NL-08-1085, Response to Request for Additional Information FNP-ISI-ALT-02, Version 1.0, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)
| ML082050362 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/22/2008 |
| From: | Ajluni M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-08-1085 | |
| Download: ML082050362 (4) | |
Text
Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, Alabama 35201 -1295 Tel 205.992.5000 SOUIHERN'\\
COMPANY July 22,2008 Energy to Serve Your World SM Docket Nos.: 50-348 NL-08-1Q85 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 & 2 FNP-ISI-ALT-02, Version 1.0, Proposed Alternative in Accordance With 10 CFR 50.55a(a)(3)(iil Ladies and Gentlemen:
In letter dated October 8,2007, Southern Nuclear Operating Company (SNC) submitted a request for NRC approval of proposed Alternative FNP-ISI-ALT-02. This Alternative proposes that each weld and area undergoing a surface or volumetric examination will receive the Code required reference markings and identification, as the examinations are being performed, in lieu of marking all of the welds and areas as required by the Code. The proposed alternative is applicable for the 4th Inservice Inspection Interval. Approval was requested by September 14, 2008, to support 4th interval examinations to be performed during the fall 2008 Outage at FNP-2.
On July 1, 2008, a NRC Request for Additional Information (RAI) was received regarding the proposed Alternative. The SNC response to the requested information is provided in the Enclosure.
This letter contains no NRC commitments. If you have any questions, please advise.
Sincerely,
~~et-:
M. J. Ajluni Manager, Nuclear Licensing MJAlBDM/daj
Enclosure:
- 1. Request for Additional Information - Southern Nuclear Response
- u. S. Nuclear Regulatory Commission NL-08-1085 Page 2 cc:
Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. H. Jones, Vice President - Engineering RTYPE: CFA04.054; LC# 14797 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley
Joseph M. Farley Nuclear Plant - Units 1 & 2 Request for Additional Information Southern Nuclear Response Request for Additional Information Southern Nuclear Response
- 1. Please explain whether the proposed alternative will eliminate the marking of welds normally sUbject to Paragraph IWA-2610 requirements, but not actually receiving examinations during the 4th lSI interval.
SNC Response - The ASME Code did not require the marking of welds until Plant Farley started the 3rd 151 interval. Plant Farley established a weld reference methodology and a permanent weld marking system for welds receiving an NDE examination (surface or volumetric examination) in the 3rd 151 interval; however, this was limited to those welds being examined for 3rd 151 interval credit. SNC submitted RR-11 to implement these requirements in May 1997 and the NRC approved the relief request in January 1999. Alternative FNP-ISI-ALT-02 has been written to continue this for the 4th 151 interval. The identification markings of the welds that are scheduled to be examined will enable SNC to accurately identify any given weld during the subsequent examinations. In addition, the identification markings will facilitate accurate identification of the previously recorded indications that are associated with the subject weld.
Since only a limited number of welds will undergo either surface or volumetric examinations, the proposed alternative will eliminate the marking of welds normally subject to Paragraph IWA-2610 requirements, but not actually receiving examinations during the 4th 151 interval. SNC believes that establishing a comprehensive reference markings and identification system for only those welds that undergo 151 examinations will not compromise safety and quality.
In summary, the NDE examinations performed per Subsections IWB, IWC, and IWD during the 4th 151 interval for preservice and inservice, as well as sample expansion examinations, will include the marking, per Paragraph IWA-2610, of only those welds that will be examined.
- 2. Will welds and regions sUbject to surface or volumetric examination continue to receive markings as required by the ASME Code,Section XI, Paragraphs IWA-2620, IWA-2630, and IWA-2640?
SNC Response - Yes.
- 3. Will the proposed alternative have any impact on the performance of lSI examinations under Subsections IWB, IWC, and IWO, specifically with respect to sampling and sample expansion requirements?
SNC Response - No.
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