ML20236S994
| ML20236S994 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/20/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711300224 | |
| Download: ML20236S994 (4) | |
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Alabama Power Company 600 North 18th Street.
l Post Ofhce Box 2641 Birmingham. Alabama 35291-0400 Telephone 205 250-1835 m
R. P. Mcdonald Alabama Power Senior Vice President Docket No. 50-364 10CFR50.55a Hovember 20, 1987 I
- b. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D. C.
20555 Gentlemen:
Joseph M. Farley Nuclear Plant - Unit 2 Inservice Inspection and Testing Program Updates to the Latest ASME Code,Section XI For the first ten years of operation for Farley Nuclear Plant, Units 1 and 2, the Inservice Inspection (ISI) and Inservice Testing (IST) Programs for each unit have met the requirements of the ASt1E Code,Section XI,1974 Edition with Addenda through Summer 1975. Pursuant to the requirements of 10CFR50.55a(g)(4)(ii), the Unit 1 ISI and IST Programs have been updated to the latest Section XI approved by the HRC (1983 Edition through the Summer 1983 Addenda). These updated programs were originally submitted tc the NRC by separate letters each dated May 27, 1987 and are scheduled to go into effect for Unit 1 on December 1,1987, which begins the second ten-year interval of operation.
At the present time, it is planned that Unit 2 will continue operation under the earlier Code until its first ten-year interval of operation ends on July 30, 1991.
During the first ten years of operation, numerous benefits have resulted from performing ISI and IST activities under the same Code requirements for each unit. The plaris, procedures, and manuals which govern ISI and IST activities as well as the program scope and technical requirements have been essentially the same on both units.
This has resulted in uniform implementation of inspection and testing activities.
With the update of the Unit 1 programs, substantial changes to supporting documents and work requirements have occurred resulting in significant differences from the existing Unit 2 programs.
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' U. S. Nuclear. Regulatory Commission November 20, 1987 Page 2 In addition, with the existing regulation, the continually changing ASME l
Code requirements and the significant separation in ten-year interval start l
dates for the two units, the existing update schedule will probably require that each unit meet a dif ferent Code for the remaining life of the plant.
The schedule would currently require that the Unit 2 programs be updated approximately 3-2/3 years af ter the Unit 1 programs and that Unit 1 be updated again approximately 6-1/3 years af ter the Unit 2 programs were u pdated.
Alabama Power Company desires to proceed with updating the Unit 2 ISI and IST Programs to the latest NRC approved ASME Code,Section XI (1983 Edition through Summer 1983' Addenda).
By updating to the same Code of record for both units, the plans, procedures and manuals governing ISI and IST activities can be standardized for both units.
The engineering costs required to update the programs will be greatly reduced due to the similarities in plant design and the use of identical Code requirements.
This will also enable the NRC to perform reviews of the updated Unit 1 programs and apply these reviews to the updated Unit 2 programs, since the programs will be identical (except where minor design differences exist) to those submitted for Unit 1.
The requirements' for updating the ISI and IST Programs for each ten-year interval of. operation are defined in 10CFR50.55a(g).
Deviations from these requirements are permitted by 10CFR50.55a(a)(3) which states:
" Proposed alternatives to the requirements of paragraphs (c), (d), (e), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant must demonstrate that (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements of this section would result in hardship or unusual difficulties without a compensating increase in the level of quality and sa fety."
As an alternative to the required July 30, 1991 update of the Unit 2 ISI and IST Programs, Alabama Power Company proposes to proceed with the Unit 2 update at this time so that the same Code of record will be applied to each unit.
However, prior to proceeding with these updates, NRC approval is necessary to apply the latest NRC approved Code to Unit 2 pursuant to 10CFR50.55a(g)(4)(iv) and authorize Alabama Power Company's use of an alternative update schedule for Unit 2 instead of that currently required by 10CFR50. 55a( g) (4) (ii ). Once the approval and authorization are received and the updated programs are put into effect, Unit 2 would remain under these programs and the same Code of record until December 1,1997 (end of the Unit 1 second ten-year interval).
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.U. S. Nuclear Regulatory Commission 1
e November 20, 1987.
Page 3 Alabama Power Company, therefore, requests approval to utilize the ASME Code,Section XI,1983 Edition through the Summer 1983 Addenda as the Code of record for the remainder of the Unit 2 first ten year interval. This approval is requested pursuant to the requirements of 10CFR50.55a(g)(4)(iv) which permits the use of a later NRC approved Code subject to NRC approval.
In addition, Alabama Power Company requests that, in lieu of the provisions of 10CFR50.55a(g)(4)(ii) requiring that the Unit 2 ISI and IST Programs be updated by July 30, 1991 to the Code of record as of July 30,1990, i ts programs remain under the same Code of record through the first and second forty-month periods of the second ten year interval.
It is anticipated that the third forty-month period of the second ten-year interval would be requested, at the appropriate time, to be conducted under the December 1, 1996 Code of record.
It is not intended that the proposed update would change either the first ten-year interval completion schedule or the start date for the second ten-year interval.
While the ten-year interval schedule has no affect on IST Program implementation, there is significant impact to the ISI Program activities due to refueling outage schedules. The third forty-month period for Unit 2 begins on March 30, 1988 and the remaining outages for the first ten-year ' interval are tentatively scheduled for March,1989 and September, 1990. While Alabama Power Company has strived to complete the maximum number of inspections permitted by the Code during each of the first two periods, the remaining inspection work cannot be completed in less than the two remaining outage s.
The provisions of 10CFR50.55a(a)(3) require Alabama Power Company to demonstrate that the proposed alternative would provide an acceptable level of quality and safety.
It is considered that application of the latest NRC approved Code for the remainder of the Unit 2 first ten-year interval in advance of the update required by the regulation will improve the level of quality and safety.
In as much as this same Code is being implemented for the updated Unit 1 ISI and IST Programs through December 1,1997, it is also considered, pending completion of the NRC's review and issuance of Safety Evaluation Reports or the Unit 1 programs, that it will remain an acceptable basis for the Unit 2 programs through that same time period. Therefore, updating the Unit 2 ISI and IST Programs under APCo's alternative update schedule provides an acceptable level of quality and safety.
Upon receipt of the requested approval and authorization, Alabama Power Company will proceed with updating the Unit 2 programs and will submit them for NRC review and granting of reliefs.
The programs will be identical (to the extent practical given minor design differences between the two units) to those already under review by the NRC for Unit 1.
Once the NRC grants the requested reliefs for Unit 2, the updated programs will be placed into effect at the earliest convenient date.
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,.. ; - ' U. S. Nuclear Regulatory Commission A +
November 20, 1987
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Updating /the Unit'2 ISI and-IST Programs on a concurrent schedule with the Unit l'second; ten-yearlinterval' update represents. a substantial. cost savings
' to Alabama ~ Power. Company by.' standardizing the. technical ' requirements and
-program documents esed in program implementation.
This will.also reduce.the.
required.re' view effort for _ the NRC,. since the' Unit 1 Safety Evaluation
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m Reports can be generically applied to the updated programs for:each unit.
Updating the Unit 2 programs in advance of _ that required by the regulation will' provide.'an acceptable level of quality and safety 'and, under the later Code, these' programs are, expected to maintain - this. level through the end of the Unit 1 Mcond ten-year interval.
To facilitate-timely completion of this effort pricr to the next refueling outage, it is respectfully. requested that the subject approval-and.
authorization be granted by February 18,1988._. Pursuant to.10CFR170.21, the
. required application fee of $150.00'is enclosed.
If.there are any
. questions, please advise.
Respectfully submitted, ALABAMA P ER COMPA Y V
R. P. Mcdonald
-RPM / STB:csla2 Enclosure cc: Mr. L. B. Long Dr. J. N. Grace
.Mr. E. A. Leeves
.Mr. W. H. Bradford l
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