ML060320733

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Response to NRC Request EMEB-B.7 from NRC Round 2 Requests for Additional Information Related to Technical Specification (TS) Change No. TS-418 - Request for Extended Power Uprate
ML060320733
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 02/01/2006
From: Crouch W
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC3743, TAC MC3744, TVA-BFN-418
Download: ML060320733 (11)
v • d • e


Text

TVA-BFN-418 February 1, 2006 10 CFR 50.90 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. 50-260 Tennessee Valley Authority ) 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 2 AND 3 - RESPONSE TO NRC REQUEST EMEB-B.7 FROM NRC ROUND 2 REQUESTS FOR ADDITIONAL INFORMATION RELATED TO TECHNICAL SPECIFICATIONS (TS) CHANGE NO. TS-418 - REQUEST FOR EXTENDED POWER UPRATE (TAC NOS. MC3743 AND MC3744)

TVAs letter of December 19, 2005 (Reference 1), provided TVAs response to the NRC Staffs request for additional information, which was submitted to TVA by letter dated October 3, 2005 (Reference 2), in order to support review of the BFN Units 2 and 3 Extended Power Uprate (EPU) license amendment applications. TVAs letter noted that the response to NRC Request EMEB-B.7 would be deferred, and that TVA would provide the complete response by February 1, 2006. This letter provides the response to NRC Request EMEB-B.7.

TVA submitted the BFN Units 2 and 3 EPU application to the NRC by letter dated June 25, 2004 (Reference 3). TVA supplemented that application by letters dated February 23, 2005 (Reference 4), April 25, 2005 (Reference 5), and June 6, 2005 (Reference 6).

U.S. Nuclear Regulatory Commission Page 2 February 1, 2006 There are no new regulatory commitments associated with this submittal. If you have any questions concerning this letter, please contact me at (256) 729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 1st day of February, 2006.

Sincerely, Original signed by:

William D. Crouch Manager of Licensing and Industry Affairs

References:

1. TVA letter, Brian OGrady to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Response to NRC Round 2 Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418 - Request For Extended Power Uprate Operation (TAC Nos. MC3743 and MC3744)," dated December 19, 2005
2. NRC letter, Eva A. Brown to TVA, "Browns Ferry Nuclear Plant, Units 2 and 3 - Request for Additional Information for Extended power Uprate (TS-431)(TAC NOs. MC3743 and MC3744)," dated October 3, 2005
3. TVA letter, T. E. Abney to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Proposed Technical Specifications (TS) Change TS-418 - Request for License Amendment Extended Power Uprate (EPU) Operation," dated June 25, 2004

U.S. Nuclear Regulatory Commission Page 3 February 1, 2006

4. TVA letter, T. E. Abney to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Response to NRCs Acceptance Review Letter and Request for Additional Information Related to Technical Specifications (TS)

Change No. TS-418 - Request for Extended Power Uprate Operation, (TAC Nos MC3743 and MC3744)," dated February 23, 2005

5. TVA letter, T. E. Abney to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2, and 3 - Response to NRC's Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418 - Request for Extended Power Uprate Operation (TAC Nos MC3743 and MC3744)," dated April 25, 2005
6. TVA letter, William D. Crouch to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Response to NRC's Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418 - Request For License Amendment - Extended Power Uprate (EPU) Operation (TAC Nos MC3743 and MC3744)," dated June 6, 2005

Enclosures:

cc: See page 4

U.S. Nuclear Regulatory Commission Page 4 February 1, 2006 Enclosures cc (Enclosures):

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)

Enclosures cc (Enclosures):

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 cc: continued page 5

U.S. Nuclear Regulatory Commission Page 5 February 1, 2006 cc: (Enclosures)

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

U.S. Nuclear Regulatory Commission Page 6 February 1, 2006 JEM:TLE:BAB Enclosure cc (Enclosures):

B. M. Aukland, POB 2C-BFN M. Bajestani, NAB 1A-C A. S. Bhatnagar, LP 6A-C J. C. Fornicola, LP 6A-C R. G. Jones, POB 2C-BFN R. F. Marks, Jr., PAB 1A-BFN G. W. Morris, LP 4G-C B. J. OGrady, PAB 1E-BFN K. W. Singer, LP 6A-C E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS, WT CA-K S:Lic/submit/subs/response U2 EMEB B 7.doc

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNITS 2 AND 3 DOCKET NOS. 50-260 AND 50-296 RESPONSE TO NRC REQUEST EMEB-B.7 FROM NRC ROUND 2 REQUESTS FOR ADDITIONAL INFORMATION RELATED TO TECHNICAL SPECIFICATIONS (TS) CHANGE NO. TS-418 - REQUEST FOR EXTENDED POWER UPRATE By letter dated June 25, 2004 (Reference 1), TVA submitted to the NRC license amendment application requesting authorization for Extended Power Uprate (EPU) operation for Browns Ferry Nuclear Plant (BFN) Units 2 and 3. TVA supplemented that application by letters dated February 23, 2005 (Reference 2), April 25, 2005 (Reference 3), and June 6, 2005 (Reference 4). By letter dated October 3, 2005 (Reference 5), the NRC Staff transmitted a request for additional information to support its review of the BFN Units 2 and 3 EPU application.

TVAs letter of December 19, 2005 (Reference 6), provided TVAs response to the NRC Staffs request for additional information. TVAs letter noted that the response to NRC Request EMEB-B.7 would be deferred, and that TVA would provide the complete request by February 1, 2006. This enclosure provides the response to NRC Request EMEB-B.7.

NRC Request EMEB-B.7 Section 10.4.3, Main Steam Line, Feedwater and Reactor Recirculation Piping Flow Induced Vibration Testing, of of the June 25, 2004, submittal discusses the plans for vibration monitoring during initial plant operation for the new EPU operating conditions. Discuss in more detail, the procedures for avoiding adverse flow effects during power escalation and after achieving EPU conditions, including specific hold points and duration, inspections, plant walkdowns, vibration data collection methods and locations, planned data evaluation, and decision criteria for reducing plant power level or initiating plant shutdown.

E-1

TVA Reply to EMEB-B.7 Piping and components in the Main Steam and Feedwater systems will experience flow increases due to EPU and, therefore, will be monitored for steady state vibration.

Steady state vibration monitoring for piping will follow the guidance of ASME Standards and Guides for Operation and Maintenance of Nuclear Power Plants OM-S/G Part 3 (OM-3).

Scope The scope of BFNs flow induced vibration (FIV) monitoring for EPU is as follows:

the Main steam lines from the outboard containment anchors to the High Pressure Turbine; the Feedwater lines from the three Feedwater Pumps to the High Pressure Heaters, then to the outboard containment anchors; and small bore piping attached to the Main Steam and Feedwater piping.

TVAs procedures for vibration monitoring will require monitoring, evaluating, and taking prompt action in response to potential adverse flow effects that may result from power uprate operation. These procedures will include:

Hold Points and Duration During a units initial power ascension to EPU, vibration data collection and analysis will be performed at power levels below the final, maximum extended power level.

Vibration data is typically collected at 50%, 75%, 100%,

105%, 110%, 115% and 120% of originally licensed thermal power (OLTP). The duration of the hold points will be determined by the time required to obtain the specified data, complete the evaluation, and obtain approval to proceed.

E-2

Inspections and Walkdowns Piping classified in OM-3 group 3 outside the drywell will be monitored visually by walkdown or cameras at each test plateau. If visual observation indicates significant vibration, the condition will be evaluated in more detail.

Data Collection Methods and Locations

a. PIPING INSIDE DRYWELL Main Steam and Feedwater piping inside the drywell will be monitored using accelerometers or linear voltage differential transformers (LVDTs) and recorded on a data acquisition system (DAS) located outside the drywell.

Monitoring locations are based on hydraulic and structural analyses which identified where significant displacements are expected to occur relative to other locations. Branch line locations connected to main line piping which are expected to experience vibration effects were identified by walkdown.

b. COMPONENTS INSIDE DRYWELL Components inside the drywell will be monitored using accelerometers and recorded on a DAS located outside the drywell. Locations are chosen based upon recent industry experience with component failures during EPU conditions and engineering judgment as to the susceptibility of the components. Currently, 1 Main Steam Isolation Valve (MSIV), 1 Main Steam drain valve, 2 main steam safety relief valves (SRVs), 1 HPCI steam valve, and 1 RCIC steam valve have been selected for monitoring and will be baselined during the upcoming Unit 3 operating cycle at CLTP.
c. PIPING OUTSIDE THE DRYWELL Main Steam piping from the outboard containment anchors to the high pressure turbine and Feedwater piping from the Feedwater Pumps to the High Pressure Heaters, and from the High Pressure Heaters to the outboard containment anchors will be monitored using remote sensors and DAS equipment or with hand held vibration monitors depending upon accessibility. Monitoring locations are based on hydraulic and structural analyses which identified where significant displacements are expected to occur relative to other locations. Branch line locations connected to main line piping which are expected to experience vibration effects were identified by walkdown.

E-3

Planned Data Evaluation Piping within the scope is classified into one of 3 groups defined in OM-3 depending upon the degree of rigor required to assess the affects of vibration. The effects prediction analysis, vibration data gathering, data analysis, and acceptance criteria for BFNs program are based on OM-3 requirements for the appropriate group. Testing procedures will contain criteria consistent with the appropriate OM-3 group. Data taken at each test plateau will be evaluated and compared to the acceptance criteria in the procedure prior to proceeding to the next power plateau.

Decision Criteria For Reducing Plant Power Level Or Initiating Plant Shutdown In the event that measured vibrations at a given power level exceed the acceptance criteria, an evaluation will be performed to disposition the test deficiency. If appropriate, the power level would be reduced to a level where vibration amplitudes were previously shown to be acceptable until the deficiency is corrected.

References:

1. TVA letter, T. E. Abney to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Proposed Technical Specifications (TS) Change TS-418 - Request for License Amendment Extended Power Uprate (EPU) Operation," dated June 25, 2004
2. TVA letter, T. E. Abney to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Response to NRCs Acceptance Review Letter and Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418

- Request for Extended Power Uprate Operation, (TAC Nos MC3743 and MC3744)," dated February 23, 2005

3. TVA letter, T. E. Abney to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2, and 3 - Response to NRC's Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418 - Request for Extended Power Uprate Operation (TAC Nos MC3743 and MC3744)," dated April 25, 2005
4. TVA letter, William D. Crouch to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Response to NRC's Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418 - Request For License Amendment - Extended Power Uprate (EPU) Operation (TAC Nos MC3743 and MC3744)," dated June 6, 2005 E-4
5. NRC letter, Eva A. Brown to TVA, "Browns Ferry Nuclear Plant, Units 2 and 3 - Request for Additional Information for Extended power Uprate (TS-431)(TAC NOs. MC3743 and MC3744)," dated October 3, 2005
6. TVA letter, Brian OGrady to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 2 and 3 - Response to NRC Round 2 Request for Additional Information Related to Technical Specifications (TS) Change No. TS-418 - Request For Extended Power Uprate Operation (TAC Nos. MC3743 and MC3744)," dated December 19, 2005 E-5
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