ML23003A809

NRR E-mail Capture - for Your Action - RAI - Farley - ISI Alternative FNP-ISI-ALT-05-05 (L-2022-LLR-0068)

ML23003A809
Person / Time
Site:	Farley
Issue date:	01/03/2023
From:	John Lamb Plant Licensing Branch II
To:	Pournaras D, Sparkman W Southern Nuclear Operating Co
References
L-2022-LLR-0068
Download: ML23003A809 (4)

Text

From: John Lamb Sent: Tuesday, January 3, 2023 3:52 PM To: Sparkman, Wesley A.; Pournaras, DeLisa S.

Cc: Chamberlain, Amy Christine

Subject:

For Your Action - RAI - Farley - ISI Alternative FNP-ISI-ALT-05-05 (L-2022-LLR-0068)

Importance: High Wes and DeLisa, By letter dated September 30, 2022, Southern Nuclear Operating Company (SNC, the licensee) an inservice inspection (ISI) alternative request for Joseph M. Farley Nuclear Plant (Farley),

Units 1 and 2. SNC is requesting an ISI alternative to the examination requirements of American Society of Mechanical Engineers (ASME)Section XI, Table IWC-2500-1, Examination Category C-B, Item Nos. C2.21 and C2.22. The proposed alternative by SNC is to increase the inspection interval for these Item Nos. for the replacement steam generators (SGs) to 20 years (from the current ASME Code,Section XI 10-year requirement).

Specifically, pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a, Paragraph (z)(1) (10 CFR 50.55a(z)(1)), the licensee is proposing to increase the ISI interval for the subject SG welds of FNP Unit 1 and 2 from the current ASME Code,Section XI 10-year requirement to 20 years for the remainder of the fifth 10-year ISI interval and through the sixth 10-year ISI interval, which is currently scheduled to end on November 30, 2037. The licensee referred to the results of the probabilistic fracture mechanics (PFM) analyses in non-proprietary Electric Power Research Institute (EPRI) Technical Report 3002014590, Technical Bases for Inspection Requirements for PWR Steam Generator Class 1 Feedwater and Main Steam Nozzle-to-Shell Welds and Nozzle Inside Radius Sections, 2019 (ADAMS Accession No. ML19347B107) as the primary basis for the deferral of the ISI examinations.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the ISI alternative request and determined that more information is needed to complete its review.

On December 29, 2022, the NRC staff provided a draft RAI question to SNC to make sure that the RAI is understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was previously docketed. On January 3, 2023, SNC stated that a clarifying call was not needed and it would provide the RAI response 30 days from the date of this email.

If you have any questions, you can contact me at 301-415-3100.

Sincerely, John REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter dated September 30, 2022, Southern Nuclear Operating Company (SNC, the licensee) an inservice inspection (ISI) alternative request for Joseph M. Farley Nuclear Plant (Farley),

Units 1 and 2. SNC is requesting an ISI alternative to the examination requirements of American Society of Mechanical Engineers (ASME)Section XI, Table IWC-2500-1, Examination Category C-B, Item Nos. C2.21 and C2.22. The proposed alternative by SNC is to increase the inspection interval for these Item Nos. for the replacement steam generators (SGs) to 20 years (from the current ASME Code,Section XI 10-year requirement).

Specifically, pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a, Paragraph (z)(1) (10 CFR 50.55a(z)(1)), the licensee is proposing to increase the ISI interval for the subject SG welds of FNP Unit 1 and 2 from the current ASME Code,Section XI 10-year requirement to 20 years for the remainder of the fifth 10-year ISI interval and through the sixth 10-year ISI interval, which is currently scheduled to end on November 30, 2037. The licensee referred to the results of the probabilistic fracture mechanics (PFM) analyses in non-proprietary Electric Power Research Institute (EPRI) Technical Report 3002014590, Technical Bases for Inspection Requirements for PWR Steam Generator Class 1 Feedwater and Main Steam Nozzle-to-Shell Welds and Nozzle Inside Radius Sections, 2019 (ADAMS Accession No. ML19347B107) as the primary basis for the deferral of the ISI examinations.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the ISI alternative request and determined that more information is needed to complete its review.

Regulatory Analysis Basis The NRC has established requirements in 10 CFR Part 50 to protect the structural integrity of structures and components in nuclear power plants. Among these requirements are the ISI requirements of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a to ensure that adequate structural integrity of SG vessels (including their welds) is maintained through the service life of the vessels. Therefore, the regulatory basis for the following request for additional information (RAI) has to do with demonstrating that the proposed alternative ISI requirements would ensure adequate structural integrity of the SG welds of Farley, Units 1 and 2, and thereby would provide an acceptable level of quality and safety per 10 CFR 50.55a(z)(1) for the welds.

RAI No. 1 Issue In Section 5.0 of the enclosure to the submittal, the licensee is proposing to increase the ISI interval for the subject SG welds of Farley, Units 1 and 2, from the current ASME Code,Section XI 10-year requirement to 20 years for the remainder of the fifth 10-year ISI interval and through the sixth 10-year ISI interval, which is currently scheduled to end on November 30, 2037. The licensee stated that all exams will be scheduled to occur in the same period as the last examination, but with a two interval inspection periodicity. The licensee provided the inspection history of the affected components in Appendix B of the enclosure to the submittal. The NRC staff reads the stated two interval inspection periodicity as being a 20-year period, but for clarity would like the estimated dates for the next examinations of the affected components.

Request Given the licensees proposed alternative in Section 5.0 of the enclosure to the submittal, the inspection history of the affected components in Appendix B of the enclosure to the submittal, and the NRC staffs understanding of two interval inspection periodicity as being a 20-year

period, provide estimated dates (expected to be before the end of the sixth 10-year ISI interval on November 30, 2037) for the next examinations of the affected components listed in Section 1.0 of the enclosure to the submittal.

Hearing Identifier: NRR_DRMA Email Number: 1881 Mail Envelope Properties (MN2PR09MB5084B8DD6CBC43E95872ECBFFAF49)

Subject:

For Your Action - RAI - Farley - ISI Alternative FNP-ISI-ALT-05-05 (L-2022-LLR-0068)

Sent Date: 1/3/2023 3:51:31 PM Received Date: 1/3/2023 3:51:00 PM From: John Lamb Created By: John.Lamb@nrc.gov Recipients:

"Chamberlain, Amy Christine" <ACCHAMBE@southernco.com>

Tracking Status: None "Sparkman, Wesley A." <WASPARKM@southernco.com>

Tracking Status: None "Pournaras, DeLisa S." <DSPOURNA@SOUTHERNCO.COM>

Tracking Status: None Post Office: MN2PR09MB5084.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6137 1/3/2023 3:51:00 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: