NL-08-1370, Response to Request for Additional Information Regarding FNP-ISI-ALT-01, Version 1.0, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
| ML082560828 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/12/2008 |
| From: | Ajluni M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| FNP-ISI-ALT-01, Ver 1.0, NL-08-1370 | |
| Download: ML082560828 (4) | |
Text
Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, Alabama 35201-1295 Tel 205992.5000 SOUTHERN'\\
September 12, 2008 COMPANY Energy to Serve Your WorldS" Docket Nos.: 50-364 NL-08-1370 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Unit 2 Response to Request for Additional Information Regarding FNP-ISI-ALT-01, Version 1.0, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
Ladies and Gentlemen:
In letter dated October 8,2007, and supplemented by Southern Nuclear Operating Company (SNC) letter dated June 27, 2008, SNC requested NRC approval of proposed requested Alternative FNP-ISI-ALT-01 to change the Joseph M. Farley Nuclear Plant (FNP) Unit 2 lSI interval dates to correspond to the FNP Unit 1 lSI interval dates. The duration of this alternative is throughout the licensed life of FNP-2.
Approval was requested by September 14, 2008, to support 4th interval examinations to be performed during the Fall 2008 Outage at FNP-2.
On August 28, 2008 a telecon was held with the NRC Staff to discuss this request. The SNC response to the requested information is provided in the Enclosure to this letter. Proposed FNP-ISI-ALT-02 and FNP-ISI-ALT-03 submitted to the NRC on October 8,2007 are not impacted by this response for FNP-ISI-ALT-01.
This letter contains no NRC commitments.
If you have any questions, please advise.
Sincerely,
~~r M. J. Ajluni Manager, Nuclear Licensing MJAlBDM/phr
- u. S. Nuclear Regulatory Commission NL-08-1370 Page 2
Enclosure:
Response to Request for Additional Information Regarding FNP-ISI-ALT-01 cc:
Southern Nuclear Operating Company 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# 14830 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. K. D. Feintuch, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley
Joseph M. Farley Nuclear Plant - Unit 2 Response to Request for Additional Information Regarding FNP-ISI-ALT-01, Version 1.0, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
Enclosure Response to Request for Additional Information Regarding FNP-ISI-ALT-01
Enclosure Response to Request for Additional Information Regarding FNP-ISI-ALT-01 NRC Question Discuss what FNP is doing to satisfy the requirements for the third interval of their risk-informed inservice inspection (RI-ISI) program for ASME Code category B-F, B-J, C-F-1, C-F-2 piping for Unit 2. Also, please confirm that a RI-ISI renewal application for the fourth interval has been submitted if SNC intends to continue to implement a RI-ISI program.
SNC Response (Note: Both Unit 1 and Unit 2 will be discussed in this response to provide a more comprehensive answer).
FNP-1 is in the fourth lSI interval because the third lSI interval for FNP-1 expired by 10 CFR 50.55a regulations on November 30, 2007 and the fourth lSI interval began on December 1, 2007. By 10 CFR 50.55a regulations, the third lSI interval for FNP Unit 2 is scheduled to continue through July 30, 2011 and the fourth lSI interval is scheduled to begin on July 31, 2011. SNC submitted, and expected approval of, FNP-ISI-ALT-01 to administratively align the Unit 2 fourth interval dates to coincide with the FNP Unit 1 dates. Approval was anticipated since the same request had been granted for Vogtle, Hatch, and other plants. Anticipating the NRC approval of the re-alignment, lSI plans, procedures, NDE procedures, repair/replacement procedures, etc. were developed and put in place for both units using the 200'1 Edition of Section XI with Addenda through 2003 for the fourth lSI interval.
Based on anticipated approval of FNP-ISI-ALT-01, the third interval for Unit 2 would have expired on November 30, 2007; therefore, Unit 2 would no longer have an NRC-approved RI-ISI program. Also assuming approval of FNP-ISI-ALT-01,Unit 2 would currently be in the first period of the fourth lSI interval and there have been no refueling outages to date. A risk informed lSI submittal for Farley Units 1 and 2, based on Code Case N-716, will be submitted to the NRC in 2009. This submittal will be made at least one year prior to the start of the Unit 1 1R23 outage which is currently scheduled for October 2010. This will allow the NRC sufficient time to approve the submittal. This outage is the key outage for approval because it is the last outage of the first period for Unit 1 while Unit 2 has a later outage by Section XI Code rules.
Because there is not a NRC-approved Risk-Informed lSI submittal, a sufficient number of welds will be scheduled and examined for both units such that Section XI Category B-F, B-J, C-F-1, and C-F-2 examination requirements for a conventional lSI program will be met for the first period of the fourth lSI interval. It should be noted that the welds to be examined per the proposed Code Case N-716 submittal are a subset of Section XI Category B-F, B-J, C-F-1, and C-F-2 welds. Therefore,Section XI Category B-F, B-J, C-F-1, and C-F-2 welds that are also in the scope of Code Case N-716 will be scheduled for examination, when practical, during the first period of the fourth lSI interval. The proposed Risk-Informed lSI program submittal to the NRC will state SNC's intention to take credit for the appropriate examinations in meeting Code Case N-716 requirements once the NRC has approved the risk-informed submittal.
On June 27,2008, SNC submitted a response to the NRC request for additional information pertaining to FNP-ISI-ALT-01 (reference SNC letter NL-08-0884). The information supplied for Category R-A (risk-informed lSI) in that response should be replaced by the above information.
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