ML041610260

Response to Issuance of First Revised Nuclear Regulatory Commission Order (EA-03-009) Establishing Interim Inspection Requirements for Reactor Pressure Vessel (RPV) Heads at Pressurized Water Reactors (Pwrs) for Sequoyah Nuclear Plant (SQN)

ML041610260
Person / Time
Site:	Sequoyah
Issue date:	03/09/2004
From:	Salas P Tennessee Valley Authority
To:	NRC/SECY/RAS
References
EA-03-009
Download: ML041610260 (6)

Text

el, Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 March 9, 2004 EA-03-009 10 CFR 2.202 Secretary Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Staff Washington, D.C. 20555-0001 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 RESPONSE TO ISSUANCE OF FIRST REVISED NUCLEAR REGULATORY COMMISSION (NRC) ORDER (EA-03-009) ESTABLISHING INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL (RPV)

HEADS AT PRESSURIZED WATER REACTORS (PWRs) FOR SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 The Tennessee Valley Authority (TVA) hereby submits its response to the Revised Order for Establishing Interim Inspection Requirements for RPV heads at PWRs (hereinafter "Order") issued by the NRC on February 20, 2004.

Pursuant to the requirements of 10 CFR § 2.202, Enclosure 1 provides TVA' s answer to the Order. Enclosure 2 to this response provides additional information pertaining to SQN's low-susceptibility ranking which was calculated utilizing the methodology prescribed in the Order.

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U.S. Nuclear Regulatory Commission Page 2 March 9, 2004 This letter does not contain any regulatory commitments. If you have any questions concerning this matter, please contact J. D. Smith at (423) 843-6672 or me at (423) 843-7170.

I declare under penalty of perjury that the fore oing is true and correct. Executed on this X day of W Az J0'-\.

ensing and Industry Affairs Manager Enclosures cc (Enclosures):

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Mr. J. E. Dyer, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Mr. Michael L. Marshall, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08 G9 One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. Luis Reyes, Regional Administrator U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 cc: Continued on page 3

a A U.S. Nuclear Regulatory Commission Page 3 March 9, 2004 cc (Enclosures):

Assistant General Counsel for Materials Litigation and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 NRC Senior Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379-3624

ENCLOSURE 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-327 Tennessee Valley Authority 50-328 Sequoyah Nuclear Plant, Unit 1 and Unit 2 ANSWER TO FEBRUARY 20, 2004 COMMISSION REVISED ORDER ESTABLISHING INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL (RPV) HEAD AT PRESSURIZED WATER REACTORS (PWRs)

On February 20, 2004, the Nuclear Regulatory Commission

("NRC" or "Commission") issued an order in the captioned matter entitled, "First Revised Order Modifying Licenses" to, inter alia, TVA. The Order stated that since the issuance of the Order Modifying Licenses (Effective Immediately)(EA-03-009),

dated February 11, 2003, that was issued to establish required inspections of RPV heads and associated penetration nozzles at PWRs, the NRC staff has reviewed and granted many requests for relaxation thereof. The arguments in the relaxation requests provided reasonable assurance of the continued structural integrity of the RPV head, and the associated nozzle penetrations and J-groove welds. As a result, NRC has determined that it is appropriate to revise that Order with respect to bare metal visual inspections, penetration nozzle inspection coverage, flexibility in combining nondestructive examination (NDE) methods, flaw evaluation, and requirements for plants which have replaced their RVP head.

Additionally, NRC has determined that it is appropriate and necessary for the protection of public health and safety to establish a clear regulatory framework, pending the incorporation of revised inspection requirements into 10 CFR 50.55a. To provide reasonable assurance of adequate protection of public health and safety for the interim period, those PWR Licenses identified in the attachment to the subject Order were to be modified to include the inspection requirements for RPV heads and associated penetration nozzles identified in Section IV of the Order.

TVA' s response to the substantive requirements of the Order is contained in TVA' s letter dated March 9, 2004, along with its enclosures, as directed by the Order. In accordance with Section V of the Order and 10 CFR 2.202, TVA hereby consents to the Order and does not request a hearing.

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN), UNITS 1 AND 2 ADDITIONAL INFORMATION PURSUANT TO FEBRUARY 20, 2004 COMMISSION ORDER ESTABLISHING INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL (RPV) HEAD AT PRESSURIZED WATER REACTORS The following provides additional information pertaining to SQN's susceptibility ranking calculated utilizing the methodology prescribed in the Order:

Utilizing the methodology prescribed in the Order, TVA has calculated the susceptibility category for SQN Units 1 and 2, as represented by the value of "Effective Degradation Years" (EDYs). As stated in the Order, "The calculated value of EDY shall determine the susceptibility category and the appropriate inspection for the RPV head during each refueling outage." The following summarizes the results of these calculations and demonstrates that SQN Units 1 and 2 are in the low susceptibility category (i.e., EDY less than 8):

Unit Estimated EFPYs Head Estimated Estimated (Effective Full Temperature EDYs at EDYs at Power Years) at next end-of-next refueling refueling life (32 outage/Date outage EFPY)

SQN 15.45 - Fall 2004 547 1.62 3.4 Ul SQN 16 - Spring 2005 547 1.68 3.4 U2 As shown in the Table, SQN is a low-susceptibility plant as defined by NRC' s Order. The SQN RPV head will not exceed the NRC established threshold (< 8.0 EDYs) of low susceptibility for the current licensed life of the plant primarily due to the low operating head temperatures.

TVA has completed the bare metal visual examination of the reactor vessel head surface described in paragraph IV.C(5)(a) for SQN Units 1 and 2. In accordance with IV.E, the inspection results were provided to NRC by letters dated August 14, 2003, for SQN Unit 1, and June 13, 2002, for SQN Unit 2.