ML20083D860
| ML20083D860 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/20/1991 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9110010300 | |
| Download: ML20083D860 (44) | |
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'I SEP 2019M U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
1 In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
- ^-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - STATUS AND SCllECULE FOR COMPLETION OF UNIT 2 POST-RESTART ISSUES The purpose of this letter is to provide the implementation schedule for the corrective actions categorized aa post-restart commitments. As disetc. sed in NUREG 1232, Volume 3, Supplement 2, this status is being j
nrsvidad within 120 days after Unit 2 rectart.
v.nclor se 1 provides a summary of the open items identified in NUREG 1232 and its supplements. Also included is a listing and schedule for aompletion of each long-term or ongoing post-restart commitment contained in Section IV, "The Summtry of Browns Ferry Nuclear P,.at Commitments",
Attachments IV-1 through 1V-4, of the Browns Ferry Nuclear Performance Plan, Revision 2. contains a list of new commitments identified in this submittal.
If you have any questions, please contact Patrick P. Carier at (205) 729-7566.
Very truly yours,
, TENNESSEE ALLEY AUT110RITY j
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2 U.S. Nuclear Regula tory Commission SEP 2 0 linn Enclosures cc (Enclosures):
HRC 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 Rockv1110, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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e ENCI4SURE 1 POST-RESTART COMMITMENTS CONTAINED IN Ti!E BROWNS FERRY NUCLEAR PERFORMANCE PIAN i
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l ENCLOSURE 1 By letter dated April 16, 1991, TVA provided the status of BFN corrective actions to be completed prior to the restatt of Unit 2.
This enclosure provides a summary of the open issues identified in NRC Safety Evaluation Reports (SERs) and Inspection Reports (IR) and a list of the long-term or ongoing post-restart commitments identified in Section IV of the Browns Ferry Nuclear Performance Plan (BFNPP).
The open items for the SER and irs are at the beginning of each paragraph followed by the BFNPP commitments.
Also, provided is an update on the status of the two restart commitments (Commitment Nos. 99 and 105), discussed in the April 16, 1991 submittal, that required testing at power.
For ease of reference this enclosure follows the format of the BFHPP Volume 3, Revision 2.
SUMMARY
OF BROWNS FERRY NUCLEAR PLANT COMMITMENTS SECTION IV CORPORATE NUCLEAR PERFORMANCE PLAN (CNPP) -
ATTACHMENT IV_1 VOLUME 1 COMMITMENTS FOR BFN These commitments are exclusively from revision 6 of the CNPP Volume 1. TVA stated in a letter to NRC dated April 5, 1991, the Vc' ame 1 commitments are complete, except for the following post-restart commitment:
Commitment No. 35, Page No. 124 - The configuration management function will include a controlled master equipment list and a master design document list.
The Master Equipment List has been incorporated into the Browns Ferry Equipment Management System (EMS) data base.
Key safety-related listings of equipment information have been loaded into EMS including the Q-List, 50.49 List.
Valve tabulations will be added by September 30, 1993..
Procedures for maintaining these listings are in place.
Remaining work will be ongoing through the end of September 1993.
The EMS, the Document Control Management System and the Calculation Cross Reference Informt. tion System are the controlled systems that make up the Master Design Doc'.. ment List.
These systems arc currently in place.
11.
INTRODUCTION The BFNPP defines a long-term commitment as these commitments involving long-term programs which are not committed for completion prior to restart, but plans for completion will be in place prior to restart. An 1
ENCLOSURE 1 (Cont'd) ongoing commitment is defined as these commitments that will nave an established program for ongoing compliance prior to restart of unit 2.
The BFN Quality Assurance staff reviewed the long-term and ongoing commitments prior to restart, to verify that a plan was available.
The BFNPP contains no long-term or ongoing post-restart activities in this section.
112 CONDUCT OF BROWNS PERRY ACTIVITIES 122 Strenathenino BFN Manaaement and Oraanizati D R
SER Open Items:
There are no SER open items contained ir. this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
a.
Commitment No.
4, Page No. II Periodic reports are issued to site and Nuclear Power management showing the number of HRC commitme ts made and completed.
This action was completed November 21, 1989.
Licensing compiles and distributes reports to site and management on the status and number of commitments made to NRC.
b.
Commitment No. 8, Page No. II BFN's original goal was to replace loaned managers or contracted managers with permanent TVA personnel where the position filled was to be permanent.
A general plan for the future management program was presented to NRC on November ?.1, 1986.
With the submittal of the BFNPP Revision 2, dated October 24, 1988, this action was complete.
c.
Commitment No.
9, Page No, II A management craining program has been established within Nuclear Power to prepare employees for management positions.
Additienal managament development efforts are in various stage of implementation as supplements to the training effort.
2
a ENCLOSURE 1 (Cont'd)
A management training program has been established.
This action was completed February 7, 1991.
21Q jianaggAent Control and Involvement Each program in thie section will be addressed individually.
L1 liana 99 ment Sqnia_and Obiectives SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
212 Communication with Emoloyegg SER Open Items:
There ars no SER open items contained in this section.
BFNPP Volume 3 Long-Term or ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
La Trainina Proaram SER Opan Items:
The NRC staff evaluated TVA's training program in a SER, dated November 23, 1988 and concluded that the upgraded training program addressed the deficiencies identified in the BFNPP.
However, the NRC noted that the BFN simulator would be modified to a pl6nt referenced simulator and that TVA certify by March 1991, per 10 CFR 55 March 1987 revision, that this modification has been completed. In a letter to NRC, dated July 13, 1990, TVt. requested a temporary exemption to this regulation until December 31, 1991.
NRC granted this exemption on 3
I
ENCLOhURE 1 (Cont'd)
January 2, 1991.
This certification will be 1
submitted to the NRC by December 31, 1991.
The simulator upgrade project was identified as an open item in NRC Inspection Report 90-07.
This open item is on schedule and will be completed bf December 31, 1991.
DFNPP Volume 3 Long-Term or ongoing Commitments:
a.
Comraitment No. 10, Page No. II TVA will evaluate the improvements from the increased annual requalification training, but in any case will continue with at least six weeks of annual requalification training.
The increased requalification training has been evaluated and is in place.
The NRC evaluated the upgraded training program in an SER dated November 23, 1988, and concluded ic was acceptable.
This action was completed November 30, 1988, b.
Commitment No. 13, Page No. II Newly assigned plant technical stuff managers and engineers are required to complete this orientation phase training within 18 months of assignment to BFN unless a waiver is granted per defined criteria from Site Director's Standard Practice (SDSP) 4.9 (Formerly Standard Practice Erowns Ferry (BF) 4.14).
Plant technical staff managers and engineers, identified as of the effective date of BF 4.14, were required to complete this training by August 1, 1987, have an approved waiver, or have limited duties.
A review was perfcrmed and documented to verify that plant technical managers and engineers were trained or that a waiver was submitted as of the effective date of procedure BF 4.14.
This action was completed April 22, 1988.
2_,A Erpcedures Uncrade SER Open Items:
The NRC staff reviewed the Procedures Upgrade Program in NUREG 1232, Volume 3, Supplement 2.
The near-term portion of the program was completed 4
l
ENCLOSURE 1 (Cont'd) before restart and the long-term portion will extend on for several years.
The staff concluded that tia TVA programs to upgrade procedures are effective, except for certain aspects of the Surveillance Instruction (SI) upgrado program.
These concerns were resolved in subsequent inspections of the SI program, and are discussed further in Section II.5.0
" Plant Curveillance Program."
BFNPP Volume 3 Long-Term or Ongoing Commitments:
a.
Commitment No. 16, Page No. II Procedures that are identified as requiring development or upgrading, but which are no? important to restart and operation of BFN, will be revised and upgraded as part of the long-term program to develop and implement the Nuclear Procedures System as described in the Revised CNPP Volume 1.
In a letter dated April 16, 1991, TVA stated that the remainder of the maintenance instructions would be upgraded after Unit 2 restart.
The maintenance instructions upgrade is scheduled and will be completed September 30, 1993.
b.
Ccmmitment No. 17, Page No. II The new precedures system of policies, directives, standarde, 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 ccmpleted by October 31, 1991.
c.
Commitment No. 18, Page No. II-C6 - As plant procedures are upgraded and approved in accordance with Site Directors Standard Practice (SDSP) 2.11 " Implementation and Change of Site Procedures and Instructions", they are also reviewed for adequate specification of independent verification requirements per SDSP 3.15 " Independent Verification," as appropriate.
5 l
ENCLOSURE 1 (Cont'd)
SDSP 2.11 was revised to include requiroments for indopondent verification.
This action was completed December 29, 1980.
M Car.rgetive Action SER Open Items:
There are no SER open iteins contained in this section.
BFNPP ">lume 3 Long-Term er ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
215 Quality Assurants Procram SER Open Items:
There are no SER open items contained in this section.
BFNPP Volumo 3 Long-Term or ongoing Commitments:
Commitment ho. 24, Page No. II The Quality Assurance (qA) Staff is implementing generic BFN QA management review guidelines for tl.e quality surveillance program whicii can be used by QA ae
- 11 as plant organizations to improve plant performance.
This action was completed December 2, 1987.
NRC issued an SER for the program description on April 10, 1988.
2x7.
Employeo Concerns SER Open Items:
There are no SER open items contain3d in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The DFNPP contains no long-term or ongoing post-restart activities in this section.
6
n.
I ENCLOSURE 1 (Cont'd) 1,1 Plant Performance Momitorina Procram SER Open Items:
There are no SER open items contained in this section.
DFNPP Volume 3 Long-Term or ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
112 Fitness For Duty SER Open Items:
Thero are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or ongoing Commitments.
The BFNPP contains no long-term or ongoing post-restart activities in this section.
M Work Control SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFHPP contains no long-term or ongoing post-restart activities in this section.
1,_Q Plant Ooeratiplm SER Open Items:
The NRC staff has reviewed the Plant Operations Program in an SER, NUREG 1232, Volume 3, Supplement 2,
dated January 23, 1991.
The staff concluded that Browns Ferry's assessment of the root causes for operations-related deficiencies was accurate and the corrective actions taken should help to resolve operation's performance problems.
7
~_ -. _.
ENCLOSURE 1 (Cont'd}
In a letter dated June 12, 1991, NRC staff reviewed the developmental guidelines utilized by TVA to upgrade the BFN Plant Emergency Operating.
Instructions (EOIs) in accordance with Revision 4 of the Boiling Water Reactor Owner's Group guidelines.
The staff stated that after TVA has satisfactorily resolved the NRC comments, the BFN EOI developmental guidelines will be capable of providing sufficient guidance for ensuring that adequate EGIS are developed at BFN.
TVA was scheduled to upgrade to Revision 4 of the Emargency Procedures Guidelines by December.31, 1991, however, due to the startup of Unit 2 and the manpower needed to support restart, full-implementation should be completed by June 15, 1992.
BFNPP Volume 3 Long-term or Ongoing Commitments:
The BFNPP contains no long-term.or ongoing post-restart activities in this section.
A2R Maintenance Procraq SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
ExR llant Surveillance Procram SER Open Items:
The NRC staff' reviewed the Plant Surveillance-f:
Program in an SER, NUREG 1232, Volume-3, Supplement L
2,.and identified an open item related to improved
. management practices to foster procedure compliance among personnel.
In a letter dated April 16, 1991, TVA stated that the corrective actions to address the NRC concerns were completed and an upcoming inspection should close this issue.
A special inspection (IR 91-13) was conducted in March and April 1991 to assess the adequacy of-the SI program to support restart and operation of-BFN l
8 4
~
m ENCLOSURE 1 (Cont'd)
Unit 2.
Of the four cr.on NUREG 1232 issues, three were closed in IR 91-13.
One issue involving the validation of sis was left open pending further action by TVA.
Following the implementation of the enhancements to the validation process, NRC concluded in IR 91-21 that this concern had been resolved.
BFNPP Volume 3 Long-Term or ongoing Commitments:
Commitment No. 20, Page No. II In addition to ensuring proper references in burveillance Instructions (SI), Vendor Manual Control Program (VMCP) information is being incorporated in the ongoing review and upgrade of plant operating and maintanance instructions.
The vendor manual control ensures that VMCP information is incorporated into plant procedures.
The staff reviewed this program in an SER dated September 29, 1988, and concluded that the management contro7s established by the VMCP as it applies to surveillance instructior.s was acceptable.
This action was completed March 6, 1991.
Euq Badioloaical Control and Chemistry Improvement SEP_ Open Items:
The NRC staff has evaluated the Radiological Control
~
and Chemistry Improvement programs in an SER on Volume 3,Section II.6.0 and Section 111.8.0, dated August 12, 1988. An open item identified in this SER Was to install a permanent Post-Accident Sampling Bystam (PASS) before restart of Unit 1 and 3 and during the next (cycle 6) refueling outage for Unit 2.
In a letter dated December 28, 1989, TVA revised the ccmmitment to fully implement PASS during this outage.
The PASS tystem was installed this outage, but required testing at power.
NRC staff opened an Inspector Followup Item (IR.: 90-02-01) to track the testing at power portion of the PASS system.
IR 91-28 subsequently closed this issue, however testing of the containment atmosphere sampling remains open.
9 l
l
ENCLOSURE 1 (Cont'd)
BFNPP Volume 3 Long-Term or Ongoing Commitments:
a.
Commitment No. 36, Page No. II Increase the experience level of the chemistry organization.
The BFN chemistry group has acquired experienced engineers, chemists and radiochemical laboratory analysts in major areas of responsibility. This action was completed May 5, 1988.
b.
Commitment No. 39, Page No. II A permanent Post-Accident Sampling System (PASC) will be installed before restart of Units 1 and 3 and during the next (cycle 6) refueling outage for Unit 2.
By letter dated December 28, 1989, TVA accelerated this commitment to have a permanent PASS system installed this outage. Technical i
Specification Amendment 284 was submitted to NRC to include the PASS system installation. This amendment was approvod April 10, 1991.
In IR 91-28, the permanent PASS system was evaluated against the NUREG 0737 criterja and one area remains open.
This item is the PASS containment atmosphere sampling and analysis and is tracked by Inspector Followup Item 91-28-01.
c.
Commitment No. 39a, Page No. II Evaluate the interim PASS under full power operating conditions against NUREG-0737 criteria.
This item will be accomplished after Unit 2 achieves full power.
TVA submitted a letter to the NRC, dated December 28, 1989, that accelerated this commitment.
TVA installed a permanent PASS.
system during this outage, therefore an interim PASS system was not needed.
In NUREG 1232, Volume 3, Supplement 2, the NRC approved this schedule and considered installation of a final PASS system a restart commitment.
The final PASS system was installed and has been reviewed in IR 91-28.
l L
10 l
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. - m-
4 ENCLOSURE 1 (Cont'd) 222 Plant Security SER Open Items:
The NRC staff has evaluated the Plant Security program as documented in an GER on Volume 3,Section II.7,0, dated October 31, 1988.
The SER noted that the staff's evaluation of the proposed corrective actions were acceptable and continued rigorous implementation of the plant security upgrade program will increase the overall safety of BFN.
In a letter dated December 10, 1987, TVA committed to upgrade the security system.
The schedule for completion is to have design complcte in October 1991, begin construction in January 1992 and the installation will be completed by March 31, 1993.
BFNPP Volume 3 Iong-Term or ongoing Commitments:
The BFWPP contains no long-term or ongoing post-restart activities in this section.
112 Emeraency 1*reDaredness SER Open Items:
The NRC staff reviewed the Emergency Preparedness Program in an SER, NUREG 1232, Volune 3, Supplement 2,
dated January 23, 1991, and found the program acceptable. !n the BFNPP Volumo 3, TVA committed to upgrade the public address and evacuation system.
This upgrade will be completed by tb3 end of the Unit 2 cycle 6 refueling outage.
BFNPP Volume 3 Long-Tt in or Ongoing cc mitments:
Commitment No. 40, Page No.
'I-102 - The scope of needed design changes to the public address and evacuation system was defined at the end of 1986.
Present plans call for upgrading the system during the Unit 2 cycle 6 outage.
This action will be completed by the end of Unit 2 cycle 6 refueling outage.
11 1
l l
ENCLOSURE 1 (Cont'd) 21Q Eite Schedulina SER Open Items:
There are no SER open items in this section.
DFNPP Volume 3 Long-Term or Ongoing Commitments:
a.
Commitment No. 41, Page No. II-104 - Major modifications (other than those associated with operational emergencies) have detailed estimates and implementation plans prepared.
Site proceduros we e revised to require cost estimates, implementation plans, project justification and proposed schedules when the issue is identified.
This action was completed October 23, 1990.
b.
Commitment No. 42a, Pago No. II-106 - TVA will renew the integrated schedule approach for regulatory committed modifications for each unit as that unit restarts from the current outage.
BFN issued procedures to implement the Integrated Living Schedule (ILS).
By letters dated August 14, 1984, September 21, 1984 and April 12, 1985, TVA submitted to NRC for their approval a License Amendment to include the ILS.
TVA has prepared a submittal to NRC dated September 20, 1991, to withdraw this commitment and license amendment to implement the ILS.
TVA will use Nuclear Dusiness Practices to control the ILS function and provide NRC with the same information on project status that the ILS provided.
III.
SPECIAL PROGRAMS 1xQ Cnvironmental Qualification of Equinment SER Open Items:
The NRC staff evaluated the Environmental Qualification (EQ) Program in NUREG 1232, Volume 3, Supplement 2, and concluded that TVA was implementing an EQ program that would bring BFN Ur.it 2 into compliance with the requirements of 12
ENCLOSURE 1 (Cont'd) 10 CFR 50.49 once the program was completed.
The NUREG stated that TVA certify that its 10 CFR 50.49 list is complete and that all electrical equipment and components within the scope of 10 CFR 50.49 are qualified to meet these requirements. TVA submitted a letter to the NRC dated May 13, 1991, certifying that safety-related electrical equipment and components met the requirements of 10 CFR 50.49.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 50, Page No. III The 50.49 list of all class 1E equipment located in a harsh environment will be maintained current by reflecting ongoing modifications and installations.
The 50.49 list was issued March 25, 1988 and site procedures were issued for the preparation, maintenance and control of the 50.49 list.
This action was completed November 16, 1990.
AtQ Conficuration Manacement The NRC staff evaluated the.configuracion Management Program including the Design Baseline Verification Program (DBVP) in an SER dated December 8, 1988.
The staff cencluded that the program contains the essential elements to assess and re-establish the Unit 2 design basis and evaluate the plant configuration to ensure that it satisfies the design basis.
In NUREG 1232, Volume-3, supplement 2,-the staff.again reviewed the DBVP Program implementation and stated that TVA was adequately in.plementing the DBVP program.
The SER noted eight post-restart action items that were identified in NRC special inspection of the BFN Civil Calculation Review Program.
These post-restart actions will be completed by the end of Unit 2 cycle 6 refueling. outage.
The items related to the resolution of the Unresolved Safety Issue (USI) A-46 will be respor.ded to after the receipt of the SER from the NRC
.for the SQUG program.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
4 a.
Commitment No. 53, Page No. III The post-restart phase of-the DBVP will continue the engineering activities to complete engineering documentation describing the functional as-constructed configuration of the remaining 13
ENCLOSURE 1 (Cont'd) systems or portions of systems that are safety related.
The scope of this program was submitted to the NRC by letter dated May 3, 1991.
This action will be completed by the end of Unit 2 cycle 6 refueling outage.
b.
Commitment No. 55, Page No. III The design baseline will be established for post-restart systems using a similar hethod as described in Section III.2.2.1.
This action was deleted.
This itsim was a j
duplicate of Commitment No. 53 on page 15.
j c.
Commitment No. 63, Page No. III Design changes vill be developed on a unit specific basis and will be of manageable size to implement in a defined period. The unreviewed safety question determination for the completed design package will be updated, if necessary, after installation and testing to reflect the final installed conditions.
The Nuclear Quality Assurance Manual was revised to implement the change control process.
Site procedures also require this action to be done.
This action was completed July 28, 1987.
d.
Commitment No. 64, Page No. III TVA's permanent design system will further develop the plant modification package concept.
Nuclear Power Standards define the objectives for the control of permanent plant modifications.
This directive provides the approach for TVAs permanent design control procesa.
This action was completed May 5, 1990.
e.
Commitment No. 65, Page No. III The design control system will be controlled by NE procedures. Implementation of these procedures will be monitcred by Engineering Assurance.
Site procedures were issued to implement this process.
This action was completed April 22, 1988, 14
ENCLOSURE 1 (Cont'd) 222 Soismic Desian Each program in this section will be addressed individually.
L1 Ignas Modifiedgna SER Open Items The NRC reviewed issues relating to the Torus design area in an CER dated August 20, 1980, on the BFN Plant Torus Integrity Long-Term Program.
The staff further reviewed Torus Modifications in NUREG 1232, Volume 3, Supplements 1 and 2 and in NRC IR 89-44.
The open items associated with the IR are closed and there were no open items listed in the SERs.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 67, Page No. III For Units 1 and 3,
a similar effort of torus internals reinspection and resolution of discrepancies will be made before restart of each unit respectively.
TVA submitted a letter dated July 10; 1991, to NRC that discusses the regulatory framework for the restart of Units 1 and 3.
This action will be completed before restart of each unit.
222 Pinina and Supports f1E Bulletins 79-02 & 79-14)
SER Open Items:
The NRC staff reviewed IE Bulletins 79-02 and 79-14 programs in NUREG 1232, Volume 3, Supplement 1, and concludad that TVA has defined en adequate program for resolving the bulletins concerns.
In a letter dated March 28, 1991, TVA notified NRC of the implementation of IE Bulletins 79-02 and 79-14 for Unit 2.
The NRC staff conducted an implementation inspection and subsequently, closed the bulletins for Unit 2 in IR 91-11.
BFNPP volume 3 Long-Term or Ongoing Commitments Commitment No. 71, Page No. III A final reinspection and analysis to establish full compliance of all covered piping and supports with-bulletins 79-02 and 79-14 will be completed prior to 15
a.
I ENCLOSURE 1 (Cont'd) restart of Units 1 and 3 and before tho end of the next refueling outage (cycle 6) for Unit 2.
By letter dated March 28, 1991, TVA notified NRC of the completion of Inspection and Enforcement Bulletins (IEB) 79-14/02 for Unit 2.
For Units 1 and 3, TVA submittod a letter dated July 10, 1991, to NRC that discusses the regulatory framework for the restart of units.
This action will be completed before restart of each unit.
lz2 Cable Tray Suncorts SER Open Items:
The NRC staff evaluated the Cable Tray and Supports Program in NUREG 1232, Volume 3, Suoplements 1 and 2,
and concluded that the interim acceptance evaluation for Unit 2 is satisfactory.
However, the long-term evaluation of cable tray and supports will be covered within the framework of the USI A-46 program.
BFNPP Volume 3 Long-Term or ongoing Commitments:
Commitment No. 73, Page No. III Direct comparison, using the approach developed by Seismic Qualification Utilities Group (SQUG) with NRC involvement and oversight, will be used to show long-term qualification of BFN cable trays.
TVA will provide a response identifying a completion date for this program after receipt of the SER from the NRC for the SQUG program.
lui Conduit Suonorts SER Open Items:
The NRC staff reviewed Electrical Conduits and Supports Program in NUREG 1232, Volume 3, Supplements 1 and 2.
The NUREG contained two post-restart open items which were originally identified in NRC Inspection Report (IR) 89-29 and are stated below:
a.
TVA should evaluate and upgrade, as needed, the aluminum conduit and supports qualified to the 16 I
ENCLOSURE 1 (Corit ' d) interim criteria against the USI A-46 program guidelines, b.
TVA should evaluate and upgrade, as needed, the steel conduit and supports qualified to the interim criteria against the USI A-46 program ouldelines.
Resolution of these two open items will be addressed within the framework of USI 1.-46 issue.
TVA will provide a response identifying a completion date for this program after the receipt of the SER from the NRC.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
L_E HVAC Ductwar]g SER Open Items:
The NRC staff roviewed the HVAC Supports and Ductwork restart criteria in an SER dated August 22, 1990, and concluded that the new amplified response spectra performed by TVA meets the restart-criteria.
The staff also reviewed this program in NUREG 1232, Volume 3, Supplements 1 and 2 and identified three post-restart open items.
These post-restart open items were identified in NRC irs 88-38 and 89-42 and are stated below:
a.
TVA should evaluate and identify the need for long-term modification of the approximately 11,830 feet of ductwork that met the interim criteria (IR 88-38).
Based on the resolution of item "c" below, TVA will complete the evaluation to the long-term criteria 6 months before the start of the Unit 2 cycle 5 refueling outage.
b.
TVA should peirform the long-term modification of the 509 existing supports that were qualified to the interim criteria (IR 88-38),
17
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ENCLOSURE 1 (Cont'd) l Based cn the resolution to item "c" below, TVA will complete any modifications before the end L
of Unit 2 cycle 6 refueling outage, c.
TVA should develop long-term criteria for HVAC evaluation and perform long-term buckling evaluation for all duutwork qualified to the l.;
interim criteria (IR 89-42).
TVA will develop and submit for review to the NRC the long-term criteria by November 15, 1991.
BFNPP Volume 3 Long-Term or ongoing Commitments:
Commitment No. 75a, Page No. III Unit 2 and common ducts or supports that do not meet the design criteria, but are within the interim operability criteria, will be modified to the design criteria after restart.
TVA will complete these actions as identified in a, b, and c above.
22h control Rod Drive (CRD) Insert and Withdrawal Pininc SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments' Commitment No. 76a, Page No. III Long-term qualification of CRD insert and withdrawal piping support systems will be accomplished prior to the end of the next refueling outage (cycle 6) for Unit 2.
TVA's CRD Insert and Withdrawal Piping Systems Program initially utilized criteria different from that specified in the BFN FSAR. By letter dated March 17, 1988, TVA revised its program to incorporate the same restart criteria contained in the IEB 79-02/14 programs.
TVA accelerated its l
program by qualifying the piping and supports for the CRD insert and withdrawal piping program to the long-term design criteria.
This action was completed March 27, 1991.
18 L
ENCLOSURE 1 (Cont'd) lil 83fety Related Small Bore Picina Succorta SER Open Items:
The NRC staff evaluated the Small Bore Piping Program in NUREG 1232, Volume 3, Supplements 1 and 2.
The staff found the two phase approach adequate for the resolution of concerns identified with small-bore piping.
However, a post-restart item remains open and is also a post-restart BFNPP Volume 3 commitment.
BFNPP Volume 3 Long-Term or Ongoing Commitmente:
Commitment No. 77h, Page No. III Modifications required to meet final design criteria for small bore piping and supports will be completed prior to restart from Unit 2 cycle 6 refueling outage.
This action will be completed by the end of Unit 2 cycle 6 refueling outage.
221 Drvwell Steel Platforms SER Open Item:
The NF' staff reviewed the Drywell Steel Platforms progr.
"UREG 1232, Volume 3, Supplements 1 ar.d 2.
TL
- L identified a post-restart item for the Drywell
,2orms to be qualified to design criteria those structural steel elements qualified to the interim criteria (Ref.: IR 89-42).
TVA submitted the long-term design criteria by letter dated June 12, 1991.
Subsequently, in August 26, 1991, TVA met with representatives of the NRC to discuss this issue.
This issue will be completed by the end of Unit 2 cycle 6 refueling nutage.
EFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 77f, Page No. III Full compliance with design criteria (for the two lower drywell steel platforms) will be completed before the end of the next refueling outage (cycle 6).
This action will be completed by the end of Unit 2 cycle 6 refueling outage.
19
1 ENCIOSURE 1 (Cont'd)
Lj, Miscellangges Steel Evaluation Tn NUREG 1232, Volume 3, Supplament 1, the NRC reviewed the status of the miscellaneous steel program and identified a concern on the design criteria and the percent of work completed.
This concern war subsequently resolved in inspection rep 3rt 89-32.
In NUREG 1232, Volume 3, supplement 2, NRC reiterated a open item from an SER dated.7uly 26, 1988.
The open item requested TVA address the adequacy of using the 1978 edition of the American Institute of Steel Construction (AISC) Specifications in the restart evaluation in lieu of the 1963 edition specified in the FSAR.
TVA submitted the long-term design criteria by letter dated June 12, 1991.
Subsequently, in August 28, 1991, TVA met with representatives of the NRC to discuss this issue.
This issue will be completed by the end of Unit 2 cycle 6 refueling outage.
SFNPP Volume 3 Iong-Term or Ongoing Commitments:
Commitment No. 77b, Page No. III The long-term qualification of the remainder of the miscellaneous
= teel will be completed concurrent with phase 2 of the 79-14 program.
The 79-14 program was complete prior to Unit 2 restart.
The commitment for Miscellaneous Steel Evaluation will be completed by the end of Unit 2 cycle 6 refueling outage.
3,10 Class II Features Qver Class I Features SER Open Itenc:
The NRC staff evaluated TVA's program for class II ever class I features in NUREG 1232, Volume 3, Supplements 1 and 2.
The staff concluded that the program to evaluate water spray effects of seismic clasa II piping systems on seismic class I piping systems is an adequate interim approach.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 779, Page No. III The program to evaluate seismic spatial interactions will be 20
i I
l ENCLOSURE 1 (Cont'd) j i
I conducted following resolution of USI A-46 utilizing l
1 techniques _ developed by SQUG.
TVA will provide a response identifying a completion date for this program after receipt of the SER from the NRC for the SQUG program, i
3.11 Secondary containment Penetrations SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3'Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
3.12 Miscellaneous Civil Issues SER Open Items:
The NRC-staff reviewed Miscellaneous Civil Issues in NUREG 1232, Volume 3, Supplements 1 and 2.
The open items remaining within the program scope are the qualification of Mechanical and Electrical Equipment and the evaluation of Seismic Spatial Interactions.
These open issues are within the scope of the USI A-46 program.
TVA will provide a response identifying a completion date for this program after receipt of the SER from the NRC for the SQUG program.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
42 Desian Calculations Review - Electrical, Mechanical; 2
Nuclear and Civil SER Open Items:
There are no SER open items contained in tais
- section, 21 a
ENCLOSURE 1 (Cont'd)
BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 79, Page No. III The post-restart calculation activity will assure functionality of the balance of the safety systems, plus those portions of non-safety systems as considered appropriate.
This commitment will be completed by the end of Unit 2 cycle 6 refueling outage.
5.0 Fire Protection Improvement SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Tarm or Ongoing Commitments:
Commitment No. Bla, Page No. III All future modifications to the fire protection systems will also be in compliance with the industry standards of National Fire Protection Association (NFPA) or CMEB 9.5-1.
TVA is presently revising-the Fire Protection Report which consolidated the fire protection program and fire protection related commitments into one document.
The revised report will be available for review by January 15, 1992.
529 Plant Weldina'Procram SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
a.
Commitment No. 86, Page No. III Include in existing orientation programs or develop additional orientation programs for NE which will-indoctrinate engineers, designors, technical supervisors, and engineering managers in specified areas.
22
=. -
\\
ENCIOSURE 1 (Cont'd)
A weld training program has been developed and implemented at BFN.
This action was completed July 21, 1989.
b.
Commitment No. 87, Page No. III Establish site specific communication link to obtain feedback from the user on NE output documents.
Prepare additional drawings, specifications, and instructions or revise existing documents, as necessary, to meet user organization needs in the areas of welding and Nondestructive Examination (NDE).
Site procedures have implemented this recommendation from the Phase 1 Weld Project Report.
The Phase 2 Report acknowledged that this communication link concerning feedback from the user on NE output documents involving welding and NDE exists.
This action was completed May 5, 1988.
c.
Commitment No. 88, Page No. III When BFN safety-related physical drawings are revised, spec.ify applicable welding requirements, i.e.,
American Institute of Steel Construction (AISC)/American Welding Society (AWS), American National Standards Institute (ANSI) B31.1, or other applicable codes.
Engineering Procedures were revised to include applicable welding requirements on safety-related design changes or drawings.
This action was completed July 8, 1988.
d.
Commitment No. 89, Page No. III Review and revise, as necessary, the BFN Final Safety Analysis Report (FSAR) to consistently identify the source of fabrication, inspection, and testing requirements for safety-related systems and structures.
A review of the FSAR has been completed and the review has determined that no FSAR change was necessary.
Engineering Design Criteria contains the inspection, fabrication, and testing requirements on safety-related systems and structures in them therefore an FSAR revision is not necessary.
23 I
ENCLOSURE 1 (Cont'd) e.
Commitment No. 89a, Page No. III NE shall review and ensure that user organization implementing program procedures delineate the design requirements for welding and NDE.
Site procedures were reviewed and revised, if needed, to include NE as the principal manager to ensure that design requirements for welding and NDE procedures were specified.
This action was completed June 3, 1988.
f.
Commitment No. 89b, Page No. III 2nclude in existing orientation programs (for appropriate engineering, craft and QA personnel) and/or provide additional orientation programs which emphasize:
1.
Maintaining welder qualification (i.e.,
limits of qualificatior nd centinuity).
2.
Preparation of work inst actions.
3.
That only NE-specified welding procedures are approprir.te for use.
4.
Preparation of Notice of Indication forms.
5.
The necescity of accu;.te filler metal record keeping on weld data sheets, particularly when combination-process welding procedures are used (i.e.,
for all filler metal used; record type, size, and traceability reference).
Site procedures address welding concerns identified in the Phase 1 and 2 Weld Project Reports.
In addition, training for craft, engineering, and QA personnel is ongoing.
This action was completed October 31, 1988.
g.
Commitment No. 89c, Page No. III Develop a weld identification and control program for-future welds which provides for unique identification of safety-related welds and has the provisions for record retrievability.
This program was developed and is controlled by site procedures.
This action was completed October 12, 1990, 1
h.
Commitment No. 89d, Page No. III Revise l
SDSP 9.8 to require that engineering data collection for structural evaluation include 24 l
l
l t
r ENCLOSURE.1 (Cont'd)_
o l
weld presence, type, size, length, location, and-those other indications which affect weld size such as burn through,-missing weld,.-and p
L excessive slag.
This procedure was revised to address this concern.
This action was completed June 15, 1988.
i.
Commitment No. 89e, Page No. III Nuclear Engineering (NE) will issue documents specifying_
welding procedures and NDE requirements for all future welding.
E NE has issued procedures specifying welding and j
NDE requirements.
This action was completed E
October 26, 1989.
j Commitment No. 89f, Page No. III Uniquely identify future safety-related welds on weld maps or other suitable records.
Maintain these records as life of plant documents.
Safety-related welds have a controlled unique identification number on weld. maps and are stored as life of the plant documents in L
accordance with site procedures.
This action was completed November 7, 1989.
k.
Commitment No. 899, Page No III Inservice Inspection (ISI) program will assure that inspection of all supports within the ISI program is accomplished over the-next inspection ll interval.
i Procedures are in place to do a visual inspection of supports and computer tracking is utilized to ensure this~ inspection takes place within a stated interval.
This commitment was completed June 8, 1988.
1.
Commitment No.-89h, Page No..III The supports included 1within the ISI program shall.
also be examined for support _and weld configuration.- once final configuration for an item has been verified and documented, this additional examination requirement will be dropped.
25 i-i ww
-~--
wm--
-x-
-r---
v
., ~ --
1 ENCLOSURE 1 (Cont'd)
Walkdown procedures required that support and weld configuration were verified and documented.
This action was completed January 5,
- 1989, 110 Interaranular Stress corrosion Crackina (IGSCC)
SER Open Items:
The NRC staff reviewed TVA's IGSCC Program in an SER on Volume 3,Section III.7,0, and in NUREG 1232, Volume 3, Supplements 1 and 2 and concluded the program was acceptable.
However, in NUREG 1232, Volume 3, Supplement 2, three post-restart activities were mentioned:
a.
Hydrogen water chemistry control will be implemented by the next refueling outage.
TVA is currently evaluating this program.
A submittal will be forwarded to the NRC providing a definitive plan of action to resolve this issue by January 31, 1992.
b.
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.
TVA is currently evaluating the technical merit of stress improvement on these Core Spray welds.
A submittal will be forwarded to the NRC providing TVAs position on this issue by December 31, 1991.
c.
The four-inch and larger stainless steel piping of the Reactor Water Cleanup (RNCU) System located outside containment will be replaced during the next refueling outage (see SER dated December 21, 1989)
This issue will be completed by the end of Unit 2 cycle 6 refueling outage.
BFNPP Volume 3 Long-Term or ongoing Commitments:
a.
Commitment No. 91, Page No. III The Unit 1 and 3 recirculation inlet safe ends will be inspected before restart of each unit.
26
1 I
I
~
ENCLOSURE 1 (Cont'd) i l
TVA submitted a letter dated July 10, 1991, to NRC that discusses the regulatory framework for the restart of Units 1 and 3.
This action will 1
be completed before restart of each unit, j
b.
Commitment No. 92, Page No.III The Unit 1 jet pump instrumentation (JPI) safe ends will be inspected before Unit 1 restart.
TVA submitted a letter dated July 10, 1991, to l
NRC that discusses the regulatory Vramework for the restart of Units 1 and 3.
This action will be completed before restart of Unit 1.
c.
Commitment No. 93, Page No. III If the Unit j
1 recirculation pipe is replaced, IHSI will be performed on the new piping welds.
If pipe l
replacement is not required, the mitigation measures listed under the " restart" column in Table III-7 will be carried out during the l
current cycle 5 outage prior to restart. In either case, hydrogen water chemistry will be implemented prior to restart.
TVA submitted a letter dated July 10, 1991, to NRC that discusses the regulatory framework for the restart of Units 1 and 3.
This action will be completed before restart of Unit 1.
d.
Commitment No. 96, Page No. III All Unit 3 jet pump beams will be inspected prior to restart of Unit 3 and those beams having crack indications will be replaced.
t l
TVA submitted a letter dated July 10, 1991, to NRC that discusses the regulatory framework for the restart of Units 1 and 3.
This action will be completed before restart of Unit 3.
1 e.
Commitment No. 97, Page No. III Unit 3 shroud head bolts will be replaced as needed prior to the restart of Unit 3.
TVA submitted a letter dated July 10, 1991, to NRC that discusses the regulatory framework for l
the restart of Units 1 and 3.
This action will be completed before restart of Unit 3.
27
1 l
a ENCLOSURE 1 (Cont'd) f.
Commitment No. 97b, Page No. III The Unit 1 I
and 3 pump wear rings will be replaced as on Unit 2.
a I
TVA submitted a letter dated July 10, 1991, to NRC that discusses the regulatory framework for the restart of Units 1 and 3.
This action will i
be completed before restart of each unit.
g.
Commitment No. 97c, Page No. III A program for periodic inspection of shroud head bolts
{
will be established.
1 A program is in place to inspect the shroud head j
bolts. A Surveillance Instruction has been j
revised to include this requirement.
This j
action was completed October 16, 1990.
=
i M
Restart Test Procram SER Ooen Items:
There are no SER open items contained in this section.
i BFNPP Volume 3 Restart Commitment:
Commitment No. 99, Page No. III A System Test specification and associated Test Instruction will be generated for each designated plant system to define the scope of testing required, identify additional tests, track test completion, and evaluate test results.
The restart tests were written and performed on Unit 2 and commtc. systems.
The primary purpose of these tests was to demonstrate their safe shutdown functions.
Test objectives have been satisfactorily completed and test results have been approved.
This action was completed September 20, 1991.
L_Q Instrument Sensina lid _en e
SER Open Items:
There are no SER open items contained in this section.
28 1
1 l
ENCLOSURE 1 (Cont'd)
,~
1 l
t BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
10.0 Wall Thinnina Assessment Procram SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commit.nents:
l The BFNPP contains no long-term or ongoing post-l restart activities in this section.
l 11.0 Probabilistic Risk Assessment (PRA) l SER Open Items:
I NUREG 1232, Volume 3, Supplement 2, the NRC 7taff reviewed TVA's draft version of BFN PRA and stated that the restart concerns were adequately resolved and concurred with TVA's conclusion that the BFN facility was not an outlier with respect to core i
mcit frequency. NRC issued Generic Letter (GL) 88-20, Individual Plant Examination for Severe l
Accident Vulnerabilities, dated November 23, 1988.
l Supplement 1 to GL 88-20 was issued August 29, 1989 and requested licensees to provide milestones and schedules for performing an Individual Plant l
. Evaluation of their plant for severe accident vulnerabilities and submitting the results.
In a letter dated October 30, 1989, TVA committed to complete a Level 1 PRA and containment analysis and submit the results by September 1, 1992.
I BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 99d, Page No. III TVA will'as a post-restart commitment, perform a full scope PRA.
A schedule for a full PRA update will be provided before Unit 2 restart.
By letter dated July 26, 1989, TVA documented the closure of this PRA commitment.
TVA considers this commitment closed as it has been superseded by the issuance of GL 88-20.
TVA will address the issue of l
29
ENCLOSURE 1 (Cont'd) plant specific severe accident vulnerabilities consistent with the requirements of the generic letter.
11tQ Comoonent and Piece Part OualificatiRD j
SER Open Items:
j The NRC staff reviewed the Component and Piece Part Qualification _ Program in an SER on Volume 3,Section III.12.0, dated January 10, 1990 and in NUREG 1232, Volume 3, Supplement 2, dated January 23, 1991.
NUREG 1232, described one post-restart activity which is also a long-term Volume 3 commitment.
This j
action will be completed by September 30, 1993.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 99f, Page No.III BFN will j
establish programs and practices that will ensure i
that previously qualified equipment (seismic and environmental) will not be degraded in the future through the use of spare and replacement parts.
An evaluation of both installed and inventoried iter.s, 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.
11,_q Electrical Issues Each program in this section will be addressed individually.
13.1 Cable Installation Issues SER Open Items:
The NRC staff reviewed Cable Installatis7 Issues in NUREG 123I, Volume 3, Supplement 2 and ct1cluded that cable installation issues at BFN are suf ficiently resolved to ensure the perfor tance capability of safety-related cables.
Howe er, one open item was mentioned as described belows 30
ENCLOSURE 1 (Cont'd)
Cables from three of the harshest environmental areas of the plant will be replaced before Unit 2 restart.
This issue was addressed in TVA's letter to NRC dated April 16, 1991.
At the time of the submittal the physical work was complete but three Engineering Change Notices (ECN's) were not completely closed out.
These ECN's were closed May 8, 1991.
This action is complete.
BFNPP Volume 3 Long-Term or Ongojng Commitments:
Commitment No. 99g-2, Page No. III Class 1E low voltage cable will be evaluated for compliance with the established requirements for support of vertical cables as a long-tern post-restart cctivity.
This action will be completed by the end of Unit 2 cycle 6 refueling outage.
13.2 Caole Appacity SER Open Items:
The NRC staff reviewed the Cable Ampacity Program in an SER dated December 19, 1989, and in NUREG 1232, Volume 3, Supplement 2.
The staff concluded there is reasonable assurance that the Unit 2 cables will not be utilized above their rated temperature and will be capable of performing their intended safety functions under normal, abnormal, and accident conditions.
However, the staff requested TVA provide a technical basis for derating factors of cable tray covers between six and ten feet long and to take necessary corrective actions by the end of the first refueling outage after Unit 2 restart.
This issue is presently schedulci and will be completed by the ca.d of Unit 2 cycle 6 refueling outage.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
31 i
E ENCLOSURE 1 (Cont'd)
I 13.3 Flexible Conduit SER Open Items:
The NRC staff reviewed the Flexible Conduit Program in NUREG 1232, Volume 3, Supplement 2, and concluded that the program provides assurance that flexible conduits are adequately installed to accommodate seismic and thermal movements of the attached equipment, devices, and pipes.
However, the staff requested that TVA notify the staff upon completion of the program.
This notification was provided on May 13, 1991, as part of the EQ certification letter.
There are no additional open items.
I BFPPP Volums 3 Long-Term or ongoing Commitments:
Commitment No. 99s, Page No. III Other safuty related flexible conduits attached to safety-related equipment will be evaluated for seismic adequacy j
using the BFN A-46 program.
TVA will provide a response identifying a completion date for this program after receipt of the SER from the NRC for the SQUG program.
l 13.4 Thermal overloads l
SER Open Iters:
l The NRC staff evaluated BFN's Thermal Overload Program in NUREG 1232, Volume 3, Supplements 1 and 2 I
and concluded that TVA had identified the root cause l
and the corrective actions taken were acceptable.
l However, in NUREG 1232, Volume 3, Supplement 2, the staff identified 3 open items and requested notification upon completion of these items.
In a letter dated April 16, 1991, TVA provided the notification of completion of these items.
BFNPP Volume 3 Long-Term or Ongoine, Commitments:
The BFNPP contains no long-turn or ongoing post-restart activities in this section.
l 32
i I
ENCIOSURE 1 (Cont'd) 13.5 Cable Solices SER Open Items:
The NRC staff reviewed TVA's Cable Splice ' Program in NUREG 1232, Volume 3, Supplement 2 and concluded that-the program was acceptable and provided adequate assurance that qualified electrical cable L
splices within the plant are-installed correctly.
L However, in NUREG 1232, Volume 3, Supplement 2, the-l staff identified one open item and requested notification upon completion-of this item.
In a letter _ dated April 16, 1991, TVA provided the notification of completion of this item.
BFNPP Volume 3 Long-Term or ongoing Commitments:
I The BFNPP contains no long-term or ongoing post -
i restart activities in this section.
lJ 13.6 Puse Procram i
SER Open Items:
'The NRC staff-evaluated the Fuse Program in NUREG 1232,. Volume 3, Supplements 0, 1, and 2, and concluded that TVA has ider.tified the root cause of-l-
misapplication of-current-limiting fuses and the corrective actions 1taken are acceptable.
- However, in NRC IR 89-59,-and.in NUREG 1232, Volume 3, 2
post-restart commitments were identified and are listed below:
a.
~BFN will1 remove tue 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),
b.
BFN will install. permanent fuse labeling, prior to startup from the next refueling outage (cycle 6).
i TVA is currently evaluating these programs.
A
. submittal will be. forwarded to the NRC providing a definitive plan of-action.to. resolve this issue by January 15, 1992.
33
- l..
i ENCLOSURE 1 (Cont'd)
BFNPP Volume 3 Long-Term or ongoing Commitwents:
a.
Commitment No. 99 (1)-2, Page No. III 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.
TVA is currently evaluating this program.
A submittal will be forwarded to NRC providing a definitive plan of action to resolve this issue by January 15, 1992.
b.
Commitment No. 99m, Page No. III In addition, NE will develop a controlled computerized' fuse list unique to BFN.
This action was deleted.
This commitment is a duplicate of a restart Commitment No. 99 (1) -1.
14.0 Hiscellaneous Procrama Each program in this section will be addressed individually.
14.1 O-List SER Open Items:
There-are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
Commitment No. 99n, Page No. III TVA is developing a Q-List for BFN.
This program is a two phase program.
Phase 1 was completed'May 7, 1991.
Phase 2 is expected to be completed by September 30, 1993.
34
l-ENCLOSURE 1 (Cont'd) 14.2 Moderate Eneray Line Break-Floodina SER Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
14.3 Containment Coatinas SER Open Items:
L There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
i The BFNPP contains no long-term or ongoing post-i restart. activities in this section.
14.4 Platform Thermal Growth SER'Open Items:
There are no SER open items contained in this section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
14,5 Heat Code Traceability SER Open Items:
[
There are no SER open items contained in this i
section.
BFNPP Volume 3 Long-Term or Ongoing Commitments:
The BFNPP contains no long-term or ongoing post-restart activities in this section.
35 l
l ENCLOSURE 1 (Cont'd)
ATTACHMENT IV-3 COMMITTED REGULATORY MODIFICATIONS WHICH WILL BE COMPLETED BEFORE RESTART OF UNIT 2 L
This attachment contained no long-term or ongoing post-restart activities.
ATTACHMENT IV-4 COMMITTED REGULATORY MODIFICATIONS WHICH WILL BE COMPLETED IN THE FIRST REFUELING OUTAGE FOLLOWING UNIT 2 RESTART 1.
NUREG-0737 Item I.D.2 Safety Parameter Display System (SPDS)
By letter dated April 16, 1991, TVA updated the staff on the status of this issue.
2.
NUREG 0737-Item II.B.3 Implement Post-Accident Sampling System (PASS) l In a letter dated December 28, 1989, TVA revised the commitment to fully implement PASS during cycle SB. The system has been installed and has been evaluated against NUREG 0737 criteria during plant operating conditions (Ref.. IR 91-28).
See Section 6
" Radiological Control and Chemistry Improvement",
page 11, for additiot.al information.
3.
NUREG 0737-Item K.3.28 Qualification of Automatic Depressurization System (ADS)
Accumulators By letter dated April 16, 1991, TVA updated the staff on this issue.
4.
Generic Letter 84-23 Reactor Vessel Water Level Instrumentation in BWR's By letter dated April 16, 1991, TVA updated the staff on this issue.
BFNPP Volume 3 Restart Commitment:
Commitment No. 105, Page No. IV-21 Special testing will be employed during restart heatup of the vessel to ensure that the water level instruments are operating properly.
Special testing was done to collect sufficient data to verify that the reactor water level monitoring 36
l 1
ENCLOSURE 1 (Cont'd) instrumentation _ operated correctly during reactor heat up to rated conditions and power increases up to full power.
This was achieved by recording readings on all water level indication and comparing them to each other and to predicted level readings based on existing plant conditions.
This action was completed September 17, 1991.
5.
1.E.
Bulletin 79-02 Pipe Support Base Plate Design Using Concrete Expansion Anchor Bolts By letter dated April 16, 1991, TVA updated the staff on this issue.
6.
I.E.
Bulletin 79-14 Seismic Analysis For As-Built Safety-Related Piping Systems By letter dated April 16, 1991, TVA updated the staff on this issue.
7.
NUREG-0737-Item I.D.1 Detailed Control Room Design Review (DCRDR)
As requested in an SER dated August 15, 1990, TVA submitted a supplemental report for the DCRDR program 90 days after restart of BFN Unit 2.
This submittal I
was transmitted to the NRC dated August 22, 1991.
8.
Fire Protection As described in TVA's April 4, 1988 letter and later i
revised in a September 21, 1989 submittal, a number of l
fire protection system upgrades are scheduled for post-l restart.
TVA is presently revising the Fire Protection Report which consolidated the fire protection program and fire protection related commitments into one document.
The l
revised report will be available for review by January 15, 1992.
HECTION V.
- OPERATIONAL READINESS PROGRAM SER Open Items:
NRC staff reviewed the Operational Readiness Review (ORR) Program in NUREG 1232, Volume 3, Supplement 2 and stated the staff will continue to evaluate and 37
l l
ENCLOSURE 1 (Cont'd) examination of TVAs ORR program.
NRC conducted an Operational Readiness Assessment Team (ORAT)
Inspection (IR 91-201) prior to Unit 2 restart.
The inspection team performed an independent assessment of the readiness of management controls, programs, and personnel to support safe restart and operation of Browns Ferry.
The ORAT team identified thirteen open items. TVA has completed the corrective actions associated with these items.
BFNPP Volume 3 Long-Term or ongoing Commitments:
This section contained no long-term or ongoing post-restart activities.
~
b 38
i l
ENCIASURE 2 1
LIST OF COMMITMENTS 1
l l
l l
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ENCLOSURE 2 I.
LIST OF COMMITMENTS HAVING A NEW OR REVISED SCHEDUII 1.
The Master Equipment List has been incorporated into the Browns Ferry Equipment Management System (EMS) data base.
Key safety-related listings of equipment information have been loaded into EMS including the Q-List, 50.49 List.
Valve tabulations will be added by September 30, 1991.
Remaining work will be ongoing through the end of September 1993.
2.
The maintenance instructions upgrade is scheduled and will be completed Septemb6r 30, 1993.
3.
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.
4.
TVA was scheduled to upgrade to Revision 4 of the Emergency Procedures Guidelines by December 31, 1991, however, due to the startup of Unit 2 and the manpower needed to support restart, full implementation should be completed by June 15, 1992.
5.
In a letter dated December 10, 1987, TVA committed to l
upgrade the security system.
The schedule for completion is to have design complete in October 1991, begin construction in January 1992 and the installation will be completed by March 31, 1993.
6.
TVA should develop long-term criteria for HVAC evaluation and perform long-term buckling evaluation for all ductwork qualified to the interim criteria (IR 89-42).
TVA will develop and submit for review to the NRC 4
the long-term criteria by November 15, 1991.
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ENCLOSURE 2 (Cont'd)
II.
LIST OF COMMITMENTS INVOLVING CHANGES IN PREVIOUSLY DEECEIBED SCOPE 1.
Hydrogen water chemistry control will be implemented by the next refueling outage.
TVA is currently-evaluating this program.
A submittal will be forwarded to the NRC providing a definitive plan of action to resolve this issue by January 31, 1992.-
2.
Six welds-in the Core Spray System with austenitic stainless steel. fittings will undergo Post-Induction Heat Stress Inspection during the next refueling outage.
TVA is currently evaluating the technical merit of stress improvement on these Core Spray welds.
A submittal will be forwarded to.the-NRC providing TVA's position on this issue by December 31, 1991.
3.
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.
TVA is currently evaluating this program.
A submittal-will be forwarded to NRC providing a definitive plan of action to resolve this issue by January 15, 1992.
4.
BFN will-install permanent fuse labeling, prior to startup from the next refueling outage (cycle 6).
TVA is currently evaluating these programs.
A submittal will be forwarded-to the NRC providing a definitive plan of action to resolve this issue by January 15, 1992.
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