ML071030397
| ML071030397 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/13/2007 |
| From: | Crouch W Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML071030397 (151) | |
Text
April 13, 2007
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Gentlemen:
In the Matter of ) Docket No. 50-259 Tennessee Valley Authority )
BROWNS FERRY NUCLEAR PLANT (BFN) - STATUS OF UNIT 1 RESTART ISSUES, REVISION 12 This letter updates the status of the Unit 1 Bulletins, Generic Letters, Nuclear Performance Plan Special Programs, and TMI Action Items identified in TVA's regulatory framework
letters to NRC (References 1 and 2). As documented in the
NRC's approval of TVA's regulatory framework (References 3
and 4), the staff requested and TVA agreed to provide formal
notification of the completion of each generic communication
within 90 days of its internal commitment completion. This
letter is part of the process that is being used to satisfy
this request. Additional items from the NRC's Browns Ferry
Unit 1 Recovery Issues List (Reference 5) have also been
included.
to this letter provides background information
regarding the regulatory framework for the restart of Unit 1, lists the individual issues cited in the framework letters and
the NRC's Recovery Issues List, describes TVA's commitment or
outstanding action for each issue, references key
correspondence, discusses the background of the issue, and
describes the completion or status of each issue, as
appropriate. A summary of the issues that will be completed
after restart for Unit 1 is provided as Enclosure 2.
U.S. Nuclear Regulatory Commission Page 2 April 13, 2007
TVA intends to periodically update this submittal until the
Unit 1 commitments related to restart or power operation are
completed (TVA committed actions are completed). The first
status of these generic communications was provided in
Reference 6. The updates will provide the formal notification
of the completion of each Unit 1 Bulletin, Generic Letter, Nuclear Performance Plan Special Program, and TMI Action Item
required for restart. Changes to the completion status and
newly added issues are bolded in the table of contents.
Changes to the completion status are also bolded in the text
which describes each item. Other changes are noted by
revision bars on the right hand side of the page.
There are no new positions or commitments contained in this
letter. If you have any questions, please contact me at
(205) 729-2636.
Sincerely,
Original signed by:
William D. Crouch
Manager of Licensing
and Industry Affairs
References
- 1. TVA letter, T. E. Abney to NRC, dated December 13, 2002, Browns Ferry Nuclear Plant (BFN) - Unit 1 - Regulatory
Framework for the Restart of Unit 1 2. TVA letter, T. E. Abney to NRC, dated February 28, 2003, Browns Ferry Nuclear Plant (BFN) - Unit 1 - Regulatory
Framework for the Restart of Unit 1 3. NRC memorandum from K. N. Jabbour, dated May 13, 2003, Summary of April 24, 2003, Meeting Regarding the
Regulatory Framework for Browns Ferry Unit 1 Restart
Project (TAC No. MB7679) 4. NRC letter, K. N. Jabbour to J. A. Scalice, dated August 14, 2003, Regulatory Framework for the Restart of
Browns Ferry Nuclear Plan, Unit 1 (TAC MB7679)
U.S. Nuclear Regulatory Commission Page 3 April 13, 2007
- 5. NRC letter, J. W. Shea to K. W. Singer, dated January 6, 2006, Meeting Summaries: 1.) Category 1 Public
Meeting with Tennessee Valley Authority (TVA) RE. Browns
Ferry Unit 1 Recovery Status; 2.) Meeting of the NRC
Restart Panel for the Browns Ferry Unit 1 Recovery -
Docket No. 50-259 6. TVA letter, T. E. Abney to NRC, dated November 19, 2004, Browns Ferry Nuclear Plant (BFN) - Status of Unit 1
Restart Issues
Enclosures
cc (Enclosures):
(Via NRC Electronic Distribution)
U.S. Nuclear Regulatory Commission
Region II
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW, Suite 23T85
Atlanta, Georgia 30303-3415
Mr. Malcolm T. Widmann, Branch Chief
U.S. Nuclear Regulatory Commission
Region II
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW, Suite 23T85
Atlanta, Georgia 30303-8931
NRC Senior Resident Inspector
Browns Ferry Nuclear Plant
10833 Shaw Road
Athens, AL 35611-6970
Ms. Margaret Chernoff, Senior Project Manager
U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North
11555 Rockville Pike
Rockville, Maryland 20852-2739
Ms. Eva A. Brown, Project Manager
U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North
11555 Rockville Pike
Rockville, Maryland 20852-2739 U.S. Nuclear Regulatory Commission Page 4 April 13, 2007
JEM:TLE:BAB
Enclosures
cc (Enclosures):
M. Bajestani, NAB 1A-BFN
R. G. Jones, POB 2C-BFN
R. F. Marks, PAB 1A-BFN
B. J. O'Grady, PAB 1E-BFN
J. Valente, NAB 1E-BFN
B. A. Wetzel, BR 4X-C
EDMS WT CA-K S:lic/submit/subs/Status of Unit 1 Restart Issues - R12.doc
Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-i INDEX TO ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
STATUS OF UNIT 1 ISSUES
TABLE OF COMMENTS TOPIC PAGE STATUS FOR RESTART Background E1-1 -
Bulletin 79-02, Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts E1-4 C-C Bulletin 79-12, Short Period Scrams at BWR Facilities E1-5 C-C Bulletin 79-14, Seismic Analysis for As-Built Safety-Related Piping Systems E1-6 C-C Bulletin 80-06, Engineered Safety Feature (ESF)
Reset Controls E1-7 C-C Bulletin 84-02, Failures of General Electric Type HFA Relays in Use in Class 1E Safety
Systems E1-8 Closed Bulletin 86-02, Static "O" Ring Differential Pressure Switches E1-9 C-C Bulletin 88-03, Inadequate Latch Engagement in HFA Type Relays Manufactured by General
Electric (GE) Company E1-11 Closed Bulletin 88-04, Potential Safety-Related Pump Loss E1-12 C-C Bulletin 88-07, Power Oscillations in Boiling Water Reactors, and Supplement 1 E1-14 C-C Bulletin 88-10, Nonconforming Molded-Case Circuit Breakers E1-15 C-C Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-ii TOPIC PAGE STATUS FOR RESTART Bulletin 90-01, Loss of Fill Oil in Transmitters Manufactured by Rosemount E1-16 C-C Bulletin 93-02, Debris Plugging of Emergency Core Cooling Suction Strainers, and
Supplement 1 E1-18 C-C Bulletin 93-03, Resolution of Issues Related To Reactor Vessel Water Level Instrumentation in
BWRs E1-20 C-C Bulletin 95-02, Unexpected Clogging of a Residual Heat Removal (RHR) Pump Strainer
While Operating in Suppression Pool Cooling
Mode E1-21 C-C Bulletin 96-03, Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in
Boiling-Water Reactors E1-22 C-C Cable Ampacity E1-23 Complete Cable Installation Issue Number 1, Brand Rex Cable Issues E1-24 Open Cable Installation Issue Number 2, Cable Separations Issues E1-25 Complete Cable Installation Issue Number 3, Low Voltage Vertical Cable Supports E1-28 Open Cable Installation Issue Number 4, Medium Voltage Cable Bend Radius E1-29 Open Cable Installation Issue Number 5, Missing Conduit Bushings E1-31 Open Cable Installation Issue Number 6, Sidewall Pressure, Cable Pullbys, Cable Jamming, Pulling Around 90 Degree Condulets and Thru
Mid-Run Flex Conduit Issues E1-32 Open Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-iii TOPIC PAGE STATUS FOR RESTART Cable Installation Issue Number 7, Use of Condulets as Pull Points E1-33 Open Cable Installation Issue Number 8, Medium Voltage Vertical Cable Supports E1-34 Open Cable Splices E1-35 Complete Cable Tray Supports E1-36 C-C Component and Piece Part Qualification E1-38 Complete Conduit Supports E1-39 C-C Configuration Management/Design Baseline E1-41 C-C Containment Coatings E1-42 Complete Control Rod Drive (CRD) Insert and Withdrawal Piping E1-43 C-C Design Calculation Review E1-44 C-C Environmental Qualification E1-45 Open Fire Protection / 10 CFR 50, Appendix R E1-46 Open Flexible Conduits E1-48 Complete Fuses E1-50 Complete Generic Letter 82-33, Instrumentation to Follow the Course of an Accident - Regulatory Guide
1.97 E1-51 C-C Generic Letter 83-08, Modification of Vacuum Breakers on Mark 1 Containments E1-54 C-C Generic Letter 83-28, Salem ATWS, Item 1.2, Post Trip Review (Data and Information
Capability)
E1-55 Closed Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-iv TOPIC PAGE STATUS FOR RESTART Generic Letter 83-28, Salem ATWS, Item 4.5.2, Periodic On-Line Testing E1-56 Closed Generic Letter 83-28, Salem ATWS, Item 4.5.3, Intervals for On-Line Testing E1-57 Closed Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical
Equipment In Operating Reactors, Unresolved
Safety Issue (USI) A-46 E1-58 Complete Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping E1-60 C-C Generic Letter 88-11, Radiation Embrittlement of Reactor Vessel Materials and Its Impact on
Plant Operations E1-61 C-C Generic Letter 88-14, Instrument Air Supply System Problems Affecting Safety-Related
Equipment E1-63 Closed Generic Letter 88-20, Individual Plant Examination for Severe Accident
Vulnerabilities E1-64 Complete Generic Letter 88-20, Supplement 4, Individual Plant Examination of External Events (IPEEE)
for Severe Accident Vulnerabilities E1-66 Complete Generic Letter 89-06, Task Action Plan Item I.D.2 - Safety Parameter Display System E1-68 Closed Generic Letter 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning E1-70 Closed Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance E1-71 Closed Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment E1-73 C-C Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-v TOPIC PAGE STATUS FOR RESTART Generic Letter 89-16, Installation of a Hardened Wetwell Vent E1-74 C-C Generic Letter 92-01, Reactor Vessel Structural Integrity, Revision 1, and Revision 1
Supplement 1 E1-75 C-C Generic Letter 92-04, Resolution of the Issues Related to Reactor Vessel Water Level
Instrumentation in BWRs E1-78 C-C Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Operating Recommendations
for Thermal-Hydraulic Instabilities in
Boiling Water Reactors E1-79 Closed Generic Letter 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling
Water Reactors E1-80 C-C Generic Letter 95-07, Pressure Locking and Thermal Binding of Safety-Related and
Power-Operated Gate Valves E1-81 C-C Generic Letter 96-01, Testing of Safety-Related Logic Circuits E1-83 Closed Generic Letter 96-05, Periodic Verification of Design-Basis Capability of Motor-Operated
Valves E1-84 C-C Generic Letter 96-06, Assurance of Equipment Operability and Containment Integrity During
Design-Basis Accident Conditions E1-85 C-C Generic Letter 97-04, Assurance of Sufficient Net Positive Suction Head for Emergency Core
Cooling and Containment Heat Removal Pumps E1-87 C-C Generic Letter 98-01, Year 2000 Readiness of Computer Systems at Nuclear Power Plants E1-89 C-C Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-vi TOPIC PAGE STATUS FOR RESTART Generic Letter 98-04, Potential for Degradation of the Emergency Core Cooling System and the
Containment Spray System After a Loss-of-
Coolant Accident Because of Construction and
Protective Coating Deficiencies and Foreign
Material in Containment E1-90 C-C Generic Letter 2003-01, Control Room Habitability E1-92 Complete Generic Safety Issue 75 / Multi-Plant Action B085, Generic Letter 83-28, Item 1.2,
Post-Trip Review - Data and Information
Capability E1-94 Closed HVAC Duct Supports E1-95 C-C Instrument Sensing Lines E1-96 Complete Instrument Tubing E1-97 Complete Intergranular Stress Corrosion Cracking (IGSCC) E1-98 C-C Large Bore Piping Supports E1-99 C-C License Renewal - Appendix F Commitments E1-100 Open License Renewal - Non-Appendix F Commitments E1-103 Open Long Term Torus Integrity Program E1-104 Complete Lower Drywell Platforms and Miscellaneous Steel E1-106 C-C Moderate Energy Line Break (MELB) E1-108 C-C NUREG-0737 (TMI Action Plan), Action Item I.D.1, Control Room Design Review E1-109 Closed NUREG-0737 (TMI Action Plan), Action Item I.D.2, Safety Parameter Display Console E1-111 Closed Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-vii TOPIC PAGE STATUS FOR RESTART NUREG-0737 (TMI Action Plan), Action Item II.B.3, Post-Accident Sampling System E1-112 C-C NUREG-0737 (TMI Action Plan), Action Item II.E.4.2.1-4, Containment Isolation
Dependability - Implement Diverse Isolation E1-114 Open NUREG-0737 (TMI Action Plan), Action Item II.F.1.2.C, Accident - Monitoring -
Containment High Range Radiation E1-115 Closed NUREG-0737 (TMI Action Plan), Action Item II.F.1.2.D, Accident - Monitoring -
Containment Pressure E1-116 C-C NUREG-0737 (TMI Action Plan), Action Item II.F.1.2.E, Accident - Monitoring -
Containment Water Level E1-117 C-C NUREG-0737 (TMI Action Plan), Action Item II.F.2.4 (Generic Letter 84-23),
Instrumentation for Detection of Inadequate
Core Cooling E1-118 C-C NUREG-0737 (TMI Action Plan), Action Item II.K.3.13, HPCI/RCIC Initiation Levels E1-120 C-C NUREG-0737 (TMI Action Plan), Action Item II.K.3.18, ADS Actuation Modifications E1-122 Closed NUREG-0737 (TMI Action Plan), Action Item II.K.3.27, Common Reference Level for Vessel
Level Instrumentation E1-123 C-C NUREG-0737 (TMI Action Plan), Action Item II.K.3.28, Qualification of ADS Accumulators E1-124 C-C Platform Thermal Growth E1-126 C-C Q-List E1-127 Complete Restart Test Program E1-128 Open Open: TVA committed actions are not complete.
Closed: Item has been closed by NRC document.
Complete: TVA committed actions are completed.
C-C: Issue is "Closed" and "Complete."
E1-viii TOPIC PAGE STATUS FOR RESTART Seismic Class II Over I / Spatial Systems Interactions and Water Spray E1-129 Complete Small Bore Piping E1-130 Complete Thermal Overloads E1-131 C-C Unresolved Safety Issue A-7, Mark I Long-Term Program E1-133 C-C Unresolved Safety Issue A-9, Anticipated Transients Without Scram E1-133 C-C Unresolved Safety Issue A-24, Qualification of Class 1E Safety Related Equipment E1-135 C-C Unresolved Safety Issue A-26, Reactor Vessel Pressure Transient Protection E1-136 C-C Unresolved Safety Issue A-44, Station Blackout E1-137 Complete Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating
Plants E1-138 Complete April 13, 2007 E1-1 ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
STATUS OF UNIT 1 ISSUES BACKGROUND T he Browns Ferry Nuclear Plant (BFN) consists of three units.
Units 1 and 3 were voluntarily shut down by the Tennessee Valley
Authority (TVA) in March 1985 because of questions about the
primary containment isolation leak rate testing for Unit 1 and
reactor water level instrumentation for Unit 3. Unit 2 was in a
refueling outage at the time. Additional questions and concerns
were subsequently raised about the overall adequacy of TVA's
nuclear program, and Browns Ferry remained shut down until
adequate corrective actions were defined to address the root
causes of TVA's nuclear program problems.
On September 17, 1985, NRC requested, pursuant to 10 CFR
50.54(f), that TVA submit information about its plans for
correcting Browns Ferry's problems and for correcting problems in
the overall management of its nuclear program. NRC also
requested that this information be submitted before TVA restarted
Browns Ferry. In response to this request, TVA prepared a
Corporate Nuclear Performance Plan (CNPP) Volume 1 which
identified the root causes of the problems in the management of
TVA's nuclear program and described TVA's plans for correcting
those problems.
Additionally, TVA prepared a Browns Ferry Nuclear Performance
Plan (BFNPP) Volume 3 which identified the root causes of
problems specifically related to Browns Ferry, defined plans for
correcting those problems, and responded to the NRC's request for
Browns Ferry specific information. Taken together, these
two plans provided a complete account of the actions which TVA
undertook to improve its nuclear program for Browns Ferry.
The regulatory framework for the restart of Unit 2 after its
extended outage was unusual. TVA's submittal of the Browns Ferry
Nuclear Performance Plan and NRC's review and issuance of Safety
Evaluation Reports for each individual program was atypical.
While this level of NRC involvement did result in added
confidence for the approval of Unit 2 restart, it required
significant TVA and NRC resources for the approval of individual
programs and criteria. In most cases, TVA began the
implementation of these programs "at risk," which meant prior to
NRC approval. Significant redesign and additional modifications
were required whenever the criteria was changed during the
approval process. NRC evaluation of the BFNPP special programs
was documented by the issuance of issue specific Safety April 13, 2007 E1-2 Evaluation Reports (SERs) or in NUREG-1232, Volume 3, Safety Evaluation Report on the Browns Ferry Nuclear Performance Plan, and its supplements. Following implementation of these recovery
programs, Unit 2 returned to service on May 24, 1991, and was
removed from the Problem Plant List in June 1992.
TVA's proposed regulatory framework for the restart of Units
1 and 3 (Reference 1) was more consistent with normal industry
practice. The proposed programs were established to provide a
high degree of confidence that the facility and personnel were
ready to restart and operate Units 1 and 3 in a safe and reliable
manner, and promote the efficient utilization of TVA and NRC
resources. TVA's plans for the restart of Units 1 and 3 were
based on the regulatory requirements, corrective action programs, commitments, Technical Specifications improvements, and
internally identified deficiencies and concerns that were
resolved prior to the restart of Unit 2. NRC approval of the
framework for the restart of Units 1 and 3 was documented in
Reference 2. Changes to the implementation of BFNPP special
programs on Unit 3 was documented by the issuance of issue
specific SERs. The NRC Staff's request that the Commission
authorize the Region II Administrator to allow restart of Unit 3
was forwarded by SECY 95-264. Following restart plan completion
and NRC restart approval, Unit 3 restarted on November 19, 1995.
Units 1 and 3 were removed from the Watch List in June 1996.
Since restart of Unit 3, there were changes in regulations, TVA's
processes, and NRC's processes which warranted revision to the
regulatory framework for restart of Unit 1. TVA's successful
restart and operation of Units 2 and 3 and the proposed revision
to the Unit 1 restart program (References 3 and 4) will establish
a high degree of confidence that the facility and personnel are
ready to restart and operate Unit 1 in a safe and reliable
manner, and promote the efficient utilization of TVA and NRC
resources. TVA's plans for the restart of Unit 1 continue to be
based on the regulatory requirements, corrective action special
programs, commitments, Technical Specifications improvements, and
internally identified deficiencies and concerns that were
resolved prior to restart of Units 2 and 3. TVA proposed that, at its discretion, it could modify the implementation precedent
for BFNPP Special Programs to incorporate efficiencies or
experience gained from use of those precedents in restarting
Unit 3 or from changes in TVA internal processes.
As documented in the NRC's approval of TVA's proposed regulatory
framework (References 5 and 6), the staff requested and TVA
agreed to provide formal notification of the completion of each
generic communication within 90 days of its internal commitment
completion. This letter provides the process that will be used
to satisfy this request. Additional items for restart were also
identified in the NRC's Browns Ferry Unit 1 Recovery Issues List (Reference 7).
April 13, 2007 E1-3 This enclosure lists the individual issues cited in the framework letters and the NRC's Recovery Issues List, describes TVA's
commitment or outstanding action for each issue, references key
correspondence, discusses the background of the issue, and
describes the completion or status of each issue, as appropriate.
A summary of the issues that will be completed after restart for
Unit 1 is provided as Enclosure 2.
TVA intends to update this submittal until the Unit 1 commitments
related to restart or power operation are completed (TVA
committed actions are completed). Changes to the completion
status and newly added issues are bolded in the table of
contents. Changes to the completion status are also bolded in
the text which describes each item. In addition, the bottom of
each page will contain a stamp that will show the submittal date.
Other changes are noted by revision bars on the right hand side
of the page. These updates will provide the formal notification
of the completion of each Unit 1 Bulletin, Generic Letter, Nuclear Performance Plan Special Program, and TMI Action Item
required for restart and listed in the regulatory framework
letters. REFERENCES
- 1. TVA letter to NRC, dated July 10, 1991, Regulatory Framework for the Restart of Units 1 and 3 2. NRC letter to TVA, dated April 1, 1992, Return to Service of Browns Ferry, Units 1 and 3 3. TVA letter to NRC, dated December 13, 2002, Regulatory Framework for the Restart of Unit 1 4. TVA letter to NRC, dated February 28, 2003, Regulatory Framework for the Restart of Unit 1 5. NRC memorandum from K. N. Jabbour, dated May 13, 2003, Summary of April 24, 2003, Meeting Regarding the Regulatory
Framework for Browns Ferry Unit 1 Restart Project (TAC No.
MB7679) 6. NRC letter to TVA, dated August 14, 2003, Regulatory Framework for the Restart of Browns Ferry Nuclear Plant, Unit
1 7. NRC letter, J. W. Shea to K. W. Singer, dated January 6, 2006, Meeting Summaries: 1.) Category 1 Public Meeting with Tennessee Valley Authority (TVA) RE. Browns
Ferry Unit 1 Recovery Status; 2.) Meeting of the NRC Restart
Panel for the Browns Ferry Unit 1 Recovery - Docket No. 50-
259 April 13, 2007 E1-4 Bulletin 79-02, Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts
Commitment: TVA will complete Bulletin 79-02.
Discussion: TVA initiated programs in 1979 to comply with Bulletins 79-02 and 79-14 regarding the adequacy of
piping system supports and anchor bolts. BFN's
programs involved the reanalysis of pipe stress
problems using the as-built configuration and
amplified response spectra for Seismic Class I
structures and the evaluation of the acceptability
of the associated pipe supports. The scope of the
program included Unit 1 safety-related large bore (greater than 2 2 inches in diameter) piping and computer analyzed small bore piping that was not
included in the Small Bore Piping Program.
Pipe stress analysis and pipe support evaluations
are based on walkdown inspection data for the
safety-related piping systems. The walkdown
inspections were instituted to determine the actual
field configuration of the Class I piping systems
and supports. NRC approval of TVA's program for
the resolution of Bulletins 79-02 and 79-14 is
documented in Reference 1.
Status: C-C
Piping stress analysis and pipe support
calculations were prepared for Class I piping.
Where required, design modifications were
implemented.
NRC closed this item in Inspection Report 2006-009 (Reference 2).
References:
1.
NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 -
Browns Ferry, Unit 2, Section 2.2.3.1 (Page 2-8)
- 2. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-5 Bulletin 79-12, Short Period Scrams at BWR Facilities
Commitment: TVA will complete Bulletin 79-12.
Discussion: In response to Bulletin 79-12, TVA committed to perform unit and cycle specific analyses of control
rod withdrawal sequences in order to ensure that
rod notch worths were acceptable (References 1
and 2). In Reference 3, TVA notified NRC that it
was implementing the generic Banked Position
Withdrawal Sequence and Reduced Notch Worth
Procedure. The resulting withdrawal sequences
ensure that the notch worths are sufficiently small
so as to minimize the possibility of a fast period
scram. Therefore, cycle specific analyses of
control rod withdrawal sequences were no longer
required.
Status: C-C
The Banked Position Withdrawal Sequence and Reduced
Notch Worth Procedures have been incorporated into
plant procedures.
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated July 30, 1979, Office of Inspection and Enforcement Bulletin 79
RII:JPO 50-259, -260, -296 - Browns Ferry
Nuclear Plant Units 1, 2, and 3
- 2. TVA letter to NRC, dated August 19, 1981, Office of Inspection and Enforcement Bulletin 79
RII:JPO 50-259, -260, -296 - Browns Ferry
Nuclear Plant
- 3. TVA letter to NRC, dated January 4, 1990, Office of Inspection and Enforcement Bulletin 79
Commitment Revisions Regarding Fast Period
Scrams 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-6 Bulletin 79-14, Seismic Analysis for As-Built Safety-Related Piping Systems
Commitment: TVA will complete Bulletin 79-14.
Discussion: TVA initiated programs in 1979 to comply with Bulletins 79-02 and 79-14 regarding the adequacy of
piping system supports and anchor bolts. BFN's
programs involved the reanalysis of pipe stress
problems using the as-built configuration and
amplified response spectra for Seismic Class I
structures and the evaluation of the acceptability
of the associated pipe supports. The scope of the
program included Unit 1 safety-related large bore (greater than 2 2 inches in diameter) piping and computer analyzed small bore piping that was not
included in the Small Bore Piping Program.
Pipe stress analysis and pipe support evaluations
were based on walkdown inspection data for the
safety-related piping systems. The walkdown
inspections were instituted to determine the actual
field configuration of the Class I piping systems
and supports. NRC approval of TVA's program for
the resolution of Bulletins 79-02 and 79-14 is
documented in Reference 1.
Status: C-C
Piping stress analysis and pipe support
calculations were prepared for Class I piping.
Where required, design modifications were
implemented.
NRC closed this item in Inspection Report 2006-009 (Reference 2).
References:
1.
NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 -
Browns Ferry, Unit 2, Section 2.2.3.1 (Page 2-8)
- 2. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-7 Bulletin 80-06, Engineered Safety Feature (ESF) Reset Controls
Commitment: TVA will complete Bulletin 80-06.
Discussion: In Reference 1, TVA stated that the need for modification to the Traversing Incore Probe (TIP)
system was identified as a result of the reviews
performed for Bulletin 80-06. In Reference 2, TVA
committed to perform the modification to the TIP
system prior to restart.
Status: C-C
TVA modified TIP circuitry for ESF reset.
NRC closed this item in Inspection Report 2006-008 (Reference 3).
References:
1.
TVA letter to NRC, dated December 4, 1981, in Regards to Bulletin 80-06
Feature (ESF) Reset Control
- 3. NRC letter to TVA, dated November 9, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006008
April 13, 2007 E1-8 Bulletin 84-02, Failures of General Electric Type HFA Relays in Use in Class 1E Safety Systems
Commitment: TVA will replace relay coil spools in HFA relays in the reactor protection system (RPS) and other
safety systems.
Discussion: TVA responded to Bulletin 84-02 by Reference 1.
Status: Closed
NRC closed this item in Inspection Report 2004-009 (Reference 2).
References:
1.
TVA letter to NRC, dated July 10, 1984, Inspection and Enforcement Bulletin 84
Failures of General Electric Type HFA Relays in
Use in Class 1E Safety Systems - Browns Ferry, Sequoyah, Watts Bar, and Bellefonte Nuclear
Plants 2. NRC letter to TVA, dated February 11, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2004009
April 13, 2007 E1-9 Bulletin 86-02, Static "O" Ring Differential Pressure Switches
Commitment: TVA will complete Bulletin 86-02.
Discussion: TVA responded to Bulletin 86-02 by Reference 1.
Two Static "O" Ring (SOR) differential pressure
switches were installed (or planned for
installation) in the Residual Heat Removal (RHR)
system minimum flow recirculation lines. TVA
committed to:
- 1. Revise the RHR pump flow rate test to include steps to verify minimum flow switch operability;
- 2. Perform maintenance instructions semiannually until two consecutive tests were attained; and
- 3. Evaluate the SOR test report and adjust setpoints, as required.
Status: C-C
TVA installed two Static "O" Ring differential
pressure switches in the Unit 1 RHR system and the
RHR Pump Surveillance Instructions were revised to
include steps to verify proper switch operation.
TVA installed two Static "O" Ring differential
pressure switches in the Unit 1 Core Spray system
and the Core Spray Pump Surveillance Instructions
were revised to include steps to verify proper
switch operation.
The commitment to perform the maintenance
instruction semiannually has been evaluated in
accordance with the commitment management process
and deleted. NRC was notified of the commitment
deletion by Reference 2.
The SOR test report has been evaluated; the
accuracy values used for these switches are bounded
by the data used in the SOR test report.
NRC closed this item in Inspection Report 2005-06 (Reference 3).
References:
1.
TVA letter to NRC, dated July 20, 1987, NRC Office of Inspection and Enforcement (IE)
Bulletin 86 Static "O" Ring (SOR)
Differential Pressure Switches April 13, 2007 E1-10
Static-O-Ring Differential Pressure Switches and
Voltage Verification Testing of Reactor
Protective System Equipment
- 3. NRC letter to TVA, dated May 16, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005006
April 13, 2007 E1-11 Bulletin 88-03, Inadequate Latch Engagement in HFA Type Relays Manufactured by General Electric (GE) Company
Commitment: TVA will complete Bulletin 88-03.
Discussion: TVA originally responded to Bulletin 88-03 in Reference 1. TVA stated the BFN inspections and
the repair or replacement of the relays which fail
the inspection criteria are scheduled to be
completed before restart of each unit. In
Reference 2, NRC closed Bulletin 88-03. However, TVA was still required to notify the NRC of
inspection results for Unit 1.
Status: Closed
NRC closed this item in Inspection Report 2004-009 (Reference 3).
References:
1.
TVA letter to NRC, dated July 6, 1988, Nuclear Regulatory Commission (NRC)Bulletin 88-03, Inadequate Latch Engagement in HFA-Type Latching
Relays Manufactured by General Electric (GE)
Company 2. NRC letter to TVA, dated August 2, 1990, Closure of NRC Bulletin 88-03 for the Browns Ferry
Nuclear Plant (TAC Nos. 73852, 73853, and 73854)
- 3. NRC letter to TVA, dated February 11, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2004009 April 13, 2007 E1-12 Bulletin 88-04, Potential Safety-Related Pump Loss
Commitment: TVA will complete Bulletin 88-04.
Discussion: NRC Bulletin 88-04 requested licensees to investigate and correct, as applicable, two
miniflow design concerns for safety-related system
pumps. The first concern involved the potential
for dead-heading one or more pumps. The second
concern was whether or not the installed miniflow
capacity was adequate.
TVA responded to the Bulletin (Reference 1),
endorsing the BWR Owners Group response and
providing BFN specific information. NRC requested
additional information in Reference 2, which was
provided by TVA in Reference 3. Reference 4
documents NRR closure of this issue for Unit 1.
NRC addressed this issue for Unit 1 in Inspection
Report 95-31 (Reference 5). TVA notified NRC that
its actions were complete in Reference 6.
Status: C-C
NRC closed this item in Inspection Report 2004-009 (Reference 7).
References:
1.
Letter from TVA to NRC dated September 30, 1988, Browns Ferry (BFN), Watts Bar (WBN), and
Bellefonte (BLN) Nuclear Plants - NRC Bulletin (NRCB) 88-04, Potential Safety-Related Pump Loss
- 2. Letter from NRC to TVA dated March 1, 1989, Response to NRC Bulletin 88 Browns Ferry
Nuclear Plant, Units 1, 2, and 3
Additional Response to NRC Bulletin 88-04 (NRCB 88-04) - Potential Safety-Related Pump
Loss 4. Letter from NRC to TVA, dated May 8, 1989, Response to NRC Bulletin 88 Browns Ferry
Nuclear Plant, Units 1 and 3
- 5. NRC letter to TVA, dated June 28, 1995, NRC Inspection Report 95-31 [Section 7.b., page 18]
April 13, 2007 E1-13
NRC Bulletin 88-04, Potential Safety-Related
Pump Loss
- 7. NRC letter to TVA, dated February 11, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2004009 April 13, 2007 E1-14 Bulletin 88-07, Power Oscillations in Boiling Water Reactors, and Supplement 1
Commitment: TVA will complete Bulletin 88-07.
Discussion: TVA responded to Bulletin 88-07 by Reference 1 and confirmed that the actions required by the Bulletin
were implemented. TVA responded to Supplement 1 to
Bulletin 88-07 by Reference 2 and confirmed its
plans to implement the General Electric interim
stability recommendations. The proposed Technical
Specification changes to implement the reactor core
thermal-hydraulic stability recommendations
contained in Supplement 1 to Bulletin 88-07 were
provided by Reference 3 and approved in
Reference 4.
Status: C-C
Refer to the topic entitled Generic Letter 94
Long-Term Solutions and Upgrade of Interim
Operating Recommendations for Thermal-Hydraulic
Instabilities in Boiling Water Reactors for
additional actions TVA has taken to address this
issue.
NRC closed this item in Inspection Report 2006-007 (Reference 5).
References:
1.
TVA letter to NRC, dated November 4, 1988, NRC Bulletin 88-07: Power Oscillations in Boiling
Water Reactors
- 2. TVA letter to NRC, dated March 6, 1989, NRC Bulletin 88-07, Supplement 1 - Power
Oscillations in Boiling Water Reactors (BWRs)
Core Thermal-Hydraulic Stability
- 4. NRC letter to TVA, dated May 31, 1994, Issuance of Technical Specification Amendments for the
Browns Ferry Nuclear Plant Units 1 and 3 (TS 300) 5. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-15 Bulletin 88-10, Nonconforming Molded-Case Circuit Breakers
Commitment: TVA will complete Bulletin 88-10.
Discussion: TVA provided a revised response to Bulletin 88-10 in Reference 1. TVA stated that it had completed
itsBulletin 88-10 effort for Units 1, 2 and 3.
TVA had removed the Class 1E Molded Case Circuit
Breakers (MCCBs) without adequate traceability from
installed service and the warehouse. NRC closed
this Bulletin for Unit 1 in Reference 2.
Status: C-C
For Unit 1, TVA has removed the Class 1E MCCBs
which did not have adequate traceability from both
installed service and the warehouse.
NRC closed this item in Inspection Report 2005-009 (Reference 3).
References:
1.
TVA letter to NRC, dated November 29, 1990, Browns Ferry Nuclear Plant (BFN) - Revised
Response and Notification of Implementation of
NRC Bulletin 88-10 Nonconforming Molded Case
Circuit Breakers (MCCBs)
- 2. NRC letter to TVA, dated March 10, 1992, NRC Inspection Report Nos. 50-259/92-03,
50-260/92-03, and 50-296/92-03)
- 3. NRC letter to TVA, dated February 13, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005009 April 13, 2007 E1-16 Bulletin 90-01, Loss of Fill Oil in Transmitters Manufactured by Rosemount
Commitment: TVA will complete Bulletin 90-01.
Discussion: TVA originally responded to Bulletin 90-01 in Reference 1. TVA responded to Supplement 1 to
Bulletin 90-01 in Reference 2. The commitments
made in Reference 2 superseded the commitments made
in Reference 1. In Reference 2, TVA stated that it
would formally notify the NRC of the proposed
resolution of the Rosemount transmitter issue for
Unit 1 prior to Unit 1 startup. NRC's Safety
Evaluation (Reference 3) applied to all three units
but stated additional information would be required
on Unit 1.
In Reference 4, TVA notified NRC of its plan to
replace the BFN Unit 1 Rosemount transmitters that
meet the criteria specified in NRC Bulletin 90-01, Supplement 1 with new or refurbished transmitters
prior to Unit 1 restart. NRC found TVA's response
acceptable in Reference 5.
Status: C-C TVA has replaced the BFN Unit 1 Rosemount
transmitters that meet the criteria specified in
NRC Bulletin 90-01, Supplement 1 with new or
refurbished transmitters.
NRC closed this item in Inspection Report 2005-009 (Reference 6).
April 13, 2007 E1-17
References:
1.
TVA letter to NRC, dated July 18, 1990, Response to NRC Bulletin No. 90-01: Loss of Fill-Oil in
Transmitters Manufactured by Rosemount
- 2. TVA letter to NRC, dated March 5, 1993, Response to NRC Bulletin No. 90-01, Supplement 1 - Loss
of Fill Oil in Transmitters Manufactured by
Rosemount
- 3. NRC letter to TVA, dated April 4, 1995, NRC Bulletin 90-01, Supplement 1, Loss of Fill-Oil
in Transmitters Manufactured by Rosemount -
Browns Ferry Nuclear Plant Units 1, 2, and 3 (TAC Nos. M85361, M85362, and M85363)
NRC Bulletin no. 90-01, Supplement 1 - Loss of
Fill Oil in Transmitters Manufactured by
Rosemount
- 5. NRC letter to TVA, dated February 7, 2005, Browns Ferry Nuclear Plant, Unit 1 - Closeout of
Bulletin 90-01, Supplement 1, Loss of Fill-Oil
in Transmitters Manufactured by Rosemount (TAC No. MC3381)
- 6. NRC letter to TVA, dated February 13, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005009
April 13, 2007 E1-18 Bulletin 93-02, Debris Plugging of Emergency Core Cooling Suction Strainers, and Supplement 1
Commitment: TVA will complete Bulletin 93-02 and Supplement 1 prior to restart.
Discussion: TVA responded to Bulletin 93-02 in Reference 1 and committed to:
- 1. Evaluate Unit 1 for permanent fibrous material.
- 2. Inspect Unit 1 and remove temporary fibrous material.
- 3. Confirm completion of the above listed activities before startup.
In TVA's response to Supplement 1 of Bulletin 93-02 (Reference 2), TVA committed to augment the
operator's required reading program, conduct
classroom and/or simulator training, revise
appendices in BFN's Emergency Operating
Instructions (EOIs) to include caution statements
and actions for monitoring net positive suction
head, and change the applicable design control
procedure to require evaluation of fibrous material
being introduced into the drywell.
In Reference 3, NRC stated that TVA's response to
Supplement 1 adequately addressed the actions TVA
would take to assure continued Emergency Core
Cooling System (ECCS) suction capability. TVA
notified NRC of the completion of the commitments
made in response to Supplement 1 of Bulletin 93-02
for all three units in Reference 4.
TVA updated its response to the Bulletin for Unit 1
in Reference 5.
Status: C-C
TVA has evaluated the drywell for permanent fibrous
material. The results were similar to Units
2 and 3. Limited amounts of fibrous material are
permanently installed in several containment
penetrations. Also, in accordance with the Units 2
and 3's precedent, TVA has revised its Unit 1
General Operating Instruction on Drywell Closeout
to ensure temporary fibrous air filters or other
temporary sources of fibrous material are removed.
April 13, 2007 E1-19 Inspection Report 2006-006 (Reference 6) stated "-
However, final closure of this item will be
deferred until NRR completes their review in this
area and any SERs, if required, are issued."
In a letter dated July 26, 2006 (Reference 7), NRR
issued an SER concluding BFN has satisfied this
Bulletin.
NRC closed this item in Inspection Report 2006-008 (Reference 8).
References:
1.
TVA letter to NRC, dated May 23, 1993, NRC Bulletin No. 93-02, Debris Plugging of Emergency
Core Cooling Suction Strainers
- 2. TVA letter to NRC, dated April 18, 1994, NRC Bulletin 93-02, Supplement 1 - Debris Plugging
of Emergency Core Cooling System (ECCS) Suction
Strainers
- 3. NRC letter to TVA, dated July 19, 1994, Response to NRC Bulletin 93 Supplement 1, Debris
Plugging of Emergency Core Cooling Suction
Strainers
- 4. TVA letter to NRC, dated July 29, 1994, NRC Bulletin 93-02, Supplement 1 - Debris Plugging
of Emergency Core Cooling System (ECCS) Suction
Strainers - Commitment Completion
Response to NRC Bulletin No. 93-02, Debris
Plugging of Emergency Core Cooling Suction
Strainers
- 6. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006006
- 7. NRC Letter To TVA, dated July 26, 2006, Browns Ferry Nuclear Plant, Unit 1 - Review Of Licensee
Response To NRC Bulletin 93-02, "Debris Plugging
of Emergency Core Cooling Suction Strainers" (TAC No. Mc3393)
- 8. NRC letter to TVA, dated November 9, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006008
April 13, 2007 E1-20 Bulletin 93-03, Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs
Commitment: TVA intends to complete a modification which will prevent the buildup of non-condensibles in water
level reference legs by injecting CRD system
charging water into the reference legs.
Discussion: TVA's response to Bulletin 93-03 was provided by Reference 1. TVA committed to perform
modifications on Unit 1 prior to restart. NRC
accepted TVA's response to the Bulletin in
Reference 2. A detailed description of the
modification installed on Unit 2 was provided in
Reference 3.
Status: C-C
TVA completed the described modification.
NRC closed this item in Inspection Report 2006-009 (Reference 4).
References:
1.
TVA letter to NRC, dated July 30, 1993, Response to NRC Bulletin (NRCB) 93-03, Resolution of
Issues Related to Reactor Vessel Water Level
Instrumentation in Boiling Water Reactors
- 2. NRC letter to TVA, dated April 20, 1994, Browns Ferry Nuclear Plant Units 1, 2, and 3 - Response
To NRC Bulletin 93-03, "Resolution of Issues
Related to Reactor Vessel Water Level
Instrumentation in BWRs," (TAC Nos. M86882, M86883, and M86884)
- 3. TVA letter to NRC, dated December 14, 1994, Hardware Modification Completion and Description
in Response to Bulletin 93-03, Resolution of
Issues Related to Reactor Vessel Water Level
Instrumentation in Boiling Water Reactors
- 4. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-21 Bulletin 95-02, Unexpected Clogging of a Residual Heat Removal (RHR) Pump Strainer While Operating in
Suppression Pool Cooling Mode
Commitment: Appropriate actions will be taken prior to Unit 1 restart.
Discussion: TVA's response to Bulletin 95-02 was provided in Reference 1. For Units 2 and 3, TVA committed to
clean the suppression pool and perform confirmatory
inspection and test prior to restart. TVA also
committed to perform a visual inspection of the
Emergency Core Cooling System pump suction
strainers during each refueling outage and a
program for suppression pool cleaning will be
developed prior to restart. TVA stated that the
programs established to ensure Emergency Core
Cooling System pump operability on Units 2 and 3
would apply to Unit 1 when it was returned to
service. NRC found TVA's response acceptable in
Reference 2.
Status: C-C
The Unit 1 suppression pool was drained, cleaned, inspected and recoated as necessary. Program to
ensure suppression pool cleanliness and control of
foreign material has been implemented.
NRC closed this item in Inspection Report 2006-006 (Reference 3).
References:
1.
TVA letter to NRC, dated November 15, 1995, Browns Ferry Nuclear Plant (BFN) - NRC Bulletin
95-02, Unexpected Clogging of a Residual Heat
Removal (RHR) Pump Strainer While Operating In
Suppression Pool Cooling Mode
- 2. NRC letter to TVA, dated March 14, 1996, Browns Ferry Nuclear Plant Units 1, 2, and 3 - Response
to Bulletin 95-02 (TAC Nos. M93876, M93877, and
M93878) 3. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006006
April 13, 2007 E1-22 Bulletin 96-03, Potential Plugging of Emergency Core Cooling Suction Strainers By Debris In Boiling-Water
Reactors Commitment: Appropriate modifications to addressBulletin 96-03 will be implemented on Unit 1 prior to its restart.
Discussion: TVA originally responded to the Bulletin in Reference 1 and committed to describing planned
actions and schedules to be utilized to resolve the
Bulletin within 90 days following the approval of
the Utility Resolution Guidelines. TVA described
its plans for resolution of the Bulletin in
Reference 2 and committed to resolve the Bulletin
prior to restart for Unit 1.
Status: C-C
TVA has installed new, high capacity passive
strainers on Unit 1, which are of the same design
as on Units 2 and 3.
NRC closed this item in Inspection Report 2006-009 (Reference 3).
References:
1.
TVA letter to NRC, dated November 4, 1996, Browns Ferry Nuclear Plant (BFN) - NRC Bulletin
No. 96-03, Potential Plugging of Emergency Core
Cooling Suction Strainers by Debris in
Boiling-Water Reactors (TAC Nos. M96135, M96136, M96137) 2. TVA letter to NRC, dated July 25, 1997, Browns Ferry Nuclear Plant (BFN) - NRC Bulletin No.
96-03, Potential Plugging of Emergency Core
Cooling Suction (ECCS) Strainers by Debris in
Boiling Water Reactors (TAC Nos. M96135, M96136, M96137) 3. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-23 Cable Ampacity Commitment: The cable ampacity issue will be resolved in accordance with the Unit 2 precedent.
Discussion: TVA developed a new electrical design standard to address ampacities for cables in conduits, cable
trays, and duct banks, as well as derating factors
for cable coatings, fire wraps, cable tray covers, and cable tray bottoms. Approval of this program
is contained in NUREG-1232 (Reference 1).
Status: Complete
TVA has resolved the cable ampacity issue.
References:
1.
NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 -
Browns Ferry Unit 2 [Section 3.11.3, Page 3-9]
April 13, 2007 E1-24 Cable Installation Issue Number 1, Brand Rex Cable Issues Commitment: To resolve the Brand Rex cable issue, corrective actions will be implemented prior to the restart of
Unit 1 in accordance with the Unit 2 precedent.
Discussion: The action plan to disposition concerns related to cable installation issues, including Brand Rex, was
provided in Reference 1. The Safety Evaluation on
this program was provided by Reference 2. In
summary, the Staff found implementing the
corrective actions for the Brand Rex cable issue in
accordance with the Unit 2 precedent to be
acceptable pending the results of additional
qualification testing being performed by TVA.
TVA has identified contract number 80K6-825419 as
the source of the Brand Rex cables issue for BFN.
Additional testing demonstrated the ability of the
cables to perform their intended safety function
for a qualified life of 40 years. TVA has removed
all non-installed Brand Rex cable furnished on
contract 80K6-825419. Administrative controls are
in place to prevent future applications of this
cable type and manufacturer from being installed at
BFN.
Status: Open
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Cable Installation and Separation Issues
April 13, 2007 E1-25 Cable Installation Issue Number 2, Cable Separations Issues
Commitment: TVA committed to the following:
- 1. Prior to fuel load of Unit 1, TVA will implement all corrective actions in accordance
with the Unit 2 criteria and implementation
precedent for the following cable separations
issues:
- V4 and V5 cables which originate from safety-related power supplies,
- Nondivisional V4 and V5 cables which originate from nonsafety-related power
supplies,
- V3 cables which originate from safety-related and from nonsafety-related
power supplies,
- Nondivisional V1 and V2 cables which originate from both safety-related and
nonsafety-related power supplies,
- Divisional and nondivisional cables designated with an IE and IES suffix, and
- Divisional V1 and V2 cables. 2. As documented in References 1 through 6, Unit 2 validated the use of the cable schedule
drawings (45C800 series) in determining the
installed configuration of cables in the plant.
Unit 1 cables were included in the population
of cables that were used in the validation
process during the Unit 2 restart effort. As
documented in Reference 7, the Unit 1 cables
have always been routed manually. The Unit 1
circuit schedule was not an electronic
database. Therefore, TVA will use the 45C800
series drawings as the document of record in
the determination of acceptable routing for
Unit 1.
April 13, 2007 E1-26
- 3. The Unit 1 Master Equipment List (MEL) will establish the list of equipment and device IDs
for safety-related and quality-related systems.
For nondivisional V1, V2, V3, V4 and V5 cables
identified in the MEL as safety-related for
Unit 1, cable separation issues will be
resolved by analyzing design drawings to
identify cables required to support the
safety-related and quality-related devices.
The resulting list will be compared against the
45C800 drawings to determine if cables are
correctly identified as divisional. If it is
determined that a change in divisional status
is required, the respective cables will be
evaluated against separations criteria.
Corrective actions will be completed prior to
fuel load.
- 4. For cables contained in divisional and nondivisional cable trays that physically
connect on Unit 1, corrective actions will be
implemented prior to Unit 1 fuel load.
Discussion: TVA had identified instances where the electrical separation requirements had not been met at BFN.
The Units 1 and 3 specific action plan to
disposition concerns related to cable installation
issues, including cable separation, was provided
in Reference 1. The Safety Evaluation on this
program was provided by Reference 2. Additional
information was requested regarding the corrective
actions to be implemented for discrepancies
associated with the two cables contained in
divisional and nondivisional cable trays that
physically connect. This additional information
was provided by TVA in Reference 3. The NRC Staff
accepted this information in Reference 4.
Status: Complete
Evaluations have been completed and noted
discrepancies have been completed.
April 13, 2007 E1-27
References:
1.
TVA letter to NRC, dated January 6, 1989, Browns Ferry Nuclear Plant (BFN) - Electrical
Cable Separation
Separation
Cable Separation
Cable Separation
- 5. NRC letter to TVA, dated February 23, 1990, NRC Inspection Report No. 50-260/89-59
- 6. NRC letter to TVA, dated August 10, 1990, NRC Inspection Report No. 50-260/90-13
- 7. TVA letter to NRC, dated December 29, 1992, Response to Request for Additional Information
on Electrical Cables in Divisional and
Nondivisional Trays Which Are Physically
Connected
April 13, 2007 E1-28 Cable Installation Issue Number 3, Low Voltage Vertical Cable Supports Commitment: TVA will resolve the low voltage vertical cable supports issue in accordance with the Unit 2
precedent.
Discussion: The action plan to disposition concerns related to cable installation issues, including vertical cable
supports, was provided in Reference 1. The Safety
Evaluation on this program was provided by
Reference 2. In summary, since no Unit 2 cables
with acceptable sidewall bearing pressure failed
Hi-Pot testing, the walkdown and evaluation of
Unit 1 safety-related low voltage power, control
and instrumentation cable is adequate to
satisfactorily resolve the vertical support issue.
Status: Open
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Cable Installation and Separation Issues
April 13, 2007 E1-29 Cable Installation Issue Number 4, Medium Voltage Cable Bend Radius Commitment: Safety-related medium voltage cables will be identified, walked down and evaluated against the
bend radius criteria used for Unit 2 (General
Construction Specification G-38). The following
corrective actions will be completed:
A. Group 1 cables with bend radius of less than 6 times the cable outside diameter (OD) will be
replaced.
B. Group 2 cables with bend radius from 6 times the cable OD to less than 8 times the cable OD will
be tested prior to restart and during subsequent
outages to facilitate a trend analysis.
C. Group 3 cables, with bend radius 8 times or greater than the cable OD will be allowed to
remain in service and be subjected to only
normal maintenance testing.
Discussion: The action plan to disposition concerns related to cable installation issues, including medium voltage
cable bend radius, was provided in Reference 1.
The Safety Evaluation of this program was provided
by Reference 2. In summary, since safety-related
medium voltage cables are to be identified, walked
down and evaluated against the bend radius
acceptance criteria contained in Construction
Specification G-38 and dispositioned in accordance
with the same criteria used for Unit 2, the
proposed corrective actions are adequate.
In Reference 3, TVA proposed a new program and
corrective actions for medium cable bend radius
issues. Results of reinspections were presented to
NRC and Hi-Pot testing was replaced with Load Cycle
and Corona Testing. Additional information
regarding the revised program was requested in
Reference 4, which was provided by TVA in
Reference 5. NRC issuance of a Safety Evaluation
for this program and a request for additional
information was contained in Reference 6. TVA
replied in Reference 7, and the Supplemental Safety
Evaluation Report was provided in Reference 8.
Status: Open
April 13, 2007 E1-30
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Cable Installation and Separation Issues
- 3. TVA letter to NRC, dated March 17, 1993, Medium Voltage Cable Bend Radius Issues
- 4. NRC letter to TVA, dated August 23, 1993, Request for Additional Information Regarding
Medium Voltage Cable Bend Radius
- 5. TVA letter to NRC, dated January 10, 1994, Response to Request for Additional Information
Regarding Medium Voltage Cable Bend Radius
- 6. NRC letter to TVA, dated July 1, 1994, Safety Evaluation and Request for Additional
Information Regarding Medium Voltage Cable Bend
Radius Issues
- 7. TVA letter to NRC, dated September 15, 1994, Reply to NRC Request for Additional Information (RAI) Regarding Medium Voltage Cable Bend Radius
Issues 8. NRC letter to TVA, dated January 9, 1995, Supplemental Safety Evaluation for Medium
Voltage Cable Bend Radius
April 13, 2007 E1-31 Cable Installation Issue Number 5, Missing Conduit Bushings
Commitment: Type PN cables in 10 CFR 50.49 circuits will be replaced under the Environmental Qualification
program.
Discussion: The action plan to disposition concerns related to cable installation issues, including missing
conduit bushings, was provided in Reference 1. The
Safety Evaluation on this program was provided by
Reference 2. In summary, the only cables found
damaged on Unit 2 as a result of pulling the cables
over a conduit end with a missing bushing were the
Type PN. Replacing this type of cable in Unit 1
10 CFR 50.49 circuits was considered adequate to
resolve this issue.
Status: Open
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Cable Installation and Separation Issues
April 13, 2007 E1-32 Cable Installation Issue Number 6, Sidewall Pressure, Cable Pullbys, Cable Jamming, Pulling Around 90 Degree
Condulets and Thru Mid-Run
Flex Conduit Issues
Commitment: The cables identified in the Master Equipment List (MEL) as safety-related cables for Unit 1, which are not replaced by other programs, will be
reviewed to determine the configuration of their
associated raceway. If the design of the raceway
meets the criteria for sidewall pressure, jamming, pullbys, mid-run flex or pulling around 90 degree
condulet concerns, a walkdown will be performed to
confirm the installed configuration. Confirmatory
walkdowns will be completed prior to Unit 1
restart.
Discussion: The action plan to disposition concerns related to cable installation issues, including sidewall
pressure, cable pullbys, cable jamming, pulling
around 90 degree condulets and thru mid-run flex
conduit issues, was provided in Reference 1.
Information regarding cable walkdowns and cable
routing system database validation was provided in
Reference 2.
A Safety Evaluation on cable installation and
separation and request for additional information
on divisional/nondivisional separation
discrepancies was provided in Reference 3. In
summary, cable damage was not identified on Unit 2
during the resolution of the sidewall pressure, cable pullbys, cable jamming and pulling around
90-degree condulets and through mid-run flex
conduits issues.
Status: Open
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Units 1 and 3 Cable Installation Issues
Including Cable Separations
Cable Installation and Separation Issues
April 13, 2007 E1-33 Cable Installation Issue Number 7, Use of Condulets as Pull Points Commitment: The 600V safety-related cables that are susceptible to damage from the use of condulets as pull points
will be resolved in accordance with the Unit 2
precedent.
Discussion: The action plan to disposition concerns related to cable installation issues, including the use of
condulets as pull points, was provided in
Reference 1. The Safety Evaluation on this program
was provided by Reference 2. In summary, TVA's
evaluation of this issue for Unit 2 determined that
the type of conduit configurations susceptible to
this problem was limited to several cases of large
600 volt cables in three inch conduits. Therefore, TVA will review the Unit 1 600 volts cables
installed in conduit in accordance with the Unit 2
program guidelines / The required corrective
actions will be completed prior to fuel load.
Status: Open
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Cable Installation and Separation Issues
April 13, 2007 E1-34 Cable Installation Issue Number 8, Medium Voltage Vertical Cable Supports Commitment: The medium voltage vertical cable supports issue will be resolved by evaluating cables not meeting
the vertical cable support criteria for static
sidewall bearing pressure (SSBP). Cables with
unacceptable SSBP will be Hi-Pot tested. Cables
passing the Hi-Pot test will be supported in
accordance with G-38. Cables failing the
Hi-Pot test will be replaced.
Discussion: The action plan to disposition concerns related to cable installation issues, including medium voltage
vertical cable supports, was provided in
Reference 1. The Safety Evaluation on this program
was provided by Reference 2. In summary, since no
Unit 2 cables with acceptable sidewall bearing
pressure failed Hi-Pot testing, the walkdowns and
evaluation of Class 1E medium voltage cables is
adequate to satisfactorily resolve the vertical
support issue.
Status: Open
References:
1.
TVA letter to NRC, dated May 10, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Installation Issues Including Cable
Separations
Cable Installation and Separation Issues
April 13, 2007 E1-35 Cable Splices
Commitment: TVA will identify Class IE cable splices located in harsh environment and ensure they are qualified for
their intended service during a design basis
accident (DBA).
Discussion: TVA's program to resolve the splice issue was submitted in Reference 1. TVA performed a field
walkdown of safety-related conduits to identify and
document Class 1E cable splices which are required
to be environmentally qualified and to verify the
installed splice configuration. The field data was
evaluated against construction specification
requirements to determine which splices require
rework. Actions were taken to either rework the
splice or rework both the splice and raceway system
to accommodate a qualified splice.
Status: Complete
References:
1.
TVA letter to NRC, dated April 28, 1988, Browns Ferry Nuclear Plant (BFN) - Electrical Issues (NRC TAC No. 62260)
April 13, 2007 E1-36 Cable Tray Supports
Commitment: TVA intends to utilize the Seismic Qualification Utility Group (SQUG) Generic Implementation
Procedure (GIP) for seismic qualification of cable
trays.
Discussion: The original action plan to disposition concerns related to Unit 1 cable tray supports was provided
in Reference 1. However, due to the issuance of
Supplement 1 to Generic Letter 87-02, Verification
of Seismic Adequacy of Mechanical and Electrical
Equipment in Operating Reactors, Unresolved Safety
Issue (USI) A-46, BFN submitted a revised program
in order to take advantage of the NRC approved
process for resolving USI A-46 (Reference 2). NRC
accepted the schedule for implementing the revised
program for Unit 1 in Reference 3 and requested
additional information regarding the revised
methodology and criteria. This information was
provided in Reference 4 and accepted by NRC in
Reference 5.
Status: C-C
The Unit 1 cable tray supports have been evaluated
utilizing the GIP in accordance with USI A-46. A
summary report was provided to NRC in Reference 6.
Necessary modifications and repairs have been
completed.
NRC closed this item in document dated
March 9, 2007 (Reference 7).
References:
1.
TVA letter to NRC, dated March 27, 1991, Action Plan to Disposition Concerns Related to Units 1
and 3 Cable Tray Supports
- 2. TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical
and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and
Supplement 4 to Generic Letter 88-20, Individual
Plant Examination of External Events (IPEEE) for
Severe Accident Vulnerabilities
- 3. NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response -
Browns Ferry Nuclear Plant April 13, 2007 E1-37
- 4. TVA letter to NRC, dated January 19, 1993, Generic Letter (GL) 87-02, Supplement 1, 120-Day
Response, Request for Additional Information
- 5. NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response - Browns
Ferry Nuclear Plant
NRC Generic Letter (GL) 87-02, Supplement 1 that
Transmits Supplemental Safety Evaluation Report
No. 2 (SSER No. 2) on SQUG Generic
Implementation Procedure, Revision 2, as
corrected on February 14, 1992 (GIP-2)
- 7. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-38 Component and Piece Part Qualification
Commitment: TVA will implement a component and piece part qualification program.
Discussion: In Reference 1, TVA provided a change in methodology in performing the component and piece
part qualification for safety-related components in
10 CFR 50.49 applications. TVA proposed to use
statistical sampling techniques to achieve a 95/95
confidence level of qualification adequacy as
opposed to the 100% verification performed for
Unit 2. Additional information was requested by
the NRC Staff in Reference 2, which was provided by
TVA in Reference 3. In Reference 4, NRC responded
that this issue would be addressed by inspection
rather than a revision to the Safety Evaluation.
Since this correspondence, TVA decided to perform
a 100% verification as performed on Unit 2.
Status: Complete
The Unit 1 component and piece part qualification
program for safety-related components in
10 CFR 50.49 applications has been implemented.
References:
1.
TVA letter to NRC, dated June 12, 1992, Request for Revision to Safety Evaluation Issued by NRC
on January 10, 1990, Related to Component and
Piece Part Qualification Plan
- 2. NRC letter to TVA, dated October 29, 1992, Request for Additional Information Regarding
Browns Ferry Nuclear Plant Units 1 and 3
Component and Piece Parts Qualification Program
Regarding BFN Units 1 and 3 Component and Piece
Parts Qualification Plan
- 4. NRC letter to TVA, dated December 7, 1993, Browns Ferry Nuclear Plant Units 1 and 3
Component and Piece Parts Qualification Program
April 13, 2007 E1-39 Conduit Supports
Commitment: TVA intends to utilize the Seismic Qualification Utility Group (SQUG) Generic Implementation
Procedure (GIP) for seismic qualification of
conduit supports.
Discussion: The original action plan to disposition concerns related to Unit 1 conduits and conduit supports was
provided in References 1 through 3 and approved in
Reference 4. However, due to the issuance of
Supplement 1 to Generic Letter 87-02, Verification
of Seismic Adequacy of Mechanical and Electrical
Equipment in Operating Reactors, Unresolved Safety
Issue (USI) A-46, BFN submitted a revised program
in order to take advantage of the NRC approved
process for resolving USI A-46 (Reference 5). NRC
requested additional information regarding the
schedule for implementing the revised program in
Reference 6.
In Reference 7, TVA committed to implement the
long-term qualification of conduits and conduit
supports prior to Unit 1 restart. In Reference 8, NRC determined that it was acceptable for TVA to
complete the portion of its USI A-46 program that
pertain to conduits and conduit supports, prior to
Unit 1 restart in lieu of its prior restart
commitments.
Status: C-C
The Unit 1 conduit supports have been evaluated
utilizing the GIP in accordance with USI A-46.
A summary report was provided to NRC in
Reference 9. Necessary modifications and repairs
have been completed.
NRC closed this item in document dated
March 9, 2007 (Reference 10).
References:
1.
TVA letter to NRC, dated May 6, 1991, Program for Resolving Conduit and Conduit Supports Issue
Prior to the Restart of Units 1 and 3
Support Plans for Units 1 and 3 - Additional
Information April 13, 2007 E1-40
- 3. TVA letter to NRC, dated January 29, 1992, Action Plan to Disposition Concerns Related to
Units 1 and 3 Conduit and Conduit Support -
Additional Information
- 4. NRC letter to TVA, dated March 20, 1992, Safety Evaluation of Action Plan to Resolve Conduit and
Conduit Supports Issues for the Browns Ferry
Nuclear Plant Units 1 and 3
- 5. TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical
and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and
Supplement 4 to Generic Letter 88-20, Individual
Plant Examination of External Events (IPEEE) for
Severe Accident Vulnerabilities
- 6. NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response -
Browns Ferry Nuclear Plant
- 7. TVA letter to NRC, dated January 19, 1993, Generic Letter (GL) 87-02, Supplement 1, 120-Day
Response, Request for Additional Information
- 8. NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response - Browns
Ferry Nuclear Plant
NRC Generic Letter (GL) 87-02, Supplement 1 that
Transmits Supplemental Safety Evaluation Report
No. 2 (SSER No. 2) on SQUG Generic
Implementation Procedure, Revision 2, as
corrected on February 14, 1992 (GIP-2) 1 0. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-41 Configuration Management/Design Baseline
Commitment: The Unit 1 Design Baseline Verification Program (DBVP) will consolidate the two-phase (pre- and
post-restart) approach performed on Unit 2.
Discussion: The objective of the DBVP was to re-establish the design basis and evaluate the plant configuration
to ensure that it satisfies the design basis. The
DBVP, including a discussion of lessons learned
from the Unit 2 precedent, was provided in
Reference 1. In Reference 2, NRC determined that
this commitment was more comprehensive than that
accepted by the staff for Unit 2, and was therefore
acceptable.
Status: C-C
Unit 1 satisfies its design basis, safety related
structures, systems, and components are supported
by engineering analysis and documentation, and the
plant configuration is in conformance with TVA's
commitments.
NRC closed this item in document dated
March 9, 2007 (Reference 3).
References:
1.
TVA letter to NRC, dated June 13, 1991, Design Baseline Verification Program (DBVP)
- 2. NRC letter to TVA, dated November 21, 1991, Assessment of Browns Ferry Nuclear Plant, Units 1 and 3 Design Baseline Verification
Program 3. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-42 Containment Coatings
Commitment: The containment coating program will be implemented in accordance with the Unit 2 precedent.
Discussion: The containment coatings program was described in the Nuclear Performance Plan (Reference 1). TVA
performed walkdown inspections of unqualified
coating on components installed inside primary
containment on Unit 2 to baseline the uncontrolled
coating log. An analysis was performed to
determine the maximum allowable quantity of coating
debris which could be transported to the suction
strainers without affecting the ability of the ECCS
pumps to perform their post-Loss of Coolant
Accident (LOCA) function. Corrective actions were
taken to ensure that the amount of unqualified
coating is maintained below the maximum allowable
quantity. NRC approval of the program is
documented in Reference 2.
Status: Complete
The containment coatings program was completed, and
the Uncontrolled Coatings Log was issued.
References:
1.
TVA letter to NRC, dated October 24, 1988, Browns Ferry Nuclear Plant (BFN) - Nuclear
Performance Plan, Revision 2
- 2. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 - Browns
Ferry, Unit 2, Section 3.7 (Page 3-7)
April 13, 2007 E1-43 Control Rod Drive (CRD) Insert and Withdrawal Piping
Commitment: The seismic qualification of the CRD insert and withdrawal piping will be implemented in accordance
with the Unit 2 precedent.
Discussion: TVA's program for the seismic qualification of the 185 CRD insert and withdrawal lines on Unit 2 was
provided in Reference 1 and approved by NRC in
Reference 2.
Status: C-C
Based on reanalysis, pipe supports for CRD insert
and withdrawal piping were replaced with new
support frames.
NRC closed this item in document dated
March 9, 2007 (Reference 3).
References:
1.
TVA letter to NRC, dated December 11, 1989, Revised Program Plan - Seismic Qualification of
the Control Rod Drive Hydraulic (CRDH) Piping
System 2. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 -
Browns Ferry, Unit 2, Section 2.2.3.2 (Page 2-9)
- 3. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-44 Design Calculation Review
Issue: Complete a design calculation review.
Discussion: The objective of the design calculation review was to: a. Identify calculations considered to be essential;
- b. Ensure that essential calculations support the plant licensing commitments and design basis
requirements;
- c. Ensure that essential calculations are technically adequate and consistent with the
plant configuration; and
- d. Ensure that essential calculations supporting the Design Baseline and Verification Program (DBVP) are consistent with the plant functional
configuration.
Status: C-C
The design calculation review was incorporated into
the Configuration Management / Design Baseline
Verification Program in Reference 1.
NRC closed this item in document dated
March 9, 2007 (Reference 2).
References:
1.
TVA letter to NRC, dated June 13, 1991, Design Baseline Verification Program (DBVP)
- 2. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-45 Environmental Qualification
Commitment: TVA will complete the qualification of Class IE safety-related equipment.
Discussion: The qualification of Class IE safety-related equipment will be accomplished when BFN certifies
compliance with 10 CFR 50.49, Environmental
qualification of electric equipment important to
safety for nuclear power plants.
Status: Open
References:
None
April 13, 2007 E1-46 Fire Protection / 10 CFR 50, Appendix R
Commitment: TVA will comply with License Condition 2.C(13).
Discussion: License Condition 2.C(13) states:
"Browns Ferry Nuclear Plant shall implement
and maintain in effect all provisions of the
approved Fire Protection Program as described
in the Final Safety Analysis Report for BFN
as approved in the SEs dated December 8, 1988, March 6, 1991, March 31, 1993, November 2, 1995 and Supplement dated
November 3, 1989 subject to the following
provision:
The licensee may make changes to the
approved fire protection program
without prior approval of the
Commission only if those changes would
not adversely affect the ability to
achieve and maintain safe shutdown in
the event of a fire."
NRC issued its Safety Evaluation Report (SER) for
BFN's Safe Shutdown Analysis in Reference 1 and
approved the associated License Amendment in
Reference 2. The SER for the BFN Fire Protection
Plan and Fire Hazards Analysis was provided in
Reference 3. The NRC staff issued a License
amendment for the 10 CFR 50, Appendix R Post-fire
Safe Shutdown Program in Reference 4 and issued a
supplemental Safety Evaluation in Reference 5.
As requested by the NRC in a letter to TVA dated September 21, 2006 (Reference 6), TVA will notify
the NRC of each of the following items:
- 1. TVA, in its letter of April 24, 2006 (Reference 7), committed to identify the
Appendix R, Paragraph III.G.2, noncompliances
involving operator manual actions, to place them
into TVA's corrective action program, and to
implement compensatory measures. Therefore, TVA
should complete the commitments made in its
April 24, 2006, letter, as well as any other
restart related commitments made previously to
the NRC regarding post-fire operator manual
actions.
April 13, 2007 E1-47
- 2. Safe Shutdown Instructions used to direct those actions needed to bring the unit to safe
shutdown in the event of a fire will be
completed by January 1, 2007.
- 3. Concerning the Unit 1 safe-shutdown analysis design assumptions.
Status: Open
References:
1.
NRC letter to TVA, dated December 8, 1988, Units 1, 2 and 3 - Appendix R Safe Shutdown
System Analysis (TAC 60627, 60628, 60629)
- 2. NRC letter to TVA, dated March 6, 1991, Issuance of Amendment (TAC No. 72965) (TS 268)
- 3. NRC letter to TVA, dated March 31, 1993, Fire Protection Program - Browns Ferry Nuclear Plant
Units 1, 2 and 3 (TAC Nos. M82687, M82688 and
M82689) 4. NRC letter to TVA, dated November 2, 1995, Safety Evaluation of Post-Fire Safe Shutdown
Capability and Issuance of Technical
Specification Amendments for the Browns Ferry
Nuclear Plant Units 1, 2, and 3 (TAC Nos.
M85254, N87900, M87901, and M87902) (TS 337)
- 5. NRC letter to TVA, dated November 3, 1989, Supplemental Safety Evaluation on Post-Fire Safe
Shutdown Systems and Final Review of the
National Fire Protection Association Code
Deviations - Browns Ferry Nuclear Plant, Unit 2 (TAC Nos. 72908 and 00459)
- 6. NRC letter to TVA, dated September 21, 2006, Browns Ferry Nuclear Plant, Unit 1 - Status of
Fire Protection Program (TAC No. MC8826)
Fire Protection Program - Post-Fire Operator
Manual Actions
April 13, 2007 E1-48 Flexible Conduits
Commitment: Actions necessary to disposition flexible conduit concerns for the 10 CFR 50.49 equipment will be
completed prior to restart. Flexible conduits
attached to safety-related electrical equipment not
covered by 10 CFR 50.49 and within the scope of USI
A-46 will be evaluated for seismic adequacy using
BFN's A-46 program.
Discussion: The program and schedule for the resolution of flexible conduit issues for Unit 1 has been
provided to the NRC as part of the resolution of
Generic Letter 87-02. In Reference 1, TVA provided
a schedule for flexible conduits associated with
the resolution of USI A-46. NRC requested
additional information regarding the schedule in
Reference 2. In Reference 3, TVA provided the
schedule for completing flexible conduit concerns
in two phases. Flexible conduits attached to
electrical equipment covered by 10 CFR 50.49 would
be resolved prior to restart of Unit 1. Seismic
qualification of flexible conduit other than those
connected to electrical equipment covered by 10 CFR
50.49 (i.e., important to safety, but in a mild
environment) and within the scope of USI A-46 would
be included as part of the resolution of USI A-46.
In Reference 4, NRC found this program acceptable;
however, additional information was requested
regarding two separate issues regarding flexible
conduit. TVA provided the requested information in
Reference 5. Additional information was provided
by TVA in Reference 6. NRC subsequently provided a
supplemental safety evaluation in Reference 7.
Status: Complete
Safety related flexible conduits were evaluated.
Breakages (conduit failures) from this evaluation
were resolved.
References:
1.
TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical
and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and
Supplement 4 to Generic Letter 88-20, Individual
Plant Examination of External Events (IPEEE) for
Severe Accident Vulnerabilities.
April 13, 2007 E1-49
- 2. NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response -
Browns Ferry Nuclear Plant
- 3. TVA letter to NRC, dated January 19, 1993, Generic Letter (GL) 87-02, Supplement 1, 120-Day
Response, Request for Additional Information
- 4. NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response - Browns
Ferry Nuclear Plant
- 5. TVA letter to NRC, dated October 15, 1993, Generic Letter (GL) 87-02, Supplement 1, Verification of Seismic Adequacy of Mechanical
and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A Response to
Request for Additional Information Regarding the
Evaluation of the Seismic Adequacy of Flexible
Conduit 6. TVA letter to NRC, dated September 28, 1995, Browns Ferry Nuclear Plant (BFN)- Units 1, 2,
and 3 - Seismic Adequacy of Flexible Conduits
- 7. NRC letter to TVA, dated October 3, 1995, Supplemental Safety Evaluation of Flexible
Conduit Seismic Design and Installation Criteria
April 13, 2007 E1-50 Fuses Commitment: The fuse issue will be resolved in accordance with the Unit 2 precedent.
Discussion: NRC approval of TVA's fuse program is documented in NUREG-1232 (Reference 1). The completion plan for
the fuse program was provided by Reference 2. TVA
has removed the reference to amperage from drawings
and replaced them with the appropriate unique
identifier for Class 1E fuses. TVA has installed
permanent fuse labeling.
Status: Complete
References:
1.
NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 - Browns
Ferry, Unit 2, Section 3.11.2 (Page 3-9)
- 2. TVA letter to NRC, dated January 29, 1992, Completion Plan for the Fuse Program
April 13, 2007 E1-51 Generic Letter 82-33, Instrumentation to Follow the Course of an Accident - Regulatory Guide 1.97 Commitment: TVA will complete Generic Letter 82-33.
Discussion: Supplement 1 to NUREG-0737, which included the request to review Regulatory Guide 1.97, was sent
to TVA in Generic Letter 82-33 (Reference 1). TVA
originally responded to Generic Letter 82-33 in
Reference 2.
TVA was ordered to submit a report to NRC
describing how the requirements of Supplement 1 to
NUREG-0737 have been or will be met and an
implementation schedule (Reference 3).
NRC requested additional information and/or
justification in Reference 4. TVA responded to
this request in Reference 5. TVA provided updated
information regarding Reactor Coolant System
pressure indication in Reference 6. A Safety
Evaluation Report (SER) was issued by NRC in
Reference 7. As part of this SER, TVA was directed
to qualify the instrumentation that measures seven
variables in accordance with 10 CFR 50.49. TVA
either provided additional justification or
committed to upgrade the instrumentation discussed
in the SER in Reference 8. A revised SER was
issued as part of the NRC's February 8, 1990 letter (Reference 9). This revised SER also directed TVA
to install a qualified neutron monitoring system.
In Reference 10, TVA requested further BFN specific
actions regarding the neutron flux monitoring
instrumentation be deferred pending the resolution
of the BWR Owners' Group appeal.
In Reference 11, TVA identified previously
submitted deviation to Regulatory Guide 1.97 for
which NRC review was still required, addressed
discrepancies between TVA letters and NRC SERs, and
identified new deviations for NRC review.
Additional information regarding emergency damper
position indication was provided by TVA in
Reference 12. The deviations addressed above were
addressed in the NRC's May 10, 1991, SER (Reference 13). In addition, implementation of
qualified neutron flux monitoring capability was
deferred pending review of an appeal by the BWR
Owners Group.
April 13, 2007 E1-52 A revised SER regarding neutron flux monitoring instrumentation was issued in Reference 14. TVA's
review of BFN's neutron flux monitoring
instrumentation against the criteria referenced by
the SER was provided in References 15 and 16. As
part of Reference 16, TVA committed to evaluate the
neutron monitoring system cables, electrical
penetrations and connectors for conformance to the
criteria reference by the SER. This evaluation has
been completed. Consistent with the conclusions
reached for Units 2 and 3, the Unit 1 neutron
monitoring system cables, electrical penetrations, and electrical connectors are capable of operating
throughout the one hour duration of the ATWS event.
NRC acceptance of the deviation requested by TVA
was documented in the May 3, 1994 SER (Reference 17).
Status: C-C TVA has replaced the subject instrumentation with
qualified devices.
NRC closed this item in Inspection Report 2005-07 (Reference 18).
References:
1.
NRC letter to All Licensees of Operating Reactors, Applicants for Operating Licenses, and
Holders of Construction Permits, dated
December 17, 1982, Supplement 1 to NUREG-0737 -
Requirements for Emergency Response Capability (Generic Letter 82-33)
- 2. TVA letter to NRC, dated April 30, 1984, in regards to Generic Letter 82-33
- 3. NRC letter to TVA, dated June 12, 1984, Issuance of Orders Confirming Licensee Commitments on
Emergency Response Capability
- 4. NRC letter to TVA, dated January 23, 1985, Emergency Response Capability - Conformance to
R.G. 1.97, Rev. 2
- 5. TVA letter to NRC, dated May 7, 1985, in regards to conformance with Regulatory Guide 1.97
- 6. TVA letter to NRC, dated November 20, 1985, in regards to conformance with Regulatory
Guide 1.97
- 7. NRC letter to TVA, date June 23, 1988, Generic Letter 82-33, Request for Compliance with the
Guidelines of Regulatory Guide (R.G.) 1.97 as
Applied to Emergency Response Facilities April 13, 2007 E1-53
- 8. TVA letter to NRC, dated August 23, 1988, Response to NRC's Safety Evaluation Report on
Regulatory Guide 1.97 as Applied to Emergency
Response Facilities Dated June 23, 1988
- 9. NRC letter to TVA, dated February 8, 1990, Emergency Response Capability - Conformance to
Regulatory Guide 1.97. Revision 3 1 0. TVA letter to NRC, dated September 14, 1990, Response to NRC's February 8, 1990 Safety
Evaluation Report Regarding Conformance to
Regulatory Guide 1.97, Revision 3 - Neutron Flux
Monitoring Instrumentation 1 1. TVA letter to NRC, dated October 15, 1990, Response to NRC Supplemental Safety Evaluation
Report (SER) on Regulatory Guide (RG) 1.97
Compliance dated February 8, 1990 1 2. TVA letter to NRC, dated December 21, 1990, Regulatory Guide (RG) 1.97 Emergency Ventilation
Dampers Position Indication 1 3. NRC letter to TVA, dated May 10, 1991, Safety Evaluation of Emergency Response Capability -
Conformance to Regulatory Guide 1.97, Revision 3 1 4. NRC letter to TVA, dated May 27, 1993, Regulatory Guide 1.97 - Boiling Water Reactor
Neutron Flux Monitoring 1 5. TVA letter to NRC, dated July 30, 1993, Regulatory Guide 1.97 - Boiling Water Reactor
Neutron Flux Monitoring 1 6. TVA letter to NRC, dated March 10, 1994, Regulatory Guide 1.97 - Boiling Water Reactor
Neutron Flux Monitoring 1 7. NRC letter to TVA, dated May 3, 1994, Boiling Water Reactor Neutron Flux Monitoring for the
Browns Ferry Nuclear Plant 1 8. NRC letter to TVA, dated August 15, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005007
April 13, 2007 E1-54 Generic Letter 83-08, Modification of Vacuum Breakers on Mark I Containments
Commitment: TVA will modify the torus vacuum breakers.
Discussion: TVA responded to the Generic Letter in Reference 1 and committed to modify the torus vacuum breakers.
NRC requested additional information in
Reference 2, which was provided by TVA in
Reference 3. The NRC Safety Evaluation Report was
issued in Reference 4. It concluded that TVA's
actions would be adequate to restore the original
design margin of safety for its vacuum breakers
under the revised loadings in the Mark I
containment.
Status: C-C
TVA modified the torus vacuum breakers.
NRC closed this item in Inspection Report 2005-006 (Reference 5).
References:
1.
TVA letter to NRC, dated November 5, 1984, in regards to Generic Letter 83-08
- 2. NRC letter to TVA, dated January 17, 1986, Modification of Vacuum Breakers on Mark I
Containments (Generic Letter 83-08)
- 3. TVA letter to NRC, dated April 7, 1986, in regards to Generic Letter 83-08
- 4. NRC letter to TVA, dated November 25, 1986, Modification of Vacuum Breakers on Mark I
Containments (Generic Letter 83-08); MPA D-20
- 5. NRC letter to TVA, dated May 16, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005006
April 13, 2007 E1-55 Generic Letter 83-28, Salem ATWS, Item 1.2, Post Trip Review (Data and Information Capability)
Commitment: TVA will complete Generic Letter, Item 1.2.
Discussion: In response to Generic Letter 83-28, Item 1.2, TVA committed in Reference 1 to the installation of an
upgraded process computer and an enhanced sequence
of events recording capability. TVA's response was
found to be acceptable in the NRC's Safety
Evaluation provided by Reference 2.
As discussed in Reference 3, the Unit 2 equipment
was replaced with more modern and sophisticated
hardware, since the time of the original TVA
submittal. The previously described upgrade to a
Digital VAX 11/750 process computer system was
accomplished using a Digital VAX 6000 system. The
functions previously performed by the sequence of
events and time history recorder are now
accomplished using the process computer system.
However, the guidance contained in the Generic
Letter and the requirements of the Safety
Evaluation continue to be met.
Status: Closed
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated November 7, 1983, in regards to Generic Letter 83-28
- 2. NRC letter to TVA, dated June 12, 1985, Safety Evaluation for Generic Letter 83-28, Item 1.2, Post Trip Review (Data and Information
Capability)
- 3. TVA letter to NRC, dated November 9, 1993, Completion of Unit 2 Commitment for Generic
Letter 83-28, Item 1.2 - Post-Trip Review - Data
and Information Capability (GSI 75 / MPA B-085)
- 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-56 Generic Letter 83-28, Salem ATWS, Item 4.5.2, Periodic On-Line Testing Commitment: TVA will complete Generic Letter, Item 4.5.2.
Discussion: The NRC's position on this item was that plants not currently designed to permit periodic on-line
testing shall justify not making modifications to
permit such testing. Alternatives to on-line
testing proposed by licensees will be considered
where special circumstances exist and where the
objective of high reliability can be met in another
way. TVA's initial response to this item (Reference 1) stated that on-line testing was being
evaluated. A description of the Reactor Protection
System (RPS) functional testing and reliability was
provided by TVA in Reference 2.
The NRC Safety Evaluation states the on-line
testing capability of BFN's RPS meets the intent of
this item and is therefore acceptable (Reference 3).
Status: Closed
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated November 7, 1983, in regards to Generic Letter 83-28
- 2. TVA letter to NRC, dated March 15, 1984, in regards to Generic Letter 83-28
- 3. NRC letter to TVA, dated September 2, 1986, Reactor Trip System Reliability, On-Line
Testing, Generic Letter 83-28, Item 4.5.2
- 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-57 Generic Letter 83-28, Salem ATWS, Item 4.5.3, Intervals for On-Line Testing
Commitment: TVA will complete Generic Letter 83-28, Item 4.5.3.
Discussion: The NRC Staff has reviewed the General Electric Topical Reports NEDC-30844, BWR Owners'
Group (BWROG) Response to NRC Generic Letter
83-28, Item 4.5.3, and NEDC-30851P, Technical
Specifications Improvement Analysis for BWR Reactor
Protection System, and issued a favorable Safety
Evaluation Report (Reference 1).
In Reference 2, TVA endorsed the BWROG position and
stated the analysis presented in NEDC-30851P were
applicable to BFN. No Technical Specifications
instrument calibration frequency extensions were
requested based on these reports. Differences
between the parts of BFN's Reactor Protection
System (RPS) that perform the trip functions and
those of the base case plant were analyzed using
the procedures of Appendix K of NEDC-30851P to
demonstrate no appreciable change in RPS
availability or public risk. The Safety Evaluation
that closed this item was provided by Reference 3.
Status: Closed
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
NRC letter to BWR Owners Group, dated July 15, 1987, General Electric Company (GE)
Topical Reports NEDC-30844, BWR Owners'
Group Response to NRC Generic Letter 83-28, and
NEDC-30851P, Technical Specifications
Improvement Analysis for BWR RPS
- 2. TVA letter to NRC, dated July 5, 1990, Generic Letter 83-28, Required Actions Based on Generic
Implications of Salem ATWS Events, Item 4.5.3, Reactor Trip System Reliability
- 3. NRC letter to TVA, dated August 17, 1990, Safety Evaluation of Generic Letter 83-28, Item 4.5.3, Reactor Trip Reliability - On-Line Functional
Testing of the Reactor Trip System
- 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-58 Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in
Operating Reactors, Unresolved Safety Issue (USI) A-46
Commitment: TVA will resolve USI A-46.
Discussion: In Reference 1, TVA committed to use the Seismic Qualification Utility Group (SQUG) methodology as
documented in the Generic Implementation
Procedure (GIP) to resolve USI A-46 at Browns Ferry
Nuclear Plant. NRC requested clarification
regarding TVA's approach in Reference 2, which TVA
supplied in Reference 3. In Reference 4, the staff
considered TVA's commitment to comply with GIP-2 an
acceptable method for resolving USI A-46 at BFN.
TVA provided its response to Generic Letter 87-02
for Unit 1 in Reference 5.
TVA completed the USI-A46 review and resolved
outliers. TVA completed the operations review of
Safe Shutdown Equipment List (SSEL) following the
A-46 verification. The review determined that Unit
1 can be safely shutdown to Mode 3 and maintained
while using only the equipment in the SSEL.
IR 2006-006 (Reference 6) stated "- However, final closure of these items will be deferred until NRR
completes their review in this area and any SERs, if required, are issued."
Status: Complete
The Safety Evaluation on this program was provided
by Reference 7.
References:
1.
TVA letter to NRC, dated September 21, 1992, Browns Ferry Nuclear Plant (BFN) - Supplement 1
to Generic Letter 87-02, Verification of Seismic
Adequacy of Mechanical and Electrical Equipment
in Operating Reactors, Unresolved Safety Issue (USI) A-46 and Supplement 4 to Generic
Letter 88-20, Individual Plant Examination of
External Events (IPEEE) for Severe Accident
Vulnerabilities
- 2. NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response -
Browns Ferry Nuclear Plant (TAC Nos. M69430, M69431, and M69432)
April 13, 2007 E1-59
Letter (GL) 87-02, Supplement 1, 120-Day
Response, Request for Additional Information
- 4. NRC letter to TVA, dated March 19, 1993, Generic Letter 87-02, Supplement 1 Response - Browns
Ferry Nuclear Plant (TAC Nos. M69430, M69431, and M69432)
- 5. TVA letter, T. E. Abney to NRC, dated October 7, 2004, Browns Ferry Nuclear Plant (BFN) Unit 1 - Response to NRC Generic Letter (GL) 87-02, Supplement 1 that Transmits
Supplemental Safety Evaluation Report No. 2 (SSER No. 2) on SQUG Generic Implementation
Procedure, Revision 2, as Corrected on
February 14, 1992 (GIP-2)
- 6. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006006
- 7. NRC letter to TVA, dated December 8, 2006, Review of Licensee Response to NRC Generic
Letter 87-02, Supplement 1 That Transmits
Supplemental Safety Evaluation Report No. 2 on
SQUG Generic Implementation Procedure Revision
2, As Corrected on February 14, 1992
April 13, 2007 E1-60 Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping
Commitment: TVA will complete Generic Letter 88-01.
Discussion: TVA's program to address Generic Letter 88-01 was provided by Reference 1. The Safety Evaluation
documenting the acceptability of the program was
included in Reference 2. Supplemental information
regarding Unit 1 was submitted in Reference 3. The
Safety Evaluation for Unit 1 was provided by
Reference 5.
Status: C-C
TVA has completed the Generic Letter 88-01 program.
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated December 28, 1992, Supplemental Response to Generic Letter (GL)
88-01, NRC Position on Intergranular Stress
Corrosion Cracking (IGSCC) in BWR Austenitic
Stainless Steel Piping
- 2. NRC letter to TVA, dated December 3, 1993, Safety Evaluation of Supplemental Response to
Response to Generic Letter 88-01, NRC Position
on Intergranular Stress Corrosion Cracking In
BWR Austentic Stainless Steel Piping
- 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
- 5. NRC letter to TVA dated May 30, 2006, Browns Ferry Nuclear Plant Unit 1 - Supplemental
Response to Generic Letter 88-01, NRC Position
on Intergranular Stress Corrosion Cracking in
BWR [Boiling Water Reactor] Austenitic Stainless
Steel Piping
April 13, 2007 E1-61 Generic Letter 88-11, Radiation Embrittlement of Reactor Vessel Materials and Its Impact on Plant
Operations
Commitment: TVA will complete Generic Letter 88-11.
Discussion: TVA responded to Generic Letter 88-11 in Reference 1. TVA concluded that the current
pressure-temperature curves in each plant's
Technical Specifications were valid through the
next two fuel cycles when compared to the
Regulatory Guide 1.99, Revision 2, methodology.
Supplemental information was provided for BFN in
References 2 and 3.
In Reference 4, TVA proposed Technical
Specifications changes for BFN Units 1, 2 and 3 to
incorporate pressure-temperature curves calculated
using Regulatory Guide 1.99, Revision 2, methodology. NRC requested additional information
in Reference 5, which was provided by TVA in
Reference 6. The proposed Technical Specifications
were issued by Reference 7.
Status: C-C
NRC closed this item in Inspection Report 2006-007 (Reference 8).
References:
1.
TVA letter to NRC, dated November 30, 1988, Browns Ferry Nuclear Plant (BFN), Sequoyah
Nuclear Plant (SQN), and Watts Bar Nuclear
Plant (WBN) - Response to Generic Letter
88 NRC Position on Radiation Embrittlement
of Reactor Vessel Materials and its Impact on
Plant Operations
- 2. TVA letter to NRC, dated February 28, 1991, TVA Supplemental Response to Generic Letter 88-11, NRC Position of Radiation Embrittlement of
Reactor Vessel Materials and its Impact on Plant
Operations
- 3. TVA letter to NRC, dated April 30, 1991, TVA Supplemental Response to Generic Letter 88-11, NRC Position of Radiation Embrittlement of
Reactor Vessel Materials and its Impact on Plant
Operations
April 13, 2007 E1-62
- 5. NRC letter to TVA, dated August 28, 1991, Pressure-Temperature Limits Pursuant to Generic
Letter 88-11 as Reflected in Proposed Amendment
to Technical Specification (TS 293)
Radiation Embrittlement of Reactor Vessel
Material and its Impact on Plant Operations -
Response to Request for Additional Information
- 7. NRC letter to TVA, dated January 8, 1993, Issuance of Amendments for the Browns Ferry
Nuclear Plant (TS 293)
- 8. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-63 Generic Letter 88-14, Instrument Air Supply System Problems Affecting Safety-Related Equipment
Commitment: TVA will complete Generic Letter 88-14.
Discussion: The original response to Generic Letter 88-14 was included as part of Reference 1. Additional
information regarding the dew point of air being
supplied to certain components was provided in
Reference 2. NRC confirmed TVA's commitments in
Reference 3.
Status: Closed
NRC closed this item in Inspection Report 2005-008 (Reference 4).
References:
1.
TVA letter to NRC, dated February 23, 1989, Browns Ferry Nuclear Plant (BFN), Sequoyah
Nuclear Plant (SQN), and Watts Bar Nuclear
Plant (WBN) - Response to Generic Letter
88 Instrument Air Supply System Problems
Affecting Safety-Related Equipment
- 2. TVA letter to NRC, dated July 30, 1993, Supplemental Response to Generic Letter (GL)
88-14, Instrument Air Supply System Problems
Affecting Safety-Related Equipment
- 3. NRC letter to TVA, dated May 9, 1989, Generic Letter 88 Instrument Air Supply System
Problems Affecting Safety-Related Equipment (TAC Nos. 71631/71632/71633)
- 4. NRC letter to TVA, dated November 14, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005008
April 13, 2007 E1-64 Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities
Issue: TVA will respond to Generic Letter 88-20.
Discussion: Generic Letter 88-20 requested licensees:
- 1. Perform a systematic examination to identify any plant specific vulnerabilities to severe
accidents; and
- 2. Identify and review proposed plant improvements (design changes and changes to operating
procedures, maintenance, surveillance, training, or staffing).
The Generic Letter did not request individual IPEs
be performed for each unit at a multi-unit site.
The BFN facility has been extensively reviewed by
the staff, beginning with an interim reliability
evaluation in 1982. This was followed by the
subsequent submittal of the November 20, 1986, BFN Unit 1 Probabilistic Risk Assessment (PRA) and
its subsequent NRC audit. TVA subsequently
submitted BFN's IPE in 1992 and the Multi-unit PRA (MUPRA) in 1995. Since then, TVA has performed
individual Unit 2 and Unit 3 PRAs. Neither the
MUPRA, nor the subsequently performed individual
Unit 2 and Unit 3 PRAs have identified plant
vulnerabilities when single or multiple units are
in operation. These analyses have provided the
staff with more than reasonable assurance that TVA
has adequately analyzed the plant design and
operations.
In Reference 1, NRC identified the specific
information needed for the closeout of Generic
Letter 88-20 for Browns Ferry Unit 1. This
information was provided in Reference 2.
Status: Complete
References:
1.
NRC letter to TVA, dated June 21, 2004, Browns Ferry Nuclear Plant, Unit 1 - Request for
Additional Information Related to Generic
Letter 88-20, Individual Plant Examination For
Severe Accident Vulnerability April 13, 2007 E1-65
- 2. TVA letter to NRC, dated August 17, 2004, Browns Ferry Nuclear Plant (BFN) - Unit 1 - Response to
Request for Additional Information Related to
Generic Letter 88-20, Individual Plant
Examination for Severe Accident Vulnerability April 13, 2007 E1-66 Generic Letter 88-20, Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe
Accident Vulnerabilities
Commitment: TVA will complete an Individual Plant Examination of External Events (IPEEE).
Discussion: In Reference 1, TVA described BFN's program and schedule for completing the internal fires, high
winds, external floods, and transportation and
nearby facility accidents portions of the IPEEE.
NRC acceptance of the methods and schedules for the
addressed portions of the IPEEE was documented in
Reference 2.
TVA provided its initial program and schedule for
responding to the seismic portion of the IPEEE in
Reference 3. NRC requested additional information
on this subject in Reference 4, which TVA provided
in Reference 5.
The summary report for the high winds, external
floods, and transportation and nearby facility
accidents IPEEE was provided by TVA in Reference 6
for all three BFN units. The seismic IPEEE Report
and the Fire Induced Vulnerability Evaluation were
provided in Reference 7.
Status: Complete
TVA completed corrective actions to address the
seismic-induced fire vulnerability associated with
the emergency lighting battery racks located in the
BFN Unit 1 cable spreading room prior to restart.
References:
1.
TVA letter to NRC, dated December 20, 1991, Individual Plant Examination of External
Events (IPEEE) for Severe Accident
Vulnerabilities (Generic Letter 88-20, Supplement 4)
- 2. NRC letter to TVA, dated July 2, 1992, Review of Response to Generic Letter 88-20, Supplement
No. 4 - Individual Plant Examinations for
External Events
April 13, 2007 E1-67
- 3. TVA letter to NRC, dated September 21, 1992, Supplement 1 to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical
and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and
Supplement 4 to Generic Letter 88-20, Individual
Plant Examination of External Events (IPEEE) for
Severe Accident Vulnerabilities
- 4. NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response
- 5. TVA letter to NRC, dated January 19, 1993, Generic Letter (GL) 87-02, Supplement 1, 120-Day
Response, Request for Additional Information
- 6. TVA letter to NRC, dated July 24, 1995, Browns Ferry Nuclear Plant - Generic Letter 88-20, Supplement 4, Individual Plant Examination of
External Events (IPEEE) for Severe Accident
Vulnerabilities - Partial Submittal of Report
Response to NRC Generic Letter (GL) 88-20, Supplement 4 - Individual Plant Examination of
External Events (IPEEE) for Severe Accident
Vulnerabilities - Submittal of Browns Ferry
Nuclear Plant Unit 1 Seismic and Internal Fires
IPEEE Reports
April 13, 2007 E1-68 Generic Letter 89-06, Task Action Plan Item I.D.2 - Safety Parameter Display System
Commitment: TVA will install and make operational a Safety Parameter Display System (SPDS) and certify that
the SPDS fully meets the requirements of
NUREG-0737, Supplement 1, taking into account the
information provided in NUREG-1342.
Discussion: Certification that BFN's SPDS fully meets the requirements of NUREG-0737, Supplement 1, taking
into account the information provided in
NUREG-1342, was requested by Generic Letter
89-06 (Reference 1). TVA's commitment to implement
an SPDS on Unit 1 before restart is contained in
Reference 2. The final design description for the
SPDS was provided by TVA in References 3 and 4.
The initial Safety Evaluation Report (SER) of the
SPDS design description was documented in
Reference 5. TVA responded to the SER open items
in Reference 6. NRC concluded in a Supplemental
SER that TVA's SPDS design description fully met
the requirements of NUREG-0737, Supplement 1 (Reference 7).
Status: Closed
NRC closed this item in Inspection Report 2006-007 (Reference 8).
References:
1.
NRC letter to All Licensees of Operating Plants, Applicants for Operating Licenses and Holders of
Construction Permits, dated April 12, 1989, Task
Action Plan Item I.D.2 - Safety Parameter
Display System - 10 CFR 50.54(f) - (Generic
Letter No. 89-06)
- 2. TVA letter to NRC, dated April 8, 1987, Safety Parameter Display System (SPDS) - Schedule for
Response to Request for Additional Information
- 3. TVA letter to NRC, dated October 22, 1990, Notification of Implementation of NUREG-0737 (TMI Action Plan), Item I.D.2.1, Safety
Parameter Display System (SPDS), Phase I
Installation and Final Design Description
- 4. TVA letter to NRC, dated December 11, 1990, Notification of Implementation of NUREG-0737 (TMI Action Plan), Item I.D.2.1, Safety
Parameter Display System (SPDS), Final Design
Description
April 13, 2007 E1-69
- 5. NRC letter to TVA, dated March 6, 1991, Interim and Final Design of the Safety Parameter Display
System at the Browns Ferry Nuclear Plant
- 6. TVA letter to NRC, dated December 17, 1991, Safety Parameter Display System (SPDS), Response
to NRC Safety Evaluation Report (SER) Open Items
- 7. NRC letter to TVA, dated February 5, 1992, Safety Parameter Display System - Browns Ferry
Nuclear Plant, Units 1, 2, and 3)
- 8. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-70 Generic Letter 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning Commitment: TVA will complete Generic Letter 89-08.
Discussion: TVA responded to Generic Letter 89-08 in Reference 1 and committed to implement a
long-term monitoring program (single and dual phase
piping). NRC acceptance of the program was
provided in Reference 2.
Status: Closed
NRC closed this item in Inspection Report 2005-009 (Reference 3).
References:
1.
TVA letter to NRC, dated July 19, 1989, Response to Generic Letter 89 Erosion/Corrosion-
Induced Pipe Wall Thinning
- 2. NRC letter to TVA, dated August 21, 1989, Licensee Confirmation of its Response to NRC
- 3. NRC letter to TVA, dated February 13, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005009
April 13, 2007 E1-71 Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance
Commitment: TVA will complete Generic Letter 89-10.
Discussion: TVA responded to Generic Letter 89-10 in Reference 1 and committed to implement a
comprehensive motor operated valve program within
the requested 5-year implementation schedule.
Additional schedule information was provided by NRC
in Reference 2. TVA provided the 30-day response
to Generic Letter 89-10, Supplement 3 by
Reference 3 and informed the Staff that the plant
specific safety assessment was available for
review. TVA also responded to Reference 2 and
informed the Staff in Reference 4 that the program
description for implementing Generic Letter 89-10
was also available for review.
The 120-day response requested in Supplement 3 to
the Generic Letter was provided by TVA in
Reference 5. It stated that no deficiencies were
identified in the motor-operated valves for primary
containment isolation for the High Pressure Coolant
Injection and Reactor Core Isolation Cooling steam
supply lines or the Reactor Water Cleanup water
supply line.
In Reference 6, TVA clarified the implementation
schedule for Unit 1. Based on test requirements
and system configurations, it would be necessary to
perform differential pressure testing on some motor
operated valves during the power ascension test
program. Consequently, TVA committed to complete
the required testing within 30 days following the
completion of the power ascension test program.
This implementation schedule was acknowledged by
the NRC Staff in Reference 7.
TVA submitted a Unit 1 specific program description
in Reference 8. The Generic Letter 89-10 program
for BFN Unit 1 has been developed.
TVA's review and documentation of the design basis
for the operation of each Unit 1 MOV within the
scope of the Generic Letter 89-10 program, the
valves included in the program, the methods for
determining and adjusting switch settings, testing, surveillance, and maintenance are the same as with
the Units 2 and 3 program.
April 13, 2007 E1-72 Status: Closed
NRC closed this item in Inspection Report 2006-009 (Reference 9).
References:
1.
TVA letter to NRC, dated December 21, 1989, Browns Ferry Nuclear Plant (BFN), Sequoyah
Nuclear Plant (SQN), and Watts Bar Nuclear
Plant (WBN) - Response to Generic Letter
89 Safety-Related Motor-Operated
Valve (MOV) Testing and Surveillance
- 2. NRC letter to TVA, dated September 14, 1990, Response to Generic Letter 89-10,
Safety-Related Motor-Operated Valve Testing and
Surveillance for the Browns Ferry, Sequoyah, Watts Bar and Bellefonte Nuclear Plants (MPA B-110)
- 3. TVA letter to NRC, dated December 10, 1990, Response to Generic Letter (GL) 89-10, Supplement 3 - Consideration of the Results of
NRC-Sponsored Tests of Motor-Operated Valves (MOV) 4. TVA letter to NRC, dated December 21, 1990, Response to Generic Letter 89-10, Safety-Related
Motor-Operated Valve Testing and Surveillance
- 5. TVA letter to NRC, dated March 13, 1991, Response to Generic Letter (GL) 89-10, Supplement 3 - Consideration of the Results of
NRC-Sponsored Tests of Motor-Operated Valves (MOV) 6. TVA letter to NRC, dated April 14, 1992, Generic Letter (GL) 89-10, Safety-Related Motor-Operated
Valve Testing and Surveillance - Implementation
Schedule 7. NRC letter to TVA, dated June 30, 1992, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -
Implementation Schedule for Generic Letter 89-10 (TAC Nos. M75635, M75636 and M75637)
Letter 89-10 and Supplements 1 to 7,
Safety-Related Motor-Operated Valve (MOV)
Testing and Surveillance
- 9. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-73 Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment
Commitment: TVA will complete Generic Letter 89-13.
Discussion: TVA responded to Generic Letter 89-13 in Reference 1. Three of the near-term commitments
were rescheduled in Reference 2. NRC was notified
of the completion of the majority of the
commitments made in response to Generic Letter
89-13 in Reference 3. The remaining commitment on
Unit 1 is to verify that the Unit 1 portions of the
Residual Heat Removal Service Water (RHRSW) and
Emergency Equipment Cooling Water (EECW) systems
satisfy their design criteria. Completion of NRC's
review is documented in Reference 4.
Status: C-C
The Unit 1 RHRSW and EECW systems' ability to
satisfy their design basis has been verified.
NRC closed this item in Inspection Report 2006-007 (Reference 5).
References:
1.
TVA letter to NRC, dated March 16, 1990, Response to Generic Letter (GL) 89-13 Service
Water System Problems Affecting Safety-Related
Equipment
- 2. TVA letter to NRC, dated December 31, 1990, Generic Letter (GL) 89-13, Service Water System
Problems Affecting Safety-Related Equipment
Letter (GL) 89 Service Water System (SWS)
Problems Affecting Safety-Related Equipment
- 4. NRC letter to TVA, dated April 23, 1990, Licensee's Response To Generic Letter 89-13
Regarding Service Water Systems (TAC Nos. 73970, 73971, and 73972)
- 5. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-74 Generic Letter 89-16, Installation of a Hardened Wetwell Vent
Commitment: TVA will complete Generic Letter 89-16.
Discussion: In Reference 1, NRC requested licensees with Mark I containments to voluntarily install a hardened
vent. In response, TVA committed to install a
hardened vent prior to restart in Reference 2.
Status: C-C
TVA installed a hardened wetwell vent.
NRC closed this item in Inspection Report 2005-006 (Reference 3).
References:
1.
NRC letter to All Operating Licensees with Mark I Containments, dated September 1, 1989, Installation of a Hardened Wetwell Vent (Generic
Letter 89-16)
- 2. TVA letter to NRC, dated October 30, 1989, Response to Generic Letter 89-16, Installation
of Hardened Wetwell Vent
- 3. NRC letter to TVA, dated May 16, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005006
April 13, 2007 E1-75 Generic Letter 92-01, Reactor Vessel Structural Integrity, Revision 1, and Revision 1 Supplement 1
Commitment: TVA will submit a summary evaluation of the time and accumulated fluence during intervals of BFN operation below 525 F and its effect on the reference temperature and on the Charpy upper shelf
energy.
Discussion: TVA provided an initial response to Generic Letter 92-01 in Reference 1 and made the commitment reiterated above. The summary evaluation of the
time and accumulated fluence during intervals of BFN operation below 525 F was provided by TVA in Reference 2. Additional information was requested
by the NRC Staff in Reference 3 , which was provided by TVA in Reference 4.
In Reference 5, NRC requested TVA verify the data
entered into the Reactor Vessel Integrity Database.
TVA responded to this request in References 6
and 7. Updated material and fluence data was
provided by TVA in Reference 8.
In Reference 9, NRC requested Licensees verify the
completeness of the information previously
submitted by November 15, 1995. TVA's response was
provided in References 10 and 11.
As a result of new industry data, NRC again
requested updated information in Reference 12. The
requested information was provided by TVA in
Reference 13 for Browns Ferry.
Status: C-C for restart.
As committed in TVA's May 23, 1 994 letter, TVA will inform NRC of the applicability of NEDO 32205
within 90 days of the final surveillance capsules
analysis report.
NRC closed this item in Inspection Report 2006-007 (Reference 14).
References:
1.
TVA letter to NRC, dated July 7, 1992, Browns Ferry Nuclear Plant (BFN), Sequoyah Nuclear
Plant (SQN), and Watts Bar Nuclear Plant (WBN) -
Response to generic Letter 92-0 1 (Reactor Vessel Structural Integrity)
April 13, 2007 E1-76
- 2. TVA letter to NRC, dated December 1, 1992, Completion of Commitment Made in Response to
Generic Letter 92-01, Reactor Vessel Structural
Integrity
Response to Generic Letter 92-01, Revision 1, Reactor Vessel Structural Integrity
- 4. TVA letter to NRC, dated August 2, 1993, Response to Request for Additional Information, Generic Letter 92-01, Revision 1
- 5. NRC letter to TVA, dated April 19, 1994, Generic Letter 92-01, Revision 1, Reactor Vessel
Structural Integrity
- 6. TVA letter to NRC, dated May 23, 1994, TVA's Response to NRC's Letter Dated April 19, 1994, Generic Letter 92-01, Revision 1 , Reactor Vessel Structural Integrity
May 23, 1994, Generic Letter 92-01, Revision 1, Reactor Vessel Structural Integrity
- 8. TVA letter to NRC, dated March 27, 1995, Generic Letter 92-01, Reactor Vessel Structural
Integrity - Update to the Initial Reference
Nil-Ductility Temperature (RT NDT), Chemical Composition and Fluence Values
- 9. NRC letter to TVA, dated May 19, 1995, NRC Generic Letter 92-01, Revision 1, Supplement 1:
Reactor Vessel Structural Integrity 1 0. TVA letter to NRC, dated August 7, 1995, in regards to Generic Letter 92-01 1 1. TVA letter to NRC, dated November 7, 1995, Response to NRC Generic Letter (GL) 92-01, Revision 1, Supplement 1; Reactor Vessel
Structural Integrity - Browns Ferry (BFN),
Watts Bar (WBN), and Sequoyah (SQN) Nuclear
Plants 1 2. NRC letter to TVA, dated June 10, 1998, Request for Additional Information Regarding Pressure
Vessel Integrity at Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MA1179, MA1180, and
MA1181)
April 13, 2007 E1-77 1 3. TVA letter to NRC, dated September 8, 1998, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Generic Letter (GL) 92-01, Revision 1, Supplement 1, Reactor Vessel Structural
Integrity - Response to NRC Request for
Additional Information (TAC Nos. MA1179, MA1180, and MA1181) 1 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-78 Generic Letter 92-04, Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs
Commitment: TVA will continue to support the BWR Owners' Group (BWROG) program of analysis, testing, and
development of possible hardware changes which is
being conducted by the BWROG.
TVA will review the results of the BWROG program
for potential training requirements for operators.
Discussion: TVA responded to Generic Letter 92-04 by Reference 1. NRC approval of TVA's program for the
resolution of Generic Letter 92-0 4 is documented in Reference 2. Interim training of the operators was
provided as documented in Inspection Report 93-16 (Reference 3).
Long-term actions were addressed as part of the resolution of Bulletin 93-03 -Resolution of Issues
Related to Reactor Vessel Water Level
Instrumentation in BWRs.
Status: C-C
NRC closed this item in Inspection Report 2006-009 (Reference 4).
References:
1.
TVA letter to NRC, dated September 28, 1992, Response to Generic Letter (GL) 92
Resolution of the Issues Related to Reactor
Vessel Water Level Instrumentation in BWRs
- 2. NRC letter to TVA, dated March 25, 1993, Response to Generic Letter 92-04, Resolution of
the Issues Related to Reactor Vessel Water Level
Instrumentation in Boiling Water Reactors
- 3. NRC letter to TVA, dated May 18, 1993, NRC Inspection Report No. 259/93-16, 260/93-16 and
296/93-16
- 4. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-79 Generic Letter 94-02, Long-Term Solutions and Upgrade of Interim Operating Recommendations for
Thermal-Hydraulic Instabilities in Boiling
Water Reactors
Commitment: 1.
TVA will modify BFN operating procedures and training programs to make them consistent or
more conservative than the BWR Owners'
Group (BWROG) interim guidelines.
solution.
Discussion: TVA responded to Generic Letter 94-02 in Reference 1. In Reference 2 , TVA notified NRC that the Unit 1 procedure revisions would be completed
prior to restart. In Reference 3, TVA stated its
intent to implement the long-term stability
solution on Unit 1 before the restart of that unit.
Status: Closed
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated September 8, 1994, Response to NRC Generic Letter (GL) 94
Long-Term Solutions and Upgrade of Interim
Operating Recommendations for Thermal-Hydraulic
Instabilities in Boiling Water Reactors
- 2. TVA letter to NRC, dated December 22, 1994, NRC Generic Letter (GL) 94-02, Long-Term Solutions
and Upgrade of Interim Operating Recommendations
for Thermal-Hydraulic Instabilities in Boiling
Water Reactors - Completion of Requested
Action 1, Interim Corrective Actions
TVA Confirmation of the Installation Schedule
for the Stability Long-Term Solution for NRC
- 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-80 Generic Letter 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling Water Reactors
Commitment: TVA will inspect 100% of the accessible areas on core shroud welds Hl through H7. The inspections
will be conducted using the best available
technology (i.e., Smart-2000 system, suction cup
scanners, Westinghouse 1250 camera, etc.) prior to
restart.
Discussion: In Reference 1, TVA committed to inspect the accessible areas of the core shroud prior to Unit 1 restart. The NRC's Safety Evaluation is contained
in Reference 2.
Status: C-C
TVA inspected 100% of the accessible areas on core
shroud welds Hl through H7. A structural margin
analysis of the core shroud inspections results was
performed. This analysis determined Unit 1 can
resume operation without repair.
NRC closed this item in Inspection Report 2005-008 (Reference 3).
References:
1.
TVA letter to NRC, dated August 23, 1994, Response to NRC Generic Letter (GL) 94
Intergranular Stress Corrosion Cracking (IGSCC)
of Shrouds in Boiling Water Reactors.
- 2. NRC letter to TVA, dated January 13, 1995, Browns Ferry Nuclear Plant Units 1, 2, and 3
Safety Evaluation of Response to Generic Letter
94-03 (IGSCC of Core Shroud in BWRs)
- 3. NRC letter to TVA, dated November 14, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery -NRC
Integrated Inspection Report 05000259/2005008
April 13, 2007 E1-81 Generic Letter 95-07, Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves
Commitment: Unit 1 will be evaluated for the requirements of Generic Letter 95-07 prior to restart.
Discussion: TVA provided response to NRC in References 1 through 5 for BFN Units 2 and 3, Sequoyah Units 1
and 2, and Watts Bar. The NRC's Safety Evaluation
for Generic Letter 95-07 was provided in
Reference 6.
TVA responded to Generic Letter 95-07 for BFN
Unit 1 in Reference 7 and provided additional
information in Reference
- 8. The review methodology used for Unit 1 is the same as that used for TVA's
other operating nuclear plants.
The safety related power operated gate valves in
Unit 1 have been reviewed for potential
susceptibility to the pressure locking and thermal
binding phenomenon. There is one High Pressure
Coolant Injection valve in Unit 1 which is
susceptible to thermal binding. Prior to restart, this valve wasreplaced with a double disc valve of
similar design as Units 2 and 3. Two Core Spray
minimum flow valves in Unit 1 were replaced with
double disc valves prior to Unit 1 restart. In
addition, five safety related power operated gate
valves were modified prior to Unit 1 restart to
preclude the potential for pressure locking. The
reactor side disc face of these five valves was
modified by drilling a hole in the disc face into
the cavity between the disc faces to avoid pressure
locking. NRC found TVA's responses to be an
acceptable resolution to the GL 95-07 concerns (Reference 9).
Status: C-C
NRC closed this item in Inspection Report 2006-006 (Reference 10).
References:
1.
TVA letter to NRC, dated October 16, 1995, Browns Ferry (BFN), Sequoyah (SQN), and Watts
Bar (WBN) Nuclear Plants - Response to Generic
Letter, Pressure Locking and Thermal Binding of
Safety-Related Power-Operated Gate Valves
April 13, 2007 E1-82
- 2. TVA letter to NRC, dated December 15, 1995, Browns Ferry (BFN), Sequoyah (SQN), and Watts Bar (WBN) Nuclear Plants -Supplemental Response
to Generic Letter, Pressure Locking and Thermal
Binding of Safety-Related Power-Operated Gate
Valves 3. TVA letter to NRC, dated February 13, 1996, Browns Ferry (BFN), Sequoyah (SQN), and Watts
Bar (WBN) Nuclear Plants - 180-Day Response to
Generic Letter, Pressure Locking and Thermal
Binding of Safety-Related Power-Operated Gate
Valves 4. TVA letter to NRC, dated July 30, 1996, Browns Ferry Nuclear Plant (BFN) - Units 2 and 3, Pressure Locking and Thermal Binding of Safety-
Related Power-Operated Gate Valves - Response to
Request for Additional Information (TAC Nos. M93437 and M93438)
- Generic Letter (GL) 95-07, Pressure Locking
and Thermal Binding of Safety-Related Power-
Operated Gate Valves - Supplemental Response (TAC Nos. M93437 and M93438)
- 6. NRC letter to TVA, dated June 23, 1999, Safety Evaluation for Generic Letter, Pressure Locking
and Thermal Binding of Safety-Related Power-
Operated Gate Valves, Browns Ferry Nuclear Plant (BFN) - (TAC Nos. M93436, M93437 and M93438)
Letter 95-07, Pressure Locking and Thermal
Binding of Safety-Related Power-Operated Gate
Valves 8. TVA letter to NRC, dated July 29, 2004, Browns Ferry Nuclear Plant (BFN) Unit 1 - Response to
Request for Additional Information Regarding
Generic Letter 95-07, Pressure Locking and
Thermal Binding of Safety-R elated Power Operated Gate Valves
- 9. NRC letter to TVA, dated January 28, 2005, Browns Ferry Nuclear Plant, Unit 1 - Closeout of
Generic Letter 95-07, "Pressure Locking and
Thermal Binding of Safety-Related Power-Operated
Gate Valves," Browns Ferry Nuclear Plant, Unit 1 (TAC No. MC3125) 1 0. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006006
.
April 13, 2007 E1-83 Generic Letter 96-01, Testing of Safety-Related Logic Circuits
Commitment: BFN Unit 1 will implement the recommendations of Generic Letter 96-01 prior to restart.
Discussion: TVA committed to implement the recommendations of Generic Letter 96-01 prior to restart in
Reference 1.
Status: Closed
NRC closed this item in Inspection Report 2006-009 (Reference 2).
References:
1.
TVA letter to NRC, dated April 18, 1996, Response to Generic Letter (GL) 96-01, Testing
of Safety-Related Logic Circuits (TAC Nos.
M94650, M94651, M95652, M94732, M94733, M94750)
- 2. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-84 Generic Letter 96-05, Periodic Verification of Design-Basis Capability of Motor-Operated Valves
Commitment: BFN Unit 1 will implement the Joint Owner's Group recommended GL 96-0 5 Periodic Verification Program, and begin testing during the first refueling outage
after restart.
Discussion: TVA responded for all its nuclear facilities in Reference 1 and supplemented the response in
Reference 2. TVA was a member of the Joint Owners'
Group (JOG), which culminated in the dynamic
testing of 176 Motor Operated Valves (MOVs) at 98
BWR and PWR plants. Each valve was tested three
times over five years to address potential
degradation in required thrust or torque. The
final Topical Report and recommendations for
periodic testing were submitted by Reference
- 3. No additional interim testing is required for Unit 1
since the industry program has been completed.
Status: C-C
NRC closed this item in Inspection Report 2005-009 (Reference 4).
References:
1.
TVA letter to NRC, dated March 17, 1997, Browns Ferry Nuclear Plant (BFN) (TAC Nos. M97020, M97021, M97022), Sequoyah Nuclear Plant (SQN),
Watts Bar Nuclear Plant (WBN), and Bellefonte
Nuclear Plant (BLN) 180-Day Response to NRC
Generic Letter (GL) 96-0 5, Periodic Verification of Design-Basis Capability of Safety-Related
Motor-Operated Valves, Dated September 18, 1996
- 2. TVA letter to NRC, dated April 28, 1998, Browns Ferry Nuclear Plant (BFN) (TAC Nos. M97020, M97021, M97022), Sequoyah Nuclear Plant (SQN),
Watts Bar Nuclear Plant (WBN), and Bellefonte
Nuclear Plant (BLN) Response to NRC's Safety
Evaluation Dated October 30, 1997, on Joint
Owners Group's (JOG) Program for Generic Letter (GL) 96-05, Periodic Verification (PV) of
Motor-Operated Valves (MOV) Described in Topical
Report MPR-1807 (Revision 2)
- 3. JOG letter to NRC, dated February 27, 2004, Joint Owners Group Program on Motor-Operated
Valve Periodic Verification
- 4. NRC letter to TVA, dated February 13, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery -NRC
Integrated Inspection Report 05000259/2005009
April 13, 2007 E1-85 Generic Letter 96-06, Assurance of Equipment Operability and Containment Integrity During Design-Basis
Accident Conditions
Commitment: TVA will address Generic Letter 96-06 prior to restart.
Discussion: On September 30, 1996, NRC issued Generic Letter 96-06, which requested licensees address the
susceptibility for waterhammer and two-phase flow
in the containment air cooler system and over
pressurization of piping that penetrates
containment.
As described in Reference 1, TVA evaluated the
Unit 1 cont a inment air cooler cooling water systems to determine if they are susceptible to either
water hammer or two-phase flow conditions during
postulated accident conditions. TVA has also
evaluated piping systems that penetrate containment
to determine if they are susceptible to thermal
expansion of fluid such that overpressurization of
piping may occur. Two commitments resulted from
this evaluation:
The Drywell Floor and Equipment Drains system is acceptable based on leakage through valves which
will avoid thermally induced pressure increases
above the rated design pressure of the system.
However, TVA will modify the system to provide a
designed method of overpressure protection.
The Demineralized Water system has the potential to be affected by overpressurization during a
postulated LOCA if the piping is completely
filled with water and isolated. In response, TVA will implement procedure changes to assure
the system is sufficiently drained following use
and is open to containment during power
operation.
In Reference 2 , NRC stated that TVA had provided an acceptable resolution to the concerns of the
Generic Letter.
April 13, 2007 E1-86 Status: C-C TVA modified the Drywell Floor and Equipment Drains system to provide a designed method of
overpressure protection.
Demineraliz e d water piping in the Unit 1 drywell has been either removed or abandoned. Procedure
changes were not required.
NRC closed this item in Inspection Report 2005-008 (Reference 3).
References:
1.
TVA letter to NRC, dated May 12, 2004, Browns Ferry Nuclear Plant (BFN) Unit 1 - Generic
Letter 96-0 6, Assurance of Equipment Operability and Containment Integrity During Design Basis
Accident Conditions
- 2. NRC letter to TVA, dated February 7, 2005, Browns Ferry Nuclear Plant, Unit 1 - Closeout of
Generic Letter 96-06, "Assurance of Equipment
Operability and Containment Integrity During
Design-basis Accident Conditions" (TAC No. MC3186)
- 3. NRC letter to TVA, dated November 14, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery -NRC
Integrated Inspection Report 05000259/2005008
April 13, 2007 E1-87 Generic Letter 97-04, Assurance Of Sufficient Net Positive Suction Head For Emergency Core Cooling and
Containment Heat Removal Pumps
Commitment: TVA will address Generic Letter 97-04 prior to restart.
Discussion: On October 7, 1997, NRC issued Generic Letter 97-04, which requested licensees review the current
design-basis analyses used to determine the
available net positive suction head for the
emergency core cooling (including core spray and
decay heat removal) and containment heat removal
pumps.
TVA replied to Generic Letter 97-04 for BFN Unit 1
in Reference 1. TVA stated that it would request
approval to credit containment overpressure as part
of proposed Technical Specifications (TS) 431, the
BFN Unit 1 Extended Power Uprate application, which
was submitted in Reference 2.
U pon approval of the requested change, no additional information should
be required to close Generic Letter 97-04 for BFN
Unit 1.
Status: C-C
In a letter dated July 26, 2006 (Reference 3), NRR
issued an SER concluding BFN has satisfied this
Bulletin.
NRC closed this item in Inspection Report 2006-009 (Reference 4).
References:
1.
TVA letter to NRC, dated May 6, 2004, Browns Ferry Nuclear Plant (BFN) Unit 1 - Response to
NRC Generic Letter (GL) 97-04, Assurance of
Sufficient Net Positive Suction Head (NPSH) for
Emergency Core Cooling and Containment Heat
Removal Pumps
Specifications (TS) Change TS - 431 - Request
For License Amendment - Extended Power Uprate (EPU) Operation," dated June 28, 2004 April 13, 2007 E1-88
- 3. NRC Letter to TVA, dated July 27, 2006, Browns Ferry Nuclear Plant, Unit 1 -Review of Licensee
Response To NRC Generic Letter 97-04, "Assurance
Of Sufficient Net Positive Suction Head for
Emergency Core Cooling And Containment Heat
Removal Pumps" (TAC No. MC3392)
- 4. NRC letter to TVA, dated March 5, 2007, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006009
April 13, 2007 E1-89 Generic Letter 98-01, Year 2000 Readiness of Computer Systems at Nuclear Power Plants
Commitment: None
Discussion: Generic Letter 98-01 requested information regarding year 2000 readiness at nuclear power
plants. TVA certified the readiness of its nuclear
facilities in Reference 1. In Reference 2, the NRC
concluded that all requested information had been
provided. Therefore, NRC considered GL 98-01 to
be closed for TVA's nuclear facilities.
Status: C-C
NRC closed this item in Inspection Report 2005-006 (Reference 3).
References:
1.
TVA letter to NRC, dated June 29, 1999, Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3, Sequoyah Nuclear Plant (SQN) Units 1 and 2, Watts Bar Nuclear Plant (WBN) Unit 1, Final
Response to Generic Letter (GL) 98-01, Year 2000 (Y2K) Readiness of Computer Systems at Nuclear
Power Plants
- 2. NRC letter to TVA, dated October 18, 1999, Watts Bar, Browns Ferry and Sequoyah - Response to
Generic Letter 98-01, "Year 2000 Readiness of
Computer Systems at Nuclear Power Plants" (TAC Nos. MA1810, MA1811, MA1812, MAl888, MA1889
and MA1906)
- 3. NRC letter to TVA, dated May 16, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery -
NRC Integrated Inspection Report
April 13, 2007 E1-90 Generic Letter 98-04, Potential for Degradation of the Emergency Core Cooling System and the Containment
Spray System after a Loss-Of-Coolant
Accident Because of Construction and
Protective Coating Deficiencies and Foreign
Material in Containment
Commitment: TVA will address Generic Letter 98-04 prior to restart.
Discussion: NRC issued GL 98-04 to alert licensees to concerns with the material condition of Service Level 1
protective coatings inside the containment.
GL 98-04 requested that licensees describe their
programs for ensuring that Service Level 1
protective coatings inside containment do not
detach from their substrate and adversely affect
the ability of the Emergency Core Cooling Systems (ECCS) and the safety-related Containment Spray
System to perform their function following a Design
Basis Loss of Coolant Accident (LOCA).
TVA responded to GL 98-04 for Unit 1 in
Reference 1. In summary, TVA has implemented
controls for the procurement, application, and
maintenance of Service Level 1 protective coatings
used inside the primary containment in a manner
that is consistent with the licensing basis and
regulatory requirements applicable to BFN. The NRC
Safety Evaluation (Reference 3) concluded that BFN
had provided the information required by GL 98-04.
Status: C-C IR 2006-006 (Reference 2) stated "- However, final closure of this item will be deferred until NRR
completes their review in this area."
NRC closed this item in Inspection Report 2006-008 (Reference 4).
References:
1.
TVA letter to NRC, dated May 11, 2004, Browns Ferry Nuclear Plant (BFN) Unit 1 - Response to
NRC Generic Letter (GL) 98-04, Potential for
Degradation of the Emergency Core Cooling System
and the Containment Spray System After a Loss-
Of-Coolant Accident Because of Construction and
Protective Coating Deficiencies and Foreign
Material in Containment
- 2. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC April 13, 2007 E1-91 Integrated Inspection Report 05000259/2006006
- 3. NRC letter to TVA dated September 27, 2006, Browns Ferry Nuclear Plant, Unit 1 - Review of
Licensee Response to NRC Generic Letter 98-04, "Potential for Degradation of the Emergency Core
Cooling System and the Containment Spray System
After a Loss-Of-Coolant Accident Because of
Construction and Protective Coating Deficiencies
and Foreign Material in Containment"
- 4. NRC letter to TVA, dated November 9, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery -NRC
Integrated Inspection Report 05000259/2006008
April 13, 2007 E1-92 Generic Letter 2003-01, Control Room Habitability
Commitment: TVA will address Generic Letter 2003-01 prior to restart.
Discussion: NRC issued GL 2003-01 to:
- 1. alert addressees to findings at U.S. power reactor facilities suggesting that the control
room licensing and design bases, and applicable
regulatory requirements may not be met, and that
existing technical specification surveillance
requirements (SRs) may not be adequate, 2. emphasize the importance of reliable, comprehensive surveillance testing to verify
control room habitability, 3. request addressees to submit information that demonstrates that the control room at each of
their respective facilities complies with the
current licensing and design bases, and
applicable regulatory requirements, and that
suitable design, maintenance and testing control
measures are in place for maintaining this
compliance, and
- 4. collect the requested information to determine if additional regulatory action is required.
TVA responded to GL 2003-01 in Reference 1. In
summary, the BFN Units 1, 2, and 3 design basis and
licensing basis are in compliance with the
applicable regulatory requirements. The plant is
constructed and maintained in accordance with its
design, and the testing performed in accordance
with the BFN Technical Specifications (TS) and
their bases is adequate to demonstrate this
compliance and material condition.
In Reference 2, the NRC provided a request for
additional information (RAI) to TVA. TVA answered
this RAI in Reference 3.
Status: Complete
April 13, 2007 E1-93
References:
1.
TVA letter to NRC, dated December 8, 2003, Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 Response to NRC Generic Letter (GL)
2003 Control Room Habitability
- 2. NRC letter to TVA, dated January 9, 2007, Browns Ferry Nuclear Plant, Units 1, 2 and 3, Request
For Additional Information Regarding Generic
Letter 2003-01, "Control Room Habitability"
- 3. TVA letter to NRC, dated February 8, 2007, Browns Ferry Nuclear Plant Units 1, 2 and 3 -
Request For Additional Information Regarding
Generic Letter 2003-01, "Control Room
Habitability"
April 13, 2007 E1-94 Generic Safety Issue 75 / Multi-Plant Action B085, Generic Letter 83-28, Item 1.2, Post-Trip Review -
Data and Information Capability
Issue: This issue arose from the staff concerns resulting from analysis of events that occurred at the Salem
Nuclear Power Plant on February 22 and 25, 1983.
The study of these events resulted in the issuance
of NUREG-1000 and Generic Letter 83-28. Item 1.2
of the Generic Letter requests licensees have the
capability to record, recall, and display data and
information to permit diagnosing the causes of
unscheduled reactor shutdowns and the proper
functioning of safety-related equipment during
these events using systematic safety assessment
procedures.
Discussion: Refer to previous topic entitled Generic Letter 83-28, Salem ATWS, Item 1.2, Post Trip Review (Data and Information Capability) (Page E1-55).
Status: Refer to previous topic entitled Generic Letter 83-28, Salem ATWS, Item 1.2, Post Trip Review (Data and Information Capability) (Page E1-55).
References:
Refer to previous topic entitled Generic Letter 83-28, Salem ATWS, Item 1.2, Post Trip Review (Data and Information Capability) (Page E1-55).
April 13, 2007 E1-95 HVAC Duct Supports
Commitment: The HVAC Duct Supports program will be implemented in accordance with the Unit 2 precedent.
Discussion: The approval of the program for the seismic qualification of HVAC duct supports is contained in
References 1 and 2. The design criteria for the
seismic qualification of the HVAC and supports was
submitted in Reference 3. The NRC staff's Safety
Evaluation Report (SER) on the criteria was
included in Reference 4.
Status: C-C
For Unit 1, a review was performed to identify the
areas of Class I HVAC ductwork that were not
previously qualified for Units 2 and 3 operation.
The only areas specific to Unit 1 thus identified
were the ductwork associated with the pump motor
coolers for the Unit 1 Residual Heat Removal system
and Core Spray system. Based upon the seismic
qualification calculations, modifications have been
completed to ensure that this ductwork is qualified
to the long term requirements of the design
criteria.
NRC closed this item in document dated
March 9, 2007 (Reference 5).
References:
1.
NRC letter to TVA, dated August 22, 1990, Safety Evaluation of Inspection Open Item Regarding
HVAC Ductworks and Supports for Browns Ferry
Nuclear Plant, Unit 2 (TAC No. 62259)
- 2. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 - Browns
Ferry, Unit 2, Section 2.2.2.4 (Page 2-5)
Seismic Design Criteria
- 4. NRC letter to TVA, dated July 16, 1992, Evaluation of Seismic Design Criteria for
Heating Ventilation and Air Conditioning
- 5. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-96 Instrument Sensing Lines
Commitment: 1.
The H 2 O 2 analyzers will be modified in accordance with the Unit 2 precedent.
- 2. Where satisfactory operation can not be justified, the sensing lines will be reworked.
- 3. The 10 CFR 50, Appendix R, FSAR Appendix M, and Generic Evaluation of Internally Generated
Missiles programs will require evaluations to
maintain the integrity of instrument sense line
separation.
Discussion: The action plan for dispositioning instrument sensing line issues, including a discussion of
lessons learned from the Unit 2 precedent, was
provided in Reference 1. In Reference 2, NRC
concluded that the program to address concerns
related to instrument sensing lines was adequate.
Status: Complete
The sample lines to the H 2 O 2 analyzers were modified to assure that there are no moisture traps
which would block the air sample flow from the
drywell/torus to the analyzers.
Safety-related sensing lines were evaluated in
order to maintain the integrity of instrument
sensing line separation as required by the
10 CFR 50, Appendix R, FSAR Appendix M, and Generic
Evaluation of Internally Generated Missiles
programs. Sensing lines were either justified for
use-as-is, or modified as required.
References:
1.
TVA letter to NRC, dated February 13, 1991, Action Plan to Disposition Concerns Related to
Instrument Sensing Lines for Units 1 and 3
Concerns Related to Instrument Sensing Lines for
the Browns Ferry Nuclear Plant, Units 1 and 3
April 13, 2007 E1-97 Instrument Tubing
Commitment: Safety-related instrument tubing will be seismically qualified to meet the final design
criteria.
Discussion: The action plan for dispositioning concerns regarding the seismic qualification of instrument
tubing, including a discussion of lessons learned
from the Unit 2 precedent, was provided in
Reference 1. Additional information regarding
inspection attributes and sampling sizes was
provided in Reference 2. In Reference 3, NRC
concluded that the program was an acceptable basis
for restart of Unit 1 provided that the licensee
also evaluates the instrument tubing populations in
all units for any new attributes which may be
identified during the implementation of the revised
program.
Status: Complete
The affected systems / supports were analyzed for
Seismic Class I qualification, and necessary
modifications were completed.
References:
1.
TVA letter to NRC, dated February 27, 1991, Action Plan to Disposition Concerns Regarding
the Seismic Qualification of Units 1 and 3
Instrument Tubing
Support Plans for Units 1 and 3 - Additional
Information
Seismic Qualification of Instrument Tubing
Programs for Browns Ferry Nuclear Plant, Units 1 and 3 April 13, 2007 E1-98 Intergranular Stress Corrosion Cracking (IGSCC)
Commitment: The Intergranular Stress Corrosion Cracking (IGSCC) program will be implemented in accordance with the
Unit 2 precedent.
Discussion: Refer to previous topic entitled Generic Letter 88 NRC Position on IGSCC in BWR Austenitic
Stainless Steel Piping (Page E1-60).
Status: Refer to previous topic entitled Generic Letter 88 NRC Position on IGSCC in BWR Austenitic
Stainless Steel Piping (Page E1-60).
References:
None
April 13, 2007 E1-99 Large Bore Piping Supports
Commitment: TVA will complete Bulletin 79-14.
Discussion: Refer to previous topic entitled Bulletin 79-14, Seismic Analysis for As-Built Safety-Related Piping
Systems (Page E1-6).
Status: Refer to previous topic entitled Bulletin 79-14, Seismic Analysis for As-Built Safety-Related Piping
Systems (Page E1-6).
References:
None
April 13, 2007 E1-100 License Renewal - Appendix F Commitments
Commitment: TVA will implement the License Renewal - Appendix F commitments prior to Unit 1 restart.
Discussion: On April 21, 2006, TVA sent the NRC a revised list of commitments for License Renewal (Reference 1).
Table 3 of Enclosure 1 of the letter contains the
list of License Renewal commitments which are
required for Unit 1 restart. The items originate
from Appendix F of the License Renewal Application
and are required to make the current licensing
basis (CLB) of Unit 1 at restart the same as the
CLB for Units 2 and 3. These commitments are
contained in Table 3 of Appendix A of the Safety
Evaluation Report related to the License Renewal of
BFN (Reference 2).
Status: Each of the 13 Appendix F commitments and its status is as follows: F.1 Evaluate and modify, as required, main steam leakage path piping to ensure structural
integrity.
Status: Open F.2 Implement Containment Atmosphere Dilution (CAD) System modification.
Status: Complete TVA completed the modifications to the CAD system. F.3 Revise Fire Protection Report per Unit 1 License Condition 2.C.13.
Status: Refer to previous topic entitled Fire Protection / 10 CFR 50, Appendix R (Page E1-46). F.4 Implement Environmental Qualification Program. Status: Refer to previous topic entitled Environmental Qualification (Page E1-45).
April 13, 2007 E1-101 F.5 Address GL 88-01, and make necessary plant modifications.
Status: Refer to previous topic entitled Generic Letter 88-01, NRC Position
Stainless Steel Piping (Page E1-60). F.6 BWRVIP Programs used for Units 2 and 3 will be used for Unit 1.
Status: Complete Required inspections have been completed, and examination reports
have been filed. The required
Unit 1 examinations have been
incorporated into applicable
procedure. F.7 Install ATWS features.
Status: Refer to the topic entitled Unresolved Safety Issue A-9, Anticipated Transients Without
Scram (Page E1-134). F.8 Remove Reactor Vessel Head Spray piping in drywell, and seal the primary containment
Status: Complete Piping has been removed, and penetrations have been capped. F.9 Implement the Hardened Wetwell Vent modification.
Status: C-C Refer to previous topic entitled Generic Letter 89-16, Installation
of a Hardened Wetwell Vent (Page E1-74).
April 13, 2007 E1-102 F.10 Cap Service Air and Demineralized Water Primary Containment Penetrations.
Status: Complete The Service Air and Demineralized Water Primary Containment
Penetrations were capped. F.11 Modify Auxiliary Decay Heat Removal (ADHR)
System to serve Unit 1.
Status: Complete ADHR has been modified to serve Unit 1. F.12 Fully implement the Maintenance Rule.
Unit 1's temporary exemption ceases to be
effective.
Status: Open F.13 Replace RWCU piping outside of primary containment with IGSCC resistant piping.
Status: Complete Implement actions requested in GL 89-10 for RWCU.
Status: Complete
References:
1.
TVA letter to NRC, dated April 21, 2006, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, AND 3 -
License Renewal Application (LRA) - Revised
Commitment List (TAC Nos. MC1704, MC1705, and
MC1706) 2. NUREG-1843, Supplement 1, "Safety Evaluation Report Related to the License Renewal of the
Browns Ferry Nuclear Plant, Units 1, 2, and 3, Docket Nos. 50-259, 50-260, and 50-296"
April 13, 2007 E1-103 License Renewal - Non-Appendix F Commitments
Commitment: TVA will implement applicable License Renewal -
Non-Appendix F Commitments prior to Unit 1 restart.
Discussion: On April 21, 2006, TVA sent the NRC a revised list of commitments for License Renewal (Reference 1).
of the letter contains the list of
License Renewal commitments which are required for
Unit 1 restart. Certain of those commitments are
not Appendix F items but are required to be
implemented prior to Unit 1 restart. These
commitments are contained in Appendix A of the
Safety Evaluation Report related to the License
Renewal of BFN (Reference 2).
The applicable commitments are as follow: Table 1, Item 24., last portion; and Table 2 items with an Implementation Schedule of "Prior to Unit 1 restart."
Status: Open
References:
1.
TVA letter to NRC, dated April 21, 2006, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, AND 3 -
License Renewal Application (LRA) - Revised
Commitment List (TAC Nos. MC1704, MC1705, and
MC1706) 2. NUREG-1843, Supplement 1, "Safety Evaluation Report Related to the License Renewal of the
Browns Ferry Nuclear Plant, Units 1, 2, and 3, Docket Nos. 50-259, 50-260, and 50-296"
April 13, 2007 E1-104 Long Term Torus Integrity Program
Commitment: TVA committed to resolve torus attached piping support discrepancies in accordance with the Unit 2 criteria precedent. The inspection of the
nonsafety-related catwalk will be limited to welds
and bolted connections associated with maintaining
the integrity of the safety-related structures.
The resolution of catwalk discrepancies will be in
accordance with the Unit 2 criteria.
Discussion: On January 13, 1981 (Reference 1), the Commission issued an Order that required the reassessment of
the containment design for suppression pool
hydrodynamic loading conditions. In Reference 2 , a subsequent Order extended the modification
completion date until prior to the start of
Cycle 6. NRC conducted a post-i mplementation audit review of the BFN Plant Unique Analysis Report for
the Mark I containment long-term program (Reference 3). The staff determined that all but a few of the modifications made by TVA were in
accordance with the generic acceptance criteria and
the deviations from the acceptance criteria were
found acceptable. Discrepancies were identified
between design drawings and the actual
modifications. The action plan for dispositioning
the long-term torus integrity discrepancies was
provided by TVA in Reference 4 and approved by NRC
in Reference 5.
In Reference 6, NRC identified a Violation with
regards to activities associated with the Unit 1
LTTIP corrective actions. TVA responded in
Reference 7.
Status: Complete
TVA performed modifications to resolve torus
attached piping support discrepancies, safety-
related torus and torus related structure
discrepancies, and nonsafety-related catwalk
discrepancies in accordance with the Unit 2
precedent.
References:
1.
NRC letter to TVA, dated January 13, 1981, in regards to Orders for Modification of Licenses
and Grant of Extension of Exemptions
- 2. NRC letter to TVA, dated January 19, 1982, in regards to Order Modifying the January 13, 1981
Order April 13, 2007 E1-105
- 3. NRC letter to TVA, dated May 6, 1985, Mark I Containment Long Term Program
- 4. TVA letter to NRC, dated April 29, 1991, Program for Resolving Long-Term Torus Integrity Issue
Prior to the Restart of Units 1 and 3
- 5. NRC letter to TVA, dated February 10, 1992, Evaluation of Long-Term Torus Integrity Program
for Browns Ferry Nuclear Plant, Units 1 and 3
- 6. NRC letter to TVA, dated May 12, 2004, Notice of Violation (Browns Ferry Nuclear Plant Unit 1
Recovery - NRC Inspection Report
No. 5000259/2004011)
Report 50-259/2004-011 - Reply to Notice Of
April 13, 2007 E1-106 Lower Drywell Platforms and Miscellaneous Steel
Commitment: The lower drywell steel platforms and miscellaneous steel will be evaluated and modified, if required, to meet the design criteria.
Discussion: The action plan for dispositioning the Lower Drywell Platforms and Miscellaneous Steel issue was
provided in Reference 1. Additional information
requested by the Staff was provided in Reference 2.
Additional information was requested by the Staff
in Reference 3 and provided by TVA in Reference 4.
An NRC position regarding the design criteria was
issued by Reference 5 and a subsequent Safety
Evaluation and request for additional information
was issued as Reference 6. This additional
information was provided by TVA in Reference 7.
A supplemental Safety Evaluation was issued by NRC
in Reference 8. Additional information was
provided by TVA in References 9 and 10. The final
Safety Evaluation was issued in Reference 11 and
the issue was closed after an audit of the design
criteria implementation as documented in
Reference 12.
Status: C-C
The lower drywell steel platforms and miscellaneous
steel were evaluated and modified, if required, to
meet the design criteria.
NRC closed this item in document dated March 9, 2007 (Reference 13).
References:
1.
TVA letter to NRC, dated June 12, 1991, Corrective Action Plan and Design Criteria for
Lower Drywell Steel Platforms and Miscellaneous
Steel 2. TVA letter to NRC, dated November 8, 1991, Seismic Design Criteria for Lower Drywell Steel
Platforms and Miscellaneous Steel
- 3. NRC letter to TVA, dated December 12, 1991, Request for Additional Information Regarding
Browns Ferry Drywell and Miscellaneous Steel
Design Criteria April 13, 2007 E1-107
- 4. TVA letter to NRC, dated February 6, 1992, Lower Drywell Platforms and Miscellaneous Steel
Seismic Criteria
- 5. NRC letter to TVA, dated March 19, 1992, NRC Staff Position on Proposed Ductility Ratio
Design Criteria
- 6. NRC letter to TVA, dated July 13, 1992, Safety Evaluation and Request for Additional
Information Regarding Browns Ferry Nuclear Plant
Units 1, 2, and 3 Design Criteria for Lower
Drywell Steel Platforms and Miscellaneous Steel
- 7. TVA letter to NRC, dated July 31, 1992, Response to Request for Additional Information Regarding
Design Criteria for Lower Drywell Steel
Platforms and Miscellaneous Steel
- 8. NRC letter to TVA, dated October 29, 1992, Supplemental Safety Evaluation of Steel Design
Criteria for the Browns Ferry Nuclear Power
Plant 9. TVA letter to NRC, dated September 30, 1992, Resolution of the Thermal Growth Issue Outside
Containment 1 0. TVA letter to NRC, dated June 29, 1993, Resolution of the Thermal Growth Issue 1 1. NRC letter to TVA, dated December 7, 1993, Supplemental Safety Evaluation of Structural
Steel Thermal Growth Design Criteria 1 2. NRC letter to TVA, dated April 20, 1994, Audit of Structural Steel Design Criteria
Implementation 1 3. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of the
Browns Ferry Unit 1 Restart Panel - Docket No.
50-259" April 13, 2007 E1-108 Moderate Energy Line Break (MELB)
Commitment: The Moderate Energy Line Break (MELB) program will be implemented in accordance with the Unit 2
precedent.
Discussion: As part of the restart effort on Unit 2, TVA committed to review the effects of flooding due to
breaks in moderate energy lines outside primary
containment (Reference 1). NRC approval of the
program was documented in Reference 2.
The critical plant features that are required to
mitigate or limit the consequences of moderate
energy piping failures exist in the current BFN
design. The results of the Unit 1 evaluation
concluded that Browns Ferry conforms to the
original licensing basis for MELB flooding and t h at the existing flooding studies and protective
measures are adequate to justify continued
operations (Reference 3).
Status: C-C
NRC closed this item in Inspection Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated October 24, 1988, Browns Ferry Nuclear Plant (BFN) - Nuclear
Performance Plan, Revision 2
- 2. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 - Browns
Ferry, Unit 2, Section 3.8 (Page 3-8)
the Program - Moderate Energy Line Break (MELB)
Flooding Evaluation
- 4. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-109 NUREG-0737 (TMI Action Plan), Action Item I.D.1, Control Room Design Review
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item I.D.1 - Control Room Design Review.
Discussion: Pursuant to NUREG-0737 (TMI Action Plan) and Supplement 1, TVA provided its Control Room Design
Review (CRDR) corrective action plan and
commitments in Reference 1. NRC's initial Safety
Evaluation Report (SER) was issued as Reference 2.
TVA provided additional information in Reference 3.
In Reference 4, TVA also committed to complete all
safety and non-s afety significant Human Engineering Discrepancies (HEDs) prior to the restart of
Units 1 and 3. The final SER for the BFN CRDR was
provided in Reference 5.
As part of BFN's Operating and Maintenance Cost
Reduction Program, TVA submitted a Cost Beneficial
Licensing Action to discontinue the cost-benefit
analysis of non-safety significant HEDs (Reference 6). NRC approval of this request was
contained in Reference 7.
Status: Closed
TVA is implementing its CRDR c o rrective action plan for Unit 1 and all safety significant HEDs will be
corrected.
NRC closed this item in Inspection Report 2006-007 (Reference 8).
References:
1.
TVA letter to NRC, dated December 30, 1986, Detailed Control Room Design Review (DCRDR) -
NUREG-0737, Item I.D.1
- 2. NRC letter to TVA, dated August 9, 1988, Safety Evaluation for the Detailed Control Room Design, Browns Ferry Nuclear Plant, Units 1, 2 and 3 (TACs 56104, 56105, 56106)
Detailed Control Room Design Review (DCRDR)
- 4. TVA letter to NRC, dated August 22, 1991, Supplemental Response to NRC Safety Evaluation
for the BFN Detailed Control Room Design
Review (DCRDR)
April 13, 2007 E1-110
- 5. NRC letter to TVA, dated October 29, 1991, Safety Evaluation of the Browns Ferry Nuclear
Plant Detailed Control Room Design Review
- 6. TVA letter to NRC, dated December 15, 1993, Operating & Maintenance (O&M) Cost Reduction
Program - Cost Beneficial Licensing Action -
Revision of Detailed Control Room Design
Review (DCRDR) Program to Discontinue Cost-
Benefit Analysis of Non-S afety Significant Human Engineering Discrepancies (HEDs)
- 7. NRC letter to TVA, dated February 4, 1994, Revision of Detailed Control Room Design Review
Program to Discontinue Cost-Benefit Analysis of
Non-Safety Significant Human Engineering
Discrepancies
- 8. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-111 NUREG-0737 (TMI Action Plan), Action ItemI.D.2, Safety Parameter Display Console
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item I.D.2 - Safety Parameter Display
Console.
Discussion: Refer to the previous item entitled Generic Letter 89 Task Action Plan Item I.D.2 - Safety
Parameter Display System (Page E1-68).
Status: Refer to the previous item entitled Generic Letter 89 Task Action Plan Item I.D.2 - Safety
Parameter Display System (Page E1-68).
References:
None
April 13, 2007 E1-112 NUREG-0737 (TMI Action Plan), Action Item II.B.3, Post-Accident Sampling System
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.B.3 - Post-Accident Sampling System (PASS).
Discussion: A description of BFN's PASS design was provided in References 1 and 2. The Safety Evaluation Report
for this system was provided by Reference 3.
TVA submitted a request to decommit to the
requirement for a PASS in Reference 4. NRC
approved this request in Reference 5.
TVA committed to:
Develop contingency plans for obtaining and analyzing highly radioactive samples of reactor
coolant, the suppression pool, and containment
atmosphere prior to Unit 1 fuel load; and Describe in emergency plan implementing procedures the capability for classifying fuel
damage events at the Alert level threshold at
radioactivity levels of 300 uCi/ml dose
equivalent I-131 prior to Unit 1 fuel load.
Status: C-C
TVA has implemented contingency plans for obtaining
and analyzing highly radioactiv e samples of reactor coolant, the suppression pool, and containment
atmosphere.
Emergency plan implementing procedures contain the capability for classifying fuel damage events at
the Alert level threshold at radioactivity levels
of 300 uCi/ml dose equivalent I-131.
NRC closed this item in Inspection Report 2006-006 (Reference 6).
References:
1.
TVA letter to NRC, dated December 19, 1986, NUREG-0737, Item II.B.3 - Postaccident Sampling
System 2. TVA letter to NRC, dated April 1, 1987, NUREG-0737, Item II.B.3 - Postaccident Sampling System
- 3. NRC letter to TVA, dated May 27, 1987, Post Accident Sampling System April 13, 2007 E1-113
- 4. TVA letter to NRC, dated February 19, 2003, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Technical Specifications (TS) Change 423
- Eliminate Requirements for Post Accident
Sampling System (PASS) using the Consolidated
Line Item Improvement Process and Delete
Regulatory Commitment
- 5. NRC letter to TVA, dated May 9, 2003, Browns Ferry Nuclear Plant, Units 1, 2 and 3,
Re: Issuance of Amendments Eliminating
Requirements for Postaccident Sampling (TAC Nos. MB7747, MB7748 and MB7749)
- 6. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006006
April 13, 2007 E1-114 NUREG-0737 (TMI Action Plan), Action Item II.E.4.2.1-4, Containment Isolation
Dependability - Implement Diverse
Isolation
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.E.4.2.1 Containment Isolation
Dependability - Implement Diverse Isolation.
Discussion: In Reference 1, NRC requested additional information regarding Units 1 and 3 conformance
with NUREG-0737, Item II.E.4.2 and 10 CFR 50, Appendix J. In order to minimize the number and
scope of updates that would have to be provided to
NRC on this issue, TVA replied in Reference 2 using
the anticipated configuration at the time of the
restart of Unit 1. NRC approval of the Unit 1
containment isolation design is provided in
Reference 3. NRC was notified of subsequent
changes to the containment isolatio n configuration, which were being made under the provisions of
10 CFR 50.59, in Reference 4.
Status: Open
References:
1.
NRC letter to TVA, dated May 5, 1992, Request for Additional Information to Review Browns
Ferry Nuclear Plant Units 1 and 3 Compliance
with NUREG-0737 Item II.E.4.2 and 10CFR50, Appendix J
- 2. TVA letter to NRC, dated September 1, 1992, Response to NRC Request for Additional
Information Regarding Units 1 and 3 Conformance
with NUREG-0737, Item II.E.4.2 and 10CFR50, Appendix J
- 3. NRC letter to TVA, dated January 6, 1995, Browns Ferry Nuclear Plant Units 1 and 3 - NUREG-0737, Item II.E.4.2, Containment Isolation
Dependability
Information for Conformance with NUREG-0737, Item II.E.4.2, and 10 CFR 50, Appendix J
April 13, 2007 E1-115 NUREG-0737 (TMI Action Plan), Action Item II.F.1.2.C, Accident - Monitoring -Containment High Range
Radiation
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.F.1.2.C - Accident - Monitoring -
Containment High Range Radiation.
Discussion: In Reference 1, TVA committed to install a containment high range radiation monitor. In
Reference 2, NRC stated no deviations from NRC
requirements had been identified; hence no NRC
review was required. Reference 3 issued a
Confirmatory Order for the installation of the
radiation monitors prior to start-up in Cycle 6.
Status: Closed
TVA will upgrade the two Unit 1 drywell radiation
monitor loops to meet the requirements of
NUREG-0737 for Containment High Range Radiation
Monitors (CHRRM). The modifications will ensure
that the CHRRMs are capable of detecting and
measuring the radiation level within the drywell
during and following an accident.
NRC closed this item in Inspection Report 2006-006 (Reference 4).
References:
1.
TVA letter to NRC, dated December 23, 1980, in regards to post-TMI requirements
- 2. NRC letter to TVA, dated January 8, 1982, Re: Status of NUREG-0737 ItemII.F.1.3 at Browns Ferry Unit Nos. 1, 2 and 3
- 3. NRC letter to TVA, dated March 25, 1983, in regards to Confirmatory Order for Post-TMI
Related Items Set Forth in NUREG-0737
- 4. NRC letter to TVA, dated May 15, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006006
April 13, 2007 E1-116 NUREG-0737 (TMI Action Plan), Action Item II.F.1.2.D, Accident -
Monitoring - Containment Pressure
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.F.1.2.D - Accident - Monitoring -
Containment Pressure.
Discussion: In Reference 1, TVA committed to install a containment pressure monitor. NRC requested
additional information in Reference 2, which was
provided by TVA in Reference 3. Reference 4 issued
a Confirmatory Order for the installation of the
pressure monitor prior to start-up in Cycle 6. The
Safety Evaluation Report for this item was issued
in Reference 5. NRC closed this item in Inspection
Report 90-29 (Reference 6).
Status: C-C
NRC closed this item in Inspection Report 2005-006 (Reference 7).
References:
1.
TVA letter to NRC, dated December 23, 1980, in regards to post-TMI requirements
- 2. NRC letter to TVA, dated March 22, 1982, NUREG-0737, Items I I.F.1.4, Containment Pressure Monitor; II.F.1.5, Containment Water Level
Monitor, and II.F.1.6, Containment Hydrogen
Monitor 3. TVA letter to NRC, dated April 26, 1982, in regards to NUREG-0 737, Items II.F.1.4, II.F.1.5, and II.F.1.6
- 4. NRC letter to TVA, dated March 25, 1983, in regards to Confirmatory Order for Post-TMI
Related Items Set Forth in NUREG-0737
- 5. NRC letter to TVA, dated June 16, 1983, NUREG-0737, Item II.F.1.4 Containment Pressure
Monitor, II.F.1.5 Containment Water Level
Monitor, and II.F.1.6 Containment Hydrogen
Monitor 6. NRC letter to TVA, dated November 8, 1990, Notice of Violation (NRC Inspection Report Nos.
50-259/90-29, 50-260/90-29, and
50-296/90-29)
- 7. NRC letter to TVA, dated May 16, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005006
April 13, 2007 E1-117 NUREG-0737 (TMI Action Plan), Action Item II.F.1.2.E, Accident -
Monitoring - Containment Water
Level Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.F.1.2.E - Accident - Monitoring -
Containment Water Level.
Discussion: In Reference 1, TVA committed to install a containment water level monitor. NRC requested
additional information in Reference 2, which was
provided by TVA in Reference 3. In Reference 4, NRC issued a Confirmatory Order for the
installation of the water level monitor prior to
start-up in Cycle 6 (July 1983). The Safety
Evaluation Report for this item was issued in
Reference 5. A Technical Specifications amendment
was issued to reflect the modifications performed
during that outage (Reference 6).
Status: C-C
NRC closed this item in Inspection Report 2005-006 (Reference 7).
References:
1.
TVA letter to NRC, dated December 23, 1980, in Regards to Post-TMI Requirements
- 2. NRC letter to TVA, dated March 22, 1982, NUREG-0737, Items I I.F.1.4, Containment Pressure Monitor; II.F.1.5, Containment Water Level
Monitor, and II.F.1.6, Containment Hydrogen
Monitor 3. TVA letter to NRC, dated April 26, 1982, in regards to NUREG-0 737, Items II.F.1.4, II.F.1.5, and II.F.1.6
- 4. NRC letter to TVA, dated March 25, 1983, in regards to Confirmatory Order for Post-TMI
Related Items Set Forth in NUREG-0737
- 5. NRC letter to TVA, dated June 16, 1983, NUREG-0737, Item II.F.1.4 Containment Pressure
Monitor II.F.1.5 Containment Water Level Monitor
II.F.1.6 Containment Hydrogen Monitor
- 6. NRC letter to TVA, dated December 12, 1983, in regards to Amendment 92 for Browns Ferry Unit 1
- 7. NRC letter to TVA, dated May 16, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005006
April 13, 2007 E1-118 NUREG-0737 (TMI Action Plan), Action Item II.F.2.4 (Generic Letter 84-23), Instrumentation for
Detection of Inadequate Core
Cooling Commitment: TVA committed to:
- 1. Convert level instruments which initiate the Reactor Protection System (RPS) and Emergency
Core Cooling System (ECCS) and provide class 1E
level indication in the control room to analog
trip units.
- 2. Minimize the effects of high drywell temperature on level indications by limiting the vertical
drop of the reference legs inside the drywell to
no more than two feet.
Discussion: The long-term modifications to improve the reliability and accuracy of BWR water level
measurement and instrumentation were requested by
Generic Letter 84-23. TVA committed in Reference 1 to replace the RPS and ECCS instruments with analog
trip units. TVA committed in Reference 2 to
minimize the vertical drop of the reference legs
inside containment by bringing the reference legs
outside the drywell at higher elevations. This
commitment was modified in accordance with the
commitment management process to limit the vertical
drop inside the drywell to be no more than 2 feet 5
inches. NRC found TVA's proposed modifications
acceptable in Reference
- 3. The NRC was notified of this change by Reference 4.
Status: C-C TVA has: 1. Converted level instruments which initiate the Reactor Protection System (RPS) and Emergency
Core Cooling System (ECCS) and provided class 1E
level indication in the control room to analog
trip units.
- 2. Minimized the effects of high drywell temperature on level indications by limiting the
vertical drop of the reference legs inside the
drywell to no more than two feet.
NRC closed this item in Inspection Report 2005-007 (Reference 5).
April 13, 2007 E1-119
References:
1.
TVA letter to NRC, dated April 8, 1995, in regards to Generic Letter 84-23
- 2. TVA letter to NRC, dated March 12, 1986, in regards to Generic Letter 84-23
- 3. NRC letter to TVA, dated November 18, 1986, NUREG-0731, Item II.F.2, Inadequate Core Cooling
Instrumentation (Generic Letter 84-23); MPA-F-26 4. TVA letter to NRC, dated September 5, 1995, Browns Ferry Nuclear Plant (BFN) - Units 1 and 3
Revision to Commitments Concerning The Senior
Management Assessment of Readiness Team (SMART)
and The Vertical Drop of Reactor Vessel
Reference Legs (Generic Letter 84-23)
- 5. NRC letter to TVA, dated August 15, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005007
April 13, 2007 E1-120 NUREG-0737 (TMI Action Plan), Action Item II.K.3.13, HPCI/RCIC Initiation Levels
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.K.3.13 - HPCI/RCIC Initiation
Levels.
Discussion: In Reference 1 , TVA states that it concurs with the BWR Owners' Group recommendation that separation of
the HPCI/RCIC level setpoints had no substantial
benefit and committed to implement an automatic
restart of RCIC. In Reference 2, NRC concurred
that no significant benefit would be gained by the
separation of the HPCI/RCIC initiation levels and
requested TVA evaluate the acceptance criteria
provided for the RCIC automatic restart. One
exception to the criteria was identified in
Reference 3 and approved by NRC in Reference 4.
TVA clarified Technical Specifications Bases Section 4.2 in Reference
- 5. The Bases were revised to state that the automatic restart feature is
tested during the performance of logic system
functional tests. The issuance of these Bases
changes was documented in Reference 6. TVA
modified the RCIC logic in order to automatically
restart the RCIC system on vessel low water level (without operator action) following a vessel high
water trip.
Status: C-C
NRC closed this item in Inspection Report 2005-007 (Reference 7).
References:
1.
TVA letter to NRC, dated December 23, 1980, in Regards to Post-TMI Requirements
- 2. NRC letter to TVA, dated March 16, 1983, NUREG-0737, Item II.K.3.13, RCIC Automatic
Restart 3. TVA letter to NRC, dated May 24, 1983, in Regards to NUREG-0737, Item II.K.3.13
- 4. NRC letter to TVA, dated September 19, 1983, NUREG-0737, Item II.K.3.13, RCIC Automatic
Restart 5. TVA letter to NRC, dated January 14, 1992, TVA BFN Technical Specification (TS) No. 300 Reactor
Core Thermal-Hydraulic Stability April 13, 2007 E1-121
- 6. NRC letter to TVA, dated May 31, 1994, Issuance of Technical Specification Amendments for the
Browns Ferry Nuclear Plant Units 1 and 3 (TS 300) 7. NRC letter to TVA, dated August 15, 2005, B r owns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005007
April 13, 2007 E1-122 NUREG-0737 (TMI Action Plan), Action Item II.K.3.18, ADS Actuation Modifications
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.K.3.18 - ADS Actuation
Modifications.
Discussion: In response to Item II.K.3.18, the BWR Owners' Group performed an evaluation of options for
compliance. Two of these options were found to be
acceptable by the NRC Staff and TVA was requested
in Reference 1 to commit to one of these options.
TVA chose Option 2, to modify the ADS logic to
allow the ADS to initiate vessel depressurization, automatically bypassing the high drywell pressure
signal 10 minutes after a sustained lo-lo-lo
reactor vessel water level signal (Reference 2).
TVA will perform modifications to the ADS logic
that will allow the ADS to initiate vessel
depressurization.
Status: Closed
NRC closed this item in Inspection Report 2005-007 (Reference 3).
References:
1.
NRC letter to TVA, dated June 3, 1983, NUREG-0737, Item II.K.3.18, ADS Logic
Modifications
- 2. TVA letter to NRC, dated March 5, 1987, Modifications to Automatic Depressurization
System (ADS) Logic - NUREG-0737, Item II.K.3.18
- 3. NRC letter to TVA, dated August 15, 2005, Brown s Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005007
April 13, 2007 E1-123 NUREG-0737 (TMI Action Plan), Action Item II.K.3.27, Common Reference Level for Vessel Level
Instrumentation
Issue: Provide level instruments that are referenced to the same point.
Discussion: In Reference 1, NRC proposed that TVA incorporate the requirements of Action Item II.K.3.27 into the
control room design review to be performed per
NUREG-0737, Action Item I.D.1. This approach
eliminates the possibility of changing water level
instrument scales twice; once per Item II.K.3.27
and then possibly again per Item I.D.1. TVA
accepted this proposal in Reference 2.
Status: C-C
NRC letter to TVA, dated December 30, 1982 (Reference 3), incorporated this item into
NUREG-0737, Action Item I I.K.3.27, Common Reference Level.
NRC closed this item in Inspection Report 2005-008 (Reference 4).
References:
1.
NRC letter to TVA, dated October 28, 1982,
Subject:
NUREG-0737 Action Item II.K.3.27 (Common Reference Level)
- 2. TVA letter to NRC, dated December 3, 1982, in regards to NUREG-0737, Item II.I.3.27 (Common
Reference Level)
- 3. NRC letter to TVA, dated December 30, 1982, NUREG-0737, Action Item II.K.3.27, Common
Reference Level
- 4. NRC letter to TVA, dated November 14, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery -NRC
Integrated Inspection Report 05000259/2005008
April 13, 2007 E1-124 NUREG-0737 (TMI Action Plan), Action Item II.K.3.28, Qualification of ADS Accumulators
Commitment: TVA will complete NUREG-0737 (TMI Action Plan)
Action Item II.K.3.28 - Qualification of ADS
Discussion: TVA responded to Item II.K.3.28 by Reference
- 1. The NRC Staff requested additional information in
Reference 2, which was provided by TVA in
Reference 3. Additional information was requested
in Reference 4 and provided in Reference 5. TVA
responded to a verbal request for additional
information in Reference 6. The Safety Evaluation
that documents the acceptability of TVA's plan to
satisfy Item II.K.3.28 was provided in Reference 7.
TVA performed modifications to upgrade the ADS
accumulator system. This was accomplished by
splitting the ring header into two sections, and
providing an alternate nitrogen supply to the
Drywell Control Air System.
Status: C-C
NRC closed this item in Inspection Report 2005-007 (Reference 8).
References:
1.
TVA letter to NRC, dated December 30, 1981, in regards to NUREG-0737, Items II.K.3.24, II.K.3.28 and II.B.4
- 2. NRC letter to TVA, dated May 11, 1983, Request for Additional Information - NUREG-0737, Item II.K.3.28, Qualification of ADS
- 3. TVA letter to NRC, dated July 8, 1983, in regards to NUREG-0737, Item II.K.3.28
- 4. NRC letter to TVA, dated May 29, 1984, Request for Additional Information - MPA F-55 (TMI II.K.3.28) Qualification of ADS
- 5. TVA letter to NRC, dated July 12, 1984, in regards to NUREG-0737, Item II.K.3.28
- 6. TVA letter to NRC, dated July 11, 1985, in regards to NUREG-0737, Item II.K.3.28
- 7. NRC letter to TVA, dated July 24, 1985, NUREG-0737, Item II.K.3.28, Qualification of ADS
April 13, 2007 E1-125
- 8. NRC letter to TVA, dated August 15, 2005, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2005007
April 13, 2007 E1-126 Platform Thermal Growth
Issue: TVA will address thermal growth in drywell platforms and miscellaneous steel frames.
Discussion: In Reference 1 , TVA informed NRC that TVA's program for the resolution of issues associated with
drywell steel platforms for Unit 3 was incorporated
into the program "Lower Drywell Platforms and
Miscellaneous Steel." This program includes upper
drywell platforms and platform thermal growth as
well.
Status: C-C
Refer to previous topic entitled Lower Drywell
Platforms and Miscellaneous Steel (Page E1-106).
References:
1.
TVA letter, T. E. Abney to NRC, dated December 13, 2002, Browns Ferry Nuclear Plant (BFN) - Unit 1 - Regulatory Framework for the
Restart of Unit 1
April 13, 2007 E1-127 Q-List Commitment: TVA will develop a Q-list which provides a list of safety-related systems, structures, and components
necessary to ensure: The integrity of the reactor coolant pressure boundary; The capability to shut down the reactor and maintain it in a safe shutdown condition; and The capability to prevent or mitigate the consequences of accidents which could result in
potential offsite radiation exposures comparable
to the 10 CFR 100 limits.
Discussion: BFN's Q-List Program is described in Section III.14.1 of the Browns Ferry Nuclear
Performance Plan (Reference 1).
Status: Complete TVA has incorporated Unit 1 into BFN's Q-List
Program.
References:
1.
TVA letter to NRC, dated October 24, 1988, Browns Ferry Nuclear Plant (BFN) - Nuclear
Performance Plan, Revision 2
April 13, 2007 E1-128 Restart Test Program
Commitment: For those systems that support safe shutdown, administrative controls for the Restart Test
Program will be implemented to insure that an
assessment of the Unit 3 System Test
Specifications, test procedures, and test results
is performed. Administrative controls will be used
to insure that the sta t us of the operating units is considered during the planning and scheduling of
restart tests.
Discussion: The restart test program was submitted in Reference 1 and supplemented by References 2
through 6.
Status: Open
References:
1.
TVA letter to NRC, dated September 27, 1991, Restart Test Program (RTP) Description for
Units 1 and 3
- 2. TVA letter to NRC, dated February 18, 1992, Request for Additional Information Regarding the
Restart Test Program for Units 1 and 3
for Units 1 and 3
Units 1 and 3
- 6. TVA letter to NRC, dated June 15, 2005, Browns Ferry Nuclear Plant, Unit 1 - Request for
Additional Information Regarding Restart Testing
Program April 13, 2007 E1-129 Seismic Class II Over I / Spatial Systems Interactions and Water Spray
Commitment: The Seismic Class II Over I / Spatial Systems Interactions and Water Spray program will be
implemented in accordance with the Unit 2
precedent.
Discussion: TVA is utilizing a two phase program to address Class II systems. The action plan for Unit 1 was
provided to th e NRC in Reference 1. The first part involves the evaluation of potential
seismic-induced water spray effects of Class II
systems on Class I systems. The second part
involves the evaluation of potential
seismic-induced, spatial interaction effects of
Class II systems on Class I systems. The approval
of the Seismic Class II Over I / Spatial Systems
Interactions and Water Spray program is contained
in References 2 and 3.
Status: Complete
Walk downs were completed. Outliers were resolved
by either further analysis, plant modification, or
maintenance action.
References:
1.
TVA letter to NRC dated February 27, 1991, Browns Ferry Nuclear Plant (BFN) - Action Plan
to Disposition Concerns Related to Units 1 and 3
Seismic Class II Piping Over Class I Commodities
- 2. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 -
Browns Ferry, Unit 2, Section 2.2.4.2 (Page 2-10)
- 3. NRC letter to TVA, dated November 19, 1992, Generic Letter 87-02, Supplement 1 Response -
Browns Ferry Nuclear Plant (TAC Nos. M69430, M69431, and M69432)
April 13, 2007 E1-130 Small Bore Piping
Commitment: The Seismic Class I small bore piping will be qualified to meet the final design criteria.
Discussion: TVA's action plan to disposition concerns related to Units 1 and 3 small bore piping was provided in
Reference 1 and augmented by Reference 2. NRC
approval of this program is documented in the
Safety Evaluation transmitted by Reference 3.
Status: Complete
TVA qualified the Class I small bore piping to meet
the final design criteria.
References:
1.
TVA letter to NRC, dated February 27, 1991, Action Plan to Disposition concerns Related to
Units 1 and 3 Small Bore Piping
Support Plans for Units 1 and 3 - Additional
Information
Seismic Qualification of Instrument Tubing
Programs for Browns Ferry Nuclear Plant,
Units 1 and 3
April 13, 2007 E1-131 Thermal Overloads
Commitment: TVA will resolve the thermal overload issue on Unit 1 prior to restart.
Discussion: A review of BFN design drawings identified that thermal overload (TOL) heater sizes for 480 VAC and
250 VDC motor control centers (MCs) were not
specified. Consequently, there was no
documentation to verify that TOL heater
installations are properly sized.
TVA's plan for addressing the TOL issue was
submitted in Reference
- 1. NRC requested additional information in Reference 2, which TVA provided in
Reference 3. Supplemental information was provided
in References 4 and 5. NRC approval of the program
is documented in Reference 6.
Status: C-C
TVA completed a walkdown program to document the
nameplate data for each load and replaced the TOLs
with ones of the proper size. The criteria for
sizing has been determined and documented.
Calculations have been performed to ensure the TOL
heaters are the proper size for their loads.
NRC closed this item in document dated March 9, 2007 (Reference 7).
References:
1.
TVA letter to NRC, dated April 28, 1988, Browns Ferry Nuclear Plant (BFN)- Electrical Issues (NRC TAC No. 62260)
- 2. NRC letter to TVA, dated August 10, 1988, Request For Additional Information - Browns
Ferry Nuclear Plant, Unit 2
Request for Additional Information - Electric
Circuit Protection by Current Limiting Fuses (TAC No. 62260-F)
Overload (TOL) Heaters (TAC No. 62260-F)
- 5. TVA letter to NRC, dated May 15, 1989, Browns Ferry Nuclear Plant (BFN) - Thermal Overload (TOL) Heaters - Sizing Criteria Clarification -
(TAC No. 62260-F)
April 13, 2007 E1-132
- 6. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 -
Browns Ferry, Unit 2, Section 3.11.1 (Page 3-8)
- 7. NRC Meeting Summary dated March 9, 2007, "Meeting Summary - Internal Meeting of
the Browns Ferry Unit 1 Restart Panel -
Docket No. 50-259"
April 13, 2007 E1-133 Unresolved Safety Issue A-7, Mark I Long-Term Program
Issue: This Unresolved Safety Issue was resolved in August 1982, with the publication of Supplement 1 to
NUREG-0661, "Safety Evaluation Report, Mark I
Containment Long-Term Program" and Standard Review
Plan Section 6.2.1.1.C.
Discussion: Refer to previous topic entitled Long Term Torus Integrity Program (Page E1-104).
Status: C-C
Refer to previous topic entitled Long Term Torus
Integrity Program (Page E1-104).
NRC administratively c l osed this item in Inspection Report 2006-007 (Reference 1). Since this item was
added only as a tracking means for this Unresolved
Safety Issue, TVA considers it complete also.
References:
- 1. NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-134 Unresolved Safety Issue A-9, Anticipated Transients Without Scram Issue: This Unresolved Safety Issue was resolved in June 1983, with the publication of a final rule
(10 CFR 50.62) to require improvements in plants to
reduce the likelihood of failure of the reactor
protection system (RPS) to shut down the reactor
following anticipated transients and to mitigate
the consequences of an anticipated transient
Discussion: TVA provided conceptual design information for conformance with the ATWS Rule in Reference 1. In
Reference 2, the NRC found that TVA's design
conformance with the ATWS Rule with exception that
the Browns Ferry's Alternate Rod Injection and
Reactor Pump Trip designs utilized the same analog
trip units for both the ATWS system and the reactor
trip system (RTS). TVA's response to the diversity
issue was provided in Reference 3.
Status: C-C
TVA implemented the requirements, actions, and
conceptual design modifications submitted. The
analog trip units utilized for the ATWS and RPS
systems were from different manufacturers.
NRC administratively closed this item in Inspection
Report 2006-007 (Reference 4).
References:
1.
TVA letter to NRC, dated March 1, 1988, Browns Ferry Nuclear Plant (BFN) - Anticipated
Transients Without Scram (ATWS) Rule
(10 CFR 50.62) - Plant Specific Design
- 2. NRC letter to TVA, dated January 22, 1989, Compliance with Rule 10 CFR 50.62 Relating to
Alternate Rod Injection and Reactor Pump Trip
Systems (TAC 59072, 59073 and 59074)
NRC Followup Items Received During ATWS
Inspection
- 4. NRC letter to TVA, dated August 10, 2006, B r owns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
April 13, 2007 E1-135 Unresolved Safety Issue A-24, Qualification of Class 1E Safety Related Equipment
Issue: This Unresolved Safety Issue was resolved in July 1981, with the publication of NUREG-0588, Revision 1, "Interim Staff Position on
Environmental Qualification of Safety-Related
Electrical Equipment." In summary, the resolution
of A-24 is embodied in 10 CFR 50.49.
Discussion: Refer to previous topic entitled Environmental Qualification (Page E1-45).
Status: C-C
Refer to previous topic entitled Environmental
Qualification (Page E1-45).
NRC administratively closed this item in Inspection
Report 2006-007 (Reference 1). Since this item was
added only as a tracking means for this Unresolved
Safety Issue, TVA considers it complete also.
References:
1.
NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
- 2. Refer to previous topic entitled Environmental Qualification (Page E1-45).
April 13, 2007 E1-136 Unresolved Safety Issue A-26, Reactor Vessel Pressure Transient Protection
Issue: This Unresolved Safety Issue was resolved in September 1978, with the publication of
NUREG-0224, "Reactor Vessel Pressure Transient
Protection for PWRs," and Standard Review Plan
Section 5.2. NRC subsequently issued Generic
Letter 88-11, "NRC Position on Radiation
Embrittlement of Reactor Vessel Materials and Its
Impact on Plant Operations," which provided
guidance regarding the review of
pressure-temperature limits.
Discussion: Refer to previous topic entitled Generic Letter 88-11, Radiation Embrittlement of Reactor Vessel
Materials and Its Impact on Plant Operations (Page E1-61).
Status: C-C
Refer to previous topic entitled Generic Letter 88-11, Radiation Embrittlement of Reactor Vessel
Materials and Its Impact on Plant Operations (Page E1-61).
NRC administrat i vely closed this item in Inspection Report 2006-007 (Reference 1). Since this item was
added only as a tracking means for this Unresolved
Safety Issue, TVA considers it complete also.
References:
1.
NRC letter to TVA, dated August 10, 2006, Browns Ferry Nuclear Plant Unit 1 Recovery - NRC
Integrated Inspection Report 05000259/2006007
- 2. Refer to previous topic entitled Generic Letter 88-1 1, Radiation Embrittlement of Reactor Vessel Materials and its Impact on Plant
Operations (Page E1-61).
April 13, 2007 E1-137 Unresolved Safety Issue A-44, Station Blackout
Issue: This Unresolved Safety Issue was resolved in June 1988,with the publication of the Station Blackout
Rule (10 CFR 50.63) and Regulatory Guide 1.155.
Discussion: In Reference 1, the staff Safety Evaluation concluded that TVA's proposed methodology for
coping with a Station Blackout event at BFN,
Units 1, 2, and 3 conforms with 10 CFR 50.63. As
requested in the NRC's Safety Evaluation Report, TVA provided its implementation schedule in
Reference 2. This letter included a commitment to
complete the Unit 1 equipment and associated
procedure modifications required for SBO rule
compliance prior to restart.
Status: Complete TVA implemented the modifications to the DC power supply system and the DC connected loads.
References:
1.
NRC letter to TVA, dated September 16, 1992, Station Blackout - Browns Ferry Units 1, 2,
and 3 (MPA-A022) (TAC Nos. M68517, M68518, and
M68519) 2. TVA letter to NRC, dated October 15, 1992, Browns Ferry Nuclear Plant (BFN) - Response to
NRC Supplemental Safety Evaluation on the
Conformance of BFN with the Station Blackout (SBO) Rule
April 13, 2007 E1-138 Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating Plants
Issue: This Unresolved Safety Issue was resolved with the issuance of Generic Letter 87-02 on
February 19, 1987, which endorsed the approach of
using the seismic and test experience data proposed
by the Seismic Qualification Utility Group (SQUG)
and Electric Power Research Institute (EPRI). This
approach was endorsed by the Senior Seismic Review
and Advisory Panel (SSRAP) and approved by the NRC
staff.
Discussion: Refer to previous topic entitled Generic Letter 87-02, Verification of Seismic Adequacy of
Mechanical and Electrical Equipment In Operating
Reactors, Unresolved Safety Issue (USI) A-46 (Page E1-58).
Status: Refer to previous topic entitled Generic Letter 87-02, Verification of Seismic Adequacy of
Mechanical and Electrical Equipment In Operating
Reactors, Unresolved Safety Issue (USI) A-46 (Page E1-58).
References:
Refer to previous topic entitled Generic Letter 87-02, Verification of Seismic Adequacy of
Mechanical and Electrical Equipment In Operating
Reactors, Unresolved Safety Issue (USI) A-46 (Page E1-58).
April 13, 2007 E2-1 ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
SUMMARY
OF REMAINING UNIT 1 RESTART ISSUES
TOPIC COMMITMENT SCHEDULE PAGE Generic Letter 92-01, Reactor Vessel
Structural Integrity, Revision 1, and
Revision 1 Supplement 1 TVA has submitted the available data requested by NRC. TVA
will inform NRC of the
applicability of NEDO 32205
within 90 days of the final
surveillance capsules analysis
report. Ninety days after the final
surveillance
capsules analysis
report. E1-75