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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M4461999-10-20020 October 1999 Forwards Rev 8 to Sequoyah Nuclear Plant Physical Security/ Contingency Plan, IAW 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 ML20217J4151999-10-15015 October 1999 Forwards Request for Addl Info Re Util 990624 Application for Amend of TSs That Would Revise TS for Weighing of Ice Condenser Ice Baskets 05000327/LER-1999-002, Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project1999-10-15015 October 1999 Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project ML20217G1141999-10-0707 October 1999 Responds to from P Salas,Providing Response to NRC Risk Determination Associated with 990630 Flooding Event at Sequoyah Facility.Meeting to Discuss Risk Determination Issues Scheduled for 991021 in Atlanta,Ga ML20217B2981999-10-0606 October 1999 Discusses Closeout of GL 92-01,rev 1,suppl 1, Reactor Vessel Integrity, for Sequoyah Nuclear Plant,Units 1 & 2. NRC Also Hereby Solicits Any Written Comments That TVA May Have on Current Rvid Data by 991101 ML20217B8431999-10-0505 October 1999 Requests NRC Review & Approval of ASME Code Relief Requests That Were Identified in Plant Second 10-yr ISI Interval for Both Units.Encl 3 Provides Util Procedure for Calculation of ASME Code Coverage for Section XI Nondestructive Exams IR 05000327/19990041999-10-0101 October 1999 Ack Receipt of Providing Comments on Insp Repts 50-327/99-04 & 50-328/99-04.NRC Considered Comments for Apparent Violation Involving 10CFR50.59 Issue ML20217C7101999-10-0101 October 1999 Forwards Response to NRC 990910 RAI Re Sequoyah Nuclear Plant,Units 1 & 2 URI 50-327/98-04-02 & 50-328/98-04-02 Re Ice Weight Representative Sample ML20212J5981999-10-0101 October 1999 Forwards SE Accepting Request for Relief from ASME Boiler & Pressure Vessel Code,Section Xi,Requirements for Certain Inservice Insp at Plnat,Unit 1 ML20212M1081999-09-29029 September 1999 Confirms Intent to Meet with Utils on 991025 in Atlanta,Ga to Discuss Pilot Plants,Shearon Harris & Sequoyah Any Observations & Lessons Learned & Recommendations Re Implementation of Pilot Program ML20217A9451999-09-27027 September 1999 Forwards Insp Repts 50-327/99-05 & 50-328/99-05 on 990718- 0828.One Violation Identified & Being Treated as Non-Cited Violation ML20216J9351999-09-27027 September 1999 Responds to NRC Re Violations Noted in Insp Repts 50-327/99-04 & 50-328/99-04.Corrective Actions:Risk Determination Evaluation Was Performed & Licensee Concluded That Event Is in Green Regulatory Response Band ML20212F0751999-09-23023 September 1999 Forwards SER Granting Util 981021 Request for Relief from ASME Code,Section XI Requirements from Certain Inservice Insp at Sequoyah Nuclear Power Plant,Units 1 & 2 Pursuant to 10CFR50.55a(a)(3)(ii) ML20212F4501999-09-23023 September 1999 Forwards Amends 246 & 237 to Licenses DPR-77 & DPR-79, Respectively & Ser.Amends Approve Request to Revise TSs to Allow Use of Fully Qualified & Tested Spare Inverter in Place of Any of Eight Required Inverters ML20212M1911999-09-21021 September 1999 Discusses Exercise of Enforcement Discretion Re Apparent Violation Noted in Insp Repts 50-327/99-04 & 50-328/99-04 Associated with Implementation of Procedural Changes Which Resulted in Three Containment Penetrations Being Left Open ML20211Q0311999-09-10010 September 1999 Requests Written Documentation from TVA to Provide Technical Assistance to Region II Re TS Compliance & Ice Condenser Maint Practices at Plant ML20216F5441999-09-0707 September 1999 Provides Results of Risk Evaluation of 990630,flooding Event at Sequoyah 1 & 2 Reactor Facilities.Event Was Documented in Insp Rept 50-327/99-04 & 50-328/99-04 & Transmitted in Ltr, ML20211N5681999-09-0101 September 1999 Submits Clarification of Two Issues Raised in Insp Repts 50-327/99-04 & 50-328/99-04,dtd 990813,which Was First Insp Rept Issued for Plant Under NRC Power Reactor Oversight Process Pilot Plant Study ML20211G5881999-08-27027 August 1999 Submits Summary of 990820 Management Meeting Re Plant Performance.List of Attendees & Matl Used in Presentation Enclosed ML20211F8891999-08-25025 August 1999 Forwards Sequoyah Nuclear Plant Unit 1 Cycle 9 Refueling Outage, Re Completed SG Activities,Per TSs 4.4.5.5.b & 4.4.5.5.c ML20211A1851999-08-16016 August 1999 Forwards Proprietary TR WCAP-15128 & non-proprietary Rept WCAP-15129 for NRC Review.Repts Are Provided in Advance of TS Change That Is Being Prepared to Support Cycle 10 Rfo. Proprietary TR Withheld,Per 10CFR2.790 ML20210V1471999-08-13013 August 1999 Forwards Insp Repts 50-327/99-04 & 50-328/99-04 on 990601- 0717.One Potentially Safety Significant Issue Identified.On 990630,inadequate Performance of Storm Drain Sys Caused Water from Heavy Rainfall to Backup & Flood Turbine Bldg ML20211A1921999-08-12012 August 1999 Requests Proprietary TR WCAP-15128, Depth-Based SG Tube Repair Criteria for Axial PWSCC at Dented TSP Intersections, Be Withheld from Public Disclosure Per 10CFR2.790 ML20210Q5011999-08-0505 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006 at Sequoyah Nuclear Plant. Sample Registration Ltr Encl ML20210L4291999-08-0202 August 1999 Forwards Sequoyah Nuclear Plant Unit 2 Cycle 9 12-Month SG Insp Rept & SG-99-07-009, Sequoyah Unit-2 Cycle 10 Voltage-Based Repair Criteria 90-Day Rept. Repts Submitted IAW TS 4.4.5.5.b & TS 4.4.5.5.c ML20210L1611999-07-30030 July 1999 Forwards Request for Relief RV-4 Re ASME Class 1,2 & 3 Prvs, Per First ten-year Inservice Test Time Interval.Review & Approval of RV-4 Is Requested to Support Unit 1 Cycle 10 Refueling Outage,Scheduled to Start 000213 ML20210G5301999-07-28028 July 1999 Forwards Sequoyah Nuclear Plant Unit 2 ISI Summary Rept That Contains Historical Record of Repairs,Replacement & ISI & Augmented Examinations That Were Performed on ASME Code Class 1 & 2 Components from 971104-990511 ML20211B9661999-07-26026 July 1999 Informs That Sequoyah Nuclear Plant Sewage Treatment Plant, NPDES 0026450 Outfall 112,is in Standby Status.Flow Has Been Diverted from Sys Since Jan 1998 ML20210B2521999-07-14014 July 1999 Confirms 990712 Telcon Between J Smith of Licensee Staff & M Shannon of NRC Re semi-annual Mgt Meeting Schedule for 990820 in Atlanta,Ga to Discuss Recent Sequoyah Nuclear Plant Performance ML20210J1091999-07-10010 July 1999 Submits Suggestions & Concerns Re Y2K & Nuclear Power Plants ML20196K0381999-06-30030 June 1999 Provides Written Confirmation of Completed Commitment for Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Snp,Per GL 92-08 ML20209E4071999-06-30030 June 1999 Forwards Insp Repts 50-327/99-03 & 50-328/99-03 on 990328- 0531.Violations Being Treated as Noncited Violations ML20196J8261999-06-28028 June 1999 Forwards Safety Evaluation Authorizing Request for Relief from ASME Boiler & Pressure Vessel Code,Section XI Requirements for Certain Inservice Inspections at Sequoyah Nuclear Plant,Units 1 & 2 ML20196G7881999-06-22022 June 1999 Informs NRC of Changes That Util Incorporated Into TS Bases Sections & Trm.Encl Provides Revised TS Bases Pages & TRM Affected by Listed Revs ML20196G1801999-06-21021 June 1999 Requests Termination of SRO License SOP-20751-1,for Lf Hardin,Effective 990611.Subject Individual Resigned from Position at TVA ML20195G1821999-06-0808 June 1999 Requests NRC Review & Approval of ASME Code Relief for ISI Program.Encl 1 Provides Relief Request 1-ISI-14 That Includes Two Attachments.Encl 2 Provides Copy of Related ASME Code Page ML20195E9521999-06-0707 June 1999 Requests Relief from Specific Requirements of ASME Section Xi,Subsection IWE of 1992 Edition,1992 Addenda.Util Has Determined That Proposed Alternatives Would Provide Acceptable Level of Quality & Safety ML20195E9311999-05-28028 May 1999 Informs of Planned Insp Activities for Licensee to Have Opportunity to Prepare for Insps & Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20195B3631999-05-21021 May 1999 Requests Termination of SRO License for Tj Van Huis,Per 10CFR50.74(a).TJ Van Huis Retired from Util,Effective 990514 ML20207A5721999-05-20020 May 1999 Forwards Correction to Previously Issued Amend 163 to License DPR-79 Re SR 4.1.1.1.1.d Inadvertently Omitted from Pp 3/4 1-1 of Unit 2 TS ML20206Q8791999-05-13013 May 1999 Forwards L36 9990415 802, COLR for Sequoyah Nuclear Plant Unit 2,Cycle 10, IAW Plant TS 6.9.1.14.c 05000327/LER-1999-001, Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv)1999-05-11011 May 1999 Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv) ML20206M9341999-05-10010 May 1999 Forwards Rept of SG Tube Plugging During Unit 2 Cycle 9 Refueling Outage,As Required by TS 4.4.5.5.a.ISI of Unit 2 SG Tubes Was Completed on 990503 ML20206K6271999-05-0606 May 1999 Requests Termination of SRO License for MR Taggart,License SOP-21336 Due to Resignation on 990430 ML20206J2061999-05-0404 May 1999 Requests Relief from Specified ISI Requirements in Section XI of ASME B&PV Code.Tva Requests Approval to Use Wire Type Penetrameters in Lieu of Plaque Type Penetrameters for Performing Radiographic Insps.Specific Relief Request,Encl ML20209J0391999-04-27027 April 1999 Forwards Annual Radioactive Effluent Release Rept, Radiological Impact Assessment Rept & Rev 41 to ODCM, for Period of Jan-Dec 1998 ML20206C6541999-04-23023 April 1999 Forwards Response to NRC 990127 RAI Re GL 96-05 for Sequoyah Nuclear Plant,Units 1 & 2 ML20206C0841999-04-23023 April 1999 Forwards Insp Repts 50-327/99-02 & 50-328/99-02 on 990214-0327.No Violations Noted ML20206B9591999-04-20020 April 1999 Responds to 990417 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required in Unit 1 TS 3.1.2.2,3.1.2.4 & 3.5.2 & Documents 990417 Telephone Conversation When NRC Orally Issued NOED ML20205S5891999-04-17017 April 1999 Documents Request for Discretionary Enforcement for Unit 1 TS LCOs 3.1.2.2,3.1.2.4 & 3.5.2 to Support Completion of Repairs & Testing for 1B-B Centrifugal Charging Pump (CCP) 1999-09-07
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217M4461999-10-20020 October 1999 Forwards Rev 8 to Sequoyah Nuclear Plant Physical Security/ Contingency Plan, IAW 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 05000327/LER-1999-002, Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project1999-10-15015 October 1999 Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project ML20217B8431999-10-0505 October 1999 Requests NRC Review & Approval of ASME Code Relief Requests That Were Identified in Plant Second 10-yr ISI Interval for Both Units.Encl 3 Provides Util Procedure for Calculation of ASME Code Coverage for Section XI Nondestructive Exams ML20217C7101999-10-0101 October 1999 Forwards Response to NRC 990910 RAI Re Sequoyah Nuclear Plant,Units 1 & 2 URI 50-327/98-04-02 & 50-328/98-04-02 Re Ice Weight Representative Sample ML20216J9351999-09-27027 September 1999 Responds to NRC Re Violations Noted in Insp Repts 50-327/99-04 & 50-328/99-04.Corrective Actions:Risk Determination Evaluation Was Performed & Licensee Concluded That Event Is in Green Regulatory Response Band ML20211N5681999-09-0101 September 1999 Submits Clarification of Two Issues Raised in Insp Repts 50-327/99-04 & 50-328/99-04,dtd 990813,which Was First Insp Rept Issued for Plant Under NRC Power Reactor Oversight Process Pilot Plant Study ML20211F8891999-08-25025 August 1999 Forwards Sequoyah Nuclear Plant Unit 1 Cycle 9 Refueling Outage, Re Completed SG Activities,Per TSs 4.4.5.5.b & 4.4.5.5.c ML20211A1851999-08-16016 August 1999 Forwards Proprietary TR WCAP-15128 & non-proprietary Rept WCAP-15129 for NRC Review.Repts Are Provided in Advance of TS Change That Is Being Prepared to Support Cycle 10 Rfo. Proprietary TR Withheld,Per 10CFR2.790 ML20211A1921999-08-12012 August 1999 Requests Proprietary TR WCAP-15128, Depth-Based SG Tube Repair Criteria for Axial PWSCC at Dented TSP Intersections, Be Withheld from Public Disclosure Per 10CFR2.790 ML20210L4291999-08-0202 August 1999 Forwards Sequoyah Nuclear Plant Unit 2 Cycle 9 12-Month SG Insp Rept & SG-99-07-009, Sequoyah Unit-2 Cycle 10 Voltage-Based Repair Criteria 90-Day Rept. Repts Submitted IAW TS 4.4.5.5.b & TS 4.4.5.5.c ML20210L1611999-07-30030 July 1999 Forwards Request for Relief RV-4 Re ASME Class 1,2 & 3 Prvs, Per First ten-year Inservice Test Time Interval.Review & Approval of RV-4 Is Requested to Support Unit 1 Cycle 10 Refueling Outage,Scheduled to Start 000213 ML20210G5301999-07-28028 July 1999 Forwards Sequoyah Nuclear Plant Unit 2 ISI Summary Rept That Contains Historical Record of Repairs,Replacement & ISI & Augmented Examinations That Were Performed on ASME Code Class 1 & 2 Components from 971104-990511 ML20210J1091999-07-10010 July 1999 Submits Suggestions & Concerns Re Y2K & Nuclear Power Plants ML20196K0381999-06-30030 June 1999 Provides Written Confirmation of Completed Commitment for Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Snp,Per GL 92-08 ML20196G7881999-06-22022 June 1999 Informs NRC of Changes That Util Incorporated Into TS Bases Sections & Trm.Encl Provides Revised TS Bases Pages & TRM Affected by Listed Revs ML20196G1801999-06-21021 June 1999 Requests Termination of SRO License SOP-20751-1,for Lf Hardin,Effective 990611.Subject Individual Resigned from Position at TVA ML20195G1821999-06-0808 June 1999 Requests NRC Review & Approval of ASME Code Relief for ISI Program.Encl 1 Provides Relief Request 1-ISI-14 That Includes Two Attachments.Encl 2 Provides Copy of Related ASME Code Page ML20195E9521999-06-0707 June 1999 Requests Relief from Specific Requirements of ASME Section Xi,Subsection IWE of 1992 Edition,1992 Addenda.Util Has Determined That Proposed Alternatives Would Provide Acceptable Level of Quality & Safety ML20195B3631999-05-21021 May 1999 Requests Termination of SRO License for Tj Van Huis,Per 10CFR50.74(a).TJ Van Huis Retired from Util,Effective 990514 ML20206Q8791999-05-13013 May 1999 Forwards L36 9990415 802, COLR for Sequoyah Nuclear Plant Unit 2,Cycle 10, IAW Plant TS 6.9.1.14.c 05000327/LER-1999-001, Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv)1999-05-11011 May 1999 Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv) ML20206M9341999-05-10010 May 1999 Forwards Rept of SG Tube Plugging During Unit 2 Cycle 9 Refueling Outage,As Required by TS 4.4.5.5.a.ISI of Unit 2 SG Tubes Was Completed on 990503 ML20206K6271999-05-0606 May 1999 Requests Termination of SRO License for MR Taggart,License SOP-21336 Due to Resignation on 990430 ML20206J2061999-05-0404 May 1999 Requests Relief from Specified ISI Requirements in Section XI of ASME B&PV Code.Tva Requests Approval to Use Wire Type Penetrameters in Lieu of Plaque Type Penetrameters for Performing Radiographic Insps.Specific Relief Request,Encl ML20209J0391999-04-27027 April 1999 Forwards Annual Radioactive Effluent Release Rept, Radiological Impact Assessment Rept & Rev 41 to ODCM, for Period of Jan-Dec 1998 ML20206C6541999-04-23023 April 1999 Forwards Response to NRC 990127 RAI Re GL 96-05 for Sequoyah Nuclear Plant,Units 1 & 2 ML20205S5891999-04-17017 April 1999 Documents Request for Discretionary Enforcement for Unit 1 TS LCOs 3.1.2.2,3.1.2.4 & 3.5.2 to Support Completion of Repairs & Testing for 1B-B Centrifugal Charging Pump (CCP) ML20205B1091999-03-19019 March 1999 Submits Response to NRC Questions Concerning Lead Test Assembly Matl History,Per Request ML20204H0161999-03-19019 March 1999 Resubmits Util 990302 Response to Violations Noted in Insp Repts 50-327/98-11 & 50-328/98-11.Corrective Actions:Lessons Learned from Event Have Been Provided to Operating Crews ML20204E8251999-03-0505 March 1999 Forwards Sequoyah Nuclear Plant,Four Yr Simulator Test Rept for Period Ending 990321, in Accordance with Requirements of 10CFR55.45 ML20207E6851999-03-0202 March 1999 Responds to NRC Re Violations Noted in Insp Repts 50-327/98-11 & 50-328/98-11.Corrective Actions:Lessons Learned from Event Have Been Provided to Operating Crews ML20207J1171999-01-29029 January 1999 Forwards Copy of Final Exercise Rept for Full Participation Ingestion Pathway Exercise of Offsite Radiological Emergency Response Plans site-specific to Sequoyah NPP ML20202A7141999-01-20020 January 1999 Provides Request for Relief for Delaying Repair on Section of ASME Code Class 3 Piping within Essential Raw Cooling Water Sys ML20198S7141998-12-29029 December 1998 Forwards Cycle 10 Voltage-Based Repair Criteria 90-Day Rept, Per GL 95-05.Rept Is Submitted IAW License Condition 2.C.(9)(d) 05000327/LER-1998-004, Forwards LER 98-004-00,providing Details Concerning Inability to Complete Surveillance within Required Time Interval1998-12-21021 December 1998 Forwards LER 98-004-00,providing Details Concerning Inability to Complete Surveillance within Required Time Interval ML20198D5471998-12-14014 December 1998 Requests That License OP-20313-2 for Je Wright,Be Terminated IAW 10CFR50.74(a).Individual Retiring ML20197J5541998-12-10010 December 1998 Forwards Unit 1 Cycle 9 90-Day ISI Summary Rept IAW IWA-6220 & IWA-6230 of ASME Code,Section Xi.Request for Relief Will Be Submitted to NRC Timeframe to Support Second 10-year Insp Interval,Per 10CFR50.55a 05000327/LER-1998-003, Forwards LER 98-003-00 Re Automatic Reactor Trip with FW Isolation & Auxiliary FW Start as Result of Failure of Vital Inverter & Second Inverter Failure.Event Is Being Reported IAW 10CFR50.73(a)(2)(iv)1998-12-0909 December 1998 Forwards LER 98-003-00 Re Automatic Reactor Trip with FW Isolation & Auxiliary FW Start as Result of Failure of Vital Inverter & Second Inverter Failure.Event Is Being Reported IAW 10CFR50.73(a)(2)(iv) ML20196F9841998-11-25025 November 1998 Provides Changes to Calculated Peak Fuel Cladding Temp, Resulting from Recent Changes to Plant ECCS Evaluation Model ML20195H7891998-11-17017 November 1998 Requests NRC Review & Approval of Five ASME Code Relief Requests Identified in Snp Second ten-year ISI Interval for Units 1 & 2 ML20195E4991998-11-12012 November 1998 Forwards Rev 7 to Physical Security/Contingency Plan.Rev Adds Requirement That Security Personnel Will Assess Search Equipment Alarms & Add Definition of Major Maint.Rev Withheld (Ref 10CFR2.790(d)(1)) 05000328/LER-1998-002, Forwards LER 98-002-00 Re Automatic Turbine & Reactor Trip, Resulting from Failure of Sudden Pressure Relay on 'B' Phase Main Transformer1998-11-10010 November 1998 Forwards LER 98-002-00 Re Automatic Turbine & Reactor Trip, Resulting from Failure of Sudden Pressure Relay on 'B' Phase Main Transformer ML20195G5701998-11-10010 November 1998 Documents Util Basis for 981110 Telcon Request for Discretionary Enforcement for Plant TS 3.8.2.1,Action B,For 120-VAC Vital Instrument Power Board 1-IV.Licensee Determined That Inverter Failed Due to Component Failure ML20155J4031998-11-0505 November 1998 Provides Clarification of Topical Rept Associated with Insertion of Limited Number of Lead Test Assemblies Beginning with Unit 2 Operating Cycle 10 Core ML20154R9581998-10-21021 October 1998 Requests Approval of Encl Request for Relief ISI-3 from ASME Code Requirements Re Integrally Welded Attachments of Supports & Restraints for AFW Piping ML20155B1481998-10-21021 October 1998 Informs That as Result of Discussion of Issues Re Recent Events in Ice Condenser Industry,Ice Condenser Mini-Group (Icmg),Decided to Focus Efforts on Review & Potential Rev of Ice condenser-related TS in Order to Clarify Issues ML20154K1581998-10-13013 October 1998 Forwards Rept Re SG Tube Plugging Which Occurred During Unit 1 Cycle 9 Refueling Outage,Per TS 4.4.5.5.a.ISI of Unit 1 SG Was Completed on 980930 ML20154H6191998-10-0808 October 1998 Forwards Rev 0 to Sequoyah Nuclear Plant Unit 1 Cycle 10 COLR, IAW TS 6.9.1.14.c 05000328/LER-1998-001, Forwards LER 98-001-00 Providing Details Re Automatic Turbine & Reactor Trip Due to Failure of Sudden Pressure Relay on 'B' Phase Main Transformer1998-09-28028 September 1998 Forwards LER 98-001-00 Providing Details Re Automatic Turbine & Reactor Trip Due to Failure of Sudden Pressure Relay on 'B' Phase Main Transformer ML20151W4901998-09-0303 September 1998 Responds to NRC Re Violations Noted in Insp Repts 50-327/98-07 & 50-328/98-07.Corrective Actions:Revised Per SQ971279PER to Address Hardware Issues of Hysteresis, Pressure Shift & Abnormal Popping Noise 1999-09-27
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I Tennessee valley Authority Post Offce Box 2000. Soddy-Daisy, Tennessee 37370 2000 I l
February 10,1997 U.S. Nuclear Regulatory Commission ,
ATTN: Document Control Desk Washington, D.C. 20555 )
Gentlemen:
In the matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN)- AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI RELIEF REQUEST - SUBSECTION IWE Pursuant to the provisions of 10CFR 50.55a(a)(3)(i), TVA is requesting relief from the requirements of ASME Section XI Code, Subsection IWE. The proposed request for relief is applicable to SON's Repair and Replacement (R&R) program for containment components and structures.
I Interim relief is requested until September 9,1997. This would provide a period of time for TVA to review SON's containment design and categorize specific containment structures and components that would fall within the scope of IWE for R&R activities. 1 As an attemative during the proposed relief period, SQN's current R&R program, which is based on the 1989 Edition of the ASME Code, would serve as the base code-of- '
record for any containment R&R activities that might occur. TVA's proposed attemative will ensure that containment structures and components following repair or replacement rneet their original construction requirements with traceable documentation of the work performed. TVA considers this attemative to be an acceptable level of quality and safety.
TVA is in the planning process of fully developing the necessary programs for implementation of the Subsection IWE rules. While TVA is developing these IWE programs, TVA is also making plant improvements that involve the replacement of five containment electrical penetrations. This work is scheduled during SQN's upcoming Unit 1 Cycle 8 refueling outage (Scheduled to begin March 22,1997). This work will involve R & R activities and compliance with ASME code requirements. Accordingly, TVA requests NRC review and approval by April 15,1997 to support the outage work.
I ADD '
9702200094 970210 PDR ADOCK 05000327 l
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[ U.S. Nuclear Regulatory Commission j Page 2 February 10,1997 Please direct questions concoming this issue to D. V. Goodin at (423) 843-7734.
l Sincerely, i e R. H. Shell Site Licensing and Industry Affairs Manager Enclosure cc (Enclosure):
Mr. R. W. Heman, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike l Rockville, Maryland 20852-2739
! NRC Resident inspector i
Sequoyah Nuclear Plant t 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 !
l I
l Regional Administrator I
U.S. Nuclear Regulatory Commission l
Region 11 101 Marietta Street, NW, Suite 2900
- Atlanta, Georgia 30323-2711 l
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r Enclosure !
Tennessee Valley Authority l Request for Relief j ASME Section XI, Subsection IWE I for l Sequoyah (SQN) Nuclear Plant !
i IJnit SQN Units 1 and 2 f Components: Components which fall under the scope of ASME Section XI, Subsection l IWE. The components will be pnmarily those pressure-retammg
{
! components associated with the steel contamment vessel, any load-bearing ,
i components (e.g. supports) associated with the pressure-retauung function, ;
i and any integral attachments to the steel containment vessel. j i
ASMIi
- Code Class
- MC (or equivalent) !
l Note: Piping systems that penetrate containment, and are included under the jurisdiction of the ASME Section XI program, are generally classified as j Code Class 2 (or equivalent). These components are covered by TVA's !
! current ASME Section XI repairs and replacements (R&R) program and are j l
not included within the applicability of this request-for-relief. !
i
! CQdC i l Ecauirement: Implementation of the requirements of ASME Section XI, Subsection IWE, l l for R&R to containment structures, as dermed in Articles IWE-4000, IWE- i 7000, paragraphs IWE-2500(b) and IWE-2600(b); and the post-repair and l replacement requirements shown in Code paragraphs IWE-2200(d), (e), (f), j (g); Articles IWF-4000 and IWF-7000; of the 1992 Edition with the 1992 Addenda of the ASME Code,Section XI; and paragraph -2220 of ASME i
Code Case N-491; commencing on the effective date of the 10CFR50.55a rule change, September 9,1996.
l Code Requirement l From Which Relief is Reauested: Pursuant to the provisions of 10CFR 50.55a(a)(3)(i), TVA is requesting l
relief from meeting certain ASME Code requirements delineated in the 10CFR 50.55a mie change dated August 8,1996, (Federal Register, l
Vol.61, No.154, page 41303). Specifically, TVA is requesting relief for an interim period of 1-year (i.e. from September 9,1996) from full compliance with the rule change as it is related to the implementation of R&R activities in accordance with ASME Boiler and Pressure Vessel Code,Section XI, of the 1992 Edition with the 1992 Addenda for the Class MC (metal contamments) This reliefis requested on the basis that the proposed alternative, as delineated below, will provide an acceptable level of quality and safety (for the interim period) until the applicable specific site programs i and procedures can be written and issued for use. In addition, inunediate total implementation of the rule change for R&R activities will precipitate l
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1 .
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actions which would result in hardships and/or difficulties without a i compensating increase in the level of quality and safety above that provided l by the processes TVA currently uses to maintain the integrity of the site containment structures and components.
l Ilackground: On September 9,1996, a rule change to 10CFR50.55a was made effective that required licensees to initiate an advanced program and schedule for the implementation of the requirements of ASME Section XI, Subsections nVE and IWL as modified within the rule. This rule change required licensees to :
apply the requirements of Subsections RVE and IWL to the inservice inspection and repairs and replacements activities associated with primary metal and concrete containment structures, their supports, and appurtenances. The steel containment vessel provides the primary barrier in protecting the public from radioactive releases tothe atmosphere in the event ofleakage from the primary coolant systems piping components. It provides the pressure-retaining membrane for containment isolation.
The revised rule gave a required completion date of September 9,2001, which allows five years to review the plant design, determine those attributes which are required to be included within the scope of the programs, create the necessary processes and procedures, and perform the required inspections. In parallel with this effort, Code based programs such as TVA's ASME Section XI Repair and Replacement Program would be revised to incorporate the ancillary program n:quirements. Following the issuance of the rule, NRC program representatives verbally stated to various licensees that the rules for repairs and replacements on contamment components and structures were required to be implemented on September 9,1996, instead of September 9,2001, as stated within the rule change. On September 19,1996, the Nuclear Energy Institute (NEI) issued (on behalf of ;
the nuclear operating utilities) a letter to the NRC requesting clarification on this issue.
On November 6,1996, NRC issued a letter to the NEI clarifying the NRC's l position on the applicability of the ASME Section XI mies and requirements for repairs and replacements associated with the recent rule change to 10CFR 50.55(a). The November 6,1996 letter to NEI states that the requirements for repairs or replacements on contamment structures must be applied starting September 9,1996. TVA currently does not have the procedures and processes in place to fully comply with this interpretation.
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l Altemative Requirements: In an effort to comply with the stated NRC position that R&R programs must be implemented starting September 9,1996, the following principles l will be used during the interim period until the appropriately integrated programs and procedures can be written, approved for use, and issued for implementation.
INTERIM PROGRAM PRINCIPLES:
These principles are based on the fact that basic procedures for use in any repair or replacement (R&R) activity, associated with containment components, are in place in the form of the original design, construction, j and installation requirements and procedures andthe application of these !
requirements through TVA's Quality Assurance programs. Actual l restoration of any containment component that needed repair would be l required by the ASME Code to meet the original construction requirements as a minimum. The guidelines outlined below will be considered as site j requirements rad would be performed in addition to the current minimum j TVA Nuclear Power Standard (NP STD) code program requirements. I
- 1. These guidelines shall be applied to the primary metal contamment structures, Class MC, pressure retaining components and their associated supports, integral attachments, and appurtenances.
- 2. Interim R&R activities shall be planned and implemented so as to provide for ANIl review and involvement. As much as possible, these activities should follow the existing processes and procedures associated with the ANil oversight and to the extent outlined under these interim guidelines.
- 3. Contamment R&R activity documentation shall include the use of existing NIS-2 procedures and reports, with minor revisions to accommodate provisions of this request-for-relief.
- 4. Inspection activities and NDE procedures used following R&R activities shall follow the requirements indicated in the original design, construction, and installation procedures. l
- 5. In the case where specific preservice/ baseline inspections (other than those addressed in item 4, above) are required by Subsection IWE, existing TVA NDE inspection exammation procedures shall be used to perform these containment structure examinations to the extent possible.
Where specific and unique examination and acceptance criteria are required by the R&R activity, existing NDE inspection techniques shall be employed in obtaining reasonable and practicable exammation results for evaluation. If the specific Subsection IWE required examination (s) can be identified, an_d existing NDE procedures are fully qualified ( in the judgment of TVA's certified technical NDE Level III personnel) to perform the required exammation; then, the Subsection IWE required examination shall be performed and the results recorded. In this manner, the current NDE personnel qualifications and certifications would be sufficient, for interim use, until such time as final contamment
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! inspection programs and the accompanying NDE procedures are in place.
- 6. Containment structure pressure and leak rate testing shall follow the l requirements established in conjunction with TVA's 10CFR 50 Appendix J program.
- 7. Materials procurement and associated documentation shall follow the current TVA safety-related component quality assurance guidelines to provide materials with quality levels of at least the equivalent to the original design requirements.
- 8. Special containment structure requirements encountered during R&R activities, such as the maintenance and repair of component corrosion protective coatings, shall follow the existing TVA programs and procedures.
- 9. Special processes such as welding and brazing activities in the repair of containment structure pressure boundary components and their supports shall follow the existing TVA programs and procedures, as appropriate.
- 10. Existing TVA ASME Section XI R&R program guidelines and defmitions, such as the identification of maintenance activities that would be performed on contamment structures and components, shall be used during this interim implementation period.
I1. 'the current plans and schedules for the next scheduled refueling outages shall be reviewed for work packages which could contain activities that would fall within these interim guidelines. Emergent work and issues will have to be evaluated on a case-by-case basis, as they are encountered, and the interim processes of this request-for-relief applied.
- 12. Plant work planning personnel shall be thoroughly informed of these interim program principles.
Justification: TVA is just beginning, as are other utilities, to review our plant designs to determine what specifically should be included within the scope of the containment inspection program. The major components of the steel containment vessel would obviously be within the scope of the rule. TVA has performed a preliminary review and determined that the requirements of Subsection IWL do not apply to the free-standing metal contamment structure at SQN. However, without a more detailed review, it is not possible to readily determine all the speci% site / unit components which would be required to be included within the scope of Subsection IWE.
Without the proper classification of these components with respect to the inspection categories in Table IWE 2500-1, it is not possible to completely ensure that, if repairs or replacements are made to these components, the I proper preservice exammations are performed. In addition, without the proper programs being fully established, it is not possible, both technically and administratively, to control and ensure that all the requirements within the scope of the rule are being addressed. ,
It should be noted that any components within the scope of the rule are also within the scope of TVA's QA program. These components are generally categorized as TVA Safety Classification B. This corresponds to an ANS Safety Classification 2a. TVA's classifications impose strict Code and i
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q w Quality Assurance requirements on work activities associated with these components. 'Ilese requirements are also the rules that the Code would require to be part of any owner's ASME Section XI contamment repair and replacements program. In addition, these requirements have consistently been used as a basis for containment structure work activities at TVA's nuclear plants. The major differences between the current TVA QA program based R&R requirements and the ASME Section XI, Subsection IWE, based requirements are the performance of the required preservice exammations following the repair or replacement, and the involvement of the Authorized Nuclear Inservice Inspector.
TVA is in the planning process of fully developing the necessary programs for implementation of the Subsection IWE rules. Currently, our prelimmary schedule shows that we are planning to have the necessary R&R procedures in place by August 8,1997. In addition, TVA program personnel are planning to complete initial reviews of design drawings by September 26, 1997. Walk-downs of these items for verification, are scheduled commencing with the next available unit outages after this initial design drawing review. Our current pretinunary schedule indicates that we will start our actual first period first interval exammations for compliance to the new rule on the next available outages at the specific sites, as currently scheduled. For SQN, the currently scheduled initial examination dates are September 4,1998, for Unit I and on April 2,1999, for Unit 2. These outage schedules may vary with unit operating conditions and circumstances.
Since initial program examinations will not actually start for several years, the requirement to fully implement the new rules for repairs and replacements immediately presents an undue impact to TVA's current outage plans and schedules without a corresponding increase in quality or safety. This judgment is based upon an evaluation of the differences between the current TVA QA programmatic requirements, the proposed interim requirements, and the new requirements of Subsection IWE. In addition, implementation of the R&R requirements of the rule change, when the scope is not known to the fullest extent, could result in TVA work plarming and implementation personnel omitting small specific components and details. The lack of fully developed technical and admmistrative controls places TVA in a position in which we could be found in non-compliance with the rule change if a work activity was performed on a component which should have been included in the scope of the program.
The requirement to immediately implement a fully developed containment R&R program puts TVA in the position of having to pull back the current outage planned work activities and possibly delay their implementation until such time that the ISI and R&R procedures are in place. In some cases, this could delay much needed improvements which may effect overall plant reliability. R&R programs at TVA are currently written to meet the requirements of the 1989 Edition of Section XI of the ASME Boiler and Pressure Vessel Code with specific requirements from other base codes-of-record as applicable to the unit's current inspection interval. This Code will
Edition of Section XI of the ASME Boiler and Pressure Vessel Code with ,
specific requirements from other base codes-of record as applicable to the l unit's current inspection interval. This Code will remam the base Code-of- l Record for containment R&R programs during the proposed interim period.
In addition, any actual work that has been performed during the period between September 9,1996, and the incorporation of the interim measures outlined above will have been performed under the existing TVA QA progran requirements. Since this work was performed in accordance with the TVA's current QA and ASME Section XI R&R programs, the work restored the associated containment structures to at least the muumum ;
requirements of the original construction and installation standards, t Therefore, no further action with respect to the new requirements would be L warranted. In addition, this work will be captured within the inservice inspection programs for future inspections, as required by the fully developed contamment ISI programs.
In summary, the above proposed processes provide for the restoration of the containment structures following repairs and replacements to conditions that meet at least the original construction requirements and proside for traceable documentation of the work performed. This interim process results in a level of quality and safety equivalent to that required under the 10CFR50.55a rule change, t l
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