NL-17-0348, Proposed Alternative FNP-ISI-ALT-05-01 in Accordance with 10CFR50.55a(z)(1) to Utilize ASME Code Case N-854

Proposed Alternative FNP-ISI-ALT-05-01 in Accordance with 10CFR50.55a(z)(1) to Utilize ASME Code Case N-854

ML17221A330
Person / Time
Site:	Farley
Issue date:	08/09/2017
From:	Wheat J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-0348
Download: ML17221A330 (5)

Text

-A Southern Nuclear Justin T. Wheat Nuclear Licensing Manager 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5998 tel AUG 0 9 2017 205 992 7601 fax jtwheat@ southernco.com Docket Nos.: 50-348 NL-17-0348 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 Proposed Alternative FNP-ISI-ALT-05-01 in Accordance with 10 CFR 50.55a(z)(1) to Utilize ASME Code Case N-854 Ladies and Gentlemen:

Pursuant to 10 CFR 50.55a(z)(1 ), Southern Nuclear Operating Company (SNC) hereby requests Nuclear Regulatory Commission (NRC) approval of Alternative FNP-ISI-ALT-05-01, for the use of American Society of Mechanical Engineers (ASME) Code Case N-854, for Farley Nuclear Plant (FNP) Units 1 and 2. This alternative is applicable to the Fifth lnservice Inspection Interval, which will start on December 1, 2017. This proposed alternative request removes hold times for Class 2 and 3 components directly connected to a Class 1 system that are pressurized as part of the Class 1 system leakage test. SNC believes that use of Code Case N-854 provides an acceptable level of quality and safety.

To support planning and preparation needed for the Spring 2018 outage, SNC requests that the NRC approve the proposed alternative for FNP Units 1 and 2 by March 1, 2018.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.

Respectfully submitted, Justin Wheat Nuclear Licensing Manager JTW/PDB/Iac

Enclosure:

Proposed Alternative FNP-ISI-ALT-05-01, Version 1.0 Cc: Regional Administrator, Region II NRR Project Manager- Farley Nuclear Plant Senior Resident Inspector- Farley Nuclear Plant RTYPE: CFA04.054

Joseph M. Farley Nuclear Plant- Units 1 and 2 Proposed Alternative FNP-ISI-ALT-05-01 in Accordance with 10 CFR 50.55a{z){1) to Utilize ASME Code Case N-854 Enclosure Proposed Alternative FNP-ISI-ALT-05-01, Version 1.0

Proposed Alternative FNP-ISI-ALT-05-01, Version 1.0 In Accordance with 10 CFR 50.55a(z){1)

Plant Site-Unit:

Joseph M. Farley Nuclear Plant (FNP) - Units 1 & 2 Interval Dates:

Fifth lnservice Inspection (lSI) Interval- December 1, 2017 through November 30, 2027 Requested Date for Approval:

Approval is requested by March 1, 2018.

ASME Code Components Affected:

ASME Code Class 2 and 3 components connected directly to a Class 1 system that are pressurized as part of the Class 1 system leakage test.

Applicable Code Edition and Addenda

ASME Section XI, "Rules for lnservice Inspection of Nuclear Power Plant components,"

2007 Edition with the 2008 Addenda (Code) is the applicable Code edition and addenda for the fifth lSI interval.

Applicable Code Requirement

ASME Section XI, 2007 Edition through 2008 Addenda, IWA-5213(a) specifies the test condition holding time after pressurization to test conditions before the visual examinations commence for system pressure tests.

Reason for Request

The Code test conditions for hold time requirements during system leakage tests are based on the component classifications of ASME Section XI Code Class 1, 2, or 3 components and essentially whether the system is normally inservice. The actual hold time requirements for the system leakage tests for each Class of components are required in accordance with IWA-5213(a).

Specifically, for Class 1 components there is no hold time after attaining test pressure.

IWA-5213(a)(1 ): "For Class 1 components (IWB-2500-1 Examination Category 8-P), no holding time is required after attaining test pressure."

For Class 2 or 3 components, the hold times are 10 minutes or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> depending on specific conditions in IWA-5213(a)(2) and (a)(3):

IWA-5213(a)(2): "For Class 2 (IWC-2500-1, Examination Category C-H) and Class 3 (IWD-2500-1, Examination Category D-B) components not required to operate during normal plant operation, a 10 min holding time is required after attaining test pressure."

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Proposed Alternative FNP-151-ALT-05-01, Version 1.0 In Accordance with 10 CFR 50.55a(z)(1)

IWA-5213(a)(3): "For Class 2 (IWC-2500- 1, Examination Category C-H) and Class 3 (IWD-2500-1, Examination Category D-B) components required to operate during normal plant operation, no holding time is required, provided the system has been in operation for at least 4 hr for insulated components or 10 min for noninsulated components."

Proposed Alternative:

Pursuant to 10 CFR 50.55a(z)(1 ), Acceptable Level of quality and safety, the use of ASME Code Case N-854, "Alternative Pressure Testing Requirements for Class 2 and 3 Components Connected to the Class 1 Boundary Section XI, Division 1 ," (Reference 1) is being requested for use by Southern Nuclear Operating Company (SNC) since this Case has not yet been included in Regulatory Guide 1.147 Rev. 17 (Reference 2}. Use of Code Case N-854 does not change any pressure testing requirements except for eliminating the hold time for Class 2 and 3 components connected directly to Class 1 components that are under Class 1 pressure during the Class 1 system leakage tests that are performed during plant startup following each refueling outage at FNP Units 1 and 2.

Basis for Use Class 1 Hold Time for Class 2 and 3 Components Under Class 1 Pressure The basis for the Class 1 no hold time requirement in IWA-5213(a)(1) is centered on the fact that it takes (several hours) increasing the temperature and pressure to reach the required pressure corresponding to 100% rated reactor power in IWB-5221 to perform the system leakage test. This time period either exceeds or is more restrictive than the required 10 minute or 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time for Class 2 or 3 components in IWA-5213(a).

When Class 1 components are connected directly to Class 2 or 3 components (for example, by having a restricting orifice) the Class 1 boundary interface to Class 2 or 3 components are pressurized and examined to Class 1 pressure during the system leakage test. The Class 2 or 3 hold time requirement is not currently addressed for this design configuration in IWA-5213(a) of the ASME Code Section XI, 2007 Edition through the 2008 Addenda. The hold time requirements for these components are now included as an alternative in Code Case N-854 that may be used upon NRC authorization.

At FNP, the components affected by this request are Class 2 pipes and valves used for vents and drains with a design configuration where a flow restrictor serves as the boundary interface between the Class 1 and Class 2 components and where the Class 2 components are under Class 1 pressure during normal operation and examined during the Class 1 system leakage test under Class 1 pressure. This test is performed following each refueling outage during plant startup. An example of this design configuration are sample line connections to the reactor coolant system (RCS) piping that contain a 3/8" orifice opening restricting flow from the RCS to a loss that can be made up by normal makeup.

Due to this configuration, the sample lines downstream of the orifice are not E1-2

Proposed Alternative FNP-151-ALT-05-01, Version 1.0 In Accordance with 10 CFR 50.55a(z)(1) required to be Class 1. However, this section of sample lines may be examined as part of the Class 1 system leakage test under Class 1 pressure.

Conclusion SNC has determined that this proposed alternative request per 10 CFR 50.55a(z)(1) to use Code Case N-854 for the fifth inspection interval at FNP, Units 1 and 2, addresses the needed criteria for meeting the specific no hold time requirement that is associated with the examinations to be conducted during the Class 1 system leakage test on specifically designed Class 2 components that are directly connected to Class 1 components. Since the requirement for no hold time on Class 2 and 3 components as permitted in Code Case N-854 results in the Class 2 components being tested with the same hold time requirement as the associated Class 1 component, SNC believes that use of Code Case N-854 provides an acceptable level of quality and safety. Therefore, SNC is seeking approval to use Code Case N-854 with authorization of this request for the fifth inspection interval at FNP, Units 1 and 2.

Duration of Proposed Alternative:

The Fifth lSI Interval.

Precedents:

None.

References:

1. ASME Code Case N-854, "Alternative Pressure Testing Requirements for Class 2 and 3 Components Connected to the Class 1 Boundary Section XI, Division 1," dated: April 15, 2015

2. USNRC Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 17, dated: August 2014 Status:

Under NRC Review.

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