L-90-009, American Society of Mechanical Engineers (ASME) Section XI, Inservice Inspection (ISI) Program - Request for Relief 1-ISI-18, Examination and Testing of Snubbers
| ML041330118 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/22/2003 |
| From: | Abney T Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-90-009, R08 031022 670 | |
| Download: ML041330118 (11) | |
Text
R08 031022 670 October 22, 2003 10 CFR 50.55a(a)(3)(i)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:
In the Matter of ) Docket No. 50-259 Tennessee Valley Authority )
BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 - AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI, INSERVICE INSPECTION (ISI) PROGRAM - REQUEST FOR RELIEF 1-ISI-18, EXAMINATION AND TESTING OF SNUBBERS In accordance with 10 CFR 50.55a(a)(3)(i), TVA requests relief from ASME Section XI Code requirements associated with the selection, examination, and testing of snubbers. These requirements overlap with those contained in the BFN Unit 1 Technical Requirements Manual, which are based on the guidance contained in Nuclear Regulatory Commission (NRC)
Generic Letter 90-09, Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions. TVA has determined that the proposed alternative would provide an acceptable level of quality and safety.
There is established precedent for this relief request.
Relief Request 1-ISI-18 is consistent with request for relief 3-ISI-2, submitted by letter dated January 22, 1997, as supplemented by letter dated October 29, 1998, and approved by the NRC in a letter dated May 3, 1999, and request for relief 2-ISI-13, submitted by letter dated October 25, 2002, and approved by the NRC in a letter dated January 7, 2003.
U.S. Nuclear Regulatory Commission Page 2 October 22, 2003 A detailed discussion and justification for this relief request are included in the enclosure to this letter. TVA requests NRC review and approval of these relief requests by April 15, 2004, to support continuing BFN Unit 1 restart activities.
There are no commitments contained in this letter. If you should have any questions concerning this matter, please telephone me at (256) 729-2636.
Sincerely, Original signed by:
T. E. Abney Manager of Licensing and Industry Affairs Enclosure
U.S. Nuclear Regulatory Commission Page 3 October 22, 2003 DTL:MJB:BAB Enclosure cc (Enclosure):
A. S. Bhatnagar, PAB 1E-BFN M. J. Burzynski, BR 4X-C R. G. Jones, NAB 1A-BFN J. E. Maddox, LP 6A-C R. F. Marks, PAB 1C-BFN D. C. Olcsvary, LP 6A-C J. R. Rupert, NAB 1A-BFN K. W. Singer, LP 6A-C M. D. Skaggs, POB 2C-BFN J. Valente, NAB 1E-BFN E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS-K S:lic/submit/subs/Unit1 Relief Request 1-ISI-18 10-16-03.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNIT 1 AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI, (FIRST TEN-YEAR INSPECTION INTERVAL)
REQUEST FOR RELIEF 1-ISI-18, EXAMINATION AND TESTING OF SNUBBERS (See Attached)
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNIT 1 AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI, (FIRST TEN-YEAR INSPECTION INTERVAL)
REQUEST FOR RELIEF 1-ISI-18 EXAMINATION AND TESTING OF SNUBBERS Executive Summary: Pursuant to 10 CFR 50.55a(a)(3)(i), TVA is requesting relief from the ASME Section XI Code requirements related to selection, examination, and testing of snubbers. TVA proposes to use the selection, examination, and testing plans currently contained in the BFN Unit 1 Technical Requirements Manual (TRM) TR 3.7.4, which are based on the guidance contained in Nuclear Regulatory Commission (NRC)
Generic Letter 90-09. ASME Section XI imposes overlapping requirements that do not enhance the quality or safety of the snubber examination and testing program.
Unit: One (1)
System: Various Components: Snubbers on Class 1, 2, and 3 (equivalent) piping and components ASME Code Class: 1, 2, and 3 (equivalent)
Section XI Edition: 1995 Edition, 1996 Addenda Code Table: IWF-2500-1 Examination Category: F-A (Snubber pin-to-pin only)
Examination Item Number: F1.10, F1.20, F1.30, F1.40 (Snubber pin-to-pin only)
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Code Requirement From Which Relief Is Requested: IWF-5300(a) and (b), Inservice Examinations and Tests and referenced ASME/ANSI OM Part 4 (1987 with OMa-1988)
IWF-5400, Repair/Replacement Activities and referenced ASME/ANSI OM Part 4 (1987 with OMa-1988)
IWA-6230, Summary Report Preparation, for snubbers IWF-2110(a)(5) and (c), Duties of the Authorized Nuclear Inservice Inspector (ANII), for snubbers Basis For Relief: ASME Section XI, Class 1, 2, and 3 equivalent snubbers are required to be selected, examined, and tested in accordance with BFN Plant Technical Requirements Manual (TRM), Technical Requirement (TR) 3.7.4. The TRM was developed based on the guidance contained in NRC Generic Letter 90-09. The Generic Letter 90-09 methodology for selection of snubbers for inspection and testing was developed to maintain a high confidence level that snubbers are capable of fulfilling their function, while minimizing radiological exposure associated with these activities. The scope for snubbers examined and tested in accordance with TR 3.7.4 is not limited by line size or other applicable code exemptions.
Personnel performing examinations and testing under TRM program are task-qualified to demonstrate the capability to perform the tasks. Under the ASME Section XI program, inspection personnel would require qualification to ANSI/ASNT CP-189 "ASNT Standard for Qualification and Certification of Nondestructive Testing Personnel." This places an additional qualification and certification burden that is not needed to ensure the quality of snubber examinations and testing.
Examination and testing of the snubbers in accordance with both ASME Section XI and the plant TRM would require maintaining E-3
two programs with different standards for selection, examination, and testing of snubbers. This duplication of an existing NRC-accepted program imposes unnecessary costs and administrative burden, and would result in unnecessary additional radiological exposure without a compensating increase in safety.
Alternative Examination: The BFN TRM, TR 3.7.4, requirements will be utilized for the selection, visual examination, and functional testing of snubbers for preservice, inservice, and for repair/replacement activities. The procedures utilized for these examinations are maintained by TVA per the requirements of the TVA Nuclear Quality Assurance Program. Visual examination and testing of snubbers is performed in accordance with the following procedures:
- 1-SI-4.6.H-1, "Visual Examination of Hydraulic and Mechanical Snubbers,"
- 0-SI-4.6.H-2A, "Functional Testing of Mechanical Snubbers,"
- 0-SI-4.6.H-2B, "Functional Testing Of Bergen-Paterson, Anchor/Darling or Fronek Hydraulic Snubbers,"
- 0-SI-4.6.H-2C, "Functional Testing of Bergen-Paterson Torus Dynamic Restraints,"
- 0-SI-4.6.H-2D, "Functional Testing of Grinnell Hydraulic Snubbers,"
- MPI-0-000-SNB001, "Hydraulic Shock and Sway Arrestor Grinnell Unit Disassembly and Reassembly,"
- MPI-0-000-SNB002, "Hydraulic Shock and Sway Arrestor Bergen-Paterson Anchor/Darling and Fronek Unit Disassembly and Reassembly," and E-4
- MPI-0-000-SNB004, "Instructions for Removing and Reinstalling Pacific Scientific Mechanical, Bergen-Paterson, Anchor/Darling, Fronek and Grinnell Hydraulic, and Bergen Paterson or Lisega Torus Dynamic Restraint Snubbers."
The TRM requirements are applicable to the pin-to-pin portion, inclusive, of applicable snubbers.
Snubber examination and testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, and the implementing procedures.
The structural portions of the component supports, other than the snubbers, inclusive of the pins back to the building structure and also to the component/piping being supported, will remain in the ASME Section XI examination boundary (ISI Program).
Justification For The Granting Of Relief: The BFN Unit 1 TRM snubber inspection and testing program, defined by TR 3.7.4, provides for a level of quality and safety equal to or greater than that provided by 1995 Edition, 1996 Addenda of ASME Section XI and ASME/ANSI OM Part 4 (1987 with OMa-1988) and requirements.
For BFN Unit 1, selection, examination, testing, repair and replacement of snubbers is required to be performed in accordance with both ASME Section XI and TR 3.7.4, which is based on the guidance contained in NRC Generic Letter 90-09.
The Generic Letter 90-09 methodology for selection of snubbers for inspection and testing was developed to maintain a high confidence level that snubbers are capable of fulfilling their function, while minimizing radiological exposure associated with these activities. Because ASME Section XI has a different basis for developing examination and testing plans, it is impractical to implement the requirements of both programs.
Implementing both programs would require employing different criteria for E-5
identifying the total snubber inspection and test populations, for identifying the test groups and intervals, and for determining inspection and test sample expansion when required. These contradictory requirements would result in additional cost, unnecessary program implementation complexity, and unnecessary radiological exposure. Therefore, TVA proposes that the BFN Unit 1 snubber examination and testing program be based on the requirements contained in the BFN TR 3.7.4.
The 1995 Edition, 1996 Addenda of ASME Section XI, Subarticle IWF-1220 requires that inservice inspection of snubbers be performed in accordance with IWF-5000.
IWF-5200 requires that examinations be performed in accordance with ASME/ANSI OM Part 4 (1987 with OMa-1988). IWF-5400 of the 1995 Edition, 1996 Addenda of ASME Section XI requires snubber repair and replacement to be performed in accordance with IWA-4000. The BFN TRM program, defined in TR 3.7.4 (TSR 3.7.4.6),
requires replacement snubbers, and snubbers that have repairs which might affect the functional test results, to be tested to meet the functional test acceptance criteria prior to installation.
Accordingly, the intent of IWA-4000 is already met under the BFN Unit 1 TRM program. Further, BFN Maintenance Procedure MPI-0-000-SNB004 provides visual examination criteria following installation of a snubber after repair or replacement.
To meet code requirements, personnel performing snubber visual inspections must be certified in accordance with ASME Section XI VT-3 requirements. Under the TRM program, personnel are required to be "process qualified" to perform the examinations and testing. This training requires a visual test associated with face mask fit and specific training on the requirements and maintenance procedure acceptance criteria. Additional "visual acuity" verification for personnel performing snubber visual examinations will include visual acuity requirements that meet ASME Section XI. The training E-6
and documentation of personnel to the visual acceptance criteria specified in the TRM implementing procedures will provide an acceptable level of quality and safety.
Because relief is sought from the ASME Section XI snubber examination and test requirements, there will be no ASME Section XI snubber examination and test activities that will require ANII involvement. The BFN TRM snubber program will not require the use of an ANII for examination and test requirements. The ANII will not be involved in the TRM required visual examination or testing activities performed in lieu of the ASME Code requirements. A snubber program manager will provide the oversight of the TRM snubber program implementation for both the visual examination and functional testing. This oversight will include both review and evaluation of visual examination and functional testing data to ensure TRM requirements are met. The snubber program manager will provide the oversight that will ensure an acceptable level of quality and safety exist without ANII involvement in these activities.
ANII involvement will be maintained in inservice repair and replacement snubber activities, as required by IWA-2110(g) and (h) and implemented by BFNs ASME Section XI Repair and Replacement Program.
ASME Section XI Subarticle IWA-6230 provides requirements for ISI and testing documentation for snubbers in the framework of a summary report. Under the alternate requirements for snubbers, there will be no ASME Section XI ISI to document in a summary report.
TR 3.7.4 will be implemented per surveillance instructions and maintenance instructions written and approved in accordance with the TVA Nuclear Quality Assurance Program. These procedures include data sheets for documenting the visual examination and functional test data and results, provide for documentation of nonconforming results and evaluation of those results. The completed data sheets will be QA records E-7
controlled and maintained in accordance with the BFN QA records program. These records will be available onsite for review and inspection.
The examination and testing of snubbers under the BFN Unit 1 TRM program provides an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), TVA requests that relief be granted from the ASME Section XI requirements related to ISI and testing of snubbers.
TVA's request for relief 1-ISI-18 is consistent with request for relief 3-ISI-2 submitted by TVA letters dated January 22, 1997, as supplemented by TVA letter dated October 29, 1998, for the BFN Unit 3 Second Ten-Year Inservice Inspection Interval. The NRC staff approved the request for relief by letter dated May 3, 1999.
TVA's relief for Unit 1 is also consistent with request for relief 2-ISI-13 submitted by TVA letter dated October 25, 2002, for the BFN Unit 2 Third Ten-Year Inservice Inspection Interval. The NRC staff approved the request for relief by letter dated January 7, 2003.
Implementation Schedule: This request for relief is applicable to the remainder of the First Ten-Year Inservice Inspection (ISI) Interval for BFN Unit 1, which extends until one year following restart of the unit.
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