ML051610400

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License Renewal Application (LAR) - Response to NRC Request for Additional Information (RA) 4.7.3-1 - Radiation Dose for Valve Seals
ML051610400
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 06/09/2005
From: Crouch W
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC1704, TAC MC1705, TAC MC1706
Download: ML051610400 (8)


Text

June 9, 2005 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:

In the Matter of

)

Docket Nos. 50-259 Tennessee Valley Authority

)

50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

LICENSE RENEWAL APPLICATION (LRA) - RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) 4.7.3 RADIATION DOSE FOR VALVE SEALS (TAC NOS. MC1704, MC1705, AND MC1706)

By letter dated December 31, 2003, TVA submitted, for NRC review, an application pursuant to 10 CFR 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2, and 3. As part of its review of TVAs LRA, the NRC staff, through an informal request on May 27, 2005, identified additional information needed for RAI 4.7.3-1, radiation dose for valve seals.

The enclosure to this letter contains the specific NRC request for additional information and the corresponding TVA response.

U.S. Nuclear Regulatory Commission Page 2 June 9, 2005 If you have any questions regarding this information, please contact Ken Brune, Browns Ferry License Renewal Project Manager, at (423) 751-8421.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 9th day of June, 2005.

Sincerely, Original signed by:

William D. Crouch Acting Manager of Licensing and Industry Affairs

Enclosure:

cc: See page 3

U.S. Nuclear Regulatory Commission Page 3 June 9, 2005 Enclosure cc (Enclosure):

State Health Officer Alabama Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, Alabama 35611 (Via NRC Electronic Distribution)

Enclosure cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 Mr. Stephen J. Cahill, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 NRC Unit 1 Restart Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 cc: continued page 4

U.S. Nuclear Regulatory Commission Page 4 June 9, 2005 cc: (Enclosure)

Margaret Chernoff, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Yoira K. Diaz-Sanabria, Project Manager U.S. Nuclear Regulatory Commission (MS 011F1)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Ramachandran Subbaratnam, Project Manager U.S. Nuclear Regulatory Commission (MS 011F1)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739

U.S. Nuclear Regulatory Commission Page 5 June 9, 2005 JEM:TLE:BAB Enclosure cc (Enclosure):

A. S. Bhatnagar, LP 6-C K. A. Brune, LP 4F-C J. C. Fornicola, LP 6A-C R. G. Jones, NAB 1A-BFN K. L. Krueger, POB 2C-BFN R. F. Marks, Jr., PAB 1A-BFN F. C. Mashburn, BR 4X-C N. M. Moon, LP 6A-C J. R. Rupert, NAB 1F-BFN K. W. Singer, LP 6A-C M. D. Skaggs, PAB 1E-BFN E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS, WT CA-K s://Licensing/Lic/Submit/Subs/BFN LR Clarification of Rad Dose for Valve Seals.doc

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA)

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) 4.7.3-1, RADIATION DOSE FOR VALVE SEALS (SEE ATTACHED)

E-1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION (LRA)

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) 4.7.3-1, RADIATION DOSE FOR VALVE SEALS By letter dated December 31, 2003, TVA submitted, for NRC review, an application pursuant to 10 CFR 54, to renew the operating licenses for the Browns Ferry Nuclear Plant, Units 1, 2, and 3. As part of its review of TVAs LRA, the NRC staff, through an informal request on May 27, 2005, identified additional information needed for RAI 4.7.3-1, radiation dose for valve seals. This enclosure contains the specific NRC request for additional information and the corresponding TVA response.

NRC RAI 4.7.3-1 In LRA Section 4.7.3, the applicant indicated that, for the isolation valves for HPCI and RCIC systems' injection lines into the FW system, the 40-year normal plus accident radiation dose had been calculated and compared to the valve seals' qualification radiation dose. It also indicated that the calculation was projected to include the 60-year normal plus accident radiation dose, and then compared to the 60-year qualification radiation dose for the valve seals.

The applicant did not, however, provide the dose numbers which were calculated and the qualification doses for the valve seals which are to be compared to, both for 40-year and 60-year life times. The staff requested the applicant to provide the above information as well as the methodologies used to arrive at the results.

TVA Response to RAI 4.7.3-1 TVA originally considered a design calculation that determines the dose to the seal rings on the High Pressure Coolant Injection System (HPCI) and Reactor Core Isolation Cooling System (RCIC) testable check valves to be a Time-Limited Aging Analysis (TLAA). After further review, it was determined that the calculation is used to validate the seal design, but is not relied on to make a safety determination. The ability of the valve to perform its safety function is verified by Type C leak testing performed per BFN Technical Instruction 0-TI-360, Containment Leak Rate Programs. Based on this further review, TVA has determined that the calculation should not be considered to

E-2 be a TLAA, and Section 4.7.3 (Dose To Seal Rings For The High Pressure Coolant Injection And Reactor Core Isolation Cooling Containment Isolation Check Valves) should be deleted from the License Renewal Application.