ML092800512
| ML092800512 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/05/2009 |
| From: | Krich R Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML092800512 (5) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 October 5, 2009 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 2 Facility Operating License No. DPR-52 NRC Docket No. 50-260
Subject:
Comments Regarding NRC Letter and Associated Safety Evaluation for the Browns Ferry Nuclear Plant, Unit 2, Inservice Inspection Program Related to Examination of Piping Weld Overlays
References:
American Society of Mechanical Engineers (ASME)Section XI, Inservice Inspection Program for the Third Ten-Year Inspection Interval
- Request for Relief 2-ISI-21, Revision 1 - Resubmittal," dated May 22, 2009
- 2. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Unit 2, The Second Ten-Year Interval Inservice Inspection Program Related to the Examination of Piping Weld Overlays (TAC No. ME1319)," dated August 12, 2009 By letter dated May 22, 2009 (Reference 1), the Tennessee Valley Authority (TVA) submitted Relief Request (RR) 2-ISI-21, Revision 1, requesting relief from the requirement specified in the American Society of Mechanical Engineers (ASME) Code,Section XI for inspecting piping overlays using ultrasonic testing in accordance with 10 CFR 50.55a(a)(3)(i) for Browns Ferry Nuclear Plant Unit 2. This relief was requested to apply to the third ten-year interval. The Reference 2 letter provided the results of the NRC review of RR 2-ISI-21, Revision 1, for Browns Ferry Nuclear Plant, Unit 2 and concluded that the proposed alternative to the requirements reflected in the Reference 1 letter provides an acceptable level of quality and safety. The Reference 2 letter also included a safety evaluation documenting the NRC review and basis for authorization of RR 2-ISI-21, Revision 1, for Browns Ferry Nuclear Plant, Unit 2.
Printed or recycled paper
U.S. Nuclear Regulatory Commission Page 2 October 5, 2009 TVA representatives have reviewed the Reference 2 letter and associated NRC Safety Evaluation. During this review, some inaccuracies were identified. These inaccuracies are identified in the comments included in the enclosure to this letter.
There are no new regulatory commitments in this letter. If you have any questions regarding this matter, please contact Dan Green at (423) 751-8423.
Respectfully, zoýý
/'-R.
M. Krich Vice President Nuclear Licensing
Enclosure:
Comments Regarding NRC Letter and Associated Safety Evaluation for Browns Ferry Nuclear Plant, Unit 2, Inservice Inspection Program Related to Examination of Piping Weld Overlays cc (Enclosure):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant
Enclosure Comments Regarding NRC Letter and Associated Safety Evaluation for Browns Ferry Nuclear Plant, Unit 2, Inservice Inspection Program Related to Examination of Piping Weld Overlays Comments Re-gardinq the NRC to TVA Transmittal Letter (Reference 2)
- 1.
The subject of the transmittal letter states, "Browns Ferry Nuclear Plant, Unit 2, The Second Ten-Year Interval Inservice Inspection Program Related to the Examination of Piping Weld Overlays (TAC No. ME1319)."
As reflected in the Reference 1 TVA letter, the Inservice Inspection Program for Browns Ferry Nuclear Plant (BFN), Unit 2, is currently in the third ten-year interval. Therefore, it is recommended that the subject of the transmittal letter be revised to read as follows.
"Browns Ferry Nuclear Plant, Unit 2, The Third Ten-Year Interval Inservice Inspection Program Related to the Examination of Piping Weld Overlays (TAC No.
ME1319)."
- 2.
The second sentence of the second paragraph of the transmittal letter states, "The NRC staff concluded that the proposed alternatives to the requirements of Section Xl, 2001 Edition as amended by 10 CFR 50.55a(b)(2)(xxiv), Appendix VIII, Supplement 11 of the ASME Code described in the licensee's letter provides an acceptable level of quality and safety."
As reflected in the Reference 1 TVA letter, the code of record for the BFN Unit 2 Third Ten-Year Inservice Inspection Interval is the American Society of Mechanical Engineers (ASME)
Code, Section Xl, 1995 Edition through 1996 Addenda. Therefore, it is recommended that the second sentence of the second paragraph of the transmittal letter be revised to read as follows.
"The NRC staff concluded that the proposed alternatives to the requirements of Section Xl,1995 Edition through 1996 Addenda as amended by 10 CFR 50.55a(b)(2)(xxiv), Appendix VIII, Supplement 11 of the ASME Code described in the licensee's letter provides an acceptable level of quality and safety."
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- 3.
The sentence in the third paragraph of the transmittal letter (on the second page) states, "This relief is authorized for the remainder of the second 10-year inservice inspection interval at Browns Ferry Unit 2, which began May 23, 2001, and is scheduled to end May 24, 2011."
As reflected in the Reference 1 TVA letter, the Inservice Inspection Program for BFN, Unit 2, is currently in the third ten-year interval. Therefore, it is recommended that the sentence in the third paragraph of the transmittal letter (on the second page) be revised to read as follows.
"This relief is authorized for the remainder of the third 10-year inservice inspection interval at Browns Ferry Unit 2, which began May 23, 2001, and is scheduled to end May 24, 2011."
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Comments Regarding the NRC Safety Evaluation (enclosed in Reference 2)
- 4.
In Section 1.0 on page 1, the last sentence of the first paragraph states, "The request is for the remainder of the second 10-year inservice inspection (ISI) interval that began on May 23, 2001, and is scheduled to end May 24, 2011."
As reflected in the Reference 1 TVA letter, the Inservice Inspection Program for BFN, Unit 2, is currently in the third ten-year interval. Therefore, it is recommended that the last sentence of the first paragraph in Section 1.0 be revised to read as follows.
"The request is for the remainder of the third 10-year inservice inspection (ISI) interval that began on May 23, 2001, and is scheduled to end May 24, 2011."
- 5.
In Section 2.0, the last sentence of the second paragraph (on page 2) states, "The code of record for the second 10-year interval for Unit 1 is the 2001 Edition through 2003 addenda of the ASME Code."
As reflected in the Reference 1 TVA letter: 1) Relief Request 2-ISI-21, Revision 1, was for BFN Unit 2, not BFN Unit 1; 2) the Inservice Inspection Program for Browns BFN, Unit 2, is currently in the third ten-year interval; and 3) the code of record for the BFN Unit 2 Third Ten-Year Inservice Inspection Interval is the ASME Code, Section Xl, 1995 Edition through 1996 Addenda. Therefore, it is recommended that the last sentence of the second paragraph of Section 2.0 be revised to read as follows.
"The code of record for the third 10-year interval for Unit 2 is the 1995 Edition through 1996 addenda of the ASME Code."
- 6.
In Section 3.2, on page 2, the first sentence of the paragraph, in referring to the code of.
record, states, "'The 2001 Edition of ASME Section Xl, as required by 10 CFR 50.55a(b)(2)(xxiv)."
As reflected in the Reference 1 TVA letter, code of record for the BFN Unit 2 Third Ten-Year Inservice Inspection Interval is the ASME Code, Section Xl, 1995 Edition through 1996 Addenda. Therefore, it is recommended that the first sentence of the paragraph in Section 3.2 be revised to read as follows.
"The 1995 Edition through 1996 Addenda of ASME Section Xl, as required by 10 CFR 50.55a(b)(2)(xxiv)."
- 7.
In Section 3.3, on page 3, the first sentence of the paragraph states, "In lieu of the requirements of ASME Section XI, 2001 Edition, Appendix VIII, Supplement 11, the PDI Program shall be used."
As reflected in the Reference 1 TVA letter, code of record for the BFN Unit 2 Third Ten-Year Inservice Inspection Interval is the ASME Code,Section XI, 1995 Edition through 1996 Addenda. Therefore, it is recommended that the first sentence of the paragraph in Section 3.3 be revised to read as follows.
"In lieu of the requirements of ASME Section Xl, 1995 Edition through 1996 Addenda, Appendix VIII, Supplement 11, the PDI Program shall be used."
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- 8.
In Section 4.0, on page 8, the second sentence of the first paragraph states, "Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the alternative proposed in Relief Request 2-ISI-21 is authorized for the second 10-year ISI interval at Browns Ferry Nuclear Plant, Unit 2, that is scheduled to end May 24, 2011."
As reflected in the Reference 1 TVA letter, the Inservice Inspection Program for BFN, Unit 2, is currently in the third ten-year interval, as reflected in the Reference 1 TVA letter.
Therefore, it is recommended that the second sentence of the first paragraph be revised to read as follows.
"Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the alternative proposed in Relief Request 2-ISI-21 is authorized for the third 10-year ISI interval at Browns Ferry Nuclear Plant, Unit 2, that is scheduled to end May 24, 2011."
References
- 1. Letter from TVA to NRC, "Browns Ferry Nuclear Plant (BFN) - Unit 2 - American Society of Mechanical Engineers (ASME)Section XI, Inservice Inspection Program for the Third Ten-Year Inspection Interval - Request for Relief 2-ISI-21, Revision 1 - Resubmittal," dated May 22, 2009.
- 2. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Unit 2, The Second Ten-Year Interval Inservice Inspection Program Related to the Examination of Piping Weld Overlays (TAC No.
ME1319)," dated August 12, 2009.
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