ML20211P445
| ML20211P445 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/06/1997 |
| From: | Williams J NRC (Affiliation Not Assigned) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| TAC-M97805, NUDOCS 9710200193 | |
| Download: ML20211P445 (7) | |
Text
m Mr. Oliv:r D. Kingstry, Jr.
October 6, 1997 Fjr:sident, TVA Nuclear cnd Chtf Nucle r Officer Tennessee Valley Authority 6A Lookout Place i
1101 Market Street Chattanooga, Tennessee 37402 2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT UNIT 3 - REQUEST FOR ADDITIONAL l
INFORMATION FOR THE INSERVICE INSPECTION PROGRAM (TAC NO.
M97805)
Dear Mr. Kingsley:
By letter dated January 22.1997, the Tennessee Valley Authority submitted a revision to the Browns Ferry Nuclear Pipnt Unit 3 inservice inspection program. To complete its review, the i
Nuclear Regulatory Commission staff has determined additionalinformation will be recuired.
The enclosure to this letter describes the additional information requested.
To expedite staff review, please send a copy of your response to this request directly to the NRC's contractor at the following address:
MichaelT. Anderson INEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Please call me at (301)415-1470 if you have any questions regarding this topic.
Sincerely,
/S/
Joseph F. Williams, Project Manager Project Directorate ll-3 Division of Reactor Projects -I/II t
Office of Nuclear Reactor Regulation Docket No. 50-296
Enclosure:
Request for Additional Information cc w/ enclosure: See next page
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,j NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D.C. 3066Ho01 October 6, 1997 g.,,...,
Mr. Oliver D. Kingsley, Jr.
President,1VA Nuclear nnd Chief Nuclear Officer Tennessee Valley Authority BA Lookout Place 1101 Market Street C attanooga, Tennessee 37402 2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT UNIT 3 REQUEST FOR ADDITIONAL INFORMATION FOR THE INSERVICE INSPECTION PROGRAM (TAC NO.
M97805)
Deat Mr. Kingsley:
By letter dated January 22,1997, the Tennessee Valley Authority submitted a revision to the Browns Ferry Nuclear Plant Unit 3 inservice inspection program. To complete its review, the Nuclear Regulatory Commission (NRC) staff has determined additional hformation will be tired. The enclosure to this letter describes the additlanalinformation requested.
1 (pedite staff review, please send a copy of your response to this request directly to the Nkv's contractor at the following address:
MichaelT. Anderson INEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, !daho 83415 2209 Please call me at (301)4151470 if you have any questions regarding this topic.
Sincerely, lf
,E oseph F. Williams, Project Manager j
Project Directorate ll 3 Division of Reactor Projects - 1/ll Ohhe of Nuclear Reactor Regulation Docket No. 50-296
Enclosure:
Request for AdditionalInformation cc w/ enclosure: See next page I
Mr. Oliver D. Kingsley, Jr.
BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority cCl Mr. O. J. Zeringue, Sr. Vice President Mr. Mark J. Burzynski, Managar Nuclear Operations Nuclear Licensing Tennessee Valley Authority Tennes5n Valley Authority 6A Lookout Place 4J Blue Ridge 1101 Market Street 1101 Marktt Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 Mr. Jack A. Bailey, Vice President Mr. Timothy E. Abney, Manager Engineering & Technical Services Licensing and Industry Affairs Tennessee Valley Authority Browns Ferry Nuclear Plant 6A Lookout-Place Tennessep Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Decatur, AL 37402-2801 Mr. C. M. Crane, Site Vice President Regional Administrator, Region !!
Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Comission Tennessee Valley Authority 61 Forsyth Street, SW., Suite 23185 P.O. Box 2000 Atlanta, GA 30303-3415 Decatur, AL 35609 Mr. Leonard D. Wert General Counsel Senior Resident inspector Tennessee Valley Authority U.S. Nuclear Regulatory Comission ET 10H Browns Ferry Nuclear Plant 400 West Sumit Hill Drive 10833 Shaw Road Knoxville, TN 37902 Athens, At 35611 Mr. Raul it. Baron, General Manager State Health Officer Nuclear Assurance Alabama Dept. of Public Health Tennessee. Valley Authority 434 Monroe Street 4J Blue Ridge Montgonery, AL 35130-1701 1101 Market Street Chattanooga, TN 37402-2801 Chairman Limestone County Comission
- Mr. Karl W. Singer, Plant Manager 310 West Washington Street Browns Ferry Nuclear Plant Athens, AL 35611 Tennessee Valley Authority P.O. Box 2000 Decatur, AL-35609 l
d
4 i
BROWNS FERRY NUCLEAR PLANT. UNIT 3 TENNESSEE VALLEY AUTHORITY
~
REQUEST FOR ADDITIONAL INFORMATION l
SECOND 10 YEAR INSERVICE INSPECTION INTERVAL PROGRAM PLAN. REVISION 7
- 1. Scoce/ 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) Boller 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 the ASME Code Section XI, Rules forInservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the ccmponents. This section of the regulations also requires that inservice examinations of compnents and system pressure tests conducted during the succcssive 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, Tennessee Valley Authority, has prepared the Browns Ferry Nuclear Plant, Unit 3, Second 10-Year IntervalInservice Inspection (ISI) Program Plan, Revision 0, to meet the requirements of the 1989 Edition of Section XI of the ASME Code, As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief, the licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination, The staff has reviewed the available information in the Browns Ferry Nuclear Plant, Unit 3, Second 10-Year IntervalInservice Inspection (ISI) Program Plan, Revision 0, submitted by letter dated January 22,1997, and the requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical,
- 2. AdditionalInf0fmation Reauired Based on the above review, the staff has concluded that additionalinformation and/or clarification is required to complete the review of the ISI program plan. The licensee is requested to:
A.
Provide boundary diagrams for all ASME Code Class 1, Class 2, and Class 3 systems, These diagrams should define the ISI boundaries for all systems in the Browns Ferry Nuclear Plant, Unit 3, Second 10-Year IntervalInservice Inspection (ISI) Program Plan.
B.
Provide isometric and component drawings showing all of the Code Class 1,2, and 3 piping welds, components, and supports.
i i
2 C.
Address the degree of compliance with augmented examinations (other than those addressed in the program submittal) that have been established by the NRC vehen added assurance of structural reliability is deemed necessary, Examples of documents that address augmented examinations are:
(1) Branch Technical Position MEB 31, "High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment"; and (2) %gulatory Guide 1.150, Ultrasonic Testing of Reactor Vessel Welds Dun'ng Preservice and Inservice Examinations.
Discuss these and any other augmented examinations tL3!.my have been incorporated ir> the Browns Ferry Nuclear Plant, Unit 3, Second 10-Year IntervalIrw:rvice Inspection (ISI) Program Plan, Revision O.
D.
Discuss any plans or schedules for the examination of a sample of welds excluded from examination by Section XI based on wall thickness. Paragraph 10 CFR 50.55a(b)(2)(iv) requires that certain ASME Code Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems be examined. Portions of these systems are critical to the safe shutdown of the plant and should not be completely excluded from inservice volumetric examination based on piping wall thickness. Other utilities / licensees have deemed it technically prudent to perform augmented volumetric examinations on welds in those portions of thin wall pipe lines excluded from examination by the Code. A 7%% sample is consistent with the extent of examination required for Class 2 piping.
E.
Provide a list of the ultrasonic calibr:2 tion standards being used during the second 10-
. year interval ISI at Browns Ferry Nuclear Plant, Unit 3. The list should include the calibration standard identifications, material specifications, and sizes, and identification of the piping and/or components to which each caiibration standard applies.
F.
Verify that the NDE qualification program will be in compliance with Appendix Vll. (On Page 26 of 88, item 7.2.3, the licensee stated that NDE personnel certification will be in accordance with IWA 2300.)
G.
The licensee must state the specific paragraph of the Regulations under which each proposed alternative or request for relief is submitted. The licensee should review the current submittals and provide the required references to ensure that each proposed alternative or request for relief is evaluated in accordance with the appropriate criteria, as discussed below.
A licensee may propose an attemative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii). When submitting a proposed alternative, the licensee must specify the appropriate regulatory basis. Under 10 CFR 50.55a(a)(3)(l), the proposed attemative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original
3-requirement in terms of quality and safety. Under 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 radiat!on exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimat increases in examination coverage.
In accordance with 10 CFR 50.55a(g)(5)(iii), a licensee may submit a request for relief from ASME Code requirements. If a licensee determines that conformance with certain ASME Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in 950.4, information to support that determination. When a licensee determines that an ISl requirement is impractical, e.g.,
the system would have to ba redesigned or a component would have to be replaced to enable inspection, the licensee should cite this part of CFR to support the criteria for evaluation. The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement. Verify that the required references are appropriately referenced in the current relief request submittals.
H.
In accordance with 10 CFR 50.55a(c)(3),10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASME Code cases may be used as attematives to Code requirements. Code cases that the NRC has approved for use are published in Regulatory Guide 1.147, inservice inspection Code Case Acceptability, with any additional conditions the NRC may have imposed. When used, these Code cases must be implemented in their entirety. ASME appre ved Code cases awaiting NRC acceptance and subsequent publication in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case by-case basis.
For Code Cases not published in Regulatory Guide 1,147, their use may be acceptable when conditions deemed appropriate by the NRC are included. As such, a licensee proposing the use of alternative (s)in currently unpublished Code Case (s), m,ust commit to certain conditions, as applicable.
For Code cases that the licensee has requested to use that are currently not endorsed in Regulatory Guide 1,147, the NRC has determined that these Code cases are 1
acceptable with the following conditions:
For Code Case N 522 Pressure Testing of Containment Penetration Piping, the NRC staff finds this alternative to Code requirements acceptable o,1ly if the licensee commits to performing the pressure test at peak design pressure and implement a procedure for
)
the detection and location of through wall flaws.
For Code Case N 546, Attemative Requirements for Qualification of VT 2 Visual Examination Personnel, the NRC staff finds this alternative to Code requirements acceptable only if the licensee commits to: 1) developing procedural guidelines for obtaining consistent, quality VT 2 visual examinations; 2) document and maintain records to verify the qualification of persons selected to perform VT 2 visual i
l A
4 examinations; and 3) implement independent review and evaluation of leakage by persons other than those that performed the VT 2 visual examinations.
When requesting to use the Code cases listed above, that have not been published in Regulatory Guide 1.147, the Pcensee should confirm that the conditions will be adopted, l.
The licensee has requested approval for the use of Code Cases N 498 2, N 54 and N 566. These Code cases are currently being ieviewed by the NRC and have not been approved for use as written. As such, their use is not endorsed. Therefore, the licensee should review the current submittals associated vilth these Code cases and consider withdrawal. Describe the action the licensee proposes regarding the use of the subject Code cases.
J.
In Request for Relief 3 ISl 4, the licensee requested relief from the removal of component support clamps that interfere with integral attachment weld examinations.
This relief is viewed as a generic relief that is not acceptable to the staff. Relief will be j
considered based on examination area specific information only. Describe the action the licensee proposes regarding the subject submittal.
K.
The staff has reviewed relief request 31S12 and technical specification (TS) 3/4.6.H.
and has concluded that sufficient Information was not provided for the staff to complete its review. TS 3/4.6.H addresses plant operating requirements for snubbers, but does not address all ASME Code requirements. Information required includes procedures and instructions, personnel qualifications, documentation and record keeping, inspection and testing results, use of authorized nuclear inservice inspectors, and preparation and filing of Code-required repair and replacement forms and summary reports.
The staff requests that the licensee provide a comprehensive revision of this relief request providing sufficient justification for relief from the ASME Code Section XI requirements for ISI and testing of snubbers. The NRC staff suggests the licens6e refer to a relief request on this topic recently approved for the Watts Bar plant.
L Verify that there are no relief requeste in addition to those submitted. If additional relief requests are required, the licensee should submit them for staff review.