ML062180078

RAI Re Snubber Examination and Testing

ML062180078
Person / Time
Site:	Sequoyah
Issue date:	08/08/2006
From:	Pickett D NRC/NRR/ADRO/DORL/LPLII-2
To:	Singer K Tennessee Valley Authority
Pickett D, NRR/DORL, 415-1364
References
TAC MC9657, TAC MC9658
Download: ML062180078 (5)

Text

August 8, 2006 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING SNUBBER EXAMINATION AND TESTING (TAC NOS. MC9657 AND MC9658)

Dear Mr. Singer:

By letter dated January 25, 2006, Tennessee Valley Authority (the licensee) requested relief from the American Society of Mechanical EngineersSection XI Code requirements for snubber examination and testing. The proposed request for relief is a continuation of the previously approved relief request from the Sequoyah Nuclear Plant (SQN), Units 1 and 2 second 10-year inspection interval and was submitted for applicability during SQNs third 10-year inspection interval that began on June 1, 2006.

In order for the staff to complete its review of this application, we request that the licensee provide responses to the enclosed request for additional information (RAI). Based on discussions with your staff, we understand that you intend to respond to this RAI within 30 days of receipt of this letter.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

As stated cc w/encl: See next page

ML062180078 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA (A) CPTB/BC LPL2-2/BC NAME DPickett RSola CHammer for TLiu LRaghavan for MMarshall DATE 08 / 08 / 06 08 / 08 / 06 08 / 08 / 06 08 / 08 / 06 Mr. Karl W. Singer SEQUOYAH NUCLEAR PLANT Tennessee Valley Authority cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Glenn W. Morris, Manager Nuclear Operations Corporate Nuclear Licensing Tennessee Valley Authority and Industry Affairs 6A Lookout Place Tennessee Valley Authority 1101 Market Street 4X Blue Ridge Chattanooga, TN 37402-2801 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, Vice President Nuclear Engineering & Technical Services Mr. Paul L. Pace, Manager Tennessee Valley Authority Licensing and Industry Affairs 6A Lookout Place ATTN: Mr. James D. Smith 1101 Market Street Sequoyah Nuclear Plant Chattanooga, TN 37402-2801 Tennessee Valley Authority P.O. Box 2000 Mr. Robert J. Beecken, Vice President Soddy Daisy, TN 37384-2000 Nuclear Support Tennessee Valley Authority Mr. David A. Kulisek, Plant Manager 6A Lookout Place Sequoyah Nuclear Plant 1101 Market Street Tennessee Valley Authority Chattanooga, TN 37402-2801 P.O. Box 2000 Soddy Daisy, TN 37384-2000 Mr. Randy Douet Site Vice President Senior Resident Inspector Sequoyah Nuclear Plant Sequoyah Nuclear Plant Tennessee Valley Authority U.S. Nuclear Regulatory Commission P.O. Box 2000 2600 Igou Ferry Road Soddy Daisy, TN 37384-2000 Soddy Daisy, TN 37379 General Counsel Mr. Lawrence E. Nanney, Director Tennessee Valley Authority Division of Radiological Health ET 11A Dept. of Environment & Conservation 400 West Summit Hill Drive Third Floor, L and C Annex Knoxville, TN 37902 401 Church Street Nashville, TN 37243-1532 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing County Mayor Tennessee Valley Authority Hamilton County Courthouse 6A Lookout Place Chattanooga, TN 37402-2801 1101 Market Street Chattanooga, TN 37402-2801 Ms. Ann P. Harris 341 Swing Loop Road Rockwood, Tennessee 37854

REQUEST FOR ADDITIONAL INFORMATION SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 SNUBBER RELIEF REQUEST SNUBBERS INSPECTION AND TESTING FOR THIRD 10-YEAR INTERVAL TAC NOS. MC9657 AND MC9658

1. The licensee requested relief from the requirements of IWF-5200(a) and (b), and IWF-5300(a) and (b) (Page E1-2). IWF-1220 states that the inservice inspection requirements for snubbers shall be in accordance with the requirements of IWF-5000.

Article IWF-5000 also contains requirements for snubber preservice and inservice examinations, and tests for snubbers integral and nonintegral attachments under IWF-5200(c) and IWF-5300(c). Please explain, whether and how the requirements of IWF-5200(c) and IWF-5300(c) will be met.

2. The licensee requested relief from IWF-5400, Repair/ Replacement Activities (Page E1-2). IWF-5400 states that Repair/replacement activities performed on snubbers shall be in accordance with IWA-4000. Snubbers installed, corrected or modified by repair/replacement activities shall be examined and tested in accordance with the applicable requirements of IWF-5200 prior to return to service. Please explain, whether and how IWF-5200(c) requirements of IWF-5200 will be met.

3. IWF-5200(a) and (b), and IWF-5300(a) and (b) states that preservice and inservice examination and testings shall be performed in accordance with ASME/ANSI OM, Part

4. Under Basis for Relief (Page E1-3), the licensee states that Sequoyah Nuclear Plant (SQN) Technical Requirement Manual (TRM) adopts the provisions provided in NRC Generic Letter (GL) 90-09. GL 90-09, only provides guidance for Snubber Visual Examination Intervals and Corrective Actions. GL-90-09 does not replace any other requirements of OM Part 4. Therefore please explain the following:

3a. OM-4, Section 2.1 requires preservice examination of snubbers. Please explain, how these preservice requirements are met in the proposed alternative SQN TRM.

3b. OM-4, Section 3.1 requires preservice operability testing of snubbers. Please explain, how these preservice operability testing requirements are met in the proposed alternative SQN TRM.

4. On page E1-4, last paragraph, the licensee states that Performance of each test or inspection is documented and retained with the site procedure as a summary report with the data similar to the requirements prescribed in the ASME Section XI Code. The licensee is to provide actual subsection and/or paragraph of ASME Section XI, which is intended to meet for this requirement of documentation.

Enclosure

5. Please explain, how the requirements of OM-4, Section 3.2.4 Inservice Operability Failure Evaluation are met in the proposed alternative as specified in the SQN TRM.