ML20197H650
| ML20197H650 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/04/1997 |
| From: | Jerrica Johnson NRC (Affiliation Not Assigned) |
| To: | Hebdon F NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20197H447 | List:
|
| References | |
| FOIA-98-330 50-259-97-04, 50-259-97-4, 50-260-97-04, 50-260-97-4, 50-296-97-04, 50-296-97-4, NUDOCS 9812140151 | |
| Download: ML20197H650 (9) | |
See also: IR 05000259/1997004
Text
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UNITED STATES
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REGION II
ATLANTA FEoERAL CENTER
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'" 61 FORsYTH STREET, sW. sulTE 23T85
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ATLANTA, GEORGIA 30303
***** June 4,1997
MEMORANDUM FOR: Frederick J. Hebdon, Director
Project Directorate !!/111
Office of Nuclear Reactor Regulation
FROM: Jon R. Johnson, Director
Division of Reactor Projects r
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l SUBJECT: T!A 97-015 REQUEST FOR REVIEW ASSISTANCE - l
MAINTENANCE RULE IMPLEMENTATION FOR BROWNS i
FERRY, UNIT 1
The purpose of the memorandum is to request NRR's assistance in resolving the issue of the ;
extent of Maintenance Rule implementation for Browns Ferry, Unit 1. Region 11 completed
the Maintenance Rule Baseline inspection at Browns Ferry on April 18,1997. The results of
the inspection are documented in NRC Inspection Report No. 50-259, 260,296/97-04.
!
During the inspection, the inspection team conducted a detailed review of the implementation .
l of the Rule on all three units. The team did not have any safety concems with the manner in i which the Tennessee Valley Authority (WA) had implemented the Rule on Unit 1, and
concluded that TVA actions to implement the Rule were technically adequate. However, a
,. question arose, as to whether or not the action taken by WA met the Rule legally. Plant j conditions for Unit 1 are shutdown and defueled, and there are no current plans to restart the i unit. Although Unit 1 is licensed, it cannot be restarted without prior Commission approval. l WA's implementation of the Rule is for a shutdown, defueled condition on Unit 1 and does l not encompass all systems and components that are covered on the operating units. l- Enclosure 1 provides a more detailed discussion of the issue, and Enclosures 2,3, and 4
provide supporting documentation that may be useful.
, This issue was discussed with the NRR staff, the OGC staff, and with the licensee during the ! . inspection, and no resolution to the issue was obtained at that time. As a result, an
unresolved item was issued to assure tracking and resolution.
.
The Region requests your technical assistance with OGC to develop a list of actions
- necessary for TVA to comply legally with the Rule on Unit 1. This list of actions should be
! provided directly to WA with a copy to the RegionTThe Regional technical contacts are
Bill Holland (404) 562-4612 and Ron Gibbs (404)362-4611.
<
Enclosures: 1. Excerpt from inspection Report . 50-259,260,296/97-04
! 2. Browns Ferry MR Scoping Matrix l 3. Excerpt from Browns Ferry Technical j instruction 0-TI-346 Rev. 7 '
4. April 16,1996, Letter from the President,
TVA Nuclear and CNO to NRC
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SC unavai' ability. Also, all ROs indicated the need to document SSC outages in tjie
co rol room log books for all SSCs under the scope of the maintenance rule. F' ally,
the s indicated that they make additional entries into the log books such t the ,
system gineers can clearly identify the period during which the compone was
actually n -functional. distinct from the Technical Specification determin ion of
l equipment o rability. This distinction is especially important for the ergency j diesel generato
The " Dual Unit Maint ance Matrix"in SSP 7.1 (Revision 16) vides guidance for
evaluating the plant co uration risk for equipment out of rvice while the plant is at
power. The SROs stated ey use the matrix when eme ing failures occur and
, occasionally to check work ek activities. For cases here two SSCs may be taken
r
out of service, the SRO's unde anding of the matr' was good, except for some
( uncertainty in the interpretation o o of the sys s on the matrix: Control Rod l Drive (CRD) pumps and Residual H t Remov (RHR) unit crossovers. For the ! CRD, there was uncertainty whether th .C entry should be interpreted as both l p' umps or either pump, Also, for the RH rossover events, the matrix entries , !
appeared to be similar to matrix entrier ort RHR trains (not involving crossovers
between units). For cases where t e SSCs the matrix may be taken out of
service, the SROs correctly state hat they woul ave to contact engineering (for
PRA evaluation). Such guida is stated on the m ix Finally, for SSCs not listed
on the matrix, the operators ated they use Technical ecifications, evaluations of
l " closeness to scram", an engineering judgment to decid 'f such SSC outages are l nsk significant. I
c. Conclusions
in general, t ROs and SROs interviewed clearly understood the philo phy of the
Maintena e Rule and their responsibikties for implementation of the rule. There was
some fusion concerning the interpretation of several systems on the "Du ' Unit
l Mai nance Matrix." However, there was no evidence that the confusion led ,a j hi risk plant configuration. l.
11. MAINTENANCE
M1 Conduct of Maintenance
'
i l M1.1 Scope of Structures Systems. and Components Included Within the Rule
a. Inspection Scope (62706)
Prior to the onsite team inspection, the Team reviewed the Browns Ferry UFSAR,
LERs, the EOPs, previous NRC Inspection Reports, and other information provided by
- the licensee. The Team selected an independent sample of SSCs that the Team
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believed should be included within the scope of the Maintenance Rule. SSC scoping
criteria are described in 10 CFR 50.55 (b). During the onsite review, the Team used
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this sample and the 10 CFR 50.65 (b) cnteria to determine if the licensee had
adequately identified the SSCs that should have been included in the scope of the
Browns Ferry program.
ENCIDSURE 1
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b. Observations and Findinos
The licensee appointed an expert panel to perform several Maintenance Rule
implementation tasks including establishing the scope of the Maintenance Rule. The
expert panel reviewed the 162 systems in the plant and determined that 97 structures,
systems, and components were in the scope of the Maintenance Rule.
The Team reviewed the licensee's SSC Selection and Performance Monitoring Matrix
, '
in an effort to verify that all required structures, systems, and components were
included within the scope of the Maintenance Rule. The Team's review was
performed to assure the scoping process included:
*
All safety-related SSCs that are relied upon to remain functional during and
following design basis events and ensure the integrity of the reactor coolant
pressure boundary, the capability to shut down the reactor and maintain it in a
, safe shutdown condition, and the capability to prevent or mitigate the
consequences of accidents that could result in potential offsite exposure
comparable to the 10 CFR Part 100 guidelines
*
Non-safety SSCs that are relied upon to mitigate accidents or transients
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Non-safety SSCs which are used in the plant emergency operating procedures
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Non-safety SSCs whose failure could prevent safety-related SSCs from
fulfilling their safety-related functicn
*
Non-safety SSCs whose failure could cause a reactor trip or actuation of a
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safety-related system.
The Team verified that all required SSCs were included in the Rule for Units 2 and 3.
The Team reviewed the licensee's implementation of the Maintenance Rule on Unit 1
in a considerable amount of detail. This was necessary due to the fact that the
licensee had considered plant status (i.e., Unit 1 is shutdown and defueled and has
been for several years) in Rule implementation. The following information was
obtained from this review:
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l* The licensee's Maintenance Rule implementing procedure (0-TI-0346)
specifically stated that SSCs on Unit 1 had been scoped under the Rule
j considering plant status (i.e., shutdown and defueled).
1* This procedure also stated that if Unit 1 conditions were to change scoping
would be re-evaluated based on the change. j
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The procedure referenced a letter regarding Unit 1 status. which includes
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specific commitments to notify NRC of any plans to return the unit to operation i
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and also to obtain Commissioners' approval prior to restart of the unit
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- (Reference April 16,1996, letter from President, TVA Nuclear and Chief ;
! Nuclear Officer, (A00 960415900) to the US Nuclear Regulatory Commission). I
h* The procedure included a Maintenance Rule scoping matrix which provided a
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column for scoping of Units 2,3, and common, and a separate column for
scoping Unit 1 only.
l 1 6* Unit _1 systems which support Unit 2 and 3 operation, and Unit 1 systems l which interface (are common) with Unit 2 or 3 were properly scoped in the i Rule, as appropriate. Active performance monitoring, data collection and i
trending was being performed on these systems.
L b~* , Unit 1 systems required to maintain safe shutdown of the unit, such as, spent L fuel pool cooling were properly scoped in the Ru!e. Active performance
monitoring, data collection and trending was being performed on these
systems.
,b* Unit 1 systems which would normally be included in the scope of the Rule for '
an operating plant, such as High Pressure Coolant injection, were not included
in the scope of the Rule. Performance monitoring, data collection and trending
was n_ot being performed on these systems. These systems were in layup, not
in use, and the licensee determined that normal Maintenance Rule monitoring
was not appropriate.
The Team determined that the licensee actions to implement the Rule, based on the I
above facts, were technically adequate. However, the Team noted that other utilities
with plants shutdown for considerable amounts of time had not considered plant
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status in implementation of the Maintenance Rule. This resulted in a question as to \
whether or not the approach taken by the licensee with respect to Unit 1 was in fact
legal under the Maintenance Rule. This issue remained unresolved at the conclusion
of the inspection. As a result, an Unresolved item URI 50-290/97-04-01, Resolve
Maintenance Rule implementation on Browns Ferry Unit 1, is identified pending further
NRC review.
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c. Conclusions
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The Team determined that the required structures, systems, and components were \
included within the scope of the Maintenance Rule for Units 2,3, and Common. The ) l
Team also determined that the licensee's actions to implement the Rule for Unit 1
were technically adequate. However, an unresolved item was identified concerning i'
Maintenance Rule implementation for Unit 1.
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(JNIT U MAINTENANCE RL ERFORMANCE i
INDICATOR MONITORING, TRENDING, AND 0-TI 34t. ;
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REPORTING - 10CFRSO.65 PAGE 60 OF 163
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REV 7
APPENDlX Il
(Page1of15)
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SSC SEl.ECTION AND PERFORMANCE MONITDRING MATRI,'
%xr
SSC Scopinn Criteria , -g Specific Momtoring
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5R NSR NSR NSR KNR
[M k. M R.
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SysletH DChCli[1Iiuti '4
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ID NSC MAfr mt* t ait Tsys Lm3 Lgic M.piit
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saray no N Rt*fetCI1CC COmtHCHtS and IHIOOHallOH
ut
3 A r 1. v i n
112!.1 <*dy M li
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000 Spare Local Panels and Misc. Yes No No No No % V No No
EMS lists 15 SR components as system 000
These are admine;trative componem l
assignments and do not provide an installed
_
001 Mam Steam Yes Yes plant equipment fnnction.
Yes No Yes Yes No Yes Yes
4 X- X Risk Sign;rtcant functions are : elated to SRV i
overpressure protection, ADS, and MSIV
002 Condensate and Deminerahzed Yes Yes Yes No operation. Refer to Attachments I and 2
Yes Yes No Yes No X
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Water X X Refer to Attaclunent 3
001 Reactor Feedwater Yes Yes Yes No Yes Yes No Yes No X X X Refer to Attachment 4
00t Hydrogen loyection No No No No No No No No No
This system is not in service. EMS hsts
005 Extraction Steam No No No No No components as design in piogress. I
No No No No
Refer to Expett Panel minntes, RIMS
006 IIcater Drains and Vents No No Yes No Yes
__
R40970116328, for scoping evaluation
Yes No No No
00s Miscellaneous Tmbine I
No No No No No No No No r
No
Connections
009 Control Bay Pancis (Common) Yes No Yes No No i
Yes No No No '
010 Boiler Drains and Vents See Note 9
Yes No No No No Yes No No No
012 Auxiliaty Uciler Yes No No No No No No No No
SR devices in System 012 are inomtored mil 7
018 Fuel Oil System (Common) Yes No No No No System 064 (Containment Integnty)
Yes No Yes Yes X X
020 - Lubricating Oil Transfer No No No Refer to Attachment 24
No No No No No No .[
021 Nitrogen Purging No No No No No No No No '[
No
EMS lists I component for this system Tins ;
- - -
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^ component is momtored mth the Main Steam ;
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023 RHR Service water (Conunon) Yes No No No No Yes No Yes Yes
%n stem. - _- ^ .!
X X Refer to Attachment 5
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UNIT U M AINTENANCE Rt. /ERFORMANCE
INDICATOR MONITORING, TRENDING, AND 0-TI-34m
REPORTING - 10CFR50.65 PAGE 64. OF 163
REV7 !
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APPENDIX 11
(Page 5 of 15)
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SSC SELECTION AND PERFORMANCE MONIT'ORING MATRIX
SSC Scoping Criteria
Specific Monitoring I
S 11 R C
S. R NSR NSR NSR NSR *
M. R. M R. Rid C
bY3- System Description sxc uvr me rmi ann sye s ,: s,g,(
Standby E U N E o i
S4dy
R s c A N Reference Comments and Infoimation
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ID tM U1 A le 1. V I
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120 miy M li A A
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064A Primary Containment Integrity Yes No No No No Yes No Yes No X X Refer Attachment 13. This function captures
all containment related monitonng across f:
0648 Reactor and Refiic! Zone Yes No system boundaries
Yes No Yes Yes Yes No No [
Ventilation Core Spray and RHR toom coolers are t
monitored with systems 75 and 74
064C Secondary Contamment Yes No respectively.
Yes No No Yes No No No
(Common)
064D Primary Containment isolation Yes No No No No Yes No Yes No X X
(PCIS) Refer to Attachment 13 'I
065 Standby Gas Treatment Yes No No No No Yes No Yes Yes X X
f
(SUGTi tcommon) Refer to Attachment 14
06ti OfTGas System Yes Yes No
067
a Yes Yes Yes No No No
Emergency Equipment Coolmg Yes No No No No Yes No Yes No X X
Water (EECW)(Common) Refer to Attachment 15
06R Reactor Water Recirculation Yes Yes Yes No Yes Yes No No. No '
069 Reactor Water Cleanup Yes No Yes No Yes Yes No No No
(RWCU)
1 070 Reactor Building Closed Yes Yes Yes No. Yes Yes Yes No No ,
Cooling Water (RBCCW)
071 Reactor Core isolation Cooling Yes No No No No Yes No Yes Yes X X
m (RCIC) - Refer to Attachment 16
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0 73 Thgh PrEure Coolant injection Yes No No No No Yes No Yes Yes X X '
(HPCI) Refer to Attachment 17
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UNIT 0 MAINTENANCE RL .'ERFORMANCE
INDICATOR MONITORING, TRENDING, AND 0-TI-34s
REPORTING .10CFR50 65 PAGE 65 OF 163 ;
REV 7 !
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(Page 6 or is)
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SSC SELECTION AND PERFORMANCE MONITORING MATRIX
SSC Scoping. Criteria
Specific Monitoring
S. It NSR NSR NSR
s u R c
NSR M R. M lt }M hull.y C lI tt N !!
ID S)StCIM DC$Cli[)lIOli sse M,VI I:Ol' l-ait Tnn %pe % pe %gur O
R S C A N
SJeiy tM Ut
1. SCfCICHCC COlHHicutS 3Hd
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( 074 Residual Heat Removal (RHR) Yes No Yes No No Yes Yes Yes Yes X X
075 Core Spray Yes No Yes No Refer to Attachment ISh
No Yes No Yes Yes
076 X X Referio AttachnM
' Containment inerting System Yes No Yes No Yes Yes No No No X
077 Radwaste System _ Yes No Yes No Refer to Attachment 20
No Yes Yes No No
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47S X Refer to Attachmg.nt 21
SpetitTGeTT)o~ol Cooling and Yes No No No No Yes t
Yes No No X Refer to Attachment 2
Cleanup (SFPCC)
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079 Fuel Handhng and Storage Yes No No Yes %
Yes Yes No No No j
030 X Refer to Attachiiie'iit~f3
Prnuary Containment Cooling Yes No No No No No No No No
SR components monitored with system
082 Standby Diesel Generators Yes No No 064A
No No Yes No Yes [
Yes X X
034 Containment Atmosphere Yes No No No No Refer to Attachment 24
Yes No No Yes
Dilution (C A D) X Refer to Attachment 25 !
085 Control Rod Drive Yes Yes Yes No Yes Yes Yes Yes i
X X Refer to Attachment 26
086 Diesel Generator Startmg Air Yes No No Ne No Yes No Yes Yes X X
(Common) Monitored with diesel generators
090 Radiation Monitoring Yes No Yes y Yes Yes Yes No No X
IS} stem 032) Refer to Attachment 24
X Refet to Attachment 27
092 Neutron Monitoring Yes No No No No Yes No No No
,
094 Travereng incore Probe (TIP) Yes No No No No No No No No
SR components are assocated w1th PCIS
j Group 8 isolation and are monitored with
System 064D
O' 6 :P urculdion Flow Control Yes Yes No No Yes Yes No No No
[[ Agricult:ne Waste Heat Supply No No No No No No No No No
f,i Teactor Protection Yes No No No No Yes No Yes No
^
X X
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.Oenetrations and Sleeves Yes No No No No Yes No No No
Refer to Attachment 32
; Refer to Attachment 13. Monitored as
past of containment miegrity fimction
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BFN MAINTENANCE RULE PERFORMANCE 0-TI-346
,. UNIT 0 INDICATOR MONITORING, TRENDING, AND PAGE 6 OF 163 l
REPORTING - 10CFR50 65 REV 7
1.0 INTRODUCTION
1.1 Pu1po_se
This Technical Instruction (TI) prosides guidance for initiation, analysis, ietrieval,
trending, and reponing of data relative to " Plant Level" and " Function Specific" indicators i
ofperformance required by the Maintenance Rule, hereafter referred to as the Rule. The
requirements of this T1 are in compliance with 10CFR50.65 and NUMARC 93-01, unless
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otherwise specified in paragraph 3.3 of the TVAN Maintenance Rule Program Manual. 1
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Additional guidance is prosided for trending and reponing of repetitive preventable l
functional failures which are within the scope of the Rule. Appendix A is a sununary level
process flow chart for the trending and reporting activities described by this instruction.
1.2 Scofte
This instruction applies to individuals involved in the monitoring and trending of
performance of Units 1,2,3 and Common plant systems, structures, and components
(SSCs) listed in Appendix II, SSC Selection and Peubnnance Monitoring Matrix.
Systems monitored as Common are designated in Appendix II. Refer to paragraph 3.0,
Definitions, for clarification of the tenn " system" It includes the perfonnance ofcause
determinations for failures to meet performance criteria and for repetitive Functional
Failure -
Scoping of Unit 1 SSCs has been perfonned based on cunent plant conditions (Unit I
defueled and in layup, Units 2 and 3 in operation). If Unit I conditions change, the
affected SSCs will be re-evaluated for 10CFR50.65 applicability (refer to Reference 2.13).
Generally, plant level performance criteria apply to nonnally operating system funcuons
within the scope of the Rule that are not risk significant. Function specific perfonnance
criteria apply to risk significant functions, nonrisk standby fimetions, and those nonrisk,
nonstandby functions whose perfonnance cannot be measured at the plant level
Functional failures, both initial and repetitive, apply to all system functions within the
scope of the Rule.
2.0 REFERENCES
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2.1 10CFR50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nucl ear
Power Plants
2.2 NUMARC 93 01, Revision 2, industry Guideline foi Monitoring the Effectiveness of
Maintenance at Nuclear Power Plants, April 1996
y &LLE 15 l,2 9W.3 Cf h.6))m Tos) AefV5
ENCLOSURE 3
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( *. . l j. BFN MAINTENANCE RULE PERFORMANCE 0-TI-346 i2 UNIT 0 INDICATOR MONITORING, TRENDING. AND PAGE 7 OF 163 '- l
REPORTING - 10CFR50.65 REV 7
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2.0 REFERENCES (Continued)
2.3 TVAN Maintenance Rule Program Manual !
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2.4 INPO 96-003, Performance Indicator Program - Utility Data Coordinator Reference
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' Notebook, dated September 1996 j
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. 2.5 SSP-3.4, Corrective Action Program
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2.6 SSP-4.4, Managing The Operating Experience Program i
2.7 SSP-4.5, Regulatory Reporting Requirements
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l- 2.8 . SSP-7.1, Work Control
2.9 SSP-9.3, Plant Modifications and Design Change Control
2.10 SSP-12.16, Emergency Operating Instruction Control
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2.11 ' SSP-12.9, lucident. Investigations and Root Cause Analysis g 8-3 pM
2.12 SEP-9.5.8, Probabilistic Safety Assessment (PSA) Program
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13 April 16,1996 letter from President, TVA Nuclear and Chief Nuclear OfUcer,
(A00 960415 900) to the US Nuclear Regulatoiy Comission
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3.0 DEFINITIONS
As used in this document, (a)(1), (a)(2), and (a)(3) refer to paragraphs included in 10 CFR
50.65. Paragraph (a)(1) ofthe Rule refers to SSCs cited for improved performance.
Paragraph (a)(2) refers to SSCs exhibiting adequate performance. Paragraph (a)(3) refers
to the periodic assessment of the eiTectiveness of goals, the balancing of unavailability and
reliability ofrisk significant SSCs, and the impact on plant safety from perfonning elective
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on-line maintenance.
Function: As used in this document and the Maintenance Rule program, the function is
that attribute (e.g., safety related, mitigates accidents, causes a scram, etc ) that included
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the SSC within the scope of the Maintenance Rule. For example, the condenser vacuum
j system is scoped under the Maintenance Rule because its total failure could cause a scram '
and not the function ofpulling a vacuum on the condenser.
Functional failure: Refer to paragraph 7,4.
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