ML073320412
| ML073320412 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/06/2007 |
| From: | Catherine Haney Plant Licensing Branch III-2 |
| To: | Campbell W Tennessee Valley Authority |
| Brown, E, NRR-DLPM 301-415-2315 | |
| References | |
| TAC MD2980 | |
| Download: ML073320412 (6) | |
Text
December 6, 2007 Mr. William R. Campbell, Jr.
Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT UNIT 1 - APPLICATION OF PERFORMANCE INDICATORS AND AUGMENTED INSPECTION PROGRAM (TAC NO. MD2980)
Dear Mr. Campbell:
In a letter to the Tennessee Valley Authority (TVA), dated May 16, 2007, the U.S. Nuclear Regulatory Commission (NRC) outlined the framework for transitioning Browns Ferry Nuclear Plant, Unit 1, NRC oversight of the three remaining safety cornerstones (i.e., Initiating Events (IE), Mitigating Systems (MS), and Barrier Integrity (BI)) into the Reactor Oversight Process (ROP). In this letter, the staff informed TVA that due to the lack of valid historical Unit 1 specific performance indicator (PI) data for the IE, MS, and BI cornerstones, additional ROP baseline inspections would be performed for Unit 1. Additionally, the staff requested that TVA submit the available PI data for the IE, MS, and BI cornerstones, starting with the third quarter (3Q) of calendar year 2007. Consistent with that request, TVA provided PI data for Unit 1 for the 3Q07.
Inspection Manual Chapter (IMC) 0608, Performance Indicator Program, provides guidance for implementation of the PIs and endorses the current revision of the Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, for guidance on collecting and reporting the data elements that will be used to compute the PIs. Based on the staffs review of these documents, as well as the guidance contained in IMC 0350, Oversight of Reactor Facilities in a Shutdown Condition Due to Significant Performance and/or Operational Concerns, the PIs for the IE, MS, and BI cornerstones should be considered as valid inputs into the ROP Action Matrix as follows:
Barrier Integrity:
The Reactor Coolant System Specific Activity and Reactor Coolant System Leakage PIs use the maximum monthly value and the Technical Specification limit in the calculation. Since they use just the maximum monthly value and do not depend on critical hours or any other rate-type information in the calculation, they both can be implemented on startup. For Unit 1, valid PI information was available and reported, therefore, both PIs should be considered valid starting in the 3Q07.
W. Campbell, Jr.
Initiating Events:
Since the Unplanned Scrams per 7000 Critical Hours and Unplanned Power Changes per 7000 Critical Hours PIs are rate-type PIs and use critical hours in the calculation, some period of time is needed before the results can be used in the assessment program. There is specific guidance in IMC 0350 which states:
... since the Unplanned Scrams and Unplanned Power Changes PIs in the Initiating Events cornerstone are not considered valid if there are fewer than 2400 critical hours in the previous four quarters, it would typically take two quarters of operational data post restart for these indicators to be considered valid.
Based on this guidance, the PIs should be effective after two full quarters of operation. For Unit 1, start up was in 2Q07, therefore, the PI should be considered valid starting in the 4Q07. The staffs expectation is that all events since restart of Unit 1 on May 22, 2007, would be reported for the PI.
With respect to the Unplanned Scrams with Complications PI, since this indicator counts just the number of scrams and does not use critical hours in the calculation, it can be implemented immediately upon startup. Therefore, the PI should be considered valid starting in the 3Q07.
Mitigating Systems:
The Safety System Functional Failure PI counts the number of events or conditions that prevented, or could have prevented, the fulfillment of the safety function of structures or systems, and components. Since it counts just the number of events and does not use critical hours in the calculation, it can be implemented immediately on startup. For Unit 1, the staff indicated that Unit 1 should start reporting PI information starting in the 3Q07, therefore the PI should be considered valid starting in the 3Q07.
With respect to Mitigating System Performance Indicator (MSPI), these indicators are based on 12 quarters of component and system data, which may require additional time beyond the current three quarters of plant operation. However for some previously monitored systems, such as the Emergency AC Power System, sufficient data may exist such that they can be readily integrated into the ROP. The NRC staff requests that the licensee provide the applicable bases and schedule for integrating the other Unit 1 MSPI monitored systems into the ROP. Additionally, the staff requests that issues requiring NEI 99-02 guidance interpretation be discussed with the ROP Working Group at an upcoming ROP Monthly meeting. After MSPI implementation into the ROP, the licensee should provide a schedule indicating when TVA will be ready to support the Unit 1 MSPI initial inspection similar to the initial PI implementation inspections conducted for all other nuclear facilities. The staff also requests the applicable basis and schedule information be provided within 30 days of the issuance of this letter.
W. Campbell, Jr.
For questions concerning PI interpretation or reporting, please contact Mr. James Andersen of the Division of Inspection and Regional Support at (301) 415-3565.
Sincerely,
/RA/
Catherine Haney, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-259 cc: See next page
Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:
Page 1 of 2 Mr. Ashok S. Bhatnagar Senior Vice President Nuclear Generation Development and Construction Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. James R. Douet Vice President Nuclear Support Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. H. Rick Rogers Vice President Nuclear Engineering & Technical Services Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Brian J. OGrady, Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority 6A West Tower 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, General Manager Nuclear Assurance Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Steven M. Douglas, General Manager Browns Ferry Site Operations Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Ms. Beth A. Wetzel, Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. James E. Emens, Jr., Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 James B. Baptist Browns Ferry Senior Project Engineer Division of Reactor Projects, Branch 6 U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW.
Suite 24T85 Atlanta, GA 30303-8931 Tomy A. Nazario Browns Ferry Project Engineer Division of Reactor Projects, Branch 6 U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW.
Suite 24T85 Atlanta, GA 30303-8931 Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970
Page 2 of 2 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. Larry E. Nicholson., General Manager Performance Improvement Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801