ML042860015
| ML042860015 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/08/2004 |
| From: | Yoira Diaz-Sanabria NRC/NRR/DRIP/RLEP |
| To: | Singer K Tennessee Valley Authority |
| Diaz -Sanabria, Y, NRR/NRC/RLEP,415-1594 | |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML042860015 (8) | |
Text
October 8, 2004 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:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 LICENSE RENEWAL APPLICATION (TAC NOS. MC1704, MC1705 AND MC1706)
Dear Mr. Singer:
By letter dated December 31, 2003, Tennessee Valley Authority (TVA) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2 and 3, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified areas where additional information is needed to complete the review. Specifically, the enclosed requests for additional information (RAIs) are related to the scoping results for Reactor Coolant Systems, Engineering Safety Features, and Auxiliary Systems, Sections 2.3.1, 2.3.2, and 2.3.3 respectively. Drafted forms of these RAIs were discussed with TVA staff on a telephone conference call on September 15, 2004.
Based on discussions with Ken Brune of your staff, a mutually agreeable date for your response to the RAIs is within 30 days of the date of this letter. If you have any questions regarding this letter or if circumstances result in your need to revise the response date, please contact me at 301-415-1594 or by e-mail at yks@nrc.gov.
Sincerely,
/RA/
Yoira K. Diaz Sanabria, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260 and 50-296
Enclosure:
As stated cc w/encl: See next page
ML042860015 DISTRIBUTION: See next page
- Input provided by memo Document Name: C:\\My Files\\Copies\\RAI 2.3 Rx Systems.wpd OFFICE PM:RLEP LA:RLEP SC: SPLB*
SC:RLEP NAME YDiaz-Sanabria Y. Edmonds FAkstulewicz SLee DATE 10/804 10/8/04 9/13/04 10/8/04
DISTRIBUTION: Ltr. to K. Singer, TVA, Re: Browns Ferry Nuclear Plant, Units 1, 2 and 3, Dated: October 8, 2004 Accession No: ML042860015 HARD COPY:
RLEP RF Yoira Diaz-Sanabria (PM)
Ram Subbaratnam (PM)
E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li M. Itzkowitz (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff K. Jabbour C. Julian (RII)
S. Cahill (RII)
A. Hodgdon C. Carpenter D. Coe E. Kleeh A. Howe M. Razzaque
Enclosure BROWNS FERRY NUCLEAR PLANT (BFN), UNITS 1, 2 AND 3 LICENSE RENEWAL APPLICATION (LRA)
SCOPING: SECTIONS 2.3.1, 2.3.2, AND 2.3.3 2.3.1.2 Reactor Vessel Internals (RVI)
RAI 2.3.1.2-1 In Table 2.3.1.2 of the LRA, one of the intended functions of core spray spargers was appropriately identified as maintaining the spray pattern in a manner that all fuel assemblies will be adequately cooled following a LOCA. The staffs understanding is that adequate long-term core cooling following a LOCA can only be assured by retaining the original spray distribution over the core which was assumed for the CLB. In the safety evaluation report (SER) for the BWRVIP-18 report, the staff had concluded that when performing inspection of core spray spargers, all BWR plants must be treated as geometry-critical plants. Furthermore, it is staffs understanding that the previous BWRVIP designations of geometry-tolerant plants have been rescinded and all plants are now considered to be geometry-critical. Consequently, in order to assure adequate cooling of the uncovered upper third of the core, the core spray system must provide adequate spray distribution to all bundles in the core. The staff also believes that leakage through sparger and piping cracks, as well as repairs and potential blockage of spray nozzles must be considered in assessing the core spray distribution. As a result, it is essential that spraying water on the fuel assemblies in a pattern that was originally designed must be maintained, and that the applicants aging management activities be devised to provide a reasonable assurance that the original spray distribution will be preserved during the period of extended operation.
On the basis of the above discussion, the staff requests the applicant to affirm that when performing inspection of core spray spargers, the BFN plants are inspected in accordance to the requirements for the geometry-critical plants, as required by the staff SER for BWRVIP-18 report; and that the original spray pattern assumed for the CLB will be preserved during the extended period of operation.
RAI 2.3.1.2-2 Recent industry experience of steam dryer failures at operating BWRs following power uprate, for example at Quad Cities; and potential to generate loose parts that can degrade safety-related components have necessitated the staff to reconsider whether steam dryer should be within the scope of license renewal, in accordance with 10 CFR 54.4(a)(2), requiring aging management. Although the steam dryer does not perform a safety-related function, the steam dryer must maintain its structural integrity to support emergency core cooling system (ECCS) operation, and also to prevent the occurrence of loose parts in the reactor vessel or steam lines that could adversely affect plant operation. The Interim Staff Guidance (ISG-09),
which provides clarification of the 10 CFR 54.4(a)(2) scoping criterion, states that if industry failures of non safety-related SSCs have previously been experienced that may impact safety-related SSCs, then the applicant should include such non safety-related SSCs within the scope of license renewal; or to provide explanation that similar failures are unlikely to occur at the BFN plant following power uprate. The staff, therefore, requests the applicant to include the steam dryers within the scope of license renewal requiring aging management. The applicants response should also include the following additional information:
a)
Are the steam dryer designs at BFN and Quad Cities similar? If not, please describe the significant differences between the two designs which support the conclusion that steam dryer failure similar to Quad Cities are unlikely to develop at the BFN steam dryers following power uprate.
b)
Describe any actions, including analysis, that will be performed to confirm whether extended power uprate conditions will either generate, or not generate loose parts from the steam dryer.
2.3.1.4 Reactor Recirculation System (RRS)
RAI 2.3.1.4-1 In the LRA Table 2.3.1.4 for the RRS and for a few other systems (for example Containment Inerting system), heat exchangers have been identified as a component type within the scope of license renewal. However for these heat exchangers, the pressure boundary was identified as the only intended function requiring aging management, not their heat transfer function. The staff requests the applicant to clarify why the heat transfer function, in addition to pressure boundary, was not also identified as one of the intended functions which needs to be maintained during the extended period of operation by assigning appropriate aging management program for it.
2.3.2.5 Core Spray System RAI 2.3.2.5-1 The low pressure coolant injection (LPCI) coupling was identified in the BWRVIP-06 report as a safety-related component. It appears, however, that the component was not identified in the LRA requiring an AMR. If the component exists at BFN, then the staff requests the applicant to justify its exclusion from aging management; otherwise, submit an AMR for the subject component.
2.3.2.7 Containment Atmospheric Dilution (CAD) System RAI 2.3.2.7-1 In Section 2.3.2.7 of the LRA and in the UFSAR Sections 5.2.3 and 5.2.6, it is indicated that each train of the CAD system has a liquid nitrogen supply tank, an ambient vaporizer and an unqualified electric heater. One of the intended functions identified for the CAD system is to provide dilution of the primary containment atmosphere with nitrogen after a LOCA to maintain gas concentrations below level which could produce a combustible gas mixture. However, in Table 2.3.2.7 of the LRA, the components of the CAD system which mainly perform pressure boundary function have been listed as within the scope of license renewal. Please confirm whether all the components of the CAD system that perform containment atmosphere dilution function (in addition to pressure boundary function) have been included within the scope requiring aging management.
2.3.3.23 Reactor Core Isolation Cooling RAI 2.3.3.23-1 In Section 4.7.5 of the UFSAR, it is stated that the reactor core isolation cooling (RCIC) makeup water is delivered into the reactor vessel through a connection to the feedwater line and is distributed within the reactor vessel through the feedwater sparger. The connection to the feedwater line is provided with a thermal sleeve. It is further stated that the thermal sleeve (liner) in the feedwater line is designed as a nonpressure-containing liner and is provided to protect the pressure-containing piping tee from excessive thermal stress. In Table 2.3.3.23 of the LRA, thermal sleeve (liner) was not identified as a component type within the scope of license renewal. The staff, therefore, requests the applicant to include this component type within the scope requiring aging management.
2.3.3.32 Neutron Monitoring System RAI 2.3.3.32-1 (a)
In page 2.3-104 of the LRA, it is stated that the Average Power Range Monitor Subsystem averages the Local Power Range Monitor Subsystem signals to provide an overall indication of reactor power for control and trip functions. A subsystem of the Average Power Range Monitor Subsystem [the Oscillation Power Range Monitor (OPRM)] ensures reactor operation in a stable thermal-hydraulic region. The Rod Block Monitor receives input from Local Power Range Monitors close to a control rod to prevent fuel damage in the event of a rod withdrawal error. Furthermore, it was stated in the LRA that the portions of the Neutron Monitoring System that contain components subject to an AMR are only those that form part of the reactor coolant pressure boundary. The staff believes that in addition to the portions that are pressure boundary, OPRM and its functions, as described above, are passive and safety-related; and hence meets the criteria delineated in 10 CFR 54.4(a)(1) and 10 CFR 54.21(a)(1). Therefore, unless the OPRM is subject to replacement based on a qualified life or specified time period; or degradation of its ability to perform its intended functions due to aging is readily monitorable, the component should be within the scope requiring aging management. Please provide a justification for why these components are not within the scope of license renewal.
(b)
The staff also requests the applicant to provide the basis for excluding other neutron monitoring subsystems in BFN (except portions that perform pressure boundary function) from the scope of license renewal.
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Mr. Ashok S. Bhatnagar, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. James E. Maddox, Vice President Engineering & Technical Services Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Michael D. Skaggs, Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority ET 11A 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Kurt L. Krueger, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Jon R. Rupert, Vice President Browns Ferry Unit 1 Restart Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Robert G. Jones Browns Ferry Unit 1 Plant Restart Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Mark J. Burzynski, Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Bobby L. Holbrook Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611 Mr. Fred Emerson Nuclear Energy Institute 1776 I St., NW, Suite 400 Washington, DC 20006-2708
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Ken Brune, Manager Browns Ferry License Renewal Project Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801