ML101970086

Licensing Basis Preservation Program

ML101970086
Person / Time
Site:	Watts Bar
Issue date:	07/15/2010
From:	Bajestani M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
25402-3DP-G04G-00081, Rev 008, TAC MD6581
Download: ML101970086 (9)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 July 15, 2010 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391

Subject:

Watts Bar Nuclear Plant (WBN) Unit 2 - Licensing Basis Preservation Program (TAC No. MD6581)

References:

1. NRC Letter to TVA dated April 28, 2009, Watts Bar Nuclear Plant, Unit 2 - Request for Additional Information on Programs for Licensing Basis Preservation and Construction Refurbishment (TAC No.

MD6581)

2. TVA Letter to NRC dated September 8, 2009, Response to Request for Additional Information on Programs for Licensing Basis Preservation and Construction Refurbishment (TAC No. MD6581)

The purpose of this letter is to provide the U.S. Nuclear Regulatory Commission (NRC) excerpts from Watts Bar Nuclear Plant Unit 2 (WBN-2) Construction Completion Project, Engineering Department Procedure Instruction 25402-3DP-G04G-00081, Engineering Document Construction Release, Revision 008. This procedure defines the work process for the preparation, review, approval, issuance, management, and control of the engineering-related Engineering Document Construction Release deliverables needed for installing permanent equipment and materials or in support of temporary construction activities at WBN-2.

By letter dated April 28, 2009 (Reference 1), the NRC requested additional information on programs for Licensing Basis Preservation and Construction Refurbishment at WBN-2. In response to the NRC request for additional information, TVA provided excerpts from Procedure 25402-3DP-G04G-00081, Revision 002 (Reference 2). The excerpts contained a set of questions that provided an in-depth evaluation of the potential for a design package to affect the licensing basis.

u.s. Nuclear Regulatory Commission Page 2 July 15, 2010 Following the Reference 2 submittal, TVA refined the procedure to include a screening process. The screening process is designed to identify design packages that do not have the potential to affect the licensing basis for WBN-2. Packages identified by the screening process as not having the potential to affect the licensing basis are not reviewed against the in-depth questions. The enclosure to this letter contains Attachment J, "Licensing Basis Preservation Review Form (Typical)," to Procedure 25402-3DP-G04G-00081, "Engineering Document Construction Release," Revision 008, which provides both the screening criteria and the in-depth Licensing Basis Preservation questions.

TVA has performed a self-assessment of both the screening process and the in-depth review process. The assessment concluded that the process has been effective in identifying whether the NRC-approved licensing basis has been impacted by the construction completion effort at WBN-2. The assessment identified two issues associated with the implementation of the process. It was identified that in some cases the completed forms were not permanently stored with the design change package.

Secondly, it was identified that the reviews were not consistently updated to address revisions to the parent design change package when the package was revised by a Field Change Request. Both of these issues have been entered into the TVA Corrective Action Program.

There are no regulatory commitments associated with this submittal. If you have any questions, please contact William Crouch at (423) 365-2004.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 15th day of July 2010.

Sincerely, 1'1, 1J{)4~~

Masoud:lfintani Watts B-l;Jt 2 Vice President

Enclosure:

1. Watts Bar Nuclear Plant Unit 2 Construction Completion Project, Engineering Department Procedure Instruction 25402-3DP-G04G-00081, "Engineering Document Construction Release," Revision 008, Attachment J, "Licensing Basis Preservation Review Form (Typical)"

U.S. Nuclear Regulatory Commission Page 3 July 15, 2010 cc (Enclosure):

U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381

Enclosure Watts Bar Nuclear Plant Unit 2 Construction Completion Project Engineering Department Procedure Instruction 25402-3DP-G04G-00081 Engineering Document Construction Release Revision 008 Attachment J, Licensing Basis Preservation Review Form (Typical)

EDCR No: _________

ATTACHMENT J LICENSING BASIS PRESERVATION REVIEW FORM (TYPICAL)

The Attachment J screening shall be performed for each EDCR to ensure: (1) the WBN Unit 2 licensing basis is implemented in the same manner to obtain the same conclusion as the corresponding Unit 1 licensing basis issues identified in NGDC PP-20, to the maximum extent practical, and (2) the WB2CCP construction activities do not invalidate or undo previous WBN Unit 1 licensing basis conclusions in NGDC PP-20.

Section 1 Screening Section 1 provides the screening methodology to determine whether or not NGDC PP-20 Attachments ents 1 through 4 are affected by this EDCR.

1a. Is this a Documentation Only EDCR?

YES NO If question 1a. is answered YES, then:

x Enter Not Applicable in Sections 2 through 9 x DE, TE, and respective EGS shall sign in Section 1f x Forward a copy of Attachment J to Unit 2 Bechtel Engineering Engineerin Licensing x Signatures are not required in Section 10 If question 1a. is answered NO, then continue ue to 1b.

Provide a basis for your response.

1b. Is this design functionally ctionally equequivalent to that of Unit 1?

YES NO N

Provide a basis for your yo response.

1c. Does this Unit 2 design fully comply with all design standards, processes, and general specifications?

(This means, have any exceptions been taken to any of the design standards, processes, or general specifications?) If there are no exceptions listed as part of the EDCR, the answer to this question is YES.

YES NO Provide a basis for your response.

Refer to the electronic documents in TVA Business Support Library (BSL) for current revision.

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EDCR No: _________

ATTACHMENT J LICENSING BASIS PRESERVATION REVIEW FORM (TYPICAL)

Section 1 Screening (continued)

Section 1 provides the screening methodology to determine whether or not NGDC PP-20 Attachments 1 through 4 are affected by this EDCR.

1d. Any NO response to Questions 1b., or 1c. will require the DE and TE to sign Section 1f. and forward the Attachment J (include EDCR Work Scope, EDCR Technical Evaluation, and the EDCR Unit Difference Form), to Unit 2 Bechtel Engineering Licensing for the completion of Sections 2 through 9 9.

1e. If the response to Questions 1b., and 1c. is YES, then:

x Enter Not Applicable in Sections 2 through 9 x DE, TE, and respective EGS shall sign in Section 1f.

x Forward a copy of Attachment J to Unit 2 Bechtel Engineering Licensing x Signatures are not required in Section 10 1f.

DE Print ___________________DE Signature _______________________Date ________ ______________

TE Print ___________________TE Signature _______________________Date ________ ______________

EGS Supervisor Print _________________EGS EGS Supervisor Supervi Signature __________________Date Unit 2 Bechtel Engineering Licensing ing and appropriate appro CAP/SP owners are also qualified to complete Sections 1a. through 1f. (except for the EGS S Supervisor Superv signature). However, at least one DE or TE signature (or both) is required in Section 1f.

Refer to the electronic documents in TVA Business Support Library (BSL) for current revision.

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EDCR No: _________

ATTACHMENT J LICENSING BASIS PRESERVATION REVIEW FORM (TYPICAL)

Section 2 Identify document(s) and sections, if applicable, to each of the following:

a. Nuclear Performance Plan (NPP) Corrective Action Program/Plans (CAPs)/Special Programs (SPs) -

Reference NGDC PP-20, Attachment 4.

Response

b. Generic Communications Master Table (Generic Letter, IE Bulletin, IE Circular, NUREG-0737, G-0737, etc.) -

Reference NGDC PP-20, Attachment 3.

Response

c. List of Unit 1 Exemptions, Reliefs, and Other Actions - Reference ence NGDC PP-20, PP-20 Attachment 2.

Response

For each document/section associated with the questions Sections 3 through 8 that are answered Yes, tions in S provide a response to the question in Section 9.

Section 3 Does the EDCR impact or invalidate a previo previous NRC review within the WBN Unit 1 Safety Evaluation Report (NUREG-0847) and its Supplements ments causing cau the status of an item in the TVA Regulatory Framework Letter to change?

YES NOO If yes, identify dentify the specific spe document (Section(s), figure(s), and table(s) here:

Section n4 Does the EDCR differ from the original Unit 1 modification such that it impacts or invalidates a previous NRC review within the WBN Unit 1 Safety Evaluation Report (NUREG-0847) and its Supplements causing the status of an item in the TVA Regulatory Framework Letter to change?

YES NO If yes, identify the specific document (Section(s), figure(s), and table(s) here:

Refer to the electronic documents in TVA Business Support Library (BSL) for current revision.

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EDCR No: _________

ATTACHMENT J LICENSING BASIS PRESERVATION REVIEW FORM (TYPICAL)

Section 5 Does the EDCR for multi-unit operation impact or invalidate a previous NRC review within the WBN Unit 1 Safety Evaluation Report (NUREG-0847) and its Supplements causing the status of an item in the TVA Regulatory Framework Letter to change?

YES NO If yes, identify the specific document (Section(s), figure(s), and table(s) here:

Section 6 Does the EDCR involve any of the Nuclear Performance Plan Corrective Action Program Plans/Special P Program Plans (identified in Item a of Section 2) approved by the NRC for Unit 2 such that it impacts or invalidates a previous NRC review in their February 11, 2009 Letter causing sing the status of an item in the TVA Regulatory Framework Letter to change?

YES NO If yes, identify the specific document (Section(s), figure(s), re(s), and table(s) here:

Section 7 Does the EDCR impact or invalidate e a Generic Gene Communications Master Table document (identified in Item b of Section 2) previously reviewed and approved appro by NRC causing a status of an item in the TVA Regulatory Framework Letter to change?an e?

YES NO O

If yes, identifyy the specific spe document (Section(s), figure(s), and table(s) here:

Section n8 Does the EDCR involve an exemption, relief, or other actions (identified in Item c of Section 2) that were not previously reviewed and approved by the NRC for WBN Unit 2?

YES NO If yes, identify the specific document (Section(s), figure(s), and table(s) here:

Refer to the electronic documents in TVA Business Support Library (BSL) for current revision.

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EDCR No: _________

ATTACHMENT J LICENSING BASIS PRESERVATION REVIEW FORM (TYPICAL)

Section 9 How does the EDCR differ from the information identified in Sections 3 through Section 8?

Use separate paragraphs for each affected document/section. Include the section number and document number (section(s), figure(s), and table(s)).

Example: A Yes response to the GL 89-10 document addressed in Section 7 would equate to o a response title titl of Section 7, GL 89-10 in the Responses to Section 9: area of this form.

Responses to Section 9:

Section No._________ Document No._________

Use continuation sheets as required.

Section 10 Unit 2 Bechtel Engineering Licensing nsing signature sign Preparer Signature: ___________________Preparer

__________ Print_________________ Date ________

Reviewer Signature:

gnature: ___________________Reviewer

____ Print_________________ Date ________

When hen two or mmore of questions 1a., 1b., or 1c. are answered NO, ONLY Unit 2 Bechtel Engineering Licensing, nsing with input from CAP/SP Owners, is qualified to complete Sections 2 through 10.

Note: Include a copy of Attachment J in the EDCR package and provide a copy to Unit 2 Bechtel Engineering Licensing.

Reference Section

1. Final Safety Analysis Report (FSAR)

2. Technical Specifications (and Bases), Technical Requirements Manual (and Bases)

3. WBN Unit 1 Safety Evaluation Report (NUREG-0847 and Supplements)

4. NGDC PP-20, Licensing Basis Preservation

5. NRC Letter, Status of Regulatory Framework for the Completion of Corrective Action and Special Programs and Unresolved Safety Issues, February 11, 2009 Refer to the electronic documents in TVA Business Support Library (BSL) for current revision.

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