ML20149H059

Submits Revised Request for Exemption from 10CFR50.55a(g)(4) to Allow Current 120-month Interval for ASME Section XI Pump & Valve Program to End on 920831.Fee Paid

ML20149H059
Person / Time
Site:	Browns Ferry
Issue date:	02/17/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8802190087
Download: ML20149H059 (5)

Text

4 TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 3740 8 SN 157B Lookout Place FEB 171988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - REVISED REQUEST FOR EXEMPTION FROM 10 CFR 50.55a(g)(4), INSERVICE TESTING (IST) PUMP AND VALVE PROGRAM INTERVAL On May 26 and 27, 1982, a meeting was held between NRC and TVA to discuss NRC concerns regarding the pump and valve testing program. As a result of this meeting, TVA agreed to revise the program and update to the most recent edition of the ASME code. The revised / updated program addressing the NRC concerns was submitted to the Commission on August 31, 1982.

By letter from L. M. Mills to H. R. Denton dated April 6, 1983, TVA requested an exemption from the requirements of 10 CFR Part 50.55a. The request involved placing the pump and valve programs for all BFN units on a concurrent inspection interval as opposed to a separate interval for each unit, with a proposed interval start date corresponding to the revised / updated program submitta) date of August 31, 1982. This exemption remains on the BFN docket but has nc,t been reviewed and approved.

I Since the 1983 exemption request was submitted, the regulations regarding such requests have changed. Therefore, TVA is hereby revising the exemption request under the provisions 10 CFR 50.12(a) from the requirements of 10 CFR 50.55a(g)(4) to allow the current 120-month interval for the ASME Section XI pump and valve program to end on August 31, 1992, which is 120 months following the revised / updated 1982 program submittal date. The exemption justification and evaluation, as required by 10 CFR 50.12, is enclosed. This exemption request applies to the ASME Section XI Pump and Valve program only and supercedes the 1983 request.

l l

AOC t i 8802190087 880217 N t.N PDR ADOCK 05000259 g5o,oD P

DCD '

An Equal opportunity Employer g 10

l

< l U.S. Nuclear Regulatory Comission The license review application fee of $150 as required by 10 CFR, Part 170.12, is enclosed. If you have any questions regarding this submittal, please telephone G. W. Morris at (205) 729-3583.

Very truly yours, TENNESSEE VALLEY AUTHORITY R.

/d)ridley, Di tor Nuclear Licensing and Regulatory Affairs Subscribed sworn to fore me on this / - da 1988

/ o IFotary Pubile My Comission Expires ~ ~

Enclosures cc: See page 3 i

i I

l l

l

bL U.S. Nuclear Regulatory Comission cc (Enclosure):

Mr. K. P. Barr, Acting Assistant Director for Inspection Programs Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects Mail Stop 7E23 Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12 P.O. Box 637 Athens, Alabama 35611 j

I I

ENCLOSURE BROWNS FERRY NUCLEAR PLANT (8FN)

JUSTIFICATION FOR THE REQUESTED EXEMPTION FROM 10 CFR 50.55a(g)(4)(ii) 10 CFR 50.12(a)(1)

In accordance with 10 CFR 50.12(a)(1), the Commission may grant exemptions from the requirements of 10 CFR 50 provided the exemptions are "authorized by law, will not present undue risk to the public health and safety, and are consistent with the common defense and security." The following is an evaluation to these standards.

Title 10 of the Code of Federal Regulations, Part 50.55a(g)(4)(ii), requires that:

(ii) In-service examinations of components, in-service tests to verify operational readiness of pumps and valves whose function is required for safety, and system pressure tests, conducted during successive 120-month inspection intervals shall comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed in paragraph (b) of this section.

According to 10 CFR 50.55a(g)(4), Browns Ferry would not be required to update its ASME Section XI pump and valve program to a later edition of the code until the end of the initial 120-month inspection interval which is March 1, 1988, for all In-service Inspection (ISI) and In-service Testing (IST) programs at BFN. However, following discussions between TVA and NRC in 1980, ,

1981, and 1982, TVA agreed to revise and update the pump and valve program to '

a later edition of the code. The revised program was submitted to the Commission on August 31, 1982, which was only five years into the initial 10-year inspection interval. The requested exemption from 10 CFR 50.55a(g)(4)(li), which applies to the pump and valve program only, would allow BFN to utilize the updated program for a full 10-year interval beginning on the revised program submittal date of August 31, 1982. The exemption meets the intent of the rule in that the pump and valve program will not exceed a 10-year period without an update to a more recent ASME Code edition.

Therefore, the requested exemption will not be presenting an undue risk to the public health and safety.

10 CFR 50.12(a)(2) l In accordance with 10 CFR 50.12(a)(2), the Commission will not consider granting an exemption unless special circumstances are present. These circumstances are defined in 50.12(a)(2)(1) through (vi) of the rule. The following evaluation describes the special circumstance related to the i requested exemption. '

50.12(a)(2)(ii) -

"Application of the regulation in the particular  ;

circumstances would not serve the underlying purpose  !

of the rule or is not necessary to achieve the underlying purpose of the rule."

i

w The underlying purpose of the rule (Section 50.55a(g)(4)(ii)) is to assure that the ASME Section XI In-service Testing (IST) program for applicable pumps and valves does not exceed a ten-year period without updating to a more recent edition of the code. The IST Program for pumps and valves is a continuous program for which operability tests are performed at intervals unrelated to the 120-month inspection interval defined in 10 CFR 50.55a(g)(4). The pump and valve program for 8FN was updated to the most recent edition of the ASME code in 1982. The program was submitted on August 31, 1982, only five years into the first 120-month inspection interval. Allowing the interval for the pump and valve program to extend to August 31, 1992, will permit the updated program to be used for a full 10-year period. At no point during the extended interval will the program exceed ten years without receiving an ASME code update. Therefore, application of the regulation in this particular l circumstance is not necessary to achieve the underlying purpose of the rule.

l The evaluation of this special circumstance shows that application of the regulation is not necessary to serve the underlying purpose of the rule.

Therefore, TVA considers the applicable provisions of 10CFR 50.12 have been met, and on this basis NRC should grant the requested exemption to 10CFR 50.55a(g)(4)(ii).

l l

.