ML051040164
| ML051040164 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/14/2005 |
| From: | Abney T Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML051040164 (10) | |
Text
April 14, 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) - RESPONSE TO NRC REQUESTS FOR ADDITIONAL INFORMATION (RAI) 2.4-15, 2.4-16, 3.5-17, AND 3.5-18 (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 LRA, the NRC staff, through a letter dated March 25, 2005, identified additional information needed as Requests For Additional Information (RAIs) 2.4-15, 2.4-16, 3.5-17, and 3.5-18.
U.S. Nuclear Regulatory Commission Page 2 April 14, 2005 The enclosure to this letter contains the specific NRC requests for additional information and the corresponding TVA responses.
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 14th day of April, 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 April 14, 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 April 14, 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 5 April 14, 2005 TLE: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 Response letter 2.4-15, 2.4-16, 3.5-17, 3.5-18.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
RESPONSE TO NRC REQUESTS FOR ADDITIONAL INFORMATION (RAI) 2.4-15, 2.4-16, 3.5-17, AND 3.5-18 (SEE ATTACHED)
E-1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
RESPONSE TO NRC REQUESTS FOR ADDITIONAL INFORMATION (RAI) 2.4-15, 2.4-16, 3.5-17, AND 3.5-18 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 LRA, the NRC staff, through a letter dated March 25, 2005, identified additional information needed as Requests For Additional Information (RAIs) 2.4-15, 2.4-16, 3.5-17, and 3.5-18. This enclosure contains the specific NRC requests for additional information and the corresponding TVA responses.
NRCs RAI 2.4-15 Section 2.4.7.8 Radwaste Building (page E3-2) of the LRA states that The portions of the Radwaste Building that contain components requiring an AMR include the entire structure and the component supports... discussed above.
Confirm that all structural elements of the Radwaste Building are scoped and screened in Table 2.4.7.8. If not, list those elements of the Radwaste Building that are excluded from the table and discuss the basis for their exclusion including BFNs assessment of the II/I implication pursuant to 10 CFR 54.4 (a)(2), of the excluded elements on their adjacent in-scope elements.
TVAs Response to RAI 2.4-15 All structural elements of the Radwaste Building are scoped and screened in Table 2.4.7.8.
NRCs RAI 2.4-16 Section 2.4.7.9 Service Building (page E3-10, second paragraph) of the LRA seems to indicate that only portion of the Service Building is scoped and screened in Table 2.4.7.9.
Since the paragraph only provides a general description of the boundaries between the in-scope vs out of scope structural elements of the Service Building, the applicant is requested to list those elements of the Service Building that are excluded from the table and discuss the basis for their exclusion including BFNs assessment of the II/I implication
E-2 pursuant to 10 CFR 54.4 (a)(2), of the excluded elements on their adjacent in-scope elements.
TVAs Response to RAI 2.4-16 During the scoping and screening of the Service Building for the newly identified mechanical systems discussed in TVAs response to the NRC for RAI 2.1-2, A3 (Reference 1), only a limited area of the Service Building contained the new in-scope mechanical piping. Based on that fact, it was determined that the entire structure did not need to be within the scope of License Renewal for the period of extended operation. This is described in the second paragraph of page E3-9 of that response, and reads as follows: The Service Building contains CO2 piping and a liquid (water) filled piping for the fire protection system that are required to support fire protection requirements (10 CFR 50.48) based on the criterion of 10 CFR 54.4 (a)(3).
Only those rooms of the Service Building that contain the fire protection piping are required to provide structural support and shelter/protection to support the intended function of the fire protection piping.
In order to maintain the structural integrity of the structure within the scope of License Renewal and provide reasonable assurance that these piping systems will be able to perform their intended functions, a portion of the structure was required to be in-scope such that the structure will perform its intended functions of shelter/protection and structural support of 10 CFR 54.4 (a)(3) components.
The in-scope boundary of the Service Building is described in the second paragraph of page E3-10 of that response, and reads as follows: In order to maintain the structural integrity of the Service Building to provide its intended functions for the in-scope components, the building area considered in-scope for the structure will be extended two column line bays in the west direction to column line S4 and will include the entire structure in the north-south direction between the personnel corridors on elevations 565.0 and 580.0 and roof at elevation 595.0 south of column line Sa to the north exterior wall of the Service Building. It should be noted that column line S7 is the east exterior wall of the Service Building and is located adjacent and parallel to the west exterior wall of the unit 1 Turbine Building. Additionally, from the foundation slab at El 565.0 (top of floor slab EL 565.0) to the general roof deck of the structure at EL 595.0 and to EL 605.0 above the mechanical equipment room located between column lines S5 and S6 (west to east) and the Pull-Out Space & Shop Storage
E-3 between column lines S6 and S7 (west to east) and between column lines Sb to approximately 6 ft north of column line Sh (south to north) defines the in-scope height of the structure. The basis for concluding that the structural integrity boundary of the in-scope structure will be maintained is based on a review of the design of the Service Building.
The structural elements of the Service Building that are listed in Table 2.4.7.9 encompass all the structural elements of the Service Building; none were excluded.
NRCs RAI 3.5-17 Table 3.5.2.29, Radwaste Building of the LRA has three separate rows of component type listing (i.e., reinforced concrete, beams, column, walls, and slabs) which make references to Note I,1 (last column of the table) and are shown to be associated with Section III.A3.1-h of the NUREG-1801, Vol. 2. Reading of the Note I,1 of the table implies that the Radwaste Building is founded on rock or bearing piles. The note also refers to Section 3.5.2.2.2.1 of the LRA for further evaluation. Item 5 of the section does not clearly indicate that the Radwaste Building is founded on rock or bearing piles. Provide the type of foundation medium that supports the building and if the structure is not founded on rock or piles, discuss BFNs basis for asserting that the cracking, distortion, increase in component stress level due to settlement are not aging effects requiring management. Also, as appropriate, revise Section 3.5.2.2.2.1 of the LRA to include the Radwaste Building within the scope of its discussion.
TVAs Response to RAI 3.5-17 The Radwaste Building is founded on piles as noted by the entry Piles under column heading Component Type in Table 2.4.7.8 and Table 3.5.2.29.
LRA Section 3.5.2.2.2.1, Item 5, paragraph 1 on page 3.5-43 should be revised to read:
Cracks, distortion, increase in component stress level due to settlement are not considered as aging effects requiring management for BFN structures founded on rock or bearing piles. The following BFN structures are founded on rock or bearing piles:
Reactor Buildings, Primary Containments, Intake Pumping Station, Reinforced Concrete Chimney, Off-Gas Treatment Building, Equipment Access Lock, Turbine
E-4 Buildings, Gate Structure Number 3, Diesel HPFP House, Transformer Yard, RHRSW Tunnel and Radwaste Building. Based on industry experience, settlement of Class 1 structures founded on bedrock or bearing piles have not been noted to cause aging effects requiring management.
NRCs RAI 3.5-18 Second item of Table 3.5.2.30, Service Building of the LRA makes reference to Section III.A3.1-j of the NUREG-1801, Vol. 2 and Note I,1 of Table 3.5.2.30. The note also refers to Section 3.5.2.2.2.1, Item 8, "Loss of strength and modulus of concrete structures due to elevated temperatures for Group 1-5" of the LRA for further evaluation. The staff is not clear as to whether Group 5 category referred to in this item includes the BFN Service Building. Please confirm that the BFN Service Building or portion of the building is clearly included within the scope addressed by Section 3.5.2.2.2.1 of the LRA and make any necessary revision to the LRA section to clarify the BFN position.
TVAs Response to 3.5-18 The aging management review of the Service Building was performed to the requirements for Group 3 Structures of NUREG-1801, Vol. 2, Chapter III.A3. The Service Building is included within the scope addressed by LRA Section 3.5.2.2.2.1, Item 8 since it was considered as a Group 3 Structure and that section is applicable to Group 1 through Group 5 Structures of NUREG-1801, Vol. 2 Chapter III.
REFERENCES
- 1. T. E. Abney (TVA) to Document Control Desk (NRC) letter dated February 28, 2005: BROWNS FERRY NUCLEAR PLANT (BFN)
- UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA) -
LRA SECTION 2.1 FINAL STATUS OF RESPONSE TO RAI 2.1-2, A.3 (TAC NOS. MC1704, MC1705, AND MC1706)