ML11217A107

Watts Bar, Unit 2 - Request for Additional Information Regarding Final Safety Analysis Report Amendment Related Section 3.11 - Revised Response

ML11217A107
Person / Time
Site:	Watts Bar
Issue date:	08/03/2011
From:	Stinson D Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME2731
Download: ML11217A107 (5)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000August 3, 2011 10 CFR 50.4(b)(6)10 CFR 50.34(b)10 CFR 2.390(d)(1)U.S. Nuclear Regulatory CommissionATTN: Document Control DeskMail Stop: OWFN P1-35Washington, D.C. 20555-0001Watts Bar Nuclear Plant, Unit 2NRC Docket No. 50-391

Subject:

Watts Bar Nuclear Plant, Unit 2 -Request for Additional Information (RAI)Regarding Final Safety Analysis Report Amendment Related Section 3.11Revised Response (TAC No. ME2731)

Reference:

1. Letter from TVA to NRC, "Watts Bar Nuclear Plant, Unit 2 -Request forAdditional Information (RAI) Regarding Final Safety Analysis ReportAmendment Related Section 3.11 (TAC No. ME2731)," datedSeptember 1, 2010 [ML102500170]Reference 1 provided a response to RAI 3.11-2. Enclosure 1 to this letter provides a revisedresponse to RAI 3.11-2.There are no new regulatory commitments contained in this letter. If you have any questions,please contact Bill Crouch at (423) 365-2004.I declare under penalty of perjury that the foregoing is true and correct. Executed on the3rd day of August, 2011.Respectfully,David StinsonWatts Bar Unit 2 Vice President U.S. Nuclear Regulatory CommissionPage 2August 3, 2011

Enclosure:

1. Revised Response to RAI 3.11-2cc (Enclosure):U. S. Nuclear Regulatory CommissionRegion IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257NRC Resident Inspector Unit 2Watts Bar Nuclear Plant1260 Nuclear Plant RoadSpring City, Tennessee 37381 ENCLOSUREIRevised Response to RAI 3.11-2Tennessee Valley Authority -Watts Bar Nuclear Plant -Unit 2, Docket No. 50-3913.11-2 Confirm that equipment being replaced or refurbished will be qualified as Category I asrequired by 10 CFR 50.49.Note: Since only portion e. of the original response is revised, it is the onlyportion included in this response.Original Response:Replaced equipment is being procured qualified to the NUREG-0588, Category 1requirements.A small population of components is being refurbished as follows:e. Cables purchased on Contract 81 K5-830078TVA purchased identical cables under Rockbestos contracts 80K7-826542 and81 K5-830078. The cable purchased under contract 80K7-826542 was purchasedand installed prior to the February 22, 1983, cutoff date stipulated in RegulatoryGuide 1.89, Revision 1 for Category II qualification and therefore meets the fullRegulatory Guide 1.89 and NUREG-0588 requirements for Category IIqualification. Verification of the purchasing and installation documentation forcables purchased under Rockbestos contract 81 K5-830078 has determined thatthe cables were purchased in 1982 but installed in 1985. In accordance withRegulatory Guide 1.89, Revision 1, Environmental Qualification of Certain ElectricEquipment Important to Safety for Nuclear Power Plants, paragraph 6,"Replacement electric equipment installed subsequent to February 22, 1983, mustbe qualified in accordance with the provisions of 50.49 unless there are soundreasons to the contrary. The NRC staff considers the following to be soundreasons for the use of replacement equipment previously qualified in accordancewith the DOR Guidelines or NUREG-0588 in lieu of upgrading.. .6.c. Identicalequipment to be used as a replacement was on hand as part of the utilities stockprior to February 22, 1983." The cable from contract 81 K5-830078 is not"replacement" equipment (i.e., it is new), and it was on hand prior to February 22,1983, but was installed after 1983. Since the cable from contract 81 K5-830078 isof identical design and the installation of the cable is no different than that suppliedon contract 80K7-826542, the cable purchased under contract 81 K5-830078 isconsidered equally qualified and acceptable under the Category II requirements.This is documented in EQ Binder WBNEQ-CABL-036.El-1 ENCLOSUREIRevised Response to RAI 3.11-2Tennessee Valley Authority -Watts Bar Nuclear Plant -Unit 2, Docket No. 50-391Revised Response:Replaced equipment is being procured qualified to the NUREG-0588, Category 1requirements.A small population of components is being refurbished as follows:e. CablesDuring verification and validation of Unit 2 EQ cables, it was determined thatprocurement and installation dates of some Unit 2 EQ cables from WBN contractsdo not meet the cutoff dates for procurement (May 23, 1980, as specified inIE Bulletin 79-01B, Supplement 2) and installation (February 22, 1983, as specifiedin Regulatory Guide 1.89, Revision 1). The approximate number of cables is asfollows:Contract Qty Manufacturer71 C070005476202 1 cable Triangle-Pwc-lnc.79K0500824965 8 cables American Insulated Wire Corp80K0700826542 26 cables Rockbestos Company81K0500830078 85 cables Rockbestos CompanyTotal 120 CablesThese cables were new cables installed in the plant for the first time in Unit 2.Material purchased on these contracts has been determined to meet thequalification criteria of NUREG-0588 Category II using the guidelines established inIEEE 323-1971.Material purchased on contracts 71 C070005476202, 79K0500824965, and80K0700826542 was purchased prior to May 23, 1980, and was on hand as part ofTVA stock before February 22, 1983. However, this material was not installed inUnit 2 until the 1983 to 1985 time frame. Material from each of these contractswas installed at other TVA facilities prior to the February 22, 1983, date and is infull compliance with the qualification criteria of 10 CFR 50.49 as documented in siteEQ Qualification Binders. Unit 2 material from these contracts is consideredequally qualified as those at other TVA facilities.Material purchased on contract 81 K0500830078 was purchased after May 23,1980, but was received as part of TVA stock before February 22, 1983. However,this material was not installed in Unit 2 until the 1983 to 1985 time frame. Materialfrom this contract was considered identical design, and the installation of the cableis no different than that supplied on contract 80K0700826542.E1-2 ENCLOSURE1Revised Response to RAI 3.11-2Tennessee Valley Authority -Watts Bar Nuclear Plant -Unit 2, Docket No. 50-391In accordance with C.6 of Regulatory Guide 1.89, Revision 1 (EnvironmentalQualification of Certain Electric Equipment Important to Safety for Nuclear PowerPlants), "Replacement electric equipment installed subsequent to February 22,1983, must be qualified in accordance with the provisions of 50.49 unless there aresound reasons to the contrary. The NRC staff considers the following to be soundreasons for the use of replacement equipment previously qualified in accordancewith the DOR Guidelines or NUREG-0588 in lieu of upgrading: ... c. Identicalequipment to be used as a replacement was on hand as part of the utility's stockprior to February 22, 1983."These cables were on hand as part of TVA stock before February 22, 1983, andthe material was equal to material installed and qualified at other TVA facilitiesprior to February 22, 1983. Therefore, TVA chose not to upgrade these cables toCategory I requirement when installing them in the 1983 to 1985 time frame.There are approximately 3,700 EQ cables installed for Unit 2. Therefore, theseapproxmately 120 cables represent a small percentage of the total EQ cablesinstalled in Unit 2. Should these cables require replacement in the future, TVA willfollow our internal design criteria and thus comply with NUREG-0588 and replacethe cables with material that meets the qualification criteria of NUREG-0588Category I using the guidelines established in IEEE 323-1974.E1-3