ML20236U577

Responds to Ltr of 980626 Which Noted That Ucs Has Not Been Placed on Distribution for Us NRC Correspondence Relevant to Petition Filed on 980405,pursuant to 10CFR2.206,on Behalf of Ucs

ML20236U577
Person / Time
Site:	Browns Ferry
Issue date:	07/14/1998
From:	De Agazio A NRC (Affiliation Not Assigned)
To:	Lochbaum D UNION OF CONCERNED SCIENTISTS
References
2.206, NUDOCS 9807300314
Download: ML20236U577 (5)

Text

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y*f '* %k UNITED STATES y g NUCLEAR REGULATORY COMMISSION

• WASHINGTON, D.C. 20555-0001 j# Ju19.14,1998 Mr. David A. Lochbaum Union of Concerned Scientists 1616 P Street, NW, Suite 310 Washington, DC 20036-1495

SUBJECT:

PETITION OF THE UNION OF CONCERNED SCIENTISTS PURSUANT TO 10 CFR 2.206 REGARDING BROWNS FERRY NUCLEAR PLANT, UNIT NO.1

Dear Mr. Lochbaum:

I am responding to your letter of June 26,1998, in which you note that the Union of Concemed Scientists (UCS) has not been placed on distribution for U.S. Nuclear Regulatory Commission

! (NRC) correspondence relevant to the petition you filed on April 5,1998, pursuant to 10 CFR 2.206, on behalf of the UCS. NRC Management Directive 8.11, " Review Process for 10 CFR 2.206 Petitions," states-l The petition manager should ensure that the petitioner receives copies of all NRC correspondence with the licensee pertaining to the petition by placing the l petitioner on distribution for all relevant NRC correspondence to the licensee.

Additionally, the licensee should be encouraged to place the petitioner on distribution for any responses to the NRC pertaining to the petition.

The petition manager also should ensure that the petitioner is placed on i distribution for other NRC correspondence relating to th9 issues raised in the  !

l petition, including relevant generic letters or bulletins that are raised during the l pendency of tne NRC's consideration of the petition.

L On June 30,1998, John Zwolinski, Acting Director of the NRC's Division of Reactor Projects 1/11, discussed the management directive requirement with you. Your concem with regard to l distribution of relevant documents apparently is based on the number of NRC-originated documents that you have received related to the D.C. Cook facility. Because the concems raised in the UCS petition on D.C. Cook cover a broad range of safety issues, the petition

manager for D.C. Cook decided to provide you with copies of all NRC-originated documents yj i placed on dockets 50-315 and 50-316. Thus, you are receiving many documents not relevant j 1 l to the petition. However, the issues raised in the petition concoming Browns Ferry Unit 1 are /l '

relatively narrow. The petition manager for Browns Ferry has opM instead, to provide to UCS only relevant documents. The petition manager kr ikewns Ferry will rceiew the Browns Ferry, Unit 1 docket weekly to determine which NRC-originated documents are elevant and should be provided to you. The petition manager also may include documents that may not be clearly relevant to the petition but that rnay be of interest to 'UCS. 1 f ,

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• 9807300314 980714 e fDR .ADOCK 05000259 PDR i

o Mr. David A. Lochbaum July 14,1998 A review of the Browns Ferry Unit 1 docket from the date of your petition to July 6,1998, reveals only one document that is clearly related to the petition. That document (Enclosure 1) should have been provided to you earlier. Enclosures 2 through 5 may be of interest to UCS but are not clearly relevant to the petition. Please note that Enclosure 1 encourages the licensee to include UCS on any correspondence related to the petition. ,

I believe that this letter is responsive to your concerns; however, if you have further questions with regard to the distribution of Browns Ferry Unit i documents, please contact the petition i manager, Albert De Agazio, at 301-415-1443.

Sincerely,

/s/

Albert W. DeAgazio, Sr. Project Manager Project Directorate ll-3 Division of Reactor Projects - 1/ll Off(ce of Nuclear Reactor Regulation

Enclosures:

As stated DISTRIBUTION ,

. Docket File (w/ original incoming letter) SCollins/FMiraglia '

l PUBLIC (w/ incoming) BSheron BBoger WFravers JZwolinski JRoe FHebdon RZimmerman ADeAgazio (w/ incoming) RHoefling RLaskin (RSL) '

i BClayton NRR Mail Room (YT#0980146)

NOlson LPlisco, Rll DOCUMENT NAME: G:\BFN\YT980146.UCS *See Previous Concurrence T2 receive a copy of this document, indicate in the box: "c" a copy without attachment / enclosure "E" a Copy with rttachment/ enclosure "N" a No copy 0FFICE PgIl-3/PM , l PD11-3/LA l TECH ED* l I D:PDII-3 ,7 lC NAME Gpd)eAgazio/rst W BClayton A3dAi/ BCature FHebdon W DATE 07/1c/98 07/10 /98 07/08/98 07/13/98 OFFICE D:DRPE(A) // [ _ ___ l l l NAME JZwotinski /<_

DATE 07/%V98 /

OFFICIAL RECORD COPY i

. _ ._ . ._ . . _ . _ _ _ _ . _ _ _ . __ _ _ . _ _________________m.

Mr. David A. Lochbaum -2 July 14, 1998 A review of the Browns Ferry Unit 1 docket from the date of your petition to July 6,1998, reveals only one document that is clearly related to the petition. That document (Enclosure 1) should have been provided to you earlier. Enclosures 2 through 5 may be of interest to UCS but are not clearly relevant to the petition. Please note that Enclosure 1 encourages the licenaee to include UCS on any correspondence related to the petition.

I believe that this letter is responsive to your concerns; however, if you have further questions with regard to the distribution of Browns Ferry Unit i documents, please contact the petition manager, Albert De Agazio, at 301-415-1443.

Sincerely, gAlbert W. De Agazio, Sr. Project Manager i Project Directorate 11-3 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Enclosures:

As stated

Mr. David A. Lochbrum I l

l i

A review of the Browns Ferry, Unit 1 docket from the date of your petition to July 6,1998, I

( l reveals only one document that is clearly related to the petition. That document (Enclosure 1) l l

\

should have been provided to you earlier. Enclosures 2 through 5 are other documents that l \

l may be of interest to UCS, but they are not clearly relevant to the petition. Please note that l \

Enclosure 1 encourages the licensee to include you on any correspondence related to the l

l l- petition.

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l N

l believe that the above is responsive to yo\u concerns, however,if you have further questions 1

l with regard to the distribution of Browns Ferry, Unit 1 documents, you may contact the petition

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manager, Mr. Albert De Agazio at (301) 415-1443.  !

Sin rey,

/ l l

\s l

l Sam eg. Collins, Director Offi e ofNuclear Reactor Regulation .

Enclosures:

/ ^

As stated DISTRIBUTION l Docket File (w/ original incoming letter) SCollins/FMiraglia PUBLIC BSheron l .

BBoger WTravers l JZwolinski JRoe FHebdon RZimmerman )

ADeAgazio (w/ incoming) l RLaskins (RSL) l BClayton I NRR Mail Room (YT#090146)

NOlson j l LPlisco, Ril j l

I DOCUMENT NAME: G:\BFN\UCS-0626.98 l To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" a copy with attachment / enclosure "N" a No copy ,

OFFICE PDil-3/PM l PDII 3/LA l TEC3.ED , , Wl 0GC NAME ADeAgatio 8Clayton M . ( ,, _ /'s u't .Q RHoefling DAtE 07/ /98 07/ /98 07/ 7 /98 07/ /98 h'-

1

Mr. J. A. Scalice BROWNS FERRY NUCLEAR PLANT

$ Tennessee Valley Authority cc:

Senior Vice President Mr. Mark J. Burzynski, Managar Nuclear Operations .

Nuclear Licensing Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place 4X Blue Ridge 1101 Market Street - 1101 Market Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 Mr. Jack A. Bailey, Vice President Mr. Timothy E. Abney, Manager Engineering & Technical Services Licensing and industry Affairs Tennessee Valley Authority Browns Ferry Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Decatur, AL 35609

- Mr. C. M. Crane, Site Vice President Regional Administrator, Region II

- Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority. 61 Forsyth Street, SW., Suite 23T85 P.O. Box 2000 , Atlanta, GA 30303-3415

' Decatur, AL 35609 Mr. Leonard D. Wert General Counsel ..

Senior Resident inspector

. Tennessee Valley Authority U.S. Nuclear Regulatory Commission I ET 10H . ' Browns Ferry Nuclear Plant j 400 West Summit Hill Drive . 10833 Shaw Road 1 Knoxville, TN 37902 = . Athens, AL 35611 Mr. Raul R. Baron, General Manager, State Health Officer Nuclear Assurance Alabama Dept. of Public Health Tennessee Valley Authority 434 Monros Street SM Lookout Place Montgomery, AL 36130-1701 1101 Market Street Chattanooga, TN 37402-2801 Chairman Limestone County Commission Mr. Karl W. Singer, Plant Manager 310 West Washington Street Browns Feny Nuclear Plant Athens, AL 35611 f Tennessee Valley Authority  ;

P.O. Box 2000

. Decatur, AL 35609 -

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. Mr. O. J. Zaringu3 May 12, 1998 Chief Nuclerr Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

UNION OF CONCERNED SCIENT* CTS F ETITION PURSUANT TO 10 CFR 2.206 (TAC MA1434)

Dear Mr. Zeringue:

The Nuclear Regulatory Commission (NRC) has received a request (Enclosure 1) from the Union of concemed Scientists that the Browns Feny Nuclear Plant, Unit 1 operating license be revoked, and that the NRC require the Tennessee Valley Authority (TVA) to submit either a decommissioning plan or lay-up plan for the unit. The Director of the Office of Nuclear Reactor Regulation has acknowledged receipt of the request (Enclosure 2) and that action on the request will be taken pursuant to 10 CFR 2.206 of the NRC's regulations. Additionally, the NRC has l published a notice (Enclosure 3) in the Federal Register regarding the petition.

l The NRC will provide copies to the petitioner of all NRC correspondence, Generic Letters, and y Bulletins relevant to the issues raised in the petition (except documentation related to l Investigations by the Office of Investigation) from the date of the petition until a Director's l Decision is issued. TVA is encouraged to place the petitioner on distribution for any correspondence pertaining to the petition.

( Sincerely,

,_ (Original Signed By) l- Albert W. De Agazio, Sr. Project Manager

Project Directorate ll-3

! Division of Reactor Projects - t/ll l

Office of Nuclear Reactor Regulation Docket No. 50-259 Serial No. BFN-98-010

Enclosures:

1. Petition l 2. Acknowledgment letter to Petitioner j 3. Federal Register notice cc w/ enclosures:

See next page l DISTRIBUTION.

Docket File PUBLIC JZwolinski BFN r/f FHebdon i

BClayton VADeA0azW-OGC ACRS LPlisco,m vRil qegrWGhOIN 4 s, -gws;;fv~ n ~~

OFFICE PDil-3/PM O PDil-3/LA PDll-M[ A NAME ADEAGAZIO:cw BCLAYIN FHEEb5Nb l DATE d / // /98 [/ II /98 h/k8 '

OFFICIAL RECORD COPY_ _ _ __ __ _

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+0082023320905 UCS DC 073 P02/13 APR 96 '98 10:50

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i UNION OF CONCERNED SCIENTISTS April 5,1998 Mr. L. Joseph Callan

)

Executive Director for Operations i

United States Nuclear Regulatory Commission Washmaton, DC20555 0001

SUBJECT:

PETITION PURSUANT TO 10 CFR 2.206, BROWNS FERRY NUCLEAR PLANT UNIT 1. DOCKET NO. 50-259 i i I

i Dent Mr. Callan:

The Umon of Concemed Scientists submits this petition pursuant to 10 CFR 2.206 sequesting that t l

operating beente for Tennes>ce Valley Authority's Browns Ferry Nuclear Plant Unit 1 be revoked.

I

! Background i

The NRC issued TVA a full power operating license for Browns Ferry Unit 1 on December 20,1973.

TVA declared Unit I to be in. commercial operation m August 1974.

i Browns Feny Units 1 and 3 were shut down m March 1985 after "TVA identified a failure at BFN to consistently mamtain a documented design basis and to control the plant's configuration in accordance l with that basis."' Umt 2, which had been shut down in September 1984 for a scheduled rsfueling outa L

' remamed shut down because of the same programmatic deficiencies that affected Umts 1 and 3. After extensive upgrades to the plant's equipment, procedures, and organizational stnacture, Unit 2 retumed to service in May 1991. Umt 3 subsequently resumed operation in early 1996.

l l

' !.ettet from O. L 2ermgue, Senior Vice President - Nuclear Operations, Tennessee Valley Autho States Nuclear Xcguistory Commission. "Responw to Requent for Infannation Regarding Adequacy. Ava!1 abili and Control of Design Bases Infonnation,' February 12.1997.

Washington Office 1616 P Street NW Sune 310 e Washington DC 200361495 e 202432 0000 o FAX: 202 3324905 Cambrd0e Meacowagers. Two 9 tattle Souare e Cambr494 MA 02238 910$ e 617447 8552 e FAX. 4174644405 CaMorne Office. 2397 $nattuch Avenue Suite 203 e perheter CA 9470415$7 e $104431472 e FAX 610443 3785 ENCLOSURE 1

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+0012023320905 UCS DC 073 P03/13 APR 86 '98 10:50 t

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Apnl 5,1998 Page 2 of 5 i-On June 1.1985, TVA placed Unit I on administrative hold so as to be able to focus resources

! efforts necessary to restart Units 2 and 3. Unit I remains on administrative hold. According ataff, there are no plans to restan the umt.'

i Basis fur Requested Action UCS ts a non. profit, public. interest organization with sponsors across the United States territories semced by TVA.

TVA has an operating license for Unit 1, but the facility has not been operated since March 1985' a been on admimstrative hold since June 1.1985. The NRC has issued approximately 39 bulletins, generic letters, and 1,047 information notices to its licensees while Unit I has been on administrative hold. While some of these 1,228 NRC documents do not apply to Browns Ferry Unit 1, the m  ;

them do. TVA's typical response to these document has been as follows:

"BFN Umt 1 is shutdoms, defuc!cd, and under admmistrative hold. The conditions described b this GL will be addressed prior to its return to service '#

On October 9,1996, the NRC asked TVA to provide a response regarding the adequacy, availabilit  ;

control of design basis mformation for all th ce Browns Ferry units This NRC request, prompted b '

three umt shut down at Millstone in March 1996, went to the very core of the problems that forced the three unit shut down at Browns Ferry beginning in March 1985. TVA's response described several improvement programs, including a comprehensive design basis verification program (DBVP) for Units 2 and 3. TVA's response included the fo!!owing statement, in a foomote, covering Unit 1:

"In accordance with TVA's prior commitments, TVA will implement the DBVP on Unit I prior i to its return to servsee."' '

Due to design similarities, the work required for the restart and sustained operation of Units 2 and 3 will have collateral benefit for Unit 1 if and when TVA pursues restarting it. However, due to design differences. substantial work in the configuration management area is still required before Unit I could resume operstmg

' Lener from Albert W. DeAgazio, Senior Project Mar,ager, Nuclear Regulatory Commission, to Da Lochbaum. Union of Concemed Scienusts. January 20,1994.

i

• I.ener from T. !!. Abney, Manager of Licensing and Industry Affairs. Tentwssee Valley Autho Nuclear Regulatory Commissioe.," Browns Ferry Nuclear Plant (BFN)- Revision 1, Response to NRC Genene Letter (GL) 96 06. Assurance of Equipment Operability and Containment Integnty During Design liasis Accident Conditions." October 23,1997.

{

• Letter from O J. 2eringue, Senior Vice President . Nuclear Operations, Tennessee Valley Auth States Nuclear Regulatory Commission," Response to Request for Information Regarding Adequacy, Availab and Control of Design Bases 1nformation," February 12,1997.

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April 5,1998 l

Page 3 of$

Unit I was shut down due to configuration management problems, problems which can only have deepened after 12 years on "admimstrative hold."In addition, the plant's material condition is, at best, j

equal to that which contributed to it being shut down in 1985 and is, more likely, deteriorated from that I deficient state.

Browns Feny Umt I has been on " administrative hold" longer than it operated. No US commercial nuclear power plant has ever retumed to service aner an outage lasting over 12 years.

While there are no precedents for restarting Browns Ferry Unit I after such a lengthy outage, there are ,

precedents ifit does not restart. The first of the three nuclear units constructed at indian Point. Dresden, .- '

and San Onofre were all permanently shut down by their owners. The remaining two units at each of these sites are still operational. The permanently closed units at these sites are covered by decommissiomng plans. These plans provide reasonable assurance that the irradiated fuel at the permanently closed units is safely stored and that the operating plants are suf6ciently independent from the closed facility.

IfTVA elects not to restart Unit 1 at Browns Ferry, then like Dresden, San Onofre, and Indian Point, it should arguably be made subject to federal regulations designed to provide assurance that irradiated fuel is safely stored and that operstmg umts are mdependent from the closed unit. Revokmg its operating license would imtiate the sequence of actions necessary to follow the Indian Point, Dresden, and San Onofre precedents. Thus, granting this petition would move Brovms Ferry Unit I out of" administrative hold," a non defined regulatory state, into a condition govemed by applicab!c regulations.

Even if TVA elects to restart Unit 1, revokmg its operating license now should actually facilitate the restart proceu or at least make this process safer. The NRC's current administrative process for restartmg problems plants, controlled by Inspection Manual Chapter 0350, could be twisted to fit a plant closed for over a decade, but a heense application process would be a much better, and safer, avenue.

Thus, grantmg UCS's petition would essentially wipe the licensing siste clean and allow TVA, the NRC, and the pubbe to examine restarting the plant without the burden of unraveling the mess caused by more than a decade of heensing hmbo.

De>pite Browns Feny Unit.1 bems on " administrative hold,"it "is inspected by NRC inspectors as is any other operating nuclear power station."'ISee Attachment I for a copy of the NRC letter to UCS describing how Browns Ferry Unit 1 is inspected by the NRC.J TVA has not restored the unit's design and beensms bases, the extensive configuration management problems which forced the plant to be shut down. TVA ts not taking actions required by the NRC for Unit I while it is on " administrative hold."In other words.TVA's configuration management for Browns Feny, inadequate to support plant operation m March 1985, has been degraded by subsequent neglect.

8 Lener from Alben W. DeAgazio, Sernor Project Manager, Nuclest Regulatory Commission, to David A.

oehbaum, Union of Concerned Scientists, January 20,1998.

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April 5,1998 Page 4 of5 l

i It is not clear what criteria the NRC inspectors are using when they inspect a facility that has frozen in time more than a decade ago in a degraded condition. For example, it would seem for the NRC to heve meaningfully inspected Unit l's Generic Letter 8910 Motor. Operated Valve (MOV) program as it has done for operating plants. He NRC should not be wasting its inspectioj i on a facility in an uncenain licensing condition. Denying this petition would sustain ineffective oversight.

Denying this petition could have far more serious consequences if TVA ever seeks to restan Brow Ferry Umt 1. Presently, restarting t.he plant would require. evaluating its material condition

/ and admimstrative programs against a complicated, confusing patchwork of applicable regulati three decades. nis time. consuming effort is extremely vulnerable to mistakes. Commitme overlooked and design bases requirements might be changed without NRC approval. Considerable e would still be required to restart Unit I if this petition is granted, but that effort would be properly focused on determinmg if the applicabic regulations were satisfied. Otherwisc, much of the effon w unnecessarily diverted to determining which regulations are applicable. Smcc both approaches r intensive effon, it is prudent to chose the option that yields greater assurance of safety. The approach for restaning Unit I would be for TVA to seek a new license rather than attempt to resurrect old,long. disused beense.

It is not clear that the NRC's reassurms words about Browns Ferry Unit I being inspected like any o operating plant are consistent with their actions. UCS recently obtained a copy of the NRC's resp a Freedom ofInformation Act request (No. 98101). Part of that response listed the NRC mspection hours for each plant in 1995 1997. lSee Attachment 2 for portions of this FOIA response.] The data clearly shows that there are zero (0) inspection hours indicated for Browns Ferry Unit 1. In fact, the Bronts Ferry site is designated by the NRC as a " Dual Unit Site"and inspection hours are provided for Umts 2 and 3. Hus, it appears to UCS that the NRC is already treating Browns Ferry as if Unit I were not an operating reactor.

e

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April 5,1998

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Requested Actions l

UCS petitions the NRC to revoke the opersting license for Browns Ferry Unit 1. Additionally, petitions the NRC to require TVA to submit either a decommissioning plan or a 1sy up plan for Un The NRC should conduct its inspections at Browns Ferry Uni I against the decommissioning plan lay-up plan submitted by TVA. The NRC should stop conducting inspections on Unit I as it does for l- operating plants.

UCS respectfullyt ici ue'sts a hearing iss this petition to present'new infonnation on Browns Ferry This new information will include, but is not limited to, a discussion of the voluminous licensing b reconstitution that would be required to support restan and a presentation on the potential for TVA

! wanting to keep Unit 1 on " administrative huld" to prevent exceeding its statutory debt ceilms. UCS i would prefer that this hearing be held m the DC area with at least 30 days notice.

Sincerely. .

$ \

i H2aiud-I David A. Loc baum i

l Nuc! car Safety Engineer attachments: as stated l

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! l 40012033320905 UCS DC

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• UNITED STATES

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• NUCLEAR REGULATORY COMMISSION wasmmerow, s.c. sense. coot

% ,,,,. , January,20, 1998 1

i Mr. David A. Lochbaum Union of Concerned Scientists 1616 P Street. NW., Suite 310 Washington, DC 20036-1495

Dear Mr. Lochbaum:

l .. 1 l ^

This is in response to your January 14,'1998. r E mail que'y sont t'o the'U.S. Nuclea

~

l Commission (NMC) OMice of Public Affairs. You asked if the fees charged to the Tennessee Valley Authority (TVA) for Browns Feny Unit 1 are discounted in some manner because the unit is on administrative hold. )'

Browns Ferry Unit 1 has been shutdown since March 1985 and has been in a defueled condition since late 1985. The unit is on administrative hold pending resolution of regula concerns. and there are no plans currently to restart the unit.

l The Unit 1 Technical Specifications are maintained and they are amended periodical

( with those of the other units. Many of the Unit 1 systems and components are in layup sta protect and preserve the equipment in the event a decision is made to restart the unit, and cerisin other systems are required to support the unit in the defueled condition and the -

continued operation of Units 2 and 3. The unit is inspected by NRC insoectors as is any other operating nuclear oower station The administrative held notwithstanding, TVA is the holder of an operating license for Browns Ferry Unit 1, as defined in Part 171 of Title 10 of the Code ofFeders/ Regulations (10 CFR 171.5) Furthermore, the exemption provisions of 10 CFR 170.11 and 10 CFR 171.11 do not apply. Thus, TVA'is fully subject to all applicable fees as specified in 10 CFR Parts 170 and 171 for Browns Ferry Unit 1, and the fee schedules and annualfees specified in the regulat are not discounted in any manner because of the current operational status of the facility.

Sincerely,

~

Albert W. De Agarlo. Senior PrkeerManag6r ProJoct Directorate 113 Division of Reactor Projects t/Il Office of Nuclear Reactor Regulation 4

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TOTAL INSPECTION EFFORT FOR SDiGLE UNIT M0 SITES Baswus flerry FY 1997 *'

PLANT TOTAL JIOUR5 ~

BIG ROCK POINT 3,475.6 WOLF CREEE 1 3,964.9 OYS1TR CREEK 4,131.3 EADDAM NECK 4,388.8 SUMMER 4,436.7 DUANE ARNOLD MEDIAN HOURS = 4,436.7 4.471.0 MEAN HOURS = 4,275.2 MONTINTO 4,483.5 -

MILLSTONE 1 4,553.0 MILLSTONE 2 -

4,871.7

~

FITZPATRICE 4,594.7 KEWAUNEE 4,673J PALISADES 4,705.0 GRAND GULF 1 4,743.4 RIVER BEND 4,757.1 HOPE CREEK 1 MEDIAN HOURS = 4,757.1 4,766.4 GINNA MEAN HOURS = 4,780.3 4,797.9 DAV5BESSE 4,812.6 SEABROOK1 5,162.4 TMFR MILE ISLAND 1 5,200.1 ROBINSON 2 5,202.4 MAINE YANEEE 5,213.6 CALLAWAY 5,399.1 HARRIS 1 5.472J PILGRIM 1 MEDIAN HOURS = 5,4723 5,605.0 WATTS RAR 1 MEAN HOURS = 5,480./

5,667.2 FORT CALHOUN 1 5,712.0 PERRY 1 5,936J

' VEtMONT YANEEE 6.227.3 COOPER 6,707.3 WATERFORD3 6,967.7 INDIAN POINT 2 7,181.1 INDIAN PODIT3 7,293J

. MILIJTONE 3 MEDIAN HOUR 8 = 7,300.1 7.306.6 MEAN HOUR $ = 7,717.9 FERMI 2 7,475.0

• WNP2 7,529.8 CRYSTAL RIVER 3 8,lS3.3 CLINTON 11,0 7.0 Sawan: ATTE DATA Bad at FF kppt Finc =sl>lf 98 Marst ti!998(450fpas) J, ll

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• TOTAL INSPECTION EF70RT FOR DUAL INIT SITE 8 FY 1997 M SRsms FetitY l ,

TOTAL

_ PLANT Hofms j

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BROWNS FERR[U't 1 nURTH ANNA 1,2 4,234J ~j 4.233.2 .

• LIMERICE 1,2 4,252.6 CALVERT CLIFFS 1.2 4,622,0 ~

• TUREEY PODfr2,4 4,641.4 MEDIAN = 4,02.1

. PEACE BOTIOM 2,2 4,655.1 MEAN = 4,652.9 BYRON 1,1 -

5,140J '

• COMANCHE PEAK 1,2 5,442.7 PRAIRIE ISLAND 1,2 S,475.5 VOG172 1,2 5,546.7 I SUSQUEHANNA 1,2 ...

5,663.5 LA SALLE 1,2 5,701J MEDIAN = 5,705.2 e B E A V E R V A L L E Y 1 ,2 5,708.2 ~

MEAN = 8,771.7 DIABLO CANYON 1,2 S,930.2 5 U R R Y 1 ,2 6,027.1 SOUTH TEXAS 1,2 g

6,168J "

QUAD CITIES 1,2 6,346.9 I FARLEY1,2 CATAWBA 1,2 AREANSA$ 1,2 6,313J 6,474.7 6,684.1 fij EATCE 1,2 6,766.7 MEDIAN = d,725.4 SAN ONOFRE 2,2 6,9874 MEAN = 6,734.0 BRUNSWICE 1,2 7,004.6 BRAIDWOOD 1,2 7,193J .

McGUUtE1.2 '7,209J ~

ST. LUCIE 1.2 7,521,7 SEQUOYAH 1,2 8,033J  ;

COOK 1,2 s,09sJ NINE MILE POINT 1,2 8,383.2 MEDIAN = 8,3833 230N1,2 9.427J MEAN = 9,849.7

. Po!NT BEACH 1,2 10,537.9 DRESDEN2,3 11.413J '

SALEM 1,2 18.025.9 .

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. w-Qu.ca h J Fo t A 4%-101 TOTAL INSPECTION EFFORT FOR TRIPLE UNIT SITES ry appy N o B ft.osiJN P TOTAL FLAMF .

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j Je UNITED STATES

} NUCLEAR REGULATORY COMMISSION f WASHINGTON, D.C. 3088H001 o, Q C M /

....., April 29, 1998 Mr. David A. Lochbaum Union of Concemed Scientists -

1616 P Street, NW, Suite 310 Washington, DC 200361495

Dear Mr. Lochbaum:

This letter is to acknowledge receipt of a petition dated April 5,1998, submitted by you on behalf of the Union of Concemed Scientists (UCS). The petition was addressed to the Executive -

Director for Operations of the U.S. Nuclear Regulatory Commission (NRC). The petition requests l l

(1) that the Operating License for Browns Ferry, Unit 1 be revoked and (2) that the NRC should require the Tennessee Valley Authority (TVA) to submit either a decommissioning plan or a lay-up plan for Browns Ferry, Unit 1. As the basis for the UCS request, the petition asserts that because Browns Ferry Unit i has been on " administrative hold" since June 1,1995, and has not operated since then, revocation of the operating license and requiring relicensing, if TVA later decides to restart Unit 1, is a better, safer process than is the current inspection Manual Chapter 0350 restart process. Further, the petition asserts that requiring a decommissioning plan would provide assurance that the irradiated fuelis stored safely and that Units 2 and 3 are sufficiently independent of Unit 1 for safe operation.

The petition has been referred to me pursuant to 10 CFR 2.206 of the Commission's regulations.

As provided by Section 2.206, action will be taken on the request within a reasonable time.

In the UCS petition, you requested a hearing to present new information on Browns Ferry, Unit 1 that would include a discussion of the licensing basis reconstitution that would be required to support restart, and certain financial aspects that might be a consideration for the TVA's decision for retaining the Browns Ferry, Unit 1 Operating License. NRC policy, as defined in Management Directive 8.11. " Review Process for 10 CFR 2.206 Petitions,"is to hold an informal public hearing if the 2.206 Petition meets either of the following criteria:

a The petition provides new information with reasonable su'pporting facts that raise the potential for a significant safety issue.

• The petition alleges violations of NRC requirements involving a significant safety issue for which new information or a new approach has been provided and presents reasonable supporting facts that tend to establish that the violation occurred.

The petition does not provide new information that raises the potential for a significant safety issue. According to the guidance in Management Directive 8.11, a significant safety issue would be one that could lead to an occupational exposure dose equivalent exceeding 10 rom, could cause significant core damage, or could otherwise significant reduce the protection of public health and safety. Furthermore, the Petition does not allege any violations of NRC requirements.

Therefore, the NRC does not intend to hold an informal hearing regarding the UCS Petition.

With regard to any new information that you believe should be considered by my staffin evaluating the issues in the UCS petition, please provide that information promptly in writing to Mr. Frederick J. Hebdon, U.S. NRC, PDil 3, M/S 014B21, Washington, DC 20555.

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e D. Lochbaum Apri1 29, 1998 I have enclosed for your information a copy of the notice that is being filed with the Office of the Federal Register for publication. I have also enclosed a pamphlet on the public petition process.

l Sincerely, r

S or ffice of Nuclear Reactor Regulation

Enclosures:

1. Feders/RegisterNotice 1

2. Petition Process Pamphlet cc: See next page w/o Enclosure 2 l

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. 7590 01P U S NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-259 '

LICEN'sE NO. OPR-33 TENNESSEE VALLFY AUTHORITY j

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BEC.EIPT OF PETITION FOR ' DIRECTOR'S DECISION UNDER 10 CFR 2 206 Notice is hereby given that by petition dated April 5,1998, the Union of Concemed Scientists, (or Petitioner), has requested that the U.S. Nuclear Regulatory Commission (NRC) 4 take action with regard to Browns Ferry Nuclear Plant, Unit No.1. Pet'tioner requests (1) that the j

operating license for Browns Ferry Unit 1 be revoked and (2) that the NRC require the Tennessee Valley Authority (TVA) to submit either a decommissioning plan or a lay-up plan for  ;

Browns Ferry Unit 1. Petitioner further requests a hearing on this paillion to present new information on Browns Feny Unit 1 that would v.-lude a discussion of the licensing basis reconstitution that would be required to support restart, and certain financial aspects that might

, be a consideration for the TVA's decision for retaining the Browns Feny Unit 1 operating license.

As the basis for this request, the Petitie.ier asserts that revocation of the operating license and requiring relicensing if TVA later decides to restar1 Unit 11s a better, safer process than is the current inspection Manual Chapter 0350 restart process. Further, ?,he petition asserts ,

that requiring a decommissioning plan would provide assurance that the Irradiated fuelis stored

! safely and that Units 2 and 3 are sufficiently independent of Unit 1 for safe operation.

The petition is being treated pursuant to 10 CFR 2.206 of the Commission's regulations snd has been referred to the Director of the Office of Nuclear Reactor Regulation. As provLtsd 1

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by Section 2.206, appropriate action will be taken on this petition within a reasonable time.

Byletterdated April 29, 1998 , the Director acknowledged receipt of the petition and denied Petitioners request for a public hearing to present new information.

A copy of the petition is available for inspection at the Commission's Public Document Room at 2120 L Street, NW., Washington D.C. 20555.

FOR THE NUCLEAR REGULATORY COMMISSION or Office of Nuclear Reactor Regulation l Dated at Rockville, Maryttnd, This 29th dayof April 1998.

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Mr. O. J. Zaringua May 14, 1998 Acting Chief Nuclear Officer r i and Executive Vice President j Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 96 06, ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENTS (TAC NOS. M96784, M96785, AND M96786)

Dear Mr. Zeringue:

Generic Letter 96-06, " Assurance of Equipment Operability and Containment integrity During Design-Basis Accident Conditions," dated September 30,1996, included a request for licensees to evaluate cooling water systems that serve containment air coolers to assure that they are not vulnerable to water hammer and two-phase flow conditions. Tennessee Valley Authority l provided its assessment for Browns Ferry, Unit Nos.1,2 and 3, in letters dated January 28, and October 23,1997, For the staff to complete its review of TVA's resolution of the water hammer and two-phase flow issues, additional information, as discussed in the attachment, is required.

Please provide your response no later than June 30,1998.

Sincerely, (Original Signed By) l' '

Albert W. De Agazio, Sr, Project Manager Project Directorate 11-3 Division of Reactor Projects - 1/ll

C#ce of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296 l

Serial No. BFN-98-009

Enclosure:

Request for Additional Information l cc w/ encl: See next page i

DISTRIBUTION-Docket File J. Zwolinski(A) k:::De Agazio - L Plisco, Region il PUBLIC F. Hebdon OGC J. Tatum BFN R/F B. Clayton ACRS M. Hart To receive a copy of this document, indicate in the box: "C" = Copy without attachment /encicsure "E" = Copy with.

. cttachment/ enclosure "bl" = No copy 0FFICE PM:PDil 3 /jl(// I E LAtPDII 3 l OtPDIIT ) M _ l l ,

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NAME ADeAsario\Me acteyton ' A4v ruebdonc V /

DATE 05// p/98 05/l6l/98 M/ll/ /98 05/ 90 05/ /98 Official Record Copy DO'CUMENT NAME: G:\BFNi96 06RAl.WPD

, Enclosure 2

1 Mr. O. J. Zeringue BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority cc:

1 Mr. J. A. Scalice, Senior Vice President Mr. Mark J. Burrynski, Managar

! Nuclear Operations ,

Nuclear Licensing Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place 4J Blue Ridge 1101 Market Street 1101 Market Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 Mr. Jack A. Bailey, Vice President Mr. Timothy E. Abney, Manager Engineering & Technical Services Ucensing and Industry Affairs Tennessee Valley Authority Browns Feny Nuclear Plant 6A Lookout Place Tennessee Valley Authority l 1101 Market Street P.O. Box 2006 l Chattanooga, TN 37402-2801 Decatur, AL 37402 2801 Mr. C. M. Crane, Site Vice President Regional Administrator, Region il Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority 61 Forsyth Street, SW., Suite 23T85 l P.O. Box 2000 Atlants, GA 30303-3415 Decatur, AL 3560g l . Mr. Leonard D. Wert General Counsel Senior Resident inspectot Tennessee Valley Authority U.S. Nuclear Regulatory Commission l

ET 10H Browns Ferry Nuclear Plant 400 West Summit Hill Drive 10833 Shaw Road Knoxville,TN 37g02 Athens, AL 35611 Mr. Raul R. Baron, General Manager State Health Officer Nuclear Assurance Alabama Dept. of Public Health Tennessee Valley Authority 434 Nionroe Street 4J Blue Ridge Montgomery, AL 35130-1701 1101 Market Street

! ' Chattanooga, TN 37402-2801 Chairman Limestone County Commission

Mr. Karl W. Singer, Plant Manager 310 West Washington Street

! Browns Ferry Nuclear Plant Athens, AL 35611

( Tennessee Valley Authority l l P.O. Box 2000 l Decatur, AL 3560g ,

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REQUEST FOR ADDITIONAL INFORMATION FOR RESOLUTION OF GENERIC LETTER 96-06 ISSUES AT BROWNS FERRY UNIT NOS.1,2, AND 3 (TAC NOS. M96784, M96785, AND M96786)

1. If a methodology other than that discussed in NUREG/CR-5220, " Diagnosis of Condensation Induced Water hammer," was used in evaluating the effects of water hammer, describe this sitemate methodology in detail. Explain why this methodology is applicable and gives conservative results for the Browns Ferry units. Typically, this is accomplished through rigorous plant-specific modeling, testing, and analysis.

2. For both the water hammer and two-phase flow analyses, provide the following l information:

a. Identify any computer codes that were used in the water hammer and two-phase

! flow analyses and describe the methods used to bench mark the codes for the

! specific loading conditions involved (see Standard Review Plan Section 3.9.1).

i

! b. Describe and justify all assumptions and input parameters (including those used in any computer codes) such as amplifications due to fluid-structure interaction, l cushioning, speed of sound, force reductions, and mesh sizes. Explain why the l values selected give conservative results. Provide justification for omitting any l

effects that may be relevant to the analysis, e.g., flu!d structure interaction, flow j induced vibration, erosion.

c. Provide a detailed description of the " worst case" scenarios for water hammer and I

two-phase flow (should be bounding for all three units), taking into consideration the complete range of event possibilities, system configurations, and parameters. For example, all water hammer types and water slug scenarios should be considered, as well as temperatures, pressures, flow rates, load combinations, and potential component failures. Additional examples include:

the effects of void fraction on flow balanca and heat transfer; 1

j

• the consequences of steam formation, transport, and accumulation;

• cavitation, resonance, and fatigue effects; and

• erosion considerations.

Licensees may find NUREG/CR-6031, "Cavitatiort Guide for Centrol Valves," helpful in addressing some aspects of the two-phase flow analyses.

d. Confirm that the analyses included a complete failure modes and effects analysis (FMEA) for all components (including electrical and pneumatic failures) that could i

impact performance of the cooling water system and confirm that the FMEA is documented and available for review, or explain why a complete and fully documented FMEA was not performed.

l ENCLOSURE l

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e. Explain and justify all uses of " engineering Judgment."

3. Determine the uncertainty in the water hammer and two phase flow analyses. Explain how the uncertainty was determined, and how it was accounted for in the analyses to assure conservative results for the Browns Feny units.

4. Confirm that the water hammer and two-phase flow loading conditions do not exceed any design specifications or recommended service conditions for the piping system and components, including those stated by equipment vendors. Confirm that the system will

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remain intact during all event scenarios.' '-

5. Provide a simplified diagram of the system, showing major components, active components, relative elevations, lengths of piping runs, and the location of any orifices and flow restrictions.

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May 21. 1998 1

Tennessee Valley Authority ATTN: Mr. J. A. Scalice. Acting Chief Nuclear Officer Executive Vice President 6A Lookout Place 1101 Market Street Chattanooga. TN 37402-2801

\

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) BROWNS FERRY NUCLEAR PLANT (REPORT NOS. 50-259/98-99. 50-260/98-99 AND 50-296/98-99)

Dear Mr. Scalice:

The NRC Systematic Assessment of Licensee Performance (SALP) has been completed for your Browns Ferry facility. The facility was evaluated for the period of September 8.1996, through April 18, 1998. The results of the evaluation are documented in the enclosed SALP Report. This report will be discussed with you F s public meeting to be held at the Browns Ferry site at 12:00 p.m. On June 11. 1998.

The SALP process assesses licensee performance in four functional areas: l Plant Operations. Maintenance. Engineering and Plant Support. Performance in ,

the Plant Operations and Plant Support areas remained superior. Performance j in the Maintenance area improved to superior due to improvements noted in  !

equipment performance and safety system reliability. Engineering performance  !

remained at a good level. Attention to complete and thorough analyses in

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engineering products remains a challenge. 1 Assessments of performance continued to be effective in the identification of problems. The scope of the engineering self-assessment program was limited and the evaluation of identified problems was sometimes untimely and incomplete in the engineering area.

In.accordance with Section 2.790 of the NRC's " Rules of Practice." a copy of this letter and its enclosure will be placed in the NRC Public Document Ream.

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TVA 2 l Should you have any questions or comments, I would be pleased to discuss i them with you. I look forward to discussing this assessment with you on l June 11, 1998.

l Sincerely.

l (Original signed by Luis A. Reyes) l Luis A. Reyes l Regional Administrator Docket Nos: 50-259. 50-260 and 50-296-License Nos: DPR-33. DPR-52 and DDR-68

Enclosure:

Browns Ferry SALP Report -

cc w/ encl.

Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanoog6. TN 37402-2801 Jack A. Bailey, Vice President Engineering and Technical Services j Tennessee Valley Authority

- 3B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 C. M. Crane Site Vice President Browns Ferry Nuclear Plant

- Tennessee Valley Authority P. O. Box 2000 Decatur, AL 35602 cc w/ enc 1 continued: See page 3 o

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L________.________.__ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT BROWNS FERRY NUCLEAR PLANT l

l 50 259/98 99. 50 260/98 99 AND 50 296/98 99 '

I. BACKGROUND The SALP Board convened on April 30. 1998, to assess the nuclear safety performance of the Browns Ferry Nuclear Plant for the period September 8. 1996, through April 18. 1998. The Board was conducted in accordance with Management Directive 8.6. "Sys.tematic Assessment of Licensee Performance." Board members were B. S. Hallett (Board Chairperson) Deputy Director. Division of Reactor Safety: L. R. Plisco.

Director. Division of Reactor Projects; and F. J. Hebdon. Director.

Project Directorate 11-3. Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by the Regional Administrator.

II. PLANT OPERATIONS This functional area assesses the control and execution of activities .

directly related to operating the facility. It includes activities such I as plaat startup power operation, plant shutdown. and response to transients. It also includes initial and requalification training programs for licensed operators.

Overall performance in the Plant Operations area was superior during this assessment period. Management involvement in all aspects of plant operations was evident. Management and staff have carried out many initiatives to further strengthen the performance of day-to-day i operations. Decisions on safety significant issues were conservative.

However, there were some instances whese operations persontial did r aggressively pursue equipment operability determinations.

Control room operators continued to control and execute operations activities in a professional manner. The operators responded to 1 equipment problems and plant transients promptly and effectively.

Operational decisions were conservative and focused on safety. Major planned maintenance, testing, and modification activities were well planned and implemented.

Management has been responsive to the concern regarding operator inattention-to-detail observed during the previous assessment period.

Although improvements were noted, inattention-to-detail during routine Enclosure

_9a06100220~9eos21 PDR ADOCK 05000259 -

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. task performance..especially.by auxiliary unit operators, continued during this assessment period.

The Nuclear Safety Review Board and Plant Operations Review Committee provided effective oversight to plant operations. Nuclear Assurance audits and operations self-assessment activities have been effective throughout the period in identifying areas needing improvement.

However, the. effectiveness of the audits .and self-assessment activities, particularly in the area of analysis of program results, declined near the end of the period. .

There were two isolated areas where programs were not as effective in maintaining a superior level of performance. Control room supervisory oversight was not consistently effective as evidenced by t'n .ecent control rod mispositioning event. The licensed operator react W ion program was not providing operators'with necessary trdining.

The Plant Operations area is rated Category 1.

III. MAINTENANCE This functional area assesses activities associated with diagnostic, predictive, preventive. and corrective maintenance of structures.

systems, and components. It also assesses all surveillance testing, in-service inspection and other tests associated with equipment and system operability.

Maintenance activities were generally effective as demonstrated by few plant problems caused by equipment failures and reliable safety-system-performance. P'anning, preparation and scheduling of maintenance work were excellent. Implementation of modifications during the last outage performed during the assessment period was well controlled. Overall outage planning, scheduling, and implementation were effective in completing necessary work and supporting startup with few equipment problems. One specific area that remained a challenge was the controls in place for scaffolding installation.

Performance in the areas of diagnostic, predictive, and corrective ma ktenance were generally very effective and well managed. Post-mai.itenance testing planning improved during the latter part of the assessment period. In a few cases, corrective actions for previous problems did not preclude subsequent failures.

Enclosure

3 l

In general, surveillance testing and in-service testing and inspection performance were good and effective in identifying degraded equipment.

Inattention to testing procedures contributed to inadequate test results in a few examples. In-service examination activities were conducted by knowledgeable individuals.

A large number of maintenance activities were conducted during the

.. assessment period and most were executed in accordance with requi'rements. Improvement was noted in overall human performance compared to the previous assessment period; however operational challenges continued to be caused by inattention-to-detail by maintenance workers. Adherence to procedures was generally good with some problems noted in isolated areas.

Plant material condition was good as evidenced by reliable operation of Units 2 and 3 during the period. Improvements were noted in the number of fluid leaks from equipment or systems. During the first half of the assessment period, certain equipment conditions contributed to operations problems. Foreign material exclusion controls were also noted to have problems early in the period. Improvements were noted in both these areas by the end of the assessment period. 1 The self-assessment process continued to be a strength. Self-assessmerit of maintenance deficiencies and equipment problems was very effective in identifying and pursuing areas needing improvement. During refueling outages, there was good use of Quality Assurance oversight to identify deficiencies.

The Maintenance area is rated Category 1.

IV. ENGINEERING This functional area assesses the adequacy of technical and engineering support for plant activities. It includes activities associated with the design and testing of plant modifications: engineering and technical support for operations, maintenance, outages. testing surveillance and procurement: configuration management: training of the engineering

. staff; and support for licensing activities.

Engineering management and staff were knowledgeable of the plant systems. The knowledge and experience were incorporated into the day-to-day site functions.

Enclosure

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i Engineering reviews ana assessments of emergent issues and design modifications improved over the performance noted during the previous l assessment period in attention to thoroughness and completeness. Design l control was good for modifications. Some continuation of inattention-l l

to-detail was noted in engineering products for plant changes such as '

calculations.

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. Support to operations used industry. experience and was, in general.

responsive to resolving the issue. Pursuit of issues by engineering staff resulted in identification and resolution of problems with equipment and systems not functioning as desighed. There were instances '

where the support was not thorough; and two instances where engineering actions caused a challenge for operations of the plant.

Support to maintenance activities was good with thorough evaluation of l problems once identified. Problems'noted during the previous assessment with repetitive equipment problems were not noted during this assessment. Engineering specifications and scoping of testing were i generally good. Performance continued to show instances where data was  ;

not adequately reviewed or incorporated into testing criteria. The '

Maintenance Rule Expert Review Panel's screening of equipment and systems for trending was a strength.

Efforts to update and correct license and plant discrepancies in the j updated final safety analysis report were comprehensive. Safety assessments for licensee event reports were incomplete in some cases.

Poor quality and incomplete considerations were noted in documents and analyses submitted for license changes.

l Self-assessments and event investigations were effective. but limited to only a few engineering areas selected for review. Failure to follow licensee processes for problem evaluations caused delays and incomplete initial corrective actions in some cases.

The Engineering area is rated Category 2.

V. PLMT SUPPORT l

This functional area assesses activitier, related to the plant support function, including radiological controls, radioactive effluents and waste plant chemistry, emergency preparedness security, fire protection and housekeeping.

Enclosure L __ __ __ - _ - _

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3 External and internal. radiation exposure controls continued to be aggressively managed, which resulted in site collective radiation doses to individuals at levels well below regulatory limits. Planning and monitoring processes were used by management to effect doses to

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individuals as low as reasonably achievable for work in +.he plant. l Management and staff were aggressive in controlling contaminated areas.

which created access to plant areas necessary for routine operations.

This performance contributed significantly to a very low level of personnel contamination events. Controls for keeping contaminated material within controlled areas were successful in most cases.

l Chemistry and radiological controls management and staff interfaced weU to reduce radiation source terms. Those efforts were significant contributors to low collective doses in the period when leaking fuel continued to cause an increase to the source term. Strong adherence to goals and special initiatives to con' trol inputs and process liquids resulted in continued releases of radioactive effluents well below regulatory limits.

Response to emergency exercise scenarios and to actual events was done well in most cases. The emergency preparedness programs for maintaining equipment and facilities continued to exhibit strong performance with timely resolution of problems. Responders successfully mitigated  !

accidents during exercises and drills. 1 The security program performance continued to be superior in day-to-day '

operations and response to emergent issues. There were few equipment problems and minimal compensatory measures because of concerted efforts by management and staff to monitor and correct problems. The training-and qualifications program continued to provide highly qualified security staff. 3 I

Implementation of the fire protection program was good. The control of combustibles was especially effective. Due to a strong surveillance i

program, the maintenance and material condition of the fire protection

. equipment was good. Performance of the fire brigade continued at a high l level.

General housekeeping within the plant was very good. Controls for storage of radioactive materials in the containment, reactor building and radwaste storage areas was good.

Enclosure

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i 6 Self-assessments and audits continued to be comprehensive and effective in identifying performance problems or areas where performance could be improved. There were.some instances where the review to determine performance adequacy was not as thorough as other audits.

The Plant Support area is rated Category 1.

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Enclosure

. Nfh ogm UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555-0001 May 28,1998 NRC GENERIC LETTER 98-02: LOSS OF REACTOR COOLANT INVENTORY AND ASSOCIATED POTENTIAL FOR LOSS OF EMERGENCY MITIGATION FUNCTIONS WHILE IN A SHUTDOWN CONDITION Addressees All holders of operating licenses for pressurized-water reactors (PWRs), except those who have permanently ceased operations, and have certified that fuel has been permanently removed from the reactor vessel.

j Pumose l l

The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to request that addressees (1) assess the susceptibility of their residual heat removal (RHR) and emergency  ;

core cooling (ECC) cystems to common-cause failure as a result of reactor coolant system '

(RCS) draindown while in a shutdown condition, and (2) submit certain information, pursuant to i

Section 50.54(f) of Title 10 of the Code ofFeders/ Regulations (10 CFR 50.54(f)), concoming i their findings regarding potential pathways for inadvertent RCS drain down and the suitability of ,

surveillance, maintenance, modification and operating practicos and procedures regarding i

configuration control during reactor shutdown cooling. The requested information will enable NRC staff to verify whether addressees comply with NRC regulatory requirements and conform with current licensing bases for their facilities, with regard to prescribing and accomplishing activities affecting quality per Criterion V of Appendix 8 to 10 CFR Part 50. The staffis specifically concemed about addressees' controls over the conduct of activities during hot shutdown conditions that may affect the safety-related funcbons of the RHR system and the ECCS, for example, the methods used to verify valve position, the controls in place to assure compliance with plant surveillance, maintenance, modification and operating procedures, and the adequacy of operator training for such activities. (,' l Discussion The NRC issued information Notice (lN) 9543, " Loss of Reactor Coolant inventory and Potential Loss of Emergency Mitigation Functions While in a Shutdown Condition," on January 12,1995, to alert addressees to an incident at the Wolf Creek plant invoMng the loss of reactor coolant inventory while the reactor was in a .W shutdown condition. In that event,  ;

operators were attempting to reborate RHR train B, while at na same time maintenance '

personnel were repacking an RHR train A-to-train B crossover holation valve. Train B is reborated by recirculating water through a loop that contains the RHR system piping, the

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GL 98-02 May 28,1998 Page 2 of 5 refueling water strage tank (RWST), a containment spray pump, a manual RWST isolation valve, and an RHR system crossover line. When the RWST isolation valve was opened for the reboration process and the train A-to train 8 crossover isolation valve was opened for stroke testing, a drain-down path was inadvertently created from the RCS to the RWST.

At Wolf Creek, all RHR and ECC system pump suction lines are tied into a common suction

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header. When the draindown event occurred, hot RCS water was introduced into this common suction header between the RWST and the RHR and ECC system pumps. This hot water flashed to steam, resulting in a steam / water mixture in the header. Had an ECCS actuation j_

occurred, this mixture would have been introduced into the suction of the ECCS pumps. If i l

! operators had not been able to terminate the event, the hot water in the RWST suction piping might have led to steam binding, which could have advarsely affected the pumps in both ECCS trains. In addition, water flashing to steam in the heade' and the RWST could have caused serious mechanical damage to the RHR piping and the RWST as a result of water hammer.

Finally, steaming through the RWST establishes a containment bypass path.

The licensee estimated (using actual plant conditions) that for an unmitigated event, the reactor vessel water level could have dralhed to the bottom of the hot leg within 5 minutes and, as a consequence, RHR pump A would have lost suetion, cavitated, and failed. Shortly thereafter, the common ECCS suction header could have reached a 90-percent steam / water ratio. The '

licensee also estimated that continued boil-off could have caused the pressure vessel water level to drop to the point of core uncovery in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. '

i Events of this nature are considered particularly significant because they can result in loss of l

emergency core cooling capability and involve the potentiel for containment bypass. On l March 25,1996, the staff issued a supplement to IN 93-03 that further analyzed the event. The NRC has also issued a. number of other commur.ications describing events at reactor facilities involving inadvertent loss of reactor coo' ant inventory while the reactor was in a shutdown condition. The Office for Analysis and Evaluation of Operational Data (AEOD) published AEOD/E704, " Discharge of Primary Coolant Outside of Containment at PWRs While on RHR Cooling,"in March 1987, which documented six events involving RCS backflow into the RWST.

In Generic Letter 88-17, '" Loss of Decay Heat Removal (DHR) 10 CFR 50.54(f)," dated October 17,1988, the NRC requested several actions to address loss-of-DHR events that occurred while reactors were in a shutdown condition. In IN 9142, " Plant Outage Events involving Poor Coordination Between Operations and Maintenance Persor,nel During Valve Testing and Manipulations," dated June 27,1991, the NRC discussed inadvertent loss-of-inventory events. The AEOD report " Reactor Coolant System Blowdown at Wolf Creek on September 17,1994," (AEOD/S95-01), dated March 1995, noted 19 events in which RCS water was transferred to the RWST. These events were primarily caused by personnel errors, poor coordination between operations and maintenance personnel, and inadequate procedures associated with the operation of the RHR system in the shutdown cooling mode. The personnel errors were pr!marily caused by inattention or lack of training; while the procedural deficiencies were related to omissions or !ack of specificity in serquential valve operations when conducting tests on the RHR system. Cni the basis of this hitfor/ and the potential for containment bvpass, the staff has concluded that additionalinformation is required to confirm the adaquacy of existing configuration contro, operating practices, and training for assuring tFe safety function capability of the RHR and ECC systems.

i GL 98-02 May 28,1998 Page 3 of 5 BRauired Information Within 180 days of the date of this generic letter, addressees are required to perform the following: (1) an assessment of whether your emergency core cooling systems include certain design features, such as a common pump suction header, which can render the systems su:ceptible to common-cause failure as a result of events similar to the Wolf Creek RCS drain-down event of September 17,1994; and if this susceptibility is found, (2) prepare, with consider-ation of plant-specific design attributes, a description of the features of your Appendix B quality assurance program (for example, the methods used to verify valve position, the controls in i

place to assure compliance with plant surveillance, maintenance, modification and operating procedures, and the adequacy of operator training for such activities) that provide assurance that the safety-related functions of the RHR system and ECCS will not be adversely affected by j activities conducted at hot shutdown (such as occurred at Wolf Creek). Addressees may limit '

their attention to those surveillance, maintenance, modification and operationa! activities at hot i

shutdown during which it is feasible to divert RCS fluid to the RWST, resulting in simultaneous

! 1 drain-down of the RCS and voiding in the suction header for the RHR and ECC system pumps.  ;

Addressees may further limit their response to the consideration of potential configurations and conditions that involve flow paths with pipe diameters equal to or greater than 2 inches. If the l

assessment performed in response to part (1) of the above requested information does not i reveal that a susceptibility exists, then no submittal is necessary.

l if the assessment performed in response to part (1) of the sbove required information reveals l

that the susceptibilhy exists, then the result of the assessment shall be submitted in writing, pursuant to 10 CFR 50,54(f) and 10 CFR 50.4, to the U.S. Nuclear Regulatory Commission, i

ATTN; Document Control Desk, Washington, D.C. 20555-0001, signed under oath or l affirmation under the provisions of Section 182a of the Atomic Energy Act of 1954, as amended, with a copy to the appropriate regional administrator and the appropriate NRC resident insoector. The response to part (2) of the above information request need not be submitted to the NRC. However, responses to parts (1) and (2) of the required information shall be kept in a retrievable licensee system that NRC can verify on an as-needed or sample

, basis.

Backfit Discussion 1

This generic letter only requests irGaneen from the addressees under the provisions of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f), to verify addressee compliance with the Commission's regulations and conformance w!th the current licensing-basis of their respective fac!" ties relative to the safety-related functions of the RHR and ECC systems, and the requirements of Appendix B to 10 CFR Part 50. With respect to l

Appendix B to 10 CFR Part 50, the requested information will enable the NRC staff to determine whether adequate control is being exercised over surveillance, maintenance, modification and operational activities conducted at hot shutdown which can advers6y affect the safety-related functions of the RHR and ECC systems. No backfit is either intended or approved in the context of issuance of this generic letter. Therefore, the staff has not performed a backfit analysis.

l l

1

GL 98-02 May 28,1998 Page 4 of 5 Quality Assurance Criteriun V of Appendix B to 10 CFR Part 50 requires that " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Furthermore, licensees' technical specifications include -

requirements to establish, impicment, and maintain written administrative procedures to address startup, operation, and shutdown of a shutdown cooling system. Maintenance and testing activities at Wolf Creek during hot shutdown were carried out contrary to documented procedures and the technical specifications, resulting in RCS drain-down and the potential for common-cause failure of the RHR and ECC system pumps, which could have compromised the ability of the RHR and ECC systems to fulfill their safety functions. Furthermore, the staff has determined that similar loss-of-coolant events while on RHR cooling have occurred at over 19 plants. These events were due to the failure on the part of licensees to either establish adequate procedures or follow procedures and applicable technical specifications. Both of these conditions involve non-compliance with the requirements of Criterion V of Appendix B to 10 CFR Part 50, and, therefore, non-compliance with the current licensing basis for a facility.

Since, a relatively large number of the operating PWRs have experienced similar events, the i

! staff believes that additional information is required to confirm the adequacy of existing configuration control practices, operating practices, and training for assuring the safety function capability of the RHR and ECC systems. In accordance with the provisions of 10 CFR 50.54(f),

an approved evaluation of the rationale for the information request contained herein is not a prerequisite to issuance of the generic letter because the information being requested is l

! needed by the NRC staff to verify addressee compliance with the current licensing bases of their respective facilities.

FederalRealster Natsfication l

A notice of opportunity for public comment was published in the Federal Register (62 FR 7075) on February 14,1997. Comments were received from four nuclear utility companies, the Nuclear Energy Institute, and the Nuclear Utility Backfitting and Reform Group. The staff's evaluation of the comments is available from the NRC Public Document Room. The generic letter has been appropriately revised to reflect the comments received.

Panerwork Reduction Act St; ament This Generic Letter contains information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget, approval number 3150 0011, which expires -

September 30,2000.

The public reporting burden for this mandatory information collection is estimated to average 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the information collection. The U.S. Nuclear Regulatory Commission is seeking public comment on the potentialimpact of the information collections contained in the generic letter and on the following issues:

)

GL 98-02 May 28,1998 Page 5 of 5

1. Is the proposed information collection necessary for the proper performance of the functions of the NRC, including whether the information will have practical utility?

2. is the estimate of burden accurate?

3. Is there a way to enhance the quality, utility, and clarity of the information h be collected?

4. . How can the burden of the information collection be minimized, including the use of automated collection techniques?

l l

Send comments on any aspect of this information collection, including suggestions for reducing i the burden, to the Information and. Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by Intemet electronic mail at BJS1@NRC. GOV; and to the Desk Officer Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011), Office of Management and Budget, Washington, DC 20503.

Public Protection Notification if an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

if 1 a nave 'any questions about this matter, please contact the techaical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

l .

4 Original signed by Jack W. Roe, Acting Director l

Division of Reactor Program Management l_

Office of Nuclear Reactor Regulation Technical contact: M. M. Razzaque, NRR 301 415-2882 L E-mail: mmr1@nrc. gov Lead Project Manager: Kristine Thomas, NRR l 301-415-1362 E-mail: kmt@nrc. gov

Attachment:

List of Recently issued NRC Generic Letters

( ,

- DOCUMENT NAME: S:\DRPM SEC\98-02.GL

)-

.Ta receive a copy of this document indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy OFFICIAL RECORD COPY OFFICE SXRB' OGC* PECB* (A)D:DRPM NAME tr -

MRazzaque JGoldberg JStolz h oe

! DATE- 5/27/98 3/16/98 5/27/98 b8 L____________________________.___.___

1 Attachment GL 98-02 j ,

May '28,:1998 Page 1 of 1 l

LIST OF RECENTLY ISSUED GENERIC LETTERS GENERIC DATE OF LETTER SUBJECT ISSUANCE ISSUED TO j 98-01 Year 2000 Readiness of 05/12/98 All holders of OLS for '

of Computer Systems at nuclear power plants, Nuclear Power Plants except those who have permanently ceased i operations and have certified that fuel has been ,

permanently removed from 1 the reactor vessel l

9T-06 Degradation of Steam 12/30/97 All holders of OLS for l Generator intemals pressurized-water reactors, l

l except those who have i permanently ceased operations and have certifed that fuel has been perman- ,

ently removed from the '

l reactor vessel 97-05 Steam Generator Tube 12/17/97 Allholders of OLs for inspection Techniques pressurized-water reactors, except those who have  :

permanently ceased i operations and have certifed that fuel has been perman-  ;

ently removed from the reactor vessel '

i 96-06, Assurance of Equipment 11/13/97 All holders of OLs for nuclear Sup.1 Operability and Containment power reactors except those Integrity During Design-Basis who have permanently Accident Conditions ceased operations and have certified that fuel has been permanently removed from the reactor vessel OP = Operating License CP = Construction Permit NPR = Nuclear Power Reactors i

[. .

, GL. 98-02 May 28,1998 Page 5 of 5

\ ,

1.

Is the proposed information collection necessary for the proper performance of the functions of the NRC, including whether the information will have practical utility?

2. Is the estimate of burden accurate?

3. Is there a way to enhance the quality, utility, and clarity of the information to be collected?

4.

How can the burden of the information collection be minimized, including the use of (

automated collection techniques?

Send comments on any aspect of this information collection, including suggestions for reducing the burden, to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by intemet electronic mail at BJSi@NRC. GOV; and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202 (3150-0011), Office of Management and Budget, Washington, DC 20503.

Public Protection Notification if an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

If you have any questions about this matter, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Original signed by Jack W. Roe,- Acting Director Division of Reactor Program Management Office of Nuclear Reactor Regulation Technical contact: M. M. Razzaque, NRR 301-415-2882 i E-mail: mmr1@nrc. gov Lead Project Manager: Kristine Thomas, NRR 301-415-1362

- E-mail: kmt@nrc. gov

Attachment:

List of Recently issued NRC Generic Letters DOCUMENT NAME: S:\DRPM_SEC\98-Of.GL I

? To receive a copy of this document indicate in the box C= Copy w,o attachment / enclosure E= Copy with attachment / enclosure N =

OFFICIAL RECORD COPY OFFICE ' SXRB' OGC* PECB* (A)D:DRPM NAME MRazzaque tr -

L JGoldberg JStolz h oe DATE- 5/27/98 3/16/98 5/27/93 b8

V L. CPQ-W.

May 28,1998 Page 5 of 5 9

1. Is the proposed information collection necessary for the proper performance of the functions of the NRC, including whether the information will have practical utility?

2. Is the estimate of burden accurate?

3. Is there a way to enhance the quality, utility, and clarity of the information to be collected?

4. How can the burden of the information collection be minimized, including the use of automated collection techniques?

Send comments on any aspect of this information collection, including suggestions for reducing -

the burden, to the information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by Intemet electronic mail at BJS1@NRC. GOV; and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011), Office of Management and Budget, Washington, DC 20503.

Public Protection Notification if an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information -

collection.

If you have an/ questions about this matter, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager, i

I 4

Jack W. Roe, Acting Director

' Division of Reactor Program Management Office of Nuclear Reactor Regulation l Technical contact: M. M. Razzaque, NRR l 301 4 15-2882 E-mail: mmr1@nrc. gov

!: Lead Project Manager: Kristine Thomas, NRR ,

!. 301-415-1362  !

l E-mail: kmt@nrc. gov I

L

Attachment:

List of Recently issued NRC Generic Letters DOCUMENT NAME: S:\DRPM_SEC\98-02.GL Te receive a copy of this document. Indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy OFFICIAL RECORD COPY OFFICE SXRB OGC* PEOR (A)D:DRPM NAME MRazzaquqA([ JStolzk JRoe  !

DATE N8 //98 5 /98 5/ /98

, aro ug p k UNITED STATES l 3

• ]*

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 4001 June 10, 1998 l

l Mr. O. J. Zeringue Chisf Nuclear Officer

-and Executive Vice President Tennessee Valley Authority 6A Lookout Place i 1101 Market Street i Chattanooga, Tennessee 37402-2801 i j l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING REACTOR  !

PRESSURE VESSEL INTEGRITY AT BROWNS FERRY NUCLEAR PLANT, '

UNITS 1,2, AND 3 (TAC NOS. MA1179, MA1180, AND MA1181)

Dear Mr. Zeringue:

Generic Letter (GL) 92-01, Revision 1, Supplement 1 (GL 92-01, Rev.1, Supp.1), " Reactor Vessel Structural Integrity" was issued in May 1995. This GL requested licensees to perform a l review of their reactor pressure vessel (RPV) structuralintegrity assessments to identify, collect,

)

l

' and report any new data pertinent to the analysis of the structuralintegrity of their RPVs.

Licensees were asked to assess the impact of those data on their RPV integr'ty analyses relative to the requirements of Title 10 of the Code of Federal Raoulation_m. Sections 50.60 and 50.61, j

Appendices G and H which encompass pressurized thermal shock and upper shelf energy evaluations, and any potential impact on low temperature over pressure limits or pressure-l temperature (P-T) limits.

After reviewing the Tennessee Valley Authority (TVA) response submitted on July 7,1992, for i

' the Browns Ferry Nuclear Plant Units 1,2, and 3 (SFN), the U.S. Nuclear Regulatory Commission (NRC) acknowledged by latter to TVA dated July 26,1996, that TVA had submitted the requested information and had asserted that the previously submitted evaluations remained valid. As a result, the NRC concluded that no additionalinformation regarding the structural integrity of the BFN RPVs was available at that time. Subsequently, the boiling-water reactor l

Vessel and intamals Project (BWRVIP) submitted its report, " Update of Bounding Assessment of BWR/2-6 Reactor Pressure VesselIntegrity issues (BWRVIP-46)." This report included bounding assessments of new data from (1) the Combustion Engineering owners Group (CEOG) database l released in July 1997 which contains all known data for CE fabricated welds in pressurized-water l

reactor and BWR vessels; (2) Framatome Technologies incorporated (FTI) analyses of Linde 80 l welds which are documented in NRC inspection Report 99901300/97-01 dated January 28,1998; i' . (3) FTl's analysis of electro-slag welds which was referenced in a Dresden and Quad Cities P-T i limits submittal dated September 20,1996; and (4) Chicago Bridge and Iron quality assurance i records. New data for one vessel fabricated by Hitachi was also included in the BWRVIP report.

The staff la requesting that TVA re-evaluate the RPV weld chemistry values that were submitted previously as part of the BFN iicensing bases in light of the information presented in the CEOG, FTl and BWRVIP reports. The staff expects that TVA will assess this new information to l

[  % .

r-Mr. O. J. Zeringue f l determine whether any values of RPV weld chemistry need to be revised for BFN. Therefore, to .

provide a complete response to items 2,3 and 4 of the GL, the NRC requests a response to the enclosed request for additionalinformation within 90 days of receipt of this letter. If a question does not apply to the BFN situation, please indicate this in the response along with the technical

basis. Additionally, per GL 92-01, Rev.1, Supp.1, please provide a certification that the l previously submitted evaluations remain valid.

The information provided will be used in updating the Reactor Vessel Integrity Database. Please l . note that RPV integrity analyses utilizing newly identified data could require license amendments

! to maintain compliance with 10 CFR 50.60 and Appendices G and H to 10 CFR Part 50, and to l address any potential impact on P-T limits. If license amendments or additional assessments

- are necessary, please provide the schedule for such submittals.

Sincerely, l- (Original Signed By) l l Albert W. De Agazio, Senior Project Manager ,

Project Directorate 11-3 j Division of Reactor Projects - t/11  :

Office of Nuclear Reactor Regulation Docket Nos. 50 259,50-260, and 50-296 Serial No. BFN-98-013 j l

Enclosure:

Request for l AditionalInformation

!~

l: cc w/ encl: See next page l

l- DISTRIBUTION. FHebdon l Docket File OGC PUBLIC ACRS BFN r/f LPlisco, Ril l JZwolinski- Alee BClayton GVissing . j A P ^ n '=-

OFFICE PDll-3/PM . PDil-3/LA / PDil-3/D ,

i NAME ADeAg hw BC N FHEBDONfMI DATE A/ 9 /98 (/ $ /98 b/10198 f OFFICIAL RECORD COPY l

l l

l

Mr. O. J. Zeringue BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority l

cc:

! Mr. J. A. Scalice, Senior Vice President Mr. Mark J. Burzynski, Managar Nuclear Operations Nuclear Licensing Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place 4J Blue Ridge 1101 Market Street 1101 Market Street Chattanooga, TN 37402-2801

( Chattanooga, TN 37402-2801 Mr. Jack A. Bailey, Vice President Mr. Timothy E. Abney, Manager Engineering & Technical Services Licensing and Industry Affairs Tennessee Valley Authority Browns Feny Nuclear Plant

! 6A Lookout Place Tennessee Valley Authority l

1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Decatur, AL 37402-2801 Mr. C. M. Crane, Site Vice President Regional Administrator, Region ll Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority 61 Forsyth Street, SW., Suite 23T85 P.O. Box 2000 Atlanta, GA 30303-3415 Decatur, AL 35609 l Mr. Leonard D. Wort General Counsel Senior Resident inspector i Tennessee Valley Authority U.S. Nuclear Regulatory Commission '

ET 10H Browns Ferry Nucle 6r Plant 400 West Summit Hill Drive 10833 Shaw Road Knoxville, TN 37902 Athens, AL 35611

Mr. Raul R. Baron, General Manager State Health Officer Nuclear Assurance Alabama Dept. of Public Health Tennessee Valley Authority 4M Monroe Street l 4J Blue Ridge Montgomery, AL 35130-1701 1101 Market Street Chattanooga, TN 37402-2801 Chairman Limestone County Commission Mr. Karl W. Singer, Plant Manager 310 West Washington Street Browns Ferry Nuclear Plant Athens, AL 35611 Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609

l REQUEST FOR ADDITIONAL INFORMATION REACTOR PRESSURE VESSEL INTEGRITY 1 Assessment of Best Estimate Chemistry The U.S. Nuclear Regulatory Commission (NRC) staff recently received the Boiling-Water Reactor Vessel and intervals Project (BWRVIP) report, " Update of Bounding Assessment of l 6WR/2-6 Reactor Pressure Vessel Integrity issues (BWRVIP-46)." Based on information in the

! BWRVIP report, in accordance with the provisions of Generic 1.etter 92-01, Revision 1, Supplement 1, the NRC requests the following:

An evaluation of the bounding assessment in the reference above and its applicability.to  ;

the determination of the best-estimate chemistry for all of Browns Ferry Nuclear Plant, Units i 1,2 and 3 (BFN) reactor pressure vessel (RPV) beltline welds. Based upon this  !

re-evaluation, supply the information necessary to complete the data requested in Table 1 i i

' for each RPV beltline weld material, if the limiting material for the BFN vessels' pressure- i temperature (P-T) limits evaluation is not a weld, also include the information requested in l

Table 1 for the limiting material.

With respect to Tennessee Valley Authority's (TVA's) response to this question, the staff notes l that some issues regarding evaluation of the data were discussed in a public meeting between the staff, Nuclear Energy Institute (NEI), and industry representatives on November 12,1997. A summary of this meeting is documented (Reference 1)in a meeting summary dated i November 19,1997, " Meeting Summary for November 12,1997 Meeting with Owners Group Representatives and NEl Regarding Review of Responses to Generic Letter 92-01, Revision 1,

SLpplement 1 Responses". The information in Reference 1 may be usefulin helping you to prepare your response, in addition to the issues discussed in the referenced meeting, TVA shou!d also consider what method should be used for grouping sets of chemistry data (in particular, those from weld '

qualification tests) as being from "one weld" or from multiple welds. This is an important consideration when a mean-of-the-means or coil-weighted average approach is determined to be the appropriate method for determining the best-estimate chemistry. If a weld (or welds)is fabricated as weld qualification specimens by the same manufacturer, within a short time span, using similar welding input p.rameters, and using the same coil (or coils in the case of tandem arc welds) of weld consumables, it may be appropriate to consider all chemistry samples from that weld (or welds) as samples from "one weld" for the purposes of best-estimate chemistry determination, if information is not available to confirm the aforementioned details, but sufficient evidence exists to reasonably assume the details are the same, the best-estimate chemistry should be evaluated both by assuming the data came from "one weld" and by assuming that the data came from en appropriate number of "multip!s welds." A justification should then be provided for which assumption was chosen when the best-estimate chemistry was determined.

2 P.T Limit Evaluation If the limiting material for BFN changes or if the adjusted reference temperature for the limiting materialincreases as a result of the above evaluations, please provide the revised RTer vslue for the limiting material. In addition, if the adjusted RT.7 value increased,

. please provide a schedule for revising the P-T limits. The schedule should ensure that compliance with 10 CFR Part 50 Appendix G is maintained.

l

\ .

{

l 2-f Reference

1. Memorandum dated November 19,1997, from Keith R. Wichman to Edmund J. Sullivan,

" Meeting Sumrnary for November 12,1997 Meeting with Owners Group Representatives and NEl Regarding Review of Responses to Generic Letter 92-01, Revision 1, Supplement 1 Responses."

Attachment:

Table 1 l

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