ML20196E495

Requests Exemption from Program Update Requirements of 10CFR50.55a(g)(4)(ii).Proposes to Update Unit 2 Program to ASME Code 1983 Edition Rather than Update Program to Code of Record on 910731

ML20196E495
Person / Time
Site:	Farley
Issue date:	06/22/1988
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-66678, NUDOCS 8807010630
Download: ML20196E495 (5)

Text

, e Alabama Pow::r Company 600 North 18th Street Post off ce Eox 2641 Birmingham, Alabama 352914400 Telephone 205 250-1837 ,

W. G. Hairston, lll Vice President Nuclear Gereration h

Docket No. 50-364 Alabama Power

• #"1N$$$.T l l

June 22, 1988 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Gentlemen:

I Joseph M. Farley Nuclear Plant - Unit 2 Request for Exemption l from the Requirements of 10CFR50.55a(g)(4)(ii)(TAC #66678) 10CFR50.55a requires that certain components of reactors be tested and examined to the requirements of Section XI of the ASME Code, and that the examinations and tests be completed during successive 120-month (ten-year) intervals. These ten-year intervals are calculated from the start date of commercial operation of the facility. Further, S50.55a(g)(4)(ii) requires that licensees update their Inservice Inspection (ISI) and Inservice Testing (IST) programs to the latest approved edition of Section XI of the ASME Code every ten years.

During the first ten years of operation of the Farley Nuclear Plant, ISI and ISTactiv[tieswereperformedundetthesameASMECoderequirementsforUnits 1 and 2. With the Code update required by 10CFR50.55a(g)(4)(ii), however, the Unit 1 ISI and IST Frograms were updated in 1987 to the 1983 Edition of the ASME Code,2 but the earlier 1974 Edition will, under current update requirements, apply to the Unit 2 programs until 1991, the date that Unit's first ten-year interval of operation ends. At that point, Unit 2 would have to meet a later Code edition than applied to Unit 1. As the Commission has noted, sina the regulations define the start of the initial ten-year interval as the date of the facility's commercial operation, licensees with multi-unit sites "often find that each unit has an ISI and IST Program structured for a slightly different edition of the Code."

1/ ASME Code,Section XI, 1974 Edition through the Summer 1975 Addenda.

2/ Through the Summer 1983 Addenda. ,,

I \

i 8807010630 880622 PDR ADOCK 05000364 P DCD

e .

k. S.-Nuclear Regulatory Commission Juns 22, 1988 Page 2 l

50 Fed. Reg. 16180 (1985). This "can create administrative difficulties for i the licensee in keeping track of two sets of requirements for only nominal I technical differences in testing requirements." 53 Fed. Reg. 15760 (1988). j To eliminate these difficulties, Alabama Power Company hereby requests an exemption from the program update requirements of 550.55a(g)(4)(ii) pursuant to 10CFR50.12. Accordingly, rather than update the Unit 2 program to the Code of record on July 31, 1991, as now required, Alabama Power Company proposes (1) that the Unit 2 program be updated now to the ASME Code, 1983 Edition through the Sumer 1983 addenda three years in advance of requirements as allowed by S50.55a(g)(4)(iv), and (2) that the Unit 2 program maintain the 1983 Edition through the first and second 40-month periods of the second ten-year interval until December 1, 1997, the date on which the Unit 1 program is scheduled to enter its third interval (and again be updated). In this way, the Code requirements now in effect for Unit 1 would be applied to Unit 2 for the remainder of the first Unit 2 ten-year interval, and these same requirements would remain in effect throughout most of the first two forty-month periods of the second ten-year interval. It is intended that the update to be performed in 1997 would include both units.

Thus, throughout the remaining wouldbeappliedtobothUnits.}ifeoftheplant,thesameCoderequirements Section 50.12 states that the Commission will not grant an exemption unless "special circumstances" are present. 550.12(a)(2). "Special circumstances" -

are present, inter alia, whenever application of the regulation "is not necessary to achieve the underlying purpose of the rule." S50.12(a)(2)(ii).

To grant an exemption, the Commission must, in addition, find that it is authorized by law; will not present an undue risk to public health and safety; and is consistent with the common defense and security.

550.12(a)(1). Approval of the proposed exemption, which would result in synchronization of ASME Code requirements for Farley Units 1 and 2, would meet all of these requirements.

3/ It is not intended that the proposed update would change the first ten-year interval completion 'chedule or the start date for the second ten-year interval. While t ten-year interval schedule has no affect on <

IST Program implementation, there is significant impact to the ISI l Program activities due to outage schedules. The third forty-month period for Unit 2 began on March 30, 1988 and the remaining outages for the first ten-year interval are tentatively scheduled for March 1989 and September 1990. While Alabama Power Company has attempted to complete the maximum number of inspections permitted by the Code during each of l the first two periods, the remaining inspection work cannot be completed l in less than the two remaining outages. Therefore, Alabama Power Company j proposes to complete the ISI Program requirements for the third '

forty-month period of the first ten-year interval under the later Code. ,

The same updated ISI Program would then be applied to the first two '

periods of the second ten-year interval beginning on July 30, 1991.

l

e . .

'U. S. Nuclear Regulatory Comission June 22, 1988 Page 3 First, the underlying purpose of 550.55a(g)(4)(ii) would continue to be achieved, since the exemption would provide an equivalent degree of inservice testing and examination such that there would be no increase in the risk of failure for operational readiness of pumps and valves or other components.

Indeed, application of the later NRC approved Code for the remainder of the Unit 2 first ten-year interval, and in advance of the update required, will improve the level of quality and safety. Moreover, because this same Code is being implemented for the updated Unit 1 ISI and IST Programs through December 1,1997, this Code edition should be an acceptable basis for the Unit 2 programs throughout that same time period.

Second, essentially identical ISI and IST Programs would have to be submitted )

by the licensee and reviewed by the NRC. The programs will be identical (to the extent practical given minor design differences between the two Units) to those already under review for Unit 1.

'Ihird, performing ISI and IST at both plants using essentially identical programs will result in uniform procedures for both plants, and can teduce the chance of personnel errors in the performance of the testing and examination requirements.

Finally, the use of identical ISI and IST Programs will have advantages in I terms of manpower requirements, and should result in increased plant safety l through simplification of plant procedures.

In sum, the proposed exemption provides administrative, technical and cost-saving advantages, both for Alabama Power Company and the Comission.

Synchronization of ASME Code requirements for the Units 1 and 2 IFI and IST Programs will not only represent a substantial cost savings to Alabama Power Company by standardizing the technical requirements and program documents used in program implementation, but will also reduce the required review effort for the NRC, since the Unit 1 Safety Evaluation Reports can be generically applied to the updated programs for Unit 2.

ENVIRONMENTAL ASSESSMENT Identification of Proposed Action 10CFR50.55a(g)(4) requires that licensees update their Inservice Inspection and Inservice Testing Programs to a newer edition of Section XI of the ASME Code every ten years. Since the regulations require these updates based on the ten-year anniversary of facility comercial operation, multi-unit sites often find that each unit has ISI and IST Programs structured to different editions of the Code. Approval of this exemption request would allow update of the Farley Unit 2 Inservice Inspection and Testing Programs three years early, to the same Code edition that now applies to Unit 1, and in addition authorize these same Code requirements to remain in effect until 1997, i.e.,

throughout most of the first two forty-month periods of the second ten-year interval for Unit 2. 'Ihe update to be performed at that point would include both units. Thus, the same Code requirements would be applied to botn units throughout the remaining life of the plant.

4

, _ , .,v_ mm , ,,_ , _. _, _ _ _ -- -

l o *. .

l U. S. Nuclear Regulatory Commission June 22, 1988 l Page 4 i l

The Need for the Proposed Action The requested exemption is needed because the ISI and IST Programs for Farley Nuclear Plant would otherwise be accomplished under two different editions of the ASME Code. Although administratively possible, this situation could contribute to the increased administrative overhead in the performance of inspection and testing requirements to two different editions of the Code.

Wis would create an additional administrative workload for what could be described as only nominal technical differences in the inspection and testing requirements.

Environmental Impact of Proposed Action The proposed exemption would provide a degree of inservice inspection and testing that is equivalent to that required by 10CFR50.55a(g)(4), such that there would be no increase in the risk of failure for operational readiness of pumps and valves or other components whose function is required for safety at these facilities. Consequently, the probability of failure for operational readiness of components would not be increased, the radiological ,

risk would not be greater than determined previously, and the requested  ;

exemption would not otherwise affect plant radiological effluents. ,

Therefore, we conclude that there are no significant radiological l environmental impacts associated with this proposed exemption.  !

l With regard to potential nonradiological impacts, the proposed exemption involves features located entirely within the restricted area as defined in l 10CFR Part 20. It would not affect plant nonradiological effluents and would have no other environmental impact. Werefore, we conclude that there are no 1 significant nonradiological environmental impacts associated with the l proposed exemption.

Alternative Use of Resources l

This action does not involve the use of tescurces not previously considered in connection with the Final Environmental Statement for the Joseph M. Farley Nuclear Plant, Units 1 and 2. i l

Finding of No Significant Impact l We conclude that an environmental impact statement for the proposed exemption is unnecessary. Based upon the foregoing environmental assessment, we have concluded that approval of the proposed action will not have a significant effect on the quality of the human environment.

Since the first of two refueling outages remaining for completion in the first ten-year interval is scheduled to begin in March 1989, it is therefore respectfully requested that the exemption requested herein be granted by August 31, 1988 (or as soon as practical) to permit completion and submittal of the updated programs and granting of requested relief prior to this outage.

D. S. Nuclcar R2gulctory Comission Juna 22, 1988 Page 5 The required fees were submitted with our previous letter of November 20, 1987, d' _ requested authorization to synchronize the ISI and IS2 Programs under $50.55a(a)(3). If there are any questions, please advise.

Respectfully subnitted, ALABAMA POWER COMPANY _;

'A e W..b. h w n W. G. Hairsten, III WGH/S'IB:pr-D cc: Mr. L. B. Long Dr. J. N. Grace ir. E. A. Reeves [

Mr. W. H. Bradford l

I i

'-- _y -.,, _ .