ML18036B334
| ML18036B334 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/22/1993 |
| From: | Salas P TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306290227 | |
| Download: ML18036B334 (96) | |
Text
ACCELERATE+ DOCUMENT MST UTION SYSTEM REGULAT~ INFORMATION DISTRIBUTIO STEM (RIDS)
ACCESSION NBR:9306290227 DOC.DATE: 93/06/22 NOTARIZED: NO DOCKET FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 AUTH. NAME AUTHOR AFFILIATION SALAS,P. Tennessee Valley Authority W~pKt+N RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Provides notification of completion or status of post-Unit 2 Cycle 5 restart issues. Encl 1 to ltr lists commitment,refs key correspondence, discusses background of issue a closure TITLE:
NOTES:
OR or status of commitment, as appropriate.
DISTRIBUTION CODE: SQUID COPIES RECEIVED:LTR I Submittal: General Distribution ENCL j SIZE: 40 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-4 1 1 PD2-4-PD 1 1
-ROSS,T. 2 2 INTERNAL: ACRS 6 NRR/DE/EELB 1 1 NRR/DRCH/HICB 1 NRR/DRPW/OTSB 1 1 NRR/DSSA/SPLB 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT OGC/HDS3 0 G~ Ol 1
1 0
1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 iPS NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISIRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL ~8-
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Tennessee Vatiey Authority. Post Office Box 2000. Decatur. Atahama 35609 JUN 22 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of ) Docket Nos. 50-260 Tennessee Valley Authority )
BROWNS FERRY NUCLEAR'LANT (BFN) - COMPLETION OF UNIT 2 POST-RESTART ISSUES This 'letter provides notification of the completion or status of post-Unit 2 Cycle 5 'restart issues. Unless otherwise noted, the status and schedule for completion of these issues was provided in previous post-restart status submittals (References 1 and 2). In the NRC's request for additional information on post-restart issues (Reference 3), the Staff requested TVA provide formal notification upon the completion of each of these post-restart commitments. TVA committed to provide this notification as part of the Unit 2 Cycle 6 outage
.completion letter (Reference 4). Enclosure 1 to this letter lists each commitment, references key correspondence, discusses the background of the issue, and describes the closure or status of each commitment, as appropriate. A summary of the remaining open post-restart issues is provided as Enclosure 2.
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41 41 .S U..S. Nuclear Regulatory Commission JUN Q8 1993 There are no commitments contained in this letter. If you
,have any questions, please telephone me at (205) 729-2636.
Sincerely, Pe ro - alas Manager of Site Licensing Enclosures cc (Enclosures):
NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region 101.
II Marietta Street,, NW, Suite 2900 Atlanta, Georgia 30323
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U.S. Nuclear Regulatory Commission JUN 22 1993.
References:
- 1) TVA letter to NRC,'ated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues
- 2) TVA letter to NRC, dated December 24, 1991/
Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues
.3) NRC letter to TVA, dated November 21, 1991, Unit 2 Post-Restart Commitments
- 4) TVA letter to NRC, dated May 24, 1993, Completion of Commitments for Unit 2 Cycle 6 Outage and Response to Related Issues
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~, ~
ENCLOSURE 2 BROWNS FERRY NUCL'EAR 'PLANT
SUMMARY
OF'REMAINING UNIT 2 POST-RESTART ISSUES COMMITMENT REFER TO COMPLETION ENCLOSURE 1 COMMITMENT DATE PAGE The. long-term qualification of cable 3/19/96 Page 8 of 54 trays (USI A-46).
Evaluate seismic spatial 3/19/96 Page 10 of 54 interactions and .water spray effects (USI A-46).
Evaluation installed and inventoried 9/30/94 Page 12 of 54 non-. USI A-46 items used in non-10 CFR 50.59 safety related applications.
Evaluation installed and inventoried 3/19/96 Page 12 of 54 USI A-46 items used in non-10 CFR 50.-59 safety related applications.
The long-term qualification of 3/19/96 Page 15 of 54 conduit supports (USI A-46).
The configuration management system 9/30/94 Page 17 of 54 upgrade.
The post-restart portion of the 3/19/96 Page 21 of 54 DBVP elements related to USI A-46.
Evaluate non-restart safety 3/19/96 Page 27 of 54 related flexible conduits for seismic adequacy using the USI A-46 program.
Update the BFN PRA to reflect the In Progress Page 43 of 54 hardened vent.
Complete the mai.'ntenance instructions 9/30/93 Page 45 of 54 upgrade.
Complete Phase 2 of the Q-List. 9/30/94 Page 48 of 54 Upgraded security system. In Progress Page 50 of 54
.Seismically qualify mechanical and 3/19'/96 Page 51 of 54 electrical equipment (USI A-46).
Schedule provided in the Physical Security Plan.
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A.CCEI'ERAT 0 DOCUMENT DIST UTION SYSTEM REGULAT INFORMATION DISTRIBUTIO YSTEM (RIDS)
ACCESSION NBR:9306290227 DOC.DATE: 93/06/~ NOTARIZED: YES ,DOCKET FACIL:STN-50-~8 r r '5000528g AUTH. NAME '2Q AUTHOR AFFILIATION CONWAY,W.F. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) P~~
SUBJECT:
Forwards proprietary evaluation of oxide thickness I measurements on Palo Verde Unit 1 fuel rod cladding at EOC-3 TITLE:
6 projection for EOC-4.Encl withheld.
DISTRIBUTION CODE: RPOID COPIES RECEIVED:LTR Proprietary Review Distribution NOTES,:STANDARDIZED PLANT Pre Q ENCL Operating License j SIZE:
6G Operating 05000528 R.
D RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDV LA 1 1 PDV PD 1 1 D TRAMMELL,C 3 3 TRAN,L 3 3 D
INTERNAL: ACRS 6 6 AEOD OA 1 1 OGC/HDS1 1 0 REG FIL 01 1 1 EXTERNAL: NRC PDR 1 0 gR)
- 05) NR ~
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NOTE TO, ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTBl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (BXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISI'RIBUTION gc>>i LISIS FOR DOCUMENTS YOU DON'T NEEDl NUMBER OF COPIES REQUIRED: LTTR ~ ENCL 8'OTAL
Tennessee Valley Authority. Post Office Box 2000. Decatur. Alabama 36609 JUN 22 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of ) Docket Nos. 50-260 Tennessee Valley Authority )
BROWNS FERRY NUCLEAR PLANT (BFN) COMPLETION OF UNIT 2 POST-RESTART ISSUES This letter provides notification of the completion or status of post-Unit 2 Cycle 5 restart issues. Unless otherwise noted, the status and schedule for completion of these issues was provided in previous post-restart status submittals (References 1 and 2). In the NRC's request for additional information on post-restart issues (Reference 3), the Staff requested TVA provide formal notification upon the completion of each of these post-restart commitments. TVA committed to provide this notification as part of the Unit 2 Cycle 6 outage completion letter (Reference 4). Enclosure 1 to this letter lists each commitment, references key correspondence, discusses the background of the issue, and describes the closure or status of each commitment, as appropriate. A summary of the remaining open post-restart issues is provided as Enclosure 2.
<8OOLi 9306290227 930420 PDR ADOCK 05000528 P PDR ~~
Cl U. S. Nuclear Regulatory Commission JUH RP, 1993 There are no commitments contained in this letter. If you have any questions, please telephone me at (205). 729-2636.
Sincerely, Pe ro-Salas Manager of Site Licensing Enclosures cc (Enclosures):
NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One Nhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr.. R. V. Crlenj'ak, Project. Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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U.S. Nuclear Regulatory Commission JuN 22 1993
References:
- 1) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues
- 2) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues
- 3) NRC letter to TVA, dated November 21, 1991, Unit 2 Post-Restart Commitments
- 4) TVA letter to NRC, dated May 24, 1993, Completion of Commitments for Unit 2 Cycle 6 Outage and Response to Related Issues
l II ~
1
~
INDEX TO ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
COMPLETION OF UNIT 2 POST-RESTART ISSUES TOPIC LOCATION Cable Ampacity Page 1 of 54 Cable Installation Page 3 of 54 Cable Tray Supports Page 8 of 54 Class II Over Class Spatial Interactions I Features and Seismic Page 10 of 54 Component and Piece-Part Qualification Program Page 12 of 54 Conduit Supports 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Page 15 of 54 Configuration Management (Including Design Baseline and Verification Program and t Calculations)
Drywell Steel Platforms Emergency Preparedness Environmental Qualification of Equipment Electrical Page 17 Page 22 Page 24 Page 25 of of of of 54 54 54 54, Fire Protection Improvement Page 26 of 54 Flexible Conduit Page 27 of 54 Fuse Program Page 29 of 54 HVAC Ductwork Page 32 of 54 Instrument Tubing Program Page 34 of 54 Intergranular Stress Corrosion Cracking Page 35 of 54 Microbiologically Induced Corrosion Page 38 of 54 Miscellaneous Steel Page 39 of 54 Probabilistic Risk Assessment Page 41 of 54 Procedures Page 45 of 54 Q List ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Page 48 of 54
INDEX TO ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
TOPIC LOCATION Radiological Control and Chemistry Improvement (Post-Accident Sampling System) Page 49 of 54 Security Page 50 of 54 Seismic Qualification of Mechanical and Electrical Equipment Page 51 of 54 Simulator Page 53 of 54 Small Bore Piping Page 54 of 54
ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
COMPLETION OF UNIT 2 POST-RESTART ISSUES Commitments from TVA's Corporate Nuclear Performance Plan (CNPP)g Browns Ferry Nuclear Performance Plan (BFNPP), and/or open items from the Safety Evaluation Report (SER) on the BFNPP are listed below, by topic, in alphabetical order. This enclosure lists each commitment, references key correspondence, discusses the background of the issue, and describes the closure or status of each commitment, as appropriate.
Cable Ampacity-Commitment: TVA will provide a technical basis for derating factors of cable tray covers between six and ten feet long and take the necessary corrective actions by the end of the first refueling outage after Unit 2 restart.
Discussion: During the NRC staff's review of BFN's cable ampacity evaluation program plan, the staff became aware that TVA was not, using a derating factor for tray covers less than ten feet long. TVA only applied a 25 percent derating for tray covers over ten feet long. The staff requested a copy of the applicable evaluation and TVA responded that this position was based on engineering judgement.
The staff then requested TVA to either conduct a test to determine the derating factor or reduce tray cover lengths to six feet. In the staff's judgment, the lack of derating factors did not affect restart of Unit 2 but could only reduce the future life expectancy of the affected cables.
Therefore, in Reference 1, the staff requested that TVA establish derating factors (including a technical basis) for cable tray covers between six and ten feet long, and take the necessary corrective actions, before the end of the first refueling outage following restart. The status of this commitment was provided in Reference 2.
Status: Complete. The technical basis for derating factors of cable tray covers between six and ten feet long was provided in Reference 3. No physical modifications were required.
Page 2 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Ampaclty (Continued)-
References:
- 1) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.3.1, Page 3-12]
- 2) TVA letter to NRC, dated April 16, 1991, Completion Status of Corrective Actions Identified for Unit 2 Restart in Browns Ferry Nuclear Performance Plan (BFNPP) [Section III.13.2, Page 33]
- 3) TVA letter to NRC, dated December 29, 1992, Derating Factors for Cable Tray Covers Between Six and Ten Feet Long
Page 3 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Installatlon-Commitment: Group 2 cables will be tested to the requirements of SMI-65 during the next scheduled Unit 2 outage and subsequent outages to facilitate a trend analysis.
Discussion: Reference 1 transmitted a status report on the corrective actions taken to resolve the cable pullby issue. The Group 2 cable were defined as those having a bend radius of between 6.5 and 7.95 times the-cable's outside diameter (OD) . The normal allowable bend radius was twelve times the cable's OD. The testing of these cables supported their continued service. However, BFN committed to test these cables during the next three outages to determine the need for continued trending. The acceptability of BFN's program to address the cable damage issue originally identified at Watts Bar was documented in Reference 2. The status of this commitment was provided in Reference 3.
TVA submitted the revised corrective actions program for the Group 2 cable pullby issue in Reference 4.
Status: Complete. BFN implemented a Load Cycle and Corona Test Program to replace the original high potential testing program. The testing confirmed that the Group 2 cables can meet their design requirements for interfacial shield integrity with no reduction in life and without the need for further special high potential testing at each outage. The Group 2 cables will henceforth be subject to routine maintenance testing, as appropriate.
Page 4 of 54 ENCLOSURE 1 e BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Installation (Continued)-
References:
- 1) TVA letter to NRC, dated July 10, 1990, Unit 2 Cable Installation Issues Supplemental Report Corrective Actions
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.5, Page 3-19]
- 3) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 6]
- 4) TVA letter to NRC, dated March 17, 1993, Medium Voltage Cable Bend Radius Issues
Page 5 of 54 ENCLOSURE I BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable installation (Continued)-
Commitment: Class 1E low voltage cable will be evaluated for compliance with the established requirements for support of vertical cables. This action will be completed by the end of the Unit 2 Cycle 6 refueling outage.
Discussion: Reference 1 transmitted the results of the walkdowns and testing performed to resolve the support of vertical cables issue. Thirteen Class IE cables medium voltage cables were found not to meet the acceptance criteria. Five of these cables were being replaced to resolve other issues. The remaining eight cables passed a Hi-Pot test. Therefore, a program for evaluating the support of low voltage cable vertical drops was scheduled for completion prior to Cycle 7 startup. The acceptability of BFN's program to address the support of vertical cable issue was documented in Reference 2. The status of this commitment was provided in Reference 3.
Status: Complete. Walkdowns and evaluations of vertical runs of Class 1E low voltage conduits and cables were performed. The walkdowns selected only those conduits and cables that were installed prior to the issuance of Specification G-38, which contained guidelines for maximum unsupported vertical lengths. The low voltage conduits and cables were considered to be acceptable.
References:
- 1) TVA letter to NRC, dated July 10, 1990, Unit 2-Cable Installation Issues Supplemental Report Corrective Actions
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.5, Page 3-17]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section IV.13.1, Page 31]
Page 6 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Installation (Continued)-
Commitment: The five cables that operate at full system voltage in Group 1 of the bend radius evaluation will be replaced to correct the bend radius conditions during the next. Unit 2 refueling outage.
I'Please note that this commitment was not originally included in the TVA/NRC post-restart correspondence referenced (as Referrences 1 and 2) in the cover letter for this submittal.]
Discussion: Reference 1 transmitted the results of the walkdowns and testing performed to resolve the bend radius issue. Based on the satisfactory results of the bend radius measurements and the Hi-Pot testing, the Group 1 cables were considered to be acceptable as installed for Unit 2 restart.
However, five cable were identified that operated at full system voltage and were approximately fifteen years old. Therefore, TVA committed to replace them during the next scheduled Unit 2 refueling outage (Cycle 6). The acceptability of BFN's program to address the cable bend issue was documented in Reference 2.
TVA submitted the revised corrective actions program for the medium voltage electrical cable bend radius issue in Reference 3. The five cables that were slated for replacement under the original corrective action plan would not be replaced due to revised dispositions. However, TVA committed to replace a different, cable, Cable PP434-1E, during Unit 2 Cycle 6, due to identified insulation damage.
Status: Complete. Cable PP434-1E was replaced during Unit 2 Cycle 6.
Page 7 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Installation (Continued)-
References:
- 1) TVA letter to NRC, dated September 19, 1990, Unit 2 Resolution of Cable Installation Issues Supplemental Report Corrective Actions Cable Pullby
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.5, Page 3-19)
- 3) TVA letter to NRC, dated March 17, 1993, Medium Voltage Cable Bend Radius Issues
Page 8 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Tray Supports-Commitment: The long-term qualification of cable trays will use the approach developed by the Seismic Qualification Utilities Group (SQUG). TVA will provide a completion date for this program after receipt of the SER from the NRC for the SQUG program.
Discussion: Reference 1 transmitted the SER for the interim acceptance evaluation of the seismic qualification cable tray supports. In the SER, it was noted the long term evaluation of the cable trays and supports seismic qualification would be covered under the NRC's Seismic Qualification of Equipment Program (Unresolved Safety Issue A-46). The acceptability of BFN's program to address this issue was also summarized in Reference 2. The status of this commitment was provided in Reference 3.
Reference 4 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure. As committed in Reference 5, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs will be submitted to NRC prior to the restart of Unit 1. This report will document the final qualification of BFN cable trays and supports. In Reference 6, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
Status: In Reference 7, TVA committed to complete the cable tray and supports portion of the USI A-46 program prior to March 19, 1996. The NRC found this commitment to be acceptable, as documented in Reference 8.
Page 9 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Cable Tray Svpports (Contlnved)-
References:
- 1) NRC letter to TVA, dated February 5, 1987, Transmittal of Safety Evaluation Concerning the Interim Acceptance Evaluation of Seismic Qualification Cable Tray Supports
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns .Ferry Unit 2 [Section 2.2.2.7, Page 2-6]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues I'Section III.3.3, Page 16)
- 4) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 5) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
- 6) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
- 7) TVA letter to NRC, dated January 19, 1993, Generic Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
- 8) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant 0
Page 10 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Class II Over Class I Features and Seismic Spatial lnteractlons-Commitment: The program to evaluate seismic spatial interactions and water spray effects of Seismic Class II piping on Seismic Class I piping will comply with the final resolution of the USI A-46 issue. TVA will provide a completion date for this program after receipt of the SER from the NRC for the USI A-46 program.
Discussion: In Reference 1, TVA submitted a description of the two phased approach for resolving the Seismic Class II over Class I features issue. Phase I was completed prior to restart and included an evaluation of water spray effects. The second phase was to evaluate seismic spatial interactions and re-evaluate water spray effects in accordance with the final resolution of the USI A-46 issue.
The acceptability of BFN's program to address this issue was also summarized in Reference 2. The status of this commitment was provided in Reference 3.
Reference 4 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure. As committed in Reference 5, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs will be submitted to NRC prior to the restart of Unit 1. This report will document the final evaluation of seismic spatial interactions and water spray effects. In Reference 6, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
Status: In Reference 7, TVA committed to complete the seismic portion of the USI A-46 program, which includes Class II over Class I features and seismic spatial interactions, prior to March 19, 1996. The NRC found this commitment to be acceptable, as documented in Reference 8.
Page 11 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Class ll Over Class I Features and Seismic Spatial Interactions (Continued)-
References:
- 1) TVA letter to NRC, dated March 29, 1988, Seismic Class II Features Over Seismic Class I Features
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.4.2, Page 2-10]
- 3) TVA letter to NRC, dated September 20, 1991i Status and Schedule for Completion of Unit 2 Post-Restart Issues [Sections III.3.10 and III.3.12, Pages 20 and 21]
- 4) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 5) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
- 6) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response-Browns Ferry Nuclear Plant
- 7) TVA letter to NRC, dated January 19, 1993, Generic Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
- 8) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
Page 12 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Component and Piece-Part QualifIcatIon Program-Commitment: An evaluation of both installed and inventoried items, used in non-10 CFR 50.49 safety related applications will be performed. The activity associated with the inventoried items. is expected to be completed by September 30, 1993. Those activities associated with the USI A-46 will have a completion date following the receipt of the NRC SER for the SQUG program.
Discussion: Reference =1 documents the NRC staff's review of the component and piece part qualification program. The post-restart commitments to evaluate installed and inventoried items used in non-10 CFR 50.49 safety related applications were found to be acceptable. The acceptability of BFN's program to address this issue was also summarized in Reference 2. The status of this commitment was provided in References 3 and 4.
Reference 5 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure. As committed in Reference 6, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs will be submitted to NRC prior to the restart of Unit 1. This report will document the final long term qualification of mechanical and electrical equipment. In Reference 7, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
Status: In Reference 8, TVA committed to complete the seismic portion of the USI A-46 program, which includes component and piece-part qualification, prior to March 19, 1996. The NRC found this commitment to be acceptable as documented in Reference 10.
In Reference 9, TVA revised the September 30, 1993 completion date for the non USI A-46 portion of this program to September 30, 1994.
Page 13 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Component and Piece-Part Qualification Program (Continued)-
References:
- 1) NRC letter to TVA, dated January 10, 1990, Volume 3,Section III.12.0 (Component and Piece Part Qualification) of the Nuclear Performance Plan Browns Ferry Nuclear Plant, Unit 2
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.3, Page 3-2]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.12.0, Page 30]
- 4) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 4]
- 5) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 6) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
- 7) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
- 8) TVA letter to NRC, dated January 19, 1993, Generic Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
Page 14 of 54 ENCLOSURE 1 0 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Component and Piece-Part Qualification Program (Continued)-
Volume III, Revision 2, Commitment Date Related to Component and Piece-Part Qualifications
- 10) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
Page 15 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Conduit Supports-Commitment: The long-term qualification of conduit supports will use the approach developed by the Seismic Qualification Utilities Group (SQUG). TVA will provide a completion date for this program after receipt of the SER from the NRC for the SQUG program.
Discussion: In Reference 1, TVA submitted its two phased program for the seismic qualification of conduits and supports. The first phase was completed prior to restart and the second phase would be covered under the NRC's Seismic Qualification of Equipment Program (Unresolved Safety Issue A-46). The acceptability of BFN's program to address this issue was provided in Reference 2. The status of this commitment was provided in Reference 3.
Reference 4 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure. As committed in Reference 5, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs will be submitted to NRC prior to the restart of Unit 1. This report will document the final qualification of BFN conduits and supports. In Reference 6, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
Status: In Reference 7, TVA committed to complete the conduit and conduit supports portion of the USI A-46 program prior to March 19, 1996. The NRC found this commitment to be acceptable, as documented in Reference 8.
References:
- 1) TVA letter to NRC, dated May 27, 1988, Seismic Qualification of Conduit
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.2.3, Page 2-10]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.3.4, Page 17]
Page 16 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Conduit Supports (Continued)-
- 4) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 5) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
- 6) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
- 7) TVA letter to NRC, dated January 19, 1993, Generic Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
- 8) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
Page 17 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Conf lguratlon Management-Commitment: The configuration management function will include a controlled master equipment list and a master design document list. Valve tabulations will be added by September 30, 1991. Remaining work is scheduled through the end of September 1993.
Discussion: In Reference 1, TVA stated that it had completed all of the CNPP commitments with corporate responsibility with the exception of this commitment relating to the configuration management system upgrade. The forecast completion date for this commitment was provided in Reference 2. Reference 2 also provided the following information:
- 1) The Master Equipment, List had been incorporated into the Browns Ferry Equipment Management System (EMS) data base.
- 2) The key safety related listings of equipment information have been loaded into EMS, including the Q-list and 10 CFR 50.49 list.
- 3) The procedures for maintaining these listings are in place.
- 4) The valve tabulations would be added by September 30, 1991.
- 5) The EMS, the Document Change Control Management (DCCM) System and the Calculation Cross Reference Information System (CCRIS) are the controlled systems that make up the Master Design Document List.
Status: As discussed during the January 8, 1993 TVA/NRC management meeting and in Reference 3, the commitment date has been revised to September 30, 1994.
0 Page 18 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Configuration Management (Continued)-
References:
- 1) TVA letter to NRC, dated April 5, 1991, Corporate Nuclear Performance Plan (CNPP)
- 2) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues t'Page 1]
- 3) TVA letter to NRC, dated February 3, 1993, Revision of Corporate Nuclear Performance Plan (CNPP), Volume I, Revision 6, Commitment Date Related to Master Equipment List
Page 19 of 54 ENCLOSURE I BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Configuration Management (Continued)-
Commitment: The post-restart phase of the Design Baseline Verification Program, including calculation activity, will be completed by the end of the Unit 2 Cycle 6 refueling outage. The items related to the resolution of the Unresolved Safety Issue (USI) A-46 will be responded to after the receipt of the SER from the NRC for the SQUG, program.
Discussion: Revision 4 of the Design Baseline and Verification Program (DBVP) was submitted for NRC review in Reference 1. The acceptability of BFN's program and references to the post-restart action items was contained in Reference 2. The DBVP was structured as a two phased program. Phase I of DBVP was completed prior to restart and was comprised of those systems or portions of systems required for the safe shutdown of the plant as identified in'Chapter 14 of the BFN Final Safety Analysis Report (FSAR).
Phase II of the DBVP extends the program to include the balance of the safety related functions. Portions of Phase II are to be addressed as part of the NRC's Seismic Qualification of Equipment Program (Unresolved Safety Issue A-46). The scope of Phase II was provided by Reference 3. The status of this commitment was provided in Reference 4.
Reference 5 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure. As committed in Reference 6, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs will be submitted to NRC prior to the restart of Unit 1. This report will document the resolution of the items related to the resolution of USI A-46. In Reference 7, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
0 Page 20 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Configuration Management (Continued)-
Status: In .Reference 8, TVA committed to complete the seismic portion of the USI A-46 program, which includes the configuration management portion, prior to March 19, 1996. The NRC found this commitment to be acceptable as documented in Reference 9. In accordance with Reference 10, TVA will submit separate letters that describe the completion of the DBVP and calculations activity.
References:
- 1) TVA letter to NRC, dated March 25, 1988; Design Baseline and Verification Program (DBVP) Program Plan Revision 4
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.1, Page 2-1]
- 3) TVA letter to NRC, dated May 3, 1991, Request for Additional Information on TVA's Design Baseline Verification Program (DBVP) Phase II
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post.-Restart Issues [Section III.2.0, Page 13 and Section III.4.0, Page 21]
- 5) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 6) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
Page 21 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Configuration Management (Continued)-
- 7) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
- 8) TVA letter to NRC, dated January 19, 1993, Generic Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
- 9) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
- 10) TVA letter to NRC, dated May 24, 1993, Completion of Commitments for Unit 2 Cycle 6 Outage
Page 22 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Drywell Steel Platforms-Commitment: Based on the resolution of the long-term criteria issue, TVA will qualify the drywell steel platforms and perform the necessary modifications before the end of the Unit 2 Cycle 6 refueling outage.
Discussion: The two phased approach for the seismic qualification of drywell steel was described in Reference 1. The first phase, which was completed prior to restart, was the qualification of the steel to an interim criteria. The second phase was the qualification of the drywell steel to a final design criteria. The NRC staff review and approval of this program is documented in Reference 2.
The design criteria for the seismic qualification of the drywell steel platforms was submitted in Reference 3. The status of this commitment was described in References 4 and 5. The NRC staff's SER and request for additional information on the criteria was included in Reference 6. TVA responded to the request for additional information in Reference 7. In Reference 8, the long term design criteria for drywell steel was found to be acceptable.
Status: Complete. Analyses and modifications were performed to qualify drywell steel platforms to the long term design criteria.
References:
- 1) TVA letter to NRC; dated May 26, 1988, Seismic Qualification of Drywell Steel
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.2.5, Page 2-6]
- 3) TVA letter to NRC, dated June 12, 1991, Corrective Action Plan and Design Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.3.8, Page 19]
Page 23 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PIANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Drywell Steel Platforms (Continued)-
- 5) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 1)
- 6) NRC letter to TVA, dated July 13, 1992, Safety Evaluation and Request for Additional Information Regarding Browns Ferry Nuclear Plant Units 1, 2, and 3 Design Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel
- 7) TVA letter to NRC, dated July 31, 1992, Response to Request for Additional Information Regarding Design Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel
- 8) NRC letter to TVA, dated October 29, 1992, Supplemental Safety Evaluation of Steel Design Criteria for the Browns Ferry Nuclear Plant Units 1, 2, and 3
Page 24 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Emergency Preparedness-Commitment: The upgraded public address and evacuation system will be completed by the end of the Unit 2 Cycle 6 refueling outage.
Discussion: In response to Bulletin 79-18, Audibility Problem Encountered on Evacuation of Personnel from High-Noise Areas, TVA initiated a design change to improve the public address and evacuation system.
The noise levels within the plant were determined and recommended equipment upgrades for in-plant and onsite buildings. The NRC staff closed this Bulletin in Reference 1.
A weakness in onsite accountability was identified in Reference 2. Reference 3 reflects TVA's commitment to improve the public address and evacuation system before restart from the Unit 2 Cycle 6 outage. The status of this commitment was discussed in Reference 4.
Status: Complete. The upgrade to the public address and evacuation system was completed during the Unit 2 Cycle 6 outage.
References:
- 1) NRC letter to TVA, dated February 4, 1986, Report Nos. 50-259/86-01, 50-260/86-01, and 50-296/86-01
- 2) NRC letter to TVA, dated November 15, 1988, NRC Inspection Report Nos. 50-259/88-30, 50-260/88-30, and 50-296/88-30
- 3) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 4.9, Page 4-4]
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.8.0, Page 11]
Page 25 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Environmental Qualification of Electrical Equlpment-Commitment: TVA will provide environmentally qualified instrumentation by Cycle 7 for Unit 2 for the core spray flow, residual heat removal system flow (LPCI mode) and Residual Heat Removal Service Water (RHRSW) flow instrumentation, and the emergency ventilation damper position indication variables. These items will be completed by the end of the Unit 2 Cycle 6 outage.
Discussion: Reference.1 provided the schedule for the environmental qualification of certain Regulatory Guide 1.97, Category 2 instruments, including the core spray flow, LPCI flow and RHRSW flow instrumentation, and emergency ventilation damper position indication variables. Justification for this schedule was also included. The NRC staff review and approval of this schedule is reflected in Reference 2. The status of this commitment was described in Reference 3.
Status: Complete. TVA has completed the upgrade of the electrical equipment described above. However, Reference 1 identified the specific dampers that would be upgraded to include environmentally qualified position indication prior to Unit 2 Cycle 7 startup. Two of these dampers were listed in error, FCO-64-44 and FC0-64-45, Refueling Zone exhaust to the Standby Gas Treatment System.
These dampers are located in a mild environment when Units 2 and/or 3 are in operation. They will be in a harsh environment when Unit 1 is restarted. Therefore, the upgrade in their environmental qualification is not required until prior to Unit 1 restart.
References:
- 1) TVA letter to NRC, dated August 23, 1988, Response to NRC's Safety Evaluation Report on Regulatory Guide 1.97 Compliance as Applied to Emergency Response Facilities, Dated June 23, 1988
- 2) NRC letter to TVA, dated April 14, 1989, Safety Evaluation Report on the Browns Ferry Nuclear Performance Plan NUREG-1232, Volume 3
[Section 3.2.2.1, Page 3-5]
- 3) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 4]
Page 26 of -54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Fire Protection lmprovement-Commitment: TVA is revising the Fire Protection Report, which will consolidate the fire protection program and fire protection related commitments into one document. The revised report will be available for review by January 15, 1992.
Discussion: As a result of numerous discussions with the NRC staff, TVA developed a systematic approach to replace the previous license condition for fire protection with an upgraded program. The first step was the development and submittal of the Fire Protection Report (Reference 1). The NRC staff's evaluation of TVA's fire protection program is discussed in Reference 2. The changes to the BFN Technical Specifications to allow the implementation of the NRC approved Appendix R Safe Shutdown Program were approved in Reference 3.
The status of the commitments to upgrade and consolidate the Fire Protection Report was provided in Reference 4.
Status: Complete. The revised Fire Protection Report was submitted for NRC review by Reference 5 and approved Reference 6.
References:
- 1) TVA letter to NRC, dated April 4, 1988, Fire Protection Report
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.1, Page 3-1]
- 3) NRC letter to TVA, dated March 6, 1991, Issuance of Amendment (TS 268)
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.5.0, Page 22 and Section IV, Page 37]
- 6) NRC letter to TVA, dated March 31, 1993, Fire Protection Program Browns Ferry Nuclear Plant Units 1, 2 and 3
Page 27 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PIANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Flexible Condult-Commitment: Non-restart safety related flexible conduits will be evaluated for seismic adequacy using the BFN A-46 program. A completion date for this program will be provided after receipt of the SER from the NRC for the SQUG program.
Discussion: TVA program for resolving flexible conduit installation issues was provided in Reference 1.
TVA committed to inspect all flexible conduit attached to 10 CFR 50.49 devices and to ensure the length was adequate for thermal and seismic movement. This program was completed prior to restart. Approval of this program is documented in Reference 2. As part of that approval, NRC requested that TVA fully comply with the final criteria applicable to flexible conduit associated with the NRC's resolution of USI A-46 for the long-term qualification of flexible conduits. The status of this commitment was discussed in Reference 3.
Reference 4 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure for the resolution of USI A-46. As committed in Reference 5, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs for BFN Units 1, 2, and 3 will be submitted to NRC prior to the restart of Unit 1. This report will document the long-term qualification of non-restart safety related flexible conduits. In Reference 6, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
Status: In Reference 7, TVA committed to complete the qualification of flexible conduits prior to March 19, 1996. In Reference 8, NRC requested TVA provide description of the general approach, a
including the procedure and acceptance criteria, that it will use to evaluate the seismic adequacy of flexible conduit not. attached to electrical equipment. covered by 10 CFR 50.49 by September 30, 1993.
0
Page 28 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PIANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Flexible Conduit (Continued)-
References:
- 1) TVA letter to NRC, dated August 18, 1989, Flexible Conduit Program Plan
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.12, Page 3-25]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.13.4, Page 32]
- 4) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 5) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
- 6) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response-Browns Ferry Nuclear Plant
- 7) TVA letter to NRC, dated January 19, 1993, Generic
. Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
- 8) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response Browns Ferry Nuclear Plant
Page 29 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Fuse Program-Commitment: BFN will remove the reference to amperage from the drawings and replace them with the identification from the fuse tabulation controlled document, prior to startup from the next refueling outage (Cycle 6).
Discussion: In Reference 1, TVA committed to complete drawing revisions to remove references to fuse ratings and to provide a unique identification for each Class 1E fuse such that it could be cross referenced to the fuse tabulation. The acceptability of the overall fuse program is documented in Reference 2. In Reference 3, TVA stated that this commitment was being re-evaluated.'eference 4 confirmed the original commitment and its completion schedule.
Complete. References to fuse amperage have been removed from the drawings and unique identifiers were added.
References:
- 1) TVA letter to NRC, dated April 9, 1990, Response to Inspection Report 50-260/89-59 Implementation of Electrical Issues Program
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.2, Page 3-9]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.13.6, Page 33]
- 4) TVA letter to NRC, dated January 29, 1992, Completion Plan for the Fuse Program
Page 30 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Fuse Program (Continued)-
Commitment: BFN will install permanent fuse labeling, prior to startup from the next refueling outage (Cycle 6).
Discussion: In Reference 1, TVA committed to install permanent fuse labeling. The acceptability of the overall fuse program is documented in Reference 2. In Reference 3, TVA stated that this commitment was being re-evaluated. Reference 4 confirmed the original commitment and its completion schedule.
Status: Complete. Fuses identified by the fuse tabulation have been labeled in accordance with Site Standard Practice 12.53, Component Labeling, Signs and Operator Aides.
References:
- 1) TVA letter to NRC, dated April 9, 1990, Response to Inspection Report 50-260/89-59 Implementation of Electrical Issues Program
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.2, Page 3-9]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.13.6, Page 33]
- 4) TVA letter to NRC, dated January 29, 1992, Completion Plan for the Fuse Program
Page 31 of 54 ENCLOSURE I BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Fuse Program (Continued)-
Commitment: Long-term post-restart fuse substitution corrective actions will include completing the fuse tabulation to include non-restart fuses required to assure protection of equipment and personnel and removing fuse data reflected on schematic and connection diagrams for all fuses controlled by the fuse tabulation. These actions are to be completed prior to startup following the first refueling outage.
Discussion: In Reference 1, TVA committed to completing the fuse tabulation to include non-restart fuses required to assure protection of equipment and personnel and removing fuse data reflected on schematic and connection diagrams for all fuses controlled by the fuse tabulation. The acceptability of the overall fuse program is documented in Reference 2. In Reference 3, TVA stated that this commitment was being re-evaluated. In Reference 4, TVA stated that it would include non-Class 1E fuses on the fuse tabulation on an as-needed bases and will devote its resources to the completion of the safety related elements of the fuse program.
Status: Commitment withdrawn in Reference 4.
References:
- 1) TVA letter to NRC, dated April 9, 1990, Response to Inspection Report 50-260/89 Implementation of Electrical Issues Program
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.11.2, Page 3-9]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.13.6, Page 33]
- 4) TVA letter to NRC, dated January 29, 1992, Completion Plan for the Fuse Program
Page 32 of 54 ENCLOSURE 1 e BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
HVAC Ductwork-Commitment: TVA will develop the long-term HVAC criteria and submit on the it for review by November 15, 1991. Based resolution of the criteria issue, TVA will qualify the HVAC ductwork and supports and perform the necessary modifications before the end of the Unit 2 Cycle 6 refueling outage.
Discussion: The two phased approach for the seismic qualification of HVAC and supports was described in Reference 1. The first phase, which was completed prior to restart, was the qualification of the HVAC to an interim criteria. The second phase was the qualification of the HVAC to a final design criteria. The NRC staff review and approval of this program is documented in Reference 2. The status of this commitment was described in References 3 and 5. The design criteria for the seismic qualification of the HVAC and supports was submitted in Reference 4. The NRC staff's SER on the criteria was included in Reference 6.
Status: Complete. The ductwork and supports qualified to the interim design criteria were reevaluated using the revised (long term) design criteria. No duct modifications were required. However, modifications to supports were required and have been completed.
References:
- 2) NRC letter to TVA, dated January 23, 1991/
NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.2.4, Page 2-5]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues (Section III.3.5, Page 17]
Seismic Design Criteria
Page 33 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
HVAC Ductwork (Continued)-
- 5) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Pages 1 and 2]
- 6) NRC letter to TVA, dated July 16, 1992, Evaluation of Seismic Design Criteria for Heating Ventilation and Air Conditioning Browns Ferry Nuclear Plant
Page 34 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT
.COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Instrument Tubing Program-Commitment: TVA will evaluate the 70 Seismic Class installations outside the design baseline I tubing boundary. This commitment will be completed by the end of the Unit 2 Cycle 6 outage.
Discussion: Reference 1 described the two phased program for the seismic qualification of instrument tubing.
The first phase, which was completed prior to restart, involved the seismic qualification of Seismic Class I tubing within the restart scope of the design baseline program. The second phase of the program was the evaluation of the Seismic Class I tubing installations outside the scope of the design baseline verification program (DBVP).
NRC approval of the program to seismically qualify instrument tubing is included in Reference 2. The status of this commitment was discussed in Reference 3.
Status: Complete. The Seismic Class I tubing outside the scope of the DBVP has been evaluated and the modifications required for qualification have been completed.
References:
- 1) TVA letter to NRC, dated June 13, 1989, Unit 2 Seismic Qualification of Instrument Tubing
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 ISection 2.2.3.-4, Page 2-10]
- 3) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 3]
0 Page 35 of 54 ENCLOSURE 1 e BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Intergranular Stress Corrosion Cracking (IGSCC)-
Commitment: Hydrogen water chemistry control will be implemented during the next refueling outage.
Discussion: In Reference 1, TVA committed to install a permanent hydrogen water chemistry system during or before the Cycle 6 refueling outage. The acceptability of TVA's program for IGSCC mitigation is documented in Reference 2. In Reference 3, TVA stated that it was re-evaluating its commitment to implement hydrogen water chemistry control on Unit 2 prior to restart from the next refueling outage. In Reference 4, TVA stated that it would complete the installation of a hydrogen water chemistry control system during Unit 2 Cycle 7.
Status: In Reference 5, TVA informed NRC that it decided not to install a HWCC system at the had present time, due to the potential negative plant impacts associated with HWCC implementation. This closed the commitment made to NRC.
References:
- 1) TVA letter to NRC, dated August 1, 1988, Response to Bulletin (sic) 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, dated January 25, 1988
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.6, Page 3-6]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.7.0, Page 26]
- 4) TVA letter to NRC, dated January 31, 1992, Implementation Plans for Hydrogen Water Chemistry Control (HWCC)
- 5) TVA letter to NRC, dated January 19, 1993, Implementation Plans for Hydrogen Water Chemistry Control (HWCC)
Page 36 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED) lntergranular Stress Corrosion Cracking (IGSCC) (Continued)-
Commitment: Six welds in the Core Spray System with austenitic stainless steel fittings will undergo post-Induction Heating Stress Improvement (IHSI) during the next refueling outage.
Discussion: In Reference 1, TVA committed to implement stress improvement to the six Core Spray welds that were inadvertently omitted from earlier IHSI work scopes. The acceptability of TVA's program for IGSCC mitigation is documented in Reference 2.
Reference 3 reflected TVA's commitment to perform induction heating stress improvement (IHSI).on the subject welds. However, NRC was notified in Reference 4 that, after further evaluation of the technical merits of this type of stress improvement, TVA had determined that a mechanical stress improvement process would be used instead of IHSI.
Status: Complete. Mechanical stress improvement was applied to the six Unit 2 core spray welds.
References:
- 1) TVA letter to NRC, dated August 1, 1988, Response to Bulletin (sic) 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, dated January 25, 1988
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 I'Section 3.6, Page 3-6]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.7.0, Page 26]
- 4) TVA letter to NRC, dated December 26, 1991, Unit 2 Position on Stress Improvement on Six Welds in the Core Spray System
Page 37 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Intergranular Stress Corrosion Cracking (IGSCC) (Continued)-
Commitment: The four inch and larger stainless steel piping of the Reactor Water Cleanup (RWCU) System located outside containment will be replaced during the next refueling outage.
Discussion: In Reference 1, TVA committed to replace the four inch and larger stainless steel RWCU piping.
located outside containment during the next refueling outage. The acceptability of TVA's program for IGSCC mitigation is documented in Reference 2. The status of this commitment was discussed in Reference 3.
Status: Complete. The four inch and larger stainless steel RWCU piping located outside containment has been replaced.
References:
- 1) TVA letter to NRC, dated May 22, 1989, TVA's Response to NRC Inspection Report No. 89-05 on Generic Letter (GL) 88-01
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.6, Page 3-6]
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.7.0, Page 26]
Page 38 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Microblologically Induced Corrosion (MIC)-
Commitment: TVA committed to determine the rate that MIC is progressing in the stainless steel welds of the EECW system. The next inspection effort will be at the end of the Unit 2 Cycle 6 outage. This inspection will provide. the data needed to establish the trend analysis and close this item.
Discussion: To determine the rate that MIC is progressing in the stainless steel welds of the EECW system, TVA committed in Reference 1 to re-inspect the welds identified with MIC and possible MIC indications in the 1987 inspection at each unit outage. In addition, a population of the butt welds would be re-radiographed at each outage to ensure structural integrity of the system. In Reference 2, the NRC staff concluded that TVA's inspection and monitoring program for MIC would provide reasonable assurance that these systems would not lose their capability to perform their safety functions because of MIC. The commitment was modified in Reference 3 to state that the next inspection effort would provide the data needed to establish the trend analysis and close this item.
Status: Complete. EECW welds were inspected and the results evaluated. The requirements for future inspections are being incorporated into plant procedures.
References:
- 2) NRC letter to TVA, dated Zanuary 23, 1991/
NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 I'Section 3.14, Page 3-27]
- 3) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 8]
Page 39 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Miscellaneous Steel-Commitment: Based on the resolution of the long-term criteria issue, TVA will qualify the miscellaneous steel and perform the necessary modifications before the end of the Unit 2 Cycle 6 refueling outage.
Discussion: The two phased approach for the seismic qualification of miscellaneous steel was described in Reference 1. The first phase, which was completed prior to restart, was the qualification of the steel to an interim criteria. The second phase was the qualification of the miscellaneous steel to a final design criteria. The NRC staff review and approval of this program is documented in Reference 2.
The design criteria for the seismic qualification of the miscellaneous steel was submitted in Reference 3. The status of this commitment was described in References 4 and 5. The NRC staff's SER and request for additional information on the criteria was included in Reference 6. TVA responded to the request for additional information in References 7 and 8. In Reference 9, the long term design criteria was found to be acceptable, with the exception of the use of a ductility ratio, which is being addressed separately. In Reference 10, NRC requested TVA perform additional analyses and provide a schedule for modifications.
Status: Complete. Analyses and modifications were performed to qualify miscellaneous steel to the long term design criteria. However, it is understood that the Safety Evaluation Report open item regarding the use of a ductility ratio is still outstanding with the NRC Staff (References 9 and 10) and will be addressed in separate correspondence.
References:
- 1) TVA letter to NRC, dated May 26, 1988, Seismic Qualification of Drywell Steel
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.2.5, Page 2-6]
Page 40 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Miscellaneous Steel (Continued)-
- 3) TVA letter to NRC, dated June 12, 1991, Corrective Action Plan and Design Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit. 2 Post-Restart Issues [Section III.3.9, Page 20]
- 5) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues I'Page 1]
- 6) NRC letter to TVA, dated July 13, 1992, Safety Evaluation and Request for Additional Information Regarding Browns Ferry Nuclear Plant Units 1, 2, and 3 Design Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel
- 7) TVA letter to NRC, dated July 31, 1992, Response to Request for Additional Information Regarding Design Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel
- 8) TVA letter to NRC, dated September 30, 1992, Resolution of the Thermal Growth Issue Outside Containment
- 9) NRC letter to TVA, dated October 29, 1992, Supplemental Safety Evaluation of Steel Design Criteria for the Browns Ferry Nuclear Plant Units 1, 2, and 3
- 10) NRC letter to TVA, dated March 22, 1993, Summary of the March 2, 1993 Meeting Regarding Thermal Growth of Steel Structures at the Browns Ferry Nuclear Plant
Page 41 of 54 ENCLOSURE 1 e BROWNS FERRY NUCLEAR PLANT-COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Probablllstlc Risk Assessment (PRA)-
Commitment: TVA committed to complete a Level 1 PRA and containment. analysis, in accordance with the requirements of Generic Letter 88-20, and submit the results by September 1, 1992. The PRA will reflect short and long term ECCS pump combination requirements and revised human factors considerations.
Discussion: In Reference 1, the NRC staff requested all licensees perform an IPE for severe accident vulnerabilities. At that time, TVA was preparing a draft BFN PRA. As a result of the NRC staff's review of the draft PRA, in Reference 2, the NRC staff forwarded a concern with the combination of
.RHR pumps used in the draft BFN PRA. TVA responded to this concern in Reference 3 by stating that TVA would revise the PRA to reflect the correct short and long term pump requirements in the next update. In Reference 4, the NRC staff forwarded another concern regarding the PRA sequence that pertained to the residual heat removal (RHR) system's performance after a stuck open relief valve.
TVA responded to Reference 1 in Reference 5. TVA committed to complete a Level 1 PRA and containment analysis by September 1, 1992. TVA responded to Reference 4 in Reference 6. TVA committed to revise the human factors consideration for the next PRA update. In Reference 7, the NRC staff stated that the (then draft) PRA results were considered acceptable for restart. The status of the above commitments were discussed in References 8 and 9.
Status: Complete. The Individual Plant Examination for BFN was forwarded to NRC on September 1, 1992, as requested by Generic Letter 88-20 (Reference 10).
Page 42 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Probablllstlc Risk Assessment (PRA) (Continued)-
References:
- 1) NRC letter to All Licensees, dated November 23, 1988, Individual Plant Examination for Severe Accident Vulnerabilities 10 CFR 50.54(f)
- 2) NRC letter to TVA, dated March 29, 1989, Volume 3,Section III.11.0 (Probabilistic Risk Assessment) of the Nuclear Performance Plan Browns Ferry Nuclear Plant, Unit 2
- 3) TVA letter to NRC, dated June 15, 1989, Nuclear Regulatory Commission (NRC) Audit of TVA's Probabilistic Risk Assessment (PRA)
- 4) NRC letter to TVA, dated July 10, 1989, Additional NRC Staff Audit Insights Pertaining to the Browns Ferry Risk Review Generic Letter 88-19 (sic)
- 5) TVA letter to NRC, dated October 30, 1989, Proposed Program in Response to Generic Letter 88-20 Individual Plant Examination (IPE) for Severe Accident Vulnerabilities
- 6) TVA letter to NRC, dated May 1, 1990, Probabilistic Risk Assessment (PRA) and Emergency Operating Procedure (EOP)
- 7) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.9, Page 3-8]
- 8) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.11.0, Page 29]
- 9) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Pages 5 and 6]
- 10) TVA letter to NRC, dated September 1, 1992/
Response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities 0
Page 43 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Probablllstlc Risk Assessment (PRA) (Continued)-
Commitment: When BFN installs the hardened vent, the BFN PRA will be updated to reflect this change in plant design.
Discussion: After an audit of the draft BFN PRA, the Staff expressed concerns with the adequacy of a PRA sequence that, pertained to the residual heat removal (RHR) system (Reference 1). This PRA sequence involves a transient that is followed by 1 to 3 stuck open relief valves. The Staff stated that they would like to see venting, using a hardened vent, incorporated into the PRA for this sequence. In Reference 2, NRC requested Licensees with Mark I containments voluntarily install a hardened vent. TVA committed to install a hardened vent during the next refueling outage (Cycle 6) in Reference 3. TVA's commitment to model the hardened vent in the PRA after the installation of the vent was included in Reference 4. This post-restart commitment is documented in Reference 5 and the status of the commitment was reported in Reference 6.
Status: The hardened vent will be incorporated into the BFN PRA in the next update.
References:
- 1) NRC letter to TVA, dated July 10, 1989, Additional NRC Staff Audit Insights Pertaining to the Browns Ferry Risk Review Generic Letter 88-19 (sic)
- 2) NRC letter to All Operating Licensees with Mark I Containments, dated September 1, 1989, Installation of a Hardened Wetwell Vent (Generic Letter 89-16)
- 3) TVA letter to NRC, dated October 30, 1989, Response to Generic Letter 89-16 "Installation of Hardened Wetwell Vent"
- 4) TVA letter to NRC, dated May 1, 1990, Probabilistic Risk Assessment (PRA) and Emergency Operating Procedure (EOP)
Page 44 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Probablllstic Risk Assessment (PRA) (Continued)-
- 5) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.9, Page 3-8]
- 6) TVA letter to NRC, dated December 24, 1991, Supplement to the Status and Schedule for Completion of Unit 2 Post-Restart Issues [Page 6]
Page 45 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Procedures-Commitment: The maintenance instructions upgrade will be completed by September 30, 1993.
Discussion: The NRC staff reviewed the Procedures Upgrade Program in Reference 1. The short term portion of the program was completed prior to restart and the long term portion was scheduled to take several years. The September 30, 1993 completion schedule for this commitment was provided in Reference 2.
Status: The completion of the commitment is scheduled for September 30, 1993.
References:
- 1) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 - Browns Ferry Unit 2 [Section 4.11.2.4, Page 4-11]
- 2) TVA letter to NRC, dated September 20, 1991/
Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.2.4, Page 5]
Page 46 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Procedures (Continued)-
Commitment: The new procedures system of policies, directives, standards, procedures, and instructions will be developed under controls that will systematically ensure the identification and incorporation of regulatory requirements, responsibilities, and organizational interfaces. This commitment will be completed by October 31, 1991.
Discussion: The NRC staff reviewed the Procedures Upgrade Program in Reference 1. The October 31, 1991 completion schedule for this commitment was provided in Reference 2.
Status: Complete. This commitment was closed based upon the program being well defined and completed on a corporate level with programs in place on site to support transition to the new procedures system documents. This assured the integrity of administrative controls over site programs. The long term efforts to upgrade TVA's Nuclear Power and operating plant procedures has reduced the complexity of the procedures hierarchy and produced a well ordered administrative system of policies and procedures that provide clear guidance for the conduct of activities of Nuclear Power.
The new hierarchy of policies, standards, procedures, and instructions had been developed under controls that systematically ensured the identification and incorporation of regulatory requirements, responsibilities, organizational interfaces, and site specific requirements. The transition to the new procedures system documents was conducted in accordance with corporate standards and with management oversight from corporate and site.
References:
- 1) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 4.11.1, Page 4-6]
- 2) TVA letter to NRCg dated September 20i 1991i Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.2.4, Page 5]
Page 47 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Procedures (Continued)-
Commitment: TVA will fully implement Revision 4 of the Emergency Procedures Guidelines by June 15, 1992.
Discussion: TVA committed to implement the Revision 4 EPGs in Reference 1. After reevaluating the scope of the project, TVA re-scheduled the completion date of this commitment in Reference 2. The status of this commitment was discussed in Reference 3 and the subject of the TVA/NRC meeting that is documented in Reference 4.
Status: Complete. Reference 5 provided notification of the implementation of Revision 4 of the Boiling Water Reactor Owners'roup (BWROG) EPGs into the EOIs used at BFN. As documented in Reference 6, an NRC inspection team found that Revision 4 of the BWROG guidelines had been satisfactorily implemented.
TVA letter to NRC, dated May 31, 1989, Response to NRC Inspection Report No. 50-260/88-200 on Emergency Operating Instructions (EOIs)
- 2) TVA letter to NRC, dated July 6, 1990, Unit 2 Implementation of Revision 4 Emergency Procedure Guidelines (EPGs)
- 3) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.3.0, Page 8]
- 4) NRC letter to TVA; dated November 1, 1991, Summary of September 24, 1991 Meeting with the Tennessee Valley Authority Regarding Implementation of Revision 4 of the Emergency Procedure Guidelines
- 5) TVA letter to NRC, dated June 15, 1992, Implementation of Revision 4 Emergency Procedure Guidelines (EPGs) into the BFN Emergency Operating Instructions (EOIs)
- 6) NRC letter to TVA, dated August 25, 1992, NRC Inspection Report No. 50-260/92-27
Page 48 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Q-LIst-Commitment: TVA is developing a Q-List for BFN. This program is a two phase program. Phase 2 is expected to be completed by September 30, 1993.
Discussion: NRC regulations require that all safety related structures, systems, and components be identified.
The Q-list performs this function at BFN. The NRC staff's review of the Q-list program is documented in Reference 1. The status of this commitment was discussed in Reference 2. As discussed during the January 8, 1993 TVA/NRC management meeting and in Reference 3, the commitment date has been revised to September 30, 1994.
t Status: Phase 2 of the Q-List is scheduled to be completed by September 30, 1994.
References:
- 1) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 3.15, Page 3-27]
- 2) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section III.13.6, Page 34]
- 3) TVA letter to NRC, dated February 3, 1993, Revision of Corporate Nuclear Performance Plan (CNPP), Volume I, Revision 6, Commitment Date Related to Master Equipment List
Page 49 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Radlologlca1 Control and Chemistry Improvement (Post-Accident Sampling System)-
Commitment: The permanent Post-Accident Sampling System (PASS) will be installed. The testing. of the PASS containment atmosphere sampling and analysis is the only open item.
Discussion: The installation of post-accident sampling system was a requirement of NUREG-0737 (TMI Action Plan),
Item II.B.3, Post-Accident Sampling Capability.
In Reference 1, TVA accelerated the completion of this item commitment such that it would be installed prior to restart. The acceptability of this schedule was documented in Reference 2. In Reference 3, TVA notified the NRC staff that the PASS was installed. In Reference 4, TVA notified the NRC staff that the testing of the system, with the exception of the containment atmosphere, was completed.
Complete. Notification of the completion of this TMI Action Item, including the testing of the containment atmosphere, was provided by Reference 5.
References:
- 1) TVA letter to NRC, dated December 28, 1989, Browns Ferry Nuclear Performance Plan, Attachment IV-4, Response to Request for Additional Information
- 2) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 4.10, Page 4-4]
- 3) TVA letter to NRC, dated April 16, 1991, Completion Status of Corrective Actions Identified for Unit 2 Restart in Browns Ferry Nuclear Performance Plan (BFNPP) [Page 43 of 46]
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.6.0, Page 9]
- 5) TVA letter to NRC, dated March 4, 1992, Completion of NUREG-0737 (TMI Action Plan), Item II.B.3, Post-Accident Sampling Capability 0
Page 50 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
SecurIty-Commitment: The upgraded security system will be installed by March 31, 1993.
Discussion: The acceptability of the physical security upgrade program was documented in Reference 1. It assumed adequate implementation of the following security related actions:
- 1) Test security emergency power,
- 2) Reduce the size of the protected area,
- 3) Improve alarm assessment capabilities, and
- 4) Reduce the number of compensatory measures.
The first item was verified by the Staff as complete in Inspection Report 50-260/89-09, dated March 11, 1989. The status of the remaining actions was provided in Reference 2.
Status: As documented in Reference 3, the tracking of, and schedule for, the completion of phase one of the BFN security upgrade project in included in the Physical Security Plan.
References:
- 1) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 4.8, Page 4-4]
- 2) TVA letter to NRC, dated September 20, 1991/
Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.7.0, Page 11]
- 3) TVA letter to NRC, dated March 29, 1993, Security Program Upgrade
Page 51 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Seismic Qualification of Mechanical and Electrical Equlpment-Commitment: The seismic qualification of mechanical and electrical equipment will use the approach developed by the Seismic Qualification Utilities Group (SQUG). TVA will provide a completion date for this program after receipt of the SER from the NRC for the SQUG program.
Discussion: In Reference 1, the NRC staff stated that the issues relating to the seismic qualification of mechanical and electrical equipment would be resolved when the staff implemented its resolution of USI A-46. The status of this commitment was discussed in Reference 2.
Reference 3 transmitted the NRC staff's Supplemental SER of the SQUG's Generic Implementation Procedure for the resolution of USI A-46. As committed in Reference 4, a Seismic Evaluation Report summarizing the results of the USI A-46 and seismic IPEEE programs for BFN Units 1, 2, and 3 will be submitted to NRC prior to the restart of Unit 1. This report will document the long-term seismic qualification of mechanical and electrical equipment. In Reference 5, NRC stated that TVA's proposed completion date for Units 2 and 3 was unacceptable.
Status: In Reference 6, TVA committed to complete the seismic portion of the USI A-46 program prior to March 19, 1996. The NRC found this commitment to be acceptable as documented in Reference 7.
References:
'1) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.2.3, Page 2-10]
- 2) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues I'Section III.3.12, Page 21]
Page 52 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Seismic Qualification of Mechanical and Electrical Equipment (Continued)-
- 3) NRC letter to All Unresolved Safety Issue (USI)
A-46 Plant Licensees who are Members of the Seismic Qualification Utility Group (SQUG), dated May 22, 1992, Supplement No. 1 to Generic Letter 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992
- 4) TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic Letter 88-20, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities
- 5) NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response-Browns Ferry Nuclear Plant
- 6) TVA letter to NRC, dated January 19, 1993, Generic Letter 87-02, Supplement 1, 120-Day Response, Request for Additional Information
- 7) NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response - Browns Ferry Nuclear Plant
0 Page 53 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Slmulator-Commitment: The BFN simulator would be modified to a plant referenced simulator and that TVA would certify by March 1991, in accordance with 10 CFR 55, that this modification would be completed.
Discussion: Reference 1 requested a temporary exemption, until December 31, 1991, for the simulator certification requirements of 10 CFR 55.45(b)(2)(iii). This exemption was granted in Reference 2. The status of this commitment is discussed in References 3 and 4.
Status: Complete. In Reference 5, TVA certified the plant reference simulator in accordance with 10 CFR 55.45(b)(5) ~
References:
- 1) TVA letter to NRC, dated July 13, 1990, Request for Temporary Exemption from 10 CFR 55.45(b)
- 2) NRC letter to TVA, dated January 2, 1991, Exemption from 10 CFR 55.45(b)(2)(iii) and=(iv)
- 3) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 4.7, Page 4-3]
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.2.3, Page 3]
Page 54 of 54 ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT COMPLETION OF UNIT 2 POST-RESTART ISSUES (CONTINUED)
Small Bore Plplng-Commitment: Modifications required to meet the final design criteria for small bore piping and supports will be completed prior to restart from the Unit 2 Cycle 6 refueling outage.
Discussion: Reference 1 described the two phased program for the seismic qualification of small bore piping.
The first phase, which was completed prior to restart, involved the seismic qualification of Seismic Class I small bore piping within the restart scope of the design baseline program. The second phase of the program was the evaluation of Seismic Class I small bore piping outside the scope of the design baseline program. The resolution of a concern regarding the sample size used to validate attr'ibutes for the horizontal slice portion of the small bore program is contained in Reference 2. NRC approval of the program to seismically qualify small bore piping is included in Reference 3. The status of this commitment was discussed in Reference 4.
Status: Complete. The Seismic Class I small bore piping outside the scope of the DBVP has been evaluated and the modifications required for qualification have been completed.
References:
'2) TVA letter to NRC, dated November 6, 1989, Unit 2 Small Bore Piping Rigorous Analysis Population
- 3) NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 Browns Ferry Unit 2 [Section 2.2.3.3, Page 2-9]
- 4) TVA letter to NRC, dated September 20, 1991, Status and Schedule for Completion of Unit 2 Post-Restart Issues [Section II.3.7, Page 19]