ML082540260
| ML082540260 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/29/2008 |
| From: | Melanie Wong Plant Licensing Branch II |
| To: | Jerrica Johnson Southern Nuclear Operating Co |
| Jervey, Richard 301-415-2728 | |
| References | |
| FNP-ISI-ALT-02, TAC MD8131, TAC MD8132 | |
| Download: ML082540260 (7) | |
Text
September 29, 2008 Mr. J. Randy Johnson Vice President - Farley Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319
SUBJECT:
JOSEPH M FARLEY NUCLEAR PLANT, UNITS 1 AND 2, SAFETY EVALUATION FOR FNP-ISI-ALT-02 RELIEF REQUEST FROM ASME CODE REQUIREMENTS (TAC NO. MD8131 AND MD8132)
Dear Mr. Johnson:
By letter dated October 8, 2007 to the U.S. Nuclear Regulatory Commission (NRC),
(Agencywide Document Access and Management System (ADAMS) Accession No. ML072820174), supplemented by response to request for additional information dated July 22, 2008 (ADAMS Accession No. ML082050362), Southern Nuclear Operating Company, Inc. (the licensee) submitted Relief Request FNP-ISI-ALT-02 for Joseph M. Farley Nuclear Plant (FNP),
Units 1 and 2. The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI pertaining to the requirements for marking welds and areas subject to surface and/or volumetric examinations. The NRC staff determined that the proposed alternative will provide reasonable assurance that all welds which receive the ASME Code-required surface and/or volumetric examinations during the fourth ISI interval will be appropriately marked to ensure that examinations are successfully performed. Furthermore, the licensee adequately demonstrated that establishing a reference system for all welds and areas subject to surface and/or volumetric examinations in accordance with the requirements of the ASME Code,Section XI, Paragraph IWA-2610 will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the licensee's proposed alternative in Request FNP-ISI-ALT-02 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at FNP Units 1 and 2.
Sincerely,
/RA by Leonard N. Olshan for/
Melanie C. Wong, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-348 and 50-364
Enclosure:
Safety Evaluation cc w/encl: See next page
ML082050362), Southern Nuclear Operating Company, Inc. (the licensee) submitted Relief Request FNP-ISI-ALT-02 for Joseph M. Farley Nuclear Plant (FNP),
Units 1 and 2. The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI pertaining to the requirements for marking welds and areas subject to surface and/or volumetric examinations. The NRC staff determined that the proposed alternative will provide reasonable assurance that all welds which receive the ASME Code-required surface and/or volumetric examinations during the fourth ISI interval will be appropriately marked to ensure that examinations are successfully performed. Furthermore, the licensee adequately demonstrated that establishing a reference system for all welds and areas subject to surface and/or volumetric examinations in accordance with the requirements of the ASME Code,Section XI, Paragraph IWA-2610 will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the licensee's proposed alternative in Request FNP-ISI-ALT-02 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at FNP Units 1 and 2.
Sincerely,
/RA by Leonard N. Olshan for/
Melanie C. Wong, 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: Public LPL2-1 R/F RidsOgcRp Resource RidsNrrLAGLappert Resource RidsNrrDorlLpl2-1 Resource RidsAcrsAcnwMailCenter Resource RidsNrrPMKFeintuch Resource RidsRgn2MailCenter Resource Accession Number:ML082540260
- By Memo dated: 8/14/08 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA DCI/CVIB OGC LPL2-1/BC NAME KFeintuch GLappert MMitchell JBielecki, NLO MWong, LNO for DATE 9/15/08 9/15/08 8/14/08 9/23/08 9/29/08
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. 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 Mr. Kirksey Whatley Director, Office of Radiation Control Alabama Department of Public Health 201 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
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR PROPOSED ALTERNATIVE FNP-ISI-ALT-02 JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
DOCKET NUMBERS 50-348 AND 50-364
1.0 INTRODUCTION
By letter dated October 8, 2007 to the U.S. Nuclear Regulatory Commission (NRC),
(Agencywide Document Access and Management System (ADAMS) Accession No. ML072820174), supplemented by response to request for additional information dated July 22, 2008 (ADAMS Accession No. ML082050362), Southern Nuclear Operating Company, Inc. (the licensee) submitted Relief Request FNP-ISI-ALT-02 for Joseph M. Farley Nuclear Plant (FNP),
Units 1 and 2. The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI pertaining to the requirements for marking welds and areas subject to surface and/or volumetric examinations.
2.0 REGULATORY REQUIREMENTS Inservice inspection (ISI) of ASME Code Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g), except where specific relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i). 10 CFR 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, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulation requires 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) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable Code of record for the
fourth 10-year interval ISI program at FNP Units 1 and 2 is the 2001 Edition through the 2003 Addenda of the ASME Code,Section XI. The fourth 10-year interval ISI program at FNP Units 1 and 2 began on December 1, 2007, and is scheduled to end on November 30, 2017.
3.0 EVALUATION 3.1 Component Identification Request FNP-ISI-ALT-02 addresses all ASME Code Class 1, 2 and 3 welds and areas that are subject to surface and/or volumetric examination.
3.2 Staff Evaluation As noted by the licensee, the 2001 Edition through the 2003 Addenda of the ASME Code,Section XI, Paragraph IWA-2610 requires that a reference system be established for all welds and areas subject to surface or volumetric examination. Paragraph IWA-2610 also states that each weld and area shall be located and identified by a system of reference points. The reference system shall permit identification of each weld, location of each weld centerline, and designation of regular intervals along the length of the weld.
Pursuant to 10 CFR 50.55a(a)(3)(ii), Request FNP-ISI-ALT-02 proposed an alternative to the requirements of the ASME Code,Section XI, Paragraph IWA-2610. In this request, the licensee specifically requested authorization to mark individual welds and areas as the surface or volumetric examinations are being performed in lieu of the requirements of Paragraph IWA-2610, which mandates the marking of all welds and areas subject to surface or volumetric examination prior to the actual performance of the ISI examinations. The licensee provided the following justification for its proposed alternative:
For an operating plant, establishing a weld reference system for all welds and areas subject to surface or volumetric examination is a major effort and, in some cases, is prohibitive due to inaccessibility and/or high radiation areas. To establish a comprehensive weld reference system for all of the welds and areas subject to volumetric or surface examinations in accordance with the Code requirements would require many man-hours of work and many man-rem of exposure to locate the welds, remove the insulation, mark the welds, and re-install the insulation. Since only a small percentage of welds are normally examined, the majority of the welds that would be marked per the Code requirement would never receive an inservice examination. To require the marking of all of the welds and areas subject to surface or volumetric examination in an operating plant environment, even though most will not require examination, would result in a hardship without a compensating increase in quality and safety.
Marking the welds and areas that are receiving an examination will provide assurance, that when performing subsequent examinations, the correct weld is being re-examined and the recorded indications can be correlated with previous data. Not marking the welds and areas which are not receiving examination will have little, if any, affect on safety and quality at Plant Farley; therefore, approval of this request per 10 CFR 50.55a(a)(3)(ii) should be granted.
The requirements of Paragraph IWA-2610 are meant to ensure that all welds and areas that are subject to surface and/or volumetric examinations are appropriately marked to facilitate quality examinations that meet the requirements of Articles IWB-2000, IWC-2000, and IWD-2000, for ASME Code Class 1, 2, and 3 components, respectively. The NRC staff reviewed the licensees proposed alternative and determined that marking welds as they receive the ASME Code-required surface and/or volumetric examinations will not have an adverse impact on the quality of the examinations being performed provided that the actual weld marking process continues to comply with the requirements of the ASME Code,Section XI, Paragraphs IWA-2620, IWA-2630, and IWA-2640. Paragraphs IWA-2620, IWA-2630, and IWA-2640 address the requirements for physically marking the individual welds. These paragraphs include requirements for identification of the weld centerline as well as the placement and spacing of reference points along the length of the weld. These detailed marking requirements help ensure that welds actually receiving surface and/or volumetric examinations during the ISI interval will receive quality examinations. The licensee did not indicate in its October 8, 2007, letter whether the proposed alternative would continue to meet the requirements of Paragraphs IWA-2620, IWA-2630, and IWA-2640.
The NRC staff requested additional information to have the licensee clarify several issues regarding their implementation of the proposed alternative. First, the NRC staff requested that the licensee indicate whether welds and regions that receive surface and/or volumetric examinations during the fourth ISI interval will be marked in accordance with the requirements of Paragraphs IWA-2620, IWA-2630, and IWA-2640. Second, the NRC staff requested that the licensee indicate whether the proposed alternative will have any impact on the actual performance of ISI examinations under Articles IWB-2000, IWC-2000, and IWD-2000.
In the licensees response to the request for additional information (RAI), dated July 22, 2008, (ADAMS Accession No. ML082050362), the licensee stated that welds and regions that receive surface and/or volumetric examinations during the fourth ISI interval will be marked in accordance with the requirements of Paragraphs IWA-2620, IWA-2630, and IWA-2640. The licensee also indicated in its RAI response that marking actual welds as they receive their fourth ISI interval examinations will not have any impact on the successful performance of these examinations under Articles IWB-2000, IWC-2000, and IWD-2000. The NRC staff determined that the licensees RAI response adequately resolved the issues raised in the RAI because the licensee stated in the RAI response that all welds and areas receiving surface and/or volumetric examinations during the fourth ISI interval will be marked in accordance with the requirements of Paragraphs IWA-2620, IWA-2630, and IWA-2640 and that the proposed alternative will not impact the successful performance of these examinations. Therefore, based on the information provided in its initial submittal and RAI response, the NRC staff determined that the proposed alternative will provide reasonable assurance that all welds which receive the ASME Code-required surface and/or volumetric examinations during the fourth ISI interval will be appropriately marked to ensure that examinations are successfully performed.
Furthermore, the NRC staff finds that by the foregoing discussion of the work effort and man-rem of exposure necessary to mark all welds relative to the number of welds to receive an inservice examination, the licensee adequately demonstrated that establishing a reference system for all welds and areas subject to surface or volumetric examination in accordance with the requirements of the ASME Code,Section XI, Paragraph IWA-2610 will result in hardship or
unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the NRC staff found that alternative proposed by the licensee in Request FNP-ISI-ALT-02 is acceptable.
4.0 CONCLUSION
The NRC staff concludes that the licensees proposed alternative will provide reasonable assurance that all welds which receive the ASME Code-required surface and/or volumetric examinations during the fourth ISI interval will be appropriately marked to ensure that examinations are successfully performed. Furthermore, the licensee adequately demonstrated that establishing a reference system for all welds and areas subject to surface and/or volumetric examinations in accordance with the requirements of the ASME Code,Section XI, Paragraph IWA-2610 will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the licensee's proposed alternative in Request FNP-ISI-ALT-02 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at FNP Units 1 and 2. All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested and approved, remain applicable, including third party review by the Authorized Nuclear Inservice Inspector (ANI).
Principal Contributor: C. Sydnor Date: September 29, 2008