ML042750259
| ML042750259 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/30/2004 |
| From: | Abney T Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML042750259 (16) | |
Text
10 CFR 54 September 30, 2004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:
In the Matter of
) Docket Nos. 50-259 Tennessee Valley Authority
) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION - RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) (TAC NOS. MC1704, MC1705, AND MC1706)
By letter dated December 31, 2003, the Tennessee Valley Authority (TVA) submitted, for NRC review, an application pursuant to 10 CFR 54, to renew the operating licenses for Browns Ferry Nuclear Plant, Units 1, 2, and 3. As part of its review of TVAs license renewal application, the NRC staff by letter dated August 23, 2004, identified areas where additional information is needed to complete its review.
The specific areas are from Sections 2.3, 3.3, 4.4, B.2.0, and Appendix F of the fire protection system, related to the Scoping and Screening: Mechanical Systems, Aging Management of Auxiliary Systems, and Aging Management Programs respectively.
The enclosure to this letter contains the specific NRC requests for additional information and the corresponding TVA responses.
U.S. Nuclear Regulatory Commission Page 2 September 30, 2004 If you have any questions regarding this information, please contact Ken Brune, Browns Ferry License Renewal Project Manager, at (423) 751-8421.
I declare under penalty of perjury that the forgoing is true and correct. Executed on this 30th day of September, 2004.
Sincerely, Original signed by:
T. E. Abney Manager of Licensing and Industry Affairs
Enclosure:
cc: See page 3
U.S. Nuclear Regulatory Commission Page 3 September 30, 2004 Enclosure cc (Enclosure):
State Health Officer Alabama Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, Alabama 35611 (Via NRC Electronic Distribution)
Enclosure cc (Enclosure):
U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 Mr. Stephen J. Cahill, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 NRC Unit 1 Restart Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 cc: continued page 4
U.S. Nuclear Regulatory Commission Page 4 September 30, 2004 cc: (Enclosure)
Kahtan N. Jabbour, Senior Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Eva A. Brown Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Yoira K. Diaz-Sanabria, Project Manager U.S. Nuclear Regulatory Commission (MS 011F1)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739
U.S. Nuclear Regulatory Commission Page 5 September 30, 2004 JWD:BAB Enclosure cc (Enclosure):
A. S. Bhatnagar, LP 6-C K. A. Brune, LP 4F-C J. C. Fornicola, LP 6A-C D. F. Helms, LP 6A-C F. C. Mashburn, BR 4X-C R. G. Jones, NAB 1A-BFN K. L. Krueger, POB 2C-BFN R. F. Marks, Jr., PAB 1A-BFN J. R. Rupert, NAB 1F-BFN K. W. Singer, LP 6A-C M. D. Skaggs, PAB 1E-BFN E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS, WT CA-K s:lic/submit/subs/BFN LR Fire Protection RAI Response.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI)
(SEE ATTACHED)
E-2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI)
By letter dated December 31, 2003, the Tennessee Valley Authority (TVA) submitted, for NRC review, an application pursuant to 10 CFR 54, to renew the operating licenses for Browns Ferry Nuclear Plant, Units 1, 2, and 3. As part of its review of TVAs license renewal application the NRC staff, by letter dated August 23, 2004, identified areas where additional information is needed to complete its review. Listed below are the specific NRC requests for additional information and the corresponding TVA responses.
Section 2.3 Scoping and Screening Results: Mechanical Systems Section 2.3.3.6 High Pressure Fire Protection System RAI 2.3.3.6-1 The system description of the high pressure fire protection system in Section 2.3.3.6 includes fixed water spray systems.
Such systems typically utilize water spray nozzles. LRA Table 2.3.3.6 does not include water spray nozzles as a component subject to an AMR. Indicate whether the fixed water spray systems use spray nozzles other than the sprinkler heads. If so, the nozzles, which have an intended to support the system function, are passive and long lived and should be subject to an AMR.
TVA Response to RAI 2.3.3.6-1:
Fire Protection Spray nozzles (fixed spray nozzles and spray nozzles attached to fire hoses) were included in component type Sprinkler Heads in Table 2.3.3.6 of the LRA.
RAI 2.3.3.6-2 The system description of the high pressure fire protection system in Section 2.3.3.6 includes detection and alarm devices that automatically initiate the system or prompt manual fire fighting. These devices are not identified. Identify what these devices are and where they are included in the AMR.
E-3 Response to RAI 2.3.3.6-2:
High pressure fire protection detection and alarm devices do not form a pressure boundary and are active components and evaluated as electrical commodities.
RAI 2.3.3.6-3 License renewal drawing 1-47E850-1-LR shows the boundary of the high pressure fire protection water system is the service building wall. The boundary shown is not at an isolated pressure boundary (e.g., a valve or blank flange). Justify why the service building portions of the system are not in scope.
TVA Response to RAI 2.3.3.6-3:
The boundary did not end at the service building wall but continues on LR drawing 1-47E850-2-LR. BFN drawings depict continuation to other drawings with drawing coordinate flags.
For clarification the reference to drawing coordinate flag 1-47E850-2 (drawing coordinates G6) has been colored red on 1-47E850-1-LR. The boundary ends at isolation valve 0-26-907 on drawing 1-47E850-2-LR. The above drawing has been revised.
RAI 2.3.3.6-4 Drawing 3-47E850-5-LR identifies a water curtain around the equipment hatch at Elevation 565. Table 9.3.11.B in Volume 1 of the Fire Protection Report lists water curtains for the RHR Pump Room equipment hatches at Elevation 541. The license renewal drawings do not show anything on Elevation 541.
Clarify that the water curtain protection for the RHR Pump Room equipment hatches is in scope, and identify where they are located on the license renewal drawings.
TVA Response to RAI 2.3.3.6-4:
Water curtains at BFN are typically provided to protect floor openings and include closely spaced sprinklers and draft stops located around the opening underneath the floor slab. In Unit 3 Reactor building EL 565, as shown on drawing 3-47E850-5, water curtains are provided at the following six different locations:
- 1. Equipment hatch in floor opening above (between floor EL 565 and EL 593)
E-4
- 2. Stair No. 22 floor opening above (between floor EL 565 and EL 593)
- 5. East RHRSW HX/Pump Room floor opening below (between EL 541 and EL 565)
- 6. West RHRSW HX/Pump Room floor opening below (between EL 541 and EL 565)
The water curtains (5 and 6) in the RHRSW HX/Pump Room floor openings are located below EL 565 floor slab to protect the openings from the fire effects of EL 541. These two water curtains are described in Table 9.3.11.B Volume 1 of the Fire Protection Report as the water curtains for the RHR pump room equipment hatches at EL 541. These water curtains are in scope.
Section 2.3.3.12 CO2 System RAI 2.3.3.12-1 The CO2 system addressed in this section typically requires discharge nozzles to achieve the proper flow rate. The system description and LRA Table 2.3.3.12 do not include any reference to discharge nozzles. Indicate whether this system includes discharge nozzles. If so, the nozzles, which have an intended function of flow control, are passive and long lived and should be subject to an AMR.
TVA Response to RAI 2.3.3.12-1:
The discharge nozzles were included within component type Fittings in Table 2.3.3.12 with an intended function of pressure boundary and do require an AMR.
RAI 2.3.3.12-2 The system description of the CO2 System in LRA Section 2.3.3.12 includes detection and alarm devices that automatically initiate the system or prompt manual fire fighting. These devices are not identified. Identify what these devices are and where they are included in the AMR.
E-5 TVA Response to RAI 2.3.3.12-2:
CO2 System fire protection detection and alarm devices do not form a pressure boundary and are active components and evaluated as electrical commodities.
Section 3.3 Aging Management of Auxiliary Systems (Tables 3.2.2.1, 3.3.2.6, 3.3.2.12, 3.5.2.5, 3.5.2.10, and 3.5.2.12)
RAI 3.3-1 LRA Table 3.5.2.2, - Reactor Building - Summary of Aging Management Review, Lists Coating" (ALBI CLAD-161) as part of the fire barrier. This fire resistive coating for structural steel lists only for the Reactor Building in the table. It is unclear from the Fire Hazard Analysis (FHA) if this is the only building with structural steel protection. Procedure 0-SI-4.11.G.1.a, Visual Inspection of Fire Rated Barriers, refers to Albi-Clad coating on structural steel beams on Elevation 593' of the Control Building. Identify all in-scope structures which contain fire resistive coatings on structural steel. Design standard G-74, Fire Proofing of Structural Steel, Section 2.1.2, Safety-Related Nuclear Structures refers to Pyrocrete 241, Mandoseal P-50 or other approved material. Table 3.5.2.2 in the LRA refers to Albi-Clad 161. Verify which material(s) are applied. Acceptance criteria in procedure 0-SI-4.11.G.1.a, Visual Inspection of Fire Rated Barriers, is an unprotected area greater than one square foot. The fire resistance rating of the material or assembly is determined by the thickness. A reduction in thickness from mechanical or other means would reduce the fire resistance and prevent the steel from performing its intended fire protection function. Provide the technical basis for the "> one square foot" criteria for unacceptability.
Fire proofing protection (ALBI CLAD) is applied on the structural steel beams in the ceiling of elevation 593 that are used to support the floor slab (elevation 606) of the Control Building.
These structural steel beams are included in the Reactor Building license renewal boundary that includes the following fire areas that credit structural steel with ALBI CLAD fire proofing protection.
- Fire Area No. 16 - Control Building
E-6
- Fire Area No. 17 - Unit 1 Battery and Battery Board Room
- Fire Area No. 18 - Unit 2 Battery and Battery Board Room
- Fire Area No. 19 - Unit 3 Battery and Battery Board Room ALBI CLAD-900 may be used in lieu of ALBI CLAD-161 based on the general notes on drawing 0-47E403-17. Therefore, TVA will revise Table 3.5.2.2 of the LRA to show only ALBI CLAD without the type within the scope of License Renewal and update the LRA as appropriate.
Fire Barriers FB Coatings ALBI CLAD Inside Air Cracking due to vibration.
Loss of material due to abrasion, flaking.
Fire Protection Program (B.2.1.23)
None None J, 2 The above changes will be completed as part of the annual LRA update. There is no other fire proofing applied to the structural steel beams that is credited as an Appendix R Fire Barrier. G-74 is a General Engineering Specification [GES] (not a Design Standard as referred to in the above request) that establishes requirements for materials, applications, and verification of fireproofing of structural steel using bonded, cementitious materials, whereas ALBI CLAD-161 and ALBI CLAD-900 are an intumescent material. The materials specified in G-74, section 2.1.2 were not used at Browns Ferry for fireproofing; therefore, G-74 was not invoked.
The acceptance criteria in 0-SI-4.11.G.1.a, section 7.2.1.2, states...A loss of protection of > 1.0 sq. ft. (individual or cumulative) per beam is unacceptable. This criteria is contained in TVA design change notice (DCN) Q37202A and is based on A study of the Effect of Partial Loss of Protection on the Fire Resistance of Steel Columns, published in Fire Technology, Volume 29, Number 1 1993.
RAI 3.3-2 LRA Table 3.5.2.2, Reactor Building - Summary of Aging Management Review," identifies ceramic fiber as having no aging effects and therefore requiring no AMP. Describe how these materials are used and provide the technical basis for the conclusion of no aging effects.
Ceramic fiber materials are installed as part of the fire penetration seals used at Browns Ferry. Fire penetration seals
E-7 are installed in a non-aggressive, vibration free inside air environment that is not conducive to promoting aging of the ceramic fiber materials. Industry experience, including previous experience at Browns Ferry, has not identified aging that would deteriorate ceramic fiber materials installed as part of the fire penetration seals. The following ceramic fiber components in an inside air environment were identified:
- Reactor Building fire barriers
- Diesel Generator Building fire barriers Ceramic and glass fiber used to seal fire barrier penetrations do not have any applicable aging effects requiring aging management. This is consistent with the Fort Calhoun License Renewal SER concurrence that there are no applicable aging effects for glass used in a metal fire barrier penetration
[Fort Calhoun SER, ADAMS accession number ML032481209]. This is also consistent with NUREG-1769 SER related to the License Renewal of Peach Bottom Atomic Power Station 2 and 3 concurrence that insulation made of aluminum, stainless steel (mirror),
calcium silicate, ceramic fiber, or fiberglass in a sheltered environment does not have any aging effects requiring aging management.
A review of Browns Ferry operating history did not reveal any loss of intended function due to aging effects for the following ceramic fiber components.
- Reactor Building fire barriers
- Diesel Generator Building fire barriers RAI 3.3-3 LRA Table 3.5.2.12 identifies Thermolag as a fire barrier and referred to LRA Appendix B, Section B.2.1.23. Cable wraps are not specifically addressed in Section B.2.1.23. Is this the only area of the plant where cable wrap fire barriers are used?
Electrical raceway fire barriers are referenced in plant operating experience as experiencing "minor degradation."
Identify all areas where cable wraps are provided, and verify that these barriers are included in the AMP.
E-8 TVA Response to RAI 3.3-3:
Thermolag is used as a cable wrap fire barrier at the Intake Pumping Station. Visual inspection of the cable wrap fire barrier at the Intake Pumping Station is performed by Surveillance Instruction (SI) 0-SI-4.11.G.1.a (1), Visual Inspection of Fire Wraps, and this SI is included in the AMP (Fire Protection Program, B.2.1.23).
There is no other documented cable wrap fire barriers that are credited as an Appendix R Fire Barrier.
Section B.2.0 Aging Management Programs Section B.2.1.23 Fire Protection Program Section B.2.1.24 Fire Water System Program RAI B.2.0-1 Appendix B, Section B.2.1.23 Fire Protection Program," does not address what is included in the fire pumps and does not reference the electric fire pumps. The boundary drawings show the three electric and one diesel fire water pumps as in scope.
Verify that the electric fire pumps are included in the AMR and AMP. The smaller electric service water pumps are used for pressure maintenance, but are not shown in scope. Justify why these pressure maintenance devices are not in scope.
The three electric fire pump casings are included in the AMR and AMP. The raw service water (RSW) pumps are used to fill the raw water head tanks located on the roof of the reactor building to provide static head to the system and also supply water to extinguish a small fire until the fire pumps start. The RSW pumps are not used for pressure maintenance in the traditional sense (i.e., do not operate as a jockey pump). The RSW pumps maintain a static head of approximately 60 psi as opposed to the required 130 psi. The RSW pumps are isolated as soon as the fire pumps start. The electric fire pumps are started either manually from various plant locations or automatically through temperature/smoke detectors. The fire pumps at BFN do not start on low header pressure and, therefore, do not require a pressure maintenance pump. Note that only subsequent fire pump starts (after the initial start) are based on header pressure. The fire protection capability to control and extinguish fires is not dependent on the operability of the RSW pumps; therefore, these pumps are not in scope.
E-9 RAI B.2.0-2 The AMP references periodic visual inspections" as an exception to the GALL, in Section B.2.1.23. Section 9.4.11.G of the Fire Protection Report (FPR) discussed semi-annual inspection of fire doors including a check of closers and latching mechanisms.
Describe the specific exceptions to the GALL the AMP for fire doors. The GALL recommends verification of door clearances to assure the door can perform in a fire and remain latched. Explain how a visual inspection can verify the closer and latching mechanism. Verify that the frequency of these surveillances is consistent with the FPR.
Surveillance Instruction (SI) 0-SI-4.11.G.2, Semiannual Fire Door Inspection is discussed in the AMP and is being credited as one of the BFN site specific procedures credited for the Fire Protection Aging Management Program. A SI verifies the required clearances are maintained and periodic functional tests of closing mechanisms are performed. The only exception to the GALL in the AMP for fire doors is that inspectors are not qualified to visual examination (VT-1 and VT-3) requirements.
The frequency and inspection of the Fire Doors is defined in the Fire Protection Report and the SIs written to satisfy the requirement.
Appendix F - Integration of Browns Ferry Unit 1 Restart and License Renewal Activities Section F.3 Fire Protection RAI F.3-1 Appendix F to LRA states that, "Whenever text annotated with a bold border box appears in the LRA symbolizing a licensing or design basis that is only applicable to Units 2 and 3, a link is provided to the appropriate Appendix F section.
Systems/Structures/Components Impacted - The impacted systems, structures, or components are identified with links to the appropriate Chapter 2 sections and the appropriate Chapter 3 sections."
Since there is no text annotated with a bold border box that appears in either of the LRA Section 2.3.3.12, CO2 System, "LRA Section 3.3.2.1.6, High Pressure Fire Protection System" and
E-10 LRA Section 3.3.2.1.12 CO2 System," it symbolizes that the pertinent licensing or design bases equally applicable to Units 1, 2, and 3 fire protection system.
Verify that the licensing or design bases of fire protection systems listed in LRA Sections 2.3.3.12, 3.3.2.1.6, and 3.3.2.1.12 are equally applicable to Units 1, 2, and 3 without any exceptions.
Provide justification in detail, if any deviations noted, and revise corresponding LRA tables to identify these impacted systems, structures, or components that are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
Sections 2.3.3.12 and 3.3.2.1.12 are not boxed because there are no Unit 1 specific CO2 System components. Components are Unit 0 (common for both Unit 1 and Unit 2) and Unit 3; therefore, there are no licensing or design basis differences between the Units for this System.
Section 3.3.2.1.6 has nothing boxed in this table since there is not expected to be any changes to the Application based on Modifications in the High Pressure Fire Protection System (26) issued design packages. Any changes required by design work will be implemented in our annual update. The only reason Section 2.3.3.6 is boxed is because the Fire Protection Report does not reflect Unit 1 as an operating unit at the present time.
Review of Fire Protection Report (FPR)
RAI 4.4.1-1 Section 4.4.1.a of the FPR addresses a separate water supply system, including tank and pumps, which does not appear in the LRA or boundary drawings. Verify whether these system components are in scope and provide the justification if they are not.
The separate water supply system is referring to the outside loop and is not in scope since it is servicing non-safety related areas of the plant which provide equipment/property
E-11 protection and meet insurance (NEIL) requirements so they do not meet any of the criteria of 10 CFR 54.4.
RAI 4.4.5-1 Section 4.4.5 of the FPR states that Flammastic was applied to cables that did not meet IEEE-383 flame tests requirements.
Inspection Testing and Maintenance (ITM) of this is not referenced in the FPR. No reference is made to it in the LRA, either under the Fire Protection Program, Section B.2.1.23, or in the electrical or structural programs. This still appears to be a license condition. Identify where these coating are addressed in the LRA scoping, screening and AMR sections.
Flamemastic is primarily used as a flame retardant on non-IEEE 383 qualified cables. This commitment originated as part of the post-Fire Recovery Plan. As stated in the FPR, current practice is to use cables that meet the IEEE 383 requirements for flame retardant and hence, Flamemastic is not applied to these cables.
Since Flamemastic is not considered a fire stop or a fire resistive barrier, the Appendix R safe shutdown analysis does not take credit for it. Some cable tray penetration seal assemblies; however, use a coating of Flamemastic on the fiber board and cables around the opening to meet the fire barrier function.
Materials lists in Sections 3.5.2.1.2 and 3.5.2.1.5 should include Coatings.
Table 3.5.2.2 should include the following line item and Plant Specific Note for Flamemastic coatings.
Fire Barriers FB Coatings Flamemastic (when used in a qualified Fire Barrier configuration)
Inside Air Cracking due to vibration.
Loss of material due to abrasion flaking.
Fire Protection Program (B.2.1.23)
None None J, 2, 11 Note 11 - This includes both sides of the Reactor Building/Turbine Building wall cable tray penetrations.
Table 3.5.2.5 should include the following line item for Flamemastic coatings.
Fire Barriers FB Coatings Flamemastic (when used in a qualified Fire Barrier configuration)
Inside Air Cracking due to vibration.
Loss of material due to abrasion, flaking.
Fire Protection Program (B.2.1.23)
None None J, 1