ML18038B933
| ML18038B933 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/11/1997 |
| From: | Williams J NRC (Affiliation Not Assigned) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| TAC-M99004, NUDOCS 9708140268 | |
| Download: ML18038B933 (8) | |
Text
Hr. Oliver D. Kingsley, Jr.
President, TVA Nuclear and Chief Nuclear Officer Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 August 11, 1997
SUBJECT:
BROWNS FERRY NUCLEAR PLANT UNIT 2 -
REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUESTS TO SUPPORT THE CYCLE 9 REFUELING OUTAGE (TAC NO ~ H99004)
Dear Hr. Kingsley:
By letter dated June 4
~ 1997. the Tennessee Valley Authority submitted a
revision to the Browns Ferry Nuclear Plant Unit 2 inservice inspection program.
To complete its review, the Nuclear Regulatory Commission staff has determined additional inl'ormation,will be required.
The enclosure to this letter describes the additional information requested.
To expedite staff review, please send a copy of your response to this request directly to the NRC's contractor at the following'address:
Michael T
Anderson INEL Research Center 2151 North Boulevar d P.O.
Box 1625 Idaho Falls, Idaho 83415-2209 Your prompt response is required if the staff is to complete its review on a
schedule which can support the upcomin'g Unit 2 refueling outage.
Please call me at (301)415-1470 if you have any questions regarding this topic.
Sincerely, Original signed by Joseph F. Williams, Project Manager Project Directorate II-3 Division of Reactor Projects
- I/II Office of Nuclear Reactor Regulation Docket No. 50-260
Enclosure:
Request for Additional Information cc w/enclosure:
See net page Distribution
. Docket File PUBLIC BFN Rdg.
- JJohnson, RII DOCUMENT NAME:
G:lBFN'lM99004R.LTR To receive a copy of this document, indicate in the box:
"C" = Copy without attachment/enclosure "E" = Co y with attachment/enclosure "N" = No co y OFFICE PDII-3/PM PDII-3/LA PDII-3/0 NAME JWI Iliams 8Clayton
/
FNebdon DATE 08/ I /97 08/ (I /97 08/ il /97 9708i40268 9708ii ICIAL RECORD COPT PDR ADOCK 05000260 P
PDR II!IIII!IIII!IIIIlllllllllllllllllllll
I I
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Hr. Oliver D. Kingsley, Jr.
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Mr. 0. J. Zeringue, Sr. Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Hr. Jack A. Bailey, Vice President Engineering 5 Technical Services Tennessee Valley Authority 6A Lookout Place 1101 Harket Street Chattanooga, TN 37402-2801 Hr. C.
M. Crane, Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O.
Box 2000
- Decatur, AL 35609 General Counsel Tennessee Valley Authority ET IOH 400 West Summit Hill Drive Knoxville, TN 37902 Hr. Raul R. Baron, General Manager Nuclear Assurance and Licensing Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Hr. Hasoud Bajestani, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O.
Box 2000
- Decatur, AL 35609 Hr. Pedro Salas, Manager Licensing and Industry Affairs Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Hr. Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O.
Box 2000
- Decatur, AL 35609 Regional Administrator U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street, SW., Suite 23T85
- Atlanta, GA 30303-3415 Mr. Leonard D. Wert Senior Resident Inspector Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission 10833 Shaw Road
- Athens, AL 35611 Chairman Limestone County Commission 310 West Washington Street
- Athens, AL 35611 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, AL 36130-1701
BROWNS FERRY NUCLEAR PLANT UNIT 2 TENNESSEE VALLEY AUTHORITY RE UEST FOR ADDITIONAL INFORMATION SECOND 10-YEAR INTERVAL RE UESTS FOR RELIEF 1.0 Sco e/Status of Review The Nuclear Regulatory Commission (NRC) is responsible for the review and disposition of licensee submittals relating to inservice inspection (ISI) requirements contained in the Code of'ederal Regulations (CFR) 10 CFR 50.55a, and the American Society of Mechanical Engineers (ASME). Boiler and Pressure Vessel
- Code,Section XI.
Included within a submittal, licensees are required to provide both a regulatory basis (by citing the appropriate subsection of 10 CFR 50.55a),
and a technical discussion, to support the request.
This information is used to establish the context of each evaluation.
The staff has reviewed the available information submitted by the licensee in a letter dated June 4.
1997, requesting review and approval of ISI Relief Requests 2-SPT-9.
2-SPT-10, 2-SPT-ll. 2-SPT-12.
and 2-ISI-7 (revised) for the second 10-year ISI interval.
2.
Additional Information Re ui red A.
The licensee must state the specific paragraph of the Regulations under which each pr oposed alternative or request for relief is submitted.
The licensee should review the current submittal and provide the required reference to ensure that each proposed alternative or request for relief is evaluated in accordance with the appropriate criteria, as discussed below.
A licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii).
When submitting a proposed alternative, the licensee must specify the appropriate regulatory basis.
Under 10 CFR 50.55a(a)(3)(i).
the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in terms of quality and safety.
Under 10 CFR 50.55a(a)(3)(ii),
the licensee must show that compliance with the original r equi rement results in hardship or unusual difficultywithout a compensating increase in the level of quality and safety.
Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure.
disassembly of components solely to provide access for examinations.
and development of sophisticated tooling that would result in only minimal increases in examination coverage.
ENCLOSURE
In accordance with 10 CFR 50.55a(g)(5)(iii).
a licensee may submit a
request'or relief from ASHE Code requirements.
If a licensee determines that conformance with certain ASHE Code requirements is impractical f'r its facility. the licensee shall notify the Commission and submit.
as specified in 550.4, information to support that determination.
When a licensee determines that an ISI requirement is impractical. e.g.. the system would have to be redesigned or a component would have to be replaced to enable inspection, the licensee should cite this part of the CFR to support the criteria for evaluation.
The NRC may. giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.
Verify that the required reference is appropriately referenced in the current relief request submittal; B.
In accordance with 10 CFR 50.55a(c)(3),
10 CFR 50.55a(d)(2),,
and 10 CFR 50.55a(e)(2),
ASHE Code cases may be used as alternatives to Code requirements.
Code cases that the NRC has approved for use are published in Regulatory Guide 1. 147, Inservice Inspection Code Case Acceptability, with any additional conditions the NRC may have imposed.
When used, these Code cases must be implemented in their entirety.
ASHE approved Code cases awaiting NRC acceptance and subsequent publication in Regulatory Guide 1. 147 may be adopted only if the licensee
- requests,
. and the NRC authorizes, their use on a case-by-case basis.
For Code cases not published in Regulatory Guide 1. 147. their use may be acceptable when conditions deemed appropri.ate by the NRC are included.
As such, a licensee proposing the use of alternative(s) in currently unpublished Code Cases, must commit to certain conditions, as applicable.'or Code cases that the licensee has requested to use that are currently not endorsed in Regulatory Guide 1. 147, the NRC has determined that these Code cases are acceptable with the followi'ng conditions:
~
For Code Case N-522, Pressure Testing of'ontainment Penetration Piping, the NRC staff finds this alternative to Code requi rements acceptable only if the licensee commits to performing the pressure test at peak design pressure and implement a procedure for the detection and location of through wall flaws.
~
For Code Case N-546. Alternative Requirements for Qualification of VT-2 Visual Examination Personnel, the NRC staff finds this alternative to Code requi rements acceptable only if the licensee commits to:
- 1) Developing procedural guidelines for obtaining consistent, quality VT-2 examinations;
- 2) document and maintain records to verify the qualification of persons selected to perform VT-2 visual examinations; and 3) implement independent review and evaluation of leakage. by persons other than those that performed the VT-2 visual examinations.
When requesting to use the Code cases listed above. that have not been published in Regulatory Guide 1. 147, the licensee should confi rm that the conditions will be adopted.
C.
The licensee has also requested approval for the use of Code Cases N-498-2 and N-566.
These Code cases are currently being reviewed by the NRC and have not been approved for use as written.
As such. their use is not acceptable.
Describe the action the licensee proposes regarding the use of the subject Code cases.
D.
The licensee's submittal is unclear as to which interval the relief(s) apply.
Relief requests and/or proposed alternatives are only approved for a specific interval.
The cover letter dated June 4.
1997, states that:
"In Enclosure 1,
TVA is submitting four permanent relief'equests to the Unit 2 ASME Section XI system pressure test requirements."
and "In Enclosure 2,
TVA is submitting one permanent relief request (2-ISI-7 revised) to the BFN Unit 2 ASME Section XI inservice inspection program."
Please provide clarification regarding the reference to permanent relief requests.
and-describe the action the licensee proposes.
Additionally, in revised request for relief 2-ISI-7. the licensee failed to list the specific components for which relief is requested.
The original request fisted several Class 1 integrally welded supports, however in the revision the licensee deleted this Class 1 listing and expanded the request to include Class 2 attachment welds, while not identifying components for either Safety Class.
This relief is viewed as too generic in nature, and as such, not acceptable to the staff.
Relief will be considered on examination item specific information only.
Describe the action the licensee proposes regarding the subject submittal.
The schedule for timely completion of this review requi res that the licensee provide.
by the requested date.
the above requested information and/or clarification regarding. the Browns Ferry Nuclear Plant, Unit 2. second 10-year interval requests for relief 2-SPT-9 through 2-SPT-12, and 2-ISI-7.
h
C.
The licensee has also requested approval for the use of Code Cases N-498-2 and N-566.
These Code cases are currently being reviewed by the NRC and have not been approved for use as written.
As such. their use is not acceptable.
Describe the action the licensee proposes regarding the use of the subject Code cases.
D.
The licensee's submittal is unclear as to which interval the relief(s) apply.
Relief requests and/or proposed alternatives are only approved for a specific interval.
The cover letter dated June 4.
1997. states that:
/
"In Enclosure I, TVA is submitting four permanent relief requests to the Unit 2 ASNE Section XI system pressure test requirements."
and "In Enclosure 2,
TVA is submitting one permanent relief request (2-ISI-7 revised) to the BFN Unit 2 ASNE Section XI inservice inspection program."
Please provide clarification regarding the reference to permanent
'elief requests.
and describe the action the licensee proposes.
Additionally, in revised request for relief 2-ISI-7. the licensee failed to list the specific components for which relief is requested.
The original request listed several Class 1 integrally welded supports, however in the revision the licensee deleted this Class 1 listing and expanded the request to include Class 2 attachment welds, while not identifying components for either Safety Class.
This relief is viewed as too generic in nature.
and as such, not acceptable to the staff.
Relief will be considered on examination item specific information only.
Describe the action the licensee proposes regarding the subject submittal.
The schedule for timely completion of this review requires that the licensee provide.
by the requested
- date, the above requested information and/or clarification regarding the Browns Ferry Nuclear Plant. Unit 2. second 10-year inter val requests for relief 2-SPT-9 through 2-SPT-12, and 2-ISI-7.