ML20133F675

Requests Authorization of 2 Proposed Alternatives to Certain Requirements of 10CFR50.55 Re 120-month Update of Units 1 & 2 ISI & IST Programs for 3rd 10-yr Interval

ML20133F675
Person / Time
Site:	Farley
Issue date:	01/09/1997
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701140320
Download: ML20133F675 (3)

Text

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e Dave Mor:y Stuthern Nucl:ar

%ce President Operating Compxy Farley Project PO Box 1295 Birmingham Alabama ?5201 Tel 205.992.5131 January 9,1997 SOUTHERN A Docket Nos: 50-348 COMPANY

$0-364 Energy to Serve hurWorld" U. S. Nuclear Regulatory Conunission ATFN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Inservice Inspection (ISI) and Inservice Testing (IST) Program Reauest for Authorization of Proposed Altematives Ladies and Gentlemen:

Southern Nuclear Operating Company (SNC) is making preparations for updating the Joseph M.

Farley Nuclear Plant (FNP) Unit I and 2 ISI and IST Programs for the 3rd 10-year intenal in accordance with the requirements of 10CFR50.55a(0(4)(ii) and 10CFR50.55a(g)(4)(ii). SNC is requesting authorization of two proposed alternatives to certain requirements of 10CFR50.55 as detailed below. SNC respectfully requests NRC authorization by March 31,1997.

1) Request for alternative to the requirements of 10CFR50.55a(0(4)(ii) and 10CFR50.55a(g)(4)(ii) related to the 120-month update of Unit 2 ISI and IST Programs.

Sections 50.55a(0(4)(ii) and 50.55a(g)(4)(ii) of 10CFR50 require that insenice tests of safety related pumps and valves, inservice examinations of components, and system pressure tests, shall comply with requirements of the latest Edition and Addenda of the ASME Code incorporated by reference in paragraph 10CFR50.55a(b) for each successive 120-month inspection interval. These intervals start from the date of commercial operation of the facility. The FNP Unit 2 commercial operation date was July 31,1981, thus the third ten-year interval for Unit 2 begins on July 31, 2001. SNC is requesting approval to update the Unit 2 ISI and IST plans 44 months early on December 1,1997 in conjunction with the 120-month update of the Unit 1 programs so that both units will be updated to a common ASME Section XI Code edition for ISI and IST.

During the first ten years of operation of the Farley Nuclear Plant (1977 - 1987), ISI and IST activities were performed under the same ASME code requirements for Units I and 2. For the second ten years of operation (1987 - 1997), the NRC approved a request to allow Unit 2 to be updated early such that Units I and 2 would again operate under the same ASME code / ,

requirements (See NRC letter dated August 31,1988 from Edward A. Reeves, Senior Project Manager, NRC to W. G. Hairston, Senior Vice President, Alabama Power Company.) One of the -

stated conditions of the NRC approval was that the programs for both units be updated again on

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December 1,1997 to the applicable ASME Code Edition and Addenda in accordance with the f, regulations. SNC's proposed alternative fulfills the requirement of this condition as well as the intent of 10CFR50.55a(0(4)(ii) and 10CFR50.55a(g)(4)(ii), namely to assure periodic updating of ISI and IST practices to conform to industry changes on a 120-month schedule in order that any improvements in code provisions may be periodically incorporated in plant inspection and testing programs.

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U. S. Nuclear Regulatory Commission Page 2 In approving the previous request in 1988 the NRC determined that sufhcientjustification existed namely, that 1) The Farley units are nearly identical and only one ISI and IST program would be adequate to meet the basic intent of 10CFR50.55a(f) and 10CFR50.55a(g), 2) There should be minimal or no increase in risk of failure of safety related pumps, valves or other components resulting from the use of common ISI and IST programs for the remainder of the operating life of the two units, 3) The use of only one program instead of two separate programs by operators and maintenance personnel will increase plant safety through the simplification and standardization of plant testing procedures and testing requirements, and 4) It will result in a savings of manpower requirements for the licensee, as well as for the Commission staff. Identical reasoning and justification demonstrates that the use of the proposed alternative will provide an acceptable level of quality and safety and thus fulfills the requirements of 10CFR50.55a(a)(3)(i) allowing the NRC to authorize the use of the alternative under 10CFR50.55a(a)(3).

SNC proposes to update the ISI and IST Programs concurrently on December 1,1997 to the code of record referenced in paragraph (b) of 10CFR50.55a (with the exception discussed below - See Item 2.) It is SNC's intention to continue the practice of updating the ISI and IST Programs for Units I and 2 concurrently for the remainder of plant life. Therefore the next update will be on December 1,2007 for both units.

2) Request for alternative to the requirements of 10CFR50.55a(b)(2)(viii) related to the code edition and addenda of ASME/ ANSI part 6 and ASME/ ANSI part 10.

10CFR50.55a(b)(2)(viii) notes that ASME Section XI references to " Revision Date or Indicator" for ASME/ ANSI part 6 and ASME/ ANSI part 10 shall be the OMa-1988 Addenda to the OM-1987 Edition. SNC is hereby proposing as an alternative the use of the ASME OM Code-1990.

SNC has compared the OMa-1988 Addenda to the OM-1987 Standards with the ASME OM Code-1990 and finds that the ASME OM Code-1990 contains essentially the same requirements as the OM Standards with the exception that the general administrative requirements which were previously covered by Subsection IWA of Section XI are now included in Subsection ISTA of the OM Code. All other differences are strictly editorial, errata, or format changes. The use of the proposed OM Code-1990 edition therefore, will provide an acceptable level of quality and safety and thus fulfills the requirements of 10CFR50.55a(a)(3)(i) allowing the NRC to authorize the use of the alternative under 10CFR50.55a(a)(3).

The NRC has previously authorized the use of the ASME OM Code-1990 as an alternative to the OMa-1988 Addenda to the OM-1987 Edition (Reference NRC letter dated August 29,1995 from Kahton N. Jabbour, Senior Project Manager, NRC to J. T. Beckham, Jr., Vice President - Plant IIatch.) In this letter the NRC recognized the equivalence of the Code and Standards in question.

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• i U. S. Nuclear Regulatory Commission Page 3 i  :

i Should you have any questions please contact this office.

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• Respectfully submitted, ,

1 SOUTHERN NUCLEAR OPERATING COMPANY ffh 7)ms Dave Morey

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cc: Mr. Luis A. Reyes, Region II Administrator Mr. J. I. Zimmerman, NRR Senior Project Manager Mr. T. M. Ross, FNP Sr. Resident Inspector 1

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