ML051190272
| ML051190272 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/28/2005 |
| From: | Abney T Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML051190272 (11) | |
Text
April 28, 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 REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE REACTOR WATER CLEANUP SYSTEM (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 April 8, 2005 (Reference 1),
requested additional information concerning the Reactor Water Cleanup System.
The enclosure to this letter contains the specific NRC request(s) for additional information and the corresponding TVA response(s).
U.S. Nuclear Regulatory Commission Page 2 April 28, 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 28th day of April, 2005.
Sincerely, Original Signed by:
T. E. Abney Manager of Licensing and Industry Affairs
Enclosure:
cc: See page 3 REFERENCES
- 1. Ram Subbaratnam (NRC) to Karl W. Singer (TVA) letter dated April 8, 2005: REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION (TAC NOS.
U.S. Nuclear Regulatory Commission Page 3 April 28, 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 28, 2004 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 28, 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 Reactor Water Cleanup System.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI),
CONCERNING THE REACTOR WATER CLEANUP SYSTEM (SEE ATTACHED)
E-1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA),
RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI),
CONCERNING THE REACTOR WATER CLEANUP SYSTEM 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 April 8, 2005 (Reference 1),
requested additional information concerning the Reactor Water Cleanup System. This enclosure contains the specific NRC requests for additional information and the corresponding TVA responses.
NRCs RAI 2.3.3.21-1 License renewal drawings 2-47E810-1-LR and 3-47E810-1-LR show thermal tees (location F6) to be within the scope of license renewal and subject to an AMR. Thermal tees are the passive and long-lived components, however thermal tee component type is not listed in LRA Table 2.3.3.21-1 as a component type subject to an AMR, nor is it included in a component type in Section 2.3.5, "Notes Associated with Section 2.3 Tables."
Please justify the exclusion of these components from being subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
TVAs Response to RAI 2.3.3.21-1 Thermal tees are included in Table 2.3.3.21 as component type fittings. Thermal tees were not listed in Section 2.3.5 because these components are not assigned UNIDs on drawings.
Section 2.3.5 was generated to show where UNIDs appearing on the License Renewal Drawings were grouped in a component type.
NRCs RAI 2.3.3.21-2 License renewal drawings 2-47E810-1-LR and 3-47E810-1-LR show fusible plugs (location D2) to be within the scope of license renewal (in blue color for 54.4(a)(2) component in scope) and subject to an AMR. The "NOTE" on the drawing associated with fusible plugs states that fusible plug (FUPG) is a threaded pipe plug with a low temperature eutectic alloy which is attached to the RWCU pipe upstream of FCV-69-94. Eutectic
E-2 material will melt on high temperature, venting the control air line, which closes isolation valve FCV-69-94. Also, another drawing note states that the system shall be qualified for an elevated temperature excursion up to 562° F during an Appendix R event from the non-generative heat exchanger outlet to FCV-69-94.
- a. The fusible plugs are neither listed in LRA Table 2.3.3.21 as a component type subject to an AMR, nor as a subcomponent of the component types listed in Section 2.3.5. Please justify the exclusion of these components from being subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
- b. Based on the drawing notes mentioned above, it appears that FCV-69-94 satisfy the criterion in 10 CFR 54.4(a)(3) for an environmental qualification and/or fire protection regulated event. However, the piping and components associated with this valve, including the above mentioned fusible plugs, are shown as being in scope in accordance with the criterion in 10 CFR 54.4(a)(2). Explain why valve FCV-69-94 functions differently from its associated pipeline.
TVAs Response to RAI 2.3.3.21-2
- a. The fusible plugs were inadvertently colored blue on drawing but should have been black since they are active components. Additionally, the fusible plugs do not form a pressure boundary function for the Reactor Water Cleanup System. License Renewal drawings 2-47E810-1-LR and 3-47E810-1-LR will be corrected to show FUPG-32-5105 black instead of blue.
- b. The piping and equipment downstream of FCV-69-2 up to and including valve FCV-69-94 will be corrected to show red instead of blue on drawings 2-47E810-1-LR and 3-47E810-1-LR since these components are part of the reactor coolant pressure boundary during an Appendix R event. The tube side of the heat exchangers is considered part of the reactor coolant pressure boundary while the shell side provides the structural support for the tubes.
Shell side piping connections will remain blue. Also, System 43 (Sampling and Water Quality) drawing 0-105E3156-1-LR will be corrected to show components required for pressure boundary as red instead of blue on the drawing due to System 43s interface with Reactor Water Cleanup drawings 2-47E810-1-LR and 3-47E810-1-LR.
E-3 NRCs RAI 2.3.3.21-3 Browns Ferry Nuclear Plant FSAR, Revision 20, Section 4.9 (page 4.9-2) states that:
Reactor coolant is continuously removed from the reactor coolant recirculation system, cooled in the regenerative and non-regenerative heat exchangers, filtered and demineralized, and returned to the feedwater system through the shell side of the regenerative heat exchanger. The Unit 3 RWCU system has the capability to return the processed fluid to the feedwater system through both reactor feedwater lines A and B. However, Unit 2 RWCU system has only one return line through reactor feedwater line B.
License renewal drawing 3-47E810-1-LR shows (location E7) the reactor water cleanup system return line to the reactor feedwater line B only. Indicate whether feedwater line A is within the scope of license renewal and subject to an AMR, or provide an explanation for its exclusion. (Alternatively, provide a drawing that shows the reactor water cleanup system return to feedwater line A for Unit 3.)
TVAs Response to RAI 2.3.3.21-3 Unit 3 Water Cleanup Systems return to Feedwater line A is shown at coordinate G6 on License Renewal drawing 3-47E810-1-LR. Note that this return is through a HPCI line shown on License Renewal drawing 3-47E812-1-LR (location E6) which connects to Feedwater line A shown on License Renewal drawing 3-47E803-1-LR (location G6). The HPCI and Feedwater portions of this return path are within the scope of license renewal.
NRCs RAI 2.3.3.21-4 License renewal drawing 1-47E810-1-LR shows flow indicators, FI 85-75 (location G3) and FI-85-77 (location G1), and flow element, FE-69-13 (location C5), as excluded from the scope of license renewal. These flow indicators and flow element serve a pressure boundary function and are passive and long-lived components. It is noted that similar flow indicators and flow elements on drawings 2-47E810-1-LR and 3-47E810-1-LR are shown as within the scope of license renewal and subject to an AMR. However, flow indicators are neither listed in LRA Table 2.3.3.21 as a component type subject to an AMR, nor as a subcomponent of the component types listed in Section 2.3.5.
E-4
- a. Justify the exclusion of the aforementioned flow indicators and flow element in Unit 1 from the scope of license renewal and being subject to an AMR in accordance with the requirements of 10 CFR 54.4(a) and 10 CFR 54.21(a)(1), respectively.
- b. Clarify whether flow indicators are included in other component types listed in LRA Table 2.3.3.21, or justify the exclusion of them from being subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
TVAs Response to RAI 2.3.3.21-4
- a. NEI 95-10, Appendix B shows flow indicators as active components. FI 85-75 and FI 85-77 were colored blue in error on License Renewal drawings 2-47E810-1-LR and 3-47E810-1-LR and were corrected to show these components black on the drawings revised for the first annual update.
The flow element on License Renewal drawing 1-47E810-1-LR was included as a fitting in our evaluation, but was inadvertently not colored blue on the drawing. Drawing 1-47E810-1-LR was corrected to show FE 69-13 blue instead of black.
- b. Flow indicators are not contained as a component type in Table 2.3.3.21. Flow indicators were excluded from an AMR based on guidance provided in NEI 95-10, Appendix B.
NRCs RAI 2.3.3.21-5 License renewal drawing 3-47E810-1-LR shows a 4-inch pipeline to waste collector and surge tank inside the pipe tunnel to radwaste (location B4) as excluded from the scope of license renewal. However, the same pipeline on the license renewal drawing 1-47E810-1-LR (location B6) is shown as being in scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(2). Clarify this apparent discrepancy.
TVAs Response to RAI 2.3.3.21-5 This line on License Renewal drawing 1-47E810-1-LR was inadvertently colored blue but should have been black. This was corrected to show black for the first annual update.
E-5 REFERENCES
- 1. Ram Subbaratnam (NRC) to Karl W. Singer (TVA) letter dated April 8, 2005: REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION (TAC NOS. MC1704, MC1705 AND MC1706)