ML24312A190
| ML24312A190 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/06/2024 |
| From: | Turner Z Plant Licensing Branch II |
| To: | Sparkman W Southern Nuclear Operating Co |
| Turner, Zachary | |
| References | |
| EPID L-2024-LLR-0068 | |
| Download: ML24312A190 (1) | |
Text
From:
Zach Turner To:
Sparkman, Wesley A.
Cc:
Joyce, Ryan M.; John Lamb; Michael Markley; Stewart Bailey; Thomas Scarbrough; Sarah Temple; Alan Blamey
Subject:
Verbal Authorization of SNC Alternative Request RR-PR-04 (EPID L-2024-LLR-0068)
Date:
Wednesday, November 6, 2024 1:14:00 PM
- Wes,
This email serves as documentation of the verbal authorization for the alternative request that the NRC provided this afternoon (November 6, 2024). This email will be made publicly available. As discussed on the call, a formal Safety Evaluation (SE) will be issued at a later date in accordance with NRR Office Instruction LIC-102. The verbal authorization does not preclude the NRC staff from asking additional clarification question while preparing the written SE.
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
VERBAL AUTHORIZATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
ALTERNATIVE REQUEST RR-PR-04 FOR INSERVICE TESTING INTERVAL EXTENSION FOR 2A, 2B, and 2C charging pumps and mini-flow valves SOUTHERN NUCLEAR OPERATING COMPANY JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2
DOCKET NO. 50-364
Technical Evaluation read by Stewart Bailey, Chief of the Mechanical Engineering and Inservice Testing Branch, Division of Engineering and External Hazards, NRC Office of Nuclear Reactor Regulation In the submittal dated October 18, 2024, as supplemented by letter dated October 25, 2024, Southern Nuclear Operating Company, the licensee, proposed Alternative Request RR-PR-04 requesting authorization to delay the inservice testing of the 2A, 2B, and 2C charging pumps and 2A, 2B, and 2C charging pump mini-flow isolation valves at Farley Unit 2, on the basis of
hardship or unusual difficulty without a compensating increase in quality and safety. The licensee requested to defer testing until after repair of the seals in the 2B Reactor Coolant Pump. Repair of the 2B reactor coolant pump seals require the pump and motor to be decoupled, which would require shutdown of the Unit 2 reactor. The repair is scheduled for the spring of 2025 refueling outage, or for a forced outage of sufficient duration. For reasons discussed in the submittal, testing these pumps and valves at this time will cause stress to the 2B reactor coolant pump seals. The licensee asserts this could result in damage or degradation of the 2B reactor coolant pump seals and challenge plant safety and reliability.
The current Code of record for the Farley, Unit 2, Inservice Testing Program is the 2004 Edition through the 2006 Addenda of the ASME Code for Operation and Maintenance of Nuclear Power Plants as incorporated by reference in 10 CFR 50.55a. This Code requires Group A quarterly pump tests for the 2A, 2B, and 2C charging pumps and quarterly exercise testing for the 2A, 2B, and 2C charging pump mini-flow isolation valves. This testing is due on November 7, 2024.
Therefore, the licensee requested an extension of the inservice testing requirements for the specified pumps and valves under the provisions of 10 CFR 50.55a(z)(2) until after the spring of 2025 refueling outage, or for a forced outage of sufficient duration, when the 2B reactor coolant pump seal is expected to be repaired.
The submittal dated October 18, 2024, as supplemented by letter dated October 25, 2024, summarizes the history of test results for the subject pumps and valves. All charging pump comprehensive tests and valve stroke tests have been satisfactory for the last two years, and no significant maintenance has been performed or is planned for the charging pumps or mini-flow isolation valves that would alter the testing. This provides confidence that these components are operationally ready to perform their safety functions.
The NRC staff has reviewed Alternative Request RR-PR-04. The staff finds that compliance with the specified inservice testing requirements at this time would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The staff considers that testing these components at this time would cause stress to the 2B reactor coolant pump seals that could cause further seal degradation and challenge plant safety.
Also, the staff finds that the test and performance history for the specified pumps and valves provides reasonable assurance of their operational readiness over the duration of the alternative request.
Therefore, the NRC staff concludes that the proposed alternative meets the requirements of 10 CFR 50.55a(z)(2). The staff authorizes an extension of the specified testing intervals for the 2A, 2B, and 2C charging pumps and 2A, 2B, and 2C charging pump mini-flow isolation valves, until after the spring of 2025 refueling outage, or for a forced outage of sufficient duration, when the 2B reactor coolant pump seal is expected to be repaired. The licensee will be responsible for evaluating the 2B reactor coolant pump seals and conducting an extent of condition review under 10 CFR Part 50, Appendix B.
Authorization read by Michael Markley, Chief of the Plant Licensing BranchII-1, Division of Operating Reactor Licensing, NRC Office of Nuclear Reactor Regulation
As Chief of the Plant Licensing BranchII-1, Office of Nuclear Reactor Regulation, I agree with the conclusions of the Mechanical Engineering and Inservice Testing Branch.
The NRC staff has determined that Alternative Request RR-PR-04 provides reasonable assurance that the specified pumps and valves will be operationally ready for the duration of the alternative. The NRC staff determined that compliance with the applicable ASME OM Code test requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all regulatory requirements set forth in 10CFR50.55a(z)
(2).
Therefore, as of today, November 6, 2024, the NRC staff authorizes the use of the proposed alternative for an extension to the Inservice Testing Program 3-month intervals only for testing of the 2A, 2B, and 2C charging pumps and 2A, 2B, and 2C charging pump mini-flow isolation valves at Farley Unit 2, in accordance with 10 CFR 50.55a(z)(2) until after the spring of 2025 refueling outage, or for a forced outage of sufficient duration, when the 2B reactor coolant pump seal is expected to be repaired.
All other requirements in ASME OM Code for which an alternative or relief was not specifically requested and authorized or granted remain applicable.
This verbal authorization does not preclude the NRC staff from asking additional clarification questions regarding the proposed alternative while subsequently preparing the written safety evaluation.