ML18037A756

Requests That NRC Not Schedule Full Scope NRC SWS Operational Performance Insp at Plant,As Part of Util Operating & Maint Cost Reduction Program.Util Plans to Conduct self-assessment of Plant EECW & RHRSW Sys

ML18037A756
Person / Time
Site:	Browns Ferry
Issue date:	02/02/1994
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9402150228
Download: ML18037A756 (20)

Text

ACCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9402150228 DOC.DATE: 94/02/02 NOTARIZED: NO FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee

'OCKET 05000259~

50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION SALAS,P. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Requests that NRC not schedule full scope NRC SWS D operational performance insp at plant, as part of operating 6 maint cost reduction program. Util plans to util conduct self-assessment of plant EECW 6 RHRSW sys.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: Co TITLE: OR Submittal: General Distribution NOTES:

D RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-4 1 1 PD2-4-PD 1 1 TRIMBLE,D 2 2 WILLIAMS,J. 2 2 S INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1.'

NRR/DORS/OTSB 1 1 NRR/DRCH/HICB 1 1 NRR/DRPW 1 1 NRR/DSSA/SPLB 1 "1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OG/BPD'CB 1 0 OGC/HDS3 1 0 R FILE Ol 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

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D NOTE TO ALL "RIDS" RECIPIENTS:

'S PLEASE HELP US TO REDUCE WASEE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISI'RIBUTION LIPID FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 22

Tennessee Valley Authority. Post Of(ice Box 2000. Decatur. Alabama 35609 FEB 02 1994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1~ 2p AND 3 OPERATING & MAINTENANCE (O&M) COST REDUCTION PROGRAM REQUEST FOR NRC REVIEW AND APPROVAL OF COST BENEFICIAL LICENSING ACTION (CBLA) RLA-03: REDUCED SCOPE NRC SERVICE WATER SYSTEM INSPECTION As part of TVA's Operating & Maintenance Cost Reduction Program, TVA requests that NRC not schedule a full scope NRC Service Water System Operational Performance Inspection (SWSOPI) at BFN. TVA bases this request on its plans to conduct a self-assessment of BFN's Emergency Equipment Cooling Water (EECW) and Residual Heat Removal Service Water (RHRSW) systems, which are the "service water systems" at BFN. In accordance with NRC Inspection Procedure (IP) 40501, "Licensee Self-Assessments Related to Area-of-Emphasis Inspections," TVA proposes that NRC conduct a reduced scope inspection of TVA's self-assessment instead of the full scope inspection.

TVA's self-assessment will meet the criteria for acceptability identified in IP 40501 and will provide assurance that BFN's EECW and RHRSW systems are capable of performing their safety-related functions. TVA is confident that its self-assessment will identify weaknesses or deficiencies in these systems if they exist. Any identified weaknesses and deficiencies will be addressed by TVA's corrective action programs, as appropriate. Therefore, a full-scope NRC SWSOPI is not necessary.

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U. S. Nuclear Regulatory Commission Page 2 FEB 0 8 994 Currently, TVA is developing the detailed plan to conduct the BFN self-assessment. This plan will not be finalized until lessons learned from forthcoming self-assessment activities at Sequoyah Nuclear Plant (SQN), as well as any results from the NRC SWSOPI at SQN (currently planned for mid-July 1994),

are available. Once the lessons learned are incorporated into the BFN self-assessment plan, and TVA has finalized the team makeup, TVA will submit the plan to NRC for approval, in accordance with IP 40501. TVA expects to submit the BFN self-assessment plan to NRC within 60 days of issuance of the NRC inspection report for the SQN inspection.

Following NRC review and approval of the BFN self-assessment plan, TVA will conduct the self-assessment of the BFN EECW and RHRSW systems. TVA expects to commence the self-assessment within 90 days of NRC approval of the self-assessment plan. Following completion of the self-assessment, TVA will issue a report which documents the findings of the self-assessment as well as planned corrective actions to address identified weaknesses and deficiencies.

TVA expects to issue the report within 60 days of completion of the self-assessment.

TVA is submitting this request as a CBLA since a reduced scope NRC inspection of TVA's self-assessment involves significant savings of resources and will provide equivalent assurance of safety. TVA estimates that a reduced scope inspection, in lieu of the full-scope inspection, would result in one-time savings to TVA exceeding $ 300,000. to this letter provides the specifics of TVA's request. Enclosure 2 lists the commitments made in this letter.

If you telephone have any questions regarding me at (205) 729-2636.

this request, please Sincerel Pedro Salas Manager of Site Licensing Enclosures cc: See page 3

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U.S. Nuclear Regulatory Commission FEB 0 2 1994 Enclosures CC (Enclosures):

Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. A. F. Gibson, Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. F. P. Gillespie, Director Program Management Policy Development and Analysis Staff U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. E. W. Merschoff, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Regional Administrator U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611

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U.S. Nuclear Regulatory Commission Page 4 FEB 02 l994 Mr. D. C. Trimble, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Z. F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. R. P. Zimmerman U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNZTS 1q 2q AND 3 OPERATING & MAINTENANCE (O&M) COST REDUCTION PROGRAM REQUEST FOR COST BENEFICIAL LICENSING ACTION RLA-03 REDUCED SCOPE NRC SERVICE WATER SYSTEM ZNSPECTZON I'UMMARYOF RLA-03 As part of TVA's 0&M Cost Reduction Program, TVA requests that NRC not schedule a Service Water System Operational Performance Inspection (SWSOPI) at BFN based on TVA's plans to conduct a self-assessment of BFN's Emergency Equipment Cooling Water (EECW) and Residual Heat Removal Service Water (RHRSW) systems. In accordance with the guidance of NRC Inspection Procedure (IP) 40501, "Licensee Self-Assessments Related to Area-of-Emphasis Inspections,"

TVA proposes that NRC conduct a reduced scope inspection of TVA's self-assessment, rather than a full scope inspection.

TVA's self-assessment will meet the criteria for acceptability identified in IP 40501, and will provide equivalent assurance that BFN's EECW and RHRSW systems are capable of performing their safety-related functions.

Therefore, a full-scope NRC SWSOPI is not necessary.

TVA estimates that performance of a reduced scope NRC inspection of TVA's self-assessment would result in one-time savings to TVA exceeding $ 300,000.

II'ACKGROUND In 1989, following NRC review of industry operating experience and internal NRC studies, NRC questioned the compliance of nuclear plant service water systems with certain general design criteria and quality assurance requirements. As a result, NRC issued Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment." This GL required that licensees and applicants take several actions to ensure that their service water systems comply with, and are maintained to comply with, the applicable general design criteria and quality assurance requirements.

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In SECY 92-355, dated October 20, 1992, "Implementing Service Water System Operational Performance Inspections (SWSOPIs),>> the NRC noted that since the GL was issued, a number of plant specific service water system design and operational concerns have been identified. Due to these continuing concerns, NRC announced plans for a major team inspection program of plant service water systems. On November 23, 1992, the Commission approved this inspection program.

Following Commission approval, NRC initiated performance of SWSOPIs in accordance with NRC Temporary Instruction (TI) 2515/118, "Service Water System Operational Performance Inspection (SWOPI)." The purpose of SWSOPIs is to assess planned or completed actions in response to GL 89-13, and verify that service water systems are capable of fulfilling their thermal and hydraulic performance requirements and are operated consistent with their design bases. In addition, the inspections would assess service water system operational controls, maintenance, surveillance and other testing, and personnel training to determine if service water systems are operated and maintained to ensure the capability to perform their safety-related functions.

According to TI 2515/118, NRC will be focusing these inspections on plants licensed prior to 1979, such as BFN (currently, BFN has not been formally scheduled). For these plants, the TI provides for inspection implementation latitude up to complete waiver if a recent in-depth NRC inspection has been conducted which provides the equivalent of a SWSOPI in scope. Although the TI provides for waiver of the inspection at plants licensed after 1979 that have conducted self-assessments, it not specifically address inspection waiver for pre-1979 does plants that have conducted self-assessments.

Subsequently, NRC issued IP 40501. In this IP NRC notes that it will "recognize a licensee's good performance and quality self-assessment by reducing the scope of [an] NRC inspection." This reduced-scope inspection is contingent on the licensee self-assessment meeting certain criteria outlined in the IP. Specifically, the self-assessment must be at least equivalent in scope and depth to the inspection criteria outlined in the TI associated with the area of emphasis inspection. In addition, the self-assessment team must have the necessary credentials and experience to perform a technically creditable self-assessment.

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III~ REQUESTED NRC LICENSING ACTION TVA requests that a full scope SWSOPI not be scheduled for BFN. In accordance with IP 40501, TVA proposes that NRC perform a reduced scope inspection of TVA's planned self-assessment of the BFN EECW and RHRSW systems, in lieu of the full-scope inspection.

IV BASIS FOR REQUESTED NRC LICENSING ACTION TVA will be performing a self-assessment of the BFN EECW and RHRSW systems modeled after NRC TI 2515/118. This self-assessment will meet the criteria for acceptability identified in NRC IP 40501. TVA plans to use a multidisciplined team to conduct the assessment, including experienced personnel from BFN and TVA's corporate office.

In addition, TVA plans to supplement the team with outside expertise, as necessary.

TVA's self-assessment will demonstrate that BFN's EECW and RHRSW systems are designed, operated, and maintained to ensure their capability to'erform their safety-related functions. TVA's self-assessment will assess the effectiveness of planned and completed actions in response to GL 89-13. TVA's self-assessment will also assess the capability of BFN's EECW and RHRSW systems to fulfill their thermal and hydraulic performance requirements.

TVA routinely uses NRC inspection guidance, including temporary instructions, to conduct self-assessments and to help prepare for major team inspections such as Electrical Distribution System Functional Inspections (EDSFIs) and SWSOPIs. In the most recent Systematic Assessment of Licensee Performance (SALP) for BFN Unit 2 (NRC Inspection Report 50-260/93-31, dated November 4, 1993), NRC recognized the quality of TVA's self-assessments by stating that TVA's "self-assessment efforts . . . are generally effective, in-depth and normally identify and correct weaknesses in [TVA's] programs." Accordingly, TVA is confident that its proposed self-assessment will identify weaknesses or deficiencies in these systems if they exist. Furthermore, deficiencies are if identified, any weaknesses or TVA will address them in accordance with appropriate elements of its corrective action program. Therefore, a full-scope NRC SWSOPI would not be necessary.

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t II Currently, TVA is developing the detailed plan to conduct the BFN self-assessment. This plan will not be finalized until lessons learned from forthcoming self-assessment activities at Sequoyah Nuclear Plant (SQN), as well as any results from the NRC SWSOPI at SQN (currently planned for mid-July 1994), are available. Once the lessons learned from the Sequoyah self-assessment and results from the NRC inspection are incorporated into the BFN self-assessment plan, and TVA has finalized the team makeup, TVA will submit the BFN plan to NRC for approval, in accordance with IP 40501. This plan will include the scope and depth of the self-assessment, as well as the composition of the team that will conduct the assessment. TVA expects to submit the BFN self-assessment plan to NRC within 60 days of issuance of the NRC inspection report for the SQN inspection.

Following NRC review and approval of the BFN self-assessment plan, TVA will conduct the self-assessment of the BFN EECW and RHRSW systems. TVA expects to commence the self-assessment, within 90 days of NRC approval of the self-assessment plan. Following completion of the self-assessment, TVA will issue a report which documents the findings of the self-assessment as well as planned corrective actions to address identified weaknesses and deficiencies. TVA expects to issue the report within 60

, days of completion of the self-assessment.

JUSTIFICATION FOR HIGHER PRIORITY REVIEW A. RLA-03 Is Safet Neutral As noted above, NRC IP 40501 establishes acceptance criteria for licensee self-assessments and provides guidance for NRC to evaluate these self-assessments.

Consequently, a self-assessment that is conducted by TVA in accordance with an NRC-approved plan, and evaluated by NRC per the guidance of NRC IP 40501, provides equivalent assurance of safety as a full-scope NRC inspection. Therefore, TVA's request that NRC conduct a reduced scope inspection of this self-assessment in lieu of a full scope NRC team inspection is safety neutral.

B. RLA-03 Provides 8i nificant Cost Bavin s and Other Benefits TVA estimates that waiver of a full-scope NRC SWSOPI at BFN will result in cost savings exceeding

$ 300,000. TVA bases this estimate on the cost of previous similar scope inspections (e.g., EDSFIs or Integrated Design Inspections), with appropriate adjustments for current NRC fees, and the approximate internal costs associated with supporting such inspections.

In addition to significant cost savings for TVA, a reduced scope NRC inspection would also allow NRC to focus its resources on other safety significant issues.

VIE CONCLU8ION TVA is fully capable of performing an effective self-assessment of the BFN EECW and RHRSW systems. TVA's self-assessment will provide assurance that BFN's EECW and RHRSW systems are capable of performing their safety-related functions. Consequently, a full-scope is not necessary. Furthermore, a reduced scope NRC'nspection NRC inspection of TVA's self-assessment would significantly reduce the burden on TVA resources, and would also conserve NRC resources, without adversely impacting safety.

TVA has determined that RLA-03 (inclusive of TVA~s forthcoming IP 40501 submittal noted above) is a cost beneficial licensing action since it is safety neutral and provides significant cost savings.

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1g 2g AND 3 OPERATING 6 MAINTENANCE (OSM) COST REDUCTION PROGRAM REQUEST FOR COST BENEFICIAL LICENSING ACTZON RLA-03 REDUCED SCOPE NRC SERV1CE WATER SYSTEM INSPECTION List of Commitments

1. TVA will submit to NRC for review and approval its plan for conducting a self-assessment of the BFN Emergency Equipment Cooling Water (EECW) and Residual Heat Removal Service Water (RHRSW) systems. This plan will include the scope and depth of the self-assessment, as well as the composition of the team that will conduct the assessment. TVA expects to submit the plan within 60 days of issuance of the NRC inspection report for the NRC Service Water System Operational Performance Inspection of Seguoyah Nuclear Plant.

2. Following NRC review and approval of TVA's plan for conducting a self-assessment of the BFN EECW and RHRSW systems, TVA will perform the self-assessment. TVA expects to commence this self-assessment within 90 days of NRC approval of the self-assessment plan.

3. Following completion of TVA's self-assessment of the BFN EECW and RHRSW systems, TVA will issue a report which documents the findings of the self-assessment as well as planned corrective actions to address identified weaknesses and deficiencies. . TVA expects to issue the report within 60 days of completion of the self-assessment.

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