ML18033A773

Responds to NRC 890301 Ltr Re Unresolved Items Noted in Insp Repts 50-259/89-05,50-260/89-05 & 50-296/89-05.Corrective Actions:Tva Will Replace Stainless Steel RWCU Piping Outside Drywell During Unit 2 Cycle 6 Outage,Per Generic Ltr 88-01

ML18033A773
Person / Time
Site:	Browns Ferry
Issue date:	05/22/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-01, GL-88-1, NUDOCS 8906010181
Download: ML18033A773 (11)

Text

AC CELE PATED Dl STK Bt 'Tl 04 DEMON /TRACTION SY~

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8906010181 DOC.DATE: 89/05/22 NOTARIZED: NO DOCKET

.ACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION RAY,M.J. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 890301 50-259/89-05,50-260/89-05 ltr &

re violations noted in Insp Repts 50-296/89-05. D DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR Q ENCL TITLE: General (50 Dkt)-Insp Rept/Notice of Violation g SIZE:

Response 8 NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black 05000259 1 R.Pierson, ~

1 Copy each to: S.Black,D:M.Crutchfield,B.D.Liaw, 05000260 R.Pierson,B.Wilson 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 5 R.Pierson,B.Wilson D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD 1 1 GEARS,G 1 1 TERNAL ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DEST DIR 1 1 NRR/DLPQ/PQEB 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 = NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE BERMAN,J 1 1 OGC/HDS2 1 1 02 1 1 RGN2 FILE 01 1 1 R

EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 I NOTES 5 5 NOrE 'rO ALL "RIDS" RZCIPrnm PEZAS HELP US TO REDUCE HASTE! CGNrACZ 'IHE DOCUMEtir CGHrBOL DESK, ROOYi Pl-37 (EÃI'. 20079) K) ELQGZATE YOUR NAME HKH DIPIRI33VTICN LISTS K)R DXKlMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 29

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 3740t 5N 1578 Lookout Place MAY f' 1999 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROHNS FERRY NUCLEAR PLANT (BFN) TVA'S RESPONSE TO NRC INSPECTION REPORT (IR) NO. 89-05. ON GENERIC LETTER (GL) 88-01

References:

1. NRC letter to 0. D. Kingsley, Jr., dated March 1, 1989, "NRC Inspection Report Nos. 50-259/89-05, 50-260/89-05, 50-296/89-05."

2. TVA letter to NRC dated January 12, 1989, "Browns Ferry Nuclear Plant Unit 2 Response to Request for Additional Information on the Intergranular Stress Corrosion Cracking (IGSCC) Program."

In the above referenced IR, NRC provided TVA with the results of its inspection on GL 88-01, "NRC Position on IGSCC in BHR Austenitic Stainless Steel Piping." Hithin the scope of this inspection, NRC inspector J. L. Coley found no violations or deviations, but did identify two unresolved items of concern. These unresolved items and TVA's response are contained in enclosure l.

Enclosure 2 contains a complete list of commitments made in this submittal'f you have any questions, please telephone Patrick P. Carier, BFN,'Site Licensing, (205) 729-3570, Very truly yours, TENNESSEE VALLEY AUTHORITY t

Manage(, Nuclear Licensing and Regulatory Affairs Enclosures cc: See page 2 peOl..t.t 3, 01 1

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U.S. Nuclear Regulatory Commission MAY 291999 cc (Enclosures):

Hs. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Nhite Flint, North

.11555 Rockville Pike Rockville, Maryland 20852 Hr. B. A. Hilson, Assistant Director for Inspection Programs TVA Projects Division U.S.- Nuclear Regulatory Commission Region II 101 Marietta Street, NN, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

ENCLOSURE 1 NRC UNRESOLVED ITEM'NO. 1 NRC Position:

TVA's response to GL 88-01 is inadequate in that TVA has not addressed the 6 inch, 5 inch or 4 inch diameter reactor water cleanup (RHCU) system

=piping outside the drywell penetrations. 'his piping operates at temperatures far exceeding 200'F and is nonconforming stainless steel.

On January 25, 1989, NRC issued Generic Letter 88-01, "NRC's Position on Intergranular Stress Corrosion Cracking in BHR Austenitic Stainless Steel Piping. This letter also forwarded NUREG-0313, Revision 2, "Technical Report on Material Selection and Processing Guidelines for BHR Coolant Pressure Boundary Piping. "NUREG 0313, REV. 2, describes the technical bases for the staff positions on materials', processes and primary coolant chemistry to minimize and control intergranular stress corrosion cracking (IGSCC) problems." The purpose of the GL 88-01 was to seek information regarding implementation of the new staff positions covering -these technical areas.'he Generic Letter applied to all boiling water reactor (BHR) piping made of austenitic stainless steel that was four inches or larger in nominal diameter and contained reactor coolant at a temperature above 200'F during power operation regardless of code classification. It also applied to reactor vessel attachments and appurtenances such as jet pump instrumentation penetration assemblies and head spray and vent components.

TVA response:

At the time of the inspection, the term "regardless of code classification" was interpreted by TVA as meaning that only piping that had a code classification was to be included within the scope of GL 88-01. The RHCU piping outside the drywell is non-code class piping, meaning it has no code classification.

Thi.s piping is also nonsafety related and has automatic isolation capability. There is a leak detection system installed on the RHCU piping outside the drywell. This system will close the RHCU isolation valves within 30 seconds of leak detection. Surveillance Instruction 4.7.D.l;a-1 requires testing of the 30 second closure response every three months whenever the system is required to be operable. The isolation valves on the RHCU are leak tested each outage per Surveillance Instruction 4.7.A.2.,g.3/69. These valves have a record of good performance with leak rate tests usually indicating less than 0,05 leakage per hour. The isolation valves on the RHCU system are tested ft'ir every three months when the system is operable by cycling the valves closed per Surveillance Instruction 4.7.DE 1.a-l. Equipment necessary for safe unit shutdown has been qualified to operate under conditions created by a RHCU line break. This qualification was conducted as part of the Browns Ferry Environmental Qualification Program. Based on the aforementioned information, there is no impact on'safety by operating the RHCU piping for one cycle in its present condition .

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Page 2 Following the receipt of reference 1, a TVA/NRC teleconference was held to discuss the RHCU piping issue. The term non-code class was defined by NRC to include all piping both code class and non-code class. As a result of this interpretation TVA presented a plan to NRC in an April 20, 1989 meeting held at Rockville, MD. The plan which was verbally accepted by NRC, as stated in reference 2, is as follows:

'TVA will replace the four inch and larger, stainless steel, RNCU piping located outside of the drywell during BFN's unit 2 cycle six outage. No inspection of the subject RHCU piping is required prior to unit-2 restart. TVA will also replace the four inch and larger stainless steel, RHCU piping located outside of the drywell before restart of units 1 5 3.

NRC UNRESOLVED -ITEM NO. 2 NRC Position:

TVA has been requested to address in their response why 71 welds were identified to be examined on unit 2 in both of their letters of response and only 66 welds are scheduled to be examined.

TVA Response:

t TVA discovered that only 66 welds had not received post-IHSI examination, during a detailed review of weld inspection data. In a teleconference with Gerry Gears of NRC on December 6, 1988, TVA informed NRC of the changes in the number of welds to be examined.

In our submittal, dated January 12, 1989, TVA committed to initiate a

.post-IHSI weld examination project that would examine the remaining unit 2 welds that have not received post-IHSI inspection and to provide the results of our inspection, to NRC, before restart. At Mr. Coley"'s exit meeting, February 2, 1989, he was informed of the teleconference with Gerry Gears and TVA's plans to revise the GL 88-01 response.

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ENCLOSURE 2 4

The following is a list of commitments made in this submittal:

1. TVA will re P lace the four inch and a r ge r , stainless steel, RHCU 1

piping located outside of the drywell during BFN's unit 2 cycle six outage.

2. TVA will replace the four inch and larger, stainless steel, RHCU piping located outside of the drywell before restart of units 1 & 3.

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