ML062700240

Response to NRC Letter, Dated August 25, 2006 - Request for Additional Information Associated with the Restart of Unit 1

ML062700240
Person / Time
Site:	Browns Ferry
Issue date:	09/27/2006
From:	Crouch W Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC4660
Download: ML062700240 (13)

Text

September 27, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:

In the Matter of ) Docket No. 50-259 Tennessee Valley Authority )

BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 - RESPONSE TO NRC LETTER, DATED AUGUST 25, 2006 - REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH THE RESTART OF UNIT 1 (TAC NO. MC4660)

The Enclosure to this letter provides the additional information requested by NRCs letter dated August 25, 2006, (Reference 1) that questioned if TVA had considered that the status change of BFN Unit 1 could result in a need to update the licensing basis for Unit 2 and 3. NRC stated that: TVA should ensure that the licensing basis for Units 2 and 3 are continuing to be met and if there are any other outstanding licensing actions for BFN Units 2 and 3 needed prior to the restart of Unit 1, TVA should seek approvals.

Additionally, NRC requested that TVA provide a list and a schedule for submittal of any required licensing actions for Units 2 and 3, which are necessary due to previous assumptions that are no longer valid due to the restart of Unit 1.

Based on the review documented in Enclosure 1, only the two additional licensing actions for Unit 2 and 3 identified by NRC in letter dated August 25, 2006, are required to support restart of Unit 1. Both of these

U.S. Nuclear Regulatory Commission Page 2 September 27, 2006 issues were identified in TVAs regulatory framework letter dated December 13, 2002, (Reference 2) as issues requiring resolution prior to Unit 1 restart. contains the new commitment contained in this letter. If you have any questions, please contact me at (256) 729-2636.

Sincerely, Original signed by:

William D. Crouch Manager of Licensing and Industry Affairs

Reference:

1. NRCs letter dated August 25, 2006, Request for Additional Information Associated with Restart of Unit 1 (TAC No. MC4660)

2. TVA letter dated December 13, 2002, BFN Unit 1, Regulatory Framework for the Restart of Unit 1

U.S. Nuclear Regulatory Commission Page 3 September 27, 2006 Enclosure cc (Enclosure):

Mr. Malcolm T. Widmann, Branch Chief Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Ms. Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North (MS 08G9) 11555 Rockville Pike Rockville, Maryland 20852-2739 Ms. Margaret Chernoff, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North (MS 08G9) 11555 Rockville Pike Rockville, Maryland 20852-2739

U.S. Nuclear Regulatory Commission Page 4 September 27, 2006 WDC:JEM:BAB Enclosure cc (Enclosure):

B. M. Aukland, POB 2C-BFN M. Bajestani, NAB, 1A-BFN A. S. Bhatnagar, LP 6A-C L. S. Bryant, LP 6A-C R. H. Bryan, BR 4X-C J. C. Fornicola, LP 6A-C R. G. Jones, POB 2C-BFN R. F. Marks, PAB 1A-BFN K. W. Singer, LP 6A-C P. D. Swafford, LP 6A-C E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS, WT 3B-K s:\licensing\lic\submit\subs\RAI U1 restart response ltr 92606r2.doc

ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 RESPONSE TO NRC LETTER, DATED AUGUST 25, 2006 REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH RESTART OF UNIT 1 (TAC NO. MC4660)

TVA letter dated December 13, 20021, as supplemented by a February 28, 2003,2 letter, proposed the regulatory framework for the restart of Unit 1. As noted by NRC in letter dated August 25, 20063, these framework letters established a plan for addressing the generic communications, special programs, Technical Specification (TS) changes, and other licensing and regulatory issues needed prior to the restart of Unit 1.

Included with the framework was a list of license amendments, relief requests, generic communications, and special programs that would be resolved prior to Unit 1 restart. NRC stated that as they work to resolve these items, the Staff noted the potential effect of the Unit 1 restart on Units 2 and 3 was not sufficiently discussed in previous TVA correspondence. NRC identified two TVA issues that exemplify their concern.

The first example identified was TVAs proposed TS amendment request (TVA letters dated December 6, 20044 and October 28, 20055) to extend the allowed outage time for the Unit 1/2 emergency diesel generators (EDGs) from 7 days to 14 days. Specifically, NRC stated that TVA did not provide adequate justification regarding the risk impact of Unit 1 restart on the previously granted EDG AOT extension for Units 2 and 3. NRC stated in their August 17, 20066, letter that the effect of Unit 1 restart on the approval of an extension of the EDGs allowed out of service time for Units 2 and 3 from 7 days to 14 days was based on treating BFN as a two unit plant, each with four EDGs available for service. However, with the proposed restarting of Unit 1, the same eight EDGs will be shared between units.

The second example is BFN Units 1, 2 and 3 Fire Protection License Conditions 2(C)13, 2(C)14, and 2(C)7 citing two safety evaluations that were approved for all three units assuming Units 2 and 3 operating with Unit 1 shutdown and defueled (NRC SER dated November 2, 19957), and the second evaluation (NRC SER 1

TVA letter dated December 13, 2002, BFN Unit 1 - Regulatory Framework for the Restart of Unit 1.

2 TVA letter dated February 28, 2003, BFN Unit 1 - Regulatory Framework for the Restart of Unit 1.

3 NRC letter dated August 25, 2006, Request for Additional Information Associated with Restart of Unit 1 (TAC No. MC4660) 4 TVA letter dated December 6, 2004, BFN Unit 1 - TS Change TS-426 - Revision to Diesel Generators Allowed Outage Time 5

TVA letter dated October 28, 2005, BFN Unit 1 - TS-426 - Response to RAI Regarding Revision to Diesel Generators Allowed Outage (TAC No.

MC5254) 6 NRC letter dated August 17, 2006, BFN Unit 1 - Withdrawal of License Amendment Request to Revise DGs AOT (TAC No. MC5254) 7 NRC letter dated November 2, 1995, Safety Evaluation of Post-Fire Shutdown Capability and Issuance of TS Amendments for BFN Units 1, 2, and 3 (TAC Nos. M85254, M87900, M87901 and M87902) (TS-337)

ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 RESPONSE TO NRC LETTER, DATED AUGUST 25, 2006 REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH RESTART OF UNIT 1 (TAC NO. MC4660) dated November 3,19898) assumed Units 1 and 3 shut down. The NRC request and TVAs response are provided below.

NRC Request:

TVA should ensure that the licensing basis for Units 2 and 3 are continuing to be met and if there are any other outstanding licensing actions for BFN Units 2 and 3 needed prior to the restart of Unit 1, TVA should seek approvals. Based on the concern mentioned above, to ensure that all required reviews have been completed, the NRC Staff request TVA to provide a list and a schedule for submittal of any required licensing actions for Units 2 and 3, which are necessary due to previous assumptions that are no longer valid due to the restart of Unit 1.

TVA Response:

The following provides the results of the review of those items/programs that may be affected by three unit operation to determine if there are any Units 2 or 3 items/programs that may require additional regulatory action(s) due to the restart of Unit 1. TVA conducted a review of Nuclear Performance Plan (NPP) Programs, Generic Letters (GLs), Bulletins, etc., as described in TVAs regulatory framework letters. The review identified areas where TVA potentially assumed Unit 1 was not operating in order to justify operation of Units 2 and/or 3.

The attachment to this enclosure provides the results of this review. The status of NPP Programs, GLs, Bulletins and TMI items are provided quarterly to NRC.

Similarly, a review was performed of the TSs changes made since the conversion to the Improved TS, as documented in TVAs letter dated September 7, 20069. As a result of this review, TVA concluded that the supporting analysis for the affected TS changes have been completed, except for the seismic analysis associated with License Condition 2.C(15).

8 NRC letter dated November 3, 1989, Supplemental Safety Evaluation on Post-Fire Shutdown Systems and Final Review of the National Fire Protection Association Code Deviations - BFN Unit 2, (TAC Nos. 72908 and 00459) 9 TVA letter dated September 7, 2006, BFN Unit 1, Response to NRC letter dated July 7, 2006 - Review of Pending License Amendment Request (TAC No. MC 4797)(TS-432)

ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 RESPONSE TO NRC LETTER, DATED AUGUST 25, 2006 REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH RESTART OF UNIT 1 (TAC NO. MC4660)

The Attachment to this enclosure lists: 1) the areas identified; 2) discusses the assumed status of Unit 1 and the reason for the assumed status; 3) discusses the actions taken or to be taken to allow operation of Unit 1; and 4) any additional required licensing actions for Unit 2 and 3. The list includes the two examples cited by the NRC letter.

Results of Review:

As a result of TVAs review, no additional Units 2 or 3 items/programs beyond that identified in the NRC letter were identified as being affected by the Unit 1 status change (i.e.,

restart). The following provides a list of the items identified and a submittal schedule for each item:

1. EDG Allowed Outage Time Example:

With respect to the EDG example, submit a proposed TS amendment requesting a 7 day AOT for EDGs for Units 2 and 3. TVA will submit this proposed TS amendment request by October 27, 2006.

2. Fire Protection Example:

With respect to the Fire Protection example, TVAs April 24, 200610 letter summarizes the results of the meeting held between TVA and NRC on April 5, 2006. One of the actions that TVA stated it would take during this meeting, as documented in this April 24, 2006 letter, was as follows:

TVA will use existing Unit 1 License Condition 2.C(13) to approve the Unit 1, 2 and 3 Fire Protection Report (i.e.,

supersede the current Unit 2 and 3 Fire Protection Report) prior to restart (enter into Mode 2 or 3). At restart, Unit 1 will utilize the same type of manual operator actions as are currently used in Units 2 and 3. The manual operator actions will be demonstrated to be feasible via timed walkdowns.

Since this action will be performed under TS License condition 2.C (13), no additional submittals are required.

10 TVA letter dated April 24, 2006, BFN Units 1, 2 & 3 - Fire Protection Program - Post-Fire Operator Manual Actions ATTACHMENT LIST OF PROGRAMS REVIEWED FOR NRC AUGUST 25, 2006 RAI ASSOCIATED WITH RESTART OF UNIT 1 Assumed Status of Unit 1 and Action(s) Taken to Allow Licensing Action(s) Required No. Title Reason for Assumption Operation of Unit 1 for Units 2 & 3

1. 10 CFR 50, Appendix R Shutdown and defueled. Reactor Unit 1 is implementing the same Fire TVA will use existing Unit 1 TS Fire Protection building assumed as one fire area with Protection Program (modifications, Licensing Condition 2.C.(13) to low potential for fires. Modifications operator actions, fire detection, fire approve the Unit 1, 2 and 3 Fire and manual operator actions related to suppression, etc.,) as installed in Protection Report (i.e. supersede the Appendix R not required. Units 2 & 3. current Unit 2 and 3 Fire Protection Report) prior to restart (enter into Mode 2 or 3). No submittal required since this action is performed as allowed by TS License condition 2.C (13).

2. 10 CFR 50.49 Shutdown and defueled. No high 10 CFR 50.49 Program to be No additional actions required.

Environment Qualification energy sources in Unit 1 spaces to completed for Unit 1.

of Electrical Equipment create a harsh environment. All areas assumed mild.

3. Diesel Generator Indefinite non-operational status. AOT to be returned to 7 days. TVA TS proposed change will be Allowed Outage Time Facility treated as a two unit plant each to submit a proposed TS change to submitted by October 27, 2006.

with four EDGs available. return Units 2 and 3 to a 7 day AOT.

Unit 1 loads were not included in the diesel loading calculations and were not in the PSA supporting the allowed outage time in LCO 3.8.1 (Operating )

& 3.8.2 (Shutdown)

4. 10 CFR 50.63 NRCs 9/16/92 SSE concluded that TVA to complete Unit 1 equipment No additional actions required.

Station Blackout Rule TVAs proposed methodology for and associated procedural coping with an SBO event at BFN modifications required for SBO Units 1, 2, and 3 conforms with the compliance prior to restart.

SBO rule. SBO is a single unit special event. The diversity of BFN off-site power system, diesel generators, and batteries makes a multi-unit SBO unlikely and therefore is not considered.

5. Baseline Calculations. The baseline calculation program The Unit 1 baseline calculation No additional actions required.

(Electrical., Mechanical., assumed in some isolated calculations program revised all baseline Nuclear., & Civil) that Unit 1 was shutdown and defueled. calculations to ensure Unit 1 was considered in operation in the ATTACHMENT LIST OF PROGRAMS REVIEWED FOR NRC AUGUST 25, 2006 RAI ASSOCIATED WITH RESTART OF UNIT 1 Assumed Status of Unit 1 and Action(s) Taken to Allow Licensing Action(s) Required No. Title Reason for Assumption Operation of Unit 1 for Units 2 & 3 expected Extended Power Uprate (EPU) status/condition.

6. Emergency Equipment EECW is a common plant system A three unit flow balance has been No additional actions required.

Cooling Water (EECW) which has been in service to support performed confirming the EECW System Units 2 and 3 operations. Selected Unit system is capable of providing the 1 loads not required for Units 2 & 3 cooling needs of all equipment operation were valved out while Unit 1 required to safely shutdown all three was shutdown. units, with one unit mitigating a design basis LOCA.

Three unit flow modeling has been performed to ensure the system is capable of supporting 3 unit operations in all modes.

7. Residual Heat Removal RHRSW is a common plant system The Unit 1 A & C supply lines have No additional actions required.

Service Water (RHRSW) which has been in service to support been restored and seismically System Units 2 & 3 operations. The Unit 1 A qualified. Tests were performed to

& C supply lines were cut and capped ensure the system can supply design to support Unit 2 operation so that the flow to two heat exchangers downstream piping did not have to be simultaneously on the most seismically qualified for Unit 2 hydraulically limiting header (i.e., C operation. The B & D supply lines header).

were in service and seismically qualified to support Unit 2 operation.

8. Containment Atmospheric The Unit 1 supply line was cut and The Unit 1 supply lines will be No additional actions required.

Dilution (CAD) System capped to support Unit 2 operation so restored and seismically qualified.

that the downstream piping did not have to be seismically qualified for Unit 2 operation.

9. GL 87-02, Verification of The unit 1 A-46 program is a stand Unit 1 will apply the same No additional actions required.

Seismic Adequacy of alone program fashioned in the same procedures in the implementation of Mechanical and Electrical manner as the unit 2 and unit 3 the program.

Equipment in Operating programs.

Reactors, Unresolved Safety Issue (USI) - A-46

10. Nuclear Performance Plan The BFN electrical system was The Unit 1 Recovery Program is No additional actions required.

(NPP) Volume III, evaluated for Unit 2 and 3 recoveries addressing the NPP Volume III ATTACHMENT LIST OF PROGRAMS REVIEWED FOR NRC AUGUST 25, 2006 RAI ASSOCIATED WITH RESTART OF UNIT 1 Assumed Status of Unit 1 and Action(s) Taken to Allow Licensing Action(s) Required No. Title Reason for Assumption Operation of Unit 1 for Units 2 & 3 Electrical Programs assuming Unit 1 was shutdown and attributes. These programs are the defueled. The recovery effort did not subject of several TVA commitments address program attributes for Unit 1 and are in process and being verified specific loads, cables, etc. by the NRC Region II staff. The Unit 1 recovery is utilizing the same acceptance criteria as previously used for Units 2 & 3.

11. Seismic The unit 1 program did not change any The criteria and licensing basis No additional actions required.

of the requirements. requirements for BFN were developed for all three units during the unit 2 restart effort. Unit 1 modifications are in progress.

12. Probabilistic Safety The Units 2 and 3 PSAs assumed Unit The Unit 1 PSA has been issued for No additional actions required.

Assessment (PSA) 1 was shutdown and defueled. The three unit operation at EPU PSAs did not account for Unit 1 conditions. Additionally, the Units 2 GL 88-20 initiated events nor address the actions and 3 PSAs have been revised/

required to maintain Unit 1 in a safe enhanced to account for Unit 1 condition. operation and EPU conditions.

The following program examples being revised to include U1: MSPI, Online Maint, ORAM, Sentinel, and Risk Significant evaluations.

13. Individual Plant Unit 1 shutdown, no IPEEE fire and TVAs January 14, 2005 letter No additional actions required.

Examination of External seismic analysis was submitted. Unit 1 provided BFN Unit 1s: Seismic Events (IPEEE) IPEEE fire and seismic analysis to be IPEEE Report and IPEEE Fire submitted prior to restart. Induced Vulnerability Evaluation.

GL 88-20, Individual Plant This completed TVAs response to Examination, Supplement 4 TVA letter dated July 24, 1995, GL 88-20.

BFN - GL 88-20, sup 4, IPEEE for Severe Accident Vulnerabilities - Unit 1 will complete the corrective Partial Submittal of Report, actions with the emergency lighting transmitted TVAs evaluation battery racks.

addressing High Winds and Tornadoes, External Floods, Transportation and Nearby Facility Accidents for all three units, ATTACHMENT LIST OF PROGRAMS REVIEWED FOR NRC AUGUST 25, 2006 RAI ASSOCIATED WITH RESTART OF UNIT 1 Assumed Status of Unit 1 and Action(s) Taken to Allow Licensing Action(s) Required No. Title Reason for Assumption Operation of Unit 1 for Units 2 & 3 including Unit 1.

14. Common Accident Signal The Common Accident Signal To support the restart of Unit 1, TVA No additional actions required.

(CAS) (CAS) detects the presence of an performed an analysis of the ECCS accident signal on multiple units and common accident signal and then directs the partitioning of initiation logic. DCNs 51016 (U1) the diesels to support accident and 51018 (U2) implement the Unit mitigation. The signal between 1/2 ECCS Preferred Pump Logic Units 1 and 2 was disconnected changes. These modifications ensure since it was not possible to have an that the consequences of a spurious accident on Unit 1 with the unit accident signal during combined shutdown and defueled. operation of Units 1, 2, and 3 will be Disconnecting the signal prevented mitigated and that the accident signal spurious signals from Unit 1 logic will satisfy the minimum ECCS affecting Unit 2 accident response. requirements in the UFSAR Table 6-Diesel loading based on Unit 2/3 5.3. These changes were submitted accidents only. to the NRC under TS Change Request TS-424, dated April 11, 2003. TS-424 was approved by the NRC by Amendments 250, 289 and 248 (Units 1, 2 and 3 respectively) on 4/1/04.

15. Control Room Design The objective of the CRDR was to CRDR modifications are being No additional actions required.

Review (CRDR) improve the ability of the nuclear installed on Unit 1.

power plant control room operators to reduce errors and improve their ability to cope with accidents if they occur, by improving the information provide to them. A team of qualified plant operators and design engineer have reviewed the layout of the controls and instruments in the BFN control room.

There are a total of 313 CRDR concerns, 111 were safety significant (Category 1 and 2). The nine concerns ATTACHMENT LIST OF PROGRAMS REVIEWED FOR NRC AUGUST 25, 2006 RAI ASSOCIATED WITH RESTART OF UNIT 1 Assumed Status of Unit 1 and Action(s) Taken to Allow Licensing Action(s) Required No. Title Reason for Assumption Operation of Unit 1 for Units 2 & 3 that met the restart criteria were resolved on Unit 2 prior to restart.

Safety significant changes were completed on Unit 2 prior to restart from the next refueling outage (Cycle 6 outage). Non-safety concerns were implemented, if they were determined to have a positive cost/benefit ratio, prior to restart from the Unit 2 Cycle 7 outage. Similar changes were performed prior to Unit 3 restart and will be performed prior to the restart of Unit 1.

16. Emergency Operating Unit 1 assumed defueled and in layup. Sympton based EOIs for Unit 1 No additional actions required.

Instructions (EOI) No EOIs created for Unit 1 operation. similar to those on Units 2 & 3 being developed, verified and validated for restart.

17. Abnormal Operating Unit 1 assumed defueled and in layup. AOIs similar to those on Units 2 & No additional actions required.

Instructions (AOI) No AOIs created for Unit 1 operation. 3 being developed, for Unit 1 restart.

ENCLOSURE 2 COMMITMENT BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 RESPONSE TO NRC LETTER, DATED AUGUST 25, 2006 REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH RESTART OF UNIT 1 (TAC NO. MC4660)

TVA will submit a proposed TS amendment requesting a 7 day AOT for EDGs for Units 2 and 3 by October 27, 2006.