ML14148A492

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ISI Program Alternative FNP-ISI-ALT-16. Version 1
ML14148A492
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 05/28/2014
From: Pierce C R
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-07-15
Download: ML14148A492 (16)
v • d • e


Text

{{#Wiki_filter:Charles R.Pierce Southern Nuclear Regulatory Affairs Direclor Operating Company, Inc.40 Inverness Center Parkway Post Office Box 1295 Birmingtiam, Aiat}ania 35201 Tel 2D5.992.787Z Fax 205.992.7601 SOUTHERN.^ COMPANY May 28, 2014 Docket Nos.: 50-348 NL-14-0715 50-364U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington,D.C.20555-0001 Joseph M.Farley Nuclear Plant-Units1 and 2 ISI Program Alternative FNP-ISI-ALT-16. Version 1 Ladies and Gentlemen; In accordance with the provisionsof10CFR 50.55a(a)(3)(ii), Southern Nuclear Operating Company (SNC)hereby requests NRC approvalofan American Society of Mechanical Engineers (ASME)Section XI code alternative to address the leakage examination for the Class 2 reactor vessel flangeleak-offlinesforbothUnits1 and2of the Joseph M.Farley Nuclear Plant (Farley), The System Leakage Test of Class 2 pressure retaining componentsiscitedin Table IWC-2500-1, Examination CategoryC-H,ItemNo. C7,10, and requiredtobe performed during eachinspectionperiod.Table lWC-2500-1 requires that system leakage tests be conductedata pressure not less than the pressure correspondingto100%rated reactor pow/er in accordance with IWC-5221.This requested alternative (FNP-ISI-ALT-16, Version 1,0)is necessitatedbythe impracticality of conformance to requirements of Table IWC-2500-1oftheASME Section XI Code.The proposed alternative examination for Class 2 reactor vesselflangeleak-off piping pressure test at Farley is predicated on the ASME Code CaseN-805which hasyettobe approved by the NRC.However,theNRC has previously determined that similar requests from the commercial nuclear industry are acceptable for these circumstances. Enclosedisa detailed discussion of the need and justification for the use of an alternate approach for the Class 2 leakage testing of the subject vessel flange leak-off lines needed for conformance to IWC-5221 of the Code.In order to support restart of FarleyUnit2followingthe 2R23 Refueling Outage, expedited approval of the proposed alternative is requested by October 1, 2014. U.S.NuclearRegulatoryCommission NL-14-0715 Page 2Thisletter containsnoNRCcommitments. If you have any questions, please contact Ken McElroy at (205)992-7369.Sincerely,^C.R.Pierce Regulatory Affairs Director CRP/TWS/lac

Enclosure:

ProposedAlternativein accordance with 10 CFR 50.55a(a)(3)(ii) cc: Southern Nuclear Operating CompanyMr.S.E,Kuczynski, Chairman, President&CEOMr.D.G.Bost, Executive Vice President&Chief Nuclear OfficerMs.C.A.Gayheart, Vice President-FarleyMr.B.L.Ivey, Vice President-Regulatory AffairsMr.D.R.Madison,Vice President-Fleet OperationsMr.B.J.Adams, Vice President-Engineering RTYPE: CFA04.054 U.S.Nuclear Regulatory CommissionMr.V.M.McCree, Regional AdministratorMr.S.A.Williams,NRR Project Manager-Farley Mr.P.K.Niebaum, Senior Resident Inspector-Farley Mr.J.R.Sowa, Resident Inspector-Farley ENCLOSURE JOSEPH M.FARLEY NUCLEAR PLANTISIPROGRAM ALTERNATIVE FNP-ISI-ALT-16,VERSION1 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10CFR50.55a(a)(3)(ii) SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10CFR50.55a(a)(3)(ii) Plant Site-Unit: Joseph M.Farley Nuclear Plant(FNP)-Units1 and 2 Interval-Interval Dates: 4"" IS!-December 1, 2007 through November 30, 2017 Requested Date for Approval and Basis:Approvalis requested by October 1,2014topermit performance of the proposed alternative pressure test during the 23rd Refueling OutageofFNPUnit2.This proposed alternative will remain applicable through the remainder of the fourth 181 Interval.ASME Code Components Affected: FNP Units: Unit 1 and Unit 2 ASI^E Code Class: Code Class 2

References:

ASME Section XI, Table IWC-2500-1 and IWC-5220 Examination Category: C-H (All Pressure Retaining Components) Item Number: C7.10 Component: Reactor Pressure Vessel Flange Leak-off Piping with NPS3/8",3/4", and 1"

Description:

3/8"Tubingis A-213 Gr 304 and has a minimum wall thickness of 0.065" Design Pressure is 2485psigat 650T 3/4" and 1" Pipe is SA-376 Type 304 or 316 and Sch.160 Design Pressure is 2485psigat 650T Applicable Code Edition and Addenda: ASME SectionXi,2001Edition through the 2003 Addenda Applicable Code Requirements: System Leakage Test of Class 2 pressure retaining components per Table IWC-2500-1, Examination CategoryC-H(ItemNo. C7.10)are to occur each inspection period.Paragraph IWC-5221 indicates that system leakage tests are to be conducted at the system pressure obtained while the system, or portion of E-1 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(li)thesystem,isinservice performingitsnormaloperating functionoratthe system pressure developedduringa test conductedtoverify system operability. Per IWC-5222(a), the pressure retainingboundaryincludesthe portionofthesystemrequiredtooperateorsupportthesafety functionuptoand including thefirstnormally closed valve.Background and Reason for Request: SouthernNuclearrecently became aware of enforcement actions associated with failure of licensees to performoradequately performsystemleakage testsonthereactorvesselflange leak-off pipingata pressure lessthanthatrequiredbyASMESection XI, Subarticle IWC-5220.TheNRGprovidedadditionalinformationregarding these instances in Information Notice 2014-02 (IN 2014-02),FailuretoProperly Test Reactor Vessel Flange Leak-off Lines, dated February 25,2014,withthe expectation that licenseeswouldreview theinformationfor applicabilitytotheirfacilitiesand consider actions, as appropriate,toavoidsimilarproblems. SouthernNuclearOperating Company (SNO)performedareviewoftheapplicableoperational experience(OE)and IN 2014-02,alongwiththe designoftheFNP reactor vessel headflangeleak-off piping and determined thatFNPis also subject to the same limitations that resulted in the instances cited in the OE and IN 2014-02.The FNP reactor vessel flangeleak-offpipingis part of the reactor coolant pressure boundary leak detection system and is designed in accordance with the requirementsofRegulatoryGuide1.45,Revision0, dated May 1973, asspecifiedinAppendix3AoftheFNPFinal SafetyAnalysisReport(FSAR). PerSection3AoftheFNPFSAR,the designfunctionofthe reactor coolant boundary leakage detection systemistoforewarnthe operatorofminor leakage that may developduringnormal operation;however,it does notperforma safeguardfunctionandisnotrequiredto operateduringoraftera seismic event.TheRPVflange and headatFNPUnits1 and 2 are sealedbytwohollow, metallic o-rings.The o-rings are madeofa silver-plated, nickel-chromlum-lron alloy andareinstalled betweenthemating surfacesofthereactor vessel flange and the closure head to prevent reactor coolant leakage between the vessel and the closure head.The o-rings are self-energized by reactor coolant pressure acting through the slots on the inside of the o-rings causing them to expand.Two grooves are machined into the reactor vessel flange for the o-rings and the corresponding retainerrings.Two additional grooves are machined into the closure head flange for the retainerrings,which are used to support theo-ringsduringtheirinstallation and removal.The o-rings are fastenedtothe closure headbya mechanical connectiontofacilitateremoval. Oneo-ringissufficientto create the seal but the second serves as a backup.Seal leakage detection is facilitated by meansoftwoleak-off connections: one between the inner and outer o-rings and one outboard the outero-ring.A E-2 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(M) manual isolation valve is installed on each leak-off connection to allow isolationoftheinneror outerleak-offlinesinthe unlikely eventoffailureof eitherofthe o-rings.Downstream of the manual valves, the leak-off lines connecttoa common line equippedwith:(1)an air-operatedisolationvalve (AOV)that allows operatorsinthemaincontrolroomtoisolate leakagefromthe reactor vesselflangeo-rings,and(2)a resistance temperature detector (RTD)that annunciates in themaincontrolroominthe event an elevated temperature is detectedintheleak-offpiping.Theleak-offpipingis locatedinsidethe biological shield and sectionsofthispiping are considered to be inaccessibleduetoits proximitytootherpiping and equipmentinthe vicinityoftheRPVflangethatareknowntobe inaccessible.AdepictionofthetypicalRPV headflangeleak-offpipingconfigurationis shown in Attachment 1.Asindicatedearlier, IWC-5221 states the system leakage testshallbe conductedatthe system pressure obtainedwhilethe system,orportionofthe system,isin serviceperformingitsnormal operatingfunctionoratthe system pressure developedduringa test conductedtoverify system operability. IWC-5222(a)indicatesthatthe pressure retaining boundaryincludesonly those portions of the system required to operate or support the safetyfunctionuptoandincludingthefirstnormally closedvalve(includinga safetyorreliefvalve)orvalve capable of automatic closure when the safetyfunctionis required.Theconfigurationofthe reactor vesselleak-offlinesis suchthatthepipingis not capable of being pressure testedatnormal reactor operating pressure(2235psig)without:(1) changestothe reactor vessel headflangeleak-off piping design,or(2)intentionallyfailingtheinner and outer RPV flange o-rings.Neitherof these options are considered viable and the basesforthis determination are provided below.Design changes to facilitate code compliant test In ordertoperforma Code compliant system leakage test, a design change would be requiredto:(1)installanew test connectiontowhicha pump skid could be attached,or(2)modify the existing branch connection to replace valve QV018.Valve QV018isa Kerotest valve and would havetobe replaced due to its design that precludes pressurizationinthe reverse direction. A Code compliant system leakage testwouldbeideally performedduringaroutinerefueling outage with the head removed in orderto:(1)allow any trappedairto escape through the holes on the vessel flange, and(2)to preclude equalization of the innero-ringby subjectingitto reverse pressurization. In order to perform the test with the head removed, threaded plugs would be required to be installedinboth the inner and outer taps to act as the pressure boundary.Use of plugsforthis purpose poses an additional concern associated with the potential introduction of foreign material into the vessel during installation. E-3 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ll) Althoughnotanideal lest condition, performing the test with the vessel headinstalledwouldrequirethataventbe addedtoallowanyairto escape whenpressurizingthereactor vessel flange leak-off piping.Theventline would likely needtobe added closetothe reactor vesselflangewhere dose rates are elevated(approximately230mrem/hr).Inaddition,the outertapwould need tobeplugged as wellsinceitisnotlocatedbetweentheinnerandouter o-ringandIsopentothe atmosphere.Assuch,the radiological exposurerequiredtoimplementthedesign changes necessary to facilitate pressuretestingofthe reactor vesselflangeleak-offpiping andtheactual performanceofthe pressure testrequiredbyASME Section XI, Subarticle IWC-5220 during each inspection period, representsahardshipwithouta compensating increaseinthelevelofqualityor safety beyond the proposed alternative described below.Intentionally failino the RPV flange o-rinosTheoptiontointentionallyfail theRPVflangeinnero-ringto establish normal operating pressure and temperature on theleak-offpipingisnot considered a viable option due to the increased dose that would result from the need to replace theinnero-ring. Replacementoftheinnero-ring following the pressure test requires removal and reinstallation of the reactor vessel head a secondtimeduring an outage, regardless as to whether the test was perfonnedatthe beginning of the outageoratthe endofthe outage.Thetypical dose associated with removal of the reactor vessel head and reinstallation based on previous FNP outages is approximately 3.8 REM.To meet the requirements of ASME Section XI, Subarticle IWC-5220, a second removal and reinstallation of the reactor vessel headwouldbe required and resultinan additional radiological doseof3.8REM.Removalofthe reactorvesselheadisatime andlaborintensiveactivitythat includes de-tensioning the RPV studs, disconnecting the various cables and head vent piping, and moving the RPV head to the RPV head stand.Removal and reinstallation of the RPV head a secondtimeduring the outage for the purpose of performing the pressure test requiredbyASME Section XI,SubarticleIWC-5220,resultsinan increased dose associated with the outage of approximately 3.8 REM and an increasedprobabilityof occurrenceofa heavyloaddrop accident.As such, compliance with the requirementsofASME Section XI, Subarticle IWC-5220 represents a hardshipwithouta compensating increase in thelevelofqualityor safety beyond the proposed alternative described below.Proposed Alternative and Basis for Use: In accordance with the provisions of 10 CFR 50.55a(a)(3)(ii), FNP proposes to examine the accessible portions of the Class 2 reactor vessel head flange leak-offpiping once per inspection period.Accessible portions of theleak-offpiping shall be examined using the VT-2 visual examination method and will be performed by certified VT-2 examiners. The test shall be conducted at ambient conditions after the refueling cavity has been floodedtoits minimum water level E-4 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(il) for refuelingoperationsof23ftabovethetopoftheRPVflangeforatleastfour(4)hours.Astatic pressureofapproximately 10psigis expectedtobe experienced at thetopof the RPV flangewithaminimumof23ftof borated water above.Inordertoeliminateanyairthatmaybe trappedinthepiping,FNP willflushtheleak-offpipingpriortoperformingthevisualexamination. There are no ventsnearthetopelevationofthepipingthatwouldallowventingofairinthepipe.Theonly locationtopermitventing without performingadesign modification is valve QV018,whichis locatedonthelowest sectionofthepiping.Thisvalveis located downstream of the two manual isolation valves and can be seen in Attachments 1,2 and3.To ensurethepipingis watersolidpriortothebeginningofthefourhourpressurizationholdtime,theblindflangeofthe QV018 valve willberemovedandthe QV018 valve will be opened allowing watertoflowfrom the piping.Theflowof water will be allowed for approximately five minutes.Once a steady stream of water is obtained, the QV018 valve will be closedandtheblindflange willbereinstalled.Thisevolutionis expected to purgethepipingofair since this will draw water from therefuelingcavitytoflushoutair.Inaddition,thetimeit takes to fill the refuelingcavityto23ftabovetheRPVflangeandthe flowofwaterthroughthepipe,coupledwithair'sbuoyancy, willallowairtoexitthepipingthroughthetop of theRPVflange,whichis opentothe atmosphere. With this process, thereisthepotentialforsmall pocketsofairtobe trapped in thepiping.However,ifathrough-wallindication exists at the samelocationofanair pocket, eventually theairwould leakout,allowing the water to leak out aswell.The preceding process for fillingtheRPVflangeleak-offpiping will help ensure thepipingis watersolidpriorto the four hour pressurizationholdtime.The Class2portionofpipingoriginatingfrom the reactor vessel flange andterminatingatthe last boundaryisolationvalve (AOV QV019)is required to be examined.An excerpt from theUnit1 andUnit2 Reactor Coolant System (RCS)P&ID is shown in Attachments 2 and 3, respectively, depicting the reactor vessel leak-off piping subject to the proposed alternate examination method.For segmentsofthelinethat are inaccessible for directVT-2visual inspection, examination will include inspection of the surrounding areas below thelinefor evidence of leakage as permitted by IWA-5241(b)of the ASME Section XI Code,2001Edition through 2003 Addenda.Itisnot clear which sections of theleak-offpiping are fully accessible for visual examination sincethispiping has never been examined individually; however, it has been included in the scope of the Class 1 leakage exam performed at the end of each refueling outage.Therefore, visual examination of the piping has been historically performed in some manner.There are approximately 99 linear feetofpipeonUnit1 and 137 linear feet ofpipeonUnit2 that makeupthisleak-offpiping. Approximately 66 linear feet of pipe onUnit1 and 98 linear feet of pipe onUnit2 are visually accessible, either E-5 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISt-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10CFR50.55a(a)(3)(ll) by direct or remote visual examination. The sectionsofpiping that is believed tobecompletely inaccessibleforvisualexaminationduringrefuelingcavityflood up conditions starts where the piping connectstothe reactor vessel and continues to wheretheprimaryshieldwall ends.This sectionofpipingis considered inaccessible for reasons: (1)accesstothispipingisnot available while therefuelingcavityisflooded(i.e., accesstothispipingisonly accessiblethroughthe"sandbox covers" which are in therefuelingcavity),(2)a sectionofpipingis located between the reactor vessel and theinteriorof the primary shieldwall,makingit inaccessible, and (3)the final section goes through the primary shieldwallwith theRGBhotlegpiping, through the restraint rings.Attachments 4 and 5 are providedtoillustrate the reactor vessel flange leak-offpipinglayout. Attachment 4 provides a sectionviewof the area under the"sandbox cover" that is considered inaccessible when the refueling cavity is flooded while Attachment 5 providesaplanviewofboth the accessible and inaccessible sections of the reactor vessel head flangeleak-offpiping system.AVT-2 visual examination of the accessible areas will be performed on the piping subjected to the static pressure from the head of water when the reactorcavityisfilledfor at least four hours.The proposed alternative examination will be perfonned within the frequency specified by table IWC-2500-1fora System Leakage Test (once each inspection period).As stated previously, the reactor vessel head flangeleak-offpiping does not perform a safeguard function and as such, is not requiredtofunctionfor safe shutdown of the plant or decay heat removal.The reactor vessel flange leak-offpipingis essentially a leakage collection/detection system andwouldonly function as a Class 2 pressure boundaryintheunlikely event that the inner o-ringfails, or for the outerlinein the event both the inner and outer o-rings fail, thereby pressurizing thepiping.If the inner and/or outer o-rings weretofail, the piping would be exposedtoa maximum pressure of 2235 psig, which is below the design pressure (2485 psig)for theleak-offpiping.If the flange leak-off piping weretofailin conjunctionwithfailureofboth the inner and outer reactor vessel head o-rings, leakage would be identified by either;*performance of an PCS water inventory balance in accordance with Technical Specification 3.4.13, PCS Operational Leakage, or*via the RCS Leakage Detection Instrumentation required by Technical Specification 3.4.15.Leakage from the reactor vessel head flangeleak-offpipingwould be considered unidentified leakage and, as such, belimitedtoa rateof1gallon per minute(GPM)by Technical Specification 3.4.13.Per Technical Specification Bases 3.4.13,1GPMof unidentified leakage is allowed as a reasonable minimum detectable amount that the containment air monitoring E-6 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-iSI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH10CFR 50.55a(a)(3)(li) and containment sumplevelmonitoring equipment can detectina reasonable time period.Accordingly, leal<age resulting from failureofthe inner o-ring andthereactor vessel head flange leak-off pipingwouldbemonitoredandresultin entry into LimitingConditionof Operation 3.4.13 should it exceed the1GPMallowablethresholdfor unidentifiedRCSleakage.Further,significant leakage duetoathrough-wallleakofthe reactor vessel flange leak-off piping wouldbeexpectedtoclearly exhibitboricacidresidueaccumulationthatwouldbediscernibleduringthe proposed alternate VT-2visualexaminationthat willbeperformed. Additionally,thestatic head developed with the leak detectionlinefilledwith water and the minimumallowabletime thelineis filledwithwater, as describedinthe proposed alternative, willallowforthedetectionof grossindicationsinthe piping.Basedonthe above,compliancewiththe requirementsofASME Section XI, Subarticle IWC-5220 representsahardshipor unusual difficulty that does notresultina compensating increaseinlevelofqualityor safety as described in 10CFR50.55a(a)(3)(ii).Useofthe proposedalternativeinlieuofthe pressure test requiredbyASME Section XI, Subarticle IWC-5220, willprovidean acceptablelevelofquality and safety based on theabilityto detect leakage from the vessel head flangeleak-offpiping and the correspondinglimitationsof Technical Specification 3.4.13 described above.Duration of Proposed Alternative: The alternative is requested for the remainder of the current Fourth Inservice InspectionInterval,which began December 1,2007 and is scheduled to end on November 30, 2017 for both Unit 1 and 2.Precedents: 1.Arkansas Nuclear One,Unit2, Fourth Inspection Interval Alternative, Request for Relief from American Society of Mechanical Engineers (ASME)Code, Section XI-RequestforRelief AN02-ISI-015, approved by the NRCina letter dated June 27,2013 (ADAMS Accession No.ML13161A241) 2.Callaway Plant,Unit1,Third Inspection Interval Alternative, ProposedAlternativetoASME Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines (Relief Request I3R-14, approved by theNRCina letter dated August 13, 2013 (ADAMS Accession No.ML13221A091) 3.Palo Verde Nuclear Generating Station, Units 1,2, and3,Third Inspection Interval Alternative, Request for Relief from the American Society of Mechanical Engineers (ASME)Code, Section XI, Reactor Vessel Head Flange Seal Leak DetectionPiping-Relief RequestNo.49, approved by E-7 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH10CFR50.55a(a)(3)(li) theNRGina letter datedApril4, 2013 (ADAMS Accession No.ML13085A254)4.DiabloCanyon,Units1and2,ThirdInspectionIntervalAlternative, RequestforApprovalofanAlternativeto the American Society of Mechanical Engineers(ASME)Boiler and Pressure Vessel Code Section XI Pressure Test Requirements for Class 1 Reactor Vessel FlangeLeakoffLines, approved by theNRCina letter dated September 12, 2013 (ADAMS Accession No.ML 13192A354) 5.Dresden,Units2and3, FifthInspectionIntervalAlternative, Request forRelieffor Exemption from Pressure Testing Reactor Pressure Vessel Head Flange SealLeakDetection System, approved by theNRCinaletter dated September 30, 2013 (ADAMS Accession No.ML 13258A003) 6.Vermont Yankee, Fourth InspectionIntervalAlternative,Alternativeto System Leakage Test for the Reactor Pressure Vessel Head Flange Leak-offLines, approved by theNRCina letter dated March 1, 2013 (ADAMS Accession No.ML13055A009)7.VogtleElectric GeneratingPlant,Units1 and2,Third Inspection Interval Alternative, Request for Alternative VEGP-ISI-ALT-10, Version 1, Regarding System Leakage Test of Reactor Pressure Vessel Flange Leak-offPiping, approved by theNRCina letter dated March 19, 2014 (ADAMS Accession No.ML14078A331)8.EdwinI.Hatch Nuclear Plant,Units1 and 2, Safety EvaluationofRelief Request HNP-ISI-ALT-18 for the Fourth 10-Year Inservice Inspection Interval, dated Febmary 12, 2014 (ADAMS Accession No.ML14038A192).

References:

1.ASME Code Case N-805, Alternative to Class 1 Extended BoundaryEndofIntervalor Class 2 System Leakage Testing of Reactor Vessel Flange O-ring Leak Detection System was issued to the 2010 Edition of the ASME Section XI Code and is listed in Supplement6for Code Cases.However, Code Case N-805 has not been approved by the NRC andisnotidentified in Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1.Status: Pending NRC approval.E-8 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-lSI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH10CFR50.55a(a)(3)(ii) Non Code Class 2 K 41.QV019 Reactor Coolant Drain Tank ATTACHMENT 1"Simplified SchematicofRPV FlangeLeak-offLine 0-Ring Seals I QV018 QV017B 3/8" QV017A*The schematicisadepictionoftheUnit1piping. Unit2pipingdiffersonlyby the name of the QV017 valves and the location of the 3/4" to 3/8" reducers.E-9 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH10CFR50.55a(a)(3)(ij) ATTACHMENT 2 ExcerptfromFNPUnit1 P&ID D175037 i/i\iu>-ftC-250iR 5'CCA-6 CM574;i/**'.tNi 1/l\£379^379B (3££: I 4jOTt 2;KD-175039 SHJfA-Dc!C\CS*LT CHG.1 2^110EJ86 SH.1 LOC 1-U (SK NOTI 23)R29 CCA-11 CCA-71 6-BC-250lf? W'??WV 70PBB 3/<VtNT ovo?;/.-3/4" V£HT 9?3AC: QVC729 993AD NOTE 23 3/<<VEMT avl397S r w--" 6" CCiV-27 6-RC-2501R 29" CCA-n!-eD^6 j/B-i7a J/S-I4V!SL-'rg_rl 1-aO690^0 SCE NOTE 22 REACTOR VESSEL ITEU: PCSV SAFTEYCLASS1 01B11H001 E-10 Tir-<<01:-2M5R'-6C^I i 3/4-T QWI ai-tisu 6-flC-25D 6*CCA-22 ovoga 3/<<VINT CVCflOA 998AC (SEE NOTI 23)grr 24/1 f\38529" CCA-11 ftC-2501R V<(h<a2A SI f\niXJ I'CC.g<jg3CD Ji (SEE HDTE 23)WIC 7 m-2 I-15Ba<<A SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii)

ATTACHMENT 3 ExcerptfromFNPUnit2 P&ID D205037 J.076A p-}iirocM LOC.J-10 2-RC-2M1R 10 niK riCMPTER a-TA780L 2-B032 Ch'C^U 2-TW-40I V2 X i/fl'PPE TUK iilJiPTDi Q-/019 NOTE 26 379A CV074B'}/4-V Cr.CI74<<3-RC-260iR J" IX*-6-<D-20MJ9 SH.KB-lK (yti*4.1 tHd.-12ICC90 SH.t LOC.1-H 29 CCA-11 Ovnris}/*'V SE!MOTE 26 CrrW7A C.0724<<-M-250lR SEE NOTE 26 TE:^B99 93AC 6-RC-2S0IR 29" CCA-n'Q18 2-6076/a-T76 QVD17A V4-T78 2-Ki69A I HOT{8 REACTOfi VESSEL UEU.PCRv SAFTCT a;^SS I Q26nH001 E-11 6-CC 1/a'PPE 10 Tiff fits 5/4 V 5-,C'.'0I7B 92-&:>69 NOTE 7*RC-25

6-RC-2M1R 993CC^T^NjaEE fCTE 26 993CD ,**2 MOT r-(IC-2501fi r CW-J1 1-RC-iisSkA¥-{a SV'22I4A-A*

Hkf-I 1C8BR6 S-.22ti<<.-A SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-ie, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii) ATTACHMENT 4 Excerpt from FNP Drawing D176275, depicting inaccessible leak-off piping.(Note:Unit2Typical) Reactor Vessel roi ae*crof.PLOkJ REsrn.: see^_IO C,'n?i ifUcTod , WELD s<<mozzce*^f-J 3-r i.f Lpejocrpusoy^r 7'-9iie Sandbox Cover-S*1^I<*1/Concrete,, r^RESTp:<>.JMT Rt>>, DUIC/0-I7C277 MGS;S6E nr^4>>civ/r oucr'BL ut'-io'-Depiction of;^^o!Leak-Off Pipingflor eeMT<M stippr a E-12 SOUTHERN NUCLEAR OPERATING COMPANY-FNP-1 and FNP-2 FNP-ISI-ALT-16, VERSION 1.0 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(il) ATTACHMENT 5ExcerptfromFNPDrawing 0176277, depicting inaccessible leak-off piping.(Note:Unit2Typical) IjOOP2 LOOP Note: Inaccessible leak-off piping identified by clouds.E-13}}

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