ML052170406
| ML052170406 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/04/2005 |
| From: | Crouch W Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML052170406 (13) | |
Text
August 4, 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) - DESCRIPTION OF UNIT 1 PERIODIC INSPECTION PROGRAM (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. In a letter dated May 27, 2005, (Reference 1) TVA responded to NRC Proposed Unresolved Items 3.0-2 LP, 3.0-3 LP, and 3.0-4 LP. In that letter, TVA stated it would implement targeted periodic inspections for Unit 1 systems that have been shutdown during the extended plant shutdown and that were not subsequently replaced as part of the Unit 1 restart project. These targeted periodic inspections will be performed after Unit 1 is returned to operation to verify aging management program effectiveness and to verify no additional latent aging effects are occurring. These periodic inspections are in addition to the restart inspections performed prior to Unit 1 restart.
U.S. Nuclear Regulatory Commission Page 2 August 4, 2005 The first periodic inspection will be performed prior to the end of the current operating period and the subsequent frequency of the periodic inspections will be determined based on the outcome of the first periodic inspections performed.
As part of its review of TVAs LRA and the May 27, 2005, letter, the NRC staff, through an informal request on July 22, 2005, requested that TVA provide a description of the Unit 1 Periodic Inspection Program equivalent to the program descriptions provided in Appendix A and B of the License Renewal Application for the other aging management programs.
The enclosure to this letter provides the requested program descriptions.
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 4th day of August, 2005.
Sincerely, Original Signed by:
William D. Crouch Manager of Licensing and Industry Affairs
Enclosure:
cc: See page 3 REFERENCES
- 1. Letter from T. E. Abney (TVA) to NRC dated May 27, 2005:
Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 -
License Renewal Application (LRA) - Response To NRC Request For Additional Information Concerning The Unit 1 Layup Program (TAC Nos. MC1704, MC1705, and MC1706)
U.S. Nuclear Regulatory Commission Page 3 August 4, 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 August 4, 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 August 4, 2005 JEM:TLE:BAB Enclosure cc (Enclosure):
B. M. Aukland, POB 2C-BFN A. S. Bhatnagar, LP 6-C K. A. Brune, LP 4F-C J. C. Fornicola, LP 6A-C R. G. Jones, NAB 1A-BFN R. F. Marks, Jr., PAB 1A-BFN N. M. Moon, LP 6A-C G. W. Morris, LP 4G-C B. J. OGrady, PAB 1E-BFN J. R. Rupert, NAB 1F-BFN K. W. Singer, LP 6A-C E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS, WT CA-K s://Licensing/Lic/BFN LR Description Of Unit 1 Periodic Inspection Program.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA)
DESCRIPTION OF UNIT 1 PERIODIC INSPECTION PROGRAM (SEE ATTACHED)
E-1 ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA)
DESCRIPTION OF UNIT 1 PERIODIC INSPECTION PROGRAM 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. In a letter dated May 27, 2005 (Reference 1) TVA responded to NRC Proposed Unresolved Items 3.0-2 LP, 3.0-3 LP, and 3.0-4 LP. In that letter, TVA stated it would implement targeted periodic inspections for Unit 1 systems that have been shutdown during the extended plant shutdown and that were not subsequently replaced as part of the Unit 1 restart project. These targeted periodic inspections will be performed after Unit 1 is returned to operation to verify aging management program effectiveness and to verify no additional latent aging effects are occurring. These periodic inspections are in addition to the restart inspections performed prior to Unit 1 restart.
The first periodic inspection will be performed prior to the end of the current operating period and the subsequent frequency of the periodic inspections will be determined based on the outcome of the first periodic inspections performed.
As part of its review of TVAs LRA and the May 27, 2005, letter, the NRC staff, through an informal request on July 22, 2005, requested that TVA provide a description of the Unit 1 Periodic Inspection Program equivalent to the program descriptions provided in Appendix A and B of the License Renewal Application for the other aging management programs.
The attachments to this enclosure provide the requested program descriptions.
E-2 ATTACHMENT 1 A.2.4 UNIT 1 PERIODIC INSPECTION PROGRAM The is a new program that performs periodic inspections on piping and components that did not require replacement following the extended Unit 1 outage to verify that no additional latent aging effects are occurring, and to correct degraded conditions prior to loss of function.
During the Unit 1 restart project, portions of several systems were examined that did not require replacement. This piping is carbon/low alloy or stainless steel that was exposed to air, treated water, or raw water during the extended Unit 1 shutdown.
The specific examinations are discussed in the TVA Letter to the U.S. Nuclear Regulatory Commission, Document Control Desk, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - License Renewal Application (LRA) - Response to NRC Request for Additional Information Concerning the Unit 1 Lay-up Program (TAC Nos. MC1704, MC1705, and MC1706) dated May 18, 2005. The Unit 1 Periodic Inspection Program will examine a sample of those locations examined for plant restart as discussed in the referenced letter to verify that no additional latent aging effects are occurring. The sample size will be determined in accordance with the sampling methodology described in EPRI 107514, Age-Related Degradation Inspection Method and Demonstration: In Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application. If failures are identified, the sample size will be appropriately expanded using the guidance of EPRI 107514. The initial sample, once selected, will be utilized in subsequent inspections, if practical.
These periodic inspections are in addition to the restart inspections performed prior to Unit 1 restart. The Unit 1 periodic inspections will be performed after Unit 1 is returned to operation. The susceptible locations identified are those areas determined to have the highest potential for service induced wear or latent aging effects. The inspection techniques utilized evaluate internal conditions that are sensitive to the presence of unacceptable conditions including wear, erosion, and corrosion (including crevice corrosion) if present. For these locations, the restart inspections can be utilized as a baseline for comparison.
The first periodic inspection will be performed prior to the end of the current operating period and the subsequent frequency of the periodic inspections will be determined based on the outcome of the first periodic inspections performed. The inspection frequency is re-evaluated each time the inspection is performed and can be changed based on the trend of the data results. The inspections will continue until such time as the trend of the data results provides a basis to discontinue the inspections.
E-3 ATTACHMENT 2 B.2.1.42 UNIT 1 PERIODIC INSPECTION PROGRAM The is a new program that performs periodic inspections to verify that no additional latent aging effects are occurring and to correct degraded conditions prior to loss of function.
Aging Management Program Elements The requirements of the Unit 1 Periodic Inspection Program are described below along with an evaluation of the program demonstrating compliance with the program elements of Appendix A of NUREG-1800.
Element 1 - Scope of Program The scope of the program should include the specific structures and components of which the program manages the aging.
BFN Description and Evaluation The scope of the Unit 1 Periodic Inspection Program includes system piping that did not require replacement following the extended Unit 1 outage. During the Unit 1 restart project, portions of several systems were examined that did not require replacement.
This piping is carbon/low alloy or stainless steel that was exposed to air, treated water, or raw water during the extended Unit 1 shutdown. The specific examinations are discussed in the TVA Letter to the U.S. Nuclear Regulatory Commission, Document Control Desk, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 -
License Renewal Application (LRA) - Response to NRC Request for Additional Information Concerning the Unit 1 Lay-up Program (TAC Nos. MC1704, MC1705, and MC1706) dated May 18, 2005.
The Unit 1 Periodic Inspection Program will examine a sample of those locations examined for plant restart as discussed in the referenced letter. The sample size will be determined in accordance with the sampling methodology described in EPRI 107514, Age-Related Degradation Inspection Method and Demonstration: In Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application. If failures are identified, the sample size will be appropriately expanded using the guidance of EPRI 107514. The initial sample, once selected, will be utilized in subsequent inspections, if practical. These periodic inspections are in addition to the restart inspections performed prior to Unit 1 restart.
Element 2 - Preventive Actions The activities for prevention and mitigation programs should be described. These actions should mitigate or prevent aging degradation.
E-4 BFN Description and Evaluation The Unit 1 Periodic Inspection Program is a detection program and does not include preventive elements.
Element 3 - Parameters Monitored or Inspected The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended functions. For a condition monitoring program, the parameter monitored or inspected should detect the presence and extent of aging effects. For a performance monitoring program, a link should be established between the degradation of the particular structure or component intended functions and the parameter(s) being monitored. For prevention and mitigation programs, the parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects.
BFN Description and Evaluation The selected sample will be examined by the same (UT thickness for piping and UT shear wave and surface exam for welds), or equivalent, methodology as used during restart. For these locations, the restart inspections can be utilized as a baseline for comparison. The inspection techniques utilized evaluate internal conditions and are sensitive to the presence of unacceptable conditions including wear, erosion, and corrosion (including crevice corrosion) if present.
Element 4 - Detection of Aging Effects Detection of aging effects should occur before there is a loss of the structure and component intended functions. The parameters to be monitored or inspected should be appropriate to ensure that the structure and component intended functions will be adequately maintained for license renewal under all CLB design conditions.
This includes aspects such as method or technique (e.g., visual, volumetric, surface inspection), frequency, sample size, data collection, and timing of new/one-time inspections to ensure timely detection of aging effects. Provide information that links the parameters to be monitored or inspected to the aging effects being managed.
BFN Description and Evaluation The susceptible locations identified are those areas determined to have the highest potential for service induced wear or latent aging effects, which includes all types of corrosion. The inspection techniques utilized evaluate internal conditions that are sensitive to the presence of unacceptable conditions including wear, erosion, corrosion (including crevice corrosion) if present. For these locations, the restart inspections can be utilized as a baseline for comparison. The first periodic inspection will be performed prior to the end of the current operating period and the subsequent
E-5 frequency of the periodic inspections will be determined based on the outcome of the first periodic inspections performed. The inspection frequency is re-evaluated each time the inspection is performed and can be changed based on the trend of the data results. The inspections will continue until such time as the trend of the data results provides a basis to discontinue the inspections.
Element 5 - Monitoring and Trending Monitoring and trending activities should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions. Plant-specific and/or industry-wide operating experience may be considered in evaluating the appropriateness of the technique and frequency.
BFN Description and Evaluation The susceptible locations are those areas determined to have the highest potential for service induced wear or latent aging effects, which includes all types of corrosion. For these locations, the restart inspections can be utilized as a baseline for comparison.
Element 6 - Acceptance Criteria The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended functions are maintained under all CLB design conditions during the period of extended operation. The program should include a methodology for analyzing the results against applicable acceptance criteria.
BFN Description and Evaluation The acceptance criteria for these periodic inspections is that the pipe wall remains above minimum acceptable wall thickness and that no unacceptable weld cracks exist.
Element 7 - Corrective Actions Actions to be taken when the acceptance criteria are not met should be described. Corrective actions, including root cause determination and prevention of recurrence, should be timely. If corrective actions permit analysis without repair or replacement, the analysis should ensure that the structure and component intended functions will be maintained consistent with the CLB.
BFN Description and Evaluation The Corrective Action Program is administered by TVAN procedure SPP-3.1 in accordance with 10 CFR Part 50, Appendix B, and meets the conditions to be used for corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation.
E-6 Element 8 - Confirmation Process The confirmation process should ensure that preventive actions are adequate and that appropriate corrective actions have been completed and are effective. The effectiveness of prevention and mitigation programs should be verified periodically. When corrective actions are necessary, there should be follow-up activities to confirm that the corrective actions were completed, the root cause determination was performed, and recurrence is prevented.
BFN Description and Evaluation The Corrective Action Program is administered by TVAN procedure SPP-3.1 in accordance with 10 CFR Part 50, Appendix B, and meets the conditions to be used for corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation.
Element 9 - Administrative Controls The administrative controls of the program should provide a formal review and approval process. Any AMPs to be relied on for license renewal should have regulatory and administrative controls.
BFN Description and Evaluation The Corrective Action Program is administered by TVAN procedure SPP-3.1 in accordance with 10 CFR Part 50, Appendix B, and meets the conditions to be used for corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation.
Element 10 - Operating experience The operating experience of AMPs, including past corrective actions resulting in program enhancements or additional programs, should be considered. A past failure would not necessarily invalidate an AMP because the feedback from operating experience should have resulted in appropriate program enhancements or new programs. This information can show where an existing program has succeeded and where it has failed (if at all) in intercepting aging degradation in a timely manner. This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended functions will be maintained during the period of extended operation. An applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness.
BFN Description and Evaluation The Unit 1 Periodic Inspection Program is a new program that will monitor the operating condition of Unit 1 components that were not replaced during the Unit 1 restart. Therefore, there is no applicable operating experience for this inspection program.
E-7 Conclusion The Unit 1 Periodic Inspection Program is a new program identified to monitor system piping that did not require replacement following the extended Unit 1 outage. The Unit 1 Periodic Inspection Program will verify that no additional latent aging effects are occurring.
The Unit 1 periodic inspections will be performed after Unit 1 is returned to operation. The first periodic inspection will be performed prior to the end of the current operating period and the subsequent frequency of the periodic inspections will be determined based on the outcome of the first periodic inspections performed.
The inspection frequency is re-evaluated each time the inspection is performed and can be changed based on the trend of the results.
The inspections will continue until such time as the trend of the results provides a basis to discontinue the inspections.