ML20237E911
| ML20237E911 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/28/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9809010287 | |
| Download: ML20237E911 (3) | |
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Dave Morey South:rn Nuclear Vice President Operating C:mpany Farley Project R0. Box 1295 Birmingham. Alabama 35201 Tel 205.992.5131 l
August 28, 1998 SOUTHERN h Docket No. 50-348 Energy to Serve Your World' U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 10 CFR 50.55 Washington, DC 20555 Joseph M. Farley Nuclear Plant - Unit 1 Second Ten-Year Interval ASME Section XI Relief Requests Ladies and Gentlemen:
By letter dated March 4,1998, Southern Nuclear Operating Company (SNC) requested relief related to selected examinations for the close-out of the second ten-year interval including Relief Request RR-48.
In a telephone conversation on August 21,1998 between NRC and SNC personnel, RR-48 was discussed.
As agreed to in that conversation, SNC is withdrawing RR-48 and replacing it with RR-56.
Pursuant to 10 CFR 50.55a(a)(3)(ii), based on hardship, SNC is submitting RR-56. Approval is requested by September 28,1998 to support the second interval activities to be performed during the Unit I refueling outage, currently scheduled to commence in October 1998.
Should you have any questions or concerns regarding this matter, please contact this office.
Respectfully submitted, 0
Dave Morey JMA/maf: RRISI. doc Enclosure
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cc:
Mr. L. A. Reyes, Region 11 Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. P. Johnson, Sr. Resident inspector h
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9809010287 980828 PDR ADOCK 05000348 P
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SOUTHERN NUCLEAR OPERATING COMPANY FARLEY UNIT 1 SECOND 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-56 1.
System / Component for Which Reliefis Reauested: Regenerative Heat Exchanger welds and component supports.
II.
Code Requirement: Welds - Table IWC-2500-1, Examination Category C-A requires volumetric examination of pressure vessel welds at structural discontinuities. Supports -
Table IWF-2500-1, Category F-B, requires visual, VT-3 examination of component supports.
III.
Code Requirement for Which Reliefis Reauested: Reliefis requested to delete the examination of Category C-A, Regenerative Heat Exchanger weld ALA2-3560-2 and two Category F-B, Regenerative Heat Exchanger component supports (ALA2-3560-CS-5 and CS-6). These examinations are scheduled during the third period of the second interval.
IV.
Basis for Relief: 'Ihe Regenerative Heat Exchanger is a Class 2 heat exchanger that is designed to reduce unnecessary heat losses by heating the Reactor Coolant System (RCS) charging flow with the letdown flow. The 3" charging inlet / outlet lines are connected to the heat exchanger on the tube side, and the 3" letdown inlet / outlet lines are connected on the shell side. All of the 3" lines are exempt from non-destructive examinations per IWC-1220(c); however, the heat exchanger requires examination. The examination of the Regenerative Heat Exchanger is considered to constitute an unnecessary hardship
- without an associated increase in the level of quality and safety. This conclusion is based on the following.
1.
Previous dose rate surveys and data for Unit 1 Regenerative Heat Exchanger examinations indicate a contact dose rate of approximately 2800 mrem /hr with a cumulative whole body dose of approximately 2500 mrem associated with the examination of a weld. This whole body dose for examination of one weld is considered by SNC to constitute a hardship.
2.
As shown in relief Request RR-18, the Regenerative Heat Exchanger shell is fabricated from materials which restrict ultrasonic examination to a half-node technige Using a half-node technique, the geometric configuration of the weld surface liraits volumetric examinations to approximately half of the required examination volume. SNC considers this a minimal examination for the amount of corresponding dose. Also, as shown in RR-18, surface examinations are currently performed to supplement the limited volumetric examination; however, they are oflimited use on the ID defects.
3.
The subject weld and two piping supports are located on a component where all l-of the numerous welds and supports on the connecting lines are exempt from non-destructive examination. Not performing the examination of one weld and two supports in a system where almost all of the welds and supports do not require examination should have no effect on the level of quality and safety for this system.
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l-SOUTHERN NUCLEAR OPERATING COMPANY FARLEY UNIT 1 SECOND 10-YEAR INTERVAL REQUEST FOR RELIEF NO. RR-56 V.
Alternate Examination: No alternative examinations will be performed.
VI.
Justification for Grantina Relief: A radiation dose of 2500 mrem for the e.mmination of two supports and one weld, where the ultrasonic examination of the weld is limited to approximately one-half of the required volume, is considered a hardship by SNC. The function of the heat exchanger and associated piping is to provide a flow path for charging and letdown to and from the RCS. The level of quality and safety should not be decreased by deletion of the subject examinations on a component, because it is located in piping exempt from nondestructive examinations. The pressure tests which are performed on this section of piping will provide adequate assurance of the integrity of the component and piping in the flow path; therefore, approval is requested per the requirements of 10 CFR 50.55a(a)(3)(ii).
VII.
Implementation Schedule: This relief request is applicable for the current second 10-year interval.
VIII.
Relief Request Status: Relief from performing these examinations was originally requested in RR-48 which was withdrawn. Relief based on hardship is a new relief request, awaiting NRC approval.
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