ML11269A029
| ML11269A029 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 09/19/2011 |
| From: | Hruby R Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML11269A029 (7) | |
Text
I-Tennessee Valley Authority, 1101 Market Street, LP 5A, Chattanooga, Tennessee 37402-2801 September 19, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Bellefonte Nuclear Plant, Units 1 and 2 Construction Permit Nos. CPPR-122 and CPPR-123 NRC Docket Nos. 50-438 and 50-439
Subject:
UPDATED RESPONSE TO REGULATORY ISSUE
SUMMARY
2010-10
References:
- 1. NRC Regulatory Issue Summary 2010-10, "Process for Scheduling Acceptance Reviews of New Reactor Licensing Applications and Process for Determining Budget Needs for Fiscal Year 2013," dated November 15, 2010 [ML102720901].
- 2. Letter from TVA to NRC, "Bellefonte Nuclear Plant (BLN) Units 1 (CPPR-122) and 2 (CPPR-123) - Revision to Response to Regulatory Issue Summary 2010-10," dated March 1, 2011 [ML110660438].
The purpose of this letter is to provide the Tennessee Valley Authority's (TVA) updated voluntary response to Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2010-10, "Process for Scheduling Acceptance Review of New Reactor Licensing Applications and Process for Determining Budget Needs for Fiscal Year 2013" (Reference 1),
based on the August 18, 2011 decision by the TVA Board of Directors to authorize completion of Bellefonte Unit 1.
On November 15, 2010, the NRC issued RIS 2010-10, which requests information regarding "potential 10 CFR Part 52 licensing actions and related activities, submission dates and plans for construction activities." Although TVA holds construction permits for BLN Units 1 & 2 issued under 10 CFR Part 50, discussions with NRC staff have indicated value in TVA providing similar information relative to the BLN project.
TVA previously responded to RIS,201 0-10 by letter dated March 1, 2011 (Reference 2).
Enclosure 1 of this letter provides TVA's updated voluntary response to RIS 2010-10 in regards to our planned 10 CFR Part 50 licensing activities for Fiscal Years 2012 and 2013.
The information contained in Enclosure 1 updates and supersedes information previously Z/--/
U.S. Nuclear Regulatory Commission Page 2 September 19, 2011 provided in TVA's March 1, 2011 response to RIS 2010-10. TVA is providing this information solely to assist the NRC in its planning efforts.
No regulatory commitments are identified in this letter. If you have any questions concerning this matter, please call Zackary W. Rad at (256) 574-8265.
Sincerely, Raymond A. Hruby, Jr.
General Manager Bellefonte Project Enclosure(s):
- 1. TVA Response to RIS 2010-10 cc: See page 3
U.S. Nuclear Regulatory Commission Page 3 September 19, 2011 cc (w/Enclosures):
Eric Leeds, Director Robert Haag U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission One White Flint North, 13H16M Region II 11555 Rockville Pike Marquis One Tower Rockville, Maryland 20852-2738 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, Georgia 30303-1257 Stephen J. Campbell U.S. Nuclear Regulatory Commission Patrick Milano One White Flint North, 8H4A U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint North, 8H21 Rockville, Maryland 20852-2738 11555 Rockville Pike Rockville, Maryland 20852-2738 John Lamb U.S. Nuclear Regulatory Commission Larry Mellen One White Flint North, 8H21 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Region II Rockville, Maryland 20852-2738 Marquis One Tower 245 Peachtree Center Ave. NE, Suite 1200 Lakshminarasimh Raghavan Atlanta, Georgia 30303-1257 U.S. Nuclear Regulatory Commission One White Flint North, 8H4A 11555 Rockville Pike Rockville, Maryland 20852-2738 Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, Georgia 30303-1257 Charles Ogle, Deputy Regional Administrator for Construction U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 TVA Letter dated September 19, 2011 Enclosure 1 TVA Response to RIS 2010-10 NRC Request No.1 The staff is seeking notification on the number and the degree of complexity of ESP, LWA, DC, and COL applications, and any other licensing requests that applicants expect to submit in FY 2013, no later than 30 days from the date of this RIS. This information will assist the staff in determining FY 2013 budget needs.
TVA Response This response includes licensing requests anticipated for FY 2012 and FY 2013, the degree of complexity of these requests, and their anticipated impact on NRC resource needs during this time period. TVA has included estimates of NRC review resources based on historical information from similar projects to aid the staff in determining resource needs.
FY 2012:
The expected FY 2012 submittal reviews, along with their breadth and level of complexity of the subjects, are summarized below:
" TVA submitted its request to NRC to extend Construction Permit No. CPPR-122 (BLN Unit 1) on Oct. 8, 2010 (ML102870233). TVA anticipates the NRC Staff to continue the review of the construction permit extension request and estimates the NRC review effort to take six persons six months to complete or approximately 3 Fulltime Equivalent (FTE).
- Review of the BLN Units 1 & 2 Quality Verification Program (QVP). The QVP is a specific program to address the temporary cessation of TVA Nuclear Quality Assurance Plan (NQAP) activities at BLN Units 1 & 2 and involves the use of elements of Design Basis Verification, Quality Records Verification, Replacement Items Verification, and Refurbishment/Replacement. The QVP was submitted to the NRC on April 1, 2011 (ML110980306). TVA estimates this review effort will require up to 3 FTE.
" Review of the BLN Units 1 & 2 Regulatory Framework. TVA submitted the Regulatory Framework on May 5, 2011 (ML11132A118). The Regulatory Framework includes a tabular summary addressing each section of the FSAR and associated NRC Standard Review Plan (SRP) section and identifying applicable regulations, regulatory guides, and industry codes and sta ndards. It also includes key issues that affect the licensing basis of BLN but are not addressed by responses to generic communications, the status of these issues, and an indication of the manner in which TVA intends to resolve them.
El-1 TVA Letter dated September 19, 2011 Additionally, TVA submitted, as part of the Regulatory Framework submittal, a summary of the status of the NRC generic communications including a plan to resolve each, the basis for resolution or, in a limited number of cases where the approach for resolution has not yet been determined, a future date when such information will be available. A similar summary was provided for the NRC unresolved safety issues (USIs). TVA estimates the review effort during FY 2012 will require approximately 7.5 FTE.
Topical/Technical Engagements. TVA plans to engage the NRC in certain areas that will aid in updating the licensing and design basis for BLN. Engagement may involve face-to-face communications and, in some cases, technical or topical submittals for NRC review. Each of these areas includes significant technical content and complexity. There may be a significant effort required in FY 2012 to address these topics. TVA initiated this process for the first two areas below during the second half of FY 2011. TVA expects continued engagement with the NRC on those two areas and the following additional areas during FY 2012:
- Digital Instrumentation and Control system upgrades to reflect the evolution of I&C requirements using digital technology.
- Human Factors Engineering/Control Room Design Review, including potential redesign of the control room.
- Seismic analysis and the development of site-specific spectra (including Generic Issue 199). This engagement will include the seismic position papers that TVA submitted to NRC in the 1990 timeframe.
- Description of plans to resolve potential Alloy 600 issues
- Implementation of Leak-Before-Break and consideration of LOCA loads
- Potential cable issues, including position papers
- ASME Code Case for Project completion
- Probabilistic Risk Analysis TVA estimates that review of each topical/technical area will require approximately 0.5 FTE during FY 2012.
FY 2013:
TVA anticipates that review of the FY 2012 licensing submittals and engagement on the technical/topical areas that are initiated in FY 2012 will require the use of NRC resources into FY 2013.
Additionally, the following technical/topical areas may be discussed:
- Environmental Equipment Qualification, including position paper (0.5 FTE)
E1-2 TVA Letter dated September 19, 2011 TVA also anticipates that during this period it will continue to update the status of the Regulatory Framework and generic communications (actions including closures), as well as resolution and closure of other activities associated with key issues and position papers.
NRC Request No.2 The staff is seeking notification of any changes to previously announced or submitted schedules concerning the construction of power reactors under 10 CFR Part 52. In support of staffing and planning, this includes projected submission dates beyond FY 2013.
TVA Response BLN Unit 1 will be licensed and constructed under 10 CFR Part 50. On August 18, 2011, the TVA Board of Directors approved the TVA staff's recommendation to complete and operate BLN Unit 1. TVA informed the NRC of this decision by letter dated September 1, 2011 (ML11249A162). The TVA Board's decision stipulates that resumption of construction activities associated with BLN Unit 1 completion will occur only after the initial loading of fuel at Watts Bar Unit 2.
NRC Request No.3 To ensure that the NRC can effectively schedule resources and to facilitate the achievement of an acceptance review of 60 calendar days, the staff requests that, 90 days before the expected submission date, an applicant or licensee (as applicable) declare the expected submission date (month, day, and year) and the degree of complexity of each of its ESP, LWA, DC, and partial or complete COL applications or licensing action request that it intends to submit to the NRC.
TVA Response TVA will work with NRC to establish more detailed expectations and schedule information as the project progresses and such information become available.
E1-3 TVA Letter dated September 19, 2011 RC Request No.4 In addition, the NRC staff is requesting the voluntary submission to the NRC of addressee construction plans and schedules for the fabrication of large components and modules, when available.
TVA Response Currently the only large components scheduled to begin fabrication during the designated time period are Replacement Once Through Steam Generators (ROTSGs) for BLN Unit 1. Contract No. 4088 was awarded to Babcock and Wilcox Canada (BWC) for BLN Unit 1 ROTSGs on September 30, 2010. The contract delivery date for the ROTSGs is June 1, 2015.
The major production milestones/schedule durations are as follows:
- 1. BWC Manufacturing - Steam Generator A - September 2011 through March 2015
- 2. BWC Manufacturing - Steam Generator B - September 2011 through April 2015
- 3. BWC Shipment - Steam Generator A - March 2015 through June 1, 2015
- 4. BWC Shipment-Steam Generator A-April 2015 through June 1, 2015 E1-4