ML16333A390
| ML16333A390 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/21/2016 |
| From: | Bono S Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BWRVIP-25 | |
| Download: ML16333A390 (2) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 November 21, 2016 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 10 CFR 50.4 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296
Subject:
Boiling Water Reactor Vessel Internals Project (BWRVIP) - Notification of Deviation from BWRVIP-25, BWR Core Plate Inspection and Flaw Evaluation Guidelines
Reference:
Letter from Boiling Water Reactor Vessel and Internals Project (BWRVIP) to the Nuclear Regulatory Commission, "BWRVIP Utility Commitments to the BWRVIP," dated October 30, 1997 The Tennessee Valley Authority (TVA) is providing notification that the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 will not fully implement the subject guidance of BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines." In accordance with a prior agreement with the NRC and BWR utilities that are part of the Boiling Water Reactor Vessel and Internals Project (BWRVIP), participating licensees are required to provide timely notification to the NRC of a decision, by the licensee, to not fully implement the applicable BWRVIP product.
A deviation disposition (DD) has been prepared, reviewed, and approved in accordance with BWRVIP-94NP, Revision 2, "BWR Vessel and Internals Project Program Implementation Guide," and TVA internal procedures. This deviation disposition provides assurance that there are no safety implications or reliability concerns with the deviation.
This notification is being provided for information only. TVA is not requesting any specific action from the NRC.
The BFN DD concerns one item. BFN is not meeting the requirements for visual examination (EVT-1) of the core plate holddown bolts as stipulated by BWRVIP-25.
BWRVIP-25 requires that plants without core plate wedges perform EVT-1 or Ultrasonic (UT) inspections of the core plate bolts. Currently, it is not possible to perform meaningful inspections by those methods and consequently, many plants are not in compliance with the BWRVIP guidelines. The NRC became aware of this situation and indicated that in
U.S. Nuclear Regulatory Commission Page 2 November 21, 2016 accordance with BWRVIP program implementation guidance (i.e., BWRVIP-94NP) it was necessary for plants that are not in full compliance with the inspection guidance contained in BWRVIP-25 to prepare ODs to address this situation.
In order to promote standardization, in 2011 the BWRVIP developed two generic forms of the ODs: 1) an "Analysis Template" that was based on the results of a crack growth evaluation, and 2) an "Inspection Template" based on a commitment to perform VT-3 inspections. Both ODs justified postponing core plate bolt inspections until 2015 or until such time as the BWRVIP published revised guidance.
Revision 1 to "Deviation Disposition for Variance from BWRVIP-25 Guidance for Inspection of Core Plate Bolts" is being issued because the revised BWRVIP-25 core plate inspection guidance required to close this deviation was not published and submitted to the NRC in time for NRC approval before the end of 2015. BWRVIP-25 requires that core plate bolts be inspected by UT or Visual (VT) methods for plants that do not have core plate wedges installed. Currently, UT has significant limitations due to bolt geometry and VT is not able to interrogate the susceptible threaded areas of the bolting. The BWRVIP is addressing this issue and intends to develop revised guidance. Until such guidance is developed, a VT-3 exam of the bolting will be performed periodically during every refueling outage as an alternative to the required BWRVIP-25 bolt inspections.
This notification is being provided for information only. TVA is not requesting any specific action from the NRC. There are no new regulatory commitments in this letter. If you have any questions, please contact J. L. Paul, Nuclear Site Licensing Manager, at (256) 729-2636.
cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant