ML20135D833
| ML20135D833 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/04/1996 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9612100178 | |
| Download: ML20135D833 (2) | |
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e Dave Morey Southern Nuclear Vice President Operating Company Farley Project P.O. Box 1295 Birmingham. Alabama 35201 Tel 205.992.5131 December 4, 1996 SOUTHERN h COMPANY Docket Nos.:
50-348 Energy to Serve Your %rld' 50-364 U. S. Nuclear Regulatory Commission ATfN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Inservice Inspection and Inservice Testing Program IWE/IWL Repair / Replacement Reauest for Altemative Rules Ladies and Gentlemen:
By Federal Register Notice 154 (Volume 61), dated August 8,1996, the Nuclear Regulatory Commission (NRC) amended its regulations to incorporate by reference the 1992 edition with 1992 i
addenda of Subsections IWE and IWL of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, in 10 CFR 50.55a. The effective date for the amended rule was September 9,1996.
An expedited implementation schedule required licensees to incorporate the new requirements into their ISI plans and to complete the first containment inspections within five years (September 9, 2001) of the effective date of the rules.
Southern Nuclear Operating Company (SNC) interpreted the September 9, 2001 implementation date to include the IWE/IWL repair / replacement provisions into the existing FNP ASME Class 1, 2 and 3 repair / replacement program. SNC's intent was to include this work as part of the 10 year ISI/IST update which is due on December 1,1997. SNC has recently been made aware of the NRC's position that the repair / replacement rules of Subsections IWE and IWL were to be implemented on September 9,1996 rather than in conjunction with the first set of containment inspections. SNC became aware of the NRC position when it obtained a copy of a letter from the NRC to Alex Marion of NEl dated November 6,1996.
In the letter referenced above, the NRC recognized the impracticality of requiring immediate compliance with the new rules and thus recognized the need for a period of time for licensees to develop and implement procedures for repairs and replacements which meet the requirements of subsections IWE and IWL. SNC agrees that bringing the existing FNP repair / replacement i S program into immediate compliance with the new rules is impractical. This impracticability is the basis of the following request for relief. Pursuant to the provisions of 10CFR50.55a(a)(3)(ii),
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SNC is hereby requesting relief from the requirements of 10CFR50.55a(g)(4)(v), (61 Federal 7/
Register 41303). SNC requests that the NRC grant relief until March 15,1997 to approximately 4
coincide with the beginning of the Unit I refueling outage for compliance with the rule as it relates J;
to the implementation of repair and replacement activities in accordance with the ASME Section XI Code 1992 Edition with 1992 Addenda for Class CC (concrete containments) and MC (metal 9612100178 961204 PDR ADOCK 05000348 G
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U. S. Nuclear Regulatory Commission Page 2 containments). SNC is not aware of any safety concerns relative to the FNP containments' i
structural integrity and ability to perform the intended safety function. The proposed alternative, therefore, will provide an acceptable level of quality and safety for FNP.
If there are any questions or if additional information is needed, please ad5ise.
Respectfully submitted, SOlmiERN NUCLEAR OPERATING COMPANY h MM Dave Morey ADP:maf iweexemp. doc cc:
Mr. S. D. Ebneter i
Mr. J. I. Zimmerman i
Mr. T. M. Ross I
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