ML042920201
| ML042920201 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/15/2004 |
| From: | Yoira Diaz-Sanabria NRC/NRR/DRIP/RLEP |
| To: | |
| DIAZ-SANABRIA, Y /NRR/DRIP/RLEP 415-1594 | |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML042920201 (14) | |
Text
October 15, 2004 LICENSEE:
TENNESSEE VALLEY AUTHORITY FACILITY:
BROWNS FERRY NUCLEAR PLANT UNITS 1, 2 AND 3
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON SEPTEMBER 15, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE TENNESSEE VALLEY AUTHORITY CONCERNING BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 LICENSE RENEWAL APPLICATION (TAC NOS. MC1704, MC1705 AND MC1706)
The U.S. Nuclear Regulatory Commission staff and representatives of Tennessee Valley Authority (TVA or the applicant) held a telephone conference call held on September 15, 2004, to discuss questions related to Reactor Coolant System, Engineered Safety Features, Auxiliary Systems, Sections 2.3.1, 2.3.2 and 2.3.3 respectively, and Appendix F related to Section 2.3 of the Browns Ferry Nuclear Plant (BFN) license renewal application.
The conference call was useful in clarifying the intent of the staffs questions. On the basis of the discussion, the applicant was able to understand the staff's questions. The NRC staff acknowledged the applicants discussion and indicated that the clarification was understood.
No staff decisions were made during the telephone conference call. In some cases, the applicant agreed to provide information for clarification. and Enclosure 2 contain a listing of the questions discussed with the applicant, including a brief description on the status of the items. Enclosure 3 provides a listing of the telephone conference call participants. The applicant has had an opportunity to comment on this summary.
/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
Enclosures:
As stated cc w/enclosures: See next page
ML042920201 DISTRIBUTION:
See next page Document Name:C:\\MyFiles\\Copies\\DRAI 2.3 Rx Systems.wpd OFFICE PM:RLEP PM: RLEP LA:RLEP SC:RLEP NAME Y. Diaz-Sanabria R. Subbaratnam MJenkins S. Lee DATE 10/15/04 10/15/04 10/13/04 10/15/04
DISTRIBUTION: Dated: October 15, 2004 Accession ML042920201 HARD COPY RLEP RF Yoira Diaz Sanabria (PM)
Ram Subbaratnam (PM)
E-MAIL:
RidsNrrDe RidsNrrDSSA RLEP staff S. Black Y.L. (Renee) Li C. Li K. Jabbour A. Hodgdon R. Weisman C. Carpenter A. Howe J. Guo R. Goel J. Raval M. Razzaque DRAFT REQUEST FOR ADDITIONAL INFORMATION (D-RAI) RELATED TO APPENDIX F:
INTEGRATION OF BROWNS FERRY UNIT 1 RESTART AND LICENSE RENEWAL OF BROWNS FERRY UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION Section 2.3.3.14: Sample and Water Quality System D-RAI F 2.3.3.14-1 LRA Section 2.3.3.14, Sampling and Water Quality Systems, states that one of the intended functions of this system is to establish main steam isolation valve (MSIV) leakage pathway to the condenser (F.1) (denoted with a bold-bordered enclosure). Appendix F.1 states that the Unit 1 main steam piping from the outermost isolation valve up to the turbine stop valve, the bypass/drain piping to the main condenser, and the main condenser are being evaluated and modified as required to ensure the structural integrity is retained during and following a safe-shutdown earthquake (SSE). The sampling lines from the main steam system are shown as being subject to an AMR on license renewal drawing 2-47E610-43-1-LR (location E1) for Unit
- 2. However, the similar piping and components on license renewal drawing 1-47E610-43-1-LR (location E1) for Unit 1 are shown as not being subject to an AMR. It is not clear why this portion of Unit 1 piping is not subject to an AMR. Explain why this portion of piping is not subject to an AMR.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI F 2.3.3.14-1.
Section 2.3.4.1: Main Steam System D-RAI F 2.3.4.1-1 Section 2.3.4.1, Main Steam System, states that one of the intended functions of the main steam system is to establish main steam isolation valve leakage pathway to the condenser.
Section F.1 of LRA Appendix F states the Unit 1 main steam piping from the outermost isolation valve up to the turbine stop valve, the bypass/drain piping to the main condenser and the main condenser is being evaluated and modified as required to ensure the structural integrity is retained during and following an SSE. Portions of the main steam system (from the turbine building on) are not shown as being subject to an AMR on license renewal drawing 1-47E801-1-LR. However, the similar segments of piping are shown as being subject to an AMR on license renewal drawings 2-47E801-1-LR and 3-47801-1-LR. On the basis of a review of the drawings and the information provided in LRA Sections 2.1 and F.1 of Appendix F, it is not clear why the sections of piping on license renewal drawing 1-47E801-1-LR are not subject to an AMR. Justify the exclusion of the piping sections in question from being within the scope of license renewal and being subject to an AMR.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI F 2.3.4.1-1.
D-RAI F 2.3.4.1-2 Certain main steam system components in Units 2 and 3 associated with the reactor feed pump turbine drivers, the steam air ejector subsystem, and the steam seal regulator subsystem are highlighted as being subject to an AMR on license renewal drawings 2-47E801-2, 2-47E807-2, 3-47E801-2 and 3-47E807-2. The corresponding components for Unit 1 should likewise be subject to an AMR. However, the drawings which show these components, such as license renewal drawings 1-47E801-2 (shown as a continuation line on drawing 1-47E801-1) and 2-47E807-2 and 3-47E807-2 (the corresponding drawings for Unit 1) are not provided. As a result, the staff is unable to determine if all of the aforementioned Unit 1 components, which are within the scope of license renewal and subject to an AMR for Units 2 and 3, were identified.
Provide license renewal drawing 1-47E801-2 and the Unit 1 drawing which corresponds to drawings 2-47E807-2 and 3-47E807-2.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI F 2.3.4.1-2.
Section 2.3.4.5: Turbine Drains and Miscellaneous Piping System D-RAI F 2.3.4.5-1 LRA Section 2.3.4.5 states that the intended function of the turbine drains and miscellaneous piping system is to establish the main steam isolation valve leakage pathway to the condenser.
The entire LRA section is enclosed in a bold text box. Appendix F, Section F.1, Main Steam Isolation Valve Alternate Leakage Treatment, states that the Unit 1 main steam piping from the outermost isolation valve up to the turbine stop valve, the bypass/drain piping to the main condenser and the main condenser is being evaluated and modified as required to ensure that the structural integrity is retained during and following an SSE. However, it is not clear where the alternate leakage treatment flow path to the condenser exists on license renewal drawings 2-47E807-2-LR and 3-47E807-2-LR. Identify which portions of these drawings contain components that are part of the leakage pathway to the condenser.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI F 2.3.4.5-1.
Sections 2.3.2 and 2.3.3: Heating Ventilation and Air Conditioning System (HVAC) and Filtration Systems D-RAI F 2.3-1 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 LRA Section 2.3.2.1, Containment (Reactor Building Ventilation System), LRA Section 2.3.2.2, Standby Gas Treatment System, LRA Section 2.3.3.8, Ventilation System (various plant buildings including the radioactive waste building and the DG buildings), nor LRA Section 2.3.3.9, Heating, Ventilation, and Air Conditioning System, it implies that the current licensing or design bases applicable to Units 1, 2 and 3 HVAC systems remain unchanged, even if Unit 1 is in letup condition while its design modifications are currently pursued to make BFN Unit 1 current licensing or design bases identical to those in BFN Units 2 and 3. Verify whether the licensing and design bases for HVAC and exhaust filtration systems described in LRA Sections 2.3.2.1, 2.3.2.2, 2.3.3.8, and 2.3.3.9 will remain unaffected for BFN Unit 1. If any changes are need to be implemented for Unit 1 HVAC and exhaust filtration systems to make them identical to Units 2 and 3 systems, describe the process that implement these changes. Accordingly, revise the LRA on the docket to include these changes in the LRA text, tables, and drawings, as applicable, for the 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).
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI F 2.3-1.
BROWNS FERRY NUCLEAR (BFN) PLANT, 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)
D-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 ensure 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 above discussion, the staff requests the applicant to affirm 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.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.1.2-1.
D-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 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 plants following power uprate. The staff, therefore, requests the applicant to either include the steam dryers within the scope of license renewal requiring aging management, or to provide plant-specific justifications for excluding it. 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.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.1.2-2.
2.3.1.4 Reactor Recirculation System (RRS)
D-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 the intended functions which needs to be maintained during the extended period of operation by assigning appropriate aging management program for it.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.1.4-1.
2.3.2.5 Core Spray System D-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.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.2.5-1.
2.3.2.7 Containment Atmospheric Dilution (CAD) System D-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) are also have been included within the scope requiring aging management.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.2.7-1.
2.3.3.23 Reactor Core Isolation Cooling D-RAI 2.3.3.23-1 In Section 4.7.5 of the UFSAR, it is stated that the 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 scope requiring aging management.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.3.23-1.
2.3.3.32 Neutron Monitoring System D-RAI 2.3.3.32-1 (a)
On 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 sub-system 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 monitor able, 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.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as RAI 2.3.3.32-1.
LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE HELD ON September 15, 2004 Participants Affiliation Yoira Diaz U.S. Nuclear Regulatory Commission (NRC)
Ram Subbaratnam NRC Jin Guo NRC Janak Raval NRC Raj Goel NRC Muhammad Razzaque NRC Ken Brune Tennessee Valley Authority (TVA)
Don Arp TVA Roger Jennings TVA Valerie Smith TVA Bruce Buch TVA
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 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
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Mr. Fred Emerson Nuclear Energy Institute 1776 I St., NW, Suite 400 Washington, DC 20006-2708 Ken Brune, Manager Browns Ferry License Renewal Project Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801