ML050310442
| ML050310442 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/31/2005 |
| From: | Abney T Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML050310442 (10) | |
Text
January 31, 2005 10 CFR 54 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 (LRA) - LRA SECTION 2.1 STATUS OF RESPONSE TO RAI 2.1-2, A.3 (TAC NOS. MC1704, MC1705, AND MC1706)
By letter dated December 31, 2003, TVA submitted, for NRC review, an application pursuant to 10 CFR 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2, and 3. As part of its review of TVAs license response letter dated October 18, 2004, the NRC staff has requested the status of the methodology and progress for RAI 2.1-2A.3. The subject RAI 2.1-2, A.3 is the review of seismic class I piping boundaries to identify additional piping segments and supports/equivalent anchors that need to be placed in the scope of license renewal.
The enclosure to this letter contains the status information requested by the NRC.
U.S. Nuclear Regulatory Commission Page 2 January 31, 2005 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 foregoing is true and correct. Executed on this 31st day of January, 2005.
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 January 31, 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 4
U.S. Nuclear Regulatory Commission Page 4 January 31, 2005 Enclosure 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 5 January 31, 2005 GLS:BAB Enclosure cc (Enclosure):
A. S. Bhatnagar, LP 6-C K. A. Brune, LP 4F-C J. C. Fornicola, LP 6A-C R. G. Jones, NAB 1A-BFN K. L. Krueger, POB 2C-BFN R. F. Marks, Jr., PAB 1A-BFN F. C. Mashburn, BR 4X-C N. M. Moon, LP 6A-C 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/BFN LR Status Follow-up of RAI 2.1-2, A.3 TVA Response Letter.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
STATUS OF RESPONSE TO RAI 2.1-2, A.3 (SEE ATTACHED)
E-1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
STATUS OF RESPONSE TO RAI 2.1-2, A.3 By letter dated December 31, 2003, TVA submitted, for NRC review, an application pursuant to 10 CFR 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2, and 3. As part of its review of TVAs license response letter dated October 18, 2004, the NRC staff has requested the status of the methodology and progress for RAI 2.1-2A.3. The subject RAI 2.1-2, A.3 is the review of seismic class I piping boundaries to identify additional piping segments and supports/equivalent anchors that need to be placed in the scope of license renewal.
Listed below is the status information requested by the NRC.
STATUS OF TVA PROGRESS ON NRC RAI 2.1-2, A.3:
As part of its review of TVAs license renewal application, the NRC staff conducted a Scoping and Screening Audit the week of June 7-10, 2004. As a result of that audit, the NRC staff, through a written NRC request letter dated July 30, 2004 identified several areas where information was needed to complete their review.
In RAI 2.1-2, A.3 of the July 30, 2004 letter, NRC requested that TVA describe how the methodology ensured that the nonsafety-related piping up to first equivalent anchor point was included in the scope of the LRA.
TVA Responded by letter dated September 3, 2004 to RAI 2.1-2, A.3. In the response TVA committed to review the 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.
In a telephone discussion between NRC and TVA on September 24, 2004 NRC requested additional information relating to the RAI response 2.1-2, A.3. NRC requested TVA provide additional information related to methodology to be utilized to ensure that the liquid filled non-safety related piping up to the first equivalent anchor was captured.
E-2 TVA Responded by letter dated October 18, 2004 to the additional information request for RAI 2.1-2, A.3. In the response TVA committed to use the Seismic Class I qualification documentation to identify the non-safety related piping, components, and associated supports/equivalent 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.
During the restart of Units 2 and 3 and during the current restart process for Unit 1, TVA updated the Seismic Class I qualification documentation to ensure that the analyzed configuration reflected the as-built configuration. This documentation implements our CLB and provides the information necessary to determine the non-safety piping and components which are necessary to maintain qualification of the connected safety related piping and components. To ensure our license renewal boundaries are consistent with our CLB requirements, TVA is performing a detailed review of the Seismic Class I qualification documentation to identify the non-safety related piping, supports/equivalent anchors, or other components that are within the scope of license renewal for 54.4(a)(2) for the cases where non-safety related piping or components are directly connected to safety related piping or components.
This extensive review includes the verification of each Seismic Class I boundary identified in the CLB. The Seismic Class I boundaries typically fall into one of the following categories.
- Base mounted equipment (pump, heat exchanger, tank, etc.) -
A rugged component that is designed to provide support for connected piping and impose no loads on the piping. The review assures that when base mounted equipment implements a Seismic Class I boundary, the piping from the boundary to the equipment and the equipment are included in LR scope.
- Pipe Anchor - A special pipe support, which resists all six degrees of freedom, that has been designed and installed on the piping. The review assures that when a pipe anchor implements a Seismic Class I boundary, the piping from the boundary to the pipe anchor, and the pipe anchor are included in LR scope.
- Embedded Piping Segment - Where piping is structurally attached (usually welded) to piping which is embedded in a concrete floor or wall and acts as an anchor. The review assures that when an embedment implements a Seismic Class I
E-3 boundary, the piping from the boundary to the embedment and the embedment are included in LR scope.
- Large Run Line - When a branch line moment of inertia is significantly smaller than run lines moment of inertia, the branch line can be decoupled from the run line. The run line is then considered as an equivalent anchor. The review assures that in a case the where a large run line implements a Seismic Class I boundary, the large run line is included in LR scope.
- Piping Free End - Piping qualified up to an end which has no structural connection. The review assures that when a Seismic Class I boundary is implemented by a piping free end, all of the piping and supports from the boundary to piping free end(s) are included in LR scope.
- Flexible Connection - Where a pipe stress analysis terminates at a flexible connection that is considered as a free end in that analysis. The review assures that when a flexible connection implements a Seismic Class I boundary, the piping and supports from the boundary to the flexible connection are included in LR scope.
- Overlap Regions - Where a series of single or multi-directional pipe supports have been installed to isolate one region of piping from another. The review assures that, when an overlap region implements a Seismic Class I boundary, all of the piping and supports in the overlap region are included in LR scope.
At the current time TVA is continuing the detailed review of the Seismic Class I qualification documentation and plans to be complete by mid-February. The review to date has resulted in very little impact to the existing license renewal boundaries.
This result is not unexpected since, apart from the few exceptions, BFN included all non safety-related liquid filled piping located in a building or structure that contained safety-related equipment in scope for 54.4(a)(2). Also, BFN typically included all supports located in a building or structure that contained safety-related equipment into scope for 54.4(a)(2).
With few exceptions, this ensured that in the liquid filled nonsafety-related piping up to the first equivalent anchor point was included in the scope of license renewal.
E-4 The review to date has identified the following items which affect the license renewal boundaries:
- 1. An anchor required for the qualification of Seismic Class I piping in the Diesel Generator Building was located in an adjacent structure, the Radwaste Building, which is not currently in scope for license renewal. If it is not feasible to relocate the anchor to the Diesel Generator Building, TVA plans to include in scope for license renewal the anchor and the wall of the Radwaste Building where the anchor is attached.
- 2. Numerous embedded piping segments, which were not currently in scope for license renewal, were utilized as equivalent anchors. To address this issue TVA is planning to include in scope for license renewal the portion of embedded piping segments which are needed to anchor the attached piping. The aging management review will be revised as needed to include the material/environment and the program(s) necessary to manage aging. Embedded pipe/components have already been included in scope for license renewal for numerous systems for 54.4(a)(1) and (a)(3). It is expected that the same aging management reviews and programs will be used for the 54.4(a)(2) pipe/components.
TVA expects to complete the review in mid-February and provide NRC the following by February 28, 2005.
- Revised copies of affected boundary drawings;
- Changes which materially affect the LRA; and
- A summary of the review results which includes a discussion on the changes to the LRA or boundary drawing.