ML22299A029: Difference between revisions

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=Text=
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{{#Wiki_filter:From:                     Kimberly Green Sent:                     Wednesday, October 26, 2022 8:05 AM To:                       Wells, Russell Douglas Cc:                       Eckermann, Jeremy Beau
{{#Wiki_filter:From: Kimberly Green Sent: Wednesday, October 26, 2022 8:05 AM To: Wells, Russell Douglas Cc: Eckermann, Jeremy Beau


==Subject:==
==Subject:==
Line 24: Line 24:


==Dear Mr. Wells,==
==Dear Mr. Wells,==
By email dated October 12, 2022, I transmitted the following draft request for information (RAI) to you regarding the subject relief request.


By email dated October 12, 2022, I transmitted the following draft request for information (RAI) to you regarding the subject relief request.
Introduction
Introduction By {{letter dated|date=May 24, 2021|text=letter dated May 24, 2021}} (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22144A138), the Tennessee Valley Authority (TVA) submitted Relief Request BFN-2-ISI-003 for Browns Ferry Nuclear Plant, Unit 2.
 
By {{letter dated|date=May 24, 2021|text=letter dated May 24, 2021}} (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22144A138), the Tennessee Valley Authority (TVA) submitted Relief Request BFN-2-ISI-003 for Browns Ferry Nuclear Plant, Unit 2.
Pursuant to section 50.55a(g)(5)(iii) of Title 10 of the Code of Federal Regulations (10 CFR), TVA requested relief from the weld examination coverage requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, for Categories B-D and R-A, for examinations performed during the fourth 10-year inservice inspection (ISI) interval.
Pursuant to section 50.55a(g)(5)(iii) of Title 10 of the Code of Federal Regulations (10 CFR), TVA requested relief from the weld examination coverage requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, for Categories B-D and R-A, for examinations performed during the fourth 10-year inservice inspection (ISI) interval.
Regulatory Basis Pursuant to 10 CFR 50.55a(g)(5)(iii), if a licensee has determined that conformance with an ASME Code requirement is impractical for its facility, the licensee must notify the U.S.
 
Regulatory Basis
 
Pursuant to 10 CFR 50.55a(g)(5)(iii), if a licensee has determined that conformance with an ASME Code requirement is impractical for its facility, the licensee must notify the U.S.
Nuclear Regulatory Commission (NRC or the Commission) and submit, as specified in 10 CFR 50.4, information to support the determinations. Determinations of impracticality in accordance with 10 CFR 50.55a must be based on the demonstrated limitations experienced when attempting to comply with the ASME Code requirements during the ISI interval for which the request is being submitted. Requests for relief made in accordance with 10 CFR 50.55a must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.
Nuclear Regulatory Commission (NRC or the Commission) and submit, as specified in 10 CFR 50.4, information to support the determinations. Determinations of impracticality in accordance with 10 CFR 50.55a must be based on the demonstrated limitations experienced when attempting to comply with the ASME Code requirements during the ISI interval for which the request is being submitted. Requests for relief made in accordance with 10 CFR 50.55a must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.
Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations under 10 CFR 50.55a(g)(5) that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines are authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations under 10 CFR 50.55a(g)(5) that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines are authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Request In Section V of the relief request, TVA stated, in part:
In those cases where UT examinations could potentially have interrogated additional area, such as the inside surface of cast stainless valves by looking through a stainless steel weld, these were considered a


best effort examination. These are shown on the figures below by the represented angles. However, no additional coverage is credited.
Request
 
In Section V of the relief request, TVA stated, in part:
 
In those cases where UT examinations could potentially have interrogated additional area, such as the inside surface of cast stainless valves by looking through a stainless steel weld, these were considered a best effort examination. These are shown on the figures below by the represented angles. However, no additional coverage is credited.
 
The NRC staff notes that request BFN-2-ISI-003 did not include the results of best effort examination. State whether any flaws were detected in the far side volume examined by the best effort examination. If so (a) discuss how the detected flaws were dispositioned to ensure structural integrity and leak tightness of the welds, and (b) discuss the root cause analysis and extent of condition assessment performed to ensure such degradations would not impact structural integrity of similar welds subject to similar environments with limited examination coverage.
The NRC staff notes that request BFN-2-ISI-003 did not include the results of best effort examination. State whether any flaws were detected in the far side volume examined by the best effort examination. If so (a) discuss how the detected flaws were dispositioned to ensure structural integrity and leak tightness of the welds, and (b) discuss the root cause analysis and extent of condition assessment performed to ensure such degradations would not impact structural integrity of similar welds subject to similar environments with limited examination coverage.
At your request, a clarification call between TVA and NRC staff was held on October 24, 2022.
At your request, a clarification call between TVA and NRC staff was held on October 24, 2022.
During the call, TVA stated that the examination results in Table 1 of the enclosure to the request reflects the results of the ASME Code-qualified/required ultrasonic (UT) examinations (i.e., near side exam) and the non-Code qualified UT examinations (i.e., far-side exam or best effort exam).
During the call, TVA stated that the examination results in Table 1 of the enclosure to the request reflects the results of the ASME Code-qualified/required ultrasonic (UT) examinations (i.e., near side exam) and the non-Code qualified UT examinations (i.e., far-side exam or best effort exam).
Therefore, based on this clarification, the NRC staff determined that no additional information is needed because the requested information is included in the results in Table 1.
Therefore, based on this clarification, the NRC staff determined that no additional information is needed because the requested information is included in the results in Table 1.
If you have any questions, please contact me.
If you have any questions, please contact me.
Sincerely, Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627


Hearing Identifier:     NRR_DRMA Email Number:           1816 Mail Envelope Properties     (DM6PR09MB54620522AB6E1D7FB86ABEC08F309)
Sincerely,
 
Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627
 
Hearing Identifier: NRR_DRMA Email Number: 1816
 
Mail Envelope Properties (DM6PR09MB54620522AB6E1D7FB86ABEC08F309)


==Subject:==
==Subject:==
Request for Additional Information for Relief Request BFN-2-ISI-003 re Weld Examination Coverage (EPID L-2022-LLR-0049)
Request for Additional Information for Relief Request BFN-2-ISI-003 re Weld Examination Coverage (EPID L-2022-LLR-0049)
Sent Date:             10/26/2022 8:05:18 AM Received Date:         10/26/2022 8:05:00 AM From:                   Kimberly Green Created By:             Kimberly.Green@nrc.gov Recipients:
Sent Date: 10/26/2022 8:05:18 AM Received Date: 10/26/2022 8:05:00 AM From: Kimberly Green
 
Created By: Kimberly.Green@nrc.gov
 
Recipients:
"Eckermann, Jeremy Beau" <jbeckermann@tva.gov>
"Eckermann, Jeremy Beau" <jbeckermann@tva.gov>
Tracking Status: None "Wells, Russell Douglas" <rdwells0@tva.gov>
Tracking Status: None "Wells, Russell Douglas" <rdwells0@tva.gov>
Tracking Status: None Post Office:           DM6PR09MB5462.namprd09.prod.outlook.com Files                           Size                       Date & Time MESSAGE                         3882                       10/26/2022 8:05:00 AM Options Priority:                       Normal Return Notification:           No Reply Requested:               No Sensitivity:                   Normal Expiration Date:}}
Tracking Status: None
 
Post Office: DM6PR09MB5462.namprd09.prod.outlook.com
 
Files Size Date & Time MESSAGE 3882 10/26/2022 8:05:00 AM
 
Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:}}

Latest revision as of 01:22, 16 November 2024

NRR E-mail Capture - Request for Additional Information for Relief Request BFN-2-ISI-003 Re Weld Examination Coverage
ML22299A029
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 10/26/2022
From: Kimberly Green
Plant Licensing Branch II
To: Wells R
Tennessee Valley Authority
References
L-2022-LLR-0049
Download: ML22299A029 (3)
v • d • e


Text

From: Kimberly Green Sent: Wednesday, October 26, 2022 8:05 AM To: Wells, Russell Douglas Cc: Eckermann, Jeremy Beau

Subject:

Request for Additional Information for Relief Request BFN-2-ISI-003 re Weld Examination Coverage (EPID L-2022-LLR-0049)

Dear Mr. Wells,

By email dated October 12, 2022, I transmitted the following draft request for information (RAI) to you regarding the subject relief request.

Introduction

By letter dated May 24, 2021 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22144A138), the Tennessee Valley Authority (TVA) submitted Relief Request BFN-2-ISI-003 for Browns Ferry Nuclear Plant, Unit 2.

Pursuant to section 50.55a(g)(5)(iii) of Title 10 of the Code of Federal Regulations (10 CFR), TVA requested relief from the weld examination coverage requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for Categories B-D and R-A, for examinations performed during the fourth 10-year inservice inspection (ISI) interval.

Regulatory Basis

Pursuant to 10 CFR 50.55a(g)(5)(iii), if a licensee has determined that conformance with an ASME Code requirement is impractical for its facility, the licensee must notify the U.S.

Nuclear Regulatory Commission (NRC or the Commission) and submit, as specified in 10 CFR 50.4, information to support the determinations. Determinations of impracticality in accordance with 10 CFR 50.55a must be based on the demonstrated limitations experienced when attempting to comply with the ASME Code requirements during the ISI interval for which the request is being submitted. Requests for relief made in accordance with 10 CFR 50.55a must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.

Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations under 10 CFR 50.55a(g)(5) that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines are authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Request

In Section V of the relief request, TVA stated, in part:

In those cases where UT examinations could potentially have interrogated additional area, such as the inside surface of cast stainless valves by looking through a stainless steel weld, these were considered a best effort examination. These are shown on the figures below by the represented angles. However, no additional coverage is credited.

The NRC staff notes that request BFN-2-ISI-003 did not include the results of best effort examination. State whether any flaws were detected in the far side volume examined by the best effort examination. If so (a) discuss how the detected flaws were dispositioned to ensure structural integrity and leak tightness of the welds, and (b) discuss the root cause analysis and extent of condition assessment performed to ensure such degradations would not impact structural integrity of similar welds subject to similar environments with limited examination coverage.

At your request, a clarification call between TVA and NRC staff was held on October 24, 2022.

During the call, TVA stated that the examination results in Table 1 of the enclosure to the request reflects the results of the ASME Code-qualified/required ultrasonic (UT) examinations (i.e., near side exam) and the non-Code qualified UT examinations (i.e., far-side exam or best effort exam).

Therefore, based on this clarification, the NRC staff determined that no additional information is needed because the requested information is included in the results in Table 1.

If you have any questions, please contact me.

Sincerely,

Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627

Hearing Identifier: NRR_DRMA Email Number: 1816

Mail Envelope Properties (DM6PR09MB54620522AB6E1D7FB86ABEC08F309)

Subject:

Request for Additional Information for Relief Request BFN-2-ISI-003 re Weld Examination Coverage (EPID L-2022-LLR-0049)

Sent Date: 10/26/2022 8:05:18 AM Received Date: 10/26/2022 8:05:00 AM From: Kimberly Green

Created By: Kimberly.Green@nrc.gov

Recipients:

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

Tracking Status: None "Wells, Russell Douglas" <rdwells0@tva.gov>

Tracking Status: None

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

Files Size Date & Time MESSAGE 3882 10/26/2022 8:05:00 AM

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

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