ML18039A773
| ML18039A773 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/03/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML18039A772 | List: |
| References | |
| NUDOCS 9905100092 | |
| Download: ML18039A773 (10) | |
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l UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATIONBY THE OFFICE OF NUCLEAR REACTOR REGULATION SECOND 10-YEAR INTERVALINSERVICE INSPECTION PROGRAM PLAN RELIEF FROM ASME BOILER AND PRESSURE VESSEL CODE SECTION XI RE UIREMENTS - RELIEF RE UEST NO. 3-ISI-2 TENNESSEE VALLEYAUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 3 DOCKET NUMBER 50-296
1.0 INTRODUCTION
The Code of Federal Regulations, 10 CFR 50.55a, requires that inservice inspection (ISI) of certain American Society of Mechanical. Engineers (ASME) Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (Code) applicable Edition and Addenda, except where relief has been requested
- by the licensee and granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a(g)(6)(i), (a)(3)(i), or (a)(3)(ii). In order to obtain authorization or relief, the licensee must demonstrate that (1) conformance is impractical for its facility, (2) the proposed alternative provides an acceptable level of quality and safety, or (3) compliance would result in hardship or unusual difficultywithout a compensating increase in the level of quality and'safety.
10 CFR 50.55a authorizes the Commission to grant relief from ASME Code requirements or to approve proposed alternatives upon making the. necessary findings. The U. S. Nuclear Regulatory Commission (NRC) staff findings, with respect to granting the requested relief or authorizing the proposed alternative requirements for, snubber inservice examination, test, and repair/replacement activities, are contained in this Safety Evaluation (SE).
Relief Request 3-ISI-2, initiallyproposed by Tennessee Valley Authority (TVA)letter dated January 12, 1997, was revised by TVAletter October 29, 1998, in response to the staff's request for additional information (NRC letter dated October 6, 1997). TVA proposes to use alternate requirements in.accordance with its Technical Requirement Manual (TRM) TR 3.7.4, "Snubbers."
TVA's inservice inspection (ISI) program relief request is based on the 1989 Edition of the ASME Code,Section XI, Article IWF-5000 requirements, which defers snubber ISI requirements to the first Addenda to ASME/ANSI OM-1987 Edition, Part 4, published in 1988 (OMa-1988 Part 4).
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PDR ENCLOSURE
l 4I 2.0 RELIEF RE VEST 3-ISI-2 r
TVAletter dated October 29, 1998, requested relief from the ASME Code, Section XI~ Article IWF-5000, Subarticles IWF-5300 and,lWF-5400; IWA-6230 and 2110 for Code Class snubbers that require examination, testing, and repair or replacement be performed in accordance with the ASME/ANSI OM-'1987,. Part 4.
Specifically, TVA requested relief: from the requirements of.ASME Code,Section XI; (1) Subarticle-IWF-5300(a) and (b), and implied ASME/ANSI OMa-1988, Part 4, Sections 2.3, "Inservice Examination," 2.4, "Examination Documentation," 3.2, "Inservice Operability Testing," and 3.3, "Testing Documentation;" (2) Subarticle IWF-5400, ASME/ANSI OMa-1988, Part 4', Sections 1.5.6, "Snubber Maintenance or Repair," and 1.5.7, "Snubber Modification and Replacement," (3) Subsubarticle IWA-6230, "Summary Report," and (4) Subsubarticle IWA-2110(a)(5) and (c), "Duties of the Inspector."
3.0 BASIS FOR RELIEF as statedb TVA ASME Section XI Class 1, 2 and 3 equivalent snubbers are examined and tested in accordance with Browns Ferry Nuclear (BFN) Plant Technical Requirements Manual (TRM), TR 3.7.4.
BFN TR 3.7.4 is prepared in accordance with the guidance given by NRC in Generic Letter 90-09. The scope for. snubbers examined and tested in accordance with TR 3.7.4 is not.limited by line size or other applicable code exemptions and includes a numerically greater population of snubbers than the Section XI program.
Examination and.testing of the snubbers,in accordance with both ASME Section XI and the plant TRM would result in a duplication of effort utilizing different standards and require the preparation of a separate program and associated procedures.
This would result in additional cost and unnecessary radiological exposure:
In addition, the personnel performing snubber visual examinations also would be required to be certified in accordance with the American Society of Nondestructive Testing (ASNT)
SNT.-TC-1A "Personnel Qualification and Certification in Nondestructive Testing," which is an additional certification as compared to the task training qualification, required to perform the TRM 3.7.4 required. examinations and testing of snubbers.
The existing TRM program for examination and testing of snubbers was promulgated and accepted by NRC.
The implementation of OM-1987,.Part 4 would require BFN to initiate a snubber examination and:testing program that is more complicated and expensive to perform, without a compensating increase in the level of quality and safety.
4.0 EVALUATION TVAproposes that snubber examination and testing during the second ISI interval of commercial plant operation will be performed in accordance with the requirements in TRM TR 3.7.4, "Snubbers."
The areas, inclusive of the pins back to building structure and to the component/piping being supported, will remain in the ASME Section XI examination boundary.
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P TVA proposes, as an alternative to the ASME Code,Section XI, Subarticle IWF-5300(a) and (b) requirements as defined in ASME/ANSI OM-1987, Part 4, to perform the snubber inservice examination and testing in accordance with the BFN TRM TR 3.7.4.
IWF-5300(a) covers snubber visual inspection requirements and IWF-5300(b) covers snubber functional test requirements.
The snubber visual inspection requirements of TR 3.7.4 are based on the provisions of Generic Letter (GL) 90-09. The staff developed GL 90-09, in part, to reduce unnecessary radiological exposure to plant personnel during snubber visual inspections.
To verify that a snubber. can operate within specific performance limits, licensees typically perform functional testing that involves removing the snubber and testing it on a specially designed test stand.
Functional testing provides a 95 percent confidence level that 90 percent to100 percent of the snubbers.operate within the specified accepted limits.
The performance of visual examinations is a separate process that complements the functional program and provides additional confidence in.snubber operability. GL 90-09 provides an alternate schedule. for snubber visual inspections that maintains the same confidence level as the existing inspection intervals and allows for inspections and corrective actions during plant outages.
The staff determined that the visual inspection schedule of GL 90-09 is an acceptable alternative to the ASME Code requirements and encouraged licensees to change their technical specifications to be consistent with this guidance.
The-snubber visual inspection and functional test requirements of TR 3.7.4 are consistent with the Section XI, Subarticles IWF-5300(a) and (b) requirements as defined in ASME/ANSI OM-1987, Part 4 and the'alternative allowed by GL 90-09.
TVA proposes, as an alternative to the ASME Code,Section XI, Subarticle IWF-5300(a) that requires VT-3 certification for personnel performing snubber visual examinations, to use the TRM program training qualifications.
Personnel performing the TRM visual examinations are "process qualified" to perform the examinations and testing in accordance with the TRM implementing instructions and procedures.
The training includes a visual test associated with face mask fit, and "Visual Acuity" requirements.
This proposed alternative to the Code-required certification including the Visual Acuity requirements, provides an acceptable level of quality and safety.
As an alternative to the ASME Code,Section XI, Subarticle IWA-6230 requirements for filing snubber examination and test summary reports with the enforcement and regulatory authorities having jurisdiction at the plant site, and as an alternative to OM-1987, Sections 2.4 and 3.4 requirements for examination and test documentation respectively, TVA proposes to use TR 3.7.4. The procedures and instructions implementing the TR 3.7.4 requirements are written and approved in accordance with the TVANuclear Quality Assurance (QA) Program.
TVA's proposed alternative to maintain and control documentation as QA records available onsite for review and.inspection provides an acceptable level of quality and.safety.
In addition, as an alternative to certain ASME Code,Section XI, Subsubarticle IWA-21]0(a)(5) and (c) requirements involving the authorized nuclear inservice inspection (ANII)duties to verify that required visual examinations and tests have been performed and the results recorded, TVA proposes to use the BFN TRM Snubber Program.
In the BFN TRM Snubber Program, the ANIIwill not be involved in both the TRM'visual examinations performed in the
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alternate VT-3 visual examinations as required by IWA-2110(a)(5), or the TRM functional testing performed as required by IWA-2110(c). The TRM snubber program is directed by a designated snubber program manager (SPM) who willprovide oversight of the snubber program. implementation for both visual examination and functional testing.
The SPM responsibilities include both review and evaluation of visual examination and functional test data to ensure that the TRM requirements are met. ANIIinvolvement in other inservice repair and replacement snubber activities, as required by IWA-2110(g) and (h) and implemented by BFN's Repair and Replacement Program, willbe maintained.
The staff finds that TVA's, proposed alternative to use the TRM for snubber visual and functional testing without involving the ANIIin these activities provides an acceptable level.of quality and safety.
4.0 CONCLUSION
S.
The staff finds that TVA's proposed alternative to certain of the ASME Code Section XI requirements for inservice inspection of snubbers as contained in the revised relief request submitted by TVAletter dated October 29, 1998, and evaluated herein provides. an acceptable level of quality and safety.
Therefore, the licensee's request is authorized pursuant to 10 CFR 50.55a (3)(a)(i).
,Principal Contributor: L. Raghavan Date:
Nay 3, 1999
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Mr. J. A. Scalice Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT CC:
Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Jack A. Bailey, Vice President Engineering 8 Technical Services Tennessee Valley Authority 6A'Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Karl W. Singer, Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000
'Decatur, AL 35609 General Counsel Tennessee Valley Authority ET 10H 400 West Summit Hill Drive Knoxville, TN 37902 Mr. N. C. Kazanas, General-Manager Nuclear Assurance Tennessee Valley Authority 5M Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Robert G. Jones, Plant Manager Browns Ferry'Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Mark J. Burzynski, Managar Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Timothy.E.,Abney, Manager Licensing and Industry Affairs
,Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL35609 Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns'Ferry Nuclear Plant 10833 Shaw Road Athens, AL35611 State Health Officer Alabama Dept. of Public Health 434 Monroe Street Montgomery, AL36130-170I Chairman Limestone County Commission 310 West Washington Street Athens, AL'5611
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