|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML18039A9021999-10-15015 October 1999 Forwards LER 99-010-00 Re Occurrence of Plant Reactor Scram Due to Main Turbine Trip Which Resulted in Main Steam Moisture Separator.All Plant Safety Systems Operated as Designed in Response to Event ML20217E0711999-10-14014 October 1999 Grants Approval for Util to Submit Original,One Signed Paper Copy & Six CD-ROM Copies of Updates to FSAR as Listed,Per 10CFR50.4(c),in Response to ML18039A8961999-10-14014 October 1999 Forwards LER 99-009-00,re Manual Reactor Scram on Unit 2 from 54% Power,Iaw 10CFR50.73(a)(2)(iv).All Plant Safety Sys Operated as Designed in Response to Event ML20217D3261999-10-0808 October 1999 Responds to Re Event Concerning Spent Fuel Pool Water Temperature Being Undetected for Approx Two Days at Browns Ferry Unit 3 ML20217F7751999-10-0808 October 1999 Confirms 991006 Telcon Between T Abney of Licensee Staff & a Belisle of NRC Re Meeting to Be Conducted on 991109 in Atlanta,Ga to Discuss Various Maintenance Issues ML18039A8931999-10-0808 October 1999 Forwards LER 99-008-00,concerning HPCI Sys Being Declared Inoperable,Iaw 10CFR50.73(a)(2)(v).There Are No Commitments Contained in Ltr ML18039A8881999-10-0808 October 1999 Provides Licensee Supplemental Response to NRC 980713 RAI Re GL 87-02,Suppl 1, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. ML20217B5481999-10-0101 October 1999 Requests Exception to 10CFR50.4(c) Requirement to Provide Total of Twelve Paper Copies When Submitting Revs to BFN UFSAR ML20212M1481999-09-28028 September 1999 Refers to Management Meeting Conducted on 990927 at Region II for Presentation of Recent Plant Performance.List of Attendees & Copy of Presentation Handout Encl ML20212F7751999-09-22022 September 1999 Requests Operator & Senior Operator License Renewals for Listed Individuals and Licenses ML20212D3651999-09-20020 September 1999 Forwards SE Accepting Licensee 990430 Proposed Rev to Plant, Unit 3 Matl Surveillance Program ML18039A8721999-09-10010 September 1999 Informs of Licensee Decision to Withdraw Proposed Plant risk-informed Inservice Insp Program,Originally Transmitted in Util 981023 Ltr.Licensee Expects to Resubmit Revised Program within Approx 6 Wks ML20211Q5731999-09-0909 September 1999 Submits Response to Administrative Ltr 99-03 Re Preparation & Scheduling of Operator Licensing Exams.Completed NRC Form 536,operator Licensing Exam Data,Which Provides Plant Current Schedules for Specific Info Requested Encl ML20211G6491999-08-26026 August 1999 Confirms Telcon with T Abney on 990824 Re Mgt Meeting Which Has Been re-scheduled from 990830-0927.Purpose of Meeting to Discuss BFN Status & Performance ML20210Q6931999-08-0909 August 1999 Forwards Updated Changes to Distribution Lists for Browns Ferry & Bellefonte Nuclear Plants ML18039A8371999-08-0606 August 1999 Forwards BFN Unit 2 Cycle 10 ASME Section XI NIS-1 & NIS-2 Data Repts, for NRC Review.Corrected Inservice Insp Summary Rept for Unit 3 Cycle 8 Operation,Included in Rept ML20210Q4421999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 991006. Authorized Representative of Facility Must Submit Ltr with List of Individuals to Take exam,30 Days Before Exam Date ML20210N1051999-08-0202 August 1999 Forwards SE Accepting Licensee 990326 Request for Relief from ASME B&PV Code,Section XI Requirements.Request for Relief 3-ISI-7,pertains to Second 10-year Interval ISI for Plant,Unit 3 ML20210G8991999-07-28028 July 1999 Discusses 990726 Open Mgt Meeting for Discussion on Plant Engineering Status & Performance.List of Attendees & Presentation Handout Encl ML18039A8181999-07-26026 July 1999 Forwards LER 99-004-00 Re Inoperability of Two Divisions of Plant CSS Due to Personnel Error During Surveillance Testing.Event Reported Per 10CFR50.73(a)(2)(i)(B) ML20210G8051999-07-22022 July 1999 Discusses DOL Case DC Smith Vs TVA Investigation.Oi Concluded That There Was Not Sufficient Evidence Developed During Investigation to Substantiate Discrimination.Nrc Providing Results of OI Investigation to Parties ML20210F3031999-07-22022 July 1999 Submits Rept Re Impact of Changes or Errors in Methodology Used to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.One Reportable non-significant Error Was Found During Time Period of 980601-990630 ML20209J0251999-07-16016 July 1999 Forwards SE Which Constitutes Staff Review & Approval of TVA Ampacity Derating Test & Analyses for Thermo-Lag Fire Barrier Configurations as Required in App K of Draft Temporary Instruction, Fpfi, ML20210B2671999-07-14014 July 1999 Confirms 990702 Telcon Between T Abney of Licensee Staff & Author Re Mgt Meeting Scheduled for 990830 at Licensee Request in Atlanta,Ga to Discuss Browns Ferry Nuclear Plant Status & Performance ML20209E3421999-07-0707 July 1999 Confirms Arrangements Made During 990628 Telephone Conversation to Hold Meeting on 990726 in Atlanta,Ga to Discuss Plant Engineering Status & Performance ML20209E5511999-07-0707 July 1999 Informs That as Result of NRC Review of Util Responses to GL 92-01,rev 1 & Suppl 1 & Suppl 1 Rai,Staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes TACs MA1180,MA1181 & MA1179 ML20196J3531999-06-30030 June 1999 Responds to Re Boeing Rocket Booster Mfg Facility Being Constructed in Decatur,Al.Nrc Has No Unique Emergency Planning Concerns Re Proximity of Boeing Facility to BFN ML20196G9111999-06-28028 June 1999 Discusses Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits ML18039A8081999-06-28028 June 1999 Forwards LER 99-004-00 Re Esfas That Occurred When RPS Motor Generator Tripped.Rept Is Submitted IAW Provisions of 10CFR50.73(a)(2)(iv) as Event of Condition That Resulted in Automatic Actuation of ESF ML18039A8111999-06-25025 June 1999 Requests Permanent Relief from Inservice Insp Requirements of 10CFR50.55a(g) for Volumetric Exam of Bfn,Unit 3 Circumferential RPV Welds,Per GL 98-05 ML20196F8741999-06-23023 June 1999 Forwards Safety Evaluation Accepting Util Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20196F8131999-06-22022 June 1999 Forwards Rev 24 to Security Personnel Training & Qualification Plan,Per 10CFR50.54(p).Rev Withheld ML18039A8051999-06-22022 June 1999 Forwards LER 99-003-00,re Automatic Reactor Scram Due to Turbine Trip.Rept Numbered 99-001 Should Be Deleted & Replaced with Encl Rept as Result of Error Noted in 990614 Rept ML18039A8031999-06-18018 June 1999 Responds to NRC Staff Verbal Request Re TS Change TS-376, Originally Submitted on 970312, & Proposed Changes to TS to Extend Current 7-day AOT for EDGs to 14 Days ML18039A7931999-06-0101 June 1999 Provides Summary of Major Activities Performed at BFN During Scheduled Unit 2 Cycle 10 Refueling Outage ML20195D3321999-06-0101 June 1999 Informs That Cb Fisher,License OP-5525-4,can No Longer Maintain License at Plant Because of Physical Condition That Causes Licensee to Fail to Meet Requirements of 10CFR55.21 ML18039A7911999-05-24024 May 1999 Informs That by Meeting Test Criteria Established by Test Based on Ansi/Ans 3.5-1985 (License Amends 254 & 214) power- Uprate Simulation Acceptable for Operator Training ML18039A7891999-05-24024 May 1999 Informs That Oscillation Power Range Monitor Module Has Been Enabled for Current Cycle of Operation Following Unit 2 Cycle 10 Refueling Outage Which Was Completed on 990509 ML20195B9361999-05-24024 May 1999 Informs That Do Elkins,License SOP-3392-6,no Longer Needs to Maintain License as Position Does Not Require License ML20206U6551999-05-14014 May 1999 Informs That ML Meek & Wd Dawson Will No Longer Need to Maintain SRO Licenses at Plant,Due to Termination of Employment,Effective 990521 ML20206Q8421999-05-10010 May 1999 Forwards Medical Info on DM Olive,License SOP-20540-2,in Response to NRC 990428 Telcon.Encl Withheld from Public Disclosure IAW 10CFR2.790(a)(6) ML18039A7771999-05-0606 May 1999 Forwards LER 99-003-00,providing Details Re Plant HPCI Sys Being Declared Inoperable Due to Loose Electrical Connection.Ltr Contains No Commitments ML20206G6611999-05-0404 May 1999 Forwards SE Accepting GL 88-20,submitted by TVA Re multi-unit Probabilistic Risk Assessement (Mupra) for Plant, Units 1,2 & 3 ML18039A7741999-04-30030 April 1999 Forwards Proposed Rev to BFN Unit 3 RPV Matl Surveillance Program,For NRC Approval ML20206H5901999-04-30030 April 1999 Forwards Notification of Revs to BFN Unit 2 Emergency Response Data Sys Data Point Library.Revs Were Implemented on 990413 DD-99-06, Informs That Time Provided by NRC within Which Commission May Act to Review Director'S Decision (DD-99-06) Has Expired.Decision Became Final Agency Action on 990423.With Certificate of Svc.Served on 9904281999-04-28028 April 1999 Informs That Time Provided by NRC within Which Commission May Act to Review Director'S Decision (DD-99-06) Has Expired.Decision Became Final Agency Action on 990423.With Certificate of Svc.Served on 990428 ML18039A7681999-04-27027 April 1999 Requests Relief from Specified Inservice Insp Requirements in Section XI of ASME Boiler & Pressure Vessel Code,Per 10CFR50.55a(a)(3)(i).Relief Requests 2-ISI-8 & 3-ISI-8,encl for NRC Review & Approval ML18039A7591999-04-27027 April 1999 Forwards Annual Radiological Environ Operating Rept Browns Ferry Nuclear Plant 1998. Rept Includes Results of Land Use Censuses,Summarized & Tabulated Results of Radiological Environ Samples in Format of Reg Guide 4.8 & NUREG-1302 ML18039A7651999-04-27027 April 1999 Forwards Rev 0 to TVA-COLR-BF2C11, Browns Ferry Nuclear Plant Unit 2,Cycle 11 Colr. ML18039A7541999-04-23023 April 1999 Requests Approval of Bfnp Unit 3 Risk-Informed ISI (RI-ISI) Program,Per 10CFR50.55(a)(3)(i) & GL 88-01.Encl RI-ISI Program Is Alternative to Current ASME Section XI ISI Requirments for Code Class 1,2 & 3 Piping 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18039A9021999-10-15015 October 1999 Forwards LER 99-010-00 Re Occurrence of Plant Reactor Scram Due to Main Turbine Trip Which Resulted in Main Steam Moisture Separator.All Plant Safety Systems Operated as Designed in Response to Event ML18039A8961999-10-14014 October 1999 Forwards LER 99-009-00,re Manual Reactor Scram on Unit 2 from 54% Power,Iaw 10CFR50.73(a)(2)(iv).All Plant Safety Sys Operated as Designed in Response to Event ML18039A8881999-10-0808 October 1999 Provides Licensee Supplemental Response to NRC 980713 RAI Re GL 87-02,Suppl 1, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. ML18039A8931999-10-0808 October 1999 Forwards LER 99-008-00,concerning HPCI Sys Being Declared Inoperable,Iaw 10CFR50.73(a)(2)(v).There Are No Commitments Contained in Ltr ML20217B5481999-10-0101 October 1999 Requests Exception to 10CFR50.4(c) Requirement to Provide Total of Twelve Paper Copies When Submitting Revs to BFN UFSAR ML20212F7751999-09-22022 September 1999 Requests Operator & Senior Operator License Renewals for Listed Individuals and Licenses ML18039A8721999-09-10010 September 1999 Informs of Licensee Decision to Withdraw Proposed Plant risk-informed Inservice Insp Program,Originally Transmitted in Util 981023 Ltr.Licensee Expects to Resubmit Revised Program within Approx 6 Wks ML20211Q5731999-09-0909 September 1999 Submits Response to Administrative Ltr 99-03 Re Preparation & Scheduling of Operator Licensing Exams.Completed NRC Form 536,operator Licensing Exam Data,Which Provides Plant Current Schedules for Specific Info Requested Encl ML20210Q6931999-08-0909 August 1999 Forwards Updated Changes to Distribution Lists for Browns Ferry & Bellefonte Nuclear Plants ML18039A8371999-08-0606 August 1999 Forwards BFN Unit 2 Cycle 10 ASME Section XI NIS-1 & NIS-2 Data Repts, for NRC Review.Corrected Inservice Insp Summary Rept for Unit 3 Cycle 8 Operation,Included in Rept ML18039A8181999-07-26026 July 1999 Forwards LER 99-004-00 Re Inoperability of Two Divisions of Plant CSS Due to Personnel Error During Surveillance Testing.Event Reported Per 10CFR50.73(a)(2)(i)(B) ML20210F3031999-07-22022 July 1999 Submits Rept Re Impact of Changes or Errors in Methodology Used to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.One Reportable non-significant Error Was Found During Time Period of 980601-990630 ML18039A8081999-06-28028 June 1999 Forwards LER 99-004-00 Re Esfas That Occurred When RPS Motor Generator Tripped.Rept Is Submitted IAW Provisions of 10CFR50.73(a)(2)(iv) as Event of Condition That Resulted in Automatic Actuation of ESF ML18039A8111999-06-25025 June 1999 Requests Permanent Relief from Inservice Insp Requirements of 10CFR50.55a(g) for Volumetric Exam of Bfn,Unit 3 Circumferential RPV Welds,Per GL 98-05 ML20196F8131999-06-22022 June 1999 Forwards Rev 24 to Security Personnel Training & Qualification Plan,Per 10CFR50.54(p).Rev Withheld ML18039A8051999-06-22022 June 1999 Forwards LER 99-003-00,re Automatic Reactor Scram Due to Turbine Trip.Rept Numbered 99-001 Should Be Deleted & Replaced with Encl Rept as Result of Error Noted in 990614 Rept ML18039A8031999-06-18018 June 1999 Responds to NRC Staff Verbal Request Re TS Change TS-376, Originally Submitted on 970312, & Proposed Changes to TS to Extend Current 7-day AOT for EDGs to 14 Days ML18039A7931999-06-0101 June 1999 Provides Summary of Major Activities Performed at BFN During Scheduled Unit 2 Cycle 10 Refueling Outage ML20195D3321999-06-0101 June 1999 Informs That Cb Fisher,License OP-5525-4,can No Longer Maintain License at Plant Because of Physical Condition That Causes Licensee to Fail to Meet Requirements of 10CFR55.21 ML20195B9361999-05-24024 May 1999 Informs That Do Elkins,License SOP-3392-6,no Longer Needs to Maintain License as Position Does Not Require License ML18039A7911999-05-24024 May 1999 Informs That by Meeting Test Criteria Established by Test Based on Ansi/Ans 3.5-1985 (License Amends 254 & 214) power- Uprate Simulation Acceptable for Operator Training ML18039A7891999-05-24024 May 1999 Informs That Oscillation Power Range Monitor Module Has Been Enabled for Current Cycle of Operation Following Unit 2 Cycle 10 Refueling Outage Which Was Completed on 990509 ML20206U6551999-05-14014 May 1999 Informs That ML Meek & Wd Dawson Will No Longer Need to Maintain SRO Licenses at Plant,Due to Termination of Employment,Effective 990521 ML20206Q8421999-05-10010 May 1999 Forwards Medical Info on DM Olive,License SOP-20540-2,in Response to NRC 990428 Telcon.Encl Withheld from Public Disclosure IAW 10CFR2.790(a)(6) ML18039A7771999-05-0606 May 1999 Forwards LER 99-003-00,providing Details Re Plant HPCI Sys Being Declared Inoperable Due to Loose Electrical Connection.Ltr Contains No Commitments ML20206H5901999-04-30030 April 1999 Forwards Notification of Revs to BFN Unit 2 Emergency Response Data Sys Data Point Library.Revs Were Implemented on 990413 ML18039A7741999-04-30030 April 1999 Forwards Proposed Rev to BFN Unit 3 RPV Matl Surveillance Program,For NRC Approval ML18039A7681999-04-27027 April 1999 Requests Relief from Specified Inservice Insp Requirements in Section XI of ASME Boiler & Pressure Vessel Code,Per 10CFR50.55a(a)(3)(i).Relief Requests 2-ISI-8 & 3-ISI-8,encl for NRC Review & Approval ML18039A7591999-04-27027 April 1999 Forwards Annual Radiological Environ Operating Rept Browns Ferry Nuclear Plant 1998. Rept Includes Results of Land Use Censuses,Summarized & Tabulated Results of Radiological Environ Samples in Format of Reg Guide 4.8 & NUREG-1302 ML18039A7651999-04-27027 April 1999 Forwards Rev 0 to TVA-COLR-BF2C11, Browns Ferry Nuclear Plant Unit 2,Cycle 11 Colr. ML20206C8591999-04-23023 April 1999 Informs That Util Has Determined,Dr Bateman No Longer Needs to Maintain His License,Effective 990331,per Requirement of 10CFR55.55(a) ML18039A7541999-04-23023 April 1999 Requests Approval of Bfnp Unit 3 Risk-Informed ISI (RI-ISI) Program,Per 10CFR50.55(a)(3)(i) & GL 88-01.Encl RI-ISI Program Is Alternative to Current ASME Section XI ISI Requirments for Code Class 1,2 & 3 Piping ML18039A7581999-04-23023 April 1999 Responds to Item 4 of 981117 RAI Re TS Change Request 376 Re Extended EDG Allowed Outage Time,In Manner Consistent with Rgs 1.174 & 1.177 ML20206C1241999-04-21021 April 1999 Forwards Annual Occupational Radiation Exposure Rept for 1998, IAW TS Section 5.6.1.Rept Reflects Radiation Exposure Data as Tracked by Electronic Dosimeters on Radiation Work Permits ML20205T0971999-04-15015 April 1999 Submits Change in Medical Status for DM Olive in Accordance with 10CFR55.25,effective 990315.Encl Medical Info & Certification of Medical Exam,Considered by Util to Be of Personal Nature & to Be Withheld,Per 10CFR2.790(a)(6) ML18039A7441999-04-0707 April 1999 Forwards LER 99-001-00,providing Details Re Inoperability of Two Trains of Standby Gas Treatment Due to Breaker Trip on One Train in Conjunction with Planned Maint Activities on Other.Ltr Contains No New Commitments ML18039A7431999-03-30030 March 1999 Responds to NRC 990112 RAI Re BFN Program,Per GL 96-05, Periodic Verification of Design-Basis Capability of Safety- Related Movs. ML18039A7421999-03-30030 March 1999 Provides Results of Analysis of Design Basis Loca,As Required by License Condition Re Plants Power Uprate Operating License Amends 254 & 214 ML18039A7411999-03-30030 March 1999 Provides Partial Response to NRC 981117 RAI Re TS Change Request 376,proposing to Extend Current 7 Day AOT for EDG to 14 Days ML18039A7371999-03-26026 March 1999 Requests Relief from Specified ISI Requirements in Section XI of ASME Boiler & Pressure Vessel Code,1989 Edition.Encl Contains Request for Relief 3-ISI-7,for NRC Review & Approval ML18039A7331999-03-26026 March 1999 Forwards Rev 4 to TVA-COLR-BF2C10, Bnfp,Unit 2,Cycle 10 COLR, IAW Requirements of TS 5.6.5.d.COLR Was Revised to Extend Max Allowable Nodal Exposure for GE GE7B Fuel Bundles ML18039A7291999-03-22022 March 1999 Forwards Revised Epips,Including Index,Rev 26A to EPIP-1, Emergency Classification Procedure & Rev 26A to EPIP-5, General Emergency. Rev 26A Includes All Changes Made in Rev 26 as Well as Identified Errors ML20204G8471999-03-19019 March 1999 Reports Change in Medical Status for Ma Morrow,In Accordance with 10CFR55.25.Encl Medical Info & Certification of Medical Exam,Considered by Util to Be of Personal Nature & to Be Withheld from Pdr,Per 10CFR2.790(a)(6).Without Encl ML20207M0611999-03-11011 March 1999 Forwards Goals & Objectives for May 1999 for Browns Ferry Nuclear Plant,Units 1,2 & 3,radiological Emergency Plan Exercise.Plant Exercise Is Currently Scheduled for Wk of 990524 ML18039A6971999-02-22022 February 1999 Forwards Typed TS Pages,Reflecting NRC Approved TS Change 354 Requiring Oscillation PRM to Be Integrated Into Approved Power uprate,24-month Operating Cycle & Single Recirculation Loop Operation ML18039A6961999-02-19019 February 1999 Provides Util Response to GL 95-07 Re RCIC Sys Injection Valves (2/3-FCV-71-39) for BFN Units 2 & 3.Previous Responses,Dtd 951215,1016 & 960730,0315 & 0213,supplemented ML18039A6911999-02-19019 February 1999 Forwards Rev 3 to Unit 2 Cycle 10 & Rev 1 to Unit 3 Cycle 9, Colr.Colrs for Each Unit Were Revised to Include OLs Consistent with Single Recirculation Loop Operation ML20203B6031999-02-0404 February 1999 Requests Temporary Partial Exemption from Requirements of 10CFR50.65,maint Rule for Unit 1.Util Requesting Exemption to Resolve Issue Initially Raised in NRC Insp Repts 50-259/97-04,50-260/97-04 & 50-296/97-04,dtd 970521 ML18039A6741999-01-21021 January 1999 Responds to NRC 981209 Ltr Re Violations Noted in Insp Repts 50-259/98-07,50-260/98-07 & 50-296/98-07,respectively. Corrective Actions:Will Revise Procedure NEPD-8 Re Vendor Nonconformance Documentation Submission to TVA ML20199F6951999-01-0808 January 1999 Submits Request for Relief from ASME Section XI Inservice Testing Valve Program to Extend Interval Between Disassembly of Check Valve,Within Group of Four Similar Check Valves for EECW Dgs,From 18 to 24 Months 1999-09-09
[Table view] |
Text
1A Tennessee Valley Authority, Post Office Box 2000. Decatur, Alabama 35609 October 18, 1996 10 CFR 2.790(a) (4) 10 CFR 2.790 (b) (1)
U.S. Nuclear Regulatory Commission ATTN: acument Control Desk Wash:: .or., D.L. 20555 Gentlemen:
In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS PERRY NUCLEAR PLANT (BFN) - REVISED CALCULATIONS FOR TECHNICAL SPECIFICATION (TS) 356 AND COST BENEFICIAL LICENSING ACTION (CBLA) 08 - INCREASE IN ALLOWABLE MAIN STEAM ISOLATION VALVE (MSIV) LEAKAGE RATE This letter provides revised calculations to EToport proposed TS 356, Increase in Allowable MSIV Leakage Rate.
TS 356 originally was submitted on December 22, 1995, with supporting calculations provided on April 12, 1996. A i revision to the calculations was necessary due to an error in the calculation of the mean free path of steam Uhich also resulted in an error in the rate of deposition of particulate in the steam lines. The revised calculations resulted in no change in assumed MSIV leak rate with no ccedit for additional plant systems, structures, and/or
, components. Enclosure 1 contains the revision to the
~
calculations. These calculations contain information proprietary to Polestar Applied Technology Inc. Polestar requests that these calculations be withheld from public disclosure in accordance with 10 CFR 2.790(a) (4) . Enclosure 2 contains an affidavit supporting this request in accordance with 10 CFR 2.790(b) (1) . The non-proprietary calculations are provided as Enclosure 3.
I C40064 X t g$up.PM @ i w' w lN
" [
9610250075 961018 PDR ADOCK 05000259 P PDR
t U.S. Nuclear Regulatory Commission Page 2 October 18, 1996 There are no new commitments contained in this letter. If you have any questions, please contact me at (205) 729-2636. ,
Sincerely, ,
/i !
1 '
Ns _,kdys .
)
T. E. Abney i Manager of Lice '
and Industry (Affa rs cc (Enclosures):
Mr. Johnny Black, Chairman (Enclosure 3 only)
Limestone County Commisrion 310 West Washington Street Athens, Alabama 35611 Mr. Mark S. Lesser, Section Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC. Resident Inspector Browns Ferry Nuclear Plant j Route 12, Box 637 l Athens, Alabama 35611 Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson (Enclosure 3 only)
State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017 i
i
? ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) 356, INCREASE IN ALLOWABLE MAIN STEAM ISOLATION VALVE (MSIV) LEAKAGE RATE i CONTROL ROOM OPERATOR AND OFFSITE DOSE PROPRIETARY CALCULATIONS - REVISION 2 '
, l l
1 (SEE ATTACHED) i i l
- 1 4
a 1 I
I
. - . . . - .~. . . . . . . _ _ - - .. .-. - .-. .- . - . ._. .. . _ _ - _
a ENCLOSURE 2 i
TENNESSEE VALLEI A'JTHORITY BROWN 8 FERRY NUCLEAR PLANT (BFN) l UNITS 1, 2, A1TD 3 i TECHNICAL SPECIFICATIONS (TS) 356, INCREASE IN l ALLOWABLE NAIN STEAN ISOLATION VALVE (NSIV) LEAKAGE 1 RATE l CONTROL ROON OPERATOR AND OFF8ITE DOSE PROPRIETARY
, CALCULATIONS - REVISION 2 - AFFIDAVIT I
i j (SEE ATTACHED)
?
l
.. .-. ~ - - . . - _ _. . - _ . _ _ _ .
l I
ENCLOSURE 3 I 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) 356, INCREASE IN ALLOWABLE MAIN STEAN ISOLATION VALVE (NSIV) LEAKAGE RATE CONTROL ROON OPERATOR AND OFFSITE DOSE CALCULATIONS -
REVISION 2 (NON-PROPRIETARY VERSIONS)
(SEE ATTACHED) i l
l 1
I J
! I i
ENCLOSURE 2 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1,2, AND 3 TECHNICAL SPECIFICATIONS (TS) 356, INCREASE IN ALLOWABLE MAIN STEAM ISOLATION VALVE (MSIV) LEAKAGE RATE CONTROL ROOM OPERATOR AND OFFSITE DOSE PROPRIETARY CALCULATIONS - REVISION 2 - AFFIDAVIT (SEE ATTACHED) l l
l I
1 MM' "T* ~ ~
Polestar Applied Technology,Inc.
AFFIDAVIT I, David E.W. Leaver, being duly sworn, depose and state as follows:
(1) I am a Principal and an Officer of Polestar Applied Technology, Inc.
(" Polestar") and am responsible for the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the following Polestar reports and calculations prepared for TVA in support of the Browns Ferry application of the revised design basis accident source term:
(a) The Polestar proprietary report PSAT 04000U.04, " Calculation Package for Application of the Revised DBA Source Term to the Browns Ferry Nuclear Power Plant," dated February,1995, including the following:
- Attachment 1, Calculation of Containment Leakage Doses for ,
Browns Ferry, pages 8-11, pages 14-25, page 37, Appendices A-D
- Attachment 3, PSAT 04011H.01, pages 9-17, pages C2-C4, pages C8-C11
- Attachment 4, PSAT 04001H.02, pages 8-10, Appendices A-D
- Attachment 6, PSAT 04011H.04, page 4
- Attachment 10, PSAT 04002H.08, pages 8-10, Appendices A-C (b) The Polestar proprietary calculation PSAT 04101F.02, Calculation of Fraction of Containment Aerosol Deposited in Water, pages 5-6 (c) The Polestar proprietary calculation PSAT 04101F.03, The ppm Boron in Browns Ferry containment Water Pool, pages 4-6 (d) The Polestar proprietary calculation PSAT 04101F.04, Browns Ferry Containment Water Pool pH, pages 5-41 (3) In making this application for withholding of proprietary information of which it is the owner, Polestar relies upon the exemption from disclosure set forth in the NRC regulations 10 CFR 9.17(a)(4),2.790(a)(4), and 2.790(d)(1) for
" trade secrets and commercial or financial information obtained from a 1
i l
ONE FRst STREET . Suric 4 . Los altos . C AumoRNIA . 940' 22 . US A . TEL 415-948-6242 . FA. 415 948-8244 l
person and privileged or confidential" (Exemption 2.790(a)(4)). The material for which exemption from disclosure is here sought is all " confidential commercial information".
(4) Some examples of categories of information which fit into the definition of ;
proprietary information are: l
- a. Information that discloses a process or method, including supporting data l and analyses, where prevention of its use by Polestar's competitors !
without license from Polestar constitutes a competitive economic advantage over other companies.
l
- b. Information which,if used by a competitor, would significantly reduce his I expenditure of resources or Nnprove his competitive position in the analysis, design, assurance or quality, or licensing of a similar product;
- c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of Polestar, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future Polestar customer-funded development plans and programs, of potential commercial value to Polestar;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a and (4)b, above.
(5) The information sought to be withheld is being submitted to TVA (and, we trust, to NRC) in confidence. The information is of a sort customarily held in confidence by Polestar, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Polestar, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to 2
industry knowledge. Distribution of such documents within Polestar is ,
limited to those with a need to know.
(7) The approval of external release of such a document typically requires review by the project manager, and the Polestar Principal closest to the work, for j technical content, competitive effect, and determination of the accuracy of the ;
proprietary designation. Disclosures outside Polestar are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and ;
licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed information on models in current software which were developed by Polestar and are justified from numerous benchmark exercises and applications, detailed results of these models and analytical methods, and computer codes which Polestar has developed, documented, and is maintaining under the Polestar 10 CFR 50, Appendix B Quality Assurance Program. The model results are from applications of the revised l~
DBA source term to the Browns Ferry Nuclear Plant in support of TVA.
The development and documentation of the methods, models, and associated Polestar computer codes used in these analyses was achieved at a significant ;
cost to Polestar, on the order of $50,000, which is a significant fraction of internal research and development resources available to a company the size of Polestar.
The development of the models and methods, along with the interpretation and application of the results,is derived from the extensive experience -
database that constitutes a major Polestar asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Polestar's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Polestar's comprehensive technology base on application of the revised source term to operating plants and advanced light water reactors, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with methods which have been developed and are being maintained in accordance with 10 CFR 50, Appendix B requirements.
The research, development, engineering, analytical and review costs comprise a substantial investment of time and money by Polestar.
3 1
l l
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
Polestar's competitive advantage will be lost if its competitors are able to use ,
the results of the Polestar experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demons"ating ,
that they can arrive at the same or similar conclusions.
The value of this information to Polestar would be lost if the information ;
were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Polestar of the opportunity to exercise its competitive advantage ;
to seek an adequate return on its relatively large investment in developing '
these very valuable analytical tools.
f l
l l
j 4
l l
STATE OF CALIFORNIA )
) ss:
COUNTY OF SANTA CLARA )
David E.W. Leaver,is being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and I correct to the best of his knowledge, information, and belief.
Executed at Los Altos, California, this 1996.
/I day of I%
l David E.W. Leaver Polestar Applied Technology, Inc.
Subscribed and sworn before me this /9 day of A 1996.
/ ~/ l N,
a Q t
j Notav Mcanc ~ nf .
e J
8 w e "o'a cero com,oen*
y - Nota Public, State of California
_ _ m ExAre8...,oct8.1999 f 5
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1,2, AND 3 TECHNICAL SPECIFICATIONS (TS) 356, INCREASE IN ALLOWABLE MAIN STEAM ISOLATION VALVE (MSIV) LEAKAGE RATE CONTROL ROOM OPERATOR AND OFFSITE DOSE CALCULATIONS -
REVISION 2 (NON-PROPRIETARY VERSIONS)
(SEE ATTACHED) n s
J