ML20216A796
| ML20216A796 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/03/1998 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.160, RTR-REGGD-1.160 50-259-97-04, 50-259-97-4, TAC-M98931, NUDOCS 9804130294 | |
| Download: ML20216A796 (8) | |
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IM Tennessee Valley Authonty, Post once Box 2000. Decatur, Alabama 3S609-2000 April 3, 1998 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
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Docket'No. 50-259 Tennessee Valley Authority
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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. M98931)
NRC conducted an inspection of the implementation of the Maintenance Rule at BFN 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 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.
The team, however, identified or.e 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 l
concluded that the scope of the BFN Maintenance Rule program for l
Unit 1 was not consistent with the requirements of the rule.
TVA responded to the staff on September 29, 1997, providing additional information and asking the staff to reconsider its conclusion.
On January 26, 1998, TVA met with the staff to discuss TVA's position regarding this issue.
As a result of this meeting, the staff requested TVA to submit its alternate plan for the Unit 1 Maintenance Rule program.
This letter responds to the staff's request.
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l U.S. Nuclear Regulatory Commission Pa,ge 2 April 3, 1998 l
TVA continues to believe that the existing program to implement the Maintenance Rule for Unit 1 complies with 10 CFR 50.65.
TVA used a methodology for the Unit 1 program that varies only slightly from the methodology endorsed by the staff in Regulatory Guide 1.160.
TVA's methodology is appropriate given the unique regulatory and operating status of Unit 1, and it is our belief that no further actions are necessary.
However, based on the meeting on January 26, 1998, where the staff declined to approve the slight deviation from Regulatory Guide 1.160, an alternate program for Unit 1 is described in the enclosure to this letter.
This alternate program is consistent with one of the options offered by the staff in its July 30, 1997 letter to TVA.
Further, the alt - mate program complies with 10 CFR 50. 65 and regulatory guic a 3 provided by NRC as explained in the enclosure.
If the staff finds that the alternate program is acceptable, TVA will revise the Unit 1 Maintenance Rule Program within three months of receiving written notification.
There are no commitments contained in this letter.
If you have any questions, please contact me at (256) 729-2636.
Si[cerely, ney.
Manager of Licensi and Industry Af airs Enclosure cc:
See page 3 l
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U.S. Nuclear Regulatory Commission Page 3 l
. April 3, 1998 Enclosure cc (Enclosure):
Mr. A. W.
De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike l
Rockville, Maryland 20852 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II l
61 Forsyth Street, S.W.
Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road
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Athens, Alabama 35611 j
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ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN) i UNIT 1 REVISED RESPONSE TO NRC REQUEST REGARDING IMPLEMENTATION OF THE MAINTENANCE RULE, 10 CFR 50.65
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Background
l NRC conducted an inspection of the implementation of the
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Maintenance Rule at Browns Ferry on April 14-18, 1997.
The I
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 comprehensive and was effectively implemented.
The l
inspection team reviewed the actions to implement the Maintenance Rule on Unit 1 and concluded that the actions were technically adequate.
One Unresolved Item (URI) was identified from the inspection.
I 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 was not consistent with the requirements of the rule.
This letter further stated that TVA had 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
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in 10 CFR 50. 82 (a) (1) that TVA has determined to 4
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 i be applicable or propose another course of action and discuss why it considers that option to be consistent with regulatory requirements.
TVA responded to the staff on September 29, 1997, providing additional information and asking the staff to reconsider its f
conclusion.
TVA met with the staff on January 26, 1998 to discuss the issue.
In that meeting, TVA proposed to revise the i
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i scope of the Unit 1 Maintenance Rule program as proposed by the staff in its July 30, 1997 letter (Alternative 1 above).
Unit 1 Status Browns Ferry Unit 1 was shut down by TVA in March 1985.
It war defueled in late 1985 and put on administrative hold to resolve regulatory concerns.
The unit has remained in a defueled condition, and there are currently no plans for restart.
The Unit 1 systems that perform a required function in the defueled i
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 been placed in lay-up under a formal lay-up program.
For Unit 1 in its long-term defueled and administrative hold status, most of the Unit 1 systems are not required to perform the functions required to be monitored by 10 CFR 50.65(b) and cannot perform these functions due to lay-up status of the unit.
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Browns Ferry Unit 1 Alternate Program In TVA's meeting with the staff on January 26, 1998, TVA proposed to revise the scope of the Unit 1 Maintenance Rule program as proposed by the staff in its July 30, 1997 letter.
The staff's proposed Alternative 1 was to " 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."
In its January 26, 1998 meeting with the staff, TVA presented an alternate program that is consistent with the staff's Alternative 1 proposal.
NRC's letter, dated February 6, 1998, requested TVA to submit its alternate program for staff review.
TVA's alternate program to meet the scope of the Maintenance Rule j
for BFN Unit 1 structures, systems, or components (SSCs) is as i
follows:
Unit 1 SSCs that are analogous to the scoped SSCs on Units 2 and 3 will be placed within the scope of the Maintenance Rule program.
Unit 1 SSCs currently in the scope of the program (e.g.,
Unit 1 Fuel Pool Cooling, Control Rod Drive pump 1B, etc.) will retain the existing performance t
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Performance criteria for those newly scoped Unit 1 SSCs will be defined to be the same as those used for Units 2 and 3.
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With Unit 1 currently shutdown and defueled, and equipment in long-term lay-up status, applying 10 CFR
- 50. 6 5 (a) (2) to BFN Unit 1, TVA could not, at the present time, demonstrate performance "such that the SSC remains capable of performing its intended function."
All of the newly scoped Unit 1 SSCs so affected would, therefore, be placed in (a) (1) status under the rule.
10 CFR 50. 65 (a) (1) requires each holder of an operating license to " monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that such structures, systems and components as defined in paragraph (b), are capable of fulfilling their intended functions.
Such goals shall be established commensurate with safety."
The set of (a) (1) goals established for the newly scoped Unit 1 SSCs will include the successful completion of a Unit i restart test program similar in depth to those completed on Units 2 and 3, and a comparison of the Unit 1 SSCs with their analogous Unit 2 and Unit 3 SSCs when readiness for Unit 1 restart has been achieved.
If sufficient similarity exists between the Unit 1 SSCs and those on Unit 2 or Unit 3 to allow valid extrapolation of performance data, the Unit 1 SSCs will be classified according to the analogous Unit 2 or Unit 3 SSCs.
However, where no valid extrapolation of performance can be made, the Unit 1 SSCs would remain classified as (a) (1) until sufficient performance data could be obtained following Unit 1 restart.
Furthermore, 10 CFR 50. 65 (a) (1) requires thet "when the performance or condition of a structure, system or component does not meet established goals, appropriate corrective action shall be taken."
TVA has no plans to restart Unit 1 at this time, and no recovery activities are currently being conducted on the unit.
If a decision is made to return Unit 1 to operation, appropriate corrective actions for SSCs in (a) (1) status would include an extensive recovery and restart t
test program similar to that performed for BEN Units 2 l
and 3.
This program will result in the newly scoped Unit 1 SSCs remaining in (a) (1) status for an extended period of time.
Regulatory Guide 1.160 Revision 2, Section
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1.3 defines timeliness of corrective action as "to undertake and accomplish activities associated with the maintenance rule in a manner commensurate with the safety significance of the SSC and the complexity of the issue being addressed."
For Unit 1, in its current shutdown defueled condition, there is no safety impact attributable to the extended time.
Likewise, the j
complexities are readily apparent in undertaking to complete analyses, maintenance, modifications, and testing required to establish performance criteria for Unit 1 CSCs.
No efforts will be made to move the newly scoped Unit 1 SSCs out of (a) (1) status until the restart program has been completed for a given SSC.
This is consistent with the guidance of NUMARC 93-01 regarding new plants and plants shutdown for extended periods.
For plants that that have been shutdown for extended periods (i.e.,
longer than one operating cycle), NUMARC 93-01 Revision 2, Section 9.3.3 stttee that the evaluation of SSCs "should take into account existing equipment operating history to the maximum extent possible.
However, where such data is not available or is out of date, the utility should use information from sources described for new construction.'-
Unit 1 Lay-up Program The Unit 1 systems and components which are not required to be operational have been placed in lay-up under a formal lay-up program.
The lay-up program is described in plant procedures and requires periodic monitoring of equipment condition.
The program also requires periodic inspection of equipment to monitor its effectiveness.
Before Unit 1 is brought back to operation, an extensive restart test program will be implemented to ensure that the Unit 1 systems will perform their safe shutdown function.
In the January 26, 1998 meeting, the staff questioned whether the Unit 1 SSCs could be monitored by the lay-up program.
TVA does not believe that such monitoring would be appropriate or useful.
The purpose of monitoring SSCs under the Maintenance Rule is to demonstrate that the SSCs can perform their intended function.
Because the lay-up program is not designed, and does not function to demonstrate that SSCs can perform their intended function for l
lay-up of idle equipment, there is no basis for use of the lay-up j
program to meet the Maintenance Rule.
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4 Conclusion TVA continues to believe that the current Unit 1 Maintenance Rule program fully complies with 10 CFR 50.65 while taking into account the unique status of Unit 1.
However, Alternative 1 as presented in the NRC letter to TVA dated July 30, 1997, as further discussed in this enclosure, is acceptable to TVA.
The implementation of this alternative as described in TVA's alternate program for Unit 1 is in full compliance with 10 1
CFR 50.65 and guidance endorsed by NRC.
TVA will revise the Unit 1 Maintenance Rule Program as described above within three n.onths of receipt of written notification from the staff that this is acceptable.
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