ML101880337
| ML101880337 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 08/04/2010 |
| From: | Leeds E Office of Nuclear Reactor Regulation |
| To: | Bhatnagar A Tennessee Valley Authority |
| Campbell S, NRC/NRR/DORL, 415-3353 | |
| References | |
| Download: ML101880337 (6) | |
Text
August 4, 2010 Mr. Ashok Bhatnagar Senior Vice President Nuclear Generation Development and Construction Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
BELLEFONTE NUCLEAR PLANT, UNITS 1 AND 2REGARDING KEY ASSUMPTIONS FOR REACTIVATION
Dear Mr. Bhatnagar:
This is in response to Tennessee Valley Authoritys (TVAs) letter of April 9, 2010, regarding key regulatory assumptions underlying the possible reactivation and completion of construction of the unfinished Bellefonte Nuclear Plant (BLN) Units 1 and 2.
In 1988, TVA suspended construction of two Babcock and Wilcox (B&W) pressurized-water reactors, BLN Units 1 and 2. At that time, TVA implemented a layup program to preserve the condition of the plant. In the early 2000s, TVA began reducing the number of maintenance and preservation activities at BLN. In 2006, TVA requested that the U.S. Nuclear Regulatory Commission (NRC) withdraw the construction permits (CPs) for BLN Units 1 and 2, and the NRC granted this request. In 2008, TVA asked the NRC to reinstate its previously withdrawn CPs for BLN Units 1 and 2. Subsequently, on March 13, 2009, the NRC granted TVAs request and reinstated the CPs, placing BLN Units 1 and 2 in terminated plant status under the Commissions Policy Statement on Deferred Plants (NRC Generic Letter 87-15, Policy Statement on Deferred Plants, dated November 4, 1987, and published in the Federal Register as 52 FR 38077, dated October 14, 1987); hereinafter referred to as the policy statement. On January 14, 2010, the NRC authorized BLN Units 1 and 2 to be placed in deferred plant status.
In continuation of its efforts to assess the feasibility of reactivating construction at BLN Units 1 and 2, on April 9, 2010, TVA provided the NRC with a summary of key regulatory assumptions for the possible reactivation and completion. TVA has proposed four key assumptions for reactivating BLN Units 1 and 2 and requested an NRC response to them. The NRCs response is discussed below.
A. Bhatnagar 1. Approach for Review of Revised Operating License (OL) Application In its April 9, 2010, letter, TVA stated it was studying the possible reactivation and completion of a single BLN B&W unit. If TVAs Board of Directors authorizes the reactivation of construction for one B&W unit, TVA plans to submit a revised operating license (OL) application for both BLN Units 1 and 2 pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. TVA proposes that NRC licensing reviews be performed for both BLN Units 1 and 2, while its construction efforts would be applied to a single B&W unit.
This approach is acceptable to the NRC. Accordingly, the Office of Nuclear Reactor Regulation (NRR), which is responsible for licensing facilities under 10 CFR Part 50, will perform the licensing review for both BLN Units 1 and 2. The NRC will not make any final conclusion on the OL application for the unfinished second unit. TVA would need to address the items in the policy statement should it elect to reactivate construction of Unit 2. Region II will be responsible for inspection of construction, with assistance from NRR. (The Office of New Reactors is responsible for licensing new reactors under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, and will manage the review of BLN Units 3 and 4; this review is currently in progress.)
- 2. Approach to Address Temporary Cessation of Quality Assurance (QA) Program The absence of preservation and maintenance, the cessation of the QA program, and the conduct of investment recovery activities at BLN Units 1 and 2 during the period from withdrawal of the CPs in 2006 until the CPs were reinstated in 2009, renders the material condition of structures, systems, and components (SSCs) indeterminate. To address this discontinuity in QA, TVA plans to develop and implement a recovery program, which will include verification of QA records, design baseline (i.e., physical condition/configuration assessment, licensing verification, and design basis verification), and replacement items. TVA states that it will submit the recovery program for the NRCs review and approval before the reactivation of construction activities. Finalization of the BLN design would follow recovery program approval, with full implementation of the program occurring before the completion of construction. Recovery program activities undertaken during the period of deferral would be controlled to ensure compliance with the Policy Statement on Deferred Plants and the current TVA QA program.
TVA states that successful implementation of the approved recovery program would adequately address the adverse impacts from the temporary cessation of the QA program at BLN Units 1 and 2.
The staff recognizes that a comprehensive and rigorous recovery program would be necessary to restore and demonstrate the quality of SSCs. However, the staff has no basis to determine the acceptability of the recovery program to restore quality until TVA submits the program and the staff completes its review. The staff will review the recovery program, inspect the implementing procedures, and inspect implementation of the recovery program to ensure that it includes necessary elements, is comprehensive, and adequately demonstrates that SSCs will meet their design and performance standards as described in the final safety analysis report.
The staff expects TVA to replace, refurbish, or otherwise appropriately address any SSCs that fail to meet the specified requirements.
A. Bhatnagar 3. Approach on New Regulatory Requirements TVA plans to review the new regulatory requirements for applicability to BLN Units 1 and 2.
Through this review, TVA will address the elements of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor]
Edition, and NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan for New Site/Plant Applications, as they apply to the licensing and design of BLN Units 1 and 2. TVA also stated that it would seek opportunities to improve plant systems and design as part of this review.
Consistent with the policy statement, the staff will apply licensing standards in the same manner as when reviewing plants under active construction. As provided in the policy statement, any new staff positions will be applied to BLN Units 1 and 2 subject to 10 CFR 50.109, Backfitting, requirements. However, regulations that have applicability provisions built into them will be applied to BLN Units 1 and 2 without the use of the backfit rule taking into account the date of the original CP issuance and the existing OL application. If cases are identified where the current version of the Standard Review Plan addresses requirements or criteria not applicable to BLN Units 1 and 2, the staff will refer to the previous versions for guidance. The staff will also consider any alternative approaches to meeting regulatory requirements that TVA may propose.
- 4. Control of Activities Prior to Construction Reactivation TVA intends to perform walkdowns of plant SSCs and other activities necessary to further develop the licensing and engineering baseline, reestablish plant configuration control, address the preservice condition of SSCs, and prepare for any construction reactivation. TVA states that these activities will be controlled to avoid construction as described in 10 CFR 50.10, License Required; Limited Work Authorization. TVA plans to carry out these activities under an NRC-approved QA program for BLN Units 1 and 2.
The staff believes that the term construction, as defined in 10 CFR 50.10 is intended to address the work that can be performed without a CP but under a limited work authorization.
The staff determined that plant walkdown and configuration control activities are not considered construction activities and, therefore, can be performed prior to the 120-day staff notification as specified in the policy statement. TVA should develop adequate procedures to ensure that work activities performed at BLN during this period would only determine the current status of SSCs and do not further plant construction or completion. Under the policy statement, a description of the planned activities and procedural controls should be included in the QA program, which would be reviewed and approved by the NRC in accordance with 10 CFR 50.54(a)(3),
Appendix B to 10 CFR Part 50, and inspection procedures as appropriate. Further, TVA should not engage in any work activities that would preclude the NRC from identifying SSCs that may require special attention or performing inspections to verify that SSCs meet their quality and performance requirements.
A. Bhatnagar In summary, should it decide to reactivate construction, TVA should provide the information requested by the Commissions Policy Statement on Deferred Plants, including such aspects as identification of all remaining licensing issues, descriptions of changes to previously reviewed information, and descriptions of the proposed resolution of these issues, and submit an updated OL application that provides necessary information as required by 10 CFR 50.34, Contents of Applications; Technical Information.
Sincerely,
/RA/
Eric J. Leeds, Director Office of Nuclear Reactor Regulation Docket Nos. 50-438 and 50-439 cc: See next page
A.Bhatnagar In summary, should it decide to reactivate construction, TVA should provide the information requested by the Commissions Policy Statement on Deferred Plants, including such aspect as identification of all remaining licensing issues, descriptions of changes to previously reviewed information, and descriptions of the proposed resolution of these issues and submit an updated OL application that provides necessary information as required by 10 CFR 50.34.
Sincerely,
/RA/
Eric J. Leeds, Director Office of Nuclear Reactor Regulation Docket Nos. 50-438 and 50-439 cc: See next page DISTRIBUTION:
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DATE 07/26/10 07/20/10 07/22/10 08/03/10 08/ 04 /10 OFFICIAL AGENCY RECORD
Tennessee Valley Authority BELLEFONTE NUCLEAR PLANT cc:
Mr. Gordon P. Arent, Manager Mr. E. J. Vigluicci, Assistant General Counsel New Generation Licensing Tennessee Valley Authority Nuclear Generation Development 6A West Tower and Construction 400 West Summit Hill Drive Tennessee Valley Authority Knoxville, TN 37902 5A Lookout Place 1101 Market Street State Health Officer Chattanooga, TN 37402-2801 Alabama Dept. of Public Health P.O. Box 303017 Mr. J. A. Bailey, Vice President Montgomery, AL 36130-3017 New Generation Licensing Nuclear Generation Development Chairman and Construction Jackson County Commission Tennessee Valley Authority Courthouse 5A Lookout Place Scottsboro, AL 35752-0200 1101 Market Street Chattanooga, TN 37402-2801 Mr. R. M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. D. P. Pratt, General Manager Bellefonte Nuclear Plant Project Nuclear Generation Development and Construction 2744 Bellefonte Road, OSB 1A Hollywood, Alabama 35752 Mr. Z. W. Rad, Manager, Licensing Units 1 and 2, Bellefonte Nuclear Plant Nuclear Generation Development and Construction 2744 Bellefonte Road, OSB 1A Hollywood, Alabama 35752 Mr. Preston D. Swafford Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801