ML040300029
| ML040300029 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/29/2004 |
| From: | Sean Peters NRC/NRR/DLPM/LPD2 |
| To: | Southern Nuclear Operating Co |
| Peters S, NRR/DLPM, 415-1842 | |
| References | |
| EA-03-009, TAC MC1519 | |
| Download: ML040300029 (8) | |
Text
January 29, 2004 LICENSEE:
Southern Nuclear Operating Company FACILITY:
Joseph M. Farley Nuclear Plant, Unit 2
SUBJECT:
SUMMARY
- MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON REQUEST FOR RELAXATION OF ORDER EA-03-009 RE: INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL HEADS (TAC NO. MC1519)
Representatives of Southern Nuclear Operating Company (SNC), the licensee, met with members of the Nuclear Regulatory Commission (NRC) staff at NRC Headquarters on January 16, 2004, in Rockville, Maryland. The meeting addressed issues related to the licensees application dated December 3, 2003, (Reference 1) for Joseph M. Farley Nuclear Plant (FNP), Unit 2. In its application, the licensee requested relaxation of NRC Order EA-03-009 (Reference 2), issued February 11, 2003, which established interim inspection requirements for reactor pressure vessel (RPV) heads. A list of attendees is provided in and the handouts provided in the meeting are included in Enclosure 2.
Background
The discovery of leaks and nozzle cracking at the Davis-Besse Nuclear Power Station and other pressurized-water reactors plants showed the need for effective inspections of RPV heads and the associated penetration nozzles. However, the old requirements for RPV head inspection only required visual examination of the insulated surface and the surrounding area for signs of leakage. These inspections were not sufficient to reliably detect circumferential cracking of the RPV head nozzles or corrosion of the RPV head. The circumferential cracking of the RPV head nozzles and corrosion of the RPV head pose a safety concern because of the possibility of a nozzle ejection or loss-of-coolant accident if the conditions are not detected and repaired.
Therefore, on February 11, 2003, the NRC issued Order EA-03-009, which established interim requirements to ensure that licensees implement and maintain appropriate measures to inspect and, as necessary, repair RPV heads and their associated penetration nozzles. The long-term resolution of this issue is expected to involve changes to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code and will involve changes to the NRC regulations in Title 10 Code of the Federal Regulations, Section 50.55a, Codes and Standards.
With respect to the criteria of the Order, the RPV heads at FNP fall into the High category for susceptibility to primary water stress corrosion cracking (PWSCC). Therefore, the order requires RPV head and penetration nozzle inspection at every refueling outage, with a bare metal visual (BMV) of the RPV head surface and other non-destructive examination (NDE) techniques for the penetration nozzles. However, because the licensee plans to replace the FNP, Unit 2 RPV head during their following refueling outage (fall 2005), they requested a one-time relaxation of the non-visual, NDE inspection requirements set forth in the order.
January 29, 2004 To facilitate a timely review of this application, the licensee requested a meeting with the NRC to present their proposal. This meeting was held on January 16, 2004, at NRC Headquarters in Rockville, Maryland.
Summary of Meeting SNCs presentation utilized the enclosed handouts entitled, Joseph M. Farley Nuclear Plant Reactor Vessel Head Penetration Nozzle Inspection Relaxation Unit 2 Spring 2004 - 2R16 (Enclosure 2). In their presentation, the licensee provided a brief introduction, stating FNPs categorization for susceptibility to PWSCC, the inspection requirements associated with Order EA-03-009, and SNCs response to the order. They followed up with a description of the relaxation request.
For the relaxation, SNC proposed skipping the non-visual examination required by Item IV.C(1)(b) of the order for one cycle while still performing the BMV examination of the RPV head as required by Item IV.C(1)(a) of the order. Their bases for the request stemmed from several points. First, the SNC plans to replace the FNP, Unit 2 vessel head during the following refueling outage (Fall 2005, 2R17). This would mean that the relaxation would only be required for one refueling cycle (Spring 2004, 2R16). Second, during the performance of the Fall 2002, 2R15 BMV inspection of the head and Ultrasonic testing examination of the nozzles, the licensee detected no evidence of cracking. Third, they stated that analyses demonstrate that nozzle cracks propagating from below the examined volume or from flaws within the examined volume that are too small to detect would require more than two operating cycles to cause leakage and, therefore, threaten corrosion. Additionally, they stated that analyses indicate that roughly 12 cycles would be required for a circumferential crack to threaten nozzle ejection.
Finally, SNC stated that performing the non-visual NDE inspection of the nozzles would impose a hardship on the licensee by adding approximately 4.1 Rem of dose to inspection personnel without a compensating increase in the level of quality and safety.
However, the NRC staff asked SNC about the industry experience with nozzles with the same heat of materials. SNC responded by stating that four other plants in the industry have the same heat of materials as FNP, and all four (with FNP being the only exception) have experienced PWSCC. SNC attributed this exception to the fact that FNP has been injecting zinc into the RCS for greater than five years, which they believe has mitigated the initiation of PWSCC. The licensee pointed to their program of zinc injection as a key factor for mitigation of PWSCC initiation. However, SNC also noted that research shows that once the cracks have been initiated, the zinc does not slow their propagation. The NRC staff expressed concern with this fact and also expressed a desire to have the licensee submit the research data that shows the zinc capabilities for preventing PWSCC initiation.
Following the conclusion of the licensees presentation, the NRC staff took a brief recess from this meeting to discuss the presentation and to coordinate feedback. Upon its return, the NRC Staff identified the areas that were of concern. These concerns included the lack of supporting data in the licensees submittal, i.e. the crack propagation and leakage analyses and the zinc-PWSCC prevention data cited by SNC. Also, the NRC staff noted the challenging nature of the review and the tight schedule for the requested approval. The NRC staff then asked for public comment on the meeting. There were no public comments.
January 29, 2004 At the conclusion of the meeting, the licensee indicated that it would consider the information gained from this meeting and would submit a revised relaxation request to facilitate further NRC staff review.
References 1.
Letter from J. B. Beasley, Jr. to NRC, Joseph M. Farley Nuclear Plant Request for Relaxation of Order EA-03-009, December 3, 2003, ADAMS No. ML033390138.
2.
Letter from Sam Collins to the holders of licenses for operating pressurized water reactors, EA-03-009 - Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, February 11, 2003, ADAMS No. ML030380470.
Sincerely,
/RA/
Sean E. Peters, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-364
Enclosures:
- 1. Attendance List
- 2. Meeting presentation materials cc w/encls: See next page
January 29, 2004 At the conclusion of the meeting, the licensee indicated that it would consider the information gained from this meeting and would submit a revised relaxation request to facilitate further NRC staff review.
References 1.
Letter from J. B. Beasley, Jr. to NRC, Joseph M. Farley Nuclear Plant Request for Relaxation of Order EA-03-009, December 3, 2003, ADAMS No. ML033390138.
2.
Letter from Sam Collins to the holders of licenses for operating pressurized water reactors, EA-03-009 - Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, February 11, 2003, ADAMS No. ML030380470.
Sincerely,
/RA/
Sean E. Peters, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-364
Enclosures:
- 1. Attendance List
- 2. Meeting presentation materials cc w/encls: See next page DISTRIBUTION: See attached list : ML040290388 Package No. ML040300034 Meeting Notice No. ML033650445 Summary Handout No ML040300029 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME SPeters:as CHawes JNakoski DATE 1/29/04 1/29/04 1/29/04 OFFICIAL RECORD COPY ATTENDEES LIST JANUARY 16, 2004 MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY NAME ORGANIZATION Sean Peters NRC/NRR/DLPM Doug Daughhetee Southern Nuclear Operating Company Mike Stinson Southern Nuclear Operating Company Doug McKinney Southern Nuclear Operating Company Larry K. Mathews Southern Nuclear Operating Company Robert Davis NRC/NRR/EMCB John Nakoski NRC/NRR/DLPM Ed Hackett NRC/NRR/DLPM Daniel Horner McGraw-Hill William Koo NRC/NRR/EMCB Terence Chan NRC/NRR/EMCB Allen Howe NRC/NRR/DLPM
Joseph M. Farley Nuclear Plant cc:
Mr. Don E. Grissette General Manager -
Southern Nuclear Operating Company Post Office Box 470 Ashford, Alabama 36312 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm Post Office Box 306 1710 Sixth Avenue North Birmingham, Alabama 35201 Mr. J. B. Beasley, Jr.
Executive Vice President Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, Alabama 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, Alabama 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company P. O. Box 470 Ashford, Alabama 36312
DISTRIBUTION FOR -
SUMMARY
- MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON REQUEST FOR RELAXATION OF ORDER EA-03-009 RE: INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL HEADS (TAC NO. MC1519)
Dated: January 29, 2004 Hard Copy:
Public PDII-1 R/F CHawes E-Mail:
RidsNrrPMSPeters RidsOgcMailCenter RidsAcrsAcnwMailCenter RidsNrrDlpm (TMarsh/ELeeds)
RidsNrrDlpmLpdii (EHackett)
RidsNrrDlpmLpdii1 (JNakoski)
JAlbright RDavis WKoo TChan WKoo RidsNrrDlpmLpdii2 (AHowe)