ML20132D393

Forwards Third RAI Re Second 10-yr Interval Insp Program Plan for Sequoyah Nuclear Plant Units 1 & 2

ML20132D393
Person / Time
Site:	Sequoyah
Issue date:	12/13/1996
From:	Hernan R NRC (Affiliation Not Assigned)
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
TAC-M94115, NUDOCS 9612190364
Download: ML20132D393 (7)

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'Mr7.70iiver D.' K'ingsley, Jr.

} President, TVA Nuclear and December 13, 1996

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Chief Nuclear Officer

?., Tennessee Valley Authority

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-6A Lookout P1 ace L >

11101 Market Street- . . ~.

• ) ' Chattanooga, TN 37402-2801 ,

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SUBJECT:

I, REQUESTiFOR ADDITIONAL INFORMATION - SECOND 10-YEAR INTERVAL.

, s i: INSERVICE; INSPECTION PROGRAM PLAN - SEQUOYAH NUCLEAR PLANT UNITS 1 9 3, } s , ., -./AND.;2(TACNOS.1M94115ANDM94116) l 3

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h ) h De'ar[Mr. Kingsley:." ' ,

j.j i N'The* staff, wit tech $ cal . assistance from its contractor, the Idaho National

+ Engineering' Laboratory (INEL), has reviewed and evaluated the information provided by the -Tennes;see Valley Authority (TVA) in its letters dated

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n q' November 21, 1995, May 9,~1996, and September 6, 1996. As a result, we have i identified the,need for additional information in order to complete our review of the'Second 10-year Interval Inservice Inspection Program Plan for the

! Sequoyah Nuclear Plant,' Units 1 and 2. Our request for additional information'

[~ (RAI) :i s < attached. The schedule for timely completion of this review requires that TVA. provide,6 within 60 days, the above requested information. In

. addition, to expedite the review process, please also send a copy of the RAI response to INEL at the following address:

Michael T. Anderson INEL Research Center  ;

2151 North Boulevard j PO Box 1625 Idaho Falls, Idaho 83415-2209 Please contact me at (301) 415-2010 if you have any questions.

Sincerely, Original signed by Ronald W. Hernan, Sr. Project Manager Project' Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

Request for Additional Information cc w/ enclosure: See next page gggtgcmIER M Distribution: I

' Docket File PUBLIC SQN Rdg. File S. Varga Of ,1 J. Zwolinski OGC ACRS- E. Merschoff, RII T. McLellan M. Shannon, RII DOCUMENT NAME: G:\SQN\94116.RAI TO OET a copy of thle document,indcate in the boa: *C" = Copy without attachment / enclosure

• E* = Copy with attachment / enclosure .*N' = No copy 0FFICE PDII-4/PM ,) PDII-4/LA lE PDII-4/D , ) C

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NAME RHernan k W BC1ayton d a sFHebdon N _

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DATE 12/I'7 /96. 12/ je7/96 12/l'1/96

'/vOg/~f 9612190364 961213

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r PDR 'D COPY ADOCK 05000327 G PDR

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. l Mr. Oliver D. Kingsley, Jr. SEQUOYAH NUCLEAR PLANT a Tennessee Valley Authority l

CC:

Mr. O. J. Zeringue, Sr. Vice President Mr. J. T. Herron, Plant Manager Nuclear Operations Sequoyah Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority l 6A Lookout Place P.O. Box 2000 1101 Market Street Soddy Daisy, TN 37379 Chattanooga, TN 37402-2801 Regional Administrator Mr. Mark 0. Medford, Vice President U.S. Nuclear Regulatory Commission Engineering & Technical Services Region II Tennessee Valley Authority 101 Marietta Street, NW., Suite 2900 6A Lookout Place Atlanta, GA 30323 1101 Market Street Chattanooga, TN 37402-2801 Mr. Malvin C. Shannon Senior Resident Inspector Mr. R. J. Adney, Site Vice President Sequoyah Nuclear Plant Sequoyah Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority 2600 Igou Ferry Road P.O. Box 2000 Soddy Daisy, TN 37379 Soddy Daisy, TN 37379 Mr. Michael H. Mobley, Director General Counsel Division of Radiological Health Tennessee Valley Authority 3rd Floor, L and C Annex ET 10H 401 Church Street 400 West Summit Hill Drive Nashville, TN 37243-1532 Knoxville, TN 37902 County Executive Mr. Raul R. Baron, General Manager Hamilton County Courthouse Nuclear Assurance and Licensing Chattanooga, TN 37402-2801 Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Pedro Salas, Manag r Licensing and Industry Affairs }

Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Ralph H. Shell, Manager Licensing and Industry Affairs Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37379 I

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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT. UNITS 1 AND 2 ,

l DOCKET NUN 8ERS 50-327. 50-328 '

Third Reouest for Additional Information - Second 10-Year Interval Inservice Inspection Proaram Plan

1. Scope / Status of Review Throughout the service-life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the successive 120-month inspection interval comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of a successive 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and ,

addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein. The licensee for the Sequoyah Nuclear Plant, Tennessee Valley Authority (TVA), has prepared the Sequoyah Nuclear Plant, Units 1 and 2, Second 10-Year Interval Inservice Inspection (ISI) Program Plan to meet the requirements of the 1989 Edition of Section XI of the ASME Code.

The staff has reviewed the information in the Sequoyah Nuclear Plant, Units 1 and 2, Second 10-Year Interval ISI Program Plan, submitted by letter dated November 21, 1995, and the requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical. As a result of this review, a request for additional information (RAI) was prepared describing the information and/or clarification required from the licensee in order to complete the review. The licensee provided the requested information in a submittal dated May 9, 1996. After review of this information, it was determined that further clarification was required and a second RAI was sent to the licensee in a letter dated June 9, 1996. After two conference calls between the licensee and the NRC on June 25, 1996, and June 27, 1996, response to this RAI was provided in a letter dated September 6, 1996.

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i The response to the second RAI included three additional requests for i relief, one revised request or relief, and the component schedule of examinat Mns for Unit 2.

i After review of the information provided, it has been determined that t additional information is required to complete the evaluation of the j second ten-year program plan.

2. Additional Information Reauired i

! Based on the above review, the staff has concluded that additional i information and/or clarification is required to complete the review of j the ISI Program Plan:

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A. The licensee has not provided a schedule of examinations to be ,

performed in the second interval for Unit 1. In accordance with i ASME,Section XI, IWA-1310, " Components Subject to Inspection and

Testing," licensee's are required to identify components for

, inspection and testing. The selection of components for the

inservice inspection plan is subject to review by the regulatory and enforcement authorities having jurisdiction at the plant site.

IWA-1400 (c), " Owners Responsibility," requires the preparation of inspection plans and schedules, and filing of these plans and schedules with enforcement and regulatory authorities having 4 jurisdiction at the plant site. Based on these requirements, provide a schedule for each examination for Unit 1, that will be performed during the second ten-year interval. If the schedule is l not complete, provide the methodology that will be used to select welds for examination. This discussion should include the similarities and differences with the Unit 2 schedule. Also provide an estimated completion date for ~ development of this schedule.

B. Examination Categories B-G-1 and B-G-2, Items B6.180, B7.60, and B7.70 require volumetric or VT-1 visual examination. These examinations can be performed in place under tension. Provide a technical discussion explaining why Sequoyah, Unit 2 has these examinations scheduled only if an Examination Category B-L-2 or B-M-2 component is examined.

C. Requests for Relief 1-ISI-5 and 2-ISI-5 request authorization to implement Code Case N-509, Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments.

This Code Case has not been incorporated into NRC Regulatory Guide 1.147 and, therefore, NRC approval is needed for licensee implementation. The NRC is allowing the implementation of Code Case N-509 provided that the licensee commits to examine a minimum of 10%

of the total number of non-exempt integral attachments in Class 1, 2, and 3 systems. Upon review of Attachment 4 to the Sequoyah Program it appears that there are one hundred eighty Class 2 integrally welded attachments and only fourteen are scheduled for examination. Based on the conditions that the NRC has placed on the

3 use of Code Case N-509, provide an upgraded schedule of examinations for Class 1, and 2 integrally welded attachments. This schedule

~ should represent all non-exempt integrally welded attachments with a 10 percent sample being selected for examination.

D. Request for Relief ISPT-02 requests authorization to implement Code  !

Case N-416-1, Alternative Pressure Test Requirement for Welded i

Repairs or Installation of Replacement Items by Welding. This Code Case has not been incorporated into NRC Regulatory Guide 1.147 and -

1 therefore, NRC approval is needed for licensee implementation. The I NRC is allowing the implementation of Code Case N-416-1, provided the licensee commits to perform an additional surface examination on i

the root pass layer of butt and socket welds on Class 3 pressure-j retaining boundary during repair and replacement activities.

1 E. Request for Relief ISPT-04 requests authorization to implement Code I Case N-522, Pressure Testing of Containment Penetration Piping.

This Code Case has not been incorporated into NRC Regulatory Guide 1.147 and, therefore, NRC approval is needed for licensee

, implementation. The NRC is allowing the implementation of Code Case

- N-522 provided the licensee commits to 1) performing the tests at peak calculated containment pressure and 2) that the test procedures include methods for detection and location of through-wall leakage in containment isolation valves (CIVs) and pipe segments between the CIVs.

F. Request for Relief ISPT-06 requests authorization to implement Code l Case N-546, Alternative Requirements for Qualification of VT-2 '

Examination Personnel. This Code Case has not been incorporated into NRC Regulatory Guide 1.147 and, therefore, NRC approval is needed for licensee implementation. The NRC is allowing the l implementation of Code Case N-546 provided the licensee commits to:

1) develop procedural guidelines for obtaining consistent, quality VT-2 visual examinations; 2) document, and maintain records to j verify, the qualification of persons selected to perform VT-2 visual i examinations, and 3) implement independent review and evaluation of )

leakage by persons other than those that performed the VT-2 visual '

examinations.

G. Request for Relief ISPT-07 requests authorization to implement Code ,

Case N-533, Alternative Requirenents for VT-2 Visual Examination of l Class 1 Insulated Pressure-Retaining Bolted Connections. This Code Case has not been incorporated into NRC Regulatory Guide 1.147 and, therefore, NRC approval is needed for licensee implementation. The NRC is allowing the implementation of Code Case N-533, provided the licensee commits to observing a 4-hour hold time at test conditions prior to the VT-2 visual examination.

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H. Requests for Relief ISPT-03 and ISPT-08 provide different alternatives for the same Code requirement. Provide clarification as to the alternative that the licensee plans to follow in lieu of the Code.

I. The licensee must state the specific paragraph of the Regulations (10 CFR 50.55a) under which the request is submitted and provide supporting justificntion as discussed below.

The Regulations provide that a licensee may propose an alternative to CFR or Code reqiirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii). Pursuant to 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. Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without 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.

A licensee may also submit a request for relief from ASME requirements. In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for 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 inservice inspection 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 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.

Clarification is necessary for the following requests:

I.1 Requests 1-ISI-4 and 2-ISI-4 were submitted pursuant to 10 CFR 50.55a(g)(6)(i). However, the bases provided do not support impracticality. Provide appropriate references to the Code of Federal Regulations and supporting documentation for the subject requests.

I.2 Requests ISPT-1 through ISPT-8, were submitted without reference to a section of the Code of Federal Regulations. Provide appropriate references to the Code of Federal Regulations and supporting I documentation for the subject requests. l The schedule for timely completion of this review requires that the licensee provide, by the requested date, the above requested information

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5 and/or clarification with regard to the Sequoyah Nuclear Plant, Units 1  !

1 and 2, Second 10-Year Interval Inservice Inspection (ISI) Program Plan.

In addition, to expedite the review process, please send a copy of the a

RAI response to the following address:

Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 j Idaho Falls, Idaho 83415-2209 l

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