ML050100180
| ML050100180 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/07/2005 |
| From: | Skaggs M Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML050100180 (8) | |
Text
January 7, 2005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, DC 20555-001 Gentlemen:
On the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, and 3 -
SUMMARY
OF NRC SITE VISIT AND MEETING REGARDING EXTENDED POWER UPRATE (EPU) AND LICENSE RENEWAL APPLICATIONS (LRA)
On December 2, 2004, Frank Gillespie, Deputy Director of Division of Regulatory Improvement Programs, Jim Lyons, Deputy Director of Division of Licensing Project Management, and Ram Subbaratnam, Project Manager, License Renewal, visited BFN, toured the plant, and met with members of TVA management (Mike Skaggs, Jon Rupert, and Tim Abney). The purpose of this letter is to document discussions from the meeting regarding the LRA and EPU applications for BFN.
TVA submitted an application for license renewal of BFN Units 1, 2, and 3 on December 31, 2003. The application incorporated prior agreements with the staff regarding the content associated with Unit 1, due to Unit 1 being in a long-term shutdown. Additionally, since TVA planned to submit EPU applications for all three units in the near term, the license renewal application was submitted assuming the EPU condition.
U.S. Nuclear Regulatory Commission Page 2 January 7, 2005 TVA subsequently submitted EPU applications for Unit 1 and Units 2/3 on June 28, 2004, and June 25, 2004, respectively.
NRC documented the completion of the acceptance review of the EPU applications in two letters dated November 18, 2004, in which NRC also notified TVA that additional information would be required before the detailed EPU technical review could begin.
In the December 2, 2004, meeting with Messrs. Gillespie and Lyons, TVA management was notified that the NRC review of the EPU application will not be completed in time to support the current schedule for the LRA review. Mr. Gillespie explained that in order to meet the current LRA review schedule, the preliminary draft of the Safety Evaluation Report (SER) for the LRA must be completed and internal NRC reviews started by March 2005. The schedule for review of the SER (NRC staff, OGC, ACRS subcommittee, ACRS committee, NRC management, etc.) cannot be met if the basis for the SER changes significantly during the course of the review.
Mr. Gillespie further stated that if the EPU applications were approved after the draft LRA SER was issued, it would constitute a significant change in the basis of the LRA SER and the SER would have to be re-written and re-reviewed.
Two scheduling options were discussed:
- 1) Complete the LRA review based on the current licensed power level for each of the three units and address the renewed license term at EPU conditions as part of the EPU review. This option will allow the staff to complete its review of the LRA by the current schedule.
- 2) Delay completion of the LRA review until the EPU review is completed. This option, however, would result in an indeterminate delay in completion of the
U.S. Nuclear Regulatory Commission Page 3 January 7, 2005 BFN LRA review based on NRCs current schedular commitments regarding reviews of LRAs from other utilities over the next two years.
TVA expressed concerns that Option 1 would result in substantial additional TVA resources to resubmit the LRA for review as part of EPU and would increase TVA costs for NRC resources to review what has already been evaluated by the staff. Mr. Gillespie stated that Option 1 will not require TVA to resubmit the LRA at EPU conditions and the LRA review effort already expended by the staff will not be duplicated by the EPU review. Since TVAs LRA conservatively assumes EPU conditions for each of the three units, the LRA can simply be referenced for the EPU application review.
Further, Mr. Gillespie stated that the staff would take steps to ensure that the reviews already done by the staff would not be duplicated. Based on this clarification (i.e.,
no requirement to resubmit the LRA and no duplicate review costs), TVA agrees that Option 1 is acceptable.
Mr. Gillespie also noted that the staff needs information in the following three critical areas to support the schedule for the preliminary draft of the LRA SER by March 2005:
a)
Seismic Anchorage Scoping/Screening In TVAs September 3 and October 18, 2004, responses to the Request for Additional Information (RAI) 2.1-2, A.3, TVA committed to review seismic class I piping boundaries and identify any additional piping segments and supports/equivalent anchors that need to be placed in the scope of license renewal. To accomplish this TVA will use the Seismic Class I qualification documentation to identify the non-safety related piping, components, and associated supports/equivalent
U.S. Nuclear Regulatory Commission Page 4 January 7, 2005 anchors which are required for the qualification of the safety-related piping. Identified piping, supports/equivalent anchors, or other components will be added to the scope as needed. This will ensure that piping, supports/equivalent anchors, or other components up to the first seismic anchor past the safety/non-safety interface are included in scope.
This review must be completed and the results submitted to the staff.
b)
License Renewal Application Annual Update The annual update must identify Unit 1 current licensing basis differences described in Appendix F of the LRA that have been resolved.
c)
Unit 1 Lay-up RAIs At the time of the December 2, 2004, meeting, there were no Unit 1 lay-up RAIs outstanding. However, on December 16, 2004, an RAI containing 20 questions regarding Unit 1 lay-up was sent to TVA.
TVA will respond to each of these three areas by January 31, 2005.
Additionally, between December 1, 2004, and December 20, 2004, TVA received 10 additional RAIs via letter, telecom, and email containing some 146 additional questions. It is TVAs intent to provide responses to these additional questions by January 31, 2005.
U.S. Nuclear Regulatory Commission Page 5 January 7, 2005 If you have any questions regarding this, please contact Tim Abney, Manager of Licensing and Industry Affairs, at (256) 729-2636.
Sincerely, Original signed by:
Mike D. Skaggs
U.S. Nuclear Regulatory Commission Page 6 January 7, 2005 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 7
U.S. Nuclear Regulatory Commission Page 7 January 7, 2005 cc: (Enclosure)
Margaret Chernoff, 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 Ramachandran Subbaratnam, 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 8 January 7, 2005 BCM: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://Licensing/Lic/Submit/Subs/License Renewal Submittals/Letter to NRC on 12/2 Gillespie Meeting BCM1.doc