ML19330B724

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Forwards Proposed Revision to FSAR Question 5.9A Re Inservice Insp Program.Revision Constitutes Change in Requests for Relief from ASME Section XI
ML19330B724
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 07/31/1980
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 8008050424
Download: ML19330B724 (4)


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400 Chestnut Street Tower II July 31, 1980 Director of Nuclear Reactor Regulation Attention:

Mr. A. Schwencer, Chief Light Water Reactors Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Schwencer:

In the }btter of the Application of

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Docket Nos. 50-327 Tennessee Valley Authority

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50-328 Enclosed for your review is a proposed revision to the Sequoyah Nuclear Plant Final Safety Analysis Report Question 5.9A on the inservice inspection program.

This revision is a change in the requests for relief. f rom ASME Section XI (QS.9A - Exception 2) pursuant to 10 CFR 50.55a(g)(5).

Exception 2 covers ultrasonic calibration reflectors.

TVA has recently reevaluated the basis for using 5-percent deep notches in lieu of the required side-drilled holes.

This reevalua-tion'showed that the 5-percent notches may not always be more con-servative than a 3/32" side-drilled hole.

As a result, TVA has performed additional notch versus side-drilled hole comparisons and has concluded that for some thicknesses, the 5-percent notch is not an equal or more sensitive examination. However, we believe that TVA's use of 5-percent notches is considerably more conservative than the latest approved code requirements.

The initial set of requests for relief from ASME Section XI test requirements (in response to S. A. Varga's letter to N. B. Hughes dated December-6, 1978) was transmitted to S. A. Varga by J. E.,Gilleland's

-letter dated February 14, 1979.

Amendment 67 vill incorporate this revi-sion into Question 5.9A of the Sequoyah Nuclear Plant Final Safety Analysis Report.

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. Director of Nuclear Reactor Regulation July 31, 1980 If you have any questions, please get in touch with D. L. Lam'oert at FTS 837-2581.

Very truly yours, TENNESSEE VALLEY AUTHORITY

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'l'. M. Mills, Manager Nuclear Regulation and Safety Enclosure cc:

Mr. C. E. Murphy, Chief (Enclosure)

Reactor Construction and Engineering Support Branch Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Spreet Atlanta, Georgia 30303 9

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ENCLOSURE SEQUOYAH NUCLEAR PLANT REQUEST FOR RELIEF ISI-2 Comoonents:

1) Various piping systems and 2) uncladded vessel welds in ferritic material less than 2-1/2 inches in thickness.

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1 and 2 Inspection Requirement: Ultrasonic examination of welds, paragraph T-530 of ASME Section V, Article 5, 1974 Edition, Summer 1975 Addenda as referenced in paragraph IWA-2232 of ASME Section XI 1974 Edition Summer 1975 Addenda.

Basis For Relief:

Paragraph T-533.2(a) of Article 5 of ASME Section V requires that the basic calibration block include a basic calibration hole drilled parallel to the contact surface. However, paragraph T-533.2(b) permits the use of other calibration reflectors provided equivalent responses to that from the basic calibration hole are demonstrated.

TVA currently uses 5% notches in lieu of side drilled holes. Although the use of the 5% notch cannot be shown to be equivalent in all cases to the applicable side-drilled holes, TVA considers that examinations performed to.date are technically acceptable based on the calibration requirements of paragraph III-3430 of Appendix III and Supplement 7 to the 1977 Edition, Summer 1978 Addenda of ASME Section XI.

This later code edition requires the use of 10% notches located on the I.D. and 0.D. surface for -

examination of austenitic steel and dissimilar metal welds. The calibration notches for ferritic material arg 10%t when e is less than

.312" and.104t.009't for material.312"-6" chick. TVA's use of 5% notches is considerably more conservative than the latest approved code requirements.

Paragraph T-537 of ASME Section V 1974 Edition Summer 1975 Addenda requires evaluation of all indications in excess of 20% of the reference level (distance-amplitude-correction curve). The inherent difficulties in fulfilling these requirements have been recognized and changes incorporated into the Summer 1978 Addenda to ASME e

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5 Section XI, Appendix III-4500 and INA-2232, which require recording of all indications greater than 50% DAC with an evaluation required of those indications greater than 100% DAC.

Alternate Inspection:

TVA proposes to continue the use of notches located on the I.D.-and 0.D. surfaces at a nominal depth of 5%t as reference reflectors.

However, TVA at its discretion may use notches at a nominal depth up to 10%t as permitted by the Summer 1978 Addenda of Section XI.

Further, TVA proposes to continue the detailed evaluation of all reflectors which exceed the 100% DAC and the recording.of all other indica-tions greater than 50% DAC.

TVA considers the use of strip chart recorders as an acceptable recording method for the latter requirement.

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