ML20211J108
| ML20211J108 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/29/1997 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M98931, NUDOCS 9710070355 | |
| Download: ML20211J108 (10) | |
Text
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4 Ilk /l Tennessee VaHey Authority. Post Offce Box 2000, Decatur, Abams 35609-2000 September 29, 1997 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
)
Docket No. 50-259 Tennessee Valley Authority
)
BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 - RESPONSE TO NRC REQUEST REGARDING IMPLEMENTATION OF MAINTENANCE RULE, 10 CFR 50.65 (URI 50-259/97-04-01) -(TAC NO. M98931)
This letter responds to NRC's letter dated July 30, 1997, regarding implementation of the Maintenance Rule for Unit 1.
In this letter, the; staff concluded that the. scope of the Unit 1 Maintenance Rule Program is not consistent with the requirements of the rule.
The letter stated that TVA has three' apparent-alternatives:
1, Revise the scope of the Maintenance Rule monitoring program for-Unit 1 to include structures, systems-and components as specified in paragraph (b) of the rule, or 2.
Submit a written certification to-the NRC as specified in 10 CFR 50.82 (a) (1) that TVA 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 requested TVA to describe which of the three
}
-alternatives it considers to be applicable or propose another }\\
' course of action that it believes satisfies the Maintenance Rule.
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9710070355 970929 -
PDR ADOCK 050CO259 P
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S OlS.[hiuclear/RegulatoryfCommission-1:.Pqge;2' sSeptember-29. 1997f i VA" develop'ed a program for Unit lJthat was designed to comply T
with the Maintenance: Rule.=LTVA continues to believe that the program to'implementfthe. Maintenance Rule forLUnit licomplies
?with-10--CFR 50.65.
TVALused:a methodology"for"'the. Unit program.that~; varies slightly from.the methodology endorsed-by thelstaff in# Regulatory: Guide 1.160.
The regulatory guidance is:
.intendedito provide' flexibility'for7a licensee:to structure its (maintenance programiin accordance with the' safety significance
.of those structures, systems, and components within.the scope of z
,the~ rule. -Regulatory-guides'are issued to describe methods' acceptableito;the NRC staff for implementing specific' parts:of the Commission's regulations.- l Regulatory! guides > are1not-
? substitutions-for regulations and compliance withLregulatory
-guides is not required. _ TVA's. methodology 'is iappropriate given-the unique:regulstory and-operating status of-Unit 1.
- ThetEnclosure provides the basisffor TVA's position.that'the methodology.used for the. Maintenance Rule = Program.for Unit 1 is
- appropriate.and consistent
- with; the regulations.- :The Er. closure alsoLaddresses each-ofSthe three alternatives-giveni n the i
!staf f's July 30, 1997? letter.
TVA respectively requests that NRC consider the additional
~
'informationits conclusion:regarding the application:of the regarding:the: alternate:methodologyyused-by-.TVA and
? reconsider.
Maintenance Rule Program for_ Unit 1.
iTNereJare no-commitments contained in this= letter.
If you have
+ -
any questions please contact me-at (205) :729-2636.-.
.,1
-Spicerel,.
~
ff-
-T.JE..Abney Manager of ensino
- and Ind stry Affajrs
~ Enclosure
.cc:
See.page
r U.S. Nuclear Regulatory Commission Page 3..
September 29, 1997 Enclosure cc (Enclosure):
Mr. Mark S. Lesser, Branch Chief U;S. Nuclear Regulatory Commission Region.II 61 Forsyth Street, S.W.
Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
i ENCLOSURE TENNESSEE. VALLEY AUTHORITY.
BROWNS FERRY ~HUCLEAR PLANT (BFN)
UNIT 1-RESPONSE TO NRC REQUEST REGARDING IMPLEMENTATION OF THE MAINTENANCE RULE, 10 CFR 50.65 e
Background
-NRC conducted an' inspection of the implementation of the Maintenance Rule at Browns Ferry on April 14-18, 1997 The results of the inspection were documented in NRC Inspection Report' 50-259/97-04, 50-260/97-04, and 50-296/97-04, dated May 21, 1997.
The inspection report concluded that the program was 4
comprehensive and was effectively implemented.. The inspection team reviewed the actions to implement the Maintenance Rule on Unit 1 and concluded that the-actions'were technically adequate; however, the team ioentified one Unresolved Item 'URI).
The URI concerned.the application of-the Maintenance Rule for Unit 1.
.In a letter to TVA dated July 30, 1997, the staff concluded that the scope of the BFN. Maintenance Rule Program for Unit,1 is not consistent with the requirements of the rule.
This letter further stated that inDi has three apparent alternatives:
- 1. Revise the scope of the Maintenance Rule monitoring program for Unit 1 to include structures, systems and components - as specified 'in paragraph (b) of - the rule, or 2.
Submit a written certification to the NRC as specified in 10 CFR 50.82 (a) (1) that TVA 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 requested TVA to describe which of the three alternatives it considers to be applicable or propose another course of action and discuss why it considers that option to be consistent with regulatory requirements.
TVA Response TVA does not believe that the selection of any of the above-enumerated alternatives is warranted since TVA's program to implement the Maintenance Rule for Unit 1 is in compliance with 10 CFR 50.65.
u The following provides the basis for TVA's position that the Ma'intenance Rule Program for Unit 1 is in compliance with 10 CFR 50.65 and further addresses each of the three alternatives given in the staff's July 30, 1997 letter.
Unit 1 Status Browns-Ferry Units 1 and 3 were shut down by TVA in March 1985 to address questions about containment leak rate testing on Unit 1 and reactor water lovel instrumentation on Unit 3.
Unit 2 was in a refueling outage at that time.
Additional questions were subsequently raised by the NRC regarding the overall adequacy of TVA's nuclear program.
By letter dated September 17, 1985, NRC requested, pursuant to 10 CFR 50.54 (f), that TVA specify the corrective actions to be completed prior to-restart of any of its operating facilities.
This letter also confirmed TVA's verbal commitment not to restart any of TVA's operating units without prior NRC approval.
TVA responded for BFN with the Corporate Nuclear Performance Plan and the Browns Ferry Nuclear Performance Plan which addressed a number of actions to be taken to resolve management, equipment and regulatory issues prior to restart of BFN Unit 2.
Extensive recovery activities for Unit 2 were undertaken to resolve the problems identified by NRC and TVA and Unit 2 was subsequently restarted in 1991.
By letter dated July 10, 1991, TVA submitted its proposed regulatory framework for the restart of Units 1 and 3.
This letter provided the proposed scope of programs to meet regulatory requirements, implement commitments, improve technical specifications, address open corrective actions, and resolve internally identified problems prior to the restart of Units 1 and 3.
This letter also addressed differences in the proposed programs that were used for the recovery of Unit 2.
By letter to TVA, dated April 1, 1992, the staff concurred with the scope of the plans provided by TVA.
Using this regulatory framework as a basis, Unit 3 wai recovered and restarted in 1995.
Unit 1 was defueled in late 1985 and remains in a defueled condition.
The unit is on administrative hold to resolve regulatory concerns and there are currently no plans to restart it.
Unit 1 systems that perform a required function in the defueled condition or that directly support Unit 2 or Unit 3 operation are being operated and maintained under applicable technical specifications and plant programs.
The Unit 1 systems and components which are not required to be operational have typically been drained, deenergized, disassembled, and placed in dry lay-up under a formal lay-up program.
The intent of this program is to preserve TVA's investment if recovery of Unit 1 is pursued in the future.
The E-2
lay-up program is_ described in plant procedures and includes pe'riodic monitoring of equipment condition.
Plant systems included in the lay-up program include both safety-related systems and non-safety-related systems.
Where applicable, the lay-up_ program requires use of forced air drying, desiccants, nitrogen blankets, periodic motor rotations, and motor insulation 1 resistance testing to ensure that equipment is adequately presetved.
The lay-up program requires periodic visual corrosion inspections, relative humidity checks, desiccant-inspections, and oil analyses to monitor program effectiveness.
Actions are also specified (e.g., eddy current testing of heat exchangers) to assess the effectiveness of lay-up prior to return to service.
The most recent inspection of the program by the staff was documented in Inspection Report 50-259/96-12, 50-260/96-12, 50-296/96-12 dated December 20, 1996.
The staff concluded that the lay-up program and its implementation were acceptable.
One of the special programs listed in TVA's July 10, 1991 letter concerning the regulatory framework for Units 1 and 3 restart is the Restart Test Program.
This extensive test program (implemented on both Units 2 and 3) will verify that Unit.1 systems will perform their safe shutdown function.- The staff safety evaluation report for the Unit 3 Restart Test Program, dated August 30, 1994, concluded that the Unit 3 program provided I
adequate assurance that safety systems could fulfill their safe shutdown functional requirements and support the safe return to operation _of Unit 3.
For Unit 1, the Restart Test Program will likewise provide adequate assurance that Unit 1 systems are capable of performing their safe shutdown functions after the ertended outage, if recovery of Unit 1 is pursued.
TVA has not reached a decision on the long term operational status of Unit 1.
However, there are no current plans for equipment refurbishment.or recovery activities to be conducted on the unit.
TVA has previously stated that NRC will be notified of any decision to return Unit 1 to operation.
TVA has also committed to implement the same programs employed for the Unit 3 recovery. effort and not to restart Unit 1 without prior NRC approval.
I Unit 1 is in a unique regulatory position.
It is on administrative hold with extensive corrective actions, commitments, and regulatory requirements (including NRC approval of restart) to be met prior to return to service.
There has been considerable correspondence with NRC regarding Unit 1, including establishing the regulatory framework for its restart if it is ever pursued.
Based on the regulatory framework and the Unit 2 and Unit 3 precedents, there will be considerable NRC oversight of any future recovery efforts of Unit 1.
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Un;it 1 Maintenance Rule Compliance 10 CFR 50.65(b). states that the scope of the monitoring program is to include safety-related and non-safety-related structures, systems, and components (SSCs) as follows:
- 1. ' Safety-related SSCs that are relied upon to remain functional during and following design basis events to 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.
2.
Nonsafety-related SSCs:
1.
That are relied upon to mitigate accidents or transients or are used in nlant eraergency operating procedures (EOPs); or ti. Whose failure could prevent safety-related structures, systems, and components from fulfilling their safety-related function; or 111. Whose failure could cause a reactor scram or actuation of a safety-related system.
For BFN Unit 1 in its current defueled status, most of the Unit 1 SSCs are not required to perform the functions required to be monitored by 10 CFR 50.65(b) and cannot perform these functions due to the lay-up status of the unit.
This status was appropriately recognized and factored into the scoping of Unit 1 SSCs for the Maintenance Rule Program.
NRC Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" was issued to provide guidance to meet the requirements of the rule.
NRC Regulatory Guide 1.160 Revision 2, dated March 1997, endorsed NUMARC 93-01 Revision 2,
" Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants".
Regulatory Guide 1.160, Revision 2, states in Section 1.10 that licensees may use other methods to meet the requirements of the rule but NRC will determine the acceptability on a case-by-case basis.
TVA used a slightly different methodology from that described in NUMARC 93-01 to determine the scope of Unit 1 SSCs included in the program.
This methodology considered the unique status of Unit 1 and the functions required to be performed by the Unit 1 SSCs in the current status.
As part of the alternate scoping methodology, each Unit 1 SSC was evaluated for its required function for the Unit 1 defueled E4
Estatusias well astits-functions in support of Units 2 and 3.
Udit11 systems which have-a required safety-function 11n-the Ldefueled condition orfperform a function-required for Unit 2Jor-Unit 3:were scoped-intoLthe Maintenance Rule Program.
This is documented for each Unit i system in the plant Maintenance Rule implementing procedure, Technical: Instruction-346.
tsing this methodology, some Unit l' SSCs were not included in the scope that
-would otherwise have been required-if the unit was in an operational' status.. As a result, the program as.de'.ined by
-Technical Instruction-346 explicitly requires _that if the status of~ Unit 1 changes, then the' scoping must be reevaluated.
^the following Unit i systems or portions of systems were included in the scope of the program:
Raw. Cooling Water CO2 Storage, Fire _ Protection, and Purging Liquid Radwaste Control Rod Drive-480 Volt AC-Shutdown-Boards 120 Volt AC I&C Bus
'480 Volt AC RMOV Boards 250 Volt DC RMOV Boards Security (structural aspect of doors)
Fuel Pool Cooling and Cleanup Reactor and Refuel Zone Ventilation Radiation Monitoring Standby Liquid Control Residual Heat RemovalL ReactorEBuilding Closed Cooling Water The_ scoping performed for Unit 1 used an alternate methodology.
-from1that described in NUMARC 93-01 based on the unique-status of the. unit. This methodologycis fully consistent with the safety.
purpose and intent of the Maintenance Rule.- As such, monitoring of Unit 1 SSCs under'the scope of the rule has been established with recognition of the current plant status;
.This alternate methodology do6c not infer, and TVA fully
-recognizes,:that-the rule does not intend that utilities change scope based on' normal shutdowns envisioned throughout the life of the plant (e.g., refueling outages or long-term maintenance
-outages)_.
Accordingly,.the alternatefmethodology used for Unit 1 isifully appropriate given its long-term shutdown status on administrative hold, the fact-that there are currently no plans-to_ restart the unit, and the commitments and agreements previously reached with the NRC regarding Unit 1 restart as
- described above.
E-$
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.. c..i Regulatory Alternatives-Proposed By NRC
.The;applicabilityfof each of the--three alternatives proposed by
~the staff in.the July 30, 1997 letter is discussed below:
1.-
Revise the' scope.of the Maintenance Rule monitoring-program for Unit 1 to include structures, systems, and components as specified-in paragraph 00) of the rule.
As described above, all Unit 1 SSCs which perform a function specified in paragraph 03) of the rule in the current plant-status are-included in the Unit 1 Maintenance Rule monitoring program.
There are some Unit 1 SSCs which were not determined necessary to be included in the scope of the program that would be included if-the unit were operating.
The functions that these SSCs perform in the current plant status are not required as the design basis events for which they are designed to function cannot occur.
These systems are typically in lay-up and cannot perform their design function.
Therefore, performance criteria related to their design function.cannot be established and monitoring the performanc) or condition against such criteria cannot be
-done.
As a result, the purpose of the rule would not be met by including these systems into the scope of the program in-the current plant status. Therefore,-application of this alternative is unnecessary.
The current scope of systems included in the Unit 1 Maintenance Rule Program is appropriate for the current plant status.
Tnis_ fact, coupled with the requirement in the program that the scope be reevaluated if the plant
- status: changes, results-in a program that is and will-remain in full-compliance with-the rule.
2.
Submit a written certification to.the NRC-as specified in 10 CFR 50. 82 (a) (1) that TVA has determined to permanently cease BFN Unit 1 operations.
.TVA has not decided to permanently cease operations of BFN Unit 1.
- 3.
Petition the NRC for an exemption from the requirements ut the rule that are not currently _being met.
The rule does not explicitly define a methodology to
' determine the scope of the SSCs included in the Maintenance Rule Program.
As stated above, an alternate methodology to that endorsed by Regulatory Guide-1.160 was used to define the scope of Unit 1 SSCs included in the program.
The.
program requires reevaluating the scope of Unit 1 SSCs if E4
-___________---__j
l I
1 Unit:l" recovery is ever pursued so that continued compliance
.j
- with the rule-is ensured.
This alternate methodology 1
-resultsiin"a program;that meets the requirements of the~ rule 1
ifor Unit 1;given.its current status.-~The NRC has already
-determined thatithe program _for Unit 1 is technically
' adequate in-NRC-Inspection Report 50-259/97-04, 50-260/97-=
j 04, and ' 50-2 9 6/ 97-04 '.- - Therefore, an exemption to the rule is not warranted..
[TVA has considered whether.the unique' status of the unit-I warrants an exemption request to specifically address the Unit 1 SSCs that-would otherwise be required to betin,the j
scope of the rule if the unit wereioperating.
It-was a
' determined, however, that such an: approach would be inconsistent with the methodology used by TVA to' implement-
-the requirements of_the Maintenance Rule.
As discussed above, the design basis-events for which these SSCs are designed to mitigate cannot occur in the current plant status.
Therefore, there is no risk to the health and safety of_the public associated with_ excluding these SSCs from'the scope of-the monitoring. program'at this time. --This is especially true given the requirement that the scope be-i
-reevaluated if the status of Unit 1 changes. -Since it has already-been determined by the-staff that the actions taken
'by TVA are technically _ adequate,-there would be no' safety.
benefit in pursuing an exemption.
Further, the Maintenance Rule was developed and has evolved to both.a performance-
. based and risk-informed regulation,_ allowing utilities-flexibility __to utilize logical judgments in applying __
requirements in a meaningful manner commensurate with risk.
Requesting an-exemption when the intent is'both' purposefully.
and-technically _ satisfied would be afcostly and inefficient-use of.TVA-and NRC resources which could better'be applied to-safety-significant : issues.
conclusion TVA is_in compliance with-the rule for Unit 1 given its unique
-status.
'The alternate methodology to that endorsed by Regulatory Guide 1.160 used by.TVA meets the requirements of the rule for' the' current plant status. : Program controls are in place to ensuretthat the requirements of the rule will continue to.be met.
This alternate: methodology meets the purpose and intent of the:
rule:and poses no risk to the health and safety of the public.
!TVA believes that no additional actions are required on this matter.
TVA respectively requests that the-staff reconsider its conclusions on the TVA Maintenance Rule Program for Unit 1 based on-the additional'information-provided in'this Enclosure, i
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