Considerations for Elastomers EPRI Technical Report TR-1002950, Aging Effects for Structures and Structural Components (Structural Tools), Revision 1, indicates that elastomers are potentially subject to thermal degradation. Thermal degradation results in changes in the elastomer properties and potentially cracking. The EPRI Structural Tools reports continuous temperature ratings for the evaluated elastomers ranging from 130 F for natural rubber to 275 F for silicone rubber. The EPRI Structural Tools states that in general, if the ambient temperature is less than 95 F, then thermal aging is not significant for the period of extended operation. This is a conservative threshold temperature intended to encompass all elastomer materials. When the specific elastomer material type is considered, installation in thermal environments marginally above 95 F may also not be susceptible to significant thermal degradation.
The EPRI Structural Tools indicates that degradation of natural rubbers can occur through simultaneous exposure to ultraviolet radiation and oxygen, which supports an ozone - rubber reaction that embrittles the rubber and can result in cracking or checking. Sources of ultraviolet radiation include both sunlight and ultraviolet or fluorescent lamps. Areas exposed to direct sunlight are expected to have the highest potential for degradation due to ultraviolet radiation / ozone exposure since this environment best supports both the formation of ozone and the reaction between ozone and natural rubbers. The EPRI Structural Tools indicates that nitrile rubber, butyl rubber, silicone rubber, and neoprene either have good resistance to ultraviolet / ozone degradation or are essentially unaffected by ultraviolet radiation / ozone.
The EPRI Structural Tools indicates that ionizing radiation can significantly alter the molecular structure and material properties of elastomers. Radiation levels exceeding 106 Rads is the lowest reported threshold for irradiation effects in an elastomer of the types in scope for license renewal. Conservatively, radiation embrittlement is postulated for elastomers in locations above this threshold.
Attack by chemical species is also a potential degradation mechanism. Experience has shown that rubbers can be embrittled by exposure to certain chemicals present in nuclear power plants. Table 28-27 of Perrys Chemical Engineers Handbook notes that most all natural and synthetic rubbers offer poor resistance to oils and fuel products.
Resistance to water and acids is noted to be fair to good for some rubbers and excellent for others, with resistance to acid attack generally the limiting factor.
Discussion of FNP Environments for Elastomers in Scope of One-Time Inspection Program:
Control Room Area Ventilation System: Elastomer components in the Control Room Area Ventilation System are located inside the Non-Rad portion of the Auxiliary Building.
These components are protected from environmental effects, have no radiation loading, are not subject to attack by aggressive chemicals, and operate at temperatures below which thermal degradation is a significant concern.
Auxiliary & Radwaste Area Ventilation System: The in-scope elastomer components in the Auxiliary & Radwaste Area Ventilation System are divided between two locations (Rad-portion and Non-Rad portion of the Auxiliary Building). Flexible connectors for the battery room exhaust fans are located inside the Non-Rad portion of the Auxiliary Building. These components are protected from environmental effects, have no radiation loading, are not subject to attack by aggressive chemicals, and operate at temperatures below which thermal degradation is a significant concern. Flexible connectors for the penetration room filtration fans are located inside the Rad portion of the Auxiliary Building. These components are protected from environmental effects, are not subject to attack by aggressive chemicals, and operate at temperatures below which thermal degradation is a significant concern. While these components are located in the Rad portion of the Auxiliary Building, normal operating conditions provide for no significant radiation loading.
Primary Containment Ventilation System: The in-scope elastomer components in the Primary Containment Ventilation System are divided between two locations. Flexible connectors for the containment purge fans are located inside the Rad portion of the Auxiliary Building. These components are protected from environmental effects, are not subject to attack by aggressive chemicals, and operate at temperatures below which thermal degradation is a significant concern. While these components are located in the Rad portion of the Auxiliary Building, normal operating conditions provide for no significant radiation loading. Flexible connectors for the containment coolers are located inside the Containment Building. These components are replaced periodically as a preventive maintenance task. These components are therefore short-lived and not subject to an aging management review.
Liquid Waste & Drains System: The Elastomer components in the Liquid Waste &
Drains System are expandable plugs used to plug the penetration room floor drains.
Plugging of the floor drains is necessary to provide a pressure boundary for the Penetration Room Filtration System. These floor drain plugs are located inside the Rad portion of the Auxiliary Building. These components are protected from environmental effects and operate at temperatures below which thermal degradation is a significant concern. While these components are located in the Rad portion of the Auxiliary Building, normal operating conditions provide for no significant radiation loading. The floor drain plugs are installed in drains which would collect leakage, spills, etc. Although unlikely, exposure to aggressive chemicals is considered. The One-Time Inspection Program will confirm the plugs have not been exposed to conditions detrimental to the seals.
==
Conclusion:==
SNC considers the one-time inspection program an appropriate aging management program for these elastomer components. These elastomer components are installed in locations which provide minimal exposure to potential aging mechanisms therefore significant aging is not expected.
Discussion: The staff provided a facsimile copy of the following to the applicant on April 22, 2004, to facilitate the follow-up discussion of this RAI.
The staff reviewed the response of applicant to RAI 3.3-6. In order to complete the review the staff requested the following clarifications.
The applicant stated that for the Rad portion of the Auxiliary Building, normal operating conditions provide for no significant radiation loading. The applicant is requested to clarify whether under normal operating condition, the Rad portion of the Auxiliary Building is under a radiation loading below that of 106 Rads, the lowest reported threshold for irradiation effects in an elastomer of the types in scope for license renewal according to EPRI Technical Report TR-1002950, Aging Effects for Structures and Structural Components (Structural Tools), Revision 1. Provide industry and/or plant-specific operating experience on radiation-related aging degradation of these elastomer components.
The applicant stated that in the Liquid Waste & Drains System, the floor drain plugs are installed in drains which would collect leakage, spills, etc. and that although unlikely, exposure to aggressive chemicals is considered. Clarify the extent of the presence or absence of aggressive chemicals in leakage, spills etc. to justify the conclusion that exposure to aggressive chemicals is unlikely. Provide industry and/or plant-specific operating experience on the aggressive chemicals-related aging degradation of these elastomer components.
As a result of the discussion, the applicant agreed to provide the information/clarification requested by the staff.
RAI 3.3-11 Loss of material due to general, pitting, crevice, microbiologically influenced corrosion and biofouling is a plausible aging effect for stainless steel and carbon steel in the raw water environment or stainless steel exposed to lube oil that may be contaminated with water. In the LRA, the applicant credited the One-Time Inspection AMP for managing the loss of material aging effect on stainless steel and carbon steel piping and valve bodies exposed to raw water environment or stainless steel components exposed to lube oil that may be contaminated with water. However, the staff notes that the one-time inspection program is intended for use as a verification AMP to check the degree of aging of components when significant aging is not expected, while periodic inspections are more appropriate if aging effects can reasonably be expected to occur. The applicant is requested to provide justification for why the one-time inspection is appropriate for managing the identified aging effect.
The applicants provided the following response for this RAI via letter dated April 5, 2004.
Stainless Steel Exposed to Lubricating Oil w/ Potential Water Contamination (RCP Oil Collection System):
In Section 3.3 (Aging Management of Auxiliary Systems) of the LRA, SNC credits the One-Time Inspection (OTI) Program to manage stainless steel components in a lubricating oil environment for the RCP oil collection system. The RCP oil collection system is an open oil leakage collection system which is designed to collect potential external leakage from the RCP motor lubricating oil system. The RCP oil collection system includes open drip pans and therefore the presence of water contamination from the general area environment was assumed to be plausible although significant contamination is not anticipated. Stainless steel is very resistant to general corrosion, pitting, crevice, and MIC and biofouling is not expected. Additionally, the FNP operating experience review did not identify any applicable aging issues. Therefore, SNC considers use of the OTI Program for the stainless steel components in the RCP oil collection system appropriate to confirm no significant aging is occurring.
Stainless Steel And Carbon Steel Piping And Valve Bodies Exposed To Raw (Unmonitored) Water Environment:
SNC credits the OTI Program for the following carbon steel and stainless steel components that are exposed to raw water:
control room air conditioning cooling coil units,
drain piping and valves in the Liquid Waste and Drains system, and
piping, valves, and a tank in the Potable and Sanitary Water System.
These systems operate at low pressure and ambient temperature. While some degree of corrosion is expected in these components, SNC does not expect significant aging to occur in these components that could cause loss of component intended function(s). If significant aging is discovered, appropriate corrective action will be initiated to ensure the intended functions are maintained during the period of extended operation. Specific discussion of each item follows.
Control Room Air Conditioning Cooling Coil Units: The raw water environment for these units is moisture/condensation that may form on the units. The units are designed for this environment with the selection of materials intended to provide reliable service. The carbon steel that may potentially be wetted is galvanized. The One-Time Inspection Program is appropriate to inspect the unit and confirm significant aging is not occurring.
Drain Piping And Valves In The Liquid Waste And Drains System: The drain piping and valves in the liquid waste and drains system operate at low pressure and temperature and are used on an intermittent basis. Typically the piping is dry, however the LRA environment assumes the most limiting environment of raw water. This raw water is better characterized as an unmonitored and uncontrolled water source. The One-Time Inspection Program is appropriate to inspect and confirm significant aging is not occurring in the drain piping and valves.
Piping, Valves, and Tank In The Potable And Sanitary Water System: Although described as raw water, the potable and sanitary water system water is well water or potable water as described in LRA Table 3.0.4-1. The water is taken from deep wells and run through clarifiers. Operating experience with these types of systems does not indicate SNC should expect significant aging. The One-Time Inspection Program is appropriate to inspect and confirm significant aging is not occurring.
These systems operate at low pressure and ambient temperature. While some degree of corrosion is expected in these components, SNC does not expect significant aging to occur in these components. SNC will use the One-Time Inspection Program to determine if corrosion has occurred during the current operating term to such an extent that additional actions might be required during the renewal term. Such actions could include additional inspections, component replacements, or other appropriate measures.
Discussion: The staff provided a facsimile copy of the following to the applicant on April 22, 2004, to facilitate the follow-up discussion of this RAI.
The staff reviewed the response of applicant to RAI 3.3-11. In order to complete the review the staff requested the following clarifications.
For the Control Room Air Conditioning Cooling Coil Units the applicant stated that the raw water environment for these units is moisture/condensation that may form on the units. Clarify whether the raw water from moisture/condensation would provide a periodic/intermittent drying /wetting environment. If so justify the use of One-Time Inspection as an aging management program.
For the Drain Piping And Valves In The Liquid Waste And Drains System the applicant stated that the drain piping and valves in the liquid waste and drains system operate at low pressure and temperature and are used on an intermittent basis. Clarify whether the unmonitored and uncontrolled water source on an intermittent basis as stated by the applicant would provide a periodic/intermittent drying /wetting environment. If so justify the use of One-Time Inspection as an aging management program.
As a result of the discussion, the applicant agreed to provide the information/clarification requested by the staff.
RAI 3.3.2.1.15-2 In LRA Table 3.3.2-15 for emergency diesel generator system, for most copper alloy or stainless steel components exposed to an air/gas (wetted) environment, the LRA identifies loss of material as the applicable aging effect and credits the One-Time Inspection Program for aging management. However, for ducts and fittings in the intake/exhaust system, and the pipes and valve bodies in the air start system, the LRA also identifies cracking as an applicable aging effect, and credits the One-Time Inspection Program for aging management. The applicant is requested to explain the difference in aging effects for apparently similar material/environment combinations. If the cracking is due to cyclic loading of specific components, justify the use of the One-Time Inspection Program in lieu of periodic inspections, since such cracking may have a long incubation period.
The applicants provided the following response for this RAI via letter dated April 5, 2004.
Stress corrosion cracking (SCC) was identified as an aging effect requiring management for Emergency Diesel Generator (EDG) System stainless steel and copper alloy components in an air/gas (wetted) environment subject to elevated temperatures.
For stainless steels, the SNC utilizes a threshold temperature of 140 F for susceptibility to SCC.
SCC was determined to be a potential aging effect for stainless steels in the EDG exhaust system's air/gas (wetted) environment. The air/gas (wetted) environment elevated temperatures during EDG operation produced by the high temperature exhaust gases. These exhaust gases include water vapor and various corrosive combustion products. SNC does not expect SCC to actually occur given the limited number of times that each diesel generator is operated over the course of 60 years of plant operation and the proximity of the exhaust temperatures to the threshold temperature for SCC.
However, SNC has insufficient data to rule out the possibility of the aging effect therefore it is prudent to perform a one-time inspection to assure that cracking is not occurring.
SCC is not an applicable aging effect for the stainless steels in the EDG intake system's air/gas (wetted) environment. The EDG intake system operates at ambient temperatures and is not subject to elevated temperatures. Cracking should not have been indicated in LRA Table 3.3.2-15 for the stainless steel ducts and fittings in the EDG intake system.
SCC was determined to be a potential aging effect for stainless steels and copper alloys in portions of the EDG air start system exposed to the air/gas (wetted) environment with elevated temperatures. Specifically, air exiting the compressors will heat the downstream components. The one-time inspection is specifically meant to examine the inlet piping for the air receivers on the 1-2A emergency diesel generator. The air start subsystem for this diesel generator does not include an after cooler/air dryer assembly.
As such, potentially moist air at temperatures above 140 F could be in contact with the in-scope stainless steel and copper alloy components. While SNC does not consider stress corrosion cracking likely, SNC does not have sufficient data (the removal of the after cooler and air drier is a recent modification) to rule out the possibility; therefore, it is prudent to perform a one-time inspection to assure that cracking is not occurring.
Discussion: The staff provided a facsimile copy of the following to the applicant on April 22, 2004, to facilitate the follow-up discussion of this RAI.
The staff reviewed the response of applicant to RAI 3.3.2.1.15-2. In order to complete the review the staff requested the following clarifications.
For stainless steels, the applicant utilizes a threshold temperature of 140 F for susceptibility to SCC. It is not clear what temperature threshold was used for copper alloy. Provide the criteria and discuss whether the answer will affect the response to the RAI.
In discussing the potential aging effect for stainless steel in the EDG exhaust systems air/gas (wetted) environment, the applicant stated that... limited number of times that each diesel generator is operated...the proximity of the exhaust temperatures to the threshold temperature for SCC. Provide, based on the operating records, information concerning the number of times and the exhaust temperatures, and discuss and justify the use of One-Time Inspection program to manage the potential aging effects.
The applicant stated that the air start subsystem for this diesel generator does not include an after cooler/air dryer assembly. As such, the applicant further stated that, potentially moist air at temperatures above 140 F could be in contact with the in-scope stainless steel and copper alloy components. Therefore, using the criterion adopted by the applicant, the component is susceptible to SCC. Yet, the applicant considered that in this case SCC is unlikely. Justify this conclusion. If the component is susceptible to SCC and not unlikely then the applicant is requested to justify the applicability of One-Time Inspection as the applicable AMP.
As a result of the discussion, the applicant agreed to provide the information/clarification requested by the staff.
REVIEW OF LICENSE RENEWAL APPLICATION (LRA) FOR FARLEY UNITS 1 AND 2 CLARIFICATION OF REQUESTS FOR ADDITIONAL INFORMATION (RAI) RESPONSES April 30, 2004 Section 2.4: Scoping and Screening Results: Containments, Structures, and Component Supports RAI 2.4-8 The staff requests additional information concerning the possibility that thermal insulation may serve an intended function, in accordance with 10 CFR 54.4(a)(2), to control the maximum temperature of safety-related structures and structural components that meet 10 CFR 54.21(a)(1). Possible examples are maintaining the maximum temperature of steel and/or concrete elements of nuclear steam supply system (NSSS) supports below the levels assumed in the design basis of the supports; and maintaining the maximum temperature of structural concrete below the threshold levels of 150oF for general areas and 200oF for local areas around hot penetrations.
Thermal insulation is typically passive and long-lived. If it also serves an intended function, then it meets the criteria for inclusion within the scope of license renewal, in accordance with 10 CFR 54.4(a)(2). Consequently, the applicant is requested to (1) identify any thermal insulation at FNP, Units 1 and 2, that serves an intended function in accordance with 10 CFR 54.4(a)(2); (2) describe plant-specific operating experience related to degradation of a) thermal insulation in general, and b) thermal insulation that serves an intended function in accordance with 10 CFR 54.4(a)(2); and (3) describe the scoping and screening evaluation for thermal insulation that serves an intended function in accordance with 10 CFR 54.4(a)(2),
including the technical basis for either inclusion within or exclusion from the scope of license renewal.
Discussion: The applicant indicated that the question appeared to require the identification of all thermal insulations at FNP, Units 1 and 2, that serve an intended function in accordance with 10 CFR 54.4(a)(2). The staff clarified that the requested thermal insulations were limited to containments, structures, and component supports. The applicant agreed that the question was clarified.
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 Mr. L. M. Stinson, Jr.
Vice President - Farley Project Southern Nuclear Operating Company 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201