ML070590308
| ML070590308 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/30/2007 |
| From: | Marinos E NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | Jerrica Johnson Southern Nuclear Operating Co |
| Marinos, EC, NRR/DORL 415-2911 | |
| References | |
| TAC MD3612, TAC MD3613 | |
| Download: ML070590308 (8) | |
Text
March 30, 2007 Mr. J. Randy Johnson Vice President Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, AL 35201-1295
SUBJECT:
SAFETY EVALUATION OF REVISED RELIEF REQUEST RR-12 FOR THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION AND EXAMINATION PROGRAM FOR SNUBBERS - JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MD3612 AND MD3613)
Dear Mr. Johnson:
By letter dated November 17, 2006, Southern Nuclear Operating Company, Inc., the licensee, submitted revised Relief Request RR-12 for the third 10-year inservice inspection (ISI) and testing program interval at its Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2. Relief Request RR-12 is related to the ISI and examination of snubbers.
The Nuclear Regulatory Commission (NRC) staff has completed its review of revised Relief Request RR-12 and has concluded that the proposed alternative to use revised Technical Requirements Manual Section TR 13.7.2 for snubber visual inspection and functional testing provides an acceptable level of quality and safety. Therefore, pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), the NRC authorizes the proposed alternative for the remainder of third 10-year ISI interval for FNP, Units 1 and 2. The third 10-year ISI Interval ends on November 30, 2007.
The NRC staff's safety evaluation is enclosed. If you have any questions, please contact Karen Cotton at 301-415-1438.
Sincerely,
/RA/
Evangelos C. Marinos, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
Safety Evaluation cc w/encl: See next page
March 30, 2007 Mr. J. Randy Johnson Vice President Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, AL 35201-1295
SUBJECT:
SAFETY EVALUATION OF REVISED RELIEF REQUEST RR-12 FOR THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION AND EXAMINATION PROGRAM FOR SNUBBERS - JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MD3612 AND MD3613)
Dear Mr. Johnson:
By letter dated November 17, 2006, Southern Nuclear Operating Company, Inc., the licensee, submitted revised Relief Request RR-12 for the third 10-year inservice inspection (ISI) and testing program interval at its Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2. Relief Request RR-12 is related to the ISI and examination of snubbers.
The Nuclear Regulatory Commission (NRC) staff has completed its review of revised Relief Request RR-12 and has concluded that the proposed alternative to use revised Technical Requirements Manual Section TR 13.7.2 for snubber visual inspection and functional testing provides an acceptable level of quality and safety. Therefore, pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), the NRC authorizes the proposed alternative for the remainder of third 10-year ISI interval for FNP, Units 1 and 2. The third 10-year ISI Interval ends on November 30, 2007.
The NRC staff's safety evaluation is enclosed. If you have any questions, please contact Karen Cotton at 301-415-1438.
Sincerely,
/RA/
Evangelos C. Marinos, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
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RidsNrrDorlDpr LPL2-1 R/F RidsNrrPMKCotton SLee, EDO RII RidsOgcRp RidsNrrDorlLpl2-1(EMarinos)
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G. Bedi, NRR Accession No. ML070590308 *SE input dated NRR-028 OFFICE LPL2-1/PM LPL2-1/LA CPTB/BC OGC LPL2-1/BC NAME RMartin for KCotton CSola JMcHale*
DRoth RMartin for EMarinos DATE 3/30/07 3/5/07 02/26/07 3/30/07 3/30/07 OFFICIAL RECORD COPY
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THIRD 10-YEAR INTERVAL INSERVICE EXAMINATION PROGRAM FOR SNUBBERS REVISED RELIEF REQUEST RR-12 SOUTHERN NUCLEAR OPERATING COMPANY JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364
1.0 INTRODUCTION
By letter dated November 17, 2006, Southern Nuclear Operating Company, Inc., the licensee, submitted revised Relief Request RR-12 for the remainder of the third 10-year inservice inspection (ISI) and testing program interval at Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2. Relief Request RR-12 is related to ISI and examination of snubbers. The licensee requested relief from certain ISI and examination requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code)Section XI, 1989 Edition, Article IWF-5000. IWF-5000 references ASME/American Nuclear Standards Institute Code for Operation and Maintenance of Nuclear Power Plants (OM), Part 4 (OM-4),
1987 Edition with OMa-1988 Addenda. The FNP, Unit 1 and 2 third 10-year ISI interval is scheduled to be completed by November 30, 2007.
2.0 REGULATORY EVALUATION
The ISI of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the ASME Code and applicable addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific written relief has been granted by the Nuclear Regulatory Commission (NRC or Commission), pursuant to 10 CFR 50.55a(g)(6)(i).
Section 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b), 12 months prior to the start of the 10-year interval, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for the FNP, Unit 1 and 2 third 10-year ISI interval program is the 1989 Edition.
The NRCs findings with respect to authorizing an alternative pursuant to 10 CFR 50.55a(a)(3)(i) are given below:
3.0 TECHNICAL EVALUATION
3.1 Revised Relief Request RR-12 3.1.1 Component for Which Relief is Requested All FNP, Unit 1 and 2 safety related ASME Code Class 1, 2 and 3 snubbers.
3.1.2 Code Requirements The ASME Code,Section XI, Article IWF-5000, provides inservice inspection requirements for snubbers.
Paragraphs IWF-5200(a) and IWF-5300(a) require that snubber preservice and inservice examinations be performed in accordance with OM-4, using the VT-3 visual examination method described in IWA-2213.
Paragraphs IWF-5200(b) and IWF-5300(b) require that snubber preservice and inservice tests be performed in accordance with OM-4.
Paragraphs IWF-5200(c) and IWF-5300(c) require that integral and nonintegral attachments for snubbers, including lugs, bolting, pins, and clamps, be examined in accordance with the requirements of Subsection IWF.
3.1.3 Licensees Proposed Alternative FNP proposes to use revised Technical Requirements Manual (TRM) Section TR 13.7.2, Snubbers, to perform visual examination and functional testing of ASME Code Class 1, 2 and 3 snubbers in lieu of meeting ASME Code,Section XI requirements. TRM Section TR 13.7.2 is proposed to be revised to include the following:
1.
The snubber functional test sample size of 10 percent of each snubber group in lieu of the 88 snubber inspection plan currently utilized during each refueling outage.
2.
For each snubber type that does not meet the functional test acceptance criteria, an additional 5 percent of that type of snubber shall be functionally tested until no more failures occur or until all snubbers of that type have been tested.
3.1.4 Licensees Basis for Requesting Relief The FNP, Units 1 and 2 are using TRM Section TR 13.7.2 to perform visual examination and functional testing of ASME Code Class 1, 2 and 3 snubbers in lieu of meeting ASME Code,Section XI, requirements. The use of TRM Section TR 13.7.2 was previously authorized by NRC letter dated January 12, 1999, for the third 10-year ISI interval plan.
The previous authorized TRM program consisted of visual examination of 100 percent of the snubber population each refueling outage and testing of a representative sample of 88 snubbers. The previous FNP TRM snubber examination and testing program effectively demonstrated the operational readiness of Code Class 1, 2, and 3 snubbers. The previous version of the TRM committed FNP, Unit 1 and 2 to a specific snubber functional test program due to the large number of snubbers installed on safety related systems and snubber reliability issues identified during early plant life. Over the past several years, FNP has initiated a snubber reduction program combined with greatly improved periodic maintenance, routine snubber replacement and improvements in snubber design and reliability. The initial functional test of 88 snubbers greatly exceeded the standard industry accepted sample size and is no longer warranted based on FNP and industry snubber experience. Therefore, TRM Section TR 13.7.2 is proposed to be revised to incorporate a 10 percent snubber sample plan for functional testing each refueling outage. This revision also includes provisions for sample expansion due to functional test failures which is consistent with industry standard practice.
The revised TRM maintains the original 100 percent visual examination requirement each refueling outage which is consistent with the current industry practice.
3.1.5 NRC Staff Evaluation of Revised Relief Request RR-12 The licensee requested authorization of an alternative to the requirements of the ASME Code,Section XI, Article IWF-5000. The licensee proposed that the visual examinations and functional testing of ASME Code Class 1, 2 and 3 snubbers be performed in accordance with the requirements of revised FNP TRM TR 13.7.2 in lieu of meeting the requirements in the ASME Code,Section XI, Article IWF-5000.
The applicable ASME Section XI edition for the FNP, Units 1 and 2 third 10-year ISI interval is the 1989 Edition. The ASME Code,Section XI, paragraphs IWF-5200(a), (b) and (c), and IWF-5300(a), (b), and (c) reference OM-4, 1987 Edition with OMa-1988 Addenda.
The use of TRM Section TR 13.7.2 in lieu of the ASME Section XI requirements for snubber visual examination and functional testing for the third 10-year ISI interval program was previously authorized by the NRC in a letter dated January 12, 1999. Therefore, this safety evaluation only evaluates the revised requirements in TRM Section TR 13.7.2.
TRM Section TR 13.7.2 is proposed to be revised to include the following:
1.
The snubber functional test sample size of 10 percent of each snubber group in lieu of the 88 snubber inspection plan currently utilized during each refueling outage.
2.
For each snubber type that does not meet the functional test acceptance criteria, an additional 5 percent of that type snubber shall be functionally tested until no more failures occur or until all snubbers of that type have been tested.
The revised TRM Section TR 13.7.2 requires that a functional test of 10 percent of each snubber group be performed during each refueling outage. OM-4, Section 3.2.3 requires either a 10 percent testing sample plan, a 37 testing sample plan, or a 55 testing sample plan to be selected for inservice functional testing. The FNP TRM is using a 10 percent sample plan which is equivalent to the 10 percent testing plan requirements of OM-4. As a result, the number of snubbers tested during outages are considered to be equivalent to the OM-4 requirements. Therefore, the proposed revised TRM snubber sample size provides an acceptable level of quality and safety.
Revised TRM Section TR 13.7.2 requires that for each snubber type that does not meet the functional test acceptance criteria, an additional 5 percent of that type snubber shall be functionally tested until no more failures occur or until all snubbers of that type have been tested. OM-4, paragraph 3.2.3.1(b) states that the additional sample size must be at least one-half the size of the initial sample size of the defined test plan group of snubbers. That is, for a 10 percent sample program, an additional 5 percent of the same type of snubber in the overall population would need to be tested, which is considered equivalent to the TRM requirements. Therefore, the revised TRM TR 13.7.2 requirement to sample an additional 5 percent provides an acceptable level of quality and safety.
Based on the above discussions, the staff finds that snubber visual examinations and functional testing, conducted in accordance with the proposed revised TRM Section TR 13.7.2, provides reasonable assurance of snubber operability and provides a level of quality and safety equivalent to that of the ASME Code,Section XI, Article IWF-5000. Therefore, the staff finds that the licensees proposed alternative provides an acceptable level of quality and safety with respect to snubber visual inspection and functional testing. It should be noted that in authorizing revised Relief Request RR-12, TRM TR 13.7.2 becomes a regulatory requirement that may be used in lieu of the ASME Code,Section XI requirements for performing ISI and testing of snubbers. Changes to these requirements must be reviewed and approved by the NRC staff for authorization pursuant to 10 CFR 50.55a(a)(3) or as an exemption pursuant to 10 CFR 50.12.
4.0 CONCLUSION
Based on the information provided, the staff concludes that the proposed alternative to use revised TRM TR 13.7.2 for snubber visual inspection and functional testing provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the licensees alternative is authorized for the remainder of the FNP, Unit 1 and 2 third 10-year ISI interval. The FNP, Units 1 and 2 third 10-year ISI interval program is scheduled to be completed on November 30, 2007.
Principal Contributor: G. Bedi Date: March 30, 2007
5.0 REFERENCES
U.S. Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy, Section 50.55a, Codes and standards.
American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.
American Society of Mechanical Engineers Operation and Maintenance Code, Inservice Testing of Nuclear Power Plant Components.
Letter from H. L. Sumner, of Southern Nuclear Operating Company, Inc., to NRC Joseph M.
Farley Nuclear Plants, Units 1 & 2, Third 10-Year Interval Inservice Inspection Program, Submittal of Revised Request for Relief RR-12, Docket Nos. 50-348 and 50-364, dated November 17, 2006.
Joseph M. Farley Nuclear Plant, Units 1 & 2 cc:
Mr. J. Randy Johnson Vice President - Farley Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319 Mr. J. R. Johnson General Manager Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm P.O. Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. J. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 State Health Officer Alabama Department of Public Health 434 Monroe St.
Montgomery, AL 36130-1701 Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312