NL-07-1760, J. M. Farley, Units 1 and 2 - Relief Request Q1/2B13-RR-V-2, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

J. M. Farley, Units 1 and 2 - Relief Request Q1/2B13-RR-V-2, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

ML072600203
Person / Time
Site:	Hope Creek, Farley
Issue date:	09/17/2007
From:	George B Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-07-1760, Q1/2B13-RR-V-2
Download: ML072600203 (7)

Text

Southern Nuclear Operating Company, Inc.

Post Off ice Box 1295 Birmingham, Alabama 35201-1295 SOUTHERNk \

September 17, 2007 COMPANY Energy t o Serve Your WorldsM Docket Nos.: 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Relief Request Q112B13-RR-V-2 Proposed Alternative In ~ccordancewith 10 CFR 50.55a(a)(3Mi)

Ladies and Gentlemen:

Pursuant to 10 CFR 50.55a(a)(3)(i), Southern Nuclear Operating Company (SNC) hereby requests NRC approval of proposed alternative Q112B13-RR-V-2 This alternative is for the Farley Nuclear Plant (FNP) Unit 1 3'* 10-Year IST Interval and for Unit 2 until the end of the next Unit 2 refueling outage scheduled to begin October 18, 2008. The details of the request for alternative are contained in the enclosure to this letter.

Approval is requested to support the Unit 2 outage at FNP beginning October 18, 2008.

This letter contains no NRC commitments. If you have any questions, please advise.

<qQ+B. J. George Manager, Nuclear Licensing

U. S. Nuclear Regulatory Commission NL-07-1760 Page 2

Enclosure:

Relief Request Q 112B13-RR-V-2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i) cc: Southern Nuclear O~eratincrCom~anv Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. H. Jones, Vice President - Engineering RType: CFA04.054; LC# 14647 U. S. Nuclear Reaulatory 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 Qll2B13-RR-V-2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

Enclosure Joseph M. Farley Nuclear Plant - Units 1 and 2 Relief Request Q112B13-RR-V-2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

PLANTIUNIT: Joseph M. Farley Nuclear Plant (FNP) IUnits 1 and 2 INTERVAL: 3' Interval beginning December 1,1997 and ending November 30, 2007 COMPONENTS Pressurizer Safety Valves (PSVs)

AFFECTED: Serial Numbers: N56963-01-0003, N56963-01-0005 and N56963 0013 CODE EDITION ASME OM Code-1990 Edition, Mandatory Appendix I AND ADDENDA:

REQUIREMENTS: Excerpt from ASME OM Code, 1990 Edition, Appendix I 1 1.3.3 Test Frequencies, Class 1 Pressure Relief Valves (a) Initial 5 year Period. Pressure relief valves.. .[not initial period at FNP]

(b) Subsequent 5 year Periods. All valves of each type and manufacture shall be tested within each subsequent 5 year period with a minimum of 20% of the valves tested within any 24 months. This 20% shall be previously untested valves, if they exist.

(c) Replacement With Pretested Valves (1) Owners that satisfy testing requirements by installing a partial complement of pretested valves to replace those that had been in service in accordance with test schedule per para. I 1.3.3(a) shall set pressure test the valves which were removed prior to the resumption of electric power generation.

REASON FOR During review of INPO Operating Experience Report OE25262 dated REQUEST: August 3, 2007, FNP ini,tiateda review of the testing history for Class 1 Pressure Relief Valves. FNP realized that the existing surveillance procedure calculated the next "test due date" based on "install-to-test" instead of "test-to-test" dates. FNP focused on valves which were currently installed on both units and identified two PSVs that currently exceed the maximum 5-year test frequency and one valve that will exceed the frequency on September 22, 2007. Provided below is a list of the subject valves.

LAST DATE NEXT TEST TEST TO VALVE SIN -UNIT TESTED INSWED SCHEDULED TEST TIME N56963-01-0003 1 03/05/01 1R18 (04103) 1R21 (10107) = 79 months N56963-01-0005 2 10111/01 2R16 (04104) 2R19 (10108) = 84 months N56963-01-0013 2 09/22/02 2R17 (11/05) 2R19 (10108) = 73 months

Enclosure Page 2 of 4 Relief Request Q 112813-RR-V-2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

PROPOSED Alternative ALTERNATIVE AND BASIS: FNP will replace the Unit 1 PSV with a pretested valve during the fall refueling outage which is scheduled to begin September 29, 2007.

Test-to-test time for this valve will be approximately 79 months.

FNP will replace both Unit 2 PSVs with pretested valves during the next refueling outage scheduled to begin October 18, 2008. Test-to-test time for these valves will be approximately 73 months and 84 months respectively.

Additionally, FNP will revise the applicable surveillance procedures and tracking mechanism to ensure that the maximum test-to-test interval for the PSVs will be 5 5 years concurrent with the 4'h 10-Year IST Interval which begins December 1, 2007.

There are three PSVs installed on each unit at FNP. ASME OM Code, Appendix I,paragraph I 1.3.3(c)(l), which allows Owners to satisfy testing requirements by installing a partial complement of pretested valves, is utilized at FNP. Therefore, FNP maintains three pretested spare valves as replacements. One of the three installed valves is removed each outage for testing and a pretested spare is installed in its place. The removed valve is tested prior to the unit returning to power operation to determine if additional valves are required to be tested.

Each valve is visually examined, seat leakage and set-pressure tested in the "as-found" condition. If any of the examinations or tests is unsatisfactory, then the valve is repaired as necessary and retested.

All maintenance or refurbishment is implemented as an ASME Section XI repair activity which includes pre-established visual examination and documentation requirements. If additional testing is required, then the remaining two installed valves are removed and the other two spares are installed in their place. All valves are tracked by unit, installation location and serial number.

If the removed valve meets all the testing criteria, then it is returned from the test facility and stored on site for installation during a subsequent outage. Storage and handling of PSVs are performed in accordance with procedures developed to comply with the requirements of ANSI N45.2.2-1972.

Review of test data for the past 10 years indicated that the PSVs have an excellent reliability rating. During this 10-year period, there were no set point failures as a result of exceeding the 3% OM Code allowable acceptance criteria. In fact, the "as-found" set point for greater than 50% of the PSVs were within 1% of the nameplate set pressure.

Even though the "test-to-test" date for three PSVs will or has exceeded the 5-year code interval, no PSVs will have an "installed-to-test" interval which will exceed the &year interval.

Enclosure Page 3 of 4 Relief Request Q112813-RR-V-2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

A risk analysis was performed to determine the risk impact due to the extended surveillances. The data used to qualify the results included an additional 19 months for SIN N56963-01-0003, an additional 24 months for SIN N56963-01-0005 and an additional 13 months for SIN N56963-01-0013to the 5-year surveillance period. The results show that, for all cases, the Incremental Conditional Core Damage Probability (ICCDP) is less than 1.OE-06 and the lncremental Conditional Large Early Release Probability (ICLERP) is less than 1.OE-07, both of which are acceptable per Regulatory Guide (RG) 1.174. Therefore, the calculated increases in CDF and LERF are very small as defined by RG 1.174.

Therefore, based upon 10 years of test history and risk analysis, this one time relief request provides an acceptable level of quality and safety to that of the applicable Code requirement. This alternative to the ASME OM Code, Appendix I requirement should be granted in accordance with 10 CFR 50.55a(a)(3)(i).

DLIRATION: Remainder of 3d 10-Year IST Interval (until Noverr~ber30,2007) for Unit 1 and until the end of the next Unit 2 refueling outage currently scheduled to begin October 18, 2008.

PRECEDENTS: 1. In Reference 1, Exelon submitted a relief request seeking NRC approval for exceeding the ASME OM Code 5-year test interval.

This submittal is still under review by the NRC.

2. In Reference 2, the NRC approved a relief request for Susquehanna Steam Electric Station, Units 1 and 2 to extend the MSSV test interval for individual valves to 6 years for the 3'C'10-year IST interval.

3. In Reference 3, the NRC approved a relief request from Nine Mile Point, Unit 2 to extend the MSSV test interval for individual valves to three refueling outages (approximately 6 years) for the 3'C'10-year IST interval.

4. In Reference 2 and 3, the NRC approved an "installed-to-tesf' interval of at least 6 years. In contrast, FNP's request is for a one time maximum "installed-to-test" interval of approximately 4 years and 6 months.

REFERENCES:

1. Letter from Patrick R. Simpson (Exelon Nuclear) to U.S. Nuclear Regulatory Commission, "Dresden Nuclear Power Station, Unit 2 Renewed Facility Operating License No. DPR-19, NRC Docket No.

50-237, Request for Relief from ASME OM Code 5-year Test Interval for Two Main Steam Safety Valves (Relief Request RV-02B)," dated July 3,2007.

2. Letter from R. J. Laufer (USNRC) to 6. L. Shriver (SSES),

"Susquehanna Steam Electric Station Unit 1 and 2 - Third 10-Year Interval lnservice Testing (IST) Program Plans," dated March 10, 2005.

3. Letter from M. Banerjee (USNRC) to J. H. Mueller (NMPC), "Nine Mile Point Nuclear Power Station, Unit No. 2 - Alternative to

Enclosure Page 4 of 4 Relief Request Q112B13-RR-V-2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code regarding Inservice Testing of Main Steam SafetyIRelief Valves (TAC No. MB02090),"dated April 17,2001.

STATUS: Submitted for NRC review.