ML082560367
| ML082560367 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/17/2008 |
| From: | Ellen Brown Plant Licensing Branch II |
| To: | Campbell W Tennessee Valley Authority |
| Brown E, NRR/DLPM, 415-2315 | |
| References | |
| TAC MD8797 | |
| Download: ML082560367 (7) | |
Text
September 17, 2008 Mr. William R. Campbell, Jr.
Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT, UNIT 1 C REQUEST FOR ADDITIONAL INFORMATION FOR SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUEST 1-ISI-18 (TAC NO. MD8797)
Dear Mr. Campbell:
By letter dated May 27, 2008, the Tennessee Valley Authority (TVA, the licensee) requested relief from the ASME Code,Section XI 2001 Edition, 2003 requirements related to the selection, examination and testing of snubbers. The U.S. Nuclear Regulatory Commission (NRC) staff requires additional information in order to complete its evaluation of Request for Relief (RR) 1-ISI-18.
A response to the enclosed Request for Additional Information is needed before the NRC staff can complete the review. This request was discussed with Mr. James Davenport of your staff on September 09, 2008, and it was agreed that TVA would respond by October 17, 2008.
If you have any questions, please contact me at (301) 415-2315.
Sincerely,
/RA/
Eva A. Brown, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-259
Enclosure:
Request for Additional Information cc w/enclosure: See next page
ML082560367 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA DCI/CPTB LPL2-2/BC NAME EBrown BClayton JMcHale by memo TBoyce DATE 09 / 15 /08 09 / 15 /08 8/11/08 09 / 15 /08
Enclosure REQUEST FOR ADDITIONAL INFORMATION RELIEF REQEST 1-ISI-18 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-259
- 1.
The licensee requested relief from the requirements of the 2001 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) with 2003 Addenda, Section IWF-5300(a) and (b) of Article IWF-5000. Article IWF-5000 also contains requirements for snubber preservice examinations and tests in IWF-5200 and requirements for integral and nonintegral attachments for snubbers in IWF-5300(c).
Explain whether and how the requirements of IWF-5200(a), (b), and (c) and IWF-5300(c) will be met.
- 2.
On page 91 of 105 of the May 27, 2008 submittal, the licensee requested relief from Section IWF-5400 of the Article IWF-5000 and ASME/American National Standards Institute (ANSI) requirements OM-1987, Part 4 (OM-4) with OMa-1988, Section 1.5.6 and 1.5.7. IWF-5400, Repair/Replacement states that:
Repair/replacement activities performed on snubbers shall be in accordance with IWF-4000. Snubbers installed, corrected or modified by repair/replacement activities shall be examined and tested in accordance with the applicable requirements of IWF-5200 prior to return to service.
Provide an explanation whether and how IWF-4000 and IWF-5200 requirements will be met.
- 3.
On page 91 of 105 of the May 27, 2008, submittal, Basis for Relief, the licensee stated that the Plant Technical Requirement Manual (TRM), Section TR 3.7.4 is prepared in accordance with the guidance given in Generic Letter (GL) 90-09, Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions. GL 90-09 only provides guidance for Snubber Visual Examination Intervals and Corrective Actions.
GL-90-09 does not replace any other requirements of the OM-4, such as preservice examination (section 2.1), examination documentation (section 2.4), inservice operability testing (section 3.2), testing documentation (section 3.3), etc. Explain how these requirements are met in the proposed alternative.
- 4. On page 91 of 105 of the May 27, 2008, submittal, Alternative Examination, the licensee stated that TR 3.7.4 requirements will be utilized for the examination and testing of snubbers for preservice, inservice, and repair/replacement activities. The NRC staff was unable to find a request for relief from IWF-5200, Preservice Examinations and Tests and IWF-5400, Repair and Replacements [see requests for additional information (RAIs)
1 and 2]. If one was submitted and approved, provide the appropriate reference. If not, explain this discrepancy
- 5.
On page 91 of 105 of the May 27, 2008, submittal, Alternative Examination, the licensee stated that several referenced procedures will be utilized for snubber examination. The details of these procedures are not provided in the relief request. Explain and provide details whether and how these procedures are equivalent to or meet the requirements of Sections 2.4, 3.2, and 3.3 of the OM-4 (also see RAI 3).
- 6.
On page 92 of 105 of the May 27, 2008, submittal, second paragraph, under Alternative Examination, the licensee stated that visual examination of repaired and replaced snubbers will be performed in accordance with MPI-0-000-SNB004. Explain in detail how this examination is equivalent to the requirements of Sections 1.5.6 and 1.5.7 of OM-4.
- 7.
On page 92 of 105 of the May 27, 2008, submittal, third paragraph, the licensee stated that snubber examination and testing data will be maintained in accordance with the requirements of TR 3.7.4, the site corrective action program, SSP-3.1, and the implementing procedures. Explain how TR 3.7.4 and/or the other specified procedures meet OM Part 4, Section 3.3, Testing Documentation requirements.
- 8.
On page 93 of 105 of the May 27, 2008, submittal, Justification For The Granting of Relief, first paragraph, the licensee stated that the current program, as defined by TR 3.7.4 provides for a level of quality and safety equal to or greater than that provided by the OM and utilizes NRC guidance not incorporated into the OM Code. (1) Explain how TR 3.7.4 provides a level of quality and safety equal to and greater than that provided by OM-4. (2) Clarify and provide information regarding the statement and utilizes guidance not incorporated in the OM Code referenced by the 2001 Edition, 2003 addenda of ASME Section XI. (quotation marks added to facilitate identification)
- 9.
On Page 93 of 105, Justification for the Granting of Relief, second paragraph, the licensee stated that:
Examination, testing, repair and replacement of snubbers is currently performed in accordance with TR 3.7.4, which utilizes the guidance provided by NRC in GL 90-09. The OM Code referenced by ASME Section XI has a different basis for examination (failure mode groups) and testing plans (10 percent, 37, or 55). It is impractical to implement both plans because of the resulting duplication of examination and testing.
It should be noted that (1) GL 90-09 only provides guidance for Snubber Visual Examination Intervals and Corrective Actions. GL 90-09 does not provide guidance for testing and repair and replacement; and (2) the ASME Section XI references the use of OM-4, with OMa-1988, which is not same as OM Code. Please explain these discrepancies.
- 10.
On page 93 of 105, Justification for the Granting of Relief, fourth paragraph, the licensee stated that the maintenance procedure MPI-0-000-SNB004 provides visual examination criteria for installation of a snubber after repair or replacement. Provide details how the
maintenance procedure visual examination requirements are equal to OM-4 Section 2.3.1.2 requirements.
- 11.
On page 94 of 105, Justification for the Granting of Relief, first paragraph, the licensee stated that the training and documentation of personnel to the visual acceptance criteria, specified in the TRM implementing procedures provides an acceptable level of quality and safety. Justify this statement and explain how TRM implementing procedures visual training is equal to VT-3 training as required by the OM Code Section IWA-2300.
- 12.
On page 94 of 105, Justification for the Granting of Relief, second paragraph, the licensee stated that:
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 to require ANII [Authorized Nuclear Inservice Inspector] involvement.
A snubber program manager provides oversight of the TRM snubber program implementation for both visual examination and functional testing. The snubber program manager provides an acceptable level of quality and safety without ANII involvement in those activities.
Provide a justification for this statement with respect to the fact that the snubber program manager or person performing snubber inspection should be trained as required by IWA-2300 or alternative method IWA-2317.
- 13.
On Page 94 of 105, Justification for Granting of Relief, third paragraph, second sentence, the licensee stated that under the alternative requirements for snubbers, there will be no ASME Section XI inservice examination and testing to document in a summary report and TR 3.7.4 is implemented by surveillance instructions and maintenance instruction. Justify how these specified surveillance instructions are equivalent to the Code requirements of Section IWA-6230 and OM-4, Section 2.3, and 3.3.
- 14.
The TRM does not address the requirements of OM-4, Section 2.3.4 Inservice Examination Failure Evaluation. Explain how the proposed TRM revision meets this requirement.
Page 1 of 2 Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Mr. Ashok S. Bhatnagar Senior Vice President Nuclear Generation Development and Construction Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Vice President Nuclear Support Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Michael J. Lorek Vice President Nuclear Engineering & Projects Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. D. Tony Langley, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority 6A West Tower 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, General Manager Nuclear Assurance Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. R. G. (Rusty) West Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Ms. Beth A. Wetzel, Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority 4K Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. James E. Emens, Jr.
Supervisor, Nuclear Site Licensing Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 James B. Baptist Browns Ferry Senior Project Engineer Division of Reactor Projects, Branch 6 U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW.
Suite 24T85 Atlanta, GA 30303-8931 Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017
Page 2 of 2 Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611 Mr. Larry E. Nicholson, General Manager Performance Improvement Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Michael A. Purcell Senior Licensing Manager Nuclear Power Group Tennessee Valley Authority 4K Lookout Place 1101 Market Street Chattanooga, TN 37402-2801