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Category:Letter type:NL
MONTHYEARNL-24-0011, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2024-01-11011 January 2024 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0901, 30-Day 10 CFR 21 Notification - Framatome Supplied Siemens Medium Voltage (Mv) Circuit Breakers2023-12-15015 December 2023 30-Day 10 CFR 21 Notification - Framatome Supplied Siemens Medium Voltage (Mv) Circuit Breakers NL-23-0908, Cycle 30 Core Operating Limits Report2023-12-13013 December 2023 Cycle 30 Core Operating Limits Report NL-23-0877, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0825, Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection2023-11-14014 November 2023 Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection NL-23-0739, Response to NRC Inspection Report and Preliminary White Finding2023-09-0808 September 2023 Response to NRC Inspection Report and Preliminary White Finding NL-23-0716, Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-23023 August 2023 Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0713, Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-23023 August 2023 Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0704, Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-22022 August 2023 Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0628, Readiness for Supplemental Inspection EA-22-1012023-07-26026 July 2023 Readiness for Supplemental Inspection EA-22-101 NL-23-0566, ISFSI and Edwin I. Hatch Nuclear Plant ISFSI - Registration of Spent Fuel Cask Use2023-07-13013 July 2023 ISFSI and Edwin I. Hatch Nuclear Plant ISFSI - Registration of Spent Fuel Cask Use NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0444, Quality Assurance Topical Report Submittal2023-06-15015 June 2023 Quality Assurance Topical Report Submittal NL-23-0457, ISFSI, and Edwin I. Hatch Nuclear Plant, ISFSI - Registration of Spent Fuel Cask Use2023-06-12012 June 2023 ISFSI, and Edwin I. Hatch Nuclear Plant, ISFSI - Registration of Spent Fuel Cask Use NL-23-0449, National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application2023-06-0202 June 2023 National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application NL-23-0383, SNC Response to Regulatory Issue Summary 2023-01:Preparation And.2023-05-19019 May 2023 SNC Response to Regulatory Issue Summary 2023-01:Preparation And. NL-23-0372, Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 20222023-05-10010 May 2023 Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 2022 NL-23-0337, Response to Request for Additional Information Related to License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.52023-05-0505 May 2023 Response to Request for Additional Information Related to License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 NL-23-0295, Reply to a Notice of Violation; EA-22-1012023-05-0101 May 2023 Reply to a Notice of Violation; EA-22-101 NL-23-0310, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20222023-04-25025 April 2023 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2022 NL-23-0019, GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2023-04-12012 April 2023 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI NL-23-0263, Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report2023-04-0505 April 2023 Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report NL-23-0208, Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update2023-03-29029 March 2023 Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update NL-23-0014, Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding2023-03-29029 March 2023 Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding NL-23-0213, Inservice Inspection Program Owner'S Activity Report for Outage 1R312023-03-21021 March 2023 Inservice Inspection Program Owner'S Activity Report for Outage 1R31 NL-23-0228, Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21)2023-03-20020 March 2023 Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21) NL-23-0080, Response to Request for Additional Information (RAI) Related to Proposed Inservice Inspection Alternative FNP-ISI-ALT-05-05, Version 1.02023-02-0202 February 2023 Response to Request for Additional Information (RAI) Related to Proposed Inservice Inspection Alternative FNP-ISI-ALT-05-05, Version 1.0 NL-23-0008, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification 3.4.10, Pressurizer Safety Valves to Decrease Low Side Setpoint Tolerance Limiting.2023-01-17017 January 2023 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification 3.4.10, Pressurizer Safety Valves to Decrease Low Side Setpoint Tolerance Limiting. NL-23-0011, Update to Supporting Documentation Regulatory Conference EA-22-101. Cover Letter Only2023-01-0505 January 2023 Update to Supporting Documentation Regulatory Conference EA-22-101. Cover Letter Only NL-22-0799, License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.52022-12-20020 December 2022 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 NL-22-0897, Supplement to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A,2022-12-0909 December 2022 Supplement to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, NL-22-0887, Cycle 32 Core Operating Limits Report2022-11-21021 November 2022 Cycle 32 Core Operating Limits Report NL-22-0884, Response to NRC Inspection Report 05000348/2022440 and 05000364/2022440 EA-22-1012022-11-17017 November 2022 Response to NRC Inspection Report 05000348/2022440 and 05000364/2022440 EA-22-101 NL-20-0170, Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC2022-10-14014 October 2022 Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC NL-22-0756, Proposed Inservice Inspection Alternative FNP-ISI-ALT-05-05, Version 1.02022-09-30030 September 2022 Proposed Inservice Inspection Alternative FNP-ISI-ALT-05-05, Version 1.0 NL-22-0289, License Amendment Request to Revise Technical Specification 4.3 Fuel Storage to Correct Tabulated Values from the Associated Spent Fuel Pool (SFP) Criticality Analysis2022-09-21021 September 2022 License Amendment Request to Revise Technical Specification 4.3 Fuel Storage to Correct Tabulated Values from the Associated Spent Fuel Pool (SFP) Criticality Analysis NL-22-0608, Interim 10 CFR 21.21(a)(2) Report Regarding Framatome Supplied Siemens Medium Voltage Circuit Breakers2022-08-17017 August 2022 Interim 10 CFR 21.21(a)(2) Report Regarding Framatome Supplied Siemens Medium Voltage Circuit Breakers NL-22-0552, Inservice Inspection Program Owner'S Activity Report for Outage 2R282022-07-28028 July 2022 Inservice Inspection Program Owner'S Activity Report for Outage 2R28 NL-22-0510, Plants Units 1 and 2, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20212022-07-14014 July 2022 Plants Units 1 and 2, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2021 NL-22-0223, License Amendment to Revise Technical Specification 3.4.10, Pressurizer Safety Valves to Decrease Low Side Setpoint Tolerance Limiting Condition for Operation (LCO) Value2022-06-30030 June 2022 License Amendment to Revise Technical Specification 3.4.10, Pressurizer Safety Valves to Decrease Low Side Setpoint Tolerance Limiting Condition for Operation (LCO) Value NL-22-0361, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification 5.5.17, Containment Leakage Rate Testing Program to Increase Calculated Peak.2022-06-20020 June 2022 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification 5.5.17, Containment Leakage Rate Testing Program to Increase Calculated Peak. NL-22-0362, Southern Nuclear Operating Company, Inc. - Foreign Ownership, Control, or Influence Five-Year Renewal Filing and NRC Facility Clearance Update2022-06-0101 June 2022 Southern Nuclear Operating Company, Inc. - Foreign Ownership, Control, or Influence Five-Year Renewal Filing and NRC Facility Clearance Update NL-22-0388, Cycle 29 Core Operating Limits Report2022-05-31031 May 2022 Cycle 29 Core Operating Limits Report NL-22-0344, Annual Radiological Environmental Operating Reports for 20212022-05-10010 May 2022 Annual Radiological Environmental Operating Reports for 2021 NL-22-0340, Response to Request for Additional Information Related to Request for License Amendment to Relocate Augmented Piping Inspection Program Details from Technical2022-05-10010 May 2022 Response to Request for Additional Information Related to Request for License Amendment to Relocate Augmented Piping Inspection Program Details from Technical NL-22-0240, SNC Response to Regulatory Issue Summary 2022-01: Preparation and Scheduling of Operator Licensing Examinations2022-03-31031 March 2022 SNC Response to Regulatory Issue Summary 2022-01: Preparation and Scheduling of Operator Licensing Examinations 2024-01-11
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Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham. Alabama 35201-1295 August 3,2007 Energy to Serve Your Workis" Docket Nos.: 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-000 1 Joseph M. Farley Nuclear Plant - Units 1 and 2 Relief Request RR-60 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)
Ladies and Gentlemen:
Pursuant to 10 CFR 50.55a(a)(3)(ii), Southern Nuclear Operating Company (SNC) hereby requests NRC approval of proposed alternative RR-60 to allow visual examination (VT-2) at potential zero nominal pressure, of a section of the Chemical Volume and Control System piping. This is an alternative to the ASME Section XI Code, 1989 Edition with no addenda.
This alternative is for the Farley Nuclear Plant (FNP) 3rd10-Year IS1 Interval. The details of the request for alternative are contained in the enclosure to this letter.
Approval is requested to support the Unit 1 outage at FNP beginning September 29,2007.
If you have any questions, please advise.
Manager, Nuclear Licensing
Enclosure:
Relief Request RR-60, Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)
U. S. Nuclear Regulatory Commission NL-07-1523 Page 2 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Plant Farley Mr. D. H. Jones, Vice President - Engineering RType: CFA04.054; CVC7000; LC# 1461 6 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Ms. K. R. Cotton, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley
Joseph M. Farley Nuclear Plant - Units 1 and 2 Enclosure Relief Request RR-60, Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)
Enclosure Joseph M. Farley Nuclear Plant - Units 1 and 2 Relief Request RR-60 Proposed Alternative In Accordance with 1 0 CFR 50.55a(a)(3)(ii)
Plant Unit Joseph M. Farley Nuclear Plant (FNP) Unit 1 ASME Code Comvonent(s) Affected A 2" nominal pipe size Chemical Volume and Control System (CVCS) piping segment between check valve Q 1E2 1V 109 and Air Operated Valve (AOV) Q 1E2 1V245.
Avplicable Code Edition and Addenda ASME Section XI Code 1989 Edition with no Addenda Avvlicable Code Requirement Table IWB-2500-1, Items B15.5 1 (piping) and B15.71 (valves) and ASME Section XI Code Case N-498-4 require a pressure test of the entire Class 1 System boundary, once every 10-years, at nominal operating pressure, accompanied by visual examination (VT-2) after a hold time of 10-minutes for non-insulated and 4-hours for insulated components.
Reason for Request
This 2" CVCS auxiliary Pressurizer (PRZR) Spray Line piping segment cannot be pressurized in accordance with the ASME Section XI requirements without undue hardship.
Proposed Alternative and Basis for Use FNP proposes VT-2 examination of this piping segment at potentially zero nominal pressure after the remainder of the Reactor Coolant System (RCS) has been at nominal operating pressure for at least 4-hours.
From the CVCS Regenerative Heat Exchanger, a 2" branch line goes to AOV QlE21V245, on to 2" check valve Q 1E2 1V 109, then through a 2" by 4" pipe expander, then to the auxiliary PRZR spray nozzle. This flow path is used to provide an alternative PRZR pressure control method during off normal conditions, such as when no Reactor Coolant Pumps are running. CVCS is continuously insewice during normal plant operation, therefore the piping up to valve Q 1E2 1V245 is at a pressure 2 RCS pressure.
RCS pressure is controlled by the PRZR which is at 2 RCS pressure during normal operation. However, the 2" pipe segment between AOV Q 1E21V245 and check valve Q1E21V109 cannot be pressurized without impacting proper RCS pressure control.
Enclosure Page 2 of 4 Relief Request RR-60, Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)
The only practicable way to pressurize the piping segment between check valve QlE21V109 and AOV Q1E2 1V245 to nominal RCS pressure would require disassembly of check valve Q1E2 1V109, removal of the valve disc, reassembly of check valve, pressurize RCS, hold for 4-hours and then perform the VT-2 examination. This method would provide compliance with the Code and Code Case, but results in the following hardships.
- 1. Valve QlE21V109 is located inside the containment shield wall in close proximity to RCS piping and the PRZR. This area is considered a High Radiation Area and maintaining personnel dose for ALARA would be of concern. Disassembly of this valve would subject personnel not only to general radiation dose rates but also very high radiation doses once the valve is opened. Once opened, personnel contamination is also of concern since this valve provides a RCS boundary.
- 2. Unit would not be able to progress directly from pressure test completion into plant startup due to the required RCS depressurization and cooldown to enable disassembly/ reassembly of check valve QlE21V109 prior to startup. It is estimated that this iteration would require 2 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (based on; cooldown to < 200°F (Mode 5), degas RCS (remove hydrogen), depressurize RCS, disassemble valve QlE21V109 and re-install disc, reassemble valve, fill and vent the RCS, and then heat-up and pressurize to Normal Operating Temperature and Pressure). Valve QlE21V109 would then require a post reassembly VT-2 examination at normal operating pressure. All this would be critical path time which would extend the refueling outage duration.
- 3. Check valve disassembly/reassembly increases the opportunity for human error and mechanical damage resulting in unacceptable RCS pressure boundary integrity and valve operation.
- 4. QlE21V109 is a Y-Type, socket welded, check valve with a seal weld at the cover to body connection. Disassembly requires grinding away the seal weld which creates additional opportunities for valve damage. Reassembly requires machining the cover to body surface area to allow for a quality seal weld to prevent leakage during operation.
Therefore, compliance with ASME Section XI Code and Code Case N-498-4 requirements results in hardship or unusual difficulty without a compensating increase in the level of quality and safety and this proposed alternative is warranted per 10CFR50.55a(a)(3)(ii).
Duration of Proposed Alternative One time, end of 3rd10-year IS1 Interval, ending November 30,2007.
Enclosure Page 3 of 4 Relief Request RR-60, Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)
Plant Unit Joseph M. Farley Nuclear Plant (FNP) Unit 2 ASME Code Component(s) Affected A 2" nominal pipe size Chemical Volume and Control System (CVCS) piping segment between check valve Q2E2 1V 109 and Air Operated Valve (AOV) Q2E2 1V245.
Applicable Code Edition and Addenda
ASME Section XI Code 1989 Edition with no Addenda A~plicableCode Requirements Table IWB-2500-1, Items B 15.51 (piping) and B 15.7 1 (valves) and ASME Section XI Code Case N-498-4 require a pressure test of the entire Class 1 System boundary, once every 10-years, at nominal operating pressure, accompanied by visual examination (VT-2) after a hold time of 10-minutes for non-insulated and 4-hours for insulated components.
Reason for Recluest This 2" CVCS auxiliary Pressurizer (PRZR) Spray Line piping segment cannot be pressurized in accordance with the ASME Section XI requirements without undue hardship.
Proposed Alternative and Basis for Use FNP proposes VT-2 examination of this piping segment at potentially zero nominal pressure after the remainder of the Reactor Coolant System (RCS) has been at nominal operating pressure for at least 4-hours.
From the CVCS Regenerative Heat Exchanger, a 2" branch line goes to AOV Q2E21V245, on to 2" check valve Q2E21V 109, then through a 2" by 4" pipe expander, then to the auxiliary PRZR spray nozzle. This flow path is used to provide an alternative PRZR pressure control method during off normal conditions, such as when no Reactor Coolant Pumps are running. CVCS is continuously inservice during normal plant operation, therefore the piping up to valve Q2E21V245 is at a pressure 2 RCS pressure.
RCS pressure is controlled by the PRZR which is at 2 RCS pressure during normal operation. However, the 2" pipe segment between AOV Q2E21V245 and check valve Q2E21V109 cannot be pressurized without impacting proper RCS pressure control.
The only practicable way to pressurize the piping segment between check valve Q2E21V109 and AOV Q2E21V245 to nominal RCS pressure would require disassembly of check valve Q2E21V109, removal of the valve disc, reassembly of check valve, pressurize RCS, hold for 4-hours and then perform the VT-2
Enclosure Page 4 of 4 Relief Request RR-60, Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii) examination. This method would provide compliance with the Code and Code Case, but results in the following hardships.
- 1. Valve Q2E21V109 is located inside the containment shield wall in close proximity to RCS piping and the PRZR. This area is considered a High Radiation Area and maintaining personnel dose for ALARA would be of concern. Disassembly of this valve would subject personnel not only to general radiation dose rates but also very high radiation doses once the valve is opened. Once opened, personnel contamination is also of concern since this valve provides a RCS boundary.
- 2. Unit would not be able to progress directly from pressure test completion into plant startup due to the required RCS depressurization and cooldown to enable disassembly1reassembly of check valve Q2E21V109 prior to startup. It is estimated that this iteration would require 2 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (based on; cooldown to c 200°F (Mode 5), degas RCS (remove hydrogen), depressurize RCS, disassemble valve Q2E21V109 and re-install disc, reassemble valve, fill and vent the RCS, and then heat-up and pressurize to Normal Operating Temperature and Pressure). Valve Q2E21V109 would then require a post reassembly VT-2 examination at normal operating pressure. All this would be critical path time which would extend the refueling outage duration.
- 3. Check valve disassemblylreassembly increases the opportunity for human error and mechanical damage resulting in unacceptable RCS pressure boundary integrity and valve operation.
- 4. Q2E21V109 is a Y-Type, socket welded, check valve with a seal weld at the cover to body connection. Disassembly requires grinding away the seal weld which creates additional opportunities for valve damage. Reassembly requires machining the cover to body surface area to allow for a quality seal weld to prevent leakage during operation.
Therefore, compliance with ASME Section XI Code and Code Case N-498-4 requirements results in hardship or unusual difficulty without a compensating increase in the level of quality and safety and this proposed alternative is warranted per 10CFR50.55a(a)(3)(ii).
Duration of Proposed Alternative One time, end of 3rd10-year IS1 Interval, ending November 30,2007.