ML23332A004

NRR E-mail Capture - Request for Additional Information Related to Proposed Revised Alternative 0-ISI-47

ML23332A004
Person / Time
Site:	Browns Ferry
Issue date:	11/27/2023
From:	Kimberly Green Plant Licensing Branch II
To:	Eckermann J Tennessee Valley Authority
References
L-2023-LLR-0034
Download: ML23332A004 (4)

Text

From: Kimberly Green Sent: Monday, November 27, 2023 2:55 PM To: Eckermann, Jeremy Beau

Subject:

Request for Additional Information Related to Proposed Revised Alternative 0-ISI-47 (EPID L-2023-LLR-0034)

Attachments: BFN BWRVIP Alt 0-ISI-47 Final RAI.pdf

Dear Mr. Eckermann,

By letter dated July 3, 2023, (Agencywide Documents Access and Management System (ADAMS), Accession No. ML23184A142), Tennessee Valley Authority (TVA), requested an alternative (Revised Request for Alternative 0-ISI-47) to certain requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), for the third, fifth and fourth 10-year inservice inspection (ISI) intervals for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified areas where additional information is needed to complete its review. A draft request for additional information (RAI) was previously sent to you via email on November 15, 2023.

TVA did not request a clarification call. However, TVA requested 45 days to respond to the request due to the holidays. Therefore, a response to the attached RAI is requested by January 11, 2024.

The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please me at (301) 415-1627 or via email at Kimberly.Green@nrc.gov.

Sincerely, Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Hearing Identifier: NRR_DRMA Email Number: 2317

Mail Envelope Properties (DM6PR09MB5462B344933A55B4886C75808FBDA)

Subject:

Request for Additional Information Related to Proposed Revised Alternative 0-ISI-47 (EPID L-2023-LLR-0034)

Sent Date: 11/27/2023 2:54:39 PM Received Date: 11/27/2023 2:54:00 PM From: Kimberly Green

Created By: Kimberly.Green@nrc.gov

Recipients:

"Eckermann, Jeremy Beau" <jbeckermann@tva.gov>

Tracking Status: None

Post Office: DM6PR09MB5462.namprd09.prod.outlook.com

Files Size Date & Time MESSAGE 1535 11/27/2023 2:54:00 PM BFN BWRVIP Alt 0-ISI-47 Final RAI.pdf 86333

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION

PROPOSED REVISED REQUEST FOR ALTERNATIVE 0-ISI-47

FOR THE THIRD, FIFTH AND FOURTH 10-YEAR INSERVICE INSPECTION INTERVALS

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3

TENNESSEE VALLEY AUTHORITY

DOCKET NOS. 50-259, 50-260, AND 50-296

EPID L-2023-LLR-0034

==

Introduction:==

By letter dated July 3, 2023, (Agencywi de Documents Access and Management System (ADAMS), Accession No. ML23184A142), Tennessee Valley Authority (TVA), submitted Proposed Revised Request for Alternative 0-ISI-47 (Proposed Alternative) to certain requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), for the third, fifth and fourth 10-year inservice inspection (ISI) intervals for the Browns Ferry Nuclear Plant (Browns Ferry), Units 1, 2, and 3, respectively. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.55a(z)(1), TVA requested approval to implement alternative Boiling Water Reactor Vessel and Internals Program (BWRVIP) Guidelines in lieu of ASME Code Section XI Table IWB-2500-1 Examination Category B-N-1 and B-N-2 requirements.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the request and has identified areas where it needs additional information to support its review. In order for the NRC staff to determine if the proposed alternative may be authorized pursuant to 10 CFR 50.55a(z)(1), the staff requests the following additional information.

Background:

Nuclear Energy Institute (NEI) 03-08, Guide line for the Management of Materials Issues, Revision 4 (ML20315A536) provides the industrys process for determining when an updated industry inspection and evaluation guideline may be implemented by an industry licensee without NRC prior approval of the guideline. TVA proposes to use BWRVIP-48, Revision 2, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines, as the basis for inspecting reactor pressure vessel interior attachment welds in lieu of applicable ASME Section XI, Examination Category B-N-2 requirements or the most recent NRC-approved revision BWRVIP-48-A. BWRVIP-48, Revision 2 was not submitted to the NRC staff for review and approval.

Issue:

Table 1 and Sections 2 and 3 of the Enclosure to the July 3, 2023, letter describe the changes between BWRVIP-48-A and BWRVIP-48, Revision 2, regarding the ASME Code inspection requirements for the B13.20 and B13.30 components. TVA stated that several components inspected in accordance with BWRVIP-48, Revision 2 are inspected by EVT-1 methodology in lieu of VT-1 or VT-3 and why the proposed inspection methodology is more conservative.

However, the submittal does not provide justification for the reduction in inspection frequency for B13.20 riser braces and B13.30 steam dryer support brackets nor does it describe methodology for selection of the riser braces.

Request:

1. Discuss the plant-specific bases for Browns Ferry Units 1, 2, and 3 that demonstrate that the proposed reduction in frequency of inspection provides an acceptable alternative to ASME Code requirements or BWRVIP-48-A for the inspection of the applicable reactor pressure vessel interior attachments welds.

2. Describe the sampling methodology for all components proposed to be inspected at a frequency less than that specified in the ASME Code or BWRVIP-48-A that are covered by the alternative request.