ML061160258
| ML061160258 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/21/2006 |
| From: | Yoira Diaz-Sanabria NRC/NRR/ADRO/DLR/RLRA |
| To: | |
| DIAZ-SANABRIA, Y /NRR/DLR/RLRA, 415-1594 | |
| Shared Package | |
| ML061160247 | List: |
| References | |
| NUREG-1843 S1 | |
| Download: ML061160258 (65) | |
Text
NUREG-1843 Supplement 1Safety Evaluation ReportRelated to the License Renewal of the Browns FerryNuclear Plant, Units 1, 2, and 3Supplement 1Docket Nos. 50-259, 50-260, and 50-296Tennessee Valley AuthorityU.S. Nuclear Regulatory CommissionOffice of Nuclear Reactor RegulationApril 2006 THIS PAGE IS INTENTIONALLY LEFT BLANK.
iiiABSTRACTThis document is a supplemental safety evaluation report (SSER) on the application for licenserenewal for the Browns Ferry Nuclear Plant (BFN), as filed by Tennessee Valley Authority (TVA or the applicant). By letter dated December 31, 2003, TVA submitted its application to the U.S.Nuclear Regulatory Commission (NRC or the Commission) for renewal of the BFN operatinglicenses for an additional 20 years. The NRC staff (the staff) issued a safety evaluation report(SER), dated January 12, 2006, which summarizes the results of its safety review of the renewal application for compliance with the requirements of Title 10, Part 54, of the Code ofFederal Regulations, (10 CFR Part 54), "Requirements for Renewal of Operating Licenses forNuclear Power Plants." During the 530 th full committee meeting of the Advisory Committee on Reactor Safeguards,March 9, 2006, the Committee reviewed the license renewal application (LRA) for BFN Units 1,2, and 3. The staff had closed the open items with a commitment to issue a supplemental safety evaluation report (SSER) that addresses the Committee's review comments on the SER.This SSER addresses the Committee's concerns and includes revisions and enhancements to the following aging management programs (AMPs): (1) Unit 1 Periodic Inspection Program (B.2.1.42), (2) ASME Section XI Subsection IWE Program (B.2.1.32), and (3) Open-Cycle Cooling Water System Program (B.2.1.17). This supplement also addresses the Committee's other concerns as documented in its final letter report dated March 23, 2006.
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1The numbering of the sections listed in this NUREG supplement is based on thenumbering of the corresponding chapters and sections in NUREG-1843.vTABLE OF CONTENTS 1Abstract.................................................................iiiTable of Contents...........................................................v Abbreviations.............................................................vi 1 Introduction and General Discussion........................................1-13 Aging Management Review Results.........................................3-13.0.3 Aging Management Programs...............................3-13.0.3.2 AMPs That Are Consistent with the GALL Report with Exceptions or Enhancements.........................3-13.0.3.3 AMPs That Are Not Consistent with or Not Addressed in theGALL Report .....................................3-73.3 Aging Management of Auxiliary Systems.............................3-143.3.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report...............................3-143.5 Aging Management of Containments, Structures, and Components Supports3-163.5.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report................................3-163.5.3 Conclusion.............................................3-183.8 Conclusion for Aging Management.................................3-185 Review by the Advisory Committee on Reactor Safeguards.......................5-16 Conclusions...........................................................6-1 Appendix A: Commitments for License Renewals................................A-1Appendix B: Chronology...................................................B-1Appendix C: Principal Contributors...........................................C-1 viABBREVIATIONSACIAmerican Concrete InstituteACRSAdvisory Committee on Reactor SafeguardsAHCaccess hole coverAMPaging management programAMRaging management reviewANSIAmerican National Standards InstituteASMEAmerican Society of Mechanical EngineersASTMAmerican Society for Testing and MaterialsATWSanticipated transient without scramBFNBrowns Ferry Nuclear PlantBWRboiling water reactorBWRVIPBoiling Water Reactor Vessel and Internals ProjectCCWcondensate circulating water CFRCode of Federal RegulationsCLBcurrent licensing basisCRDcontrol rod driveEECWemergency equipment cooling waterEPRIElectric Power Research InstituteEPUextended power uprateEQenvironmental qualificationFACflow-accelerated corrosion F enenvironmental fatigue life correction factorFERCFederal Energy Regulatory CommissionGALLGeneric Aging Lessons Learned ReportGLgeneric letterIGSCCintergranular stress corrosion crackingIRMintermediate range monitorISPIntegrated Surveillance ProgramLPRMlocal power range monitorLRAlicense renewal applicationLTOPlow temperature over-pressureMICmicrobiologically influenced corrosionNDEnondestructive examinationNRCU.S. Nuclear Regulatory CommissionNUREGNRC technical report designation (Nuclear Regulatory Commission)OCCWopen-cycle cooling waterRAIrequest for additional informationRHRSWresidual heat removal service water viiRPVreactor pressure vesselRPVIIreactor pressure vessel internals inspectionRWCUreactor water cleanupSCstructure and componentSERSafety Evaluation ReportSRP-LRStandard Review Plan for Review of License Renewal Applications for NuclearPower PlantsSRVsafety relief valveSSCsystem, structure, and componentSSERsupplemental safety evaluation reportTLAAtime-limited aging analysisTStechnical specificationTVATennessee Valley AuthorityUFSARupdated final safety analysis reportUTultrasonic testing THIS PAGE IS INTENTIONALLY LEFT BLANK.
1-1SECTION 1INTRODUCTION AND GENERAL DISCUSSIONThis document is a supplemental safety evaluation report (SSER) on the application for licenserenewal for the Browns Ferry Nuclear Plant (BFN), as filed by Tennessee Valley Authority (TVA or the applicant). By letter dated December 31, 2003, TVA submitted its application to the U.S.Nuclear Regulatory Commission (NRC or the Commission) for renewal of the BFN operatinglicenses for an additional 20 years. The NRC staff (the staff) issued a safety evaluation report(SER), dated January 12, 2006, which summarizes the results of its safety review of the renewal application for compliance with the requirements of Title 10, Part 54, of the Code ofFederal Regulations, (10 CFR Part 54), "Requirements for Renewal of Operating Licenses forNuclear Power Plants." During the 530 th full committee meeting of the Advisory Committee on Reactor Safeguards,March 9, 2006, the Committee reviewed the license renewal application (LRA) for BFN Units 1,2, and 3. The staff had closed the open items with a commitment to issue a supplemental safety evaluation report (SSER) that addresses the Committee's review comments on the SER.This SSER addresses the Committee's concerns and includes revisions and enhancements to the following aging management programs (AMPs): (1) Unit 1 Periodic Inspection Program (B.2.1.42), (2) ASME Section XI Subsection IWE Program (B.2.1.32), and (3) Open-Cycle Cooling Water System Program (B.2.1.17). This supplement also addresses the Committee's other concerns as documented in its final letter report dated March 23, 2006.
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3-1SECTION 3AGING MANAGEMENT REVIEW RESULTS3.0.3 Aging Management Programs3.0.3.2 AMPs That Are Consistent with the GALL Report with Exceptions orEnhancementsAs supplemented in LRA Appendix B, the applicant identified that the following agingmanagement programs (AMPs) were, or will be, consistent with the GALL Report, withadditional enhancements:
- Open-Cycle Cooling Water System Program (B.2.1.17)
- ASME Section XI Subsection IWE Program (B.2.1.32)
In its letter dated April 4, 2006, the applicant included additional supplemental information to theLRA for the above-mentioned programs that address the Advisory Committee on ReactorSafeguards (ACRS) concerns raised in the 530 th full committee meeting, as documented byletter dated March 23, 2006.3.0.3.2.11 Open-Cycle Cooling Water System Program Summary of Technical Information in the Application. The applicant's Open-Cycle CoolingWater (OCCW) System Program is described in LRA Section B.2.1.17, "Open-Cycle Cooling Water System Program." In the LRA, the applicant stated that this is an existing program. Thisprogram is consistent, with enhancement, with GALL AMP XI.M20, "Open-Cycle Cooling Water System."The OCCW System Program relies on implementation of the recommendations of GL 89-13 toensure that the effects of aging on the OCCW system will be managed for the extended periodof operation. The program includes surveillance and control techniques to manage agingeffects caused by biofouling, corrosion, erosion, protective coating failures, and silting in the OCCW system or structures and components servic ed by the OCCW system.During the 530 th full committee meeting of the ACRS, March 9, 2006, the committee reviewedthe LRA for BFN Units 1, 2, and 3. The staff had closed the open items with a commitment to issue a supplemental safety evaluation report (SSER) that would address an inspection concern on an open item on residual heat removal service water (RHRSW) system com ponent, RHRSWpump pit suction pipe (see SSER Section 3.3.2.3.3). The aging management review (AMR) of this component required an enhancement to the OCCWS Program (see previous safety evaluation report (SER), dated January 12, 2006, SER Section 3.0.3.2.11)In resolving the issue, by letter dated April 4, 2006, the applicant stated the following:In Enclosure 4 of a TVA letter to the NRC dated November 16, 2005 (ADAMS AccessionNo. ML053320331), TVA committed to perform a confirmatory inspection of the RHRSW 3-2pump pit supply piping, sluice gate valves and seismic restraints in the RHRSW pumppit prior to the period of extended operation. As discussed with the ACRS on March 9, 2006, BFN will perform an additional inspection within 10 years of entering the period ofextended operation.These additional inspections require changes to the Open-Cycle Cooling Water SystemProgram described in LRA Sections A.1.16 and B.2.1.17. The following is to be added to the end of LRA Section A.1.16:In addition to the requirements of GL 89-13, the Open-Cycle Cooling WaterSystem Program will be enhanced to perform inspections on the internal portionof one of the embedded RHRSW pipes that run between the CCW Pump Pits tothe EECW / RHRSW Pump Pits, the RHRSW sluice gate valves located in the CCW pump pits, and the seismic restraints in the RHRSW pump pits. Theseinspections will be performed prior to the expiration of the current 40-year license, and will be conducted at least one additional time within ten years ofentering the period of extended operation.The following is being added to the LRA Section B.2.1.17 Enhancements:In addition to the requirements of GL 89-13, the Open-Cycle Cooling WaterSystem Program will be enhanced to perform inspections on the internal portionof one of the embedded RHRSW pipes that run between the CCW Pump Pits tothe EECW / RHRSW Pump Pits, the RHRSW sluice gate valves located in the CCW pump pits, and the seismic restraints in the RHRSW pump pits. Theseinspections will be performed prior to the expiration of the current 40-year license, and will be conducted at least one additional time within ten years ofentering the period of extended operation.Program Elements Affected:Element 5 - Monitoring and Trending Inspection scope, method (e.g., visual or nondestructive examination [NDE]),and testing frequencies are in accordance with the utility commitments underNRC GL 89-13. Testing and inspections are done annually and during refuelingoutages. Inspections or nondestructive testing will determine the extent ofbiofouling, the condition of the surface coating, the magnitude of localized pitting,and the amount of MIC, if applicable. Heat transfer testing results are documented in plant test procedures and are trended and reviewed by the appropriate group.BFN Evaluation Element 5 requires that inspection scope, method (e.g., visual or nondestructiveexamination [NDE]), and testing frequencies are in accordance with the utilitycommitments under NRC GL 89-13. The inspections associated with thisenhancement are in addition to the BFN commitments under NRC GL 89-13.
3-3These inspections will provide additional assurance that there is no loss ofintended function of the Open-Cycle Cooling Water System.By letter dated November 16, 2005, the applicant committed to perform a confirmatoryinspection of the RHRSW pump pit supply piping, sluice gate valves, and seismic restraints inthe RHRSW pump pit prior to the period of extended operation. As discussed with the ACRS onMarch 9, 2006, the applicant will perform an additional inspection within 10 years of entering theperiod of extended operation. Staff Evaluation. The staff agrees with the applicant's evaluation and concludes that with theproposed enhancement, the staff found the OCCW System Program is consistent with GALL AMP XI.M20 and, therefore, acceptable. These additional inspections require changes to the OCCW System Program described in LRA Sections A.1.16 and B.2.1.17. This also closed theopen item from the AMP inspection.UFSAR Supplement. In LRA Section A.1.16, the applicant provided the UFSAR supplement forthe OCCW System Program. The staff reviewed this section and determined that the information, with the above revision to the UFSAR supplement provides an adequate summary description of the program. The staff found that this section of the UFSAR supplement, with revision, met the requirements of 10 CFR 54.21(d).Conclusion. On the basis of its review and audit of the applicant's program, the staff determinedthat those program elements for which the applicant claimed consistency with the GALL Reportare consistent with the GALL Report. In addition, the staff reviewed the enhancement andconfirmed that the implementation of the enhancement prior to the period of extended operationwould result in the existing AMP being consistent with the GALL Report AMP to which it was compared. The staff concluded that the applicant had demonstrated that the effects of agingwill be adequately managed so that the intended functions will be maintained consistent withthe current licensing basis (CLB) for the period of extended operation, as required by10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concluded that, with revision, it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).3.0.3.2.20 ASME Section XI Subsection IWE Program Summary of Technical Information in the Application. The applicant's ASME Code Section XISubsection IWE Program is described in LRA Section B.2.1.32, "ASME Section XI Subsection IWE Program." In the LRA, the applicant stated that this is an existing program. This program is consistent, with exceptions, with GALL AMP XI.S1, "ASME Section XI Subsection IWE."During the 530 th full committee meeting of the ACRS, March 9, 2006, the committee reviewedthe LRA for BFN Units 1, 2, and 3. The staff had closed the open items with a commitment to issue an SSER that will address a concern that the committee had raised on an open item ondrywell shell, specifically related to the aging management in the sand bed region. The AMR review of this component is discussed in the SER dated January 12, 2006, (see SER Section 3.5.2.3.1). In resolving the open item, by letter dated April 4, 2006, the applicantcommitted to perform an ultrasonic testing (UT) thickness measurement as an enhancement to the ASME Section XI Subsection IWE Program as follows.
3-4These additional periodic inspections in the sand bed region require changes to theASME Section XI Subsection IWE Program described in LRA Sections A.1.29 and
B.2.1.32.The following is to be added to the end of LRA Section A.1.29:The ASME Section XI Subsection IWE Program will be enhanced to requireultrasonic inspections of the Units 1, 2, and 3 drywell liner plate near the sand bed region. The first inspection on each unit will be performed prior to the periodof extended operation. Subsequent periodic inspections will be performed oneach unit at a period not to exceed 10 years. The results of these inspections willbe reviewed to ensure that the acceptance criteria of ASME Section XI Subsection IWE-3000 are met.The following is to be added to the LRA Section B.2.1.32 Enhancements (Note that allprogram elements were reviewed and only those affected by this enhancement are included in the following additions to Section B.2.1.32):The ASME Section XI Subsection IWE Program will be enhanced to requireultrasonic inspections of the Units 1, 2, and 3 drywell liner plate near the sand bed region. The first inspection on each unit will be performed prior to the periodof extended operation. Subsequent periodic inspections will be performed oneach unit at a period not to exceed 10 years. The results of these inspections willbe reviewed to ensure that the acceptance criteria of ASME Section XI Subsection IWE-3000 are met.Program Elements Affected:Element 4 - Detection of Aging Effects The frequency and scope of examination specified in 10 CFR 50.55a andSubsection IWE ensure that aging effects would be detected before they would compromise the design-basis requirements. As indicated in IWE-2400, inservice examinations and pressure tests are performed in accordance with one of two inspection programs, A or B, on a specified schedule. Under Inspection Program A, there are four inspection intervals (at 3, 10, 23, and 40 years) for which 100% of the required examinations must be completed. Within each interval, there are various inspection periods for which a certain percentage of the examinations are to be performed to reach 100% at the end of that interval. In addition, a general visual examination is performed once each inspection period. After 40 years of operation, any future examinations will be performed inaccordance with Inspection Program B. Under Inspection Program B, starting with the time the plant is placed into service, there is an initial inspection interval of 10 years and successive inspection intervals of 10 years each, during which 100% of the required examinations are to be completed. An expedited examination of containment is required by 10 CFR 50.55a in which an inservice (baseline) examination specified for the first period of the first inspection interval for containment is to be 3-5performed by September 9, 2001. Thereafter, subsequent examinationsare performed every 10 years from the baseline examination. Regarding the extent of examination, all accessible surfaces receive a visual examination such as General Visual, VT-1, or VT-3 (see table in item 3 above). IWE-1240 requires augmented examinations (Examination Category E-C) of containment surface areas subject to degradation. A VT-1 visual examination is performed for areas accessible from both sides, and volumetric (ultrasonic thickness measurement) examination is performed for areas accessible from only one side.BFN Evaluation Element 4 states 'The frequency and scope of examination specified in10 CFR 50.55a and Subsection IWE ensure that aging effects would be detected before they would compromise the design-basis requirements.'
The inspections associated with this enhancement are of the inaccessible area of the drywell shell liner plate and are in addition to the current BFN ASME Section XI, Subsection IWE procedural requirements. These inspections will provide additional assurance that there is no loss ofintended function of the drywell shell.Element 5 - Monitoring and Trending With the exception of inaccessible areas, all surfaces are monitored byvirtue of the examination requirements on a scheduled basis. When component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs, and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next inspection period, in accordance with Examination Category E-C. When these reexaminations reveal that the flaws, areas of degradation, or repairs remain essentially unchanged for three consecutive inspection periods, these areas no longer require augmented examination in accordance with Examination Category E-C.BFN Evaluation Element 5 states 'With the exception of inaccessible areas, all surfacesare monitored by virtue of the examination requirements on a scheduled basis.' The inspections associated with this enhancement are of the inaccessible area of the drywell shell liner plate and are in addition to the current BFN ASME Section XI, Subsection IWE procedural requirements.
These inspections will provide additional assurance that there is no lossof intended function of the drywell shell.Element 6 - Acceptance Criteria IWE-3000 provides acceptance standards for components of steelcontainments and liners of concrete containments. Table IWE-3410-1 3-6presents criteria to evaluate the acceptability of the containmentcomponents for service following the preservice examination and each inservice examination. This table specifies the acceptance standard for each examination category. Most of the acceptance standards rely on visual examinations. Areas that are suspect require an engineering evaluation or require correction by repair or replacement. For some examinations, numerical values are specified for the acceptance standards. For the containment steel shell or liner, material loss exceeding 10% of the nominal containment wall thickness, or material loss that is projected to exceed 10% of the nominal containment wall thickness before the next examination, are documented. Such areas are to be accepted by engineering evaluation or corrected by repair or replacement in accordance with IWE-3122.BFN Evaluation Element 6 states 'For the containment steel shell or liner, material lossexceeding 10% of the nominal containment wall thickness, or material loss that is projected to exceed 10% of the nominal containment wall thickness before the next examination, are documented. Such areas are to be accepted by engineering evaluation or corrected by repair or replacement in accordance with IWE-3122.' The acceptance criteria for the inspections associated with this enhancement will provide additionalassurance that the design minimum wall thickness is being maintained. If during the License Renewal examinations local areas of degradation are found, IWE-3122 provides the acceptance criteria. If either the thickness of the base metal in local areas is reduced by no more than 10% of the nominal plate thickness of the reduced thickness can be shown by engineering analysis to satisfy the requirements of the BFN Design Criteria, the component is acceptable by engineering evaluation.
Additionally, the noted degradation condition would be subject to the site Corrective Action Program.Staff Evaluation. As discussed in their letter dated March 23, 2006, the ACRS recommendedthat either the drywell refueling seals should be included within the scope of license renewal and be subjected to periodic inspections or the drywell shells should be subjected to periodic volumetric inspections to detect external corrosion. The applicant addressed the drywell refueling seals in followup to RAI 2.4-3 by letter dated May 31, 2005. The applicant's response to RAI 2.4-3 stated that the Browns Ferry refueling seals are not within the scope of licenserenewal. In addressing the ACRS's concern, the applicant chose to perform periodic ultrasonic inspections of the drywell shell in the area of the sand bed region. The sand bed region was chosen for inspection because it is the terminus for the drainage pathway for water that may enter the inaccessible area. By being a drainage pathway, it could be subjected to wetting and drying in the lower areas near the sand bed region which could result in corrosion of the shell.As discussed at the ACRS meeting, BFN will perform periodic UT of the Units 1, 2, and 3drywell in the area of the sand bed region. These UT thickness measurements will beperformed as an enhancement to the ASME Section XI Subsection IWE License Renewal Aging Management Program. BFN will perform the first inspection on each unit prior to the 3-7period of extended operation. Subsequent inspections will be performed on each unit at aninterval not to exceed 10 years. The results of these inspections will be reviewed to ensure thatthe acceptance criteria of ASME Section Subsection IWE-3000 are met during each inspection.
The staff evaluated the applicant's acceptance criteria for the inspections associated with thisenhancement which will provide additional assurance that the design minimum wall thicknesswill be maintained and found it acceptable. The staff also found that these enhancements willaddress the aging concerns that staff documented previously in the RAI 3.5-4 and the periodicinspection provides assurance that any degradation identified will be suitably addressed andmanaged. Staff considers this open issue adequately resolved.The applicant has also previously committed (Commitment # 46, BFN letter datedNovember 16, 2005) to perform supplementary inspections of the vertical portions of the drywell shell which were intended to provide the staff the necessary assurance that the potentialdegradation of the uninspectable side of the drywell will be monitored and managed. Theinspections of the drywell shell near the sand bed region are in addition to the inspections discussed in Enclosure 1 of the TVA letter to the NRC dated November 16, 2005. As discussedin this letter:For Unit 1, TVA will perform one time confirmatory ultrasonic thickness measurements on thevertical cylindrical area immediately below the drywell flange.For Units 2 and 3, TVA will perform one time confirmatory ultrasonic thickness measurementson a portion of the cylindrical section of the drywell in a region where liner plate is 0.75 inches thick (i.e. below the drywell head).UFSAR Supplement. In LRA Section A.1.29 and supplement, the applicant provided theUFSAR supplement for the ASME Code Section XI Subsection IWE Program. The staff reviewed this section and determined that the information in the UFSAR supplement with the above revisions to the UFSAR supplement provides an adequate summary description of the program. The staff found that this section of the UFSAR supplement, with revision, met the requirements of 10 CFR 54.21(d).Conclusion. On the basis of its review, RAI responses, and audit of the applicant's program, thestaff determined that those program elements for which the applicant claimed consistency withthe GALL Report are consistent with the GALL Report. In addition, the staff reviewed the exceptions and the associated justifications and determined that the AMP, with exceptions, isadequate to manage the aging effects for which it is credited. The staff concluded that theapplicant had demonstrated that the effects of aging will be adequately managed so that theintended functions will be maintained consistent with the CLB for the period of extendedoperation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concluded that, with revisions, it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).3.0.3.3 AMPs That Are Not Consistent with or Not Addressed in the GALL Report In its letter dated April 4, 2006, the applicant supplemented LRA Appendix B. The applicantidentified and added the following plant-specific AMP: Unit 1 Periodic Inspection Program (B.2.1.42) 3-8For AMPs that are not consistent with or not addressed by the GALL Report, the staffperformed a complete review of the AMPs to determine whether they were adequate to monitor or manage aging. The staff's review of these plant-specific AMPs is documented in the following section of this SSER.3.0.3.3.5 Unit 1 Periodic Inspection Program (B.2.1.42)
Summary of Technical Information in the Application. In the LRA, the applicant did not include adescription of the new, plant-specific AMP B.2.1.42, "Unit 1 Periodic Inspection Program."
During the course of the staff's AMR of Unit 1 systems in layup for the extended outage, it wasrealized that neither the GALL-recommended one-time inspection nor the Unit 1 restart inspection would be sufficient in itself to monitor the effects of any new degradation that might occur during the period of extended operation. This plant-specific program is designed to monitor the condition of and perform periodic inspections of components that were in layup and have been requalified without replacement.Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the informationincluded in AMP B.2.1.42 regarding the applicant's demonstration of the Unit 1 PeriodicInspection Program to ensure that the effects of aging will be adequately managed so that theintended functions will be maintained consistent with the CLB throughout the period of extendedoperation. The staff reviewed the Unit 1 Periodic Inspection Program against the AMP elements found inthe SRP-LR Section A.1.2.3 and Table A.1-1, and focused on how the program manages agingeffects through the effective incorporation of the 10 program elements (i.e., program scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience).The applicant indicated that the corrective actions, confirmation process, and administrativecontrols are part of the site-controlled quality assurance program. The staff's evaluation of the quality assurance program is discussed in SER Section 3.0.4. The remaining seven elements are discussed below.The program was initially submitted for review by the applicant's letter dated August 4, 2005.The staff review determined that the required information submitted was not entirely completeor consistent with the information identified in SRP-LR Section A.1.2.3. On September 2, 2005,in an informal communication (eight staff questions addressed below) and in a formal meeting summary dated October 31, 2005, the staff requested additional information to support its review. The program was initially revised and resubmitted by TVA letter dated November 16, 2005. Subsequently, by letters dated March 7 and April 4, 2006, the applicant submitted itsrevised Unit 1 Periodic Inspection Program to resolve staff comments and close out all remaining open items.In NRC Question 1 of the informal staff request of September 2, 2005, the staff requested theapplicant to review the entire SRP-LR Section A.1.2.3 and to include additional applicable information. In NRC Question 2 of the informal staff request of September 2, 2005, the staffalso identified a general concern that, in the description of the program, the use of the term "failures" is not appropriate for license renewal. In response, the applicant revised the term 3-9"failures" to read, "acceptable degradation." The applicant also revised the UFSARSection A.2.4 and the description of each element to include the information identified in SRP-LR Section A.1.2.3, as discussed below. (1)Scope of Program - In LRA Section B.2.1.42, the applicant stated that the programprovides periodic monitoring of the non-replaced piping/fittings that were not in service supporting operation of Units 2 and 3. 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 susceptible locations identified are those areas determined to have the highest potential for service-induced wear or latent aging effects. The staff found, in general, the scope of the program to be comprehensive and acceptable because it includes components that were subject to lay-up at locations most susceptible to degradation as a result of the extended outage. The applicant's response to Question 3of the informal staff request of September 2, 2005, by the revised letter dated November 16, 2005, did not include a detailed AMR table (Table 3) in a standard format.
The format should list system and components, and it should reference the newinspection program, "B.2.1.42 Unit 1 Periodic Inspection Program," as the AMP. The submitted format did not allow a staff review of specific combinations of components, materials, environments, and aging effects to be managed by the new Unit 1 Periodic Inspection Program. In addition, the applicant did not respond to NRC Question 3(b)concerning the number of sample locations. Instead, the applicant stated that its earlierresponse, dated May 18, 2005, in a table titled,"NDE Examinations Performed forOriginal Non-replaced Piping, (3 sheets)," had identified specific components, piping, and welds that will be included in the scope of this new program. The applicant statedthat the table included piping and welds in the RHRSW, fire protection, EECW, rawcooling water, control rod drive, core spray, feedwater, high pressure coolant injection, main steam, reactor core isolation cooling, residual heat removal, and reactor building closed cooling water systems. The staff accepts this list to satisfy the requirement of theprogram element "scope" in lieu of the detailed AMR table for purpose of this evaluation.
However, in a teleconference on December 7, 2005, the applicant agreed (by letter dated December 20, 2005) to revise the LRA AMR tables (Table 3) to add the newly identified piping and components that will be included in the scope of the program andto identify these in appropriate systems tables in a future revision. Also, the applicantagreed to review the adequacy of the number of sample locations on the basis of a 95/95 confidence level. By letter dated March 7, 2006, the applicant included a detaileddescription of the scope of the program and, by letter dated April 4, 2006, the applicantagain modified the scope of the program. The revised scope includes five common material and environment combinations and a comprehensive list of systems that werenot in service during the extended outage and are now subject to periodic inspections.
These systems include all systems that were subject to moisture as a result of layupconditions during the extended outage. The inspection locations will be selected fromnon-replaced piping that is in-scope for license renewal and will include areas wheredegradation would be expected as well as areas where degradation would not be expected.The staff confirmed that the scope of program element satisfies the criterion defined inSRP-LR Section A.1.2.3.1. The staff concluded that the program attribute is acceptable.
3-10 (2)Preventive Actions - In the initial preventive action program element, the applicantidentified the Unit 1 Periodic Inspection Program as a detection program. Programs are normally identified as condition monitoring, performance monitoring, or prevention and mitigation programs. In NRC Question 5 of the informal staff request of September 2,2005, the staff requested the applicant to clarify that the program is a conditionmonitoring program. In the revised LRA Section B.2.1.42, the applicant stated that theprogram is a condition monitoring program and, thus, there are no preventive actions.
The staff concurred with this assessment and does not identify the need for any preventive actions associated with this program.The staff confirmed that the preventive actions program element satisfies the criteriondefined in SRP-LR Section A.1.2.3.2. The staff concluded that the program attribute isacceptable. (3)Parameters Monitored or Inspected - In LRA Section B.2.1.42, the applicant clarifiedthat the Unit 1 Periodic Inspection Program is a condition monitoring program and only the first two items of the SRP-LR are applicable. The applicant identified that theselected sample will be examined by the same or equivalent methodology (UT thicknessfor piping and UT shear wave and surface exam for weld), as performed to determine acceptability of not replacing piping sections prior to restart. The applicant stated thatthe susceptible locations were those areas determined to have the highest potential forservice-induced wear or latent aging effects, which includes all types of corrosion. The applicant also identified that the inspection techniques utilized evaluate internalconditions and are sensitive to the presence of unacceptable conditions, including wear, erosion, and corrosion (including crevice corrosion), if present. In addition, the applicant initially identified that the sample selected for periodic inspection will be based on a90/90 confidence level consistent with the methodology identified in Electric Power Research Institute (EPRI) 107514. The staff was concerned that a 90/90 confidence level may not be appropriate and that EPRI 107514 had not been reviewed by the staff.
In NRC Question 4 of the informal staff request of September 2, 2005, the staffrequested the applicant to clarify whether application of EPRI 107514 represented anindustry consensus for selecting a sample on the basis of 90/90 criteria. The applicant was also requested to identify the sample size on the basis of 90/90 criteria versus 95/95 and to justify selecting a sample size on the basis of the 90/90 criteria versus the more restrictive 95/95 criteria. In its response, dated November 16, 2005, the applicant revised the sample size basis to reflect a confidence level of 95/95 and replaced the EPRI reference with "Elementary Statistical Analysis." TVA's letter dated April 4, 2006, clarified that the sample size for the 95/95 assurance criterion for the common materialand environment groupings will be based on NUREG-1575. The staff's review of theacceptability of the revised basis for the sample size is further discussed underElement 4. The staff found that the parameters monitored or inspected will providesymptomatic evidence of potential degradation and, therefore, are acceptable.The staff confirmed that the parameters monitored or inspected program elementsatisfies the criterion defined in SRP-LR Section A.1.2.3.3. The staff concluded that thisprogram attribute is acceptable. (4)Detection of Aging Effects - SRP-LR Section A.1.2.3.4 states that the applicant is toprovide justification, including codes and standards referenced, that the inspection 3-11technique and frequency are adequate to detect the aging effects before a loss ofstructure and component (SC) intended function. In the initial submittal of LRA Section B.2.1.42, the applicant did not identify any codes and standards. In NRCQuestion 6 of the informal staff request of September 2, 2005, the staff requested theapplicant to include additional information to demonstrate that the technique and frequency of future inspections is justified. In revised LRA Section B.2.1.42, in its submittal dated November 16, 2005, the applicant stated that the program is notcovered by industry codes or standards and the selected inspection methodologies are based on the inspections performed to determine whether components require replacement prior to restart. The applicant also stated that the examination techniquesutilized for the baseline inspection were ultrasonic thickness measurements for the piping and ultrasonic shear wave for welds. The applicant identified that the restart inspections can be used as a baseline and additional periodic inspections of sample locations will be performed after Unit 1 is returned to service and again within the first10 years of the period of extended operation. The ultrasonic thickness measurements used should be capable of detecting most forms of internal degradation of the piping caused by the extended outage. The staff was concerned that inspections may not beperformed to recognized codes and standards and that UT inspection may not be the best technique to detect certain types of corrosion. The staff believes that codes and standards such as ASME Section V and ASTM are appropriate references. Based on industry standards such as ASTM G46-94 and standard practices identified in EPRI documents and the GALL Report, visual inspections may be a more appropriate technique to identify certain types of internal degradation, such as pitting and MIC.
Therefore, the applicant was requested to identify specific codes and standards used for periodic inspections and evaluate the acceptability of UT alone to detect all forms ofcorrosion. In a teleconference with the applicant on December 7, 2005 (as referenced in the applicant submittal dated December 20, 2005) the applicant indicated that internalvisual inspections are performed as part of other aging management programs when
the system is open, but UT is preferred for periodic inspection trending purposes, sinceopportunistic internal inspections are limited by accessibility. By letter dated March 7,2006, the applicant clarified that the selected sample will be examined by UT thicknessfor piping and welds not covered by ASME Section XI, and the program has been revised to select inspection locations from areas where degradation would be expected as well as areas where degradation would not be expected. The applicant stated that ifunacceptable degradation is detected in any sample location, the unacceptabledegradation will be evaluated and dispositioned using the Corrective Action Program.The staff found a combination of opportunistic internal visual inspections combined with periodic UT inspections to be an acceptable technique to detect latent aging effects. In regard to the basis for the sample size addressed in the SRP-LR "detection of agingeffects" element, the applicant described the sample size basis under Element 3, "parameters monitored or inspected.
" The applicant applied a statistical analysis toestablish a confidence level of 95/95 for selecting a sample size within a common material and environment. In SER Section A.2.4, submitted by letter dated October 19, 2005, the applicant stated that if unacceptable degradation is identified, the sample sizewill be appropriately expanded. Although the applicant did not respond to staff's requestin NRC Question 3(b) concerning the number of sample locations (scope) to beinspected, the applicant did adequately identify the basis for the sample size. Thenumber of sample locations was subsequently identified in TVA draft letter dated 3-12March 7, 2006. The applicant clarified that the sample size will be based onNUREG-1475, with a minimum sample size of 59 locations for each material andenvironmental combination. In the event any inspection location fails the acceptancecriterion, the entire material and environment combination sampled is considered suspect and the unacceptable degradation must be evaluated and dispositioned using the Corrective Action Program.The staff concurred that application of periodic internal visuals from other programs,combined with ultrasonic inspections from the periodic inspection program, are acceptable to detect potential aging effects that may have occurred as the result of theextended outage. Frequency of inspections is addressed under Element 5, below.The staff found that the 95/95 confidence level is an acceptable basis for determining anadequate sample size and that, in the event unacceptable degradation is detected, aprovision to expand the sample size by considering all common material and environment combinations as suspect is consistent with NUREG-1475, industry practice,and SRP-LR Section A.1.2.3.4. The staff concluded that this program attribute isacceptable. (5)Monitoring and Trending - In the initial submittal of LRA Section B.2.1.42, the applicantdid not identify whether results will be monitored and trended. In NRC Question 7 of theinformal staff request of September 2, 2005, the staff requested the applicant to clarifythat results will be monitored and trended. In its response, the applicant confirmed thatthe program has been revised to clarify the requirement to monitor and trend the results of periodic inspections. In revised LRA Section B.2.1.42, the applicant stated that theinspection frequency is re-evaluated each time the inspection is performed and can be changed based on the trend of the results. SRP-LR Section A.1.2.3.5 states that plant-specific and/or industry-wide operating experience may be considered in evaluating the appropriateness of the technique and frequency. The applicant credits lessons learned from the Units 2 and 3 restart experience, and TVA draft letter dated March 7, 2006, clarified that the baseline inspections will be performed on the selected sample locations prior to restart. The first periodic inspection will be performed after Unit 1 is retur ned tooperation, but prior to the end of the current operating period, and the second periodicinspection of all sample locations will be completed within the first 10 years of the period of extended operation. The applicant further clarified that, to ensure accurate and repeatable baseline values are available, sample locations will be identified on controlleddrawings contained in the technical instruction for the Unit 1 Periodic Inspection Program. The staff found that the overall monitoring and trending proposed by the applicant is acceptable because there is reasonable assurance that effective periodic inspections at the frequency identified combined with the Corrective Action Program willeffectively manage the applicable aging effects.The staff confirmed that the monitoring and trending program element satisfies thecriterion defined in SRP-LR Section A.1.2.3.5. The staff concluded that this programattribute is acceptable. (6)Acceptance Criteria - In LRA Section B.2.1.42, revised by letter dated March 7, 2006,the applicant stated that the acceptance criteria is that the pipe wall will remain aboveminimum acceptable wall thickness until the next periodic inspection. The staff found the 3-13application of minimum wall thickness based on the Code of record to be reasonableand appropriate acceptance criteria to maintain the intended functions of the components inspected.The staff confirmed that the acceptance criteria program element satisfies the criteriondefined in SRP-LR Section A.1.2.3.6. The staff concluded that this program attribute isacceptable. (10)Operating Experience - In NRC Question 8 of the informal staff request of September 2,2005, the staff requested the applicant to identify a commitment to provide (or haveavailable for review) operating experience for this new program in the future to confirm its effectiveness. The applicant's response confirmed that the program has been revised to clarify the requirement to evaluate the results of the periodic inspections to verify program effectiveness. In the revised version of LRA Section B.2.1.42, the applicant stated that the Unit 1 Periodic Inspection Program is a new program that will monitor the operating conditions of Unit 1 components that were not replaced during the Unit 1 restart. The applicant credits the trending data developed in Element 5 to demonstrate the effectiveness of the Unit 1 Periodic Inspection Program. The staff found that there is reasonable assurance that the use of trending data will provide objective evidence todetermine the effectiveness of the periodic inspection program.The staff confirmed that the operating experience program element satisfies the criteriondefined in SRP-LR Section A.1.2.3.10. The staff concluded that this program attribute isacceptable.UFSAR Supplement. By letter dated March 7, 2006, the applicant provided the following revisedUFSAR supplement for the Unit 1 Periodic Inspection Program:A.2.4 Unit 1 Periodic Inspection Program The Unit 1 Periodic Inspection Program is a new program that performs periodicinspections of the non-replaced piping/fittings that were not in service supporting operation of Units 2 and 3 following the extended Unit 1 outage to verify that no latentaging effects are occurring, and to correct degraded conditions prior to loss of function.The piping in the program is carbon/low-alloy or stainless steel that: 1) was exposed toair, treated water or raw water during the extended Unit 1 shutdown; and 2) will beexposed to treated water or raw water during normal operation. The inspection locations will be selected from non-replaced piping which is within the scope of license renewal and will include areas where degradation would be expected as well as areas wheredegradation would not be expected. The sample selected for periodic inspection will bebased on a 95/95 confidence level on a common material and environment bases. The sample size for the 95/95 assurance criterion for the common material and environment groupings will be based on NUREG-1475 as described in Chapter 21 which is based ona large or infinite lot size.The initial sample, once selected, will be utilized in subsequent inspections. The initialbaseline inspection of the sample locations will be performed prior to restart. The first Unit 1 periodic inspection of all sample locations will be performed after Unit 1 is 3-14returned to operation but prior to the end of the current operating period. The secondperiodic inspection of all sample locations will be completed within the first 10 years of the period of extended operation. 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 the trend of the results provides a basis to discontinue theinspections. However, as a minimum, periodic inspections of all selected sample locations must be performed: 1) after Unit 1 is returned to operation but prior to the end of the current operating period; and 2) within the first 10 years of the period of extendedoperation.The inspection techniques utilized evaluate internal conditions that are sensitive to thepresence of unacceptable conditions including wear, erosion, and corrosion (including crevice corrosion) if present. If unacceptable degradation is detected in any sample location, the unacceptable degradation will be evaluated and dispositioned using theCorrective Action Program.The staff reviewed the above UFSAR supplement and determined that it provides an adequatesummary description of the program. The staff found that this section of the UFSAR supplement met the requirements of 10 CFR 54.21(d).Conclusion. On the basis of its review of the applicant's program, the staff found that the Unit 1Periodic Inspection Program adequately addresses the 10 program elements identified in Appendix A of the SRP-LR, and that the program can adequately manage the aging effects forwhich it is credited. The staff also reviewed the UFSAR supplement for this AMP and found that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d). The following two AMR review items are presented in this SSER for background information onissues that were raised in the ACRS full committee meeting dated March 9, 2006, because ofwhich the enhancements to the two foregoing AMPs resulted. The following sections revise the previous staff evaluations found in the final SER dated January 12, 2006.3.3 Aging Management of Auxiliary Systems3.3.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.3.2.3.3 Residual Heat Removal Service Water System - Summary of Aging ManagementEvaluation - Table 3.3.2.3Inspection of Residual Heat Removal Service Water (RHRSW) Piping. The staff reviewed LRATable 3.3.2.3, which summarizes the results of AMR evaluations for the RHRSW system component groups. This item originated from regional AMP inspections conducted during December 2004 and a followup inspection September 2005, related to the RHRSW pump pitsuction pipes. As part of its review of the LRA, the staff, by letter dated October 31, 2005, requestedsupplemental information needed to address four open items included in the ACRS interim evaluation of BFN's LRA and the staff's draft SER. This supplemental response to the staff's request concerns the open item from AMP inspection of RHRSW piping. The AMP inspection is 3-15documented by staff letter to the applicant dated November 7, 2005, "Browns Ferry NuclearPlant - Inspection Repor t 05000259/2005013, 05000260/2005013, and 05000296/2005013."In its response, by letter dated November 16, 2005 the applicant stated:The Residual Heat Removal Service Water (RHRSW) pump pit supplies waterfor both the RHRSW system and the Emergency Equipment Cooling Water(EECW) system. The RHRSW pump pit takes suction from three 24" cast iron pipes that are encased in concrete. These pipes are coated internally with cement. Each of the three 40 foot long pipes has a tee on the upstream end which receives raw cooling water from two Condenser Circulating Water (CCW) pump pits via sluice gate valves located in the CCW pump pits. There are six sluice gates with two for each of the three encased pipes. The three RHRSW inlet pipes are included in the BFN Open Cycle CoolingWater (OCCW) program. The inlets of these pipes are the injection point for corrosion inhibitors and biocides that are used to maintain the EECW System.
The chemicals being injected at the inlet of these pipes are used to treat the other components in the OCCW system, including those components located inthe RHRSW pump pits. These pipes receive the largest concentration of chemicals. The sluice gate utilizes a local manual closure mechanism. The function of the sluicegate valves is to allow isolation of the encased pipe for RHRSW pump pit or CCW pump pit maintenance. The sluice gate has no active safety function other than remaining open to provide a flow path. The previously discussed raw water chemical treatment system [System No. 23] injects chemicals or biocides immediately upstream of the sluice gates. The treated water immediately enters the throat of the valve and proceedson to the imbedded piping. Substantial chemical treatment does not come into contactwith the external portion of the sluice gate or its operator. Four of the six valves have been replaced in the past. The remaining two valves are scheduled to be replaced in January 2006. As part of the License Renewal Process, an NRC inspection of Aging ManagementPrograms (AMPs) was performed at Browns Ferry during the week of December 13, 2004. During this inspection, TVA indicated that a one time inspection of the external surfaces of the OCCW piping that is exposed to raw water would be performed. It was later determined that the external surface of the RHRSW pump pit inlet piping isencased in concrete and is not accessible for inspection. TVA did not specify an internal inspection for license renewal because the aging of the pipe internals is managed by compliance with the requirements of Generic Letter 89-13 which is consistent with requirements of NUREG 1801 for Aging Management Programs (AMPs) for Open CycleCooling Water Systems. In a follow-up NRC AMP inspection during the week of September 19, 2005, TVA was informed that the staff's expectation was that aninspection be performed on the internal surfaces of the subject pipe.Based on additional discussions with the NRC, BFN will perform the followingthree actions:
3-16 (1)Perform a confirmatory inspection of the RHRSW pump pit supply piping usingunderwater cameras or other methods or techniques available at the time of the inspection. The inspection will include internal portions of one RHRSW pump pitsupply pipe, and to the extent possible, will identify flow restrictions and materialloss due to corrosion. The inspection will be performed from either the CCWpump pit or the RHRSW Pump Pit end of the pipe. This inspection will beperformed prior to the period of extended operation. (2)BFN will include instructions in the CCW pump pit Preventive MaintenanceProgram to periodically inspect the sluice gate valves. This will be completed prior to the period of extended operation. (3)BFN will perform a confirmatory inspection of the seismic restraints in theRHRSW pump pit. This inspection will be performed prior to the period of extended operation.These confirmatory inspection items are incorporated into the Open Cycle Cooling WaterSystem Program, as an enhancement to the previously approved staff evaluation. The enhancement is shown in SSER Section 3.0.3.2.11.The staff concluded that with the proposed inspection the component will continue to fulfill itsintended function (i.e., no pipe blockage) and the proposed enhancement to the OCCWS Program is acceptable.3.5 Aging Management of Containments, Structures, and Components Supports3.5.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.5.2.3.1 Primary Containment Structures - Summary of Aging Management Evaluation -Table 3.5.2.1 - Drywell Liner plate inspection in the sand pocket regionsThe staff reviewed this AMR item previously in RAI 3.5-4 dated December 10, 2004, wasdocumented previously in the final SER issued on January 12, 2006 (see SER Section 3.5.2.3.1). UT thickness measurements of the sand pocket area that were obtainedduring the U2C10 and U3C8 refueling outages for Units 2 and 3, respectively; and in 1999 and 2002 for Unit 1 (0-TI-376 Appendix 9.7, page 4), indicated that the condition of the drywell steelliner plate in this area meets code requirements, and that this area should not be categorizedfor augmented examination. In that previous evaluation the staff, in concluding, stated:Based on the detailed response, the staff found that the applicant has in place detailedprocedures for examining the concrete and steel components inside the drywell, and systematic acceptance criteria. Since the applicant plans to continue this process duringthe extended period of operation and therefore, the staff found the applicant's processof detecting degradation of these components adequate and acceptable, and the staff'sconcern described in RAI 3.5-4 is resolved. However, when the ACRS questioned the applicant on March 9, 2006, as to the details of therecent inspections, the applicant provided details of the UT inspections that were conductedduring these outages for Units 1, 2, and 3 and earlier in 1997 and 1999. The staff found these 3-17details of particular interest for Unit 1. Staff pursued the inquiry, especially an indicationidentified in a UT inspection conducted in 1997 in Unit 1. In responding to this ACRS concern, the applicant, in its submittal dated April 4, 2006, stated:UNIT 1 DRYWELL SHELL INSPECTION RESULTS Inspections of the Unit 1 drywell liner plate in the area of the sand bed region wereperformed in 1987, 1997, 1999, 2002, and 2004. Six areas of the drywell liner plate wereultrasonically (UT) inspected for each of the noted years. Each of the areas is 7" long circumferentially and 5" wide vertically. Each area starts immediately above the concrete floor at elevation 549.92'. Each area is divided into a 6" long by 4" rectangle divided into 1" by 1" grid squares and identified physically using low stress stamps by the letters "A" thru "X" (144 total locations). An inclusion was initially detected at Area #2 grid "I", in the 1999 inspection. An inclusion is particles of nonmetallic material usually oxides,sulphides, silicates, and such which are entrapped mechanically or are formed duringsolidification or by subsequent reaction within the solid metal. The following table provides the minimum and maximum thickness measured ultrasonically at the Area #2 grid "I" for each inspection:
YearMaximum(inch)Minimum(inch)19871.1461.080 19971.1261.106 19991.1361.110 20021.1421.113 20041.1461.114[Note: Inspection results are available on site for review.]The nominal wall thickness is 1.125" for this area of the drywell liner plate. The ASMECode derived tolerance is 10% of nominal wall thickness which yields a minimum of 1.0125". Any readings below 1.0125" require documenting per the site corrective program and an engineering evaluation. As can be seen, all of the measurements are above the minimum criteria and indicate no trend in wall loss.In performing the ultrasonic inspection of this area, the inclusion was noted at a depth of0.766". There was minimum loss of back wall signal with an associated signal at 0.766" depth and no appreciable length (one half of a transducer diameter; transducer diameter is 3/8"), confirming the inclusion is small and sub-surface. Subsequent inspections revealed no measurable difference in the depth / size of the inclusion and no change in the thickness in the liner in this area. The inspection results were reviewed by a Level 3 inspector and found to be non-recordable in accordance with ASME/ASTM Specification SA 516. The inclusion was noted in the inspection results as an aid to inspectors performing future inspections of the area. The presence of the inclusion does not affect 5-1the strength of the drywell containment shell, and since it does not connect to thesurface of the liner plate, it does not represent a site for future corrosion. No additional component, material, environment, or program was brought into scope as a result of this inclusion.On March 9, 2006, the applicant also met with the ACRS and the NRC staff and confirmed thedetails of these inspections. Because of the previous operational history of the drywell shell in the sandbed region the applicant agreed and the staff concurs, that proposed revision wouldadequately supplement the AMP on ASME Section XI Subsection IWE Program in managing the component. Also, after evaluating the data provided and documented in TVA submittal dated April 4, 2006, the staff concluded that the presence of the inclusion does not affect thestrength of the drywell containment shell and as it does not connect to other corroded areas, it does not represent a site for future corrosion. The revised commitment to perform periodic UT examinations of the drywell shell in the sand-pocket areas, is shown as an augmentation to the previously approved staff evaluation of the ASME Section XI Subsection IWE Program. The enhancement is described in SSER Section 3.0.3.2.20. Therefore, the staff considers the openissue resolved. 3.5.3 Conclusion The staff concluded that the applicant provided sufficient information to demonstrate that theeffects of aging of the containments, structures, and component supports components that arewithin the scope of license renewal and subject to an AMR will be adequately managed so thatthe intended function(s) will be maintained consistent with the CLB for the period of extendedoperation, as required by 10 CFR 54.21(a)(3).The staff also reviewed the applicable UFSAR supplement program summaries and concludedthat they adequately describe the AMPs credited for managing aging of the containments,structures, and component supports, as required by 10 CFR 54.21(d).3.8 Conclusion for Aging ManagementThe staff reviewed the information in LRA Section 3, "Aging Management Review Results," and Appendix B, "Aging Management Programs and Activities." On the basis of its review of the AMR results and AMPs, the staff concluded that the applicant had demonstrated that the agingeffects will be adequately managed so that the intended functions will be maintained consistentwith the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staffalso reviewed the applicable UFSAR supplement program summaries and concluded that the UFSAR supplement adequately describes the AMPs credited for managing aging as required by 10 CFR 54.21(d).With regard to these matters, the staff concluded that there is reasonable assurance that theactivities authorized by the renewed license will continue to be conducted in accordance withthe CLB, and that any changes made to the BFN CLB in order to comply with 10 CFR 54.21(a)(3) are in accord with the Atomic Energy Act of 1954, as amended, and NRC regulations.SECTION 5 5-2REVIEW BY THE ADVISORY COMMITTEE ON REACTORSAFEGUARDSThe NRC staff issued its safety evaluation report (SER) with open items related to the renewalof operating licenses for Browns Ferry Nuclear Plant, Units 1, 2, and 3 on August 9, 2005. On October 5-6, 2005, the applicant presented its license renewal application, and the staffpresented its review findings to the Advisory Committee on Reactor Safeguards (ACRS) Plant License Renewal Subcommittee and Full Committee. The staff reviewed the applicant's comments on the SER and completed its review of the license renewal application. The staff'sevaluation is documented in an SER that was issued by letter dated January 12, 2006.During the 530 th meeting of the ACRS, March 9, 2006, the ACRS completed its review of theBFN license renewal application and the NRC staff's SER. The ACRS documented its findingsin a letter to the Commission dated March 23, 2006. This supplement addresses the committee's concern as documented in the previous sections. A copy of this letter is provided on the following pages of this SSER section.
5-3THIS PAGE INTENTIONALLY LEFT BLANK 5-4ACRSR-2180March 23, 2006The Honorable Nils J. DiazChairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
REPORT ON THE SAFETY ASPECTS OF THE LICENSE RENEWALAPPLICATION FOR THE BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3
Dear Chairman Diaz:
During the 530 th meeting of the Advisory Committee on Reactor Safeguards, March 9-11,2006, we completed our review of the license renewal application (LRA) for the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 and the associated final Safety Evaluation Report (SER) prepared by the NRC staff. On August 23, 2005, we visited the Browns Ferry site and reviewedactivities under way for license renewal, power uprate, and restart. Our Plant Operations and Plant License Renewal Subcommittees also reviewed these matters on September 21, 2005. Our Plant License Renewal Subcommittee reviewed the LRA and SER with Open Items on October 5, 2005. We issued an interim letter on the safety aspects of this application on October 19, 2005. During our reviews, we had the benefit of discussions with representatives of the NRC staff, including Region II personnel, and the Tennessee Valley Authority (TVA). Wealso had the benefit of the documents referenced. This report fulfills the requirements of10 CFR 54.25 that the ACRS review and report on all license renewal applications.CONCLUSIONS AND RECOMMENDATIONS 1.With the inclusion of the conditions in Recommendations 2 and 3, the application forlicense renewal for BFN Units 1, 2, and 3 should be approved.2.The drywell refueling seals should be included within the scope of license renewal andbe subjected to periodic inspections. Alternatively, as proposed by the staff, the drywell shells should be subjected to periodic volumetric inspections to detect external corrosion.3.If the extended power uprate (EPU) is implemented before the period of extendedoperation, the staff should require that TVA evaluate the operating experience ofUnits 1, 2, and 3 at the uprated power level and then incorporate lessons learned intotheir aging management programs prior to entering the period of extended operation.DISCUSSION TVA requested renewal of the BFN Units 1, 2, and 3 operating licenses for 20 years beyondtheir current operating terms, which expire on December 10, 2013, June 28, 2014, and July 2,2016, respectively.
5-5The BFN site is located in Limestone County, Alabama on the north shore of the WheelerReservoir. All three BFN units are General Electric boiling water reactors (BWR 4) with Mark 1containments. Units 1 and 2 commenced operation in 1973 and 1974 respectively and were both shut down after the March 22, 1975 fire in Unit 1. Both units were returned to service in 1976, the same year Unit 3 commenced operation. All three units operated until 1985, whenthey were shut down to address management, technical, and regulatory issues. Units 2 and 3 were restarted in 1991 and 1995 respectively and have been in operation since then. Unit 1 has been shut down since 1985 and TVA plans to restart it in May 2007. The approximate duration of power operation of the three units is 10 years for Unit 1, 23 years for Unit 2, and 18 years for Unit 3. As part of an extensive restart program for Unit 1, components that have been in "layup" for the past 20 years will be either replaced or requalified. Layup is intended toprovide a controlled environment to limit corrosion of plant components. BFN Unit 1 is currently not identical to Units 2 and 3. TVA has committed to implement all ofthe physical and programmatic improvements to Unit 1 that have been made to Units 2 and 3.
By the time of restart, the Unit 1 licensing basis will be identical to that of the other two units. The three units will have nearly identical components, materials, environments, operatingprocedures, and technical specifications. The Corrective Action Program applies to all three units, so that any condition identified in one unit will be reviewed for generic implications to theother units. The applicant states that, because all three units contain the same materials and have experienced the same conditions, the aging mechanisms during the layup and recovery periods are similar among the three units. Since the aging effects of the Unit 1 shutdown are similar to those experienced in Units 2 and 3, the applicant has used operating experience from the restart of Units 2 and 3 in the recovery of Unit 1. Based on these considerations, TVA has submitted a common license renewal application for all three units.In part because it is not clear to what extent the layup experience of Units 2 and 3 parallels theexperience of Unit 1, in our interim report we questioned the extent of applicability of Units 2and 3 operating experience to the unique operating history of Unit 1. The SER states that a 1987 NRC inspection report identified several instances of deficient layup conditions during theearly phase of the extended outage. This raises the possibility of potential latent effects thatcould result in accelerated aging once the plant restarts and operates at power. The applicant acknowledges this concern by stating on page B-4 of the LRA that "During the performance of the Aging Management Review activities, there was recognition that the operating experienceof Unit 1 may not be the same as the operating experience on Units 2 and 3 due to the layup program implemented on Unit 1 during its extended outage." In response to this concern, TVA added the Unit 1 Periodic Inspection Program to those agingmanagement programs described in the LRA. Although this inspection program has not been fully defined, significant attributes of this program have been provided to the staff and are discussed in the final SER. This program requires periodic inspections of those components in layup that will not be replaced before restart. The scope of this program covers carbon steel,low-alloy steel, and stainless steel pipes and fittings from 25 plant systems. Samples aregrouped by common material types and environments. The applicant has agreed to use an inspection sampling size that would reflect a 95/95confidence level that unacceptable degradation can be detected. Inspections will be performedat susceptible locations and in areas where degradation is not expected. Baseline inspections will be performed before restart. Additional inspections will be performed after Unit 1 is 5-6restarted and again within the first ten years of the period of extended operation. Theinspection frequency will depend on the results of each inspection. The acceptance criteria arethat the pipe wall remains above the minimum acceptable thickness until the next inspectionand no unacceptable weld cracks exist. We concur with the staff's conclusion that this program will adequately manage the aging effects for which it is credited.In the original BFN LRA, the applicant requested renewed licenses at EPU conditions for allthree units. In a letter dated January 7, 2005, TVA requested that the EPU and the LRA beseparated. Even though the staff reviewed the LRA based on current licensed power levels foreach unit, the final SER has several references to EPU conditions. The steam dryers are included in the scope of license renewal, but their aging management review will be performedas part of the safety evaluation of the EPU application. The time-limited aging analyses (TLAAs) associated with neutron embrittlement, reactor vessel fatigue, radiation degradation of drywell expansion gap foam, and stress relaxation of the core plate hold-down bolts were performed assuming EPU conditions. In the final SER, the staff documents its review of the license renewal application and otherinformation submitted by TVA and obtained through the audits and inspections conducted at the plant site. The staff reviewed the completeness of the applicant's identification of structures,systems, and components (SSCs) that are within the scope of license renewal; the integratedplant assessment process; the applicant's identification of the plausible aging mechanismsassociated with passive, long-lived components; the adequacy of the applicant's aging management programs (AMPs); and the identification and assessment of TLAAs requiring review.The BFN application either demonstrates consistency of aging management programs with theGeneric Aging Lessons Learned (GALL) Report or documents deviations from the approaches specified in the GALL Report. The staff reviewed this application in accordance with NUREG-1800, the Standard Review Plan for Review of License Renewal Applications forNuclear Power Plants. The staff also performed inspections and an audit of AMPs and aging management reviews(AMRs). A recent inspection found that the applicant had made significant progress in developing the AMP implementation packages but identified errors in them. The applicant initiated a Problem Evaluation Report to identify the causes of the errors and determine corrective actions to prevent recurrence. Inspections performed before BFN enters the period of extended operation should verify that implemented corrective actions have been effective. The audit of the AMPs and AMRs is documented in a report by the Brookhaven NationalLaboratory. The audit examined 28 AMPs and the associated AMRs and verified that the AMPs are consistent with the GALL Report or concluded that they would adequately manage agingduring the period of extended operation. Several of the existing AMPs will be enhanced toinclude Unit 1 prior to the period of extended operation. Appendix F of the LRA describes TVA
's plan to resolve the differences between the licensing bases of Unit 1 and Units 2 and 3 before Unit 1 restart. The staff's review of Appendix F did not identify any omissions or discrepancies. The staff concluded that the scoping and screening processes implemented by the applicanthave successfully identified SSCs within the scope of license renewal and subject to an AMR.
5-7With the inclusion in the scope of license renewal of those Unit 1 systems and components thatwere in layup and have not been replaced, we agree with this conclusion. Open Item 2.4-3 in the SER concerns aging management of drywell shell corrosion. The staffwas concerned that leakage through refueling seals at the top of the drywell could lead tocorrosion of the drywell shell in a location that cannot be inspected. This aging effect has been observed in several Mark I containments and is the subject of Generic Letter 87-05 and Information Notice 86-99 on the potential for corrosion of BWR Mark I steel drywells in the sandpocket region. The staff has concluded that the refueling seals should be within the scope of license renewal because they are nonsafety-related components whose failure can affect the integrity of the safety-related containment steel liner. We concur with this conclusion.The applicant acknowledges that water was observed below the refueling seals at BFN Unit 3during the 1998 refueling outage, but maintains that the refueling seals should not be within thescope of license renewal. As an alternative to the inclusion of the seals, the staff proposed that TVA periodically perform ultrasonic testing of the drywell shells as part of the containment inservice inspection program. Such an approach has been used by previous license renewal applicants, and we agree that it is an acceptable alternative. As an alternative to the staff'sproposal, the applicant committed to perform a one-time confirmatory inspection of the Unit 1 drywell shell prior to restart and of the Units 2 and 3 shells prior to entering the period of extended operation. Based on this commitment, the staff closed out this open item. We do not agree with this resolution. One-time inspections are intended to confirm that an unexpected aging effect is not occurring or is occurring at such a slow rate that no further inspections are required. This aging effect has been observed in several Mark I containments, and we are aware of at least one instance of through-wall corrosion. One-time inspection of the shell does not provide assurance that leakage of the refueling seals after the one-time inspection is performed will not create an environment that could result in future drywell degradation. Unlessthe applicant can demonstrate that the resulting corrosion rate would not be sufficient todegrade the pressure retaining function during the period of extended operation, the refuelingseals should be within the scope of license renewal and subject to periodic inspections, or the drywell shells should be subjected to periodic volumetric inspections.During our March 9, 2006 meeting, we were told that the staff has reopened this item based ondiscussions with the applicant regarding drywell inspection results. Ultrasonic inspections performed in 1999, 2002, and 2004 identified a small inclusion in the drywell liner of Unit 1. The applicant will submit this information to the staff in writing. The staff plans to document its evaluation of this information in a supplemental SER. Based on our discussions with the applicant and staff, the resolution of this issue does not affect our recommendations regarding this LRA. In our interim letter we noted that in the draft SER some restart inspections were referred to as"one-time" inspections. We suggested that, to avoid confusion, the term "one-time" inspection should be used only for license-renewal-related inspections. For clarification purposes, the final SER now provides definitions of one-time inspections, restart inspections, and Unit 1 periodic inspections. Section 3.7 of the final SER still refers to some restart inspections as one-timeinspections. The final SER should be revised to be consistent with these definitions. The applicant has identified systems and components requiring a TLAA and reevaluated themfor 20 more years of operation. The SER concludes that the TLAAs are valid for the period of 5-8extended operation, the TLAAs are projected to the end of the period of extended operation, orthat aging effects will be adequately managed for the period of extended operation. We concurwith this assessment.According to current plans, all three BFN units will be subjected to an EPU that will raise theirpower output to 3952 MWt prior to entering the period of extended operation. However, theLRA and the associated SER reflect operating experience only at the current power level. If the EPU is implemented before the period of extended operation, the staff should require that TVAevaluate the operating experience of Units 1, 2, and 3 at the uprated power level and thenincorporate lessons learned into their aging management programs prior to entering the period of extended operation. The EDO response to our interim letter stated that the staff's SER forthe EPU would include a commitment to perform such an evaluation. With the inclusion of commitments to perform periodic inspections of BFN Units 1, 2, and 3drywell refueling seals or drywell shells and to perform an evaluation of operating experience at the EPU level and incorporate lessons learned into their aging management programs prior to entering the period of extended operation, the application for license renewal of Browns Ferry Units 1, 2, and 3 should be approved.Sincerely, /RA/Graham B. Wa llisChairmanReferences
- 1.U.S. Nuclear Regulatory Commission, "Safety Evaluation Report Related to the LicenseRenewal of the Browns Ferry Nuclear Plant, Units 1, 2, and 3," January 2006.2.U.S. Nuclear Regulatory Commission, "Safety Evaluation Report with Open Items Related tothe License Renewal of the Browns Ferry Nuclear Plant, Units 1, 2, and 3," August 2005.3.Tennessee Valley Authority, "Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Applicationfor Renewed Operating Licenses," December 31, 2003.4.Tennessee Valley Authority, "Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 -January 28, 2004 Meeting Follow-Up - Additional Information," February 19, 2004.5.Brookhaven National Laboratory, "Audit and Review Report for Plant Aging ManagementPrograms (AMPs) and Aging Management Reviews (AMRs), Browns Ferry Nuclear PlantUnits 1, 2, and 3, Docket Nos.: 05000259, 05000260, 05000296," April 26, 2005.6.U.S. Nuclear Regulatory Commission, "Browns Ferry Nuclear Plant - Inspection Report 05000259/2004012, 05000260/2004012, and 05000296/2004012," January 27, 2005.7.U.S. Nuclear Regulatory Commission, "Browns Ferry Nuclear Plant - Inspection Report 05000259/2005013, 05000260/2005013, and 05000296/2005013," November 7, 2005.8.Tennessee Valley Authority, "Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 LicenseRenewal Application (LRA) - Annual Update (TAC Nos. MC1704, MC1705, and MC1706),"January 31, 2006.9.Letter from William J. Shack, Acting Chairman, ACRS, to Luis A. Reyes, Executive Director forOperations, NRC, "Interim Report on the Safety Aspects of the License Renewal Application forthe Browns Ferry Nuclear Plant, Units 1, 2, and 3," October 19, 2005.10.Letter from Luis A. Reyes, Executive Director for Operations, NRC, to William J. Shack, ActingChairman, ACRS, "Response to Advisory Committee on Reactor Safeguards - Interim Report 5-9on the Safety Aspects of the License Renewal Application for Browns Ferry Nuclear Plant,Units 1, 2, and 3," November 28, 2005.11.Tennessee Valley Authority, "Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Summary of NRC Site Visit and Meeting Regarding Extended Power Uprate (EPU) and License RenewalApplication (LRA)," January 7, 2005.
12.U.S. Nuclear Regulatory Commission,"10 CFR Parts 2, 50, 54, and 140, Nuclear Power PlantLicense Renewal," Federal Register, Vol. 54, No.
240, December 13, 1991, pp. 64943-64980.13.U.S. Nuclear Regulatory Commission,"10 CFR Parts 2, 51, and 54, Nuclear Power PlantLicense Renewal; Revisions," Federal Register, Vol. 60, No. 88, May 8, 1995, pp. 22461-22495.
6-1SECTION 6CONCLUSIONSThe staff of the U.S. Nuclear Regulatory Commission (NRC or the Commission) reviewed thelicense renewal applications for the Browns Ferry Nuclear, Units 1, 2, and 3, in accordance with Commission regulations and NUREG-1800, "Standard Review Plan for Review of LicenseRenewal Applications for Nuclear Power Plants," dated July 2001. Title 10, Section 54.29, of the Code of Federal Regulations (10 CFR 54.29) provides the standards for issuance of arenewed license.On the basis of its evaluation of the license renewal applications, the NRC staff concl uded thatthe requirements of 10 CFR 54.29(a) have been met and that all open items and confirmatory items have been resolved.The staff notes that any requirements of Subpart A of 10 CFR Part 51 are documented inSupplement 21 to NUREG-1437, "Generic Environmental Impact Statement for LicenseRenewal of Nuclear Plants: Regarding Browns Ferry Nuclear, Units 1, 2, and 3, Final Report,"
dated June 23, 2005.
THIS PAGE INTENTIONALLY LEFT BLANK A-1APPENDIX ACOMMITMENTS FOR LICENSE RENEWALSOF BFN UNITS 1, 2, AND 3During the review of the Browns Ferry Nuclear Plant (BFN) license renewal application (LRA) bythe U.S. Nuclear Regulatory Commission (NRC) staff, the applicant made commitments relatedto aging management programs (AMPs) to manage aging effects of structures and components (SCs) before the period of extended operation. The following tables list these commitments,along with the implementation schedules and the sources of the commitments.
- 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.
Changes to the attached Commitment Tables reflect changes made as a result of the changesdelineated in Enclosure 1 of the letter dated April 4, 2006. The following items are revised:
- Item 15 of Table 1
- Item 28 of Table 1
- Item 45 of Table 1
- Item 48 of Table 1
- Item 49 of Table 2Also, Items 50 through 62 of Table 3 were revised to add the TVA response dated March 2,2006, as a source document.Also, Items 52 of Table 3 was revised to add the TVA response dated April 21, 2006, as asource document.
A-2THIS PAGE IS INTENTIONALLY LEFT BLANK TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)A-3Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSource1.Accessible Non-EnvironmentalQualification Cablesand ConnectionsInspection ProgramDevelop and implement new program.A.1.1Prior to the period ofextended operation
- LRA Section B.2.1.12.Electrical Cables NotSubject to 10 CFR 50.49EnvironmentalQualificationRequirements Usedin InstrumentationCircuits ProgramRevise implementing documents forLPRM cable system aging to referenceexisting Technical Specificationrequirements and license renewalreference(s).A.1.2Prior to the period ofextended operation
- Response to follow-up to RAI 2.5-2 datedMarch 2, 2005Develop and implement new program tomanage IRM cabl e system aging.Prior to the period ofextended operation
- Response to follow-up to RAI 2.5-2 datedMarch 2, 20053.Inaccessible MediumVoltage Cables NotSubject to 10 CFR50.49 EnvironmentalQualificationRequirementsProgramDevelop and implement new program tomanage the medium-voltage cables to theResidual Heat Removal Service Waterpumps.A.1.3Prior to the period ofextended operation
- Response to RAI 3.6-3(a) datedDecember 9, 2004
- Response to follow-up RAI 3.6-3 datedJanuary 18, 20054.ASME Section XIInservice InspectionSubsections IWB,IWC, and IWDProgramRevise implementing documents toinclude license renewal reference(s).A.1.4Prior to the period ofextended operation
- LRA Section B.2.1.45.Chemistry ControlProgramRevise implementing documents toinclude license renewal reference(s).A.1.5Prior to the period ofextended operation
- LRA Section B.2.1.5 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-46.Reactor HeadClosure StudsProgramRevise implementing documents toinclude license renewal reference(s).A.1.6Prior to the period ofextended operation
- LRA Section B.2.1.67.Boiling WaterReactor VesselInside DiameterAttachment WeldsProgramRevise implementing documents toinclude license renewal reference(s).A.1.7Prior to the period ofextended operation
- LRA Section B.2.1.78.Boiling WaterReactor FeedwaterNozzle ProgramRevise implementing documents toinclude license renewal reference(s).A.1.8Prior to the period ofextended operation
- LRA Section B.2.1.89.Boiling WaterReactor Control RodDrive Return LineNozzle ProgramRevise implementing documents toinclude license renewal reference(s).A.1.9Prior to the period ofextended operation
- LRA Section B.2.1.910Boiling WaterReactor StressCorrosion CrackingProgramRevise implementing documents toinclude license renewal reference(s).A.1.10Prior to the period ofextended operation
- LRA Section B.2.1.1011.Boiling WaterReactor PenetrationsProgramRevise implementing documents toinclude license renewal reference(s).A.1.11Prior to the period ofextended operation
- Enclosure 1 of TVAletter datedSeptember 14, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-512.Boiling WaterReactor VesselInternals ProgramRevise implementing documents toinclude license renewal reference(s).A.1.12Prior to the period ofextended operation
- LRA Section B.2.1.12Inspect the top guide beamsPrior to the period ofextended operation
- Response to NRCQuestion (3) datedMay 25, 2005Establish an aging management programfor the steam dryers.Two years before thefirst BFN unit enters theperiod of extendedoperation
- Response toRAI 3.1-1 datedJanuary 31, 2005Enhance the Reactor Pressure VesselInternals Inspection (RPVII) Units 1, 2,and 3 procedure to require visualinspection of the Access Hole Covers(AHCs) and inspection of the AHC welds.Two years before thefirst BFN unit enters theperiod of extendedoperation
- Response to RAIB.2.1.12-1(C) datedJanuary 31, 2005
- Response to NRCQuestion (7) datedMay 25, 2005Implement the inspection of weld TS-2(BWRVIP-41).When inspectiontechnique for weld TS-2being developed by theBWRVIP InspectionCommittee is available.
- Response toQuestion (12) datedMay 25, 200513.Flow-AcceleratedCorrosion ProgramRevise implementing documents toinclude license renewal reference(s).A.1.14Prior to the period ofextended operation
- LRA Section B.2.1.1514.Bolting IntegrityProgramRevise implementing documents toinclude license renewal reference(s).A.1.15Prior to the period ofextended operation
- LRA Section B.2.1.16 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-615.Open-Cycle CoolingWater SystemProgramRevise implementing documents toinclude license renewal reference(s).A.1.16Prior to the period ofextended operation
- LRA Section B.2.1.17Enhance the Open-Cycle Cooling WaterSystem Program to perform confirmatoryinspections of the RHRSW pump pitsupply piping, sluice gate valves andseismic restraints in the RHRSW pumppit.Once prior to the periodof extended operationWithin 10 years afterentering the period ofextended operation
- Enclosure 1 of TVAletter dated April 4, 200616.Closed-CycleCooling WaterSystem ProgramRevise implementing documents toinclude license renewal reference(s).A.1.17Prior to the period ofextended operation
- LRA Section B.2.1.1817.Inspection ofOverhead HeavyLoad and Light LoadHandling SystemsProgramRevise implementing documents toinclude license renewal reference(s).A.1.18Prior to the period ofextended operation
- LRA Section B.2.1.2018.Compressed AirMonitoring ProgramRevise implementing documents to:
- Include license renewal reference(s).
- Incorporate guidelines in ASME OM-S/G-2000, Part 17; ANSI/ISA-S7.0.01-1996; and EPRI TR 108147A.1.19Prior to the period ofextended operation
- LRA Section B.2.1.2119.BWR Reactor WaterCleanup SystemProgramRevise implementing documents toinclude license renewal reference(s).A.1.20Prior to the period ofextended operation
- LRA Section B.2.1.2220.Fire ProtectionProgramRevise implementing documents toinclude license renewal reference(s).A.1.21Prior to the period ofextended operation
- LRA Section B.2.1.23 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-721.Fire Water SystemProgramRevise implementing documents to:
- Include license renewal reference(s).
- Perform flow tests or non-intrusiveexaminations to identify evidence ofloss of material due to corrosion.A.1.22Prior to the period ofextended operation
- LRA Section B.2.1.24Perform sprinkler head inspections toensure signs of degradation, such ascorrosion, are detected in a timelymanner.Prior to exceeding the50-year service life forany sprinkler
- LRA Section B.2.1.2422.Aboveground CarbonSteel Tanks ProgramRevise implementing documents toinclude license renewal reference(s).A.1.23Prior to the period ofextended operation
- LRA Section B.2.1.2623.Fuel Oil ChemistryProgramRevise implementing documents toinclude license renewal reference(s).A.1.24Prior to the period ofextended operation
- Enclosure 1 of TVAletter datedSeptember 14, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-824.Reactor VesselSurveillanceProgramRevise implementing documents toinclude license renewal reference(s).A.1.25Prior to the period ofextended operation
- LRA Section B.2.1.28Enhance the Integrated SurveillanceProgram (ISP) per proposed BWRVIP-116.Prior to the period ofextended operation
- LRA Section B.2.1.28If the ISP is not approved two years priorto the commencement of the licenserenewal period, a plant-specificsurveillance program for each BFN unitwill be submitted to the NRC.Two years prior to thecommencement of thelicense renewal period
- Response to RAIB.2.1.28-1(A) datedJanuary 31, 2005
- Response toQuestion (9) datedMay 25, 2005Maintain Unit 1 and Unit 3 surveillancecapsules (standby capsules) available tothe ISP.Unit 3 is ongoingUnit 1 will commence atrestart
- Response toQuestion (10) datedMay 25, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-925.One-Time InspectionProgramDevelop and implement new program.A.1.26Prior to the period ofextended operation
- LRA Section B.2.1.29Develop and submit procedure for NRCreview.At least two years priorto the expiration of thecurrent operating license
- Response toProposed UnresolvedItem 3.0-4 LP datedMay 27, 2005Perform a one-time inspection of theASME equivalent Class MC supports in asubmerged environment of the Units 2and 3 Torus.Prior to the period ofextended operation
- Response to RAIB.2.1.33-2 datedJanuary 18, 2005Perform a one-time inspection of the in-scope submerged concrete in oneindividual CCW pump bay of the IntakePumping Station.Prior to the period ofextended operation
- Response toQuestion 359 datedOctober 8, 2004
- Response to RAI 3.5-16 dated April 5, 2005Perform ultrasonic thicknessmeasurements of tank bottoms for thosetanks specified in the Fuel Oil ChemistryProgram (B.2.1.27) and the AbovegroundCarbon Steel Tanks Program (B.2.1.26).Prior to the period ofextended operation
- Response to RAI7.1.19-1 datedMay 25, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1026.Selective Leaching ofMaterials ProgramDevelop and implement program.A.1.27Prior to the period ofextended operation
- LRA Section B.2.1.3027.Buried Piping andTanks InspectionProgramRevise implementing documents toinclude license renewal reference(s).A.1.28Prior to the period ofextended operation
- LRA Section B.2.1.31Add a trigger to the excavation permitdocument to require notification ofengineering to perform a piping inspectionwhen piping is excavated.Complete
- NRC InspectionReport datedJanuary 27, 2005Determine (via engineering evaluation) ifsufficient inspections have beenperformed to draw conclusion regardingability of underground coating to protectpiping.If required, conduct a focused inspectionto draw conclusion concerning thecoating.Within 10 years afterentering the period ofextended operation
- Response to RAI7.1.22-1 datedMay 25, 2005Revise implementing documents toinspect buried piping when it is excavated.Complete
- Response to RAI7.1.22-1 datedMay 25, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1128.ASME Section XISubsection IWEProgramRevise implementing documents toinclude license renewal reference(s).A.1.29Prior to the period ofextended operation
- LRA Section B.2.1.32Enhance ASME Section XI, SubsectionIWE Program to perform a UT inspectionof the sand bed area of the drywell liner of Units 1, 2, and 3.First inspection on eachunit prior to the period ofextended operation.Subsequent periodicinspections will beperformed on each unitat a period not to exceed10 years.
- Enclosure 1 of TVAletter dated April 4, 200629.ASME Section XISubsection IWFProgramRevise implementing documents toinclude license renewal reference(s).A.1.30Prior to the period ofextended operation
- LRA Section B.2.1.33Enhance program to manage the agingeffects of ASME equivalent Class MCsupports.Prior to the period ofextended operation
- Response to Follow-up RAI B.2.1.33-1dated May 31, 200530.10 CFR 50 AppendixJ ProgramRevise implementing documents toinclude license renewal reference(s).A.1.31Prior to the period ofextended operation
- LRA Section B.2.1.3431.Masonry WallProgramRevise implementing documents toinclude license renewal reference(s).A.1.32Prior to the period ofextended operation
- LRA Section B.2.1.35Revise implementing procedures to clearlyidentify structures with masonry wallswithin scope and to clarify qualificationrequirements for personnel who performmasonry wall walkdowns.Prior to the period ofextended operation
- LRA Section B.2.1.35 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1232.Structures MonitoringProgramRevise implementing documents toinclude license renewal reference(s).A.1.33Prior to the period ofextended operation
- LRA Section B.2.1.36Enhance procedures implementingthe10 CFR 50.65 Maintenance RuleProgram to identify all structures andstructural components within scope.Prior to the period ofextended operation
- Response to GALLaudit Question 173dated October 8, 2004
- Response to GALLaudit Question 357dated October 8, 2004Enhance procedures implementing the10 CFR 50.65 Maintenance Rule programsampling approach to includeexaminations of below-grade concretewhen excavated.Prior to the period ofextended operation
- Response to GALLaudit Question 285dated October 8, 2004Enhance procedures implementing the10 CFR 50.65 Maintenance Rule programto include the guidance provided in ACI349.3R-96 Chapter 7.Prior to the period ofextended operation
- LRA Section B.2.1.36Enhance LCEI-CI-C9, Attachment 1,"Buried Piping Inspection Checklist," toinclude "Mechanical Penetration" as aninspection attribute.Prior to entering theperiod of extendedoperation
- Response to GALLaudit Question 285dated October 8, 2004 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1333.Inspection of Water-Control StructuresProgramRevise implementing documents toinclude license renewal reference(s).A.1.34Prior to the period ofextended operation
- LRA Section B.2.1.37Revise implementing documents toidentify required structures and structuralcomponents within the scope of licenserenewal.Prior to the period ofextended operation
- LRA Section B.2.1.37Revise implementing documents toinclude special inspections following theoccurrence of large floods, earthquakes,tornadoes, and intense rainfall.Prior to the period ofextended operation
- LRA Section B.2.1.37Implement periodic monitoring of the rawservice water in close proximity to theIntake Pumping Station for therequirements of an aggressiveenvironment.Prior to the period ofextended operation
- Response to RAI 3.5-16 dated April 5, 200534.EnvironmentalQualificationProgramRevise implementing documents toinclude license renewal reference(s).A.1.35Prior to the period ofextended operation
- LRA Section B.3.135.Fatigue MonitoringProgramImplement enhanced Fatigue MonitoringProgram using the EPRI-licensedFatiguePro cycle counting and fatigueusage tracking computer program.A.1.36Prior to the period ofextended operation
- LRA Section B.3.236.Systems MonitoringProgramRevise implementing documents toinclude license renewal reference(s).A.2.1Prior to the period ofextended operation
- Enclosure 1 of TVAletter datedSeptember 14, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1437.Bus InspectionProgramDevelop and implement new program.A.2.2Prior to the period ofextended operation
- Response to RAI 3.6-4 dated December 9, 200438.Diesel Starting AirProgramRevise implementing documents toinclude license renewal reference(s).A.2.3Prior to the period ofextended operation
- LRA Section B.2.1.4139.Time-Limited AgingAnalysis:Reactor VesselThermal LimitAnalyses: OperatingPressure-Temperature Limits(P-T)Develop and submit revised P-T limits tothe NRC for approval.A.3.1.5Prior to the period ofextended operation
- LRA Section A.3.1.5
- LRA Section 4.2.540.Time-Limited AgingAnalysis:EnvironmentalQualification ofElectrical EquipmentRevise existing EQ program to cover theextended period of operation.A.3.3Prior to the period ofextended operation
- LRA Section A.3.3
- LRA Section 4.441.Time-Limited AgingAnalysis:Other Plant SpecificTime-Limited AgingAnalysis:EmergencyEquipment CoolingWater Weld FlawEvaluationImplement an administrative trackingsystem to ensure limiting number offatigue cycles will not be exc eeded at theselect EECW locations.A.3.5.7Prior to the period ofextended operation
- LRA Section A.3.5.7
- Response to RAI4.7.8 dated March 2, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1542.RAI 2.1-2,A-3Identify additional piping segments andsupports/equivalent anchors to be placedin scope.N/AComplete
- Response to RAI 2.1-2,A-3 datedSeptember 3, 2004
- TVA response datedFebruary 28, 200543.RAI 2.1-2,BImplement Unit 1, 2, and 3 DCNs toqualify twelve temperature switches in theTurbine Building.N/APrior to the period ofextended operation
- Response to RAI 2.1-2,B datedSeptember 3, 200444.RAI 2.1-2,C RHRSW tunnelInclude 24-inch Raw Cooling Waterdischarge piping located in the RHRSWtunnel in scope of license renewal.N/AComplete
- TVA response datedJanuary 31, 200545.RAI 2.1-2,C IntakePumping StationRevise 10 CFR 54.4(a)(2) ScopingMethodology document to addresscomponents located in the lowercompartments of the Intake PumpingStation.N/AComplete
- Response to RAI 2.1-2,C Intake PumpingStation datedSeptember 3, 200446.Open Item OI 2.4-3Perform one time confirmatory ultrasonicthickness (UT) measurements on aportion of the cylindrical section of thedrywell on Units 2 and 3.N/APrior to the period ofextended operation
- Enclosures 1 and 9 ofTVA letter datedNovember 16, 2005 TABLE 1: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(NON-UNIT SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1647.Open Item OI 4.7.7Perform a BFN plant-specific analysisconsistent with BWRVIP-25 todemonstrate that the core plate hold-downbolts can withstand required loads,considering the effects of stress relaxationuntil the end of the period of extendedoperation. Take appropriate correctiveaction if the analysis does not satisfy thespecified criteria.Submit the analysis or the correctiveaction taken to resolve the core plate hold-down bolt issue to the NRC for review.N/ATwo years prior to theperiod of extendedoperation
- Enclosures 3 and 9 ofTVA letter datedNovember 16, 200548.Not Used
TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(UNIT 1 SPECIFIC)A-17 NOTE: This Table does not contain all of the same Item Numbers as contained in Table 1. While there is a one-to-one correlati on of items with the same number, the same Item Numbers are not in both tables as explained below:
- For Item Numbers 1 through 47, only those Item Numbers that have a Unit 1 specific commitment are included in this table.
- Item Numbers 49 and 63 applies only to Unit 1.Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSource2.Electrical Cables NotSubject to10 CFR 50.49EnvironmentalQualificationRequirements Usedin InstrumentationCircuits ProgramInclude Unit 1 High-Range RadiationMonitoring cables in the EnvironmentalQualification (EQ) Program.A.1.2Prior to Unit 1 restart
- Response to GALLaudit Question 169dated October 8, 20045.Chemistry ControlProgramInclude Unit 1 in the program.A.1.5Prior to Unit 1 restart
- LRA Section B.2.1.57.Boiling WaterReactor VesselInside DiameterAttachment WeldsProgramInclude Unit 1 in the program.A.1.7Prior to Unit 1 restart
- LRA Section B.2.1.78.Boiling WaterReactor FeedwaterNozzle ProgramUpgrade Unit 1 operating procedures todecrease the magnitude and frequency offeedwater temperature fluctuations.A.1.8Prior to Unit 1 restart
- LRA Section B.2.1.810.Boiling WaterReactor StressCorrosion CrackingProgramInclude Unit 1 in the program.A.1.10Prior to Unit 1 restart
- Response to GALLaudit Question 181dated October 8, 2004 TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(UNIT 1 SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1811.Boiling WaterReactor PenetrationsProgramInclude Unit 1 in the program.A.1.11Prior to Unit 1 restart
- Response to GALLaudit Question 194dated October 8, 200412.Boiling WaterReactor VesselInternals ProgramInclude Unit 1 in the program.A.1.12Prior to Unit 1 restart
- Response toQuestion (4b) datedMay 25, 200513.Flow-AcceleratedCorrosion ProgramInclude Unit 1 in the program.A.1.14Prior to Unit 1 restart
- Response to GALLaudit Question 144dated October 8, 200415.Open-Cycle CoolingWater SystemProgramInclude Unit 1 in the program.A.1.16Prior to Unit 1 restart
- Response to GALLaudit Question 144dated October 8, 200416.Closed-CycleCooling WaterSystem ProgramInclude Unit 1 in the program.A.1.17Prior to Unit 1 restart
- Response to GALLaudit Question 144dated October 8, 200418.Compressed AirMonitoring ProgramInclude Unit 1 in the program.A.1.19Prior to Unit 1 restart
- LRA Section B.2.1.21 TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(UNIT 1 SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-1919.BWR Reactor WaterCleanup SystemProgramInclude Unit 1 in the program.A.1.20Prior to Unit 1 restart
- LRA Section F.1320.Fire ProtectionProgramUpdate the Fire Protection Report and toincorporate Unit 1 as an operating unit.Fully implement the program on Unit 1.A.1.21Prior to Unit 1 restart
- LRA Section B.2.1.2321.Fire Water SystemProgramUpdate the Fire Protection Report andprocedures to incorporate Unit 1 as anoperating unit. Fully implement theprogram on Unit 1.A.1.22Prior to Unit 1 restart
- LRA Section B.2.1.2424.Reactor VesselSurveillanceProgramEither include Unit 1 within the BWRVIPISP, or submit for NRC approval a plantspecific surveillance program that meetsthe requirements of 10 CFR 50 AppendixH for the period of extended operation.A.1.25Prior to the period ofextended operation
- LRA Section B.2.1.28Ensure BWRVIP-86-A and BWRVIP-116are revised to incorporate Unit 1, andsubmit to the NRC a license amendmentrequest to implement the ISP for site-specific use forUnit 1.Prior to the period ofextended operation
- Response to RAIB.2.1.28-1 datedJanuary 31, 200525.One-Time InspectionProgramPerform a one-time inspection of theASME equivalent Class MC supports in asubmerged environment of the Unit 1Torus.A.1.26Prior to Unit 1 restart
- Response to RAIB.2.1.33-2(b) datedJanuary 18, 200534.EnvironmentalQualificationProgramInclude Unit 1 in the program.A.1.35Prior to Unit 1 restart
- LRA Section B.3.1 TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMS AND TLAAs(UNIT 1 SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-2047.Open Item OI 2.4-3Perform one time confirmatory UTmeasurements on the drywell verticalcylindrical area immediately below thedrywell flangeN/APrior to Unit 1 restart
- Enclosures 1 and 9 orTVA letter datedNovember 16, 200549.Unit 1 PeriodicInspection ProgramDevelop and implement new program.A.2.4Prior to Unit 1 restart
- Enclosure 1 of TVAletter datedSeptember 14, 2005
- Enclosure 1 of TVAletter dated April 4, 2006Develop and submit implementingprocedure(s) for NRC review.Prior to Unit 1 restart
- Response toProposed UnresolvedItems 3.0-4 LP datedMay 27, 2005
- Enclosure 1 of TVAletter dated April 4, 2006 TABLE 2: BFN COMMITMENT LIST ASSOCIATED WITH LRA APPENDIX A AGING MANAGEMENT PROGRAMSAND TLAAs(UNIT 1 SPECIFIC)Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-2163.Response to NRCQuestionsConcerning RPVInternalsReplace all BFN Unit 1 dry tubes.N/APrior to Unit 1 restart
- Response toQuestion (8) datedMay 25, 2005Perform MSIP for Unit 1 Control Rod DriveReturn Line Cap.Prior to Unit 1 restart
- Response toQuestion (6) datedMay 25, 2005Change the Unit 1 AHCs to bolted design.Prior to Unit 1 restart
- Response to NRCQuestion (7) datedMay 25, 2005
TABLE 3: UNIT 1 RESTART COMMITMENTS THAT ARE DISCUSSED IN LRA APPENDIX FA-22NOTE: See Note at the beginning of Table 2Item Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSource50.Appendix F.1Evaluate and modify, as required, mainsteam leakage path piping to ensurestructural integrity.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200651.Appendix F.2Implement Containment AtmosphereDilution System modification.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200652.Appendix F.3Revise Fire Protection Report per Unit 1License Condition 2.C.13.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 2006
- TVA response datedApril 21, 200653.Appendix F.4Implement Environmental QualificationProgram.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200654.Appendix F.5Address GL 88-01, and make necessaryplant modifications.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 2006 TABLE 3: UNIT 1 RESTART COMMITMENTS THAT ARE DISCUSSED IN LRA APPENDIX FItem Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-2355.Appendix F.6BWRVIP Programs used for Units 2 and 3will be used for Unit 1.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200657.Appendix F.8Remove Reactor Vessel Head Spraypiping in drywell, and seal the primarycontainment penetrationsN/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200658.Appendix F.9Implement the Hardened Wetwell Ventmodification.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200659.Appendix F.10Cap Service Air and Demineralized WaterPrimary Containment Penetrations.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 2006 TABLE 3: UNIT 1 RESTART COMMITMENTS THAT ARE DISCUSSED IN LRA APPENDIX FItem Number/TitleCommitmentLRAAppendix A(UFSAR)ImplementationScheduleSourceA-2460.Appendix F.11Modify Auxiliary Decay Heat RemovalSystem to serve Unit 1.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200661.Appendix F.12Fully implement the Maintenance RuleUnit 1's temporary exemption ceases tobe effective.N/APrior to Unit 1 restart
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 200662.Appendix F.13Replace RWCU piping outside of primarycontainment with IGSCC resistant piping.Implement actions requested in GL 89-10for RWCUN/AComplete
- LRA Appendix F
- TVA response datedJanuary 31, 2005
- TVA response datedMarch 2, 2006 B-1APPENDIX B CHRONOLOGYThis appendix contains a chronological listing of the routine licensing correspondence betweenthe U.S. Nuclear Regulatory Commission (NRC) staff and the Tennessee Valley Authority(TVA), and other correspondence regarding the NRC staff's reviews of the Browns FerryNuclear (BFN), Units 1, 2, and 3 (under Docket Numbers 50-259, 50-260 and 50-296) license renewal application (LRA).November 7, 2005Letter from Harold O. Christensen, NRC, to K. W. Singer, TennesseeValley Authority (TVA) regarding Browns Ferry Nuclear Plant - Inspection Report 05000259/2005013, 05000260/2005013, and 05000296/2005013 (Accession No. ML053120402)November 28, 2005Response to Advisory Committee on Reactor Safeguards (ACRS) -Interim Report on the Safety Aspects of the License Renewal Application (LRA) for Browns Ferry Nuclear Plant, Units 1, 2, and 3. (Accession No.
ML053180460)December 20, 2005TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) - SupplementalInformation for the Time Limited Aging Analysis of the Relaxation of the Core Hold-Down Bolts and the Unit 1 Periodic Inspection Program (TAC NOS. MC1704, MC1705, AND MC1706) (Accession No. ML053560328)January 31, 2006Browns Ferry Nuclear Plant, Units 1, 2, and 3 License RenewalApplication - Annual Update Letter (Accession No. ML060410288)January 31, 2006Safety Evaluation Report related to the License Renewal Application ofBrowns Ferry Nuclear Plant, Units 1, 2, and 3 - Request for Additional Information Related to Appendix F items in the Application. (Accession No. ML060330295)February 14, 2006TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3License Renewal Application - Revised Commitment Tables" (Accession No. ML060450582)March 1, 2006 Memorandum to James E. Dyer, Director of Nuclear Reactor Regulationfrom William D. Travers, Regional Administrator, regarding Browns FerryLicense Renewal Application. (Accession No. ML060610326)March 2, 2006TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3License Renewal Application - Request for Additional Information related to Appendix F of the License Renewal Application: Integration of BFN Unit 1 Restart and License Renewal Activities" (Accession No.
B-2March 3, 2006Safety Evaluation Report related to the License Renewal Application ofBrowns Ferry Nuclear Plant, Units 1, 2, and 3 - Request for Additional Information Related to Appendix F items in the Application and Topics Discussed in Public Meeting on March 1, 2006, at the Nuclear RegulatoryCommission. (Accession No. ML0606203530)March 7, 2006TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3License Renewal Application - Periodic Inspection Program" (Accession No. ML060660374)March 7, 2006TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3License Renewal Application - Supplemental Information for Open Item 2.4-3. (Accession No. ML060790376)March 23, 2006Letter from Dr. Graham B. Wallis, ACRS Chairman, to Honorable Nils J.Diaz, NRC Chairman. Report on the Safety Aspects of the LicenseRenewal Application for the Browns Ferry Nuclear Plant Units 1, 2, and 3.
(Accession No. ML060870208)April 4, 2006TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3License Renewal Application - Unit 1 Lower Drywell Liner Inspections, Unit 1 Periodic Inspection Program, and Residual Heat Removal Service Water Piping Inspections (TAC NOS. MC1704, MC1705, AND MC1706 (Accession No.ML060950060)April 21, 2006TVA letter to NRC, "Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3License Renewal Application - Revised Commitment List (TAC NOS.
C-1APPENDIX CPRINCIPAL CONTRIBUTORSNAMERESPONSIBILITYR. SubbaratnamY. Diaz Sanabria R. Karas D. Jeng H. Ashar K. Manoly Y. Li R. McNally M. Hartzman C. Julian L. Lund A. HodgdonProject ManagerProject Manager Management Supervision Civil Engineering Civil Engineering Management Supervision Technical Support: Mechanical Engineering Mechanical Engineering Mechanical Engineering Regional Support Management Supervision Office of General Counsel