NL-15-0336, License Renewal Commitment Item 11
| ML15173A158 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/22/2015 |
| From: | Pierce C Southern Co, Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-15-0336 | |
| Download: ML15173A158 (2) | |
Text
Charles R. Pierce Regulatory Affairs Director JUN 2 2 2015 Docket Nos.: 50-348 50-364 Southern Nuclear Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 SOUTHERN A COMPANY NL-15-0336 Joseph M. Farley Nuclear Plant-Units 1 and 2 License Renewal Commitment Item 11 Ladies and Gentlemen:
Commitment Item No. 11 of NUREG-1825, Safety Evaluation Report Related to the License Renewal of the Joseph M. Farley Nuclear Plant, Units 1 and 2, requires the submission of an inspection plan for the NiCrFe Component Assessment Program (now called the Nickel Alloy Program) at least 24 months prior to entering the periods of extended operation for the Farley Nuclear Plant (FNP) units. The period of extended operation for FNp, Unit 1 begins on June 25, 2017. Since establishing this commitment, the industry and Nuclear Regulatory Commission (NRC) have adopted a strategy to proceed with a generic approach through the consensus process provided by the American Society of Mechanical Engineers (ASME) Code Section XI. Thus, the nickel-based alloy inspection program is based on industry consensus prescribed in ASME Code Cases N-722-1, N-729-1 and N-770-1 as mandated and conditioned in 1 0 CFR 50.55a.
This Nickel Alloy pressure boundary program has been fully incorporated into the FNP lnservice Inspection program, is being conducted accordingly and has undergone periodic review by Region II inspectors. Southern Nuclear Operating Company, Inc. (SNC) believes that there is not a need for additional staff review and approval of the technical details and/or basis for the FNP Units 1 and 2 plant-specific inspection plans because the technical basis for the scope, periodicity, nondestructive examination requirements, and acceptance criteria are all now generically approved and mandated via rulemaking.
When the FNP license renewal application was submitted, NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 0 was the approved version. Since then, more recent versions of the GALL and the Aging Management Program (AMP) for management of nickel alloys (now XI.M11 B) have been issued. The most recent GALL and AMP requirements have been reviewed, and FNP is in compliance. A FSAR chapter 18 update will be processed to reflect the incorporation of all the necessary aging management items for nickel chrome alloys into the lSI AMP.
U.S. Nuclear Regulatory Commission NL-15-0336 Page 2 Additionally, FNP has compared its plant-specific configuration in response to recent industry experience where certain nickel alloy branch connections in the reactor coolant system (RCS) were excluded from the scope of Code Case N-770-1 examination. SNC determined that no similar configurations exist in either FNP RCS. Therefore, the only alloy locations not directly under the augmented requirements of one of the mandated code cases are the internal reactor vessel lug attachment welds, which are managed per ASME Code Section XI Category B-N-2 and augmented by an owner-elected additional measure of visual VT -1.
SNC believes that this notification effectively fulfills the intent of commitment item 11 contained in NUREG-1825, which was established prior to staff rulemaking on the generic ASME Code Case requirements.
This letter contains no new NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.
Sincerely, c.fi ft...
C.R. Pierce Regulatory Affairs Director CRP/JMC/Iac cc:
Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President-Farley Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. D. R. Madison, Vice President-Fleet Operations Mr. B. J. Adams, Vice President-Engineering Ms. B. L. Taylor, Regulatory Affairs Manager-Farley RTYPE: CFA04.054 U.S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager-Farley Mr. P. K. Niebaum, Senior Resident Inspector-Farley