ML20066D708

Submits Plan for Achieving Restart of Units 1 & 3.Summary of Actions Taken in Response to NRC 850914 Request Will Be Submitted Prior to Unit 2 Restart.Supporting Info Encl

ML20066D708
Person / Time
Site:	Browns Ferry
Issue date:	01/09/1991
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1232 NUDOCS 9101150314
Download: ML20066D708 (20)

Text

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.: TENNESSEE \! ALLEY AUTHORITY JAN 091991 6N Lookout Place U.S. Nuclear Regulatory Commission.

ATTN 1- 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) - PLANS FOR THE RETURN TO SERVICE OF BFN UNITS 1 AND 3 This letter submits TVA's plan for achieving-the restart of BFN Units 1

-and 3. By letter dated September 17, 1985, the NRC requested, pursuant.to 10 CFR-50.54(f), that TVA specify the corrective actions which would be completed prior to the restart of any of the TVA opert.;ing facilities and a schedule for longer term actions. TVA responded for the Browns Ferry Nuclear Plant with the~ submittal and subsequent' revisions to the Corporate Nuclear Performance Plan (CNPP) and Browns Ferry Nuclear Performsnce Plan (BFNPP). .

NRC review of these plans is documented in Volumes 1 and 3 of NUREG-1232. )

Section 1.0 of the BFNPP states that the CNPP and the BFNPP provided a complete account of TVA's actions to improve its nuclear program for BFN and that these volumes served as the basis for the restart of BFN.- It further i states that although many of the programs associated with Unit 2 restart have applicability to Unita 1 and 3, the BFNPP was specifically directed to l Unit:2. TVA: considers the issues raised by the NRC's September 17, 1985 l letter resolved by the implementation of the CNPP and BFHPP for Unit 2.

-Accordingly, as previously discussed with NRC, TVA will submit a summary of the Browns Ferry specific actions taken in response to the NRC's September 17, 1985 request. This submittal will be submitted prior to Unit 2 restart.

Programs and commitments contained in the BFNPP, including those applicable to Units 1 and 3, will be tracked to completion as-part-of TVA's normal commitment tracking system.

Section 1.0 of the BFNPP also stated that an-evaluation of the programa described in the BFNPP would be performed to determine applicability to Units 1 and 3. This. evaluation has been performed and is documented in the Integrated Restart Action Plan. TVA's plans for restart of Units 1 and 3 are based on the requirements for restart of Unit 2. The restart effort for Units 1 and 3 will also take advantage of the extensive discovery efforts expended

-on BFN Unit 2.

d 9101150314 910109 PDR P

ADOCK 05000259 PDR 00\ hk' @ gg, b  ;

An Equal Opportunity Employer

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. i U.S. Nuclear Regulatory Commission l

JAN 0 9199 ,

1 Enclosures 1 through 4 of this letter address the BFNPP programs which are applicable to the restart of Unita 1 and 3. Enclosure 1 lists the BFNPP special programs which are considered complete for Units 1 and 3., No further action on these programs is required.

1 Enclosure 2 lists the BFNPP special programs which will be implemented on Units 1 and 3 in accordance with the Unit 2 criteria and implementation l precedents. The implementation precedent is defined as the general technical I approach and methodologies used to implement the program. The documentation compiled during the implementation of the program may, in some cases, be of a different format or may contain a different level of detai) than that which was reviewed during the Unit 2 implementation inspections or discussed in previous Unit 2 submittals.

Enclosure 3 lists the BFNPP special programs that will take advantage of the lessons learned from Unit 2. Dates are provided for informational submittals to NRC which will define the alternate methods for achieving the Unit 2 criteria on Units 1 and 3.

Enclosure 4 lists the BFNPP special programs for which TVA will propose criteria which are different from the Unit 2 precedent. Dates are provided for these programmatic submittals. TVA will request timely review and approval of these programs. The Unit 2 design upgrades which are being implemented during this outage are being or have been incorporated in the Updated Browns Ferry Final Safety Analysis Report (UFSAR). Proposed changes to the plant as part of the Units 1 and 3 restart effort which are different than those described in the UFSAR or to the procedures discussed therein, will be evaluated in accordance with the requirements of 10 CFR 50.59.

Enclosure 5 provides a summary of previous commitments or regulatory issues which will be resolved prior to the restart of Units 1 and 3. This list includes NUREG-0737 Action Items, Bulletins, Generic Letters, Unresolved Safety Issues, Generic Safety Issues, Multi-Plant Action Items, and other regulatory requirements. It does not include commitments made in Licensee Event Reports or Notice of Violation responses. New Generic Letters, Bulletins, and regulatory requirements will be resolved on Units 1 and 3 in accordance with their generic scheduler requirements. However, consideration will be given to expedited completion of long lead time issues identified early in the Units 1 and 3 restart process. Newly identified issues will be addressed and scheduled on a case by case basis.

TVA_ plans to convert the custom Browns Ferry Technical Specifications to the Improved BWR Technical Specifications (ITS) prior to the restart of Units 1 and 3. Implementation of the ITS will be coordinated with unit 2 Technical

Specification activities and operational cycles. Development and NRC approval l of'the ITS will require considerelle TVA and NRC resources.

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.e 3, s U.S.-Nuclear Regulatory Commission.

JAN 091991

- A summary list:of' commitments contained:in-this letter is provided.in Enclosure 6. :lIf you have any questions, please contact Joseph E. McCarthy,

=

- Uni t Li censi ng. Manager, at:-(205) 729-3604.

.i Very truly yours,-

TENNESSEE VALLEY AUTHORITY Mark O. Medford, Vice. President, Nuclear Assurance, Licensing &

Fuels r

Enclosures-

• cet : See page 4

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t U.S. Nuclear Regulatory Commission JAW 091991 cc (Enclosures):

Ms. S. C. Black, Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

L l-ENCLOSURE 1 i BROWNS FERRY NUCLEAR PLANT i NUCLEAR PERFORMANCE PLAN PROGRAMS WHICH HAVE BEEN COMPLETED ON UNITS 1, 2, AND 3

- Secondary Containment Penetrations -

The secondary containment penetrations program was discussed in

Section III.3.11 of the 8FNPP. Additional information was provided by letters, dated March 16, 1988 and March 23, 1988. This program was evaluated

-as documented in-the NRC's April 11, 1988 Safety Evaluation. Notification of the completion of this program was provided by TVA letter-dated October 6, 1989.

Welding -

The welding program was discussed in Section III.6.0 of the BFNPP. Additional

.information was provided by letter, dated January 18, 1989. This program was evaluated as documented in Section 3.5 of NUREG-1232, Volume 3, Supplement 1,

'which was issued October 24, 1989. Implementation was verified as documented-in' Inspection Reports 87-19, dated June 17, 1987 and Report 88-13, dated

-October: 3, 1988.

Wall Thinning Assessment Program (Pipe Erosion / Corrosion) -

The wall thinning assessment program was discussed'in Section III.10.0 of the DFNPP. BFN's response to Bulletin 87-01 was provided on September 18, 1987.

This program was. evaluated as documented in the NRC's August 31, 1988 Safety Evaluation and an documented in Section 3.10 of NUREG-1232, Volume 3, which was issued April 14, 1989 and in Section 3.10 of NUREG-1232, Supplement 1.

Heat Code Traceability -

3 The heat code traceability program was discussed in Section III.14.5 of the BFNPP. .TVA transmitted a generic report on January 4, 1988 which provided the results of the investigations-performed on the heat code traceability issue for all'of-TVA's nuclear plants. By letter dated June 29, 1989, TVA informed the NRC that this report was considered the final resolution of this issue.

This program was evaluated as documented in Section 2.3 of NUREG-1232, Supplement 1, and in the May 31, 1990 Safety Evaluation on the TVA Employeo

-Concerne Subcategory Reports.

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ENCLOSURE 2 BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 PROGRAMS TO BE IMPLEMENTED-

<IN ACCORDANCE WITH THE. UNIT 2 PRECEDENT _

Listed below are programs for Unite 1 and 3 which will be implemented in accordance with the Unit 2 criteria and implementation precedent. The

' implementation procedent in detined as the general technical approach and

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methodologies used to implement the program. The documentation used during the implementation _of the program may, in some cases, be of a different format or may contain a different level of detail than that which was reviewed during

- the Unit 2 implementation _ inspections or discussed in previous Unit 2  !

submittale'. i

. There are no open criteria issues with the NRC staff for Unit 2 restart.

Physical implementation of the criteria on-Unit 2 is not complete in some

- cases.

Environmental Qualification -

- TVA's program for the environmental qualification.of electrical equipment was discussed =in Section III.1.0 of the Browns Ferry Nuclear Performance Plan-(8FHPP). _This program was ovaluated'as documented in the NRC's October _ 21,.1988 Safety Evaluation, Section 3.2 of NUREG-1232, Volume 3, which I was leeued April-14, 1989 (Reference 1), and in Section 3.2 of NUREG-1232, Volume 3, Supplement 1, which was issued October 24, 1989-(Reference 2).

L Implementation was-reviewed as documented in Inspection Report 88-11, dated September 1,-1988.

- Large Bore Piping and Supports (Bulletins 79 02 and 7914) -

-TVA's. program for.solemic qualification of'large bore piping and supports was=

described-in Section III.3.2 of the BFNPP. The program was addressed by TVA lettere dated April 8,1-1987, September.28, 1988,' November 10, 1988,

June 16,.

1989, and two letters on March 16, 1990.- Implementation was verified as documented in Inspection Reporte 89-15,-dated May 18, 1989, Report 89-36, dated September 21, 1989, Report 89-44,_ dated-December 11,-1989, Report 89-57, '

dated January 30,-1990, _ Report 90-09, dated _ April 26, 1990,_and Report 90-19, dated July 13, 1990.

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Tm 2 of 6 .j ENCLOSURE 2 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT l UNITS 1 AND 3 PROGRAMS TO BE IMPLEMENTED i IN ACCORDANCE WITH THE UNIT 2 PRECEDENT i 1

HVAC Duct Supports -

TVA's program for seismic qualification of HVAC duct supports was originally described in Section III.3.5 of the BFNPP. The program was addresoed by TVA letters dated April 8, 1987, March 10, 1980, and May 26, 1988. The issue of buckling of HVAC ductwork was closed in Inspection Report 89-42, dated February 26, 1990. The issue of modeling of HVAC supporte was closed in Inspection Report 89-29, dated September 20, 1989. The issue of welding allowables for HVAC supports was closed in Inspection Report 88-38, dated April 19, 1989. The Safety Evaluations regarding HVAC ductwork and supports were included in the NRC's July 26, 1988 and August 22, 1990 letters. l l

Control Rod Drive (CRD) Insert and Withdrawal Piping - .

TVA's program for seismic qualification of CRD insert and withdrawal piping and supports was. originally described in Section III.3.6 of the 8FNPP. The <

revised program for the seismic qualification of this piping was submitted by TVA letters, dated March 17,.1988, June 13, 1989, October 6, 1989, November 27, 1989, December 11, 1989, and January 22, 1990. Implementation

'was verified as documented in Inspection Reporte 89-15, dated May 18, 1989, Report 89-36, dated. September 21, 1989, Report 89-39, dated October 13, 1989, Report 89-44, dated December 11, 1989, and Report 89-62, dated February 16, 1990.

Upper Drywell Platforms -

TVA's program for seismic qualification of the upper drywell platforms was described in Section III.3.8 of-the BFNPP and in TVA letter dated May 26, 1988. The interim operability criteria were reviewed as documented in the NRC's July 26, 1988 Safety Evaluation. Implementation was verified as documented in Inspection Reports 88-38, dated April 19, 1989, Report 89-29, dated September 20, 1989, Report 89-32, dated November 8, 1989, and Report 89-42, dated February 26, 1990.

h Fage?vf6 ENCLOSURE 2 (CONTINUED)

BROWNS FERRY 1 NUCLEAR PLANT UNITS 1=AND 3 PROGRAMS TO BE IMPLEMENTED-IN ACCORDANCE WITH THE UNIT 2 PRECEDENT l

l Miscellaneous Steel Frames -

TVA's program for seismic qualification of miscellaneous steel frames was originally described in Section III.3.9 of the BFNPP and in TVA letter dated May 16, 1988. The interim operability criteria was reviewed as documented in the 1RC's July 26, 1988 Safety Evaluation. Implementation was verified as documented in Inspection Reporte 88-38, dated April 19, 1989, Report 89-29, ,

dated'. September 20, 1989, Report 89-32, dated November 8, 1989, and -

Report 89-42, (ated February 26, 1990.

Seismic Class 11 Over Class I / Spacial System Interactions -

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- TVA's program for Class II over Class I and spacial system interactions was '

originally described in Section III.3.10 of the BFNPP and in TVA letter dated March 29, 1988. This program was evaluated as documented in Section 2.2.4.2 of Reference 2.

Design Calculations Review -

TVA's program for_ design calculations review was discussed in Section III.4.0 of the BFNPP. Revicion 4 of the DBVP, which was submitted by TVA letter, dated March-25, 1988, incorporated the design calculation effort. This-1 program was evaluated as documented in the NRC's December 8, 1988 Safety Evaluation. Further discussion is also included in Section 2.1 of References'l and 2.

Intergranular Stress Corrosion Cracking (IGSCC) -

TVA's program for the resolution of the IGSCC issue was discussed in Section III.~1.0 of the BFNPP. Information was also provided by TVA letters, '

dated August 1, 1988, January 12, 1989, May 22, 1989, June 30, 1989, and

-July 13, 1990. TlLa program was approved as' discussed in Section 3.6 of

Reference:

1 and Nic letters, dated Decenter 30,-1988 and December 21, 1989.

Compliance was reviewed as documented in Inspection Report 89-05, dated March.1, 1989.

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ENCLOSURE 2.(CONTINUED)  ;

BROWNS FERRY NUCLEAR PLANT --

UNITS 1 AND 3 PROGRAMS TO BE IMPLEMENTED IN ACCORDANCE WITN TNE UNIT-2 PRECEDENT Probabilistic Risk Assessment -

TVA's program for the resolution of the probabilistic risk assessment-. issue -)

was discussed in Section III.11.0 of the BFNPP. -This program and the actions taken to resolve restart concerns was discusood in Section 3.9 of Reference 2.

The program discussed in-the BFNPP was subsequently superseded by TVA letter-

. dated October 30, 1989, which proposed TVA's program for responding to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities. TVA proposed to resolve this issue in accordance with the P approach, methodology, and schedule contained in Generic Letter 88-20 and its supplements. The proposed approach and methodology were determined to be acceptable as documented by..NRC letter dated January 12, 1990.

Component and Piece Part Qualification -

TVA's program for the resolution of the component and piece part qualification issue was discussed in Section III.11.0 of the BFNPP. This program was evaluated as documented in the NRC's January 10, 1990 Safety Evaluation.

Cable Ampacity -

TVA's program for the resolution of the ampacity issue was discussed-in Section III.13.2 of the BFNPP. TVA submitted additional information by letters dated January 25, 1988, July 7, 1988, September 30, 1988,

. February 21, 1989, March 17, 1989, April 18, 1989, April 27,:1989, July 74 1989, October 6, 1989, April 9, 1990,-and May 21, 1990. The NRC Safety Evaluation was issued by-letter, dated December 19, 1989. Compliance-

-was reviewed as documented in Inspection Reports 89-59, dated April 9, 1990 and Report 90-13, dated August 10, 1990.

Flexible Conduits -

The issue of flexible conduits was discussed in Section III.13.3 of the BFNPP.

, TVA's program for the resolution of this issue was submitted by TVA letter, dated August 18, 1989. The NRC requested additional information by letter dated December 19, 1990. TVA responded by letter dated March 2, 1990.

l'ap 3 ,1( 6 ENCLOSURE 2 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 PROGRAMS TO BE IMPLEMENTED IN-ACCORDANCE WITH THE UNIT 2 PRECEDENT Thermal Overloads -

TVA's program for the resolution of the thermal overloads issue was discuooed in Section III.13.4 of the BFNPP. Additi7nal information was provided by TVA letter, dated April 28, 1988. The NRC requested additional information by lotter, dated August 10, 1988. TVA responded by lettero, dated September 21, 1988, February 28, 1989, and May 15, 1989. This program was evaluated as documented in Section 3.11 of References I and 2. Compliance was J reviewed as documented in Inspection Report 89-59, dated February 23, 1990.

Splices -

TVA's program for the resolution of the splice iscuo was discusood in TVA letter, dated April 28, 1988, and in Section III.13.5 of the BFNPP.

Fuses -

TVA's program for the resolution of the fuso losue was discuoced in Section III.13.6 of the BFNPP. Additional information was provided by TVA lottere, dated April 28, 1988 and April 9, 1990. The NRC requested additional information by letter, dated August 10, 1988. TVA responded by letter dated September 21, 1989. This progra. was approved in Section 3.11 of Reference 2.

Compliance was reviewed an documented in Inspection Reports 89-95, dated February 23, 1990 and Report 90-13, dated August 10, 1990.

O List -

TVA's program for the development of a Q-list was discussed in Section III.14.1 of the BFNPP. This program will be fully implemented prior to the restart of Units 1 and 3.

Moderate Energy Line Break (MELB) -

TVA's program for the resolution of the MELB issue was discussed in sSection III.14.2 of the BFNPP. The MELB analysis was provided by TVA letters, dated September 23, 1988, November 29, 1988, and March 24, 1989. This program was approved in Section 3.8 of Reference 2.

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hoge6of6 ENCLOSURE 2 (CONTINUED)  ;

' BROWNS FERRY NUCLEAR PLANT

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UNITS'1 AND 3 PROGRAMS T0-BE IMPLEMENTED-

-IN ACCORDANCE WITH,THE UNIT 2 PRECEDENT Containment Coatings -  ;

TVA's program for the resolution of-the containment. coatings issue was discussed'in Section III.14.3 of.the BFNPP. The results of the review of unqualified coatings was submitted by TVA letter, dated October 4, 1989.

Platform Thermal Growth -

TVA's program for the resolution of the platform thermal growth leeue was discussed.in section III.14.4 of the BFNPP. Resolution of the leeue of thermal expansion-of steel structures inside the drywel'1 is discussed in Inspection-Report 50-260/89-29, dated September 20, 1989. Resolution of the issue of thermal expansion of steel structures outside the drywell le

' discussed-in Inspection Report 50-260/89-42, dated February 26, 1990.

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. . ENCLOSURE 3 BR09NS: FERRY NUCLEAR PLANT UNITS 1 AN 3 PROGRAMS WHICH WILL DEPART FROM THE l%IT 2 IMPLEMEN1ATION PRECEDENT' Listed below are the Units 1 and 3 programs which will use alternate implementation methods for achieving the criteria established for Unit 2 on Units 1 and 3. Commitment dates are provided for informational submittals to NRC which will summarize the issue, review the. Unit 2 resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3.

ISSUE- SUBMITTAL DATE ELECTRICAL ISSUES:

Cable Installation-(Including Cable 02/15/91 Separation) (NPP Section III.13.1)

SEISMIC DESIGN ISSUES:

~ Small Bore Piping (NPP Section III.3.7) 03/01/91 Instrument. Tubing (NPP Section III.3.7) 03/01/91 Seismic Class II Over I - Water Spray 03/01/91 (NPP-.Section III .3.10) .

Cable Tray Supports (NPP Section III.3.3) 03/29/91 Conduit Supports (NPP Section III,3.4) 03/29/91 Long Term Torus Integrity Program (NPP 04/15/91 Section III.3.1)

=OTHER ISSUES:

Instrument Sensing Lines (NPP 02/15/91 Section III.9.0)

= Configuration Management / Design Baseline 06/14/91 (NPP.Section III.2.0)

Restart Test Program To-De Scheduled At A (NPP Section III 8.0) . Later Date i

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ENCLOSURE 4

. BROWNS FERRY-NUCLEAR PLANT UNITS-I AND-3 PROGRAMS WHICH WILL DEPART-FROM THE UNIT 2 CRITERIA PRECEDENT-Lis'ted below are the Units 1 and 3 programs for which TVA will propose criterla which is different from the Unit 2 precedent. - Commitment dates are provided for programmatic submittals to NRC which will summarize the issue, review the Unit 2 resolution, discuss lessons learned, and propose the criteria for resolution of the issue on Units 1 and 3.

ISSUE SUBMITTAL DATE Drywell Steel Platforms (NPP 05/15/91 Section III.3.8)

Fire Protection / 10 CFR 50, Appendix R To Be Scheduled At A.

(NPP tiection I11.5.0) Later Date i

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ENCLOSURE 5 BROWNS FERRY NUCLEAR PLANT UNITS 11 AND 3 RESTART COMMITMENTS OR= REGULATORY-ISSUES The;following is a preliminary list of previous commitmer.ts or regulatory issuee which-will be resolved prior to the restart of Units 1 and 3. This includes NUREG-0737 Action Items,-Bulletins, Generic Letters, Unresolved

.sto y Issues, Generic Safety Issues, Multi-Plant Action Items and other rs atory requirements.

NUREG-0737 (TMl Action Plan) Action items:

Dr. T. Murley's letter of April 14, 1989 requested TVA verify the implementation status of THI Action Plan Items. . TVA's letter-of April 18, 1989 provided a "best effort' response in view of the short turnaround time requested and stated that NRC would be apprised of any chances to that list. This commitment was' closed by na letter, dated June 16, 1989.

The following list provides an "pdate to the schedule for completion of outstanding TMI Action Ito% prior to restart of Units I and 3:

Item I.D.1 - Control Room Design Review (Safety Significant (Category 1 and 2]

Human Engineering Deficiencies (HEDs) and those additional HEDs which were required for Unit 2 restart)

Item I.D.2 - Safety Parameter-Display Console Item II.B.3 - Post-Accident Sampling System Item II.E.4.2.1 Containment Isolation Dependability - Implement Diverse

-Isolation Item II.E.4.2.6 - Containment Isolation Dependability - Containment Purge Valves (Unit-3 only - Unit 1 Previously Completed)

Item _II.F.1.2.A - Accident - Monitoring - Noble Gas Monitor Item II.F.1.2.D - Accident-- Monitoring.- Iodine / Particulate Monitor Item II.F.1.2.C - Accident.- Monitoring - Containment High Range Radiation Monitor Item II.F.1.2.D --Accident - Monitoring - Containment Pressure (Unit 3 Only -

Unit 1 Previously Completed)-

Item II.F.1.2.E - Accident - Monitoring - Containment Water Level (Unit 3 Only - Unit 1 Previously Completed) i I

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ENCLOSURE 5 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 RESTART COMMITMENTS 'M REGULATORY ISSUES ,

s NUREG-0737 (TMI Action Plan) Action items (Continued):

Item II.F.2.4 (Ceneric Letter 84-23)- Instrumentation for Detection of  ;

Inadequate Core Cocling I Item II.K.3.13 - HPCI/RCIC Initiation Levels item II.K.3.18 - ADS Actuation Modifications Item II.K.3.28 - Qualifica.ien of ADS Accumulators i

Bulletins (B):

TVA has reviewed the Bulletins which were addressed during the current Unit 2 outage. Thw following list includes those Bulletins which TVA will complete ,

prior to restart of Units 1 and 3

-B 79 Pipe Support Base Plate Designs Using concrete Expansion Anchor Bcito B 79 Snort Period Scrams kt BWR Facilities B 79 Seismic Analysis for As-Built Safety-Related Piping Systems B 79 Audibility Problems B 80-06 -' Engineered Safety Feature (ELF) Reset Controls B 83 Electrical Circuit Breakers with an Undervoltage Trip Feature in use in Safety-Rol6ted Applications other that the Reactor Trip System B 84 Failures of General Electric Type HFA Relays in Use in Class 1E Safety Systems B 86 Static "O" Ring Differential Pressure Switches JB 88-03 --Inadequate Latch Engagement in HFA Type Relays Manufactured by General Electric Company B 88 Power oscillations in Boiling W6ter Reactors B 90-01-- Loss of Fill Oil in Rosomount Transmitters

Pap J d3 ENCLOSURE 5 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES Generic Letters (GL):

TVA has reviewed the Generic Letters which were addressed during the current Unit 2 outage. The following list includes those Generic Letters which TVA will complete prior to restart of Units 1 and 3 :

CL 82 Instrumentation to Follow the Course of an Accident - Regulatory cuide 1.97 (With the. exception of qualified neutron monitoring instrumentation.)

GL83-08-ModificationofVacuumDreakersonMarkIContainments (Open on Unit 1 only)

GL 83 Salem ATWS l- ~ GL 83 NUREG-0737 Technical Specifications OL 68 NRC Position on 20 SCC in BWR Austenitic Stainless Steel Piping OL 88 Radiation Embrittlement of Reactor Vessel Materials and its Impact on Plant Operations GL 88 Instrument Air Supply System Psoblems Affecting Safety-Related I Equipment OL 88 Initiation of the Individual Plant Examination for Severe Accident Vulnorabilities-

.0L 89 Safety Parameter Display' System - 10 CFR 50.54(f)

'GL 89 Safety-Related Motor-operated valve Testing and Surveillance

.0L 89 Service Water Systems Problems Affecting Safety-Related Equipment ,

GL 89 Installation of a Hardened Wetwell Vent OL 89 Request for Acticn Related to Resolution of Unresolved Safety Issue A-47, " Safety Implication of Control Systems in LWR Nuclear Power Plants", Pursuant to 10 CFR 50.54(f)

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roar e nts ENCLOSURE S (CONTINUED) l BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES Unresolved Safety issues (USIs) [ Associated Multi Plant Action item (MPA)]:

. Generic Letter 89-21, dated October 19, 1989, requested in'ormation concerning

the status of the implementation of USI requirements. TVA responded by letter ,

dated November 15, 1989. Tht following list of USIs which TVA will et 31ste prior to restart of Unita 1 and 3 reflects that submittal  !

USI A-7 (MFA 0-01) - Mark I Long-Term program USI A Anticipated Transients Without Scram (10 CFR 50.62)

USI A-24 (MPA D-60) - Qualification of Class IE Safety-Related Equipment USI-A-36 (MPA C-10) - Control of Heavy Loads Near spent Fuel pool USI A-42-(MPA D-06) - Pipe Cracks in Boiling Water Reactors USI A Station Blackout [10 CFR 50.63)

UST A-48 (MPA A-19) - Hydrogen Control Measures and Effects of Hydrogen Burne Generic Safety Issues (GSIs) [ Associated Multi Plant Action Item (MPA)]:

Generic Letter 90-04, dater

• April 26, 1990, requested information concerning the etketus of the implementation of OSIs which were resolved with imposition of requiremente or corrective actione. TVA responded by letter dated May 30, 1990. The NRC staff's understanding of the-status of these issues was documented by letter dated November 7, 1990. The following list of OSIs which TVA will complete prior to restart of Units 1 and 3 reflects that submittal

. 0SI 40.(MPA D-066) - Safety Concerns Accociated with Pipe Dreaks in the BWR Scram System OSI 41 (MPA D-0$0) - BWR Scram Discharge Volume System

- 0SI 43 (MPA D-107) - Reliability of-Air Systeme OSI $1 (HPA L-913) - Improving the Reliability of open-cycle Service Water Systeme 1

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?M$f b ff h ENCLOSURE 5 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT j

UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES l MulthPlant Action Items (Not Previously Listed):

)

i NRC letter dated June 22, 1987,. requested TVA verify the data contained in the

! NRC SIMS tracking system for BrN. TVA responded by letter dated September 2, 1980 and through subsequent discussions with the NRC Project Manager and correspondence on individual issues. The following is a list of MPAs which TVA will complete prior to restart of Units 1 and 3:

HPA A-01-- 10 CPR 50.55A(0) - Inservice Inspection

- MPA A 10 CPR 50, Appendix J - Containment Leak Testing MPA B-41 .10 CFR 50, Appendix R - Fire Protection

- MPA C centrol of Heavy Loads - Phase I (NUREG-0612)

Other Programs:-

The following rsgulatory requirement will also be completed prior to the restart of Units 1 and 3:

10 CFR 50.45(D)(2)(III) - Plant simulator 1

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ENCLOSURE 6 BROWNS FERRY NUCLEAR PLANT

SUMMARY

OF COMMITMENTS  :

1) TVA will issue a cable installation (including cable separation) submittal by February 15, 1991 which will summarize the issue, review the Unit 2 resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3.

I

2) TVA will issue an instrument sensing lines submittal by February 15, 1991 which will summarize the issue, review the Unit 2 resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3.

3) TVA will issue a seismic class II over 2 - water spray submittal by March 1, 1991'which will summarize the issue, review the Unit 2 resolution, discuss 1sceoss learned, and describe how the issue will be resolved on Units 1 and k,

4) TVA will issue a small bore piping submittal by March 1, 1991 which will

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summarize the issue, review the Unit 2 resolution, discuss lessons learned,_and describe how the issue will be resolved on Units 1 and 3.

5) TVA will issue an instrument tubing submittal by March 1, 1991 which . ,

will summarize the. issue, review the Unit 2 resolution, discuss ' lessons  !

learned, and describe how the issue will be resolved on Units 1 and 3. l

6) TVA; sill issue a cable tray supports submittal by March 29, 1991 which will summarize the issue, review the Unit 2 resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3. :t

7) TVA will' issue a conduit supports sub.Eidtal by March 29, 1991 which will summarize the issue, review the Unit 2 resolution, discuss lessons

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r  : learned, and describe how the issue will be resolved on Units 1 and 3.

8') TVA Vill insur a long term torus integrity program submittal by April 15, 199J which sill summarize the issue,_ review the Unit 2 't resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3.-

9)- TVA will; issue a drywell platforms submittal by May 15, 1991 which will- ,

summarize'the issue, review the Unit 2 resolution, discuss lessons

learned, and propose the criteria-for resolution of the issue on Units 1 l

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and 3.

10) LTVA will-issue a configuration management / design baseline program submittal by June 14, 1991 which will summarize the issue, review the Unit-2 resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3.

. ~ . _ . . , . _ . . - _

__ _._._..___ _.__ _ ._._. . , _ .- -_ _ . _ . . ~

ENCLOSURE 6 (CONTINUED) l BROWNS FERRY NUCLEAR PLANT i

SUMMARY

OF COMMITMENTS

11) TVA will issue a fire protection / 10 CFR 50, Appendix R submittal on a date to be scheduled later which will summarite the issue, review the Unit 2 resolution, discuso lessons learned, and propose the criteria for resolution of the issue on Units 1 and 3.

12) TVA will issue a restart test program submittal on a date to be scheduled later which will sunnarire the issue, review the Unit 2 resolution, discuss lessons learned, and describe how the issue will be resolved on Units 1 and 3.

13) TVA will complete NUREG-0737, Item I.D.1 - Control Room Design Review, Safety Significant Human Engineering Deficiencies and those HEDs required for Unit 2 restart prior to the restart of Units 1 and 3.

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