ML051380504

(BFN) - Units 1, 2, and 3 - License Renewal Application (LRA) - Response to NRC Request for Additional Information on Clarification of Item 2 of RAI 2.3-2 and Follow-up to RAI 2.4-14

ML051380504
Person / Time
Site:	Browns Ferry
Issue date:	05/18/2005
From:	Abney T Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC1704, TAC MC1705, TAC MC1706
Download: ML051380504 (17)

Text

May 18, 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 ON CLARIFICATION OF ITEM 2 OF RAI 2.3-2 AND FOLLOW-UP TO RAI 2.4-14 (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 informal requests on March 21 and 22, 2005, identified additional information needed for clarification on item 2 of RAI 2.3-2 and follow-up to RAI 2.4-14.

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 May 18, 2004 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 18th day of May, 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 May 18, 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 May 18, 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 May 18, 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 Clarification of item RAI 2.3-2.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) ON CLARIFICATION ON ITEM 2 OF RAI 2.3-2 AND FOLLOW-UP TO RAI 2.4-14 (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) ON CLARIFICATION ON ITEM 2 OF RAI 2.3-2 AND FOLLOW-UP TO RAI 2.4-14 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 informal requests on March 21 and 22, 2005, identified additional information needed for clarification on item 2 of RAI 2.3-2 and follow-up to RAI 2.4-14. This enclosure contains the specific NRC request(s) for additional information and the corresponding TVA response(s).

NRCs Requested Clarification On RAI 2.3-2, Item 2 The NRC staff, through a verbal request on March 22, 2005, requested additional clarification on item 2 of RAI 2.3-2.

The requested clarification was to confirm that all filters for safety related components were being monitored and replaced as required to assure that equipment will perform its function.

TVA Response to RAI 2.3-2, Item 2 To address this issue the first sentence of TVA's October 19, 2005, response for item 2 of RAI 2.3-2 should be replaced with the following:

"Browns Ferry has various maintenance procedures and work orders in place to assure that all filters for safety related components are being monitored and replaced as required to assure that equipment will perform its function."

NRC Follow-up to RAI 2.4-14 LRA Section 2.1.7.2 states that insulation at BFN does not have an intended function within the scope of 10 CFR 54.4(a)(1) - (3). Insufficient information has been included in the LRA and the UFSAR for the staff to determine if this statement is valid at such a generic level. Insulation may be installed for a variety of reasons, e.g., system efficiency, heat load calculations, EQ purposes, etc. If the

E-2 insulation is relied upon for EQ purposes, the insulation, which is passive and long-lived, should be subject to an AMR.

Provide a basis for not including any piping or equipment insulation within the scope of license renewal.

TVA Response to Follow-up to RAI 2.4-14 Based on discussions with the NRC staff, TVA has reviewed and enhanced the coverage of mechanical equipment insulation in the BFN LRA. Thermal insulation is in scope and meets the criteria of 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3). The BFN LRA is revised as follows:

Add two intended functions to Table 2.0.1 as shown below.

Table 2.0.1 Intended Functions Abbreviations and Definitions Function Abbreviation Definition Insulate - Piping and Equipment INSL Control heat transfer Insulation Jacketing Integrity INJI Protection of insulation A description of the insulation/insulation jacketing scoping is included in a new Section 2.1.7.2, shown in to this response. The AMR results for insulation/insulation jacketing are provided in the new Section 3.0.2, shown in Attachment 2 to this response.

E-3 ATTACHMENT 1 (sheet 1 of 2) 2.1.7.2 Treatment of Piping and Equipment Insulation during Scoping and Screening Insulation is used for heat conservation, temperature control, and prevention of condensation. To facilitate the aging management review, insulation is evaluated as a bulk mechanical commodity common to various systems and structures. The piping and equipment insulation is in the scope of 10 CFR 54 because it contains components that meet the criteria of 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3). The portions of piping and equipment insulation that contain components subject to aging management review include all piping and equipment insulation associated with the structures listed below:

Structure Name Reactor Buildings (Units 1, 2, and 3)

Primary Containment Structure (Units 1, 2, and 3)

Diesel Generator Buildings (Units 1&2 and Unit 3)

Reinforced Concrete Chimney Intake Pumping Station Standby Gas Treatment Building Turbine Buildings (Units 1, 2, and 3)

Radwaste Building Diesel High Pressure Fire Pump House Transformer Yard Condensate Water Storage Tanks Foundations and Trenches Containment Atmosphere Dilution Storage Tanks Foundations Ventilation Vaults Isolation Valve Pits (1 and 3)

Service Building UFSAR References Additional details for Piping and Equipment Insulation are found in UFSAR 4.2, 4.3, 5.2, and 6.5.

License Renewal Drawings None

E-4 ATTACHMENT 1 (sheet 2 of 2)

Components Subject to AMR The component types that require aging management review are indicated in Table 2.1.7.2, Piping and Equipment Insulation.

The aging management review results for insulation and insulation jacketing are provided in Table 3.0.2.1.1 Table 2.1.7.2 Piping and Equipment Insulation Component Type Intended Functions Insulation INSL Insulation Jacketing INJI

E-5 ATTACHMENT 2 (sheet 1 of 7) 3.0.2 Summary of the Evaluation of Piping and Equipment Insulation This section provides the results of the aging management review for those component types identified in Section 2.1.7.2, Piping and Equipment Insulation, as being subject to aging management review.

3.0.2.1 MATERIALS, ENVIRONMENT, AGING EFFECTS REQUIRING MANAGEMENT AND AGING MANAGEMENT PROGRAMS 3.0.2.1.1 PIPING AND EQUIPMENT INSULATION Materials The materials of construction for the Piping and Equipment Insulation components are:

Asbestos Asbestos Cloth Aluminum Asphalt Coating Calcium Silicate Canvas Carbon and Low-Alloy Steel Cellular Elastomeric Ceramic Fiber Blanket Cloth Fabric Corkmastic Elastomers Fabricell Fiberglass Glass Fabric Foam Plastic Metal Reflective Mineral Wool Polymer PVC Tape Stainless Steel

E-6 ATTACHMENT 2 (sheet 2 of 7)

Environment The Piping and Equipment Insulation components are exposed to the following environments:

Inside air (external)

Outside air (external)

E-7 ATTACHMENT 2 (sheet 3 of 7)

Table 3.0.2.1.1: Piping and Equipment Insulation - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Vol. 2 Item Table 1 Item Notes Insulation INSL Asbestos

• Inside air (external)

• Outside air (external)

None None None None J,1 Insulation INSL Calcium silicate

• Inside air (external)

• Outside air (external)

None None None None J,1 Insulation INSL Cellular elastomeric

• Inside air (external)

• Outside air (external)

None None None None J,1 Insulation INSL Ceramic fiber blanket

• Inside air (external)

None None None None J,1 Insulation INSL Corkmastic

• Inside air (external)

None None None None J,1 Insulation INSL Fabricell

• Inside air (external)

None None None None J,1

E-8 ATTACHMENT 2 (sheet 4 of 7)

Table 3.0.2.1.1: Piping and Equipment Insulation - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Vol. 2 Item Table 1 Item Notes Insulation INSL Fiberglass

• Inside air (external)

• Outside air (external)

None None None None J,1 Insulation INSL Foam plastic

• Inside air (external)

• Outside air (external)

None None None None J,1 Insulation INSL Metal reflective

• Inside air (external)

None None None None J,1 Insulation INSL Mineral wool

• Inside air (external)

• Outside air (external)

None None None None J,1 Insulation Jacketing INJI Asbestos cloth

• Inside air (external)

• Outside air (external)

None None None None J,1

E-9 ATTACHMENT 2 (sheet 5 of 7)

Table 3.0.2.1.1: Piping and Equipment Insulation - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Vol. 2 Item Table 1 Item Notes Insulation Jacketing INJI Aluminum

• Inside air (external)

• Outside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2 Insulation Jacketing INJI Asphalt coating

• Outside air (external)

None None None None J,1 Insulation Jacketing INJI Canvas

• Inside air (external)

• Outside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2 Insulation Jacketing INJI Carbon and low-alloy steel

• Inside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2 Insulation Jacketing INJI Cloth fabric

• Inside air (external)

• Outside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2

E-10 ATTACHMENT 2 (sheet 6 of 7)

Table 3.0.2.1.1: Piping and Equipment Insulation - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Vol. 2 Item Table 1 Item Notes Insulation Jacketing INJI Elastomers

• Inside air (external)

• Outside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2 Insulation Jacketing INJI Fiberglass

• Inside air (external)

None None None None J,1 Insulation Jacketing INJI Glass fabric

• Inside air (external)

None None None None J,1 Insulation Jacketing INJI Polymer

• Inside air (external)

• Outside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2 Insulation Jacketing INJI PVC tape

• Inside air (external)

• Outside air (external)

Insulation jacket degradation Systems Monitoring Program (B.2.1.39)

None None J,2 Insulation Jacketing INJI Stainless steel

• Inside air (external)

• Outside air (external)

None None None None J,1

E-11 ATTACHMENT 2 (sheet 7 of 7)

Table Notes:

Industry Standard Notes:

Note J: Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

1. There are no applicable aging effects for insulation/insulation jacketing in the identified environment. This is consistent with industry guidance/experience.

2. The aging effects identified for insulation jacketing in the identified environment are consistent with industry guidance/experience.