ML20197J057

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Partially Deleted Response to TVA Ltr Dtd 980403, Browns Ferry Nuclear Plant Unit 1 Revised Response to NRC Request Re Imlementation of Maint Rule,10CFR50.65 (URI 50-259/97-04-01)
ML20197J057
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 06/15/1998
From: Black S
NRC
To: Hebdon F
NRC
Shared Package
ML20197H447 List:
References
FOIA-98-330 50-259-97-04, 50-259-97-4, NUDOCS 9812140246
Download: ML20197J057 (4)
v • d • e


See also: IR 05000259/1997004

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June 15, 1998

MEMORANDUM TO: Frederick J. Hebdon, Chief

Project Directorate !!-3

Division of Reactor Projects

FROM: Suzanne C. Black, Chie dud k Ah

Quality Assurance, Vendor inspection and Maintenance Branc

Division of Reactor Controls and Human Factors

SUBJECT: RESPONSE TO TVA LETTER DATED APRIL 3,1998, ' BROWNS

FERRY NUCLEAR PLANT (BFN) - UNIT 1 - REVISED RESPONSE TO

NRC REQUEST REGARDING IMPLEMENTATION OF MAINTENANCE

RULE,10 CFR 50.65 (URI 50-259/97-04-01) (TAC NO. M 98931)"

BACKGROURQ_

During the period of April 4 - 18,1997, the NRC conducted an inspection of the implementation

of 10 CFR 50.65 (Maintenance Rule) at the Browns Ferry Nuclear (BFN) Plant. The results of I

that inspection were documented in NRC combined Inspection Reports 50-259/97-04,

50-260/97-04, and 50-297/97-04 (IR 97-04) issued May 21,1997. The results ofIR 97-04

determined that, in general, WA's actions to implement the Maintenance Rule (the rule) for

BFN Unit 1 were technically adequate to support the inte face functions with Units 2 and 3 and

that the Unit 1 systems required to maintain spent fuel pool cooling were properly scoped in the

rule. However, an Unresolved item (URI 50-259/97-04-01) was identified for Unit 1 conceming

the acceptability of TVA's approach to addressing the structures, systems and components

(SSCs) required to be within the scope of the rule, as required by $50.65 (b). As described in

IR 97-04, TVA's approach for the limited scoping of BFN Unit 1 SSCs was based on (1) the

long term shut down and defueled status of the plant, (2) procedural controls that would require

re-evaluation of scoping considerations if Unit 1 conditions were to change, and (3) the

docketed commitment to notify the NRC of any plans to retum the unit to operation, which

would require Commission approval prior to restart. However, the team was concemed with

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TVA's methodology, which excluded the majority of the SSCs required to be within the scope of

$50.65(b) for a facility licensed under $ 50.22 (i.e., the high pressure coolant injection, reactor

core isolation cooling, main steam and reactor water recirculation systems were not included in

the scope of the rule). The team also identified that performance monitoring, data collection,

and trending activities were not being performed on these systems. Accordingly, Region 11

forwarded Technical Interface Agreement (TIA)97-015, dated June 4,1997, to Project

Directorate (PD) ll-3, NRR, in order to resolve URI 50-259/97-04-01.

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Frederick Hebdon -2-

The Quality Assurance, Vendor inspection and Maintenance Branch (HQMB) provided its

response concoming TIA 97-015 to PD ll-3 via memorandum dated June 17,1997.  :

Subsequent to receiving this response, PD ll-3 informed WA by letter dated July 30,1997,

that, absent the certification per $50.82 (a)(1) for licensee's facilities in a decommissioning

status, all the requirements of $50.65 applied to BFN Unit 1. Specifically, the NRC's letter

stated that the existing scope of SSCs for BFN Unit 1 was inconsistent with the requirements of l

the rule. The NRC's letter also provided the following three attematives to the existing

condition: ,@ ..

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1. Revise the scope of the maintenance rule monitoring program for Unit 1 to include

structures, systems and components as specified in paragraph (b) oflhe rule, or

2. Submit a written certification to the NRC as specified in 10 CFR 50.82 (a)(1) that WA

has determined to permanently cease BFN Unit 1 operations, or

3. Petition the NRC for an exemption from the requirements of the rule that are not

currently being met.

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The staff further requested that TVA describe which of these three attematives it considered to

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be applicable or propose another course of action that it believed satisfied the requirements of

the rule. By letter dated September 29,1997, TVA provided its response. TVA stated that they

did not consider the selection of any of the three attematives was warranted, since TVA's

program to implement the maintenance rule for BFN Unit 1 was in compliance with

10 CFR 50.65.

HQMB completed its review of TVA's September 29.1997, letter and forwarded the results to 1

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PD 11-3 by memorandum dated November 6,1997.F

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l, On January 26,1998, the NRC staff, including representatives from NRR, the Office of the ,

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! - General Counsel, and the Office of Enforcement, met with representatives from TVA at the

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NRC's headquarters offices to discuss the resolution of URI 50-259/97-04-01. The results of

these discussions were documented in a meeting summary issued on Februs_ry_6.1996

During the meepng, TVA reiterated its position that those systems necessary to support Unit 1

l in a safe condition are being maintained, as are those needed to support Units 2 and 3, which

l are currently included within the scope of the monitoring program required by the rule. TVA

further stated that the remaining Unit 1 SSCs were not included within the scope of the rule

because they did not serve a function with the plant in its shutdown and defueled state.

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Frederick Hebdon -3-

Relative to the status of Unit 1, WA indicated that most of the systems and components were

in layup to preserve these iterbs for future use, if the decision is made to restart the unit. For

the systems and components maintained in layup status, WA stated that it could not be

demonstrated that these items could perform their intended function and that the preservation

program was not intended to achieve this objective. TVA also indicated that, in the event a

decision is made to restart Unit 1, the scope of their monitoring program would be revised

appropriately.

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_ ' in response to TVA's position, the staff stated that, because TVA maintains s' nil ersting

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license for Unit 1, they must comply with the requirements of the rule for all SSCs that meet the

criteria specified in 550.65(b). The staff further stated that preventive mainterstnce activities

must be implemented to provide reasonable assurance that SSCs are kept in adequate

condition while the unit remains in a shut down condition. The staffindicated that a preventive

maintenance program for Unit 1 would not need to be as comprehensive as a program for an

operating plant. However, the staff stated that TVA could consider a preventive maintenance

process that includes activities such as the existing layup program, condition monitoring,

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equipment examinations, inspections, and system walkdowns with an appropriate schedule that

is commensurate with the current operating status.

EVALUATION

Subsequent to the January 26,1998, meeting, TVA submitted its revised response to URI

50-259/97-04-01, by letter dated April 3,1998. The proposed rule implementation approach

described in TVA's letter would include in the scope of the Unit 1 program those SSCs that

would be analogous to those defined in the Unit 2 and 3 programs. The performance criteria for

those newly scoped Unit 1 SSCs would be defined to be the same as those used for Units 2

and 3. As stated in TVA's letter, with Unit 1 currently shut down and defueled, and most of the

equipment in long-term layup status, they could not effectively apply the provisions of

50.65(a)(2) to Unit 1, because they could not demonstrate that the affected SSC would remain

capable of performing its intended function. All of the newly scoped Unit 1 SSCs would,

therefore, be placed in an (a)(1) status under the rule. As Etated by TVA, the performance or

condition monitoring of many of the Unit 1 SSCs would not satisfy the established program

goals, and corrective action would be required in accordance with $50.65(a)(1). TVA reiterated

that they have no established plans to restart Unit 1, and no recovery activities are currently

being conducted on the unit. Therefore, TVA's proposed approach would define the corrective

actions as those necessary before the unit could restart which would result in the newly scoped

Unit 1 SSCs remaining in an (a)(1) status for an indefinite period of time.

CONCLUSION

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