IR 05000259/1997004
| ML20203A297 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/06/1998 |
| From: | De Agazio A NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| 50-259-97-04, 50-259-97-4, TAC-M98931, NUDOCS 9802230333 | |
| Download: ML20203A297 (8) | |
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NUCLEAR REGULATORY COMMISSION
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Ar WASHINGTON, D.c. 30e464001
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fdruary 6,1998 LICENSEE:
Tennessee Valley Authority FACILITY:
Browns Ferry, Unit i SUBJECT:
SUMMARY OF MEETING WITH TENNESSEE VALLEY AUTHORITY ON IMPLEMENTATION OF 10 CFR 50.65 MEETING OF JANUARY 26,1998 (TAC No, M98931)
pACKGROUND On January 26,1998, the NRC staff met with representatives of the Tennessee Valley Authority (TVA), the licensee for Browns Ferry Nuclear Plant, Unit 1 (BFNP-1). Tho purpose of the meeting was to discuss resolution of Unresolved Issue 50 290/97 04-01 as identified in NRC Inspection Report 50 259/97 04, A list of meeting attendees is provided in the Attachment.
During the period of April 4 - 18,1997, the NRC conducted an inspection of the implementation of 10 CFR 60,65 (Maintenance Rule) at the Browns Ferry Nuclear Plant. The results of that inspection are documented in NRC combined Inspection Reports 50-259/97 04,50 260/97 04, and 50-297/97 04 (IR 97 04) issued on May 21,1997. IR 97-04 documents that the NRC inspectors determined that TVA's actions to implement the rule at Unit i are technically adequate, however the report raised the question as to whether or not the approach taken is, in fact, legal under the maintenance rule. At issue is whether the TVA's approach to scoping Unit i structures, systems, and components by considering the defueled and indefinite shutdown condition of Unit i satisfies the requirements of the rule.
By letter dated July 30,1997, the NRC Informed TVA that the limitation of applicability stated in
$50.65(a)(1) does not apply to BFNP 1 in the absence of certification per $50.82(a)(1). The letter identified three alternatives available to TVA to resolve the issue. TVA responded by letter on September 29,1997, asserting that it believes that BFNP 1 is in compliance with $50.65 and presenting its rationale for this assertion. NRC has not yet responded to TVA's September 29th letter pending further discussion of the issue.
Each of the Browns Ferry units were shut down during 1985. Unit 2 restarted in 1991 and Unit 3 restarted in 1995, There are no current plans for Unit i restart, although the option for operation in the future is being retained.
DISCUSSION TVA stated that those Unit 1 systems necessary to support the unit in a safe condition are being maintained as are those needed to support Units 2 and 3 and are included within the scope of the monitoring program under $50.65. The remaining equipment and systems are not included within the scope of the monitoring program because they do not serve & lunction with the unit in its shutdown and defueled state. Much equipment and systems are in layup status to preserve the components for potential future use if the dec!slon is made to restart the unit. For equipment in layup status, it cannot be demonstrated that the equipment can perform its intended wnction, and the layup program is not intended for this purpose. TVA emphasized that the layup program l
Is purely for economic considerations to reasonably preserve the equipment. In the event a l
decision is made to recover Unit 1, the scope of the monitoring program for Unit 1 would be g
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revised appropriately. Furthermore, there are substantial commitments to complete to meet the Regulatory Framework for Restart of Unit 1, there would be extensive component rebuilding or replacement, analysis, and restart testing programs, and NRC approval for restart must be obtained.
The staff stated that TVA must comply with the maintenance rule for all structures, systems, and components (SSCs) that meet the criter;a in $50.65(b). Preventive maintenance (PM) activities must be implemented to provide reasonable assurance that SSCs s.re kept in adequate condition while the unit remains in a shutdown condition. The staff stated that a PM program for Unit 1 would not need to be as comprehensive as one for an operating plant. However, TVA should
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consider a PM program that includes activities such as the existing layup program, condition monitoring activities, equipment examinations, inspections, and walkdowns with an appropriate schedule that is commensurate with the current operating status. Finally, the staff reiterated its position that $50.65 does not allow, in the absence of certification per $50.82(a)(1), for considering the shutdown status of a f acility.
TVA proposed an approach that it believes may meet the requirements of $50.65. The approach would be to include in the monitoring program those structures, sy;tems and components that would be included appropriately within the scope of the rule for an operating facility, similar to the Unit 2 and 3 programs. Since the performance or condition of many Unit 1 components wcold not meet the established program goals, corrective action would be required per $50.65(a)(1). TVA would define the corrective actions as actions to be performed before the unit could restart, and would identify those corrective actions. The staff noted that there could be
a question of corrective action timeliness with this approac.h. TVA would describe the layup program and its purpose and goals, and the corrective actions to be taken. WA would identify equipment that is not included in the layup program and which equipment would be subject to
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replacement. WA is to submit the proposed approach with necessary details for staff review.
TVA's submittal should be submitted within several months.
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Albert W.
Agazlo, Sr. Project Manager Project Directorate 113 Division of Reactor Projects t/II Office of Nuclear Reactor Regulation Docket No.50-25g Attachment: As stated cc: See next page
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February 6,1998
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revised appropriately. Furthermore, there are substantial commitments to complete to meet the Regulatory Framework for Restart of Unit 1, there would be extensive component rebuilding or replacement, analysis, and restart testing programs, and NRC approval for restart must be obtained.
The staff stated that WA must comply with the maintenance rule for all structures, systems, and components (SSCs) that meet the criteria in $50.65(b). Preventive maintenance (PM) activities must be implemented to provide reasonabli assurance that SSCs are kept in adequate condition while the unit remains in a shutdown condition. The staff stated that a PM program for Unit 1 would not need to be as comprehensive as one for an operating plant. However, TVA should consider a PM program that includes activities such as the existing layup program, condition -
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monitoring activities, equipment examinations, inspections, and walkdowns with an appropriate
schedule that is commensurate with the current operating status. Finally, the staff reiterated its position that $50.65 does not allow, in the absence of certification per $50.82(a)(1), for considering the shutdown status of a facility.
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TVA proposed an approach that it believes may meet the requirements of $50.85. The
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approach would be to include in the monitoring program those structures, systems and components that would be included appropriately within the scope of the rule for an operating facility, similar to the Unit 2 and 3 programs Since the performance or condition of many Unit 1 components would not meet the established program goals, corrective action would be required per $60,65(a)(1). TVA would define the corrective actions as actions to be performed before the unit could restart, and would identify those corrective actions. The staff noted that there could be a question of corrective action timeliness with this approach. TVA would describe the layup program and its purpose and goals, and the corrective actions to be taken.1 VA would identify equipment that is not included in the layup program and which equipment v ould be subject to replacement. TVA is to submit the proposed approach with necessary details for staff review.
TVA's submittal should be submitted within several months.
Original Signed by:
Albert W. De Agazio, Sr. Project Manager Project Directorate ll 3 Division of Reactor Projects - t/ll Office of Nuclear Reactor Regulat!on Docket No. 50-259 Attachment: As stated cc: See next page DOCUMENT NAME: G:\\BFN\\98931MTG.NOT To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
"N",= No copy-orritt m post s /yXA&<
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fetruary 6,19%
2-revised appropriately. Furthermore, there are substantial commitments to complete to meet the Regulatory Framework for Restart of Unit 1, there would be extensive component rebuilding or replacement, analysis, and restart testing programs, and NRC approval for restart must be obtained.
The staff stated that TVA must comply with the maintenance rule for all structures, systems, and components (SSCs) that meet the criteria in $50.65(b). Preventive maintenance (PM) activities i
must be implemented to provide reasonable assurance that SSCs are kept in adequate condition l
while the unit remains in a shutdown condition. The staff stated that a PM program for Unit i
would not need to be as comprehensive as one for an operating plant. However, TVA should
'
consider a PM program that includes activities such as the existing layup program, condition monitoring activities. equipment examinations, inspections, and walkdowns with an appropriate schedule that is commensurate with the current operating status. Finally, the staff reiterated its position that $50.65 does not allow, in the absence of certification per $50.82(a)(1), for considering the shutdown status of a facility.
TVA proposed an approach that it believes may meet the requiremems of $50.65. The approach would be to include in the monitoring program those structures, systems and components thet would be included appropriately within the scope of the rule for an operating facility, similar to the Unit 2 ano 3 programs. Since the performance or condition of many Unit 1 l
components would not meet the established program goals, corrective action would be required i
per $50 65(a)(1). TVA would define the corrective actions as actions to be performed before the unit could restart, and would identify those corrective actions. The staff noted that there could be a question of corrective action timeliness with this approach. TVA would describe the layup program and its purpose and goals, and the corrective actions to be taken. TVA would identify equipment that is not included in the layup program and which equipment would be subject to replacement. TVA is to submit the proposed approach with necessary details for staff review.
TVA's submittal should be submitted within several months.
Original Signed by:
Albert W. De Agazio, Sr. Project Manager Project Directorate 113 Division of Reactor Projects - t/Il Office of Nuclear Reactor Regulation Docket No. 50-259 Attachment: As stated cc: See next page DOCUMENT NAME: G:\\Si if,98931MTG.NOT To rocsive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure
"E" = Copy w;th cttrchment/ enclosure
"N">= No copy OfflCE PMIPDil 3 M/E/ lad LA P0ll*3 l
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KAME ADeAgatt/t M /'
SClayton AAO thebdon M
DATf 02/ f /98 02/ /; /98 02/ L./98 02/ /98 02/ /95 Official Record Copy
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BROWNS FERRY NUCLEAR PLANT cc:
Mr. O. J. Zeringue Mr. Mark J. Burrynski, Manager Chief Nuclear Officer and Nuclear Licensing Executive Vice President Tennessee Valley Authorit,'
Tennessee Valley Authority 4J Blue Ridge 6A Lookout Place 1101 Market Street 1101 Market Street Chattanooga, TN 37402 2801 Chattanooga, Tennessee 37402 2801 Mr. Timothy E. Abney, Manager Mr. J. A. Scalice, Senior Vice President Licensing and Industry Affairs Nuclear Operations Browns Ferry Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place P.O. Box 2000 1101 Market Street Decatur, AL 3560g Chattanooga, TN 37402 2801 Regional Administrator Mr. Jack A. Bailey, Vice President U.S. Nuclear Regulatory Commission Engineering & Technical Services Region ll Tennessee Valley Authority 61 Forsyth Street, SW., Suite 23T85 BA Lookout Place Atlanta, GA 30303 3415 1101 Market Street Chattanooga, TN 37402 2801 Mr. Leonard D. Wert Senior Resident inspector
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Mr. C. M. Crane, Site Vice President Browns Ferry Nuclear Plant Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authonty 10833 Shaw Road P,0. Box 2000 Athens, AL 35611 Decatur, AL 35609 Chairman General Counsel Limestone County Commission Tennessee Valley Authority 310 West Washington Street i
ET 10H Athens, AL 35611 400 West Summit Hill Drive Knoxville, TN 37902 State Health Officer Alabama Department of Public Health Mr. Raul R. Baron, General Manager 434 Monroe Street Nuclear Assurance Montgomery, AL 36130-1701 Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402 2801 Mr. Karl W. Singer, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority
_ P.O. Box 2000 Decatur, AL 35609
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Meeting SummaryI < itribution E Mail (Attachment)
Hard conv (Attachmentsi 8. Collins /F. Miraglia(SJC1/FJM)
Docket File 8. Boger(BAB2)
PUBLIC J. Zwolinski(JAZ)
PDil 3 Reading File F. Hebdon (FJH)
OGC 8. Clayton (8/.C2).
8. Black (BBC)
R. Correia (RPC)
cc: Ucensee & Service List M. Satorius (MAS)
G. Mizuno (GSM)
P. Fredrickson(PEF)
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M. Tschiltz (MDT)
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Meeting Summary Distribution E-Mail (Attachmenti Hgd Conv (Attachment 1)
'D k t FileI S. Collins /F, Miraglia (SJC1/FJM)
oc e B, Boger(BAB2)
PUBLIC J. Zwolinski(JAZ)
PDil 3 Reading File F. Hebdon(FJH)
OGC B. Clayton(SAC 2)
A. DeAgazio (ADA).
_ ACRS S. Black (SBC)
R. Correla (RPC)
cc: Licensee & Service List M. Satorius (MAS)
G. Mizuno (GSM)
P. Fredrickson (PEF)
M. Tschiltz(MDT)
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LIST OF ATTENDEE 8
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MEETING WITH REPRESENTATIVES OF TENNESSEE VALLEY AUTHORITY ROCKVILLE. MARYLAND JANUARY 20.1998 NRC/NRR IyA Suzanne Black Tim Abney Richard Correia Marcie Cooper Albert De Agarlo John Sparks Frederick Hebdon NRC/OE NRC/Realon 11 Mark Satorius Paul Fredrickson NRR/OGC
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Geary Mizuno
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