ML20197J057
| ML20197J057 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| 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) | |
See also: IR 05000259/1997004
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NUCLEAR REGULATORY COMMISSION
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June 15, 1998
MEMORANDUM TO: Frederick J. Hebdon, Chief
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Division of Reactor Projects
FROM:
Suzanne C. Black, Chie
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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
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
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
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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
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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
the rule. The NRC's letter also provided the following three attematives to the existing
condition:
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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.
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
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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
HQMB completed its review of TVA's September 29.1997, letter and forwarded the results to
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PD 11-3 by memorandum dated November 6,1997.F
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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
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in a safe condition are being maintained, as are those needed to support Units 2 and 3, which
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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
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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,
equipment examinations, inspections, and system walkdowns with an appropriate schedule that
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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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