ML24297A604
| ML24297A604 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/22/2024 |
| From: | Turner Z Plant Licensing Branch II |
| To: | Sparkman W Southern Nuclear Operating Co |
| Turner, Zachary | |
| References | |
| EPID L-2024-LLA-0119 | |
| Download: ML24297A604 (1) | |
Text
From:
Zach Turner To:
Sparkman, Wesley A.
Cc:
Joyce, Ryan M.; Michael Markley; Stewart Bailey; Thomas Scarbrough; John Lamb
Subject:
For Your Action - RAIs - Farley Unit 2 - RAIs - Farley Unit 2 - Proposed Alternative Request for Charging Pump and Mini-Flow Iso Valve IST Requirements Date:
Tuesday, October 22, 2024 10:38:00 AM Attachments:
RAI -Farley Unit 2 Exigent Request - EPID L-2024-LLR-0068.pdf
- Wes,
By letter dated October 18, 2024 (ADAMS Accession No. ML24292A210), Southern Nuclear Operating Company (SNC) submitted a proposed alternative request for the Joseph M. Farley Nuclear Plant (Farley), Unit 2. The proposed alternative requests to defer the requirements to perform Group A quarterly pump tests as required by ISTB-3400, for the 2A, 2B, and 2C charging pumps, and quarterly exercise testing for 2A, 2B, and 2C charging pump mini-flow valves as required by ISTC-3510, until April 14, 2025.
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the submittal dated October 18, 2024, and determined that additional information is required for the staff to complete its review.
On October 21, 2024, the NRC staff provided the draft requests for additional information (RAI) 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. SNC responded that a clarification call would not be needed to review the draft RAIs.
The RAIs for Farley, Unit 2, proposed alternative request are attached to this email and are released formally with an expedited 7-day response period (October 30, 2024) requested. The expedited response period is needed to meet SNCs requested licensing action completion date of November 7, 2024.
If you have any questions, feel free to contact me at 301-415-2258.
Very Respectfully,
Zach Turner, Project Manager Nuclear Regulatory Commission Division of Operating Reactor Licensing NRR/DORL/LPL2-1 (301) 415-2258 Office: OWFN-07C12 Mail Stop: O-08 B01A
1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FARLEY - UNIT 2 - RELIEF REQUEST TO DEFER CHARGING PUMP AND MINI-FLOW ISOLATION VALVE ISTS SOUTHERN NUCLEAR OPERATING COMPANY FARLEY, UNIT 2 DOCKET NO. 05000364 ISSUE DATE: 10/22/2024
Background:
On October 18, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No, ML24292A210), Southern Nuclear Operating Company (licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) an alternative request associated with the Inservice Testing (IST) Program for the Farley Nuclear Plant (Farley), Unit 2. In its request, the licensee proposes to defer until April 14, 2025, the performance of the Group A quarterly pumps tests for the 2A, 2B, and 2C charging pumps, and the quarterly exercise tests for the 2A, 2B, and 2C charging pump mini-flow valves, required by the current Farley, Unit 2, IST Program Code of Record, the 2004 Edition through the 2006 Addenda of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) as incorporated by reference in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, Codes and standards. The licensee submitted the request as a hardship alternative pursuant to paragraph (z)(2) of 10 CFR 50.55a because of potential degradation to Reactor Coolant Pump (RCP) seals during these tests until repair of the RCP seals can be performed during the spring 2025 refueling outage at Farley, Unit 2.
Regulatory Basis:
The NRC regulations in 10 CFR 50.55a(z), Alternatives to codes and standards requirements, state:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Question 1:
Table 8, 2B Charging Pump Biennial CPT - Vibration Data, in the licensees submittal dated October 18, 2024, indicates an increase in the outboard horizontal, vertical, and axial vibration during the most recent Comprehensive Pump Test (CPT) on October 20, 2023, for the 2B Charging Pump at Farley, Unit 2, from previous vibration test data. Please provide SNCs
2 evaluation of the vibration test data for the 2B Charging Pump and plans to address the pump performance during the next refueling outage.
Question 2:
The Farley IST Program Plan (ML19070A247) indicates that the Charging Pump Mini-Flow Isolation Valves Q2E21V0259A (MOV8109A), Q2E21V0259B (MOV8109B), and Q2E21V0259C (MOV8109C) are 2-inch globe motor-operated valves (MOVs). Tables 13, 14, and 15 in the licensees submittal dated October 18, 2024, provide historical data from stroke-time testing of these MOVs as required by the Farley, Unit 2, IST Program Code of Record, the 2004 Edition through 2006 Addenda of the ASME OM Code as incorporated by reference in 10 CFR 50.55a. The NRC regulations in 10 CFR 50.55a(b)(3)(ii) require licensees to establish a program to ensure that MOVs continue to be capable of performing their design basis safety functions in addition to the ASME OM Code IST requirements. Please describe the successful performance of these MOVs demonstrated during recent diagnostic testing, such as obtained by the Generic Letter 96-05 testing program, to comply with 10 CFR 50.55a(b)(3)(ii).
OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME ZTurner MMarkley MMarkley DATE 10/21/2024 10/21/2024 10/21/2024 OFFICE NRR/DEX/EMIB/BC NAME SBailey DATE 10/21/2024