ML042360762
| ML042360762 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/23/2004 |
| From: | Yoira Diaz-Sanabria NRC/NRR/DRIP/RLEP |
| To: | Singer K Tennessee Valley Authority |
| DIAZ-SANABRIA, Y /NRR/DRIP/RLEP 415-1594 | |
| References | |
| TAC MC1704, TAC MC1705, TAC MC1706 | |
| Download: ML042360762 (7) | |
Text
August 23, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3, LICENSE RENEWAL APPLICATION (TAC NOS. MC1704, MC1705 AND MC1706)
Dear Mr. Singer:
By letter dated December 31, 2003, Tennessee Valley Authority (TVA) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2 and 3, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified areas where additional information is needed to complete the review. Those areas are stated in the enclosed requests for additional information (RAIs), specifically from Sections 2.3, 3.3, 4.4, B.2.0, and Appendix F of the fire protection system, related to the Scoping and Screening: Mechanical Systems, Aging Management of Auxiliary Systems, and Aging Management Programs respectively.
Based on discussions with Mr. Gary Adkins of your staff, a mutually agreeable date for your response to the RAIs is within 30 days of the date of this letter. If you have any questions regarding this letter or if circumstances result in your need to revise the response date, please contact me at (301) 415-1594 or by e-mail at yks@nrc.gov Sincerely,
/RA/
Yoira K. Diaz Sanabria, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-259, 50-260 and 50-296
Enclosure:
As stated cc w/encl: See next page
August 23, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3, LICENSE RENEWAL APPLICATION (TAC NOS. MC1704, MC1705 AND MC1706)
Dear Mr. Singer:
By letter dated December 31, 2003, Tennessee Valley Authority (TVA) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2 and 3, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified areas where additional information is needed to complete the review. Those areas are stated in the enclosed requests for additional information (RAIs), specifically from Sections 2.3, 3.3, 4.4, B.2.0, and Appendix F of the fire protection system, related to the Scoping and Screening: Mechanical Systems, Aging Management of Auxiliary Systems, and Aging Management Programs respectively.
Based on discussions with Mr. Gary Adkins of your staff, a mutually agreeable date for your response to the RAIs is within 30 days of the date of this letter. If you have any questions regarding this letter or if circumstances result in your need to revise the response date, please contact me at (301) 415-1594 or by e-mail at yks@nrc.gov Sincerely,
/RA/
Yoira K. Diaz Sanabria, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-259, 50-260 and 50-296
Enclosure:
As stated cc w/encl: See next page Adams Accession no.: ML042360762 DISTRIBUTION: See next page
- Input provided by memo Document Name: C:\\ORPCheckout\\FileNET\\ML042360762.wpd OFFICE PM:RLEP LA:RLEP SC:SPLB*
SC:RLEP NAME Y. Diaz-Sanabria Y. Edmonds S. Weerakkody S. Lee DATE 8/23/04 8/23/04 7/13/04 8/23/04 OFFICIAL RECORD COPY
DISTRIBUTION: Ltr. to Mr. Karl W. Singer, Dated: August 23, 2004 Adams Accession No: ML042360762 HARD COPY RLEP RF Yoira Diaz-Sanabria (PM)
E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li M. Itzkowitz (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff K. Jabbour C. Julian (RII)
S. Cahill (RII)
A. Hodgdon C. Carpenter D. Coe E. Kleeh A. Howe
Enclosure REQUEST FOR ADDITIONAL INFORMATION (RAI) RELATED TO FIRE PROTECTION SYSTEM SECTIONS 2.3, 3.3, 4.4, B.2.0 AND APPENDIX F BROWNS FERRY NUCLEAR PLANT LICENSE RENEWAL APPLICATION FIRE PROTECTION ENGINEERING AND SPECIAL PROJECTS Section 2.3 Scoping and Screening Results: Mechanical Systems Section 2.3.3.6 High Pressure Fire Protection System RAI 2.3.3.6-1 The system description of the high pressure fire protection system in Section 2.3.3.6 includes fixed water spray systems. Such systems typically utilize water spray nozzles. LRA Table 2.3.3.6 does not include water spray nozzles as a component subject to an AMR. Indicate whether the fixed water spray systems use spray nozzles other than the sprinkler heads. If so, the nozzles, which have an intended to support the system function, are passive and long lived and should be subject to an AMR.
RAI 2.3.3.6-2 The system description of the high pressure fire protection system in Section 2.3.3.6 includes detection and alarm devices that automatically initiate the system or prompt manual fire fighting. These devices are not identified. Identify what these devices are and where they are included in the AMR.
RAI 2.3.3.6-3 License renewal drawing 1-47E850-1-LR shows the boundary of the high pressure fire protection water system is the service building wall. The boundary shown is not at an isolated pressure boundary (e.g., a valve or blank flange). Justify why the service building portions of the system are not in scope.
RAI 2.3.3.6-4 Drawing 3-47E850-5-LR identifies a water curtain around the equipment hatch at Elevation 565. Table 9.3.11.B in Volume 1 of the Fire Protection Report lists water curtains for the RHR Pump Room equipment hatches at Elevation 541. The license renewal drawings do not show anything on Elevation 541. Clarify that the water curtain protection for the RHR Pump Room equipment hatches is in scope, and identify where they are located on the license renewal drawings.
Section 2.3.3.12 CO2 System RAI 2.3.3.12-1 The CO2 system addressed in this section typically requires discharge nozzles to achieve the proper flow rate. The system description and LRA Table 2.3.3.12 do not include any reference to discharge nozzles. Indicate whether this system includes discharge nozzles. If so, the nozzles, which have an intended function of flow control, are passive and long lived and should be subject to an ARM.
RAI 2.3.3.12-2 The system description of the CO2 System in LRA Section 2.3.3.12 includes detection and alarm devices that automatically initiate the system or prompt manual fire fighting. These devices are not identified. Identify what these devices are and where they are included in the AMR.
Section 3.3 Aging Management of Auxiliary Systems (Tables 3.2.2.1, 3.3.2.6, 3.3.2.12, 3.5.2.5, 3.5.2.10, and 3.5.2.12)
RAI 3.3-1 LRA Table 3.5.2.2, Reactor Building - Summary of Aging Management Review, Lists Coating (ALBI CLAD-161) as part of the fire barrier. This fire resistive coating for structural steel lists only for the Reactor Building in the table. It is unclear from the Fire Hazard Analysis (FHA) if this is the only building with structural steel protection. Procedure 0-SI-4.11.G.1.a, Visual Inspection of Fire Rated Barriers, refers to Albi-Clad coating on structural steel beams on Elevation 593 of the Control Building. Identify all in-scope structures which contain fire resistive coatings on structural steel. Design standard G-74, Fire Proofing of Structural Steel, Section 2.1.2, Safety-Related Nuclear Structures refers to Pyrocrete 241, Mandoseal P-50 or other approved material. Table 3.5.2.2 in the LRA refers to Albi-Clad 161. Verify which material(s) are applied. Acceptance criteria in procedure 0-SI-4.11.G.1.a, Visual Inspection of Fire Rated Barriers, is an unprotected area greater than one square foot. The fire resistance rating of the material or assembly is determined by the thickness. A reduction in thickness from mechanical or other means would reduce the fire resistance and prevent the steel from performing its intended fire protection function. Provide the technical basis for the > one square foot criteria for unacceptability.
RAI 3.3-2 LRA Table 3.5.2.2, Reactor Building - Summary of Aging Management Review, identifies ceramic fiber as having no aging effects and therefore requiring no AMP. Describe how these materials are used and provide the technical basis for the conclusion of no aging effects.
RAI 3.3-3 LRA Table 3.5.2.12 identifies Thermolag as a fire barrier and referred to LRA Appendix B, Section B.2.1.23. Cable wraps are not specifically addressed in Section B.2.1.23. Is this the only area of the plant where cable wrap fire barriers are used? Electrical raceway fire barriers are referenced in plant operating experience as experiencing minor degradation. Identify all areas where cable wraps are provided, and verify that these barriers are included in the AMP.
Section B.2.0 Aging Management Programs Section B.2.1.23 Fire Protection Program Section B.2.1.24 Fire Water System Program RAI B.2.0-1 Appendix B, Section B.2.1.23 Fire Protection Program, does not address what is included in the fire pumps and does not reference the electric fire pumps. The boundary drawings show the three electric and one diesel fire water pumps as in scope. Verify that the electric fire pumps are included in the AMR and AMP. The smaller electric service water pumps are used for pressure maintenance, but are not shown in scope. Justify why these pressure maintenance devices are not in scope.
RAI B.2.0-2 The AMP references periodic visual inspections as an exception to the GALL, in Section B.2.1.23. Section 9.4.11.G of the Fire Protection Report (FPR) discussed semi-annual inspection of fire doors including a check of closers and latching mechanisms. Describe the specific exceptions to the GALL the AMP for fire doors. The GALL recommends verification of door clearances to assure the door can perform in a fire and remain latched. Explain how a visual inspection can verify the closer and latching mechanism. Verify that the frequency of these surveillances is consistent with the FPR.
Appendix F - Integration of Browns Ferry Unit 1 Restart and License Renewal Activities Section F.3 Fire Protection RAI F.3-1 Appendix F to LRA states that, Whenever text annotated with a bold border box appears in the LRA symbolizing a licensing or design basis that is only applicable to Units 2 and 3, a link is provided to the appropriate Appendix F section. Systems/Structures/Components Impacted -
The impacted systems, structures, or components are identified with links to the appropriate Chapter 2 sections and the appropriate Chapter 3 sections.
Since there is no text annotated with a bold border box that appears in either of the LRA Section 2.3.3.12, CO2 System, LRA Section 3.3.2.1.6, High Pressure Fire Protection System and LRA Section 3.3.2.1.12 CO2 System it symbolizes that the pertinent licensing or design bases equally applicable to Units 1, 2 and 3 fire protection system.
Verify that the licensing or design bases of fire protection systems listed in LRA Sections 2.3.3.12, 3.3.2.1.6, and 3.3.2.1.12 are equally applicable to Units 1, 2, and 3 without any exceptions.
Provide justification in detail, if any deviations noted, and revise corresponding LRA tables to identify these impacted systems, structures, or components that are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
Review of Fire Protection Report (FPR)
RAI 4.4.1-1 Section 4.4.1.a of the FPR addresses a separate water supply system, including tank and pumps, which does not appear in the LRA or boundary drawings. Verify whether these system components are in scope and provide the justification if they are not.
RAI 4.4.5-1 Section 4.4.5 of the FPR states that Flammastic was applied to cables that did not meet IEEE-383 flame tests requirements. Inspection Testing and Maintenance (ITM) of this is not referenced in the FPR. No reference is made to it in the LRA, either under the Fire Protection Program, Section B.2.1.23, or in the electrical or structural programs. This still appears to be a license condition. Identify where these coating are addressed in the LRA scoping, screening and AMR sections.
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Mr. Ashok S. Bhatnagar, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. James E. Maddox, Vice President Engineering & Technical Services Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Michael D. Skaggs Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority ET 11A 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Kurt L. Krueger, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Jon R. Rupert, Vice President Browns Ferry Unit 1 Restart Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Robert G. Jones Browns Ferry Unit 1 Plant Restart Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Mark J. Burzynski, Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Bobby L. Holbrook Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611 Mr. Fred Emerson Nuclear Energy Institute 1776 I St., NW, Suite 400 Washington, DC 20006-2708 Gary M. Adkins Manager, Browns Ferry License Renewal Project Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801