NL-16-1969, Proposed Lnservice Inspection Alternative FNP-ISI-ALT-20, Version 1.0

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Proposed Lnservice Inspection Alternative FNP-ISI-ALT-20, Version 1.0
ML16342C529
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 12/07/2016
From: Pierce C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
FNP-151-ALT-20, NL-16-1969
Download: ML16342C529 (19)
v • d • e


Text

Charles A. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

4.. Southern Nuclear 40 Inverness Center Parkway Post Office Box 1295 Binningham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 CEC 0 7 2016 Docket Nos.: 50-348 NL-16-1969 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant, Unit 1 Proposed lnservice Inspection Alternative FNP-ISI-ALT -20, Version 1.0 Ladies and Gentlemen:

In accordance with 10 CFR 50.55a(z)(2), Southern Nuclear Operating Company (SNC) hereby requests Nuclear Regulatory Commission (NRC) approval of proposed inservice inspection (lSI) alternative FNP-ISI-ALT-20, Version 1.0. This alternative requests authorization to perform the examination of selected Class 1 piping and valves at plant conditions other than those required by IWB-5222(b) by using the alternative boundaries permitted by Code Case N-800.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.

C.R. Pierce Regulatory Affairs Director CRP/JMC/Iac

Enclosure:

Proposed Alternative FNP-ISI-ALT-20, Version 1.0, in Accordance with 10 CFR 50.55a(z)(2)

U.S. Nuclear Regulatory Commission NL-16-1969 Page2 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RTYPE: CFA04.054 U.S. Nuclear Regulatorv Commission Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley

Joseph M. Farley Nuclear Plant, Unit 1 Proposed lnservice Inspection Alternative FNP-151-ALT-20, Version 1.0 Enclosure Proposed Alternative FNP-151-ALT-20, Version 1.0, in Accordance with 10 CFR 50.55a(z)(2)

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

Plant Site-Unit:

Joseph M. Farley Nuclear Plant (FNP) - Units 1 and 2 Interval-Interval Dates:

41h 10-Year lnservice Inspection (lSI) Interval- December 1, 2007 through November 30, 2018 includes a 1-year extension as allowed by IWA-2430(d)(1).

Requested Date for Approval and Basis:

Approval is requested by August 30, 2017 to permit performance of the proposed alternative pressure test during the 1R28 Refueling Outage (4/1/2018) of FNP Unit 1 and 2R25 Refueling Outage (1 0/15/2017) of FNP Unit 2.

ASME Code Components Affected:

FNP Units: Unit 1 and Unit 2 ASME Code Class: Code Class 1

References:

ASME Section XI, Table IWB-2500-1, IWB-5222(b) and IWC-5221;and ASME Section XI, Division 1 Code Case N-800 Examination Category: B-P (All Pressure Retaining Components)

Item Number: 815.10 (Pressure Retaining Components)

Component: Class 1 boundary between and including the first and second isolation valves in the injection or return path of standby safety systems. Includes the Safety Injection System (SIS)

High (HI) Head and Low (LO) Head, Residual Heat Removal (RHR) supply lines, Accumulator Discharge lines to the Reactor Coolant System (RCS), and RHR suction lines from the RCS.

==

Description:==

Details of the piping and valves associated with this request are included in Table 2 for Unit 1 and Table 3 for Unit 2.

Applicable Code Edition and Addenda

ASME Section XI, 2001 Edition through the 2003 Addenda (ASME Section XI) (Reference 1)

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

Background and Reason for Request:

Background

ASME Section XI, Table IWB-2500-1, "Examination Categories," Examination Category 8-P, Item 815.10 requires that a system leakage test be conducted prior to startup following each refueling outage in accordance with the requirements of IWB-5220.

Paragraph IWB-5222(a) requires that the pressure retaining boundary during the system leakage test shall correspond to the reactor coolant boundary, with all valves in the position required for normal reactor operation startup with the visual examination extended to include the second closed valve at the boundary extremity. Paragraph IWB-5222(b) requires the pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary.

Reason for Request

Pursuant to 10 CFR 50.55a(z)(2), an alternative is being requested by Southern Nuclear Operating Company, Inc. (SNC) for the FNP Units 1 and 2 on the basis that a hardship and unusual difficulty exists in establishing a system configuration that will subject selected Class 1 components to RCS pressure during the system pressure test to be performed in accordance with IWB-5222{b) at or near the end of each FNP Unit's lSI Interval without a compensating increase in the level of quality and safety. SNC requests authorization to perform the examination of selected Class 1 piping and valves at plant conditions other than those required by IWB-5222(b) by using the alternative boundaries permitted by Code Case N-800 (Reference

2) with IWC-5221 defining the alternative Class 2 system test pressure between the Class 1 isolation valves. IWC-5221 states:

'The system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test to verify system operability (e.g., to demonstrate system safety function or satisfy technical specification surveillance requirements.)".

The system pressure requirements of IWC-5221 are an alternative to the system pressure requirements of CC N-800, which are:

" ... The system leakage test shall be conducted using the pressure associated with the Class 2 system function that provides the highest pressure between the Class 1 isolation valves."

Additionally, Code Case N-800 is not yet addressed or approved in the latest revision of Regulatory Guide 1.147 Revision 17 and currently requires NRC authorization prior to use.

However, the Case has been incorporated into Draft Regulatory Guide DG-1296 with no proposed NRC conditions for its use.

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

The design of the FNP Unit's 1 and 2 Class 1 process piping used in standby safety systems requires substantial effort to extend the boundary subject to RCS pressure where check valves or non-redundant components serve as the first system isolation from the RCS. Such configurations would require manually opening vent and drain type valves for the use of temporary piping installations, such as high-pressure hoses, and/or other unusual temporary system configurations in order to achieve test pressures at upstream piping and valves required by IWB-5222(b). The manually opening of inboard isolation valves defeats the double isolation barrier. By establishing and restoring temporary configurations or defeating double isolation barriers in order to test these lines in accordance with IWB-5222(b), potential hazards to personnel safety could be introduced. Examples include occupational hazards, risk for spills, contaminations, and additional radiation exposure.

All the components listed in this request are located inside the containment and in areas involving occupational radiation exposure. Pressure testing of these lines under existing ASME Section XI requirements would require establishing temporary configurations and restoring the normal operating configurations. These activities would result in an unwarranted increase of worker radiation exposure. Table 1 provides the exposure history and person-hours, for each FNP Unit, resulting from extending the boundary to the second isolation device for all Class 1 components during the noted previous FNP Unit's end of Third 10-Year lSI Interval, IWB-5222(b) system pressure tests. The activities associated with this work included scaffold erection, insulation removal, valve manipulations, examinations, re-installation of insulation, and scaffold removal. Given an acceptable alternative testing method, the stated exposure values increase the hardship associated with the present testing protocol and represent an activity against ALARA principles.

TABLE 1- ESTIMATED EXAMINATION DOSE AND PERSON-HOURS Unit Last Performed Dose in millirem Person-Hours 1 11 / 10/07 80 22 2* 11 /21 /08, 5/14/ 10 66, 18 13, 5

  • Note- All but Auxiliary Spray line completed in 2008, which was tested in 2010.

Based on the above, the extension of the boundary subjected to RCS pressure during system leakage test at or near the end of the 10-Year Interval to include all Class 1 pressure retaining components within the injection and return path of standby safety system boundaries in accordance with IWB-5222(b) represents a hardship and unusual difficulty that does not provide a compensating increase in the level of quality and safety provided by the examination.

The following tables contain specific information pertaining to the various pipe segments for which this alternative is being requested.

Table 2 for Unit 1 and Table 3 for Unit 2, "Class 1 Piping To Be Tested Per Code Case N-800,"

identifies the first and second isolation valve(s) and associated piping segments to be examined E-3

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2) at operating pressures associated with the outboard Class 2 system test pressure in accordance with IWC-5221 in partial completion of the IWB-5222(b) leakage test conducted at or near the end of the Fourth 10-Year lSI Interval.

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

TABLE 2 - UNIT 1, CLASS 1 PIPING TO BE TESTED PER CODE CASE N-800 <1>* <2>* <3>& <4>

Piping Piping and Line Function 151 lsolation Valve Affected Lines 2"d Isolation Valve(s)

Run Instrument Diagram Nos.

1. D-175037 SIS to RCS Cold Leg Loop 1 Check Valve 01E21-12" CCA-24 Check Valve 01 E21 V037 A, SH.1 RCS on P&ID D-175037 SH.1 (A- 01 E21 V032A, 1-8956A, 12-C88 I
5) from Accumulator Tank 1-8948A, 12-C88 D-175038 ATAT-1, 01E21T008A I SH.2 SIS Discharge Piping on P&ID 0-175038 SH.2 (D-1).

I

2. D-175037 SIS to RCS Cold Leg Loop 2 Check Valve 01 E21-12" CCA-24 Check Valve 01 E21 V0378, I SH.1 RCS on P&IO D-175037 SH.1 (G- 01 E21 V0328, 1-89568, 12-C88 1-89488, 12-C88 I
4) from Accumulator Tank D-175038 ATAT-2, 01E21T0088 I SH.2 SIS Discharge Piping on P&ID 0-175038 SH.2 (D-1 ). I
3. D-175037 SIS to RCS Cold Leg Loop 3 Check Valve 01E21-12" CCA-24 Check Valve 01E21V037C, ,

SH.1 RCS on P&IO D-175037 SH.1 (8- 01 E21V032C, 1-8956C, 12-C88

7) from Accumulator Tank 1-8948C, 12-C88 0-175038 ATAT-3, 01E21T008C SH.2 SIS Discharge Piping on P&ID D-175038 SH.2 (E-1).
4. D-175037 SIS HI and LO Head to Cold Check Valve 01 E11-6" CCA-22, Check Valve 01 E21 V062C, SH.1 RCS Leg Loop 1 on P&ID 0- 01 E11 V051 C, 01 E11-4" CCA pipe 1-8997C, 2-C88, Check Valve 175037 SH.1 (8-5) from HI 1-8998C, 6-C88 between two 6" x 4" 01E21V066C, 1-8995C, 2-D-175038 Head SIS (Charging) Pumps reducers, and 01 E21- C88 and Check Valve SH.1 SIS and RHR and LO Head SIS 2" -CCA-21 and 01 E21 V021 C, 1-8973C, 6-D-175038 E-5

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

SH.2 SIS Pumps. 01E21-2" CCA-26 C88

5. 0-175037 SIS HI and LO Head to Cold Check Valve 01 E11-6" CCA-22, Check Valve 01 E21 V0628, SH.1 RCS Leg Loop 2 on P&IO 0- 01E11V0518, 01 E21-8" CCA pipe 1-89978, 2-C88, Check Valve 175037 SH.1 (G-6) from HI 1-89988, 6-C88 between two 8" x 6" 01 E21V0668, 1-89958, C-0-175038 Head SIS (Charging) Pumps reducers, 01 E21-2"- 288 and Check Valve SH.1 SIS and RHR and LO Head SIS CCA-21, and 01 E21- 01 E11V021 8, 1-89738, 6-Pumps. 2" CCA-26 C88 0-175038 SH.2 SIS
6. 0-175037 SIS HI and LO Head to Cold Check Valve 01 E11-6" CCA-22, Check Valve 01 E21 V062A, SH.1 RCS Leg Loop 3 on P&IO 0- 01E11V051A, 01 E21-8" CCA pipe 1-8997A, 2-C88, Check Valve 175037 SH.1 (C-7) from HI 1-8998A, 6-C88 between two 8" x 6" 01 E21V066A, 1-8995A, C-0-175038 Head SIS (Charging) Pumps reducers, Q 1E21-2"- 288 and Check Valve SH.1 SIS and RHR and LO Head SIS CCA-21, and 01 E21- 01E11V021A, 1-8973A, 6-Pumps. 2" CCA-26 C88 0-175038 SH.2 SIS
7. 0-175037 SIS HI and LO Head to Hot Check Valve 01 E21-6" CCA-27, Check Valve 01 E21 V079A, SH.1 RCS Leg Loop 1 on P&IO 0- 01E21V077A, 01 E21-2"-CCA-30, 1-8992A, 2-C88, Check Valve 175037 SH.1 (0-5) from HI 1-8993A, 6-C88 and 01 E21-2" CCA- 01 E21 V078A, 1-8990A, C-0-175038 Head SIS (Charging) Pumps 29 288 and Check Valve SH.1 SIS and RHR and LO Head SIS 01 E21 V076A, 1-8988A, 6-Pumps. Also serves as RHR C88 supply in Mode 5.
8. 0-175037 SIS HI and LO Head to Hot Check Valve 01 E21-6" CCA-27, Check Valve 01 E21 V0798, SH.1 RCS Leg Loop 2 on P&IO 0- 01 E21 V0778, 01 E21-2"-CCA-30, 1-89928, 2-C88, Check Valve 175037 SH.1 (E-5) from HI 1-89938, 6-C88 and 01 E21-2" CCA- 01 E21V0788, 1-89908, C-0-175038 Head SIS (Charging) Pumps 29 288 and Check Valve SH.1 SIS and RHR and LO Head SIS 01E21V0768, 1-89888,6-Pumps. Also serves as RHR C88 E-6

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2) supply in Mode 5.

9. D-175037 SIS HI Head to Hot Leg Check Valve 01 E21-6" CCA-28 Check Valve 01 E21 V079C, SH.1 RCS Loop 3 on P&ID D-175037 01E21V077C, from 6" x 2" reducer, 1-8992C and Check Valve SH.1 (D-7) from HI Head SIS 1-8993C, 6-C88 01 E21-2" CCA-28, 01 E21V078C, 1-8990C, C- '

D-175038 (Charging) Pumps. and 01 E21-2"-CCA- 288 SH.1 SIS 30 I

10. D-175037 RHR suction from Hot Leg MOV, V0168, 12" CCA-16 MOV, V0018, 1-8702A, 12-SH.1 RCS Loop 1 on P&ID D-175037 1-87028, 12- GM88SEY SH.1 (C-4) GM88SEY D-175041 SH.1 RHR
11. D-175037 RHR suction from Hot Leg MOV, V016A, 12" CCA-16 MOV, V001A, 1-8701A, 12-SH.1 RCS Loop 3 on P&ID D-175037 1-8701 8, 12- GM88SEY SH.1 (C-9) GM88SEY D-175041 SH.1 RHR NOTES: I
1. Alternative Request FNP-ISI-ALT-04 for FNP Units 1 and 2 was authorized by NRC SEA on March 30, 2010 for the Fourth 10-Year Interval under (TAG NOS. ME1767 and ME1768) and ADAMS Accession No. ML100820410 and will continue to be used for pressure testing the vents and drains to and including the first isolation valves attached to the applicable piping runs and segments to be tested in accordance with this request (Reference 3).
2. Material design information is contained in SNC Specification No. SS-11 09-02 (Reference 4) and states CCA piping is all ASME Section Ill, 1971 Class 1, and the piping, valves and fittings are made of stainless steel materials and thus based on IW8-5240(c) no limitations on system test temperature is required for the pressure tests performed under this request.

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

3. All piping and components in this request are currently classified as Examination Category B-P, and include Item Number 815.10 for pressure testing each refueling outage and this alternative applies to the pressure test required at or near the end of the 10-year interval in accordance IWB-5222{b).
4. NDE of the piping components greater than NPS 1 were originally classified and examined as Examination Category 8-J, but are now included in the Risk-Informed lSI Program addressed in Alternative Request FNP-ISI-ALT-12, Version 2.0 for Units 1 &

2 and was authorized by NRC SER on January 18, 2012 for the Fourth 10-Year Interval under {TAG NOS. ME5273 and ME5274) and ADAMS Accession No. ML12012A135 (Reference 5).

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

TABLE 2 - UNIT 2, CLASS 1 PIPING TO BE TESTED PER CODE CASE N-800 <1>* <21*<a>" <4>

Piping Piping and Line Function 1st Isolation Valve Affected Lines 2"d Isolation Valve(s)

Run Instrument Diagram Nos.

1. D-205037 SIS to RCS Cold Leg Loop 1 Check Valve Q2E21-12" CCA-24 Check Valve Q2E21 V037A, SH.1 RCS on P&ID D-20507 SH.1 (A-6) Q2E21V032A, 2-8956A, 12-C88 from Accumulator Tank 2-8948A, 12-C88 D-205038 ATAT-1, Q2E21T008A SH.2 SIS Discharge Piping on P&ID D-205038 SH.2 (D-1).
2. D-205037 SIS to RCS Cold Leg Loop 2 Check Valve Q2E21-12" CCA-24 Check Valve Q2E21 V0378, SH.1 RCS on P&ID D-205037 SH.1 (G- Q2E21V0328, 2-89568, 12-C88
4) from Accumulator Tank 2-89488, 12-C88 D-205038 ATAT-2, Q2E21T0088 SH.2 SIS Discharge Piping on P&ID D-205038 SH.2 (D-1}.
3. D-205037 SIS to RCS Cold Leg Loop 3 Check Valve Q2E21-12" CCA-24 Check Valve Q2E21 V037C, SH.1 RCS on P&ID D-205037 SH.1 (A- Q2E21 V032C, 2-8956C, 12-C88
7) from Accumulator Tank 2-8948C, 12-C88 D-205038 ATAT-3, Q2E21T008C SH.2 SIS Discharge Piping on P&ID D-205038 SH.2 (E-1).
4. D-205037 SIS HI and LO Head to Cold Check Valve Q2E11-6" CCA-22, Check Valve Q2E21 V062C, SH.1 RCS Leg Loop 1 on P&ID D- Q2E11V051C, Q2E11-6" CCA pipe 1-8997C, 2-C88, Check Valve 205037 SH.1 (8-5) from HI 2-8998C, 6-C88 between two 8" x 6" Q2E21V066C, 1-8995C, 2-D-205038 Head SIS (Charging) Pumps reducers, and Q2E21- C88 and Check Valve SH.1 SIS and RHR and LO Head SIS 2"-CCA-21 and Q2E21V021C, 1-8973C, 6-D-205038 L _ _ _ _ _ _ - - * -- - - - - - - -L _ _ _ - -

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

SH.2 SIS Pumps. Q2E21-2" CCA-26 C88 '

5. D-205037 SIS HI and LO Head to Cold Check Valve 02E11-6" CCA-22, Check Valve 02E21 V0628, SH.1 RCS Leg Loop 2 on P&ID D- Q2E11 V051 8, 02E21-4" CCA pipe 2-89978, 2-C88, Check Valve 205037 SH.1 (G-5) from HI 2-89988, 6-C88 between two 6" x 4" Q2E21V0668, 2-89958, C-D-205038 Head SIS (Charging) Pumps reducers, Q2E21-2"- 288 and Check Valve SH.1 SIS and RHR and LO Head SIS CCA-21 and Q2E21- Q2E11 V021 8, 2-89738, 6-Pumps. 2" CCA-26 C88 D-205038 SH.2 SIS
6. D-205037 SIS HI and LO Head to Cold Check Valve Q2E11-6" CCA-22, Check Valve Q2E21 V062A, SH.1 RCS Leg Loop 3 on P&ID D- Q2E11V051A, Q2E21-8" CCA pipe 2-8997A, 2-C88, Check Valve 205037 SH.1 (C-7) from HI 2-8998A, 6-C88 between two 8" x 6" Q2E21V066A, 2-8995A, C-D-205038 Head SIS (Charging) Pumps reducers, Q2E21-2"- 288 and Check Valve SH.1 SIS and RHR and LO Head SIS CCA-21, and Q2E21- Q2E11V021A, 2-8973A, 6-Pumps. 2" CCA-26 C88 D-205038 SH.2 SIS
7. D-205037 SIS HI and LO Head to Hot Check Valve Q2E21-6" CCA-27, Check Valve Q2E21 V079A, SH.1 RCS Leg Loop 1 on P&ID D- Q2E21V077A, Q2E21-2"-CCA-30 2-8992A, 2-C88, Check Valve 205037 SH.1 (D-5) from HI 2-8993A, 6-C88 and Q2E21-2" CCA- Q2E21V078A, 2-8990A, C-D-205038 Head SIS (Charging) Pumps 29 288 and Check Valve SH.1 SIS and RHR and LO Head SIS Q2E21 V076A, 2-8988A, 6-Pumps. Also serves as RHR C88 supply in Mode 5.
8. D-205037 SIS HI and LO Head to Hot Check Valve Q2E21-6" CCA-27, Check Valve Q2E21 V0798, SH.1 RCS Leg Loop 2 on P&ID D- Q2E21 V0778, Q2E21-2"-CCA-30 2-89928, 2-C88, Check Valve 205037 SH.1 (E-5) from HI 2-89938, 6-C88 and 02E21-2" CCA- Q2E21 V0788, 2-89908, C-D-205038 Head SIS (Charging) Pumps 29 288 and Check Valve SH.1 SIS and RHR and LO Head SIS Q2E21 V0768, 2-89888, 6-Pumps. Also serves as RHR C88 E -10

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2) supply in Mode 5.

9. D-205037 SIS HI Head to Hot Leg Check Valve 02E21-6" CCA-28 Check Valve Q2E21 V079C, SH.1 RCS Loop 3 on P&ID D-205037 Q2E21 V077C, from 6" x 2" reducer, 2-8992C and Check Valve SH.1 (D-7) from HI Head SIS 2-8993C, 6-C88 02E21-2" CCA-28, Q2E21 V078C, 2-8990C, C-D-205038 (Charging) Pumps. and 02E21-2"-CCA- 288 SH.1 SIS 30
10. D-205037 RHR suction from Hot Leg MOV, QV0168, 12" CCA-16 MOV, QV0018, 1-8702A, 12-SH.1 RCS Loop 1 on P&ID D-205037 2-87028, GM88SEY SH.1 (C-4) 12-GM88SEY D-205041 SH.1 RHR
11. D-205037 RHR suction from Hot Leg MOV, QV016A, 12" CCA-16 MOV, QV001A, 2-8701A, 12-SH.1 RCS Loop 3 on P&ID D-205037 2-87018, GM88SEY SH.1 (C-9} 12-GM88SEY D-205041 SH.1 RHR NOTES:
1. Alternative Request FNP-ISI-ALT-04 for FNP Units 1 and 2 was authorized by NRC SER on March 30, 2010 for the Fourth 10-Year Interval under (TAC NOS. ME1767 and ME1768) and ADAMS Accession No. ML 1008204 and will continue to be used for pressure testing the vents, and drains to and including the first isolation valves attached to the applicable piping runs and segments to be tested in accordance with this request (Reference 3).
2. Material design information is contained in SNC Specification No. SS-11 09-02 (Reference 4) and states CCA piping is all ASME Section Ill, 1971 Class 1, and the piping, valves and fittings are made of stainless steel materials and thus based on IW8-5240{c) no limitations on system test temperature is required for the pressure tests performed under this request.

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SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

3. All piping and components in this request are currently classified as Examination Category 8-P, and include Item Number 815.10 for pressure testing each refueling outage and this alternative applies to the pressure test required at or near the end of the 10-year interval in accordance IW8-5222{b).
4. NDE of the piping components greater than NPS 1 were originally classified and examined as Examination Category 8-J, but are now included in the Risk-Informed lSI Program addressed in Alternative Request FNP-ISI-ALT-12, Version 2.0 for Units 1 &

2 and was authorized by NRC SER on January 18,2012 for the Fourth 10-Year Interval under (TAC NOS. ME5273 and ME5274) and ADAMS Accession No. ML12012A135 (Reference 5).

E- 12

SOUTHERN NUCLEAR OPERATING COMPANY* FNP-1 and FNP-2 FNP-ISI-ALT -20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

Proposed Alternative and Basis for Use:

Alternative In accordance with 10 CFR 50.55a(z)(2), an alternative is requested on the basis that hardship and unusual difficulty exists in establishing system configurations that will subject selected Class 1 components to RCS pressure during the system pressure test as required by IWB-5222(b) at or near the end of the 10-Year Interval without a compensating increase in the level of quality and safety.

SNC proposes to perform the examination of selected FNP Unit 1 and Unit 2, Class 1 piping and valves at or near the end of the Fourth 10-Year lSI Interval with plant conditions other than those required by IWB-5222(b) by using the alternative boundaries permitted by Code Case N-800 with alternative system test pressures per IWC-5221.

The objective of the required extended pressure boundary conditions in accordance with IWB-5222(b) is to detect evidence of leakage, and thereby verify the integrity of the Reactor Coolant Pressure Boundary (RCPB) beyond the first isolation valve. As discussed above, in order to meet IWB-5222(b) requirement, the establishment of and the return from the required temporary configurations would involve considerable time to accomplish, result in an unwarranted increase of worker radiation exposure, exposure of personnel to industrial safety risks due to use of a single isolation valve, and potentially over pressurize downstream piping in the event of valve leakage. In addition, these temporary configurations could require bypassing Final Safety Report (FSAR) specified safety system protective features and interlocks. As a result, SNC has concluded that compliance with IWB-5222(b) requirement constitutes a hardship without a compensating increase in the level of quality and safety. The proposed alternative boundaries permitted in Code Case N-800 with IWC-5221 and coupled with the continued use of Alternative Request FNP-ISI-ALT-04, (Reference 3) for vent and drain line isolation valves provides a level of assurance that the RCS pressure boundary is maintaining structural integrity at elevated pressure.

In the unlikely event of a through wall leak in the piping runs and segments identified in Tables 2 and 3 during normal operation, the leak would result in unidentified RCS leakage. RCS leakage detection instrumentation has been designed to aid operating personnel in differentiating between possible sources of detected leakage within the containment and identifying the physical location of the leak. The RCS leakage detection instrumentation consists of the Containment Air Particulate Monitor, the Containment Radioactive Gas Monitor, Specific Humidity Monitoring Devices, the Condensate Measuring System, and the Dew point Temperature Monitoring System described in the FSAR Section 5.2.7 (Reference 6). These systems are in place to assure the Technical Specifications for FNP Units 1 and 2 (Reference 7), Limiting Condition for Operation 3.4.13 RCS Operational LEAKAGE shall be limited to:

E- 13

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

(a} No pressure boundary LEAKAGE; (b) 1 gpm unidentified LEAKAGE; and (c) 10 gpm identified LEAKAGE; (d) 150 gallons per day primary to secondary Leakage though any one steam generator (SG}.

For each Unit, the limits above for ACS operation in the presence of leakage from ACS components do not compromise safety. In the event that unidentified leakage increases from the limit above and is determined to be from ACS pressure boundary leakage the Unit is to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

For those portions of the Class 1 boundary between the first and second isolation valves, FNP will conduct the required end of interval system pressure tests as prescribed in IWB-5222(b} using the alternatives of Code Case N-800 and IWC-5221 and the boundaries that will apply as follows:

  • For the SIS to ACS Cold legs associated with the Accumulator Tanks, the examinations will be performed using the outboard Class 2 highest system functional pressure associated with the tanks.
  • For the SIS HI and LO Head, Hot leg/Cold Leg injection lines the examinations will be performed using the outboard Class 2 system functional pressure associated with the SIS HI Head (Charging Pumps), during the full flow test at the end of the interval.
  • For the AHA suction lines, Hot Leg Loops 1 and 3, the examinations will be performed using the outboard Class 2 highest system functional pressure associated with the AHA suction lines.

As described above, the activities associated with the requirements of IWB-5222(b} would incur increased radiation exposure, potential personnel hazards, and additional workforce resources. The associated activities would include scaffold erection, insulation removal, valve manipulations, examinations, re-installation of insulation, and scaffold removal, which would not result in a commensurate increase in the level of quality and safety of the systems.

Therefore, the extension of the boundary subjected to ACS pressure during system leakage tests to include all Class 1 pressure retaining components within the system boundary in accordance with IWB-5222(b) represents a hardship and unusual difficulty that does not provide a compensating increase in the level of quality and safety provided by the examination.

E- 14

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2)

Duration of Proposed Alternative:

This alternative request will be applicable to FNP Units 1 and 2 to the end of the Fourth 10-Year lSI Interval.

Precedents:

The NRC has previously authorized similar relief requests for the use of ASME Code Case N-800. Authorization has been recently granted for relief requests from the following stations.

(1) Byron Station, Unit 1 - Relief Request 13R-26 Associated with the Third 10-Year lnservice Inspection Program Interval Relief from the requirements of the ASME Code authorized by NRC Safety Evaluation dated June 30, 2015, (ADAMS Accession No. ML15173A436).

(2) Sequoyah Nuclear Plant, Units 1 and 2, Third Inspection Interval Relief Request 11-SPT-1, was authorized by NRC Safety Evaluation dated May 20, 2014, (ADAMS Accession No. ML14133A112).

References:

1 American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for lnservice Inspection of Nuclear Power Plant Components, 2001 Edition, through 2003 Addenda, the American Society of Mechanical Engineers, New York.

2 ASME Code Case N-800, "Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Injection ValvesSection XI, Division 1," Dated: December 20, 2010.

3 Alternative Request FNP-ISI-ALT-04 for FNP Units 1 and 2 addresses pressure testing of vent and drain isolation valves and was authorized by NRC SER on March 30,2010 for the Fourth 10-Year lSI Interval under (TAC NOS. ME1767 and ME1768) and ADAMS Accession No. ML 1008204.

4 Southern Nuclear Operating Company, Inc., "Specification for Installation of Shop Fabricated Piping and Hangers, Furnishing of Field Fabricated Piping and Hangers, and Installation of field fabricated Piping and Hangers for Nuclear Service, Farley Nuclear Plant Unit(s) 1 & 2," Specification No. SS-11 09-02, Version 171, Dated: June 16, 2015.

5 Risk-Informed lSI Program addressed in Alternative Request FNP-ISI-ALT-12, Version 2.0 for Units 1 & 2 and was authorized by NRC SER on January 18, 2012 for the Fourth 10-Year Interval under (TAC NOS. ME5273 and ME5274) and ADAMS Accession No. ML12012A135 E- 15

SOUTHERN NUCLEAR OPERATING COMPANY- FNP-1 and FNP-2 FNP-ISI-ALT-20, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)(2) 6 FNP Units 1 and 2, FSAR Section 5.2.7 Reactor Coolant Pressure Boundary (RCPB) Leakage Detection Systems.

7 FNP Units 1 and 2, Technical Specifications, Limiting Condition for Operation (LCO) 3.4.13 RCS Operational LEAKAGE.

Status:

Out for review E -16

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