ML052220070

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Consolidated List of Commitments for License Renewal
ML052220070
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 08/09/2005
From: Crouch W
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC1704, TAC MC1705, TAC MC1706
Download: ML052220070 (36)
v • d • e


Text

August 9, 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 -

CONSOLIDATED LIST OF COMMITMENTS FOR LICENSE RENEWAL (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 to the NRC dated October 8, 2004 (Reference 1), TVA stated it would provide a consolidated list of commitments for the BFN License Renewal Application consistent with NEI letter to the NRC dated February 26, 2003, to Dr. P. T. Kuo in regards to the subject: Industry Response - Consolidated List of Commitments for License Renewal, December 16, 2002.

The enclosure to this letter provides the Lists of Commitments.

U.S. Nuclear Regulatory Commission Page 2 August 9, 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 9th day of August, 2005.

Sincerely, Original signed by:

William D. Crouch Manager of Licensing and Industry Affairs

Enclosure:

cc: See page 3 REFERENCE

1. T. E. Abney (TVA) to NRC letter dated October 8, 2004:

Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 License Renewal Application - Response To NRC Request For Additional Information (RAI) Developed During The License Renewal Audit Inspections For Comparison To Generic Aging Lessons Learned (GALL) During Weeks of June 21, 2004 and July 26, 2004 (TAC NOs. MC1704, MC1705, and MC1706)

U.S. Nuclear Regulatory Commission Page 3 August 9, 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 9, 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 9, 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 Consolidated List of Commitments for License Renewal.doc

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA)

CONSOLIDATED LISTS OF COMMITMENTS FOR LICENSE RENEWAL (SEE ATTACHED)

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA)

CONSOLIDATED LISTS OF COMMITMENTS FOR LICENSE RENEWAL 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 to the NRC dated October 8, 2004 (Reference 1), TVA stated it would provide a consolidated list of commitments for the BFN License Renewal Application consistent with NEI letter to the NRC dated February 26, 2003, to Dr. P. T. Kuo in regards to the subject: Industry Response - Consolidated List of Commitments for License Renewal, December 16, 2002.

Appendix A to this enclosure provides the Lists of Commitments.

Page A-1 APPENDIX A COMMITMENTS FOR LICENSE RENEWAL OF BFN UNITS 1, 2, AND 3 During the review of the Browns Ferry Nuclear Plant (BFN) license renewal application (LRA) by the U.S. Nuclear Regulatory Commission (NRC) staff, the applicant made commitments related to aging management programs (AMPs) to manage aging effects of structures, systems, and components (SSCs) before the period of extended operation. This Appendix includes two tables that list these commitments, along with the implementation schedule and the source of the commitment:

Table 1 lists those commitments that are not for a specific unit.

Table 2 lists commitments that are specific to Unit 1 Note that these tables also contain non-AMP commitments.

Page A-2 THIS PAGE IS INTENTIONALLY LEFT BLANK

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-3 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

1. Accessible Non-Environmental Qualification Cables and Connections Inspection Program A new program will be developed that is consistent with the program described in NUREG-1801 Section XI.E1 evaluation.

A.1.1

  • Prior to the period of extended operation
  • LRA Section B.2.1.1 The portion of the program that manages LPRM cable system aging will credit existing Technical Specification requirements and, with the exceptions specified in the LRA, will meet the intent of the program described in NUREG-1801 Section XI.E2.
  • On-going
  • Response to follow-up to RAI 2.5-2 (page E-5 of Reference 1)
2. Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program The portion of the program that manages IRM cable system aging will be a new program at BFN and will be consistent with the program described in NUREG-1801 Section XI.E2.

A.1.2

  • Prior to the period of extended operation.
  • Response to follow-up to RAI 2.5-2 (page E-5 of Reference 1)

A new program will be developed that is consistent with the program described in NUREG-1801 Section XI.E3 to manage the medium-voltage cables to the Residual Heat Removal Service Water pumps.

  • Prior to the period of extended operation
3. Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Annually inspect for water collection for in-scope cable manholes and conduit.

A.1.3

  • Prior to the period of extended operation
  • Response to Follow-Up to RAI 3.6-3 (page E-1 of Reference 2)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-4 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

4. ASME Section XI Inservice Inspection Subsections IWB, IWC, and IWD Program The existing program is credited.

A.1.4

  • On-going
5. Chemistry Control Program The existing program is credited for Units 2 and 3.

A.1.5

  • On-going
6. Reactor Head Closure Studs Program The existing program is credited.

A.1.6

  • On-going
7. Boiling Water Reactor Vessel Inside Diameter Attachment Welds Program The existing program is credited for Units 2 and 3.

A.1.7

  • On-going
8. Boiling Water Reactor Feedwater Nozzle Program The existing program is credited for Units 2 and 3.

A.1.8

  • On-going
9. Boiling Water Reactor Control Rod Drive Return Line Nozzle Program The existing program is credited.

A.1.9

  • On-going
10. Boiling Water Reactor Stress Corrosion Cracking Program The existing program is credited for Units 2 and 3.

A.1.10

  • On-going
11. Boiling Water Reactor Penetrations Program The existing program is credited for Units 2 and 3.

A.1.11

  • On-going

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-5 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source The existing program is credited for Units 2 and 3.

  • On-going
  • LRA Section B.2.1.12 Inspection will be performed of the top guide beams with examination extent and frequency similar to the CRD guide tube (BWRVIP-47) examination requirements. The sample will emphasize the components exposed to the highest fluence. The method of examination will be EVT-1. TVA reserves the right to modify the above agreed upon inspection program should BWRVIP-26 be revised in the future.

Any changes, however, will not be final until a Safety Evaluation is issued by the NRC for the revised BWRVIP-26.

A.1.12

  • Prior to the period of extended operation
  • Response to NRC Question (3) (Page E-3 of Reference 4)
12. Boiling Water Reactor Vessel Internals Program The steam dryers have been added to the scope of license renewal. The aging management review will be completed and an aging management program will be established for the steam dryers. The aging management program will be the NRC approved BWRVIP Steam Dryer Inspection and Evaluation Guidelines. If the BWRVIP Steam Dryer Inspection and Evaluation Guidelines are not approved by the NRC, then a plant specific aging management program will be submitted to the NRC for review and approval two years before the first BFN unit enters the period of extended operation.
  • Two years before the first BFN unit enters the period of extended operation.
  • Response to RAI 3.1-1 (page E-2 of Reference 3)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-6 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

12. Boiling Water Reactor Vessel Internals Program (continued)

Enhance the Reactor Pressure Vessel Internals Inspection (RPVII) Units 1, 2, and 3 procedure to require visual inspection of the AHCs and inspection of the AHCs welds by UT unless tooling constraints prohibit performance of a UT. In the event tooling constraints prohibit inspection by UT during the period of extended operation, NRC approval will be requested to substitute an EVT-1 inspection.

  • Two years before the first BFN unit enters the period of extended operation.
  • Response to RAI B.2.1.12-1 (C) (page E-70 of Reference 3)
  • Response to NRC Question (7) (pages E-7 and E-8 of Reference 4)

The BFN jet pump nozzle and forged integral portion of the thermal sleeve are type 316NG stainless steel. The BWR Reactor Vessel Internals Program implements the inspection requirements for weld TS-2. As noted in Table 3.3-1 of BWRVIP-41, the TS-2 weld is currently inaccessible and is not inspected. BFN will implement the inspection technique for this weld that the BWRVIP Inspection Committee is developing when available.

  • BFN will implement the inspection technique for weld TS-2 that the BWRVIP Inspection Committee is developing, when available.
  • Response to Question (12) (pages E-11 and E-12 of Reference 4)
13. Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program DELETED A.1.13
  • DELETED
  • Response to RAI 3.1.2.2-9 (pages E-31 and E-32 of Reference 3)
14. Flow-Accelerated Corrosion Program The existing program is credited for Units 2 and 3.

A.1.14

  • On-going

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-7 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

15. Bolting Integrity Program The existing program is credited.

A.1.15

  • On-going
16. Open-Cycle Cooling Water System Program The existing program is credited for Units 2 and 3.

A.1.16

  • On-going
17. Closed-Cycle Cooling Water System Program The existing program is credited for Units 2 and 3.

A.1.17

  • On-going
18. Inspection of Overhead Heavy Load and Light Load Handling Systems Program The existing program is credited.

A.1.18

  • On-going
  • On-going
19. Compressed Air Monitoring Program This program will be enhanced to incorporate guidelines in ASME OM-S/G-2000, Part 17; ANSI/ISA-S7.0.01-1996; and EPRI TR-108147.

A.1.19

  • Prior to the period of extended operation
20. BWR Reactor Water Cleanup System Program The existing program is credited for Units 2 and 3.

A.1.20

  • On-going
21. Fire Protection Program The existing program is credited for Units 2 and 3.

A.1.21

  • On-going

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-8 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source The existing program is credited.

This program will be enhanced by making the following changes:

  • On-going
22. Fire Water System Program BFN will perform flow tests or non-intrusive examinations to identify evidence of loss of material due to corrosion.

A.1.22

  • Before entering the period of extended operation.
  • LRA Section B.2.1.24 BFN will perform sprinkler head inspections before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the period of extended operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.
  • Prior to exceeding the 50-year service life for any sprinkler.
23. Aboveground Carbon Steel Tanks Program The existing program is credited.

A.1.23

  • On-going.
24. Fuel Oil Chemistry Program The existing program is credited.

A.1.24

  • On-going.

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-9 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source The existing program is credited.

  • On-going
  • Prior to the period of extended operation
25. Reactor Vessel Surveillance Program BFN will implement either BWRVIP-116, as approved by the staff, or if the ISP is not approved two years prior to the commencement of the license renewal period, a plant-specific surveillance program for each BFN unit will be submitted to the NRC that ensures the BFN Unit 1, Unit 2, and Unit 3 reactor vessels meet the requirements of 10 CFR 50 Appendix H.

A.1.25

  • Response to RAI B.2.1.28-1(A) (page E-76 of Reference 3)
  • Response to Question (9) (pages E-9 and E-18 of Reference 4)

The BFN, Units 1 and 3 surveillance capsules (standby capsules) will remain in place and will continue to be irradiated during plant operation, including the period of extended operation. Therefore, the BFN, Units 1 and 3 irradiated material samples continue to remain available to the ISP, if needed. If any surveillance capsules are removed without the intent to test them, these capsules will be stored in a manner which maintains them in a condition which would support re-insertion into the RV, if necessary.

  • On-going
  • Response to Question (10) (pages E-9 and E-18 of Reference 4)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-10 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source A new program will be developed to be consistent with the NUREG-1801 XI.M32 evaluation.

  • To be completed before the end of the current operating license term. Inspection schedule will be completed to minimize the impact on plant operations.

However, the inspection will not be scheduled too early in the current operating license term so that there will be no questions raised regarding the continued absence of aging effects prior to and near the extended period of operation.

26. One-Time Inspection Program Submit procedure for NRC review.

A.1.26

  • At least two years prior to the expiration of the current operating license
  • Response to Proposed Unresolved Item 3.0-4 LP (page E-5 of Reference 5)

Perform a one-time inspection of the ASME equivalent Class MC supports in a submerged environment of the Units 2 and 3 Torus.

  • Prior to the period of extended operation
  • Response to RAI B.2.1.33-2 (pages E-3 and E-4 of Reference 6)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-11 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

26. One-Time Inspection Program (continued)

Perform a one-time inspection of the in-scope submerged concrete in one individual pump bay of the Intake Pumping Station.

  • Prior to the period of extended operation
  • Response to Question 359 (Page E-55 of reference 12)
  • Response to RAI 3.5-16 (page E-5 of Reference 10)

Perform ultrasonic thickness measurements of tank bottoms to ensure that significant degradation is not occurring for those tanks specified in the Fuel Oil Chemistry Program (B.2.1.27) and the Aboveground Carbon Steel Tanks Program (B.2.1.26).

  • Prior to the period of extended operation
  • Response to RAI 7.1.19-1 (Page E-2 of Reference 8)
27. Selective Leaching of Materials Program A new program is being developed to be consistent with the NUREG-1801 XI.M33 evaluation.

A.1.27

  • Prior to the period of extended operation

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-12 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source The existing program is credited.

  • On-going
28. Buried Piping and Tanks Inspection Program Enhancement is required to add a trigger to the excavation permit document to require notification of engineering to perform a piping inspection when piping is excavated.

A.1.28

  • Prior to the period of extended operation
  • Last paragraph of II.A. (page 2) and C.10 (pages 7 and 8) of NRC Inspection Report (Reference 7)

Before the tenth year of extended operation, BFN will perform an engineering evaluation to determine if sufficient inspections have been conducted to draw a conclusion regarding the ability of the underground coatings to protect the underground piping from degradation. If not, BFN will conduct a focused inspection to allow that conclusion to be reached

  • Within ten years after entering the period of extended operation
  • Response to RAI 7.1.22-1 (page E-3 of Reference 8)

Buried piping within the scope of the Buried Piping and Tanks Inspection Program will be inspected when they are excavated for maintenance or when those components are exposed for any reason

  • On-going
  • Response to RAI 7.1.22-1 (page E-3 of Reference 8)
29. ASME Section XI Subsection IWE Program The existing program is credited.

A.1.29

  • On-going

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-13 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source The existing program is credited.

  • On-going
30. ASME Section XI Subsection IWF Program Enhance the ASME Section XI Subsection IWF Program to manage the aging effects of ASME equivalent Class MC supports.

A.1.30

  • Prior to the period of extended operation.
  • Response to Follow-up RAI B.2.1.33-1 (pages E-21 and E-23 of Reference 9)
31. 10 CFR 50 Appendix J Program The existing program is credited.

A.1.31

  • On-going
  • On-going
32. Masonry Wall Program Program will be enhanced so that structures with masonry walls within the scope of license renewal are clearly identified and the qualification requirements for personnel who perform masonry wall walkdowns within the scope of license renewal are clarified.

A.1.32

  • Prior to the period of extended operation.
  • On-going
33. Structures Monitoring Program Enhance procedures implementing the 10 CFR 50.65 Maintenance Rule Program to identify all structures and structural components within the scope of license renewal and all aging effects and associated mechanisms for inspection.

A.1.33

  • Prior to the period of extended operation.
  • Response to GALL audit question 173 (page E-10 of Reference 12)
  • Response to GALL audit question 357(pages E-54 of Reference 12)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-14 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

33. Structures Monitoring Program (continued)

Enhance procedures implementing the 10 CFR 50.65 Maintenance Rule program sampling approach to include examinations of below-grade concrete when excavated for any reason.

  • Prior to the period of extended operation.
  • Response to GALL audit question 285 (pages E-34 and E-35 of Reference
12)

Enhance procedures implementing the 10 CFR 50.65 Maintenance Rule program to include the guidance provided in ACI 349.3R-96 Chapter 7 to clarify the suitably knowledgeable or trained inspector qualifications to training and proficiency demonstration of inspectors for structural aging effects and long term performance issues. The procedures will also be clarified to identify

  • Prior to the period of extended operation.
  • Prior to entering the period of extended operation.
  • Response to GALL audit question 285 (pages E-34 and E-35 of Reference
12)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-15 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source The existing program is credited.

  • On-going
  • Prior to the period of extended operation
  • LRA Section B.2.1.37 Program documents will be enhanced to include special inspections following the occurrence of large floods, earthquakes, tornadoes, and intense rainfall.
  • Prior to the period of extended operation
34. Inspection of Water-Control Structures Program Implement periodic monitoring of the raw service water in close proximity to the Intake Pumping Station for the requirements of an aggressive environment as described in NUREG-1557. Periodic monitoring will be consistent with the BFN Structures Monitoring Program inspection frequency.

A.1.34

  • Prior to the period of extended operation
  • Response to RAI 3.5-16 (page E-9 of Reference 10)
35. Environmental Qualification Program The existing program is credited for Units 2 and 3.

A.1.35

  • On-going

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-16 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

36. Fatigue Monitoring Program The enhanced Fatigue Monitoring Program will use the EPRI-licensed FatiguePro cycle counting and fatigue usage tracking computer program. This program calculates stress cycles and resulting Cumulative Usage Factor (CUF) values from operating cycles. These calculations will be automated and performed periodically based on information downloads from the plants instrumentation computers.

The enhancements will include expansion of the program coverage as follows:

  • This program will include select Reactor Vessel locations as specified in Table 4.3.1.1 of the LRA.
  • This program will include the locations identified by NUREG /

CR-6260 for environmental fatigue evaluation as discussed in 4.3.4 of the LRA and in accordance with NUREG-1801 Section X.M1.

  • This program will include monitoring the fatigue of the suppression chamber and suppression chamber vents, as specified in 4.6.1 of the LRA.

A.1.36

  • Prior to the period of extended operation
37. Systems Monitoring Program The existing program is credited.

A.2.1

  • On-going

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-17 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

38. Bus Inspection Program The Bus Inspection Program is a new program that will be performed in conjunction with routine maintenance activities. The program will include visual inspection and electrical testing of in-scope phase bus for evidence of degraded bus insulation (non-segregated phase bus only) and loosened bolted bus connections.

The program will also include internal visual inspection of the in-scope phase bus enclosure for excessive dust build up, evidence of water intrusion, debris, and damage to internal supports and insulators. These inspections will be performed at least once every 10 years after the first inspection.

A.2.2

  • Prior to the period of extended operation
39. Diesel Starting Air Program The existing program is credited.

A.2.3

  • On-going

A.2.4

  • Prior to the period of extended operation
  • Response to Proposed Unresolved Items 3.0-2 LP (1 & 2) and 3.0-3 LP (page E-3 of Reference 5)
40. Periodic Inspection Program Submit procedure for NRC review.
  • At least two years prior to the period of extended operation
  • Response to Proposed Unresolved Item 3.0-4 LP (page E-5 of Reference 5)

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-18 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

41. Time-Limited Aging Analysis:

Reactor Vessel Thermal Limit Analyses:

Operating Pressure-Temperature Limits (P-T)

Revised P-T limits will be prepared and submitted to the NRC for approval using an approved fluence methodology.

A.3.1.5

  • Prior to the period of extended operation
  • LRA Section A.3.1.5
  • LRA Section 4.2.5
42. Time-Limited Aging Analysis:

Reactor Vessel Circumferential Weld Examination Relief An extension of the Reactor Vessel Circumferential Weld Examination Relief request will be submitted to the NRC.

A.3.1.6

  • Prior to the period of extended operation
  • LRA Section 4.2.6
  • Response to NRC RAI 4.2.6-1 (pages E-58 and E-59 of Reference 3)
  • Response to NRC RPV Internals, Question (1) (pages E-1 and E-13 of Reference 4)
43. Time-Limited Aging Analysis:

Reactor Vessel Axial Weld Failure Probability The Units 1, 2, and 3 limiting weld chemistry, chemistry factor and 60 year life mean RTNDT values are within the limits of the values assumed in the analysis performed by the NRC staff in its BWRVIP-05 SER supplement. Therefore, the probability of failure for the axial welds is bounded by the NRC evaluation.

A.3.1.7

  • Complete
  • LRA Section 4.2.7
  • Response to NRC RAI 4.2.7-1 (pages E-59 and E-60 of Reference 3)
  • Response to NRC RPV Internals, Question (2) (pages E-1 and E-13 of Reference 4)
44. Time-Limited Aging Analysis:

Environmental Qualification of Electrical Equipment The aging effects of electrical components subject to the requirements of 10 CFR 50.49 will be managed in the EQ Program in accordance with the requirements of 10 CFR 54.21(c)(1)(iii).

A.3.3

  • Prior to the period of extended operation
  • LRA Section 4.4
  • LRA Section A.3.3

TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (NON-UNIT SPECIFIC)

Page A-19 Item Number/Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

45. Time-Limited Aging Analysis:

Other Plant Specific Time-Limited Aging Analysis:

Emergency Equipment Cooling Water Weld Flaw Evaluation An administrative tracking system will be developed and used to ensure that the 125 fatigue cycles will not be exceeded at the select EECW locations.

A.3.5.7

  • Prior to the period of extended operation
  • LRA Section A.3.5.7
  • Response to RAI 4.7.8 (page E-7 of Reference 1)
46. RAI 2.1-2,A-3 Review seismic Class I piping boundaries to identify additional piping segments and supports/equivalent anchors that need to be placed in scope.

N/A

  • Completed
  • Response to RAI 2.1-2,A-3 (Page 9 of Reference 13)
  • Completion of action was documented in Reference 14.
47. RAI 2.1-2,B Perform Unit 2 and Unit 3 DCN to qualify twelve temperature switches in the Turbine Building.

N/A

  • Prior to the period of extended operation
  • Response to RAI 2.1-2,B (Page 9 of Reference 13)
48. RAI 2.1-2,C RHRSW tunnel Include 24-inch Raw Cooling Water discharge piping located in the RHRSW tunnel in scope of License Renewal.

N/A

  • Completed
  • Response to RAI 2.1-2,C RHRSW tunnel (Page 9 of Reference
13)
  • Completion of annual update was documented in Reference 15.
49. RAI 2.1-2,C Intake Pumping Station Revise 10 CFR 54.4(a)(2) Scoping Methodology document to address lower compartments of the Intake Pumping Station.

N/A

  • Prior to next annual update
  • Response to RAI 2.1-2,C Intake Pumping Station (Page 10 of Reference 13)

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-20 NOTE:

This Table does not contain all of the same Item Numbers as contained in Table 1. While there is a one-to-one correlation of items with the same number, the same Item Numbers are not in both tables as explained below:

Only those Item Numbers that have a Unit 1 Specific commitment are included in Table 2.

Item Numbers 50. through 63. apply only to Unit 1.

Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

2. Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program Unit 1 High-Range Radiation Monitoring cables will be included in the Environmental Qualification (EQ) Program, regardless of their location in mild or harsh areas of the plant.

A.1.2

  • Prior to Unit 1 restart
  • Response to GALL audit question 169 (page E-9 of Reference 12)
5. Chemistry Control Program The program will be enhanced to incorporate Unit 1.

A.1.5

  • Prior to Unit 1 restart.
7. Boiling Water Reactor Vessel Inside Diameter Attachment Welds Program The program will be enhanced to incorporate Unit 1.

A.1.7

  • Prior to Unit 1 restart.
  • LRA Appendix F.6
8. Boiling Water Reactor Feedwater Nozzle Program The Unit 1 operating procedures will be upgraded to decrease the magnitude and frequency of feedwater temperature fluctuations.

A.1.8

  • Prior to Unit 1 restart.

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-21 Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

10. Boiling Water Reactor Stress Corrosion Cracking Program The program will be enhanced to incorporate Unit 1.

A.1.10

  • Prior to Unit 1 restart.
  • LRA Appendix F.5
  • Response to GALL audit question 181 (page E-13 of Reference 12)
11. Boiling Water Reactor Penetrations Program The program will be enhanced to incorporate Unit 1.

A.1.11

  • Prior to Unit 1 restart.
  • LRA Appendix F.6
  • Response to GALL audit question 194 (page E-17 of Reference 12)

The program will be enhanced to incorporate Unit 1.

  • Prior to Unit 1 restart.
  • LRA Appendix F.6
12. Boiling Water Reactor Vessel Internals Program BWRVIP-75 will be implemented prior to Unit 1 restart.

A.1.12

  • Prior to Unit 1 restart
  • Response to Question (4b) (page E-5 of Reference 4)
14. Flow-Accelerated Corrosion Program The program will be enhanced to incorporate Unit 1.

A.1.14

  • Prior to Unit 1 restart.
  • Response to GALL audit question 144 (page E-3 of Reference 12)
16. Open-Cycle Cooling Water System Program The program will be enhanced to incorporate Unit 1.

A.1.16

  • Prior to Unit 1 restart.
  • Response to GALL audit question 144 (page E-3 of Reference 12)

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-22 Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

17. Closed-Cycle Cooling Water System Program The program will be enhanced to incorporate Unit 1.

A.1.17

  • Prior to Unit 1 restart.
  • Response to GALL audit question 144 (page E-3 of Reference 12)
19. Compressed Air Monitoring Program The program will be enhanced to incorporate Unit 1.

A.1.19

  • Prior to Unit 1 restart.
20. BWR Reactor Water Cleanup System Program The program will be enhanced to incorporate Unit 1.

A.1.20

  • Prior to Unit 1 restart
  • LRA Appendix F.5
  • LRA Appendix F.13
21. Fire Protection Program The Fire Protection Report and procedures will be updated to incorporate Unit 1 as an operating unit rather than a shutdown unit.

The program will be fully implemented on Unit 1.

A.1.21

  • Prior to Unit 1 restart
  • LRA Appendix F.3
22. Fire Water System Program The Fire Protection Report and procedures will be updated to incorporate Unit 1 as an operating unit rather than a shutdown unit.

The program will be fully implemented on Unit 1.

A.1.22

  • Prior to Unit 1 restart
  • LRA Appendix F.3

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-23 Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source Unit 1 will be included within the BWRVIP ISP, or a plant specific surveillance program will be submitted for NRC approval that meets the requirements of 10 CFR 50 Appendix H for the period of extended operation.

  • Prior to the period of extended operation
25. Reactor Vessel Surveillance Program BWRVIP-86-A and BWRVIP-116 will be updated to incorporate Browns Ferry Unit 1 accordingly and a license amendment will be submitted to the NRC to implement the ISP for site-specific use for Unit 1 prior to the beginning of the period of extended operation.

A.1.25

  • Prior to the period of extended operation
  • Response to RAI B.2.1.28-1(b) (page E-77 of Reference
3)
26. One-Time Inspection Program Perform a one-time inspection of the ASME equivalent Class MC supports in a submerged environment of the Unit 1 Torus.

A.1.26

  • Prior to Unit 1 restart
  • Response to RAI B.2.1.33-2 (pages E-3 and E-4 of Reference 6)
35. Environmental Qualification Program The program will be implemented on Unit 1.

A.1.35

  • Prior to Unit 1 restart

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-24 Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

42. Time-Limited Aging Analysis:

Reactor Vessel Circumferential Weld Examination Relief The RPV circumferential weld examination relief request for BFN Unit 1 will be included, and TVA will be using procedures and training to limit cold over-pressure events during the period of extended operation for BFN Unit 1. The procedures and training used to limit cold over-pressure events will be the same as those approved by the NRC when BFN requested that the BWRVIP-05 technical alternative be used for the current term for Units 2 and 3.

A.3.1.6

  • Prior to Unit 1 restart
  • LRA Section 4.2.6 as modified by the response to NRC Question (1) concerning RPV Internals (pages E-1 and E-13 of Reference 4)
  • Request granted by NRC letter (Reference 17)
47. RAI 2.1-2, B Perform Unit 1 DCN to qualify twelve temperature switches in the Turbine Building.

N/A

  • Prior to the period of extended operation
  • Response to RAI 2.1-2,B (page 9 of Reference 13)
50. Appendix F.1 Main steam leakage path piping will be evaluated and modified as required to ensure structural integrity.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
51. Appendix F.2 Containment Atmosphere Dilution System modification will be implemented.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
52. Appendix F.3 Fire Protection Program will be revised to ensure compliance with 10 CFR 50 Appendix R.

Fire protection Report will be revised per Unit 1 License Condition 2.C.13.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-25 Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

53. Appendix F.4 Environmental Qualification Program will be implemented.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
54. Appendix F.5 GL 88-01 will be addressed, and necessary plant modifications made.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
55. Appendix F.6 BWRVIP Programs used for Units 2 and 3 will be used for Unit 1.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
56. Appendix F.7 ATWS features will be installed.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
57. Appendix F.8 Reactor Vessel Head Spray piping in drywell will be removed, and the primary containment penetrations will be sealed.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
58. Appendix F.9 The Hardened Wetwell Vent modification will be implemented.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
59. Appendix F.10 Service Air and Demineralized Water Primary Containment Penetrations will be capped.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.

TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A, AGING MANAGEMENT PROGRAMS AND TLAAs (UNIT 1 SPECIFIC)

Page A-26 Item Number / Title Commitment LRA Appendix A (UFSAR)

Implementation Schedule Source

60. Appendix F.11 Auxiliary Decay Heat Removal System will be modified to serve Unit 1.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
61. Appendix F.12 Maintenance Rule will be fully implemented when the temporary Unit 1 exemption ceases to be effective.

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.
62. Appendix F.13

N/A

  • Prior to Unit 1 restart
  • See Reference 16 for additional information.

TVA commits to replace all BFN Unit 1 dry tubes prior to restart

  • Prior to Unit 1 restart
  • Response to Question (8) (page E-9 of Reference 4)

For Unit 1 Control Rod Drive Return Line Cap, MSIP will be performed."

  • Prior to Unit 1 restart
  • Response to Question (6) (page E-7 of Reference 4)
63. Response to NRC Questions Concerning RPV Internals The Unit 1 AHCs will be changed to bolted design prior to Unit 1 restart and do not require enhanced inspections.

N/A

  • Prior to Unit 1 restart
  • Response to NRC Question (7) (page E-7 of Reference 4)

Page A-27 REFERENCES

1.

T. E. Abney (TVA) To NRC Letter Dated March 2, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 License Renewal Application (LRA) - LRA Sections 2.5 And 4.7.8 - Response To NRC Request For Follow Up Question For RAI B.2.1.5-3, 2.5-2, And 4.7.8 (TAC Nos. MC1704, MC1705, And MC1706)

2.

T. E. Abney (TVA) To NRC Letter Dated January 18, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 License Renewal Application - Electrical And Instrument And Control (I&C)

Sections 2.5 And 3.6 - Response To NRC Request For Additional Information (RAI) For NRC Follow Up Questions (TAC Nos.

MC1704, MC1705, And MC1706)

3.

T. E. Abney (TVA) To NRC Letter Dated January 31, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - License Renewal Application - Reactor Vessel And Internals Mechanical Systems Sections 3.1, 4.2, And B.2.1 - Response To NRC Request For Additional Information (RAI) (TAC Nos. MC1704, MC1705, And MC1706)

4.

T. E. Abney (TVA) To NRC Letter Dated May 25, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - License Renewal Application (LRA) - Response To NRC Request For Additional Information Concerning Reactor Pressure Vessel (RPV) Internals (TAC Nos. MC1704, MC1705, And MC1706)

5.

T. E. Abney (TVA) To NRC Letter 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)

6.

T. E. Abney (TVA) To NRC Letter Dated January 18, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 License Renewal Application (LRA) - LRA Section Related To The ASME Section XI Subsection IWF Program, LRA Section B.2.1.33 - Request For Additional Information (RAI) (TAC Nos. MC1704, MC1705, And MC1706)

7.

Harold O. Christensen (NRC) To Karl W. Singer (TVA) Letter Dated January 27, 2005: Browns Ferry Nuclear Plant -

Inspection Report 05000259/2004012, 05000260/2004012, AND 05000296/2004012

8.

T. E. Abney (TVA) To NRC Letter Dated May 25, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - License Renewal Application (LRA) - Response To NRC Request For Additional Information On Clarification On Gall Audit RAI 7.1.19-1 And RAI 7.1.22-1 (TAC Nos. MC1704, MC1705, And MC1706)

Page A-28

9.

Mike D. Skaggs (TVA) To NRC Letter Dated May 31, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - License Renewal Application (LRA) - Response To NRC Request For Additional Information Concerning Follow Up To RAI 2.4-3, Follow Up To RAI 3.5-1, Follow Up To RAI 3.5-4, Follow Up To RAI B.2.1.33-1, And Follow Up To RAI 2.1.36 (TAC Nos. MC1704, MC1705, And MC1706)

10.

T. E. Abney (TVA) To NRC Letter Dated April 5, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - License Renewal Application (LRA) - Response To NRC Requests For Additional Information (RAIs) 3.1.2.4-7 (Aging Management Review For Small Bore Piping And Fittings) And 3.5-16 (Submerged Reinforced Concrete) (TAC Nos. MC1704, MC1705, And MC1706)

11.

T. E. Abney (TVA) to NRC Letter Dated December 9, 2004:

Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 -

License Renewal Application (LRA) - Response to NRC Request for Additional Information Concerning Electrical and Instrument and Control (I&C) Systems Section 3.6 (TAC Nos.

MC1704, MC1705, and MC1706)

12.

T. E. Abney (TVA) to NRC Letter Dated October 8, 2004:

Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 -

License Renewal Application (LRA) - Response to NRC RAI Developed During The License Renewal Audit Inspections for Comparison to Generic Aging Lessons Learned (GALL) During Weeks of June 21, 2004 and July 26, 2004 (TAC Nos. MC1704, MC1705, and MC1706)

13.

T. E. Abney (TVA) To NRC Letter Dated September 3, 2004:

Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 License Renewal Application - NRC Scoping and Screening Audit -

Request For Additional Information (TAC Nos. MM1704, MC1705, and MC1706)

14.

T. E. Abney (TVA) To 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)

15.

T. E. Abney (TVA) To NRC Letter Dated January 31, 2005:

Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 License Renewal Application - Annual Update (TAC Nos. MC1704, MC1705, and MC1706)

16.

T. E. Abney (TVA) To NRC Letter Dated January 31, 2005: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 License Renewal Application - Additional Information Concerning The Integration Of Unit 1 Restart And License Renewal Activities (TAC NOS. MC1704, MC1705, and MC1706)

Page A-29

17.

Michael L. Marshall, Jr. (NRC) to Karl W. Singer (TVA) Letter Dated May 31, 2005: Browns Ferry Nuclear Plant Unit 1 -

Safety Evaluation for Relief Request 1-ISI-19 Associated With Reactor Pressure Vessel Circumferential Shell Welds (TAC No. MC3151)

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