ML041740007

6/21/04, Browns Ferry, Unit 1, Safety Evaluation, First 10-Year Interval Inservice Inspection Request to Use the 1995 Edition Through 1996 Addenda, Article IWA-5000 of the ASME Code,Section XI

ML041740007
Person / Time
Site:	Browns Ferry
Issue date:	06/21/2004
From:	William Burton NRC/NRR/DLPM/LPD2
To:	Singer K Tennessee Valley Authority
Jabbour K, NRR/DLPM, 415-1496
References
TAC MC1331
Download: ML041740007 (8)

Text

June 21, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SAFETY EVALUATION FOR THE BROWNS FERRY NUCLEAR PLANT, UNIT 1, FIRST 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST TO USE THE 1995 EDITION THROUGH 1996 ADDENDA, ARTICLE IWA-5000, OF THE ASME CODE, SECTION XI (TAC NO. MC1331)

Dear Mr. Singer:

By letter dated October 22, 2003, the Tennessee Valley Authority (TVA) requested U.S. Nuclear Regulatory Commission staff approval to adopt the requirements of a later version of the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME) Code for the System Pressure Test program at the Browns Ferry Nuclear Plant, Unit 1.

Based on its review, as discussed in the enclosed safety evaluation, the staff finds that TVAs request to use the 1995 Edition through the 1996 Addenda, Article IWA-5000, System Pressure Tests, of the ASME Code,Section XI, is acceptable.

Sincerely,

/RA/

William F. Burton, Acting Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-259

Enclosure:

As stated cc w/enclosure: See next page

June 21, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SAFETY EVALUATION FOR THE BROWNS FERRY NUCLEAR PLANT, UNIT 1, FIRST 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST TO USE THE 1995 EDITION THROUGH 1996 ADDENDA, ARTICLE IWA-5000, OF THE ASME CODE, SECTION XI (TAC NO. MC1331)

Dear Mr. Singer:

By letter dated October 22, 2003, the Tennessee Valley Authority (TVA) requested U.S. Nuclear Regulatory Commission staff approval to adopt the requirements of a later version of the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME) Code for the System Pressure Test program at the Browns Ferry Nuclear Plant, Unit 1.

Based on its review, as discussed in the enclosed safety evaluation, the staff finds that TVAs request to use the 1995 Edition through the 1996 Addenda, Article IWA-5000, System Pressure Tests, of the ASME Code,Section XI, is acceptable.

Sincerely,

/RA/

William F. Burton, Acting Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-259

Enclosure:

As stated cc w/enclosure: See next page DISTRIBUTION:

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NAME KJabbour BClayton SCoffin APH WBurton DATE 6/7/2004 6/4/2004 5/7/2004 6/11/2004 6/21/2004 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM SYSTEM PRESSURE TEST PROGRAM TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-259

1.0 INTRODUCTION

By letter dated October 22, 2003, the Tennessee Valley Authority (TVA or the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff approval to adopt the requirements of a more recent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME) Code for the System Pressure Test (SPT) program at the Browns Ferry Nuclear Plant (BFN), Unit 1.

2.0 REGULATORY REQUIREMENTS Pursuant to Title 10, Code of the Federal Regulations (10 CFR) Section 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that the inservice inspection (ISI) of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.

As stated in 10 CFR 50.55a(g)(4)(iv), the ISI of components and SPTs may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in Section 50.55a(b), subject to the limitations and modifications listed therein and NRC approval. Portions of the editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.

3.0 TECHNICAL EVALUATION

Pursuant to 10 CFR 50.55a(g)(4)(iv), TVA requested the NRC staff approval to use the applicable portions of a more recent edition of the ASME Code for the SPTs at BFN Unit 1, which is currently shut down. This unit is in the third period of the first 10-year interval which is scheduled to end 1-year following its restart. The accepted Code of Record for the first 10-year ISI interval is the 1974 Edition through the 1975 Addenda with portions of the 1980 Edition,

Winter 1981 Addenda of the ASME Code,Section XI. TVA requested the adoption of Article IWA-5000, System Pressure Tests, of the 1995 Edition through the 1996 Addenda of the ASME Code,Section XI, for the BFN Unit 1 SPT program. The approval of this Code update would make the BFN Unit 1 SPT Program consistent with the approved BFN, Unit 2 SPT Program (Reference 2).

TVA has decided not to credit any BFN Unit 1 SPTs completed to date during the current inspection period. All subsequent third period SPTs will be conducted in accordance with the requirements of Article IWA-5000 of the 1995 Edition through the 1996 Addenda, of the ASME Code,Section XI. In addition to this requirement, TVA will conduct the BFN Unit 1 SPTs with additional hold time requirements. These additional hold time requirements stated below are the same as those adopted for BFN Unit 2, and described in the February 5, 2001, program update.

In addition to the requirements prescribed in the ASME Boiler and Pressure Vessel Code, 1995 Edition through the 1996 Addenda, BFN will institute additional test condition holding time provisions similar to those described in IWA-5213 of the 1989 Edition of the Code and clarified as follows. Section IWA-5211 and Table IWA-5210-1 of the 1989 Edition provided test descriptions and cross referenced Code Class test requirements.

BFN will use those general definitions and that logic to implement the additional test condition holding time provisions. For the purposes of these additional hold time provisions the system leakage test as described in IWA-5211(a) 1995 Edition/1996 Addendum will be broken into categories as described in IWA-5211(a), (b), and (c) and IWA-5213(a), (b), and (c) of the 1989 Edition. These hold time requirements are from the 1989 Edition and will be in addition to the 1995 Edition/1996 Addendum Code requirements:

Class 1 system leakage tests will follow IWA-5213(a).

Class 2 system leakage tests for standby systems will follow IWA-5213(b).

Class 2 system leakage tests for in service systems will follow IWA-5213(c).

Class 3 system leakage tests for standby systems will follow IWA-5213(b).

Class 3 system leakage tests for in service systems will follow IWA-5213(c).

Note: System hydrostatic and pneumatic test hold time requirements are almost identical in both subject editions of the Code. System hydrostatic and pneumatic tests will follow the requirements of the 1995 Edition/1996 Addendum of the Code.

The following hold time requirements of Section IWA-5213, Test Condition Holding Time, of the 1989 Edition of the ASME Code were adopted for the BFN Unit 1 SPT in addition to the 1995 Edition through the 1996 Addenda of the ASME Code requirements:

The holding time after pressurization to test conditions, before visual examinations commence, shall be as follows:

(a) system leakage tests - no holding time required after attaining test pressure and temperature conditions; (b) system functional tests - 10 min holding time required after attaining the system operating pressure; (c) system inservice tests - no holding time required, provided the system has been in operation for at least 4 hr The change to the later Code for the BFN Unit 1 SPT Program will bring the program into general agreement with the BFN Unit 1 ISI and Repair/Replacement programs, which were updated to the 1995 Edition through the 1996 Addenda of the ASME Code Section XI, on November 8, 2002 (Reference 3). The following list identifies approved Code Cases and Requests for Relief affecting the BFN Unit 1 SPT Program that will remain in effect for the remainder of this current Interval:

Code Cases:

N-416-1 N-416-2 N-437 N-479 N-495 N-498-1 N-498-4 N-522 N-566-1 Relief Requests (RRs):

H-3 (Approved February 14, 1989)

H-12 (Approved February 14, 1989)

H-13 (Approved September 19, 1989)

The above mentioned Code Cases were approved for use in Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 13.

Also, with the adoption of the 1995 Edition through the 1996 Addenda of the ASME Code Section XI, Code Cases N-437, N-479, and N-495, and RRs H-3, H-12, and H-13 become obsolete and unnecessary since they address either hydrostatic testing at elevated pressures or other pressure testing details that have been incorporated into the 1995 Edition through the 1996 Addenda.

By letter dated January 14, 2004 (Reference 4), the NRC staff approved the adoption of a later edition of the ASME Code,Section XI, for the qualification of VT-2 (visual) examination personnel. Specifically, TVA is adopting the 1998 Edition of the ASME Section XI Code, Subarticle IWA-2316, Alternative Qualifications of VT-2 Visual Examination Personnel, for observation of leakage during system leakage and hydrostatic tests for the BFN, Units 1, 2, and

3. Subarticle IWA-2316 of the 1998 Edition of the ASME Code states:

(a) In lieu of the requirements of IWA-2310 through IWA-2314, VT-2 visual examination personnel may be qualified by satisfying the following requirements:

(1) at least 40 hr plant walkdown experience, such as gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, quality control personnel, and nondestructive examination personnel (2) at least 4 hr of training in the Section XI requirements and plant-specific procedures for VT-2 visual examination (3) the vision test requirements of IWA-2321.

(b) These alternative qualification requirements shall be described in the Employers written practice.

TVA will adopt these alternative VT-2 qualification requirements for personnel performing system leakage and hydrostatic test examinations for BFN Unit 1.

Based on the information contained in the licensees submittal dated October 22, 2003, the staff has determined that the adoption of the 1995 Edition through the 1996 Addenda of the ASME Code,Section XI, Article IWA-5000, for the BFN Unit 1 SPT program, is acceptable, for the remainder of the current ISI interval for BFN Unit 1, provided that all related requirements of the respective edition and addenda are met. Regarding the adoption of the additional holding time provisions to the BFN Unit 1 SPT, the staff has determined that the adoption of these additional requirements is acceptable. In addition, the pressure test holding times are consistent with the requirements of 10 CFR 50.55a(b)(2)(xx). The staff notes that the use of the 1998 Edition of the ASME Code for the qualification of VT-2 examination personnel, was approved by the NRC staff by letter dated January 14, 2004 (Reference 4). These ASME Code editions have been approved by the staff in 10 CFR 50.55a.

4.0 CONCLUSION

For TVAs request to adopt the requirements of the 1995 Edition through the 1996 Addenda, of the ASME Code,Section XI, Article IWA-5000, for the BFN Unit 1 SPT Program, the staff concludes that the adoption of the later edition of the ASME Code is acceptable pursuant to 10 CFR 50.55a(g)(4)(iv), for the remainder of the first 10-year ISI interval, provided that all related requirements of the respective edition and addenda are met.

All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

5.0 REFERENCES

1. Letter from TVA to the NRC, Browns Ferry Nuclear Plant, Unit 1 - American Society of Mechanical Engineers (ASME)Section XI System Pressure Test (SPT) Program - Notification of Code Update for the Remainder (Third Period) of the First Ten-Year Inspection Interval, dated October 22, 2003.

2. Letter from TVA to the NRC, Browns Ferry Nuclear Plant (BFN) - Unit 2 -

American Society of Mechanical Engineers (ASME)Section XI, Inservice Inspection and System Pressure Test Programs for the Third Ten-Year Inspection Interval, dated February 5, 2001.

3. Letter from TVA to the NRC, Browns Ferry Nuclear Plant, Unit 1 - American Society of Mechanical Engineers (ASME)Section XI Inservice Inspection (ISI)

Program - Submittal of Program Update, dated November 8, 2002.

4. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Approval to Use More Recent Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for Alternative Qualification of VT-2 Examination Personnel, dated January 14, 2004.

Principal Contributor: J. Arroyo Date: June 21, 2004

Mr. Karl W. Singer BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Robert G. Jones Nuclear Operations Browns Ferry Tennessee Valley Authority Browns Ferry Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Decatur, AL 35609 Mr. James E. Maddox, Vice President Mr. Mark J. Burzynski, Manager Engineering & Technical Services Nuclear Licensing Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place 4X Blue Ridge 1101 Market Street 1101 Market Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 Site Vice President Mr. Timothy E. Abney, Manager Browns Ferry Nuclear Plant Licensing and Industry Affairs Tennessee Valley Authority Browns Ferry Nuclear Plant P.O. Box 2000 Tennessee Valley Authority Decatur, AL 35609 P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority Senior Resident Inspector ET 11A U.S. Nuclear Regulatory Commission 400 West Summit Hill Drive Browns Ferry Nuclear Plant Knoxville, TN 37902 10833 Shaw Road Athens, AL 35611 Mr. T. J. Niessen, Acting General Manager Nuclear Assurance State Health Officer Tennessee Valley Authority Alabama Dept. of Public Health 6A Lookout Place RSA Tower - Administration 1101 Market Street Suite 1552 Chattanooga, TN 37402-2801 P.O. Box 303017 Montgomery, AL 36130-3017 Mr. Michael D. Skaggs, Plant Manager Browns Ferry Nuclear Plant Chairman Tennessee Valley Authority Limestone County Commission P.O. Box 2000 310 West Washington Street Decatur, AL 35609 Athens, AL 35611 Mr. Jon R. Rupert, Vice President Browns Ferry Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609