NL-04-0933, Application for License Renewal - Supplemental Information

Application for License Renewal - Supplemental Information

ML041670508
Person / Time
Site:	Farley
Issue date:	06/04/2004
From:	Stinson L Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-04-0933
Download: ML041670508 (14)

Text

L M. Stinson (Mike)

Southern Nuclear Vice President Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5181 Fax 205.992.0341 SOWUT HiE R N June 4, 2004 C@OMPANY Energy to Serve Yolur WVorld Docket Nos.:

50-348 NL-04-0933 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Units I and 2 Application for License Renewal - Supplemental Information Ladies and Gentlemen:

This letter provides the following requested items to assist in the review of the Joseph M.

Farley Nuclear Plant, Units I and 2, License Renewal Application:

1.

Supplemental information concerning reactor vessel beltline neutron fluence values applicable to a postulated 20-year license renewal period.

2.

Supplemental information associated with the determination of structures and components within the scope of license renewal under the requirements of 10 CFR 54.4(a)(2).

Mr. L. M. Stinson states he is a vice president of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

If you have any questions, please contact Charles Pierce at 205-992-7872.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY L. M. Stinson Sworn to and subscribed before me this Aday of.

(

Q

.2004.

Wotary Pih7jic My commission expires: ' ' 1bS 6

q6

U. S. Nuclear Regulatory Commission NL-04-0933 Page 2 LMS/JAM/slb

Enclosures:

1. Joseph M. Farley Nuclear Plant, Units I and 2 Application for License Renewal - Supplemental Information Concerning Reactor Vessel Beltline Neutron Fluence Values Applicable to a Postulated 20-year License Renewal Period

2. Joseph M. Farley Nuclear Plant Units 1 and 2 Application for License Renewal - 10 CFR 54.4 (a)(2) Supplemental Information cc:

Southern Nuclear Operating Company Mr. J. B. Beasley Jr., Executive Vice President Mr. D. E. Grissette, General Manager - Plant Farley Document Services RTYPE: CFA04.054; LC-# 14051 U. S. Nuclear Regulatory Commission Ms. T. Y. Liu, License Renewal Project Manager Dr. W. D. Travers, Regional Administrator Mr. S. E. Peters, NRR Project Manager - Farley Mr. C. A. Patterson, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

NL-04-0933 ENCLOSURE 1 Joseph M. Farley Nuclear Plant, Units 1 and 2 Application for License Renewal Supplemental Information Concerning Reactor Vessel Beltline Neutron Fluence Values Applicable to a Postulated 20-year License Renewal Period El-1 NL-04-0933 Supplemental Information Concerning Reactor Vessel Beltline Neutron Fluence Values Applicable to a Postulated 20-year License Renewal Period The reactor vessel beltline neutron fluence values applicable to a postulated 20-year license renewal period, and provided in the Farley license renewal application, were calculated using the latest topical reports for Farley Units 1 and 2 [WCAP-1 4687, "Joseph M. Farley Units 1 and 2 Radiation Analysis and Neutron Dosimetry Evaluation",

R. L. Bencini, June 1996 and WCAP-15171, Revision 1, 'Analysis of Capsule Z from the Alabama Power Company Joseph M. Farley Unit 2 Reactor Vessel Radiation Surveillance Progranti', E. Terek, et. al., February 2000]. The analysis methods used to calculate the Farley vessel fluences follow the guidance of Regulatory Guide 1.190,

'Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence." The underlying guidance of Reg. Guide 1.190 is that fluence calculations should be made on a plant-specific basis rather than on a generic conservative basis.

The methodology used to determine the calculated fluence has been demonstrated to have an associated uncertainty consistent with the assumptions made in the development of the pressurized thermal shock (PTS) screening criteria for vessel welds and plates.

E1-2

NL-04-0933 ENCLOSURE 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Application for License Renewal Supplemental Information Related to 10 CFR 54.4 (a)(2)

E2 - 1 NL-04-0933 RAI 2.1 Supplemental Response (Part 2)

In Part 1 of the supplemental response to RAI 2.1-1 (provided in RAI response letter NL-04-0617 dated April 16, 2004), SNC agreed to broaden the methodology used for scoping of non-attached non safety-related (NSR) piping in accordance with 10 CFR 54.4(a)(2) in the following manner:

1.

Eliminate any distance criteria for excluding a spatial interaction between safety-related (SR) and NSR systems, structures and components (SSCs);

and

2.

Further evaluate spatial interaction effects on mechanical and structural SR SSCs (i.e., do not limit the valid target considerations to electrical SSCs).

10 CFR 54.4(a)(2) Scopinq Methodology Changes The original SNC scoping process for 10 CFR 54.4(a)(2) included a 20 foot spray distance criterion for evaluating the spatial interaction between non-attached low energy NSR liquid filled piping components that could suffer an age-related failure and spray/leak on vulnerable SR SSCs (refer to RAI 2.1-1 part A in SNC letter NL-04-2623 dated January 9, 2004). SNC has eliminated the spray distance criterion from the process of determining which NSR SSCs are in scope for the criterion of 10 CFR 54.4(a)(2). Note that a spray is not postulated for unpressurized piping systems, however a leak is postulated. This change in scoping methodology brings SNC in alignment with other recent applicants, most notably the V. C. Summer scoping process.

The methodology change invokes the plant spaces approach that assumes a spatial interaction can potentially occur if the SSCs are located in the same space. For the purposes of this process, a space is defined by the room in which the SR and NSR components are located.

The original SNC scoping process also limited valid target considerations to electrical SSCs for evaluating the spray/leakage effects (refer to RAI 2.1-1 part C in SNC letter NL-04-2623 dated January 9, 2004). Long-term exposure to leakage or spray was not considered credible. SNC has eliminated the limitation of a valid target to electrical SSCs. The revised methodology evaluates the impact of sprays and leaks on mechanical and structural SR SSCs, as well as electrical SR SSCs, with no limitations on the duration of the sprays/leaks. SNC considers fluid-bearing NSR SSCs to be in the scope of the criterion of 10 CFR 54.4(a)(2), provided the NSR SSCs are located in the same space as a SR SSC and the SR SSC is vulnerable to the effects of the spray/leakage. If the SR SSC is determined to not be vulnerable to the effects of the spray/leakage, then the NSR SSC would not be in the scope of the Rule since the NSR SSC could not prevent or adversely affect the SR SSC from performing its safety related function.

E2 -2 NL-04-0933 Discussion - Implementation of MethodoloqV Changes A plant spaces approach is used to define the potential for a spatial interaction. A space is defined by the room in which the SR and NSR components are located. Physical barriers (e.g., walls, ceilings, and floors) define the space. In evaluating the impact of sprays and leaks on mechanical, structural, and electrical SR SSCs, no limitation is placed on the duration. The spray/leakage is assumed to continue until detected through in-scope features or through an aging management program.

SNC has chosen to rely on the floor drains, floor drain tank, sumps, and associated pumps as mitigative features to control internal flooding (e.g., prevent leakage in a NSR space from flooding an adjoining SR space) and as a method to detect significant leakage resulting from a failed NSR SSC. The civilstructural aspects of the plant design that preclude an adverse impact on SR SSCs due to flooding are already in scope under the spaces approach used to scope civilstructural features in safety-related buildings.

Aging management of NSR piping system components that have been included within the scope of license renewal is primarily done using the preventive option. Aging management programs are provided as necessary to prevent a failure of the pressure boundary from occurring. Where long-term exposures to spray/leakage upon safety-related SSCs are postulated to occur and could prove to be detrimental, the NSR SSCs that could leak are put in scope and aging management programs for the SR SSCs (e.g., the External Surfaces Monitoring Program, the Borated Water Leakage Evaluation and Assessment Program, and/or the Structural Monitoring Program) are also credited to manage the aging effects.

Impact on LRA Results The impacts of the changes in the 10 CFR 54.4(a)(2) scoping methodology on the results presented in the License Renewal Application (LRA) were determined. The spatial interaction assessments for NSR SSCs in SR buildings were re-evaluated, including NSR systems that were previously identified as not being in the scope of the Rule but could potentially be impacted by the methodology change. NSR SSCs in containment were not re-evaluated since the SR SSCs in containment are already qualified for the most limiting post-accident environments, including spray and/or steam.

As such, all possible flooding and spray effects have been factored into the design of this equipment, and failure of NSR SSCs in the Containment Building will not result in the failure of SR SSCs in that vicinity.

For the previously in-scope systems, the methodology change expands the mechanical SSCs within the scope of license renewal; however, there is only a small increase in the number of component types. The methodology change also results in a small increase in the number of systems in the scope of license renewal due to 10 CFR 54.4(a)(2). The Roof Drains and Sanitary Drains are added to the scope of License Renewal and incorporated into the Liquid Waste and Drain LRA System. The methodology change does not result in any systems being removed from scope that were previously identified as in the scope of the Rule.

Aging management reviews were performed in support of the changes in the 10 CFR 54.4(a)(2) scoping methodology. The aging management programs credited are only E2 -3 NL-04-0933 those programs already described in the LRA. The scope of the programs will be revised (as necessary) to encompass the expanded (a)(2) scoping results.

The impact of the changes in the 10 CFR 54.4(a)(2) scoping methodology on the License Renewal Application (LRA) results is provided in the following summary table.

RAI 2.1-1 Table 1:

Impact of 10 CFR 54.4(a)(2) scoping methodology Changes on LRA Results Evaluation Results Increase in Change to Change to FNP LRA SYSTEM In-Scope Section 2 Section 3 SSCs Results Results Open Cycle Cooling Water Yes No No Closed Cycle Cooling Water Yes No No Demineralized Water Yes No No Potable and Sanitary Water Yes No No Reactor Makeup Water Yes No No Storage Chemical and Volume Control Yes Yes Yes Feedwater Yes Yes Yes Chemical Addition Liquid Waste & Drains Yes Yes Yes including:

Roof Drains Sanitary Drains For each of these systems, a discussion of the impact of the 10 CFR 54.4(a)(2) scoping methodology changes on the LRA results follows.

Open-Cycle Cooling Water (OCCW) System, Closed-Cycle Cooling Water (CCW)

Svstem. Demineralized Water (DWI Svstem. Potable and Sanitarv Water (P&SW)

System, and Reactor Makeup Water System (RMWS)

Wherever these systems' NSR components are located in the same space as SR SSCs, SNC considers the components in scope for 10 CFR 54.4(a)(2). The component types do not change from the component types listed in LRA Tables 2.3.3.5, 2.3.3.6, 2.3.3.16, 2.3.3.21, and 2.3.3.23 (for OCCW, CCCW, DW, P&SW, and RMWS respectively). In addition, there are no changes or additions to the aging management review results presented in LRA Tables 3.3.2-5, 3.3.2-6, 3.3.2-16, 3.3.2-21, and 3.3.2-23.

E2 -4 NL-04-0933 Chemical and Volume Control System (CVCS)

The CVCS contains many NSR components that pass through the Auxiliary Building..

The revised scoping methodology for 10 CFR 54.4(a)(2) results in additional NSR SSCs being brought into scope. Stainless steel lines that pass through rooms 331 and 2331 are added to scope, and the NSR lines and valves associated with the boron concentration meters in Rooms 209 and 2209, as well as the liquid bearing tanks of the meters are added to scope. The chemical mixing tanks (and associated stainless steel piping and valves) were originally considered too far from a vulnerable target in Rooms 186 and 2186. With the change in methodology, these NSR components are now considered in scope. The piping, pipe components, and valves are already listed in LRA Table 2.3.3.8 and Table 3.3.2-8, however the tanks are not.

The impact to the LRA Section 2 and Section 3 tables are as follows.

The Chemical and Volume Control System's table of component types subject to an AMR (LRA Table 2.3.3.8) should include the following:

Component Type Intended Function Chemical Mixing Tanks Pressure Boundary Boron Concentration Meter Pressure Boundary.

Tanks The CVCS aging management review summary Table 3.3.2-8 should include the following:

Component Aging Effect Aging 1801 GALL Intended Requiring Management Volume 2 Table 1 Reference Function Material Environment Management Programs Item Item Notes Tanks Pressure Stainless Borated Water Loss of Water H. 30, (Boron Boundary Steel

(<140 'F)

Material Chemistry 39 Concentration Conrol M eter Tanks)__

Pr g a Air/Gas None None J

(air space)

Required and Inside E2 -5 NL-04-0933 Component Typo NUJREG-Aging Effect Aging 1801 GALL Intended Requiring Management Volume 2 Table I Reference Function Material Environment Management Programs Item Item Notes Tanks Pressure Stainless Treated Water Loss of Water G. 30 (Chemical Boundary Steel

(<140 'F)

Material Chemistry (CheicalControl Mixing Tank)

Program And One Time Inspection Program Air/Gas None None J

(air space)

Required and In sid e Feedwater LRA System - Chemical Addition System The Chemical Addition System is addressed as part of the Feedwater LRA System in the application. A portion of the Chemical Addition System is affected by the changes in the 10 CFR 54.4(a)(2) scoping methodology. The portion of the chemical addition system that is of concern is the portion that is located in the Auxiliary Building on the 100' elevation. The system is normally unused (it is occasionally used for batch processing of wet lay-up chemicals) and unpressurized. When used, the system is operated locally such that any leak in the area containing the SR SSCs would be immediately detected and the operation stopped.

A through-wall failure in the system components on the discharge side of the system pumps could expose vulnerable SR SSCs in the space to the treated water of the system. Therefore, the discharge-side lines are included in the scope of the Rule and evaluated for aging effects that require management.

The Chemical Addition System is supplied from the condensate storage tank, and the supply line runs in the same room as SR components. Since the supply-side of the system is left unpressurized (isolated), a spray from a failure in these components is not postulated. None of the supply-side components are routed above SR SSCs that are vulnerable to a leak. Room drainage is available; therefore, leakage would not lead to a flooding event that would compromise the SR components in the area. Similarly, leakage from the chemical addition tanks (100 gallon capacity) or skid components (on the supply side of the pumps) would not cause a flood in the lower equipment room or connected rooms that would lead to a failure of a SR component.

The impact to the LRA Section 2 and Section 3 tables are as follows.

The Feedwater System's table of component types subject to an AMR (LRA Table 2.3.4.2) should include the following:

E2 - 6 NL-04-0933 The Feedwater System aging management review summary Table 3.4.2-2 should include the following:

NUREG-Component Type Aging Effect Aging 1801 Intended Requiring Management Volume 2 Table 1 GALL Reference Function Material Environment Management Programs Item Item Notes Pump Casings Pressure Stainless Water Loss of One Time J

Boundary Steel

(<140 'F)

Material Inspection Program Water Chemistry Control Program Inside None None J

Required Liauid Waste and Drains (LW&D)

The scoping results for the Liquid Waste and Drains are affected by the change in the 10 CFR 54.4(a)(2) scoping methodology. Floor drains, drain holdup tanks, and sump pumps that are relied upon in the revised methodology are brought into scope. In addition, the Roof Drains and Sanitary Drains systems are added to the scope of License Renewal and incorporated into the Liquid Waste and Drain LRA System.

The LW&D has a variety of sub-systems, so a brief explanation of the components, their materials, their environments, and their aging management strategy is appropriate.

Due to the change in scoping methodology, the leakage detection functions of the Waste Holdup Tank (WHT) and the Floor Drain Tank (FDT) are considered within the scope of 10 CFR 54.4(a)(2). This means that a new component for this LRA system, "Tank,"

requires evaluation for aging effects that require management. The tanks are stainless steel, and the fluid in the tanks is unmonitored and therefore conservatively listed as "Raw Water." The tanks are in an 'Inside" environment. SNC does not anticipate that adverse aging will occur in either of these tanks. However, SNC will include the stainless steel tanks in the sample population for the One Time Inspection (OTI) program to be applied to the LW&D (in this case specifically looking for loss of material).

The passive and long lived portions (tubing and fittings, classified as piping in the FNP LRA) of the level instrumentation for the tanks will also be included in the sample population for the OTI.

The floor drains include a cast iron drain body that is embedded in the concrete floor.

Where the drain lines are embedded in the concrete, the material is either stainless steel E2 -7 NL-04-0933 or cast iron. The external environment of the drain body and the piping is uembedded,"

and the interior environment is 'Air/Gas." Where the drains pass through the space of a room, the piping is either stainless steel or carbon steel, depending upon the area being drained (with "Air/Gas" as the interior and "Inside" as the exterior environment). The carbon steel components will be included in the sample population for the OTI to ensure that corrosion is not proceeding rapidly. The exterior surfaces are included in the External Surfaces Monitoring Program, and where the components could be exposed to leakage from borated water systems, the Borated Water Leakage Assessment and Evaluation Program will be applied. Note that LRA Table 3.3.2-19 already includes the aging management information for carbon steel components of this type. Cast iron components in accessible environments are not subject to general corrosion unless they are installed in a location that is subject to repeated wet-dry cycling. Cast iron that is not subject to wet-dry cycling develops an adherent oxide layer that limits the effects of general corrosion. For this reason, the floor drain cast iron components do not have an aging effect that requires management. The stainless steel embedded components also do not have an aging effect that requires management in these environments.

Sump pump casings are stainless steel. The pump casings are assumed to be filled with untreated Raw Water; the exterior environment is Inside." Sump pump lines that discharge to the WHT are stainless steel; those that discharge to the FDT are carbon steel. The interior environment of these lines is assumed to be Raw Water (as some of them may remain filled with sump water); the exterior environment is Inside." The sump pump casings and the discharge piping will be included in the sample population for the OTI of their interior surfaces. The exterior surfaces of the carbon steel components will be managed through the External Surfaces Monitoring Program and, where appropriate, will be included in the scope of the Borat6d Water Leakage Assessment and Evaluation Program.

The sink and floor drains from the Nuclear Laundry and from the Radio-Chemistry Labs are frequently used and are routed in such a way as to pass through spaces that contain SR SSCs. The drains are constructed of stainless steel material and are most often empty. The water chemistry of the samples that are disposed of in these drains is at least "treated water" and often "Primary Water" in purity. As a result, aggressive chemical species are not likely to build-up in the drains through wet/dry cycling.

Therefore, SNC does not expect the drains to experience adverse aging effects during the period of extended operation. Since the postulated failure modes for this piping are hypothetical, not evaluated in the FNP CLB, and not experienced at either FNP or in the industry, this piping is not in the scope of renewal for 54.4(a)(2). This same argument applies to the other, infrequently used (normally empty) stainless steel floor drains whose effluent is processed through the waste hold-up tank and the floor drain tank.

On the non-radiologically controlled side of the Auxiliary Building, portions of the drains are constructed of carbon steel material. Portions of these carbon steel drains are used to remove the condensation from ventilation units, and these drains may frequently contain untreated water. SNC does not expect the carbon steel piping to experience rapid detrimental corrosion during the period of extended operation. However, since these drains pass over SR SSCs that would be vulnerable to' leakage, the drains are considered to be in the scope of 54.4(a)(2). The External Surfaces Monitoring Program applies to the drains, and, as a further measure of prudence, SNC will apply an OTI to a sample set of locations of the carbon steel drains to determine the impact of corrosion from the untreated water in the drains.

E2 -8 NL-04-0933 Sanitary Drains: The sanitary drains are normally empty but are often used. They are normally at atmospheric conditions. The drains are routed in the same areas as SR SSCs, and some are routed over SR SSCs. Therefore, leakage from these drains has the potential to cause an adverse impact upon the performance of SR SSCs. The sanitary drains are therefore in the scope of 10 CFR 54.4(a)(2). The components in this system include carbon steel, stainless steel, cast iron, and copper alloy materials. While the lines are normally dry, the drains are frequently used. For the purposes of evaluating aging effects, the internal environment is 'Air/Gas (Wetted)." The primary concern is with the carbon steel portions of the sanitary drains. SNC does not expect significant corrosion to occur in the drains; however, aging management will include an internal OTI of a sample set of worst case locations and the use of the External Surfaces Monitoring Program for the carbon steel components.

Roof Drains: Some of the roof drains are routed in such a way that they pass directly over SR SSCs. A through-wall failure of these drains could lead to leakage upon SR SSCs. Therefore, these drains are in scope. The LW&D system would process any leakage, however unlikely, from the roof drains. Therefore, such leakage would not cause a flood. For scoping purposes, only those roof drains that are routed over SR SSCs can adversely impact the performance of any SR SSCs, and only those drains are in the scope of 10 CFR 54.4(a)(2). Roof Drain components include the drain bodies, piping, and closure bolting. The piping is stainless steel. The drain bodies, located at the roof interface, are cast iron. Closure bolting for the drains is Alloy Steel. The interior environment of the piping is Air/Gas (Wetted), and the exterior environment of the piping (and the closure bolting) is "Inside." The drain bodies, embedded in the concrete roofs, are cast iron and located in an outdoor environment. As a measure of prudence, SNC will perform a OTI on a sample set of roof drain bodies to ensure that detrimental aging is not occurring.

As a result of the reliance on these components and the inclusion of the sanitary drains and the roof drains in the LW&D, additions to Table 2.3.3.19 and Table 3.3.2-19 are required. The impact to the LRA Section 2 and Section 3 tables are as follows.

The Liquid Waste and Drain's table of component types subject to an AMR (LRA Table 2.3.3.19) should include the following:

Component Type Intended Function Drain Bodies Pressure Boundary Pump Casings Pressure Boundary The LW&D aging management review summary Table 3.3.2-19 should include the following:

E2 - 9 NL-04-0933 Component Type Aging Effect Aging GALL Intended Requiring Management NUREG-1801 Table 1 Reference Function Material Environment Management Programs Volume 2 Item Item Notes Tanks Pressure Stainless Raw Water Loss of One Time J

(Waste Boundary Steel Material Inspection Holdup and Floor Drain Tanks)

Air/Gas None None J

Required Inside None None J

Required Piping and Pressure Stainless Air/Gas Loss of One Time Components Boundary Steel (Wetted)

Material Inspection (Drain piping, Program Including floor drain bodies)

Air/Gas None None J

Required Embedded None None J

Required Inside None None J

Required Cast Iron Air/Gas None None J

Required Embedded None None J

Required Copper Air/Gas Loss of One Time J

Alloys (Wetted)

Material Inspection Program Inside None None J

Required Pump Pressure Stainless Raw Water Loss of One Time J

Casings Boundary Steel (untreated)

Material Inspection (Sump Program pumps)

Inside None None J

Required Drain Bodies Pressure Cast Iron Outside Loss of One Time J

Boundary Material Inspection (Roof Drains)

Program Embedded None None J

Required E2 - 10