ML20247E853
| ML20247E853 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/27/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9805190014 | |
| Download: ML20247E853 (3) | |
Text
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L M'
Dave Morey Southern Nuclear I
Vice President
.' Operating Company Farley Project P.O. Box 1295 Birmingham Alabama 35201
, Tel 205.992.5131 SOUTHERN COMPANY l
Apr11 27,1998 EnergytoServeYourWorld" DocketNos:
50-348 10CFR50.55a 50-364 U. S. Nuclear Reh*~y Commission ATTN: Docunumt Contrc,1 Desk WMP. DC 20555 Joseph M. Farley Nuclear Plant Inservice Inspection (ISI) Program Correction to Response to NRC Questions / Comments Updated ISI Programs Ladies and Gentlemen:
Bv letter dated February 12,1998, the NRC requested additional information regarding updated ISI programs submitted by Southern Nuclear Operatmg Company (SNC) May 28,1997. The SNC response to these mquests was mailed April 6,1998. Subsequent to this mailing, errors were noted in the response. 'The errors consisted of an extra page and two pages with an incorrect bding The
- page headags reference relief request RR-29 instead of the correct relief request RR-30.
Please remove redundant page E XI-12 located between pages E XI-9 and E XI-10. Replacement pages E XI-l1 and 12 are attached to correct the page 6Aiage. Please accept our apology for any inconvenience.
Should you have any questions please contact this office.
Respectfully submitted,'
(ft ?M Dave Morey EWC/AJP/ cit:isicorr. doc Enclosure u
L cc:
Mr. L. A. Reyes, Region II Administrator
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Mr. J. I. Zimmerman, NRR Project Manager L.
Mr. T. M. Ross,' Plant Sr. Resident inspector
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7 9905190G1A 980427 I
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FNP-2-M-096 SOUTHERN NUCLEAR OPERATING COMPANY FARLEY UNIT 2 UPDATED PROGRAM REQUEST FOR RELIEF NO. RR-30 l
l I.
System / Component for Which Reliefis Reouested: Class 2 piping segments in the Safety injection System that cannot be isolated from Class 1 piping in order to perform pressure testing at the l
Class 2 required test pressure.
Description of Piping Segments Affected:
P&lD Line Number Description D-205038-1 2" CCB-30 Between motor operated valve Q2E21V068 and check valves 3" CCB-30 Q2E21V078A, B & C (Hot Leg Safety Injection)
D-205038-1 2" CCB-31 Between motor operated valve Q2E21V072 and check valves 3" CCB-31 Q2E21V079A, B & C (Hot Leg Safety injection) l D-205038-1 2" CCB-22 Between motor operated valve Q2E21V063 and check valves 3" CCB-22 Q2E21V066A, B & C (Cold Leg Safety Injection)
D-205038-1 2" CCB-21 Between motor operated valves Q2E21V016A & B and check valves 3" CCB-21 Q2E21V062A, B & C (Cold Leg Safety Injection)
D-205038-1 6" CCB-29 Between motor operated valve Q2ElIV044 and check valves D-205038-2 10" CCR-29 Q2E21V076A & B (RHR Hot Leg Injection)
H.
Code Requirement: ASME Section XI,1989 Edition, Table IWC-2500-1, Category C-H, requires pressure testing of Class 2 pressure retaimng components in accordance with IWC-5221 and IWC-5222.
- III, Code Requirement for Which Reliefis Reauested: Reliefis requested from performing the Code-required hydrostatic pressure test at the required pressure for each of the piping segments listed above in accordance with IWC-5222.
IV.
Basis For Relief: The system design did r >t include provisions for isolating these Class 2 piping segments from the Class I system to supput Code-required pressure testing. 'Ihere is no practical method of pressure testing the subject piping segments, to the Class 2 pressure test requirements, without also pressuring the associated Class I reactor coolant system (RCS) piping and components to the same pressure. The boundary valves between the Class 1 and Class 2 piping (class break velves) consist of check valves for each of the subject segments. Therefore, these check valves allow injection to the RCS, but provide no pressure boundary between Class 2 and Class 1.
E XI-l1
A FNP-2-M-096 SOUTHERN NUCLEAR O?ERATING COMPANY FARLEY UNIT 2 UPDATED PROGRAM REQUEST FOR RELIEF NO. RR-30 l
The safety injection lines are provided with manual globe valves immediately upstream of the class break check valves. These valves are utilized for flow balancing of the safety injection flow rate to each RCS leg and are locked in a throttled position. Closing the valves to provide a boundary for pressure testing would require additional performance of the safety injection flow balance test which could significantly impact the outage duration. The RHR Hot Leg injection lines are not provided with any valves upstream of the check valves that can be used to establish the Class 2 pressure test boundary, ne only practical method to pressure test these piping segments consists of perfornung a test concurrent with the Class I system 10-year pressure test. With the Class I system at nominal operating pressure (approximately 2235 psig), these Class 2 piping segments can be pressurized, using a test pump orjumpers, to approximately the same pressure while ensuring that the boundary check valves remain closed.
V.
Altemate Examinations: He Class 2 piping segments will be included within the VT-2 visual exammation boundary during the Class I system leakage test (IWB-5221) each refueling outage.
Additionally, once each inspection interval, the piping segments will be pressurized to approximately RCS nominal operating pressure in conjunction with the Class 1 10-year interval pressure test. He Class 1 10-year pressure test is performed in conjunction with Relief Request RR-?I which utilizes ASME Code Case N-498-1. He piping will be VT-2 visual inspected while the piping is at approximately RCS nominal operating pressure after the required 4-hour hold time.
VI.
Justification for Grantina Relisf: There are no system components that can be used to provide a test boundary between these Class 2 piping segments and the Class 1 RCS. Therefore, pursuant to 10CFR50.55a(g)(6)(i), there are no practical means of performing the Code required pressure tests without modifying the existing systems or subjecting the entire Class 1 RCS to the higher Class 2 pressure. He proposed alternative pressure tests and visual exanunations should proside adequate assurance of the pressure boundary integrity of the subject Class 2 piping segments.
VII.
Implementation Schedule: This relief request is applicable for the updated program beginning December 1,1997.
VIII.
Relief Reauest Status: A version of this relief request was designated as Relief Request RR-23
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and was approved earlier in the second interval by NRC SER dated August 29,1991. This relief request is awaiting NRC approval.
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