ML20046B577
| ML20046B577 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/28/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M59457, TAC-M59458, NUDOCS 9308050179 | |
| Download: ML20046B577 (9) | |
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r Robert A Fenech Vice hesdem. Sequcyah Nuclear Plant July 28, 1993 U.S. Nuclear Regulatory Commission l
ATTN: Document Control Desk r
Washington, D.C. 20555 l
Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 l
t SEQUOYAH NUCLEAR PLANT (SQN) - IN-SERVICE IN.PECTION (ISI) PROGRAM. RELIEF i
REQUEST ISI-2
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References:
1.
NRC letter to TVA dated February 7, 1991, "First 10-Year Interval Inservice Inspection Program, Revision 14 (TAC 59458) - Sequoyah Nuclear Plant, Unit 2" 2.
NRC letter to TVA dated February 7,1991, "First 10-Year Interval Inservice Inspection Program (TAC 59457) -
Sequoyah Nuclear Plant, Unit 1" t
3.
NRC letter to TVA dated April 19, 1990, "First 10-Year Interval Inservice Inspection Program (TAC 59458) -
Sequoyah Nuclear Plant, Unit 2" The purpose of this letter is to request formal approval from'the staff for two relief requests (ISI-2) contained in SQN's ISI program for Units i
1 and 2.
The subject relief requests deal with the visual examination of valve body internal pressure boundary surfaces.
Copies of ISI-2 relief requests for Units 1 and 2 are provided in Enclosures 1 and 2, i
respectively. The subject relief requests were previously-evaluated by NRC in each of two safety evaluation reports (SERs') (References 2 and 3).
In addition, editorial clarification to the Unit 2 ISI-2 relief-i requret was subsequently provided in a supplemental SER (Reference 1).
f The c 'clusions and recommendations section of the technical evaluation l
report. provided with the SERs (see page 30 in References 2 and 3) i 1
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9308050179 930728
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PDR =ADOCK 05000327 a
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U.S. Nuclear Regulatory Commission Page 2 July 28, 1993 state that relief should be granted, provided:
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"(a) one comparable valve in either unit is examined.
If a certain type of valve is not examined at either unit, relief should be requested on a case-by-case basis near the end of the interval, I
"(b ) periodic inservice testing of the valves is conducted in accordance with IWV, and
"(c) visual examination of the valves for leakage is conducted in conjunction with system leakage and hydrostatic tests under Category B-P."
l NRC determined that relief was not needed during the early stages of the i
10-year interval since relief would be considered on a case-by-case basis for specific valves toward the end of the 10-year inspection interval.
Consequently, NRC approval of TVA's ISI-2 relief request was postponed.
TVA is approaching the end of the first 10-year interval for both SQN i
l units and has satisfied Conditions a, b, and c of ISI-2.
Since TVA has complied with and completed the conditions of ISI-2 for SQN's first 10-year inspection interval, no further relief requests are required on a case-by-case basis for either unit's first 10-year ISI interval.
Accordingly, TVA requests that NRC provide approval of ISI-2 to formally document the completion of the conditions of ISI-2 for both units. The I
end of the first 10-year ISI interval for Unit 1 is September 15, 1994, and for Unit 2, February 21, 1995.
Please direct questions concerning this issue to D. V. Goodin at (615) 843-7734.
Sincerely,
&f}k - s~<
Robert A. Fenech l
Enclosures l
l ec:
see page 3 i
1 1
1 U.S. Nuclear Regulator:r Commission Page 3 July 28, 1993 Enclosures I
cc (Enclosures):
Mr. D. E. LaBarge, Project Manager U.S. Fuclear Regulatory Commission j
One Wnite Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector l
Sequoyah Nuclear Plant i
2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator
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U.S. Nuclear Regulatory Commission l
Region II l
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 l
1 1
i ENCLOSURE 1 I
J SEQUOYAH IN-SERVICE INSPECTION (ISI) PROGRAM UNIT 1 t
-t RELIEF REQUEST ISI-2 l
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SI-114.1, Attachment 3 SURVEILLANCE Revision 4 INSTRUCTIOW REQUESTS FOR RELIEF Page 4 of 48 EEOUEST FOR' RELIEF ISI-2 Compon '_nt s :
salves exceeding 4-inch nominal pipe size Class:
ASME Code Class 1 (Equivalent)
Function:
Various functions.
Inspection Recuirement: ASME Section XI, Table IWB-2500-1, examination category B-M-2, item no. B12.40, visual examination of valve internal pressure boundary surfac2s.
Basis for Religf:
During routine maintenance, visual examinations of valve body internal pressure boundary surfaces are performed an( dorumented Lnder existing plant administrative procedures. Most Class 1 valves, particularly containment isolation valves, are disassembled frequently for maintenance.
In addition, the two units at Sequoy.h Nuclear Plant will operate under similar condi:. ions.
If a valve from one of the units is disassembled for maintenance within a 10-year interval, we feel that the visual examination performed would be representative of both units and would be sufficient co satisfy the examination requirements for both units for that particular valve classification as defined in examination category B-M-2.
We conclude that if one valve in each group of valves of the same constructional design and manufacturer that perform similar functions is disassembled from either unit during the 10-year interval, the visual examination performed satisfies examination category B-M-2 rer.oirements for both units.
Alternate Inspectiof:
If a talve from a particular classifica: ion has not been disassembled as the end of the inspection interval approaches, a case-by-case study will be made to determine the practicality of disassembling a valve from one of the units solely for visual examination (determine if d:aining the vessel would be required, etc.).
If necessary, a request for relief will be issued at that time.
(Continued) 0207o/MGTSO4
r SI-114.1,' Attachment 3 SURVEILLANCE Revision 4 INSTRUCTION REQUESTS FOR RELIEF Page 5 of 48 EEOUEST FOR RELIEF ISI-2 (Continued)
Safety Evaluation Summary:
i Request for Relief ISI-2 has been approved with the following additional j
augmented requirements.
(a) one comparable valve in either unit is examined.
If a certain type of valve is not examined at either unit, relief should be requested on a
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case-by-case basis near the end of the interval,
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(b) periodic inservice testing of the valves is conducted in accordance with IWV, and (c) visual examination of the valves for leakage is conducted in conjunction with system leakage and hydrostatic tests under Category B-P.
Reference:
Memorandum from F. J. Hebdon, NRC, to 0. D. Kingsley, TVA, dated February 7, 1991 (A02 910214 009).
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B 4
ENCLOSURE 2 i
SEQUOYAH IN-SERVICE INSPECTION (ISI) PROGRAM UNIT 2 t
RELIEF REQUEST ISI-2 e
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SI-114.2, Actachment 3.
SURVEILLANCE Revision 4
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INSTRUCTION REQUESTS FOR RELIEF Page 4 of 44 REOUEST FOR RELIEF ISI-2 Components:
Valves exceeding four-inch nominal pipe size Class:
ASMI Code Class 1 (Equivalent).
1 Function:
Various functions Insnection Reauirement: ASMI Section XI, Table IWB-2500-1, examination category B-M-2, item No. B12.40, visual examination of valve internal pressure boundary surface.
Basis for Relief:
During routine maintenance, visual examinations of
_ valve body internal pressure boundary surfaces are performed and documented under Existing plant administrative procedures. Most Class 1 valves, particularly containment isolation valves, are disassembled frequently for maintenance. - In addition, the two units at Sequoyah Nuclear Plant will operate under similar conditions.
If a valve 1
from one of the units is' disassembled for maintenance i
within a ten-year interval, we feel that the visual examination performed would be representative of both -
units and would be sufficient to satisfy the
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examination requirements for both units for that
.particular valve classification as defined in examination category B-M-2.
We conclude that if one valve in ea.ch group of valves of the same constructional derign and manufacturer that perform similar functions is disassembled from i
either unit during the ten-year-interval, the visual
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examination performed satisfies examination category B-M-2 requirements of both units.
Alternate Ipspection:
If a valve from a particular classification has not been disassembled as the end of the inspection interval approaches, a case-by-case study will,be l
made to determine the practicality of disassembling a valve from one of the units solely for visual i
examination (determine if draining the vessel would be required, etc.).
If necessary, a request for relief will be issued at that time.
L (Continued) l
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i Ol95o/MGTSO4
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'SI-114.2, Attachment 3-r
-SURVEILLANCE Revision 4
?
' INSTRUCTION REQUESTS FOR RELIEF Page 5 of 44 i
i REOUEST FOR RELIEF ISI-2 (Continued) i Safety Evaluation Summary:
Request for Relief ~.3I-2 has been approved with the following additional j
augmented requirement:
l (a) One comparable valve in either unit is examined.
If a certain type of valve is not examined at either unit, relief should be requested on a case-by-case basis near the end of the interval.
(b) Periodic inservice testing of the valves is conducted in accordance with j
.IWV, and (c) Visual examination of the valves for leakage is conducted in conjunction with system leakage and hydrostatic tests under Category B-P.
Reference:
Memorandum from F. J. Hebdon, NRC, to 0. D. Kingsley, TVA, dated February 7, 1991 (A02 910211 001).
Memorandum froti Suzanne Black, NRC, to 0. D. Kingsley, TVA, dated April 19, 1990 (A02 900426 005).
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