ML20059E978
| ML20059E978 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/10/1994 |
| From: | Siegel B Office of Nuclear Reactor Regulation |
| To: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| References | |
| TAC-M79244, TAC-M79245, NUDOCS 9401130098 | |
| Download: ML20059E978 (5) | |
Text
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E UNITED STATES iI
'l NUCLEAR REGULATORY COMMISSION sq > v f
WASWNGTON, O C. 20555 @ 01 January 10, 1994 Docket Nos. 50-348 and 50-364 t
Mr. D. N. Morey, Vice President Southern Nuclear Operating Co., Inc.
Post Office Box 1295 Birmingham, Alabama 35201-1295
Dear Mr. Morey:
SUBJECT:
BACKFIT CLAIM ISSUE FOR JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M79244 AND M79245)
Sackaround Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) addresses the examination and inspection requirements for the pressure-retaining components of boiling and pressurized water reactors. An inservice inspection program based on these requirements identifies those components essential for the protection of public health and safety and identifies areas selected for examination. The areas selected for examination are those where there exists a higher likelihood of inservice failure (e.g., welds and base metal or heat-affected zones, terminal ends, structural discontinuities, dissimilar metals, etc).
Examinations of a representative sample of such areas are performed to assess the overall condition of the component, piping or system.
As a rule, prior to 1976, nuclear power facilities were required to have an inservice inspection program (ISI) for those components listed in technical specifications. However in 1976, 10 CFR 50.55a was changed to require licensees to update the inservice inspection programs for facilities to the latest edition and addenda of Section XI of the ASME Code approved by the NRC and referenced in paragraph 50.55a(b)(2).
The ASME Code edition and addenda referenced in the regulation at that time was the 1974 Edition through Summer 1975 Addenda.
The requirements for the selection of ASME Code Class 2 components were given, in part, in paragraph IWC-1220, Exempted Components, which allowed Class 2 pressure-retaining components to be exempted from examination requirements if (1) the components were in systems where both the design temperature and pressure were equal to or less than 200 degrees Fahrenheit and 275 psig, respectively, (2) components were in systems (other than emergency core cooling systems) which did not function during normal reactor operation, (3) the components performed an emergency core cooling function, but the control of chemistry of the contained fluid was verified by periodic sampling and test, and (4) the component connections, piping, and associated valves, and vessels were 4-inch nominal pipe size and smaller.
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Application of the exemption criteria to the weld selection process virtually
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eliminated from examination welds in Class 2 systems, including safety systems such as emergency core cooling, residual heat removal, and containment heat
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removal systems.
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i Mr. D. N. Morey During the period of November 1974 to February 1977, through-wall cracks in safety-related piping systems were detected at several pressurized water reactor facilities.
The detection of these cracks was not the result of scheduled inservice inspection activities because the systems in which they were detected were allowed to be exempted from examination by paragraph IWC-1220 of the 1974 Edition of Section XI. To alert licensees of an apparent generic problem, the NRC issued IE Circular 76-06 in November 1976 and requested licensees to (1) provide a description of programs implemented at facilities for assuring continued structural integrity of the safety-related systems and (2) consider performing volumetric examination of a representative number of pipe welds in these systems by nondestructive examination techniques. The observation of through-wall cracks in safety-related systems at Three Mile Island Nuclear Station, Unit 1, in April 1979 resulted in the issuance of IE Bulletin 79-17 in July 1979.
This bulletin required licensees to conduct ultrasonic examination and liquid penetrant surface examination on a representative sample of welds in safety-related systems that was to include the emergency core cooling system, decay / residual heat removal, spent fuel pool cooling, containment spray and borated water storage tank piping.
In 1979, 10 CFR 50.55a was amended, in part, to (1) incorporate by reference the 1977 Edition and addenda through Summer 1978 Addenda to Section XI, (2) require licensees to update the inservice inspection programs for the nuclear power facilities every ten-year interval of facility operation starting with the date that the facility is placed into commercial service, and (3) provide for the use of the 1974 Edition through Summer 1975 Addenda for establishing a sampling plan for the pipe welds to be examined in the residual heat removal system, the emergency core cooling system, and the containment heat removal system.
The statements of consideration for the amended regulation clearly show that the Commission intended to address the problems associated with the inservice j
failures of piping in safety-related systems at nuclear power facilities by requiring that an adequate sample of welds in these systems be examined.
To eliminate these welds from the examination requirements based on the exemption criteria of IWC-1220 defeats the purpose of the Commission's intent in amending the regulation.
In addition, later editions and addenda of Section XI have eliminated the exemption criteria of IWC-1220 that would have eliminated the safety systems from examination.
This was done in recognition of the fact that inservice failures of piping in safety-related systems were occurring and were not being addressed by the earlier editions primarily due to the exemption criteria.
Discussion and Conclusion There have been numerous discussions and correspondence on this backfit issue related to the Farley second ten-year ISI program between the staff and Southern Nuclear Operating Company (SNC), formerly Alabama Power Company).
As i
a result, a meeting was held on July 31, 1991, with Southern Nuclear Operating Company (SNC), the NRC's projects staff, the appropriate technical staff and the Office of General Council (0GC) to discuss resolution of this issue.
The staff's position presented during this meeting was consistent with the background discussion on this issue, which is that 10 CFR 50.55a(b)(2)(iv) was 1
r January 10, 1994 Mr. D. N. Morey previously revised to specifically require the inspection of welds in the emergency core cooling (ECC), residual heat removal (RHR), and the containment heat removal (CHR) systems.
Although OGC accepted the staff's position that 10 CFR 50.55a(b)(2)(iv) could be interpreted to require use of Paragraph IWC-1220 of the 1974 Edition through the Summer 1975 Addenda for determining the sample of welds to be examined for ASME Code Class 2 systems and not to allow exclusion of welds in the ECC, RHR and CHR systems from inspection, a concern was expressed that this position could be subject to further appeal.
As a result, 0GC requested that the staff review ISI programs going back to the early 1980's for other facilities to determine if the staff's position regarding inspection of welds in these systems has been consistent with the above interpretation.
The NRC staff believes it has consistently conducted reviews and evaluations of the ISI programs in accordance with the amended regulations, i.e., to determine if the licensee's programs contain a representative sample of welds to be examined in the safety systems cited in the regulations.
Nevertheless, the staff has decided not to pursue this issue any further.
This decision is based on the following considerations (1) the systems and components will be (and should have been) subjected to pressure tests and visual inspections each period (forty months) of the interval as required (unambiguously) by Section XI of the ASME Code, thereby providing a measure of assurance of structural integrity, (2) the later editions of the ASME Code have incorporated requirements that address the exemptions and have eliminated the criteria that permitted the interpretation to eliminate the systems and components from examination, (3) the relatively short period of time remaining in the second interval for the Farley ISI program before the required update (December 1, 1997) to a later edition when this issue will no longer exist, and (4) the time and resources that would be expended in pursuing the issue versus the time remaining in the interval. We, therefore, conclude that pursuing the issue would at best result in a Pyrrhic victory and is, therefore, impractical and uneconomical to continue.
Sincerely, Original Signed by:
Byron L. Siegel, Senior Project Manager Project Directorate 11-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc:
See next page DISTRIBUTION:
Docket File S. Varga P. Anderson E. Merschoff, RII NRC & Local PDRs G. Lainas OGC B. Siegel PDIl-1 R/F S. Bajwa ACRS (101)f)
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NAME pan 5Ni B5feg h Y JStrosnibr SBajwa h V DATE
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/ / /0 /9h 0FFICIAL RECORD COPY DOCUMENT NAME: G:\\FARLEY\\BACKFIT.LTR
l Mr. D. N. Morey previously revised to specifically require the inspection of welds in the emergency core cooling (ECC), residual heat removal (RHR), and the containment heat removal (CHR) systems.
Although OGC accepted the staff's position that 10 CFR 50.55a(b)(2)(iv) could be interpreted to require use of Paragraph IWC-1220 of the 1974 Edition through the Summer 1975 Addenda for determining the sample of welds to be examined for ASME Code Class 2 systems and not to allow exclusion of welds in the ECC, RHR and CHR systems from inspection, a concern was ex :r ssed that this position could be subject to further appeal. As a resuld
,GC requested i
that the staff review ISI programs going back to the early 19t.
s for other facilities to determine if the staff's position regarding inspection of welds in these systems has been consistent with the above interpretation.
The NRC staff believes it has consistently conducted reviews and evaluations of the ISI programs in accordance with the amended regulations, i.e., to determine if the licensee's programs contain a representative sample of welds to be examined in the safety systems cited in the regulations.
Nevertheless, the staff has decided not to pursue this issue any further. This decision is based on the following considerations (1) the systems and components will be (and should have been) subjected to pressure tests and visual inspections each period (forty months) of the interval as required (unambiguously) by Section XI of the ASME Code, thereby providing a measure of assurance of structural integrity, (2) the later editions of the ASME Code have incorporated requirements that address the exemptions and have eliminated the criteria that permitted the interpretation to eliminate the systems and components from examination, (3) the relatively short period of_ time remaining in the second interval for the farley ISI program before the required update (December 1, 1997) to a later edition when this issue will no longer exist, and (4) the time and resources that would be expended in pursuing the issue versus the time remaining in the interval. We, therefore, conclude that pursuing the issue would at best result in a Pyrrhic victory and is, therefore, impractical and uneconomical to continue.
Sincerely,
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si fron L. Sieg Senior Project Manager
/ roject Directorate 11-1 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation cc:
See next page
Mr. D. N. Morey Joseph M. Farley Nuclear Plant Southern Nuclear Operating Company, Inc.
cc:
Mr. R. D. Hill, Jr.
State Health Officer General Manager - Farley Nuclear Plant Alabama Department of Public Health Southern Nuclear Operating Co., Inc.
434 Monroe Street Post Office Box 470 Montgomery, Alabama 36130-1701 Ashford, Alabama 36312 Chairman Mr. B. L. Moore, Licensing Manager Houston County Commission Southern Nuclear Operating Co., Inc.
Post Office Box 6406 Post Office Box 1295 Dothan, Alabama 36302 Birmingham, Alabama 35201-1295 Regional Administrator, Region II James H. Miller, III, Esquire U. S. Nuclear Regulatory Commission Balch and Bingham Law Firm 101 Marietta St., N.W., Ste. 2900 Post Office Box 306 Atlanta, Georgia 30323 1710 Sixth Avenue North Birmingham, Alabama 35201 Resident Inspector U.S. Nuclear Regulatory Commission Mr. J. D. Woodard Post Office Box 24 - Route 2 Executive Vice President Columbia. Alabama 36319 Southern Nuclear Operating Company P.O. Box 1295 i
Birmingham, Alabama 35201 l