ML043000040
| ML043000040 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/22/2004 |
| From: | Yoira Diaz-Sanabria NRC/NRR/DRIP/RLEP |
| To: | Tennessee Valley Authority |
| DIAZ-SANABRIA, Y /NRR/DRIP/RLEP 415-1594 | |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML043000040 (11) | |
Text
October 22, 2004 LICENSEE:
TENNESSEE VALLEY AUTHORITY FACILITY:
BROWNS FERRY NUCLEAR PLANT UNITS 1, 2 AND 3
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE HELD ON AUGUST 18, 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 on August 18, 2004, to discuss questions related to Section 3.3 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. In some cases, the applicant agreed to provide information for clarification. contains a listing of the questions discussed with the applicant. Enclosure 2 provides a list of the telephone conference 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/encls: See next page
ML043000040 DISTRIBUTION:
See next page Document Name:E:\\Filenet\\ML043000040.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME Y. Diaz-Sanabria MJenkins S. Lee DATE 9/15/04 9/14/04 10/22/04
DISTRIBUTION: Dated: October 22, 2004 Accession No.: ML043000040 HARD COPY RLEP RF Yoira Diaz Sanabria (PM)
E-MAIL:
RidsNrrDe RLEP staff S. Black Y.L. (Renee) Li R. McNally S. Bailey R. Subbaratnam K. Jabbour A. Hodgdon R. Weisman C. Carpenter A. Howe BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 LICENSE RENEWAL APPLICATION DRAFT REQUEST FOR ADDITIONAL INFORMATION (D-RAI)
AUXILIARY SYSTEM AND COMPONENTS SECTION 3.3 General Question D-RAI 3.3.2.1-1 Aging management review (AMR) table line items for copper alloy in an inside air (external) environment, for this material/environment combination, the LRA identifies no aging effect requiring management (AERMs) and, consequently, proposes no aging management programs (AMPs). However, the existence of AERMs depends on the particular alloy and whether there is condensation or pooling on the component. For example, high zinc (>15%) alloys in condensation or pooling water may exhibit stress corrosion cracking, selective leaching, or pitting and crevice corrosion. The LRA definition of inside air (external) would support condensation and pooling. Clarify how condensation and pooling were considered in the evaluation of potential aging of susceptible alloys.
Discussion: The applicant indicated that the question is clear. This question may be sent as RAI 3.3.2.1-1.
Fuel Oil System D-RAI 3.3.2.1.2-1 LRA Section 3.3.2.2.7 indicates that the one-time inspections will be performed at locations where contaminants would accumulate in the fuel oil system. It appears that this is applicable to the entire system, even though not all components specifically cite this LRA section (via Table 3.3.1 Item 3.3.1.7). Clarify whether this is the case. Also, clarify whether it applies to the copper alloy components in a fuel oil environment, if contaminants can accumulate in these components. If not, provide justification for not performing inspections at all system low points where contaminants could accumulate, or provide aging management for these areas.
Discussion: The applicant indicated that the question is clear. This question will be sent as RAI 3.3.2.1.2-1.
D-RAI 3.3.2.1.2-2 In Table 3.3.2.2 of the LRA, numerous line items state that carbon and low alloy steel components in fuel oil experience no AERMs and require no AMPs. This is not consistent with the GALL or with industry experience. Adjacent line items in LRA Table 3.3.2.2 for the same material, environment, and GALL reference state that the components are subjected to loss of material due to MIC, cite industry experience as the basis for this conclusion, and credit the Fuel Oil Chemistry Program and the One-Time Inspection Program for aging management.
Clarify whether these adjacent line items apply to the same components. If so, clarify whether the adjacent line items are intended to state that you consider MIC to be the only aging mechanism instead of the aging mechanisms in GALL. Clarify whether you intend to credit the Fuel Oil Chemistry Program and the One-Time Inspection Program for all carbon steel and low alloy steel components in the system. If not, provide aging management for the carbon steel and low alloy steel components that are not covered by these programs.
Discussion: The applicant indicated that the question is clear. This question will be sent as RAI 3.3.2.1.2-2.
Ventilation System D-RAI 3.3.2.1.8-1 Table 3.3.2.8 that the carbon and low alloy steel ductwork experiences no aging effects. The staff notes that adjacent entries in Table 3.3.2.8 for the same material, environment, and GALL reference identify a loss of material due to general corrosion. It appears that the applicant takes exception to the GALLs identification that crevice corrosion, pitting corrosion, and MIC are applicable, and instead has determined that general corrosion is applicable. The basis is that the LR scope of the system does not include drip pans and the moisture content of the air does not result in an aggressive environment or pooling water which would promote the other mechanisms. Clarify whether the adjacent line items refer to the same components, such that the components will receive a one-time inspection for general corrosion. Otherwise, provide additional justification for the determination that carbon and low alloy steel ductwork does not require aging management, or provide aging management.
Discussion: The applicant indicated that the question is clear. This question will be sent as RAI 3.3.2..8-1.
D-RAI 3.3.2.1.8-2 Table 3.3.2.8 line item related to elastomer - rubber and silicone rubber ductwork in inside air.
For this material/environment combination, the applicant claims that there are no AERMs based on industry guidance. The degradation of elastomers depends on the environmental factors such as the temperature, radiation levels, and presence of aggressive chemicals. Degradation can also be caused by wear (for items such as seals and vibration dampers). The applicant is asked to provide additional information on the above factors to justify that there are no AERMs for the elastomers, or to provide aging management for the elastomer components in the ductwork.
Discussion: The applicant indicated that the question is clear. This question will be sent as RAI 3.3.2.1.8-2.
D-RAI 3.3.2.1.8-3 Table 3.3.2.8 of the LRA identifies heat exchanger components made from copper alloy exposed to inside air (external) with an intended functions of pressure boundary and heat transfer. The LRA identifies that there are no AERMs for this component. This is contrary to industry experience, since condensation and pooling can result in loss of material for certain copper alloys and since particulate fouling can contribute to loss of heat transfer. Provide justification that the heat exchanger components will not experience aging effects, including loss of heat transfer, or provide an AMP to address this AERM.
Discussion: The applicant indicated that the question is clear. This question will be reworded, renumbered and sent as RAI 3.3.2.1.20-1.
Heating, Ventilation, and Air Conditioning System D-RAI 3.3.2.1.9-1 Table 3.3.2.9 line items related to elastomer ductwork, fittings, and flexible connectors in inside air. For this material/environment combination, the applicant claims that there are no AERMs based on industry guidance. The degradation of elastomers depends on the environmental factors such as the temperature, radiation levels, and presence of aggressive chemicals.
Degradation can also be caused by wear. The applicant is asked to provide additional information on the above factors to justify that there are no AERMs for the elastomers, or to provide aging management for the elastomer components in the ductwork, fittings, and flexible hoses.
Discussion: The applicant indicated that the question is clear. This question sent as RAI 3.3.2.1.9-1.
D-RAI 3.3.2.1.9-2 Table 3.3.2.9 line item related to copper alloy heat exchangers in inside air (external). The applicant claims that there are no AERMs for this material environment combination. The staff notes that the component intended functions are pressure boundary and heat transfer. The staff also notes that the LRA states there is condensation in the heat exchangers (Note 3 of Table 3.3.2.9). Therefore, there is the potential for corrosion and loss of heat transfer in the copper alloy heat exchanger components. There is also the potential for particulate fouling.
The applicant is asked to provide additional justification for determining that there are not AERMs for these heat exchanger components, including loss of heat transfer, or to provide aging management.
Discussion: The applicant indicated that the question is clear. This question will be sent as RAI 3.3.2.1.9-2.
Reactor Core Isolation Cooling System D-RAI 3.3.2.1.23-1 Table 3.3.2.8 of the LRA identifies heat exchanger components made from copper alloy exposed to inside air (external) with an intended functions of pressure boundary and heat transfer. The LRA identifies that there are no AERMs for this component. This is contrary to industry experience, since condensation and pooling can result in loss of material for certain copper alloys and since particulate fouling can contribute to loss of heat transfer. Provide justification that the heat exchanger components will not experience aging effects, including loss of heat transfer, or provide an AMP to address this AERM.
Discussion: The applicant indicated that the question is clear. This question will be reworded, and sent as RAI 3.3.2.1.23-1.
D-RAI 3.3.2.1.23-2 Table 3.3.2.23 of the LRA identifies strainers made from copper alloy in inside air with an intended function of differential pressure. Clarify whether these strainers are required to maintain the differential pressure function. If so, provide justification for the assertion that there are no AERMs (such as particulate buildup or fouling) that would lead to changes in differential pressure, or provide aging management for the differential pressure intended function.
Discussion: Based on the discussion this question will be withdrawn.
Bolting Commodity Group D-RAI 3.3.2.1.35-1 The LRA identifies does not consider cracking as an applicable AERM for the nickel alloy bolting (i.e., in the sampling and water quality system). Nickel alloys are susceptible to stress corrosion cracking under certain environmental conditions. Provide additional information on the nickel alloy bolting to justify that cracking will not occur.
Discussion: The applicant indicated that the question is clear. This question will be sent as RAI 3.3.2.1.35-1.
B.2.1.39 Systems Monitoring Program D-RAI B.2.1.39-1 LRA Section B.2.1.39 describes the existing plant specific systems monitoring program that includes periodic visual inspections of systems and components material condition, operation, and configuration. The LRA AMR tables identify the material and aging effect requiring management for each component crediting the systems monitoring program. The AMR identifies the main aging effect managed by the systems monitoring program as loss of material due to general corrosion on the external surfaces of carbon steel, low alloy steel, cast iron and cast iron alloy materials exposed to inside air or outside air environments. The AMR identifies that external surfaces of elastomers used in ductwork and flexible connectors are also managed by the systems monitoring program for elastomer degradation due to ultraviolet radiation or thermal exposure. The staff requires additional information concerning specific elements of AMP B.2.1.39.
a)
Element 4, Detection of Aging Effects, identifies that the systems monitoring program includes visual inspections to identify material condition on a periodic basis. Clarify if visual inspections are required for all surfaces of all components and systems crediting this program or if only selected portions of systems and components are to be inspected. The SRP-LR requires that, when sampling is used to inspect a group of SCs, the basis for the inspection population and sample size be provided. If a sampling approach is used, provide justification that the sample size is adequate. Also clarify how external surfaces of systems that are either covered by insulation or are located in normally inaccessible areas are to be visually inspected. The SRP-LR requires that the method or technique used to detect the aging effect be appropriate to ensure that the component intended function(s) will be adequately maintained. Clarify how elastomer degradation, such as hardening and loss of strength, would be detected by visual inspections, prior to loss of its intended function. Also clarify how external surface inspections using the systems monitoring program would detect internal aging effects caused by exposure to treated water for the flexible connectors in the diesel generator system.
b)
Element 6, Acceptance Criteria, identifies that during a system or component visual inspection, system engineers use their knowledge to evaluate system physical attributes and operational characteristics. The SRP-LR requires that the acceptance criteria, such as ASME codes, and its basis be described. Clarify the acceptance criteria applied in the inspection or evaluation of degradation reported as a result of the system monitoring inspection.
c)
Element 10, Operating Experience, identifies that the systems monitoring program and system health reports have identified age related degradation and material conditions of systems and components. The SRP-LR requires that operating experience with existing programs should be discussed. Identify specific operating experience that provides objective evidence to support the conclusion that the systems monitoring program is effective in managing aging effects on the external surfaces of systems and components within scope of the program. If independent assessments have been performed to evaluate the effectiveness of the systems monitoring program, describe the scope and results of these assessments.
Discussion: The applicant indicated that the question is clear. This question will be reworded, renumbered, and sent as RAI B.2.1.39-1.
LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE ON DRAFT REQUESTS FOR ADDITIONAL INFORMATION August 18, 2004 Participants Affiliation Yoira Diaz U.S. Nuclear Regulatory Commission (NRC)
Richard Mc Nally NRC Ram Subbaratnam NRC Ken Brune Tennessee Valley Authority (TVA)
Don Arp TVA Terry Knuettel TVA Don Arp TVA Mickey Hamby 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