ML20236M291
| ML20236M291 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/01/1998 |
| From: | Crane C TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2.206, IEB-94-001, IEB-94-1, NUDOCS 9807140009 | |
| Download: ML20236M291 (8) | |
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Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 Christopher M. (Chris) Crane Vice Presdent, Browns Ferry Nuclear Plant July 1, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk q
Washington, D.C. 20555 Gentlemen:
In the Matter of
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Docket No. 50-259 Tennessee Valley Authority
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BROWNS FERRY NUCLEAR PLANT (BFN) - RESPONSE TO THE UNION OF CONCERNED SCIENTISTS' ' (UCS) 10 CFR 2.206 PETITION REGARDING BFN UNIT 1 The, purpose of'this letter is to provide information on TVA's behalf in response to the subject UCS'10 CFR 2.206 Petition dated April 5, 1998.
First, and foremost, we wish to emphasize that BFN Unit 1 is being monitored and maintained in a manner and fashion that fully ensures the safety of the unit.
There is no validity to the UCS assertion that configuration management or any other aspect of BFN Unit 1 has been degraded by neglect.
I BFN Unit 1 systems that perform a required function while the unit is.in a defueled condition, or which directly support Unit 2 or Unit 3 operations, are being operated and maintained under applicable technical specifications and plant programs.
Plant systems such as Fuel Pool Cooling and Cleanup, Raw Cooling Water, Fire Protection, Reactor and
-l Refuel Zone Ventilation,. Radiation Monitoring, Residual Heat
' Removal, and Reactor Building Closed Cooling Water are being operated, tested,' and maintained to ensure they perform their
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required functions.
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O.S. Nuclear Regulatory Commission Page 2 July 1, 1998 Unit 1 systems and components that are not required to be operational have been drained, deepergized, disassembled, and placed in dry lay-up under a formal lay-up program as appropriate.
The lay-up program is described in plant procedures and includes periodic monitoring of equipment condition.
Both safety and nonsafety-related plant systems are included in this lay-up program which is designed to protect and preserve equipment until Unit 1 is returned to service.
In the NRC's January 20, 1998, letter to the UCS, the NRC accurately portrayed the fact that the BFN Unit 1 technical specifications are maintained and are amended periodically as necessary as is the case with the other BEN units.
- Further, existing technical specifications apply to Unit 1 systems that are required to be operable under current plant conditions, and these systems are being maintained consistent with the design basis. For example, the technical specifications have surveillance requirements for the Unit 1 Spent Fuel Pool.
This requires the level, temperature, conductivity, and chloride content of the Unit 1 Spent Fuel Pool to be monitored daily and maintained within acceptable limits.
These values and frequencies for Unit 1 are the same as the requirements for Units 2 and 3 Spent Fuel Pools.
In the UCS's letter of June 5, 1998, we note in particular the concern raised about the applicability of NRC Bulletin 94-01, " Potential Fuel Pool Draindown Caused by Inadequate Maintenance Practices at Dresden Unit 1."
As described in the paragraph above, the BFN Unit 1 spent fuel pool is being maintained in accordance with current technical specifications.
Further, the Unit 1 Spent Fuel Pool is located in the same structure that houses both the Unit 2 and the Unit 3 Spent Fuel Pools which are routinely toured by operators and engineers.
As described above, support systems and structures are being operated, tested and maintained in a manner to perform their required functions.
As a result, the concerns raised by NRC Bulletin 94-01 are not applicable to BFN Unit 1.
Accordingly, given the status of the plant and the manner in which it is being maintained, there is no safety issue, or the potential for a safety significant issue, raised by the UCS.
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O.S; Nuclear Regulatory _ Commission
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? July:1, 1998 In' sum,. and contrary to UCS's assertions, there is no
" regulatory mess" which needs to be unraveled nor is-there
_any-non-defined regulatory status" that needs to be addressed in relation'to BFN Unit 1 or any of its structures, systems,.or components.
'Infseveral-instances the UCS petition also refers to the configuration ~ management problems that arose in'the.past and that served as.a basis for shutting down the BFN units.
This,;however, is only part of BFN's history.
As you know,
'TVA-has successfully addressed regulatory requirements,
-including those associated with configuration management,
.necessary to restart BFN Units 2 and 3, and did so many-years afteriTVA removed ~those units from operation.
Specifically, BFN: Unit 2-was returned to operation in 1991,;.more than six yearsEafter TVA' shut that unit down.
In the years subsequent
,to Unit'2's restart,'that unit has operated above the
-_ industry; median with1an availability factor of 88.5 percent and a' capacity factor of 84.3 percent. _Since restart, thel i
' unit has been operated safely and reliably.
The sustained good performance'of Unit-2 was recognized by the NRC and the unit.was removed from: the NRC's Watch List in 1992.
BFN Unit 3-was returned to operation [in 1995, mor~e than ten years-after that-unitEwas removed-from' service. Like Unit 2, Unitf3;hastoperated safely and reliablyEsince restart.
In the' years since Unit:3's'restsrt, it has operated with an availability' factor of 94.6 percent and a capacity factor
- ofL90.4= percent. Unit 3 was removed from the Watch' List-
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in 1996,'with the'NRC citing effective improvement in operational safety performance.
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s The BFN units have achieved excellent performance since restart.
A composite of performance indicators such as
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safety system availability, thermal performance, fuel reliability, radiation exposure, chemistry performance, and
. unplanned automatic scrams place BFN in the top quartile of L
nuclear power plants'in the country.
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The:NRC's Systematic Assessment of Licensee Performance (SALP) ratings-for BFN have likewise shown consistent'
' improvement since restart.
The SALP ratings for the period endingEjust.before the restart of Unit 2 averaged 2.'1.
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4 O. S. Nuclear Regulatory Commission Page 4 July 1, 1998 Subsequent SALP scores have improved, with the most recent SALP report dated May 21, 1998, showing an average rating of 1.25.
BFN Operations, Maintenance, and Plant Support were all rated " Superior" and Engineering was rated " Good."
There are currently only three plants in the United States with SALP ratings higher than BFN.
Given this more complete and accurate history of BEN's operational accomplishments, it is clear that TVA has proved its ability to develop and implement a successful restart strategy capable of addressing all pertinent regulatory issues, and doing so under the current process used for restarting idled nuclear facilities.
The UCS petition also makes varying statements regarding the NRC inspections of BFN Unit 1, criticizing, at first, the nature of those inspections, and then questioning whether any inspections are in fact being done.
Of course, we are in a position to attest to the fact that numerous inspections associated with Unit 1 have been performed over the years, and that they have and are being performed in a manner that appropriately takes into account the status of the various BFN Unit 1 structures, systems and components.
The UCS also cites the impossibility of being able to meaningfully inspect the unit to today's standards, then immediately criticizes the NRC for wasting its inspection efforts on a facility in an uncertain license condition.
In fact, however, the UCS criticisms are invalid on all counts.
For example, the NRC's inspection efforts have focused on those aspects of Unit 1 having the greatest impact on safety.
The bulk of NRC's inspection efforts have, quite appropriately, examined those Unit 1 systems supporting safe operation of the operating units.
To the extent that any such system is relied upon to support operation of another unit, it is fully inspected in accordance with current regulatory requirements.
In those instances where a Unit 1 system is inoperable, and in lay-up status, it would indeed be wasteful of both TVA's and NRC's resources to require in-depth inspection of those systems to operability standards.
The NRC is entirely capable of making this distinction, and the fact is that the NRC has inspected those BFN Unit 1 systems, structures, and components in lay-up status in order to assess the adequacy of their condition.
In NRC Integrated
- 0. S. Nuclear Regulatory Commission Page 5 July 1, 1998 Inspection Report 50-259/96-12, 50-260/96-12 and 50-296/96-12, the NRC describes its long-term lay-up inspection of Unit 1, including a review of the applicable procedures that-implement the Unit 1 lay-up and preventative maintenance program.
Inspections were conducted of several systems in the reactor building and the NRC found the in-plant storage of equipment to be acceptable.
Specifically, the report noted that motors were observed to be adequately covered'and heat properly applied to motor windings.
Piping systems were
' observed to be under adequate humidityfcontrols, and-housekeeping was deemed acceptable.
The NRC also found that records being generated for the storage, transfer, and preventative maintenance activities were adequate and consistent with record retention requirements.
The.NRC concluded that TVA's activities associated with Unit 1 were characterized by good maintenance programs, finding that in-plant storage of Unit 1 equipment was adequately controlled and consistent with long-term storage requirements.
From the above, it is clear that the NRC has been properly. focusing its attention. on each aspect of TVA's BEN Unit 1 activities.
Regarding the level of effort expended by the NRC in carrying
-out its inspection responsibilities, TVA examined its inspection invoice ~ files for Unit 1 covering the last four years.
The invoices identify the number of hours spent by the NRC and the expenses charged by NRC contractors in-support of inspections related to the maintenance of Unit 1.
These files also identify the number of hours spent by the NRC and the expenses of its contractors in support of reviews necessary to keep the BFN Unit 1 technical specifications and licensing basis current, referred to by the NRC as " TAC" reviews.
In sum, the NRC spent an average of approximately 575 hours0.00666 days <br />0.16 hours <br />9.507275e-4 weeks <br />2.187875e-4 months <br /> per year and its contractors charged an average of approximately $6,250 per year inspecting BFN Unit 1.
In addition, the NRC spent an average of approximately 540 hours0.00625 days <br />0.15 hours <br />8.928571e-4 weeks <br />2.0547e-4 months <br /> per year and its contractors charged an average of approximately $11,840 per year for BEN Unit 1 TAC reviews.
In total, this is an average of approximately l
1115 review hours per year and contractor costs in the range of $18,000 per year devoted to BFN Unit 1.
This level of activity in the areas described-above does not fit the picture portrayed by UCS of a unit existing in some "non-defined regulatory state" or " licensing limbo."
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D.S. Nuclear Regulatory Commission Page 6 July 1, 1998 As a final matter, it is essential for TVA to maintain the operational viability of BFN Unit 1 for the near future.
As you know, TVA informed the NRC by letter dated April 16, 1996, that the long-term operational status of Unit 1 has not yet been determined.
However, TVA also committed that prior to any restart'of the unit, TVA would implement the same programs that were employed for the successful recovery of Unit.3, and that no restart would take place without the NRC Commissioners' approval.
Finally, TVA stated that if TVA ultimately decides not to restart Unit 1, applicable NRC regulations governing decommissioning activities would be followed.
It is also important to understand that the future of BEN Unit I requires the consideration of a variety of energy resource options that TVA has and will continue to evaluate.
Toward that end, and in accordance with the requirements of the Energy Policy.Act of 1992, TVA conducted a least-cost, integrated energy resource planning program entitled, " Energy Vision 2020" which identified a viable mix of customer service options and supply-side options for future' potential power system use.
TVA conducted.this energy resource planning. program in'accordance with the National Environmental Policy Act and prepared an Integrated Resource Plan (IRP) Environmental Impact Statement which it issued in final form in December 1995.
As part of the'IRP process, TVA developed and evaluated 2,000 energy resource strategies from more than 100 supply-side and 60 customer service options.
In doing so, TVA obtained public input through surveys of local opinion leaders,' numerous public meetings, and months of'public review and comment.
As a result of this extensive j
effort, TVA's IRP identified a " portfolio" of energy resource i
options in order to respond to a variety of energy uncertainties.
This was done in recognition that future events will.likely require changes in any discrete energy p
strategy.
The utility industry is entering into an era of it significant changes as it moves from a regulated to a less j
regulated environment.
This substantially heightens the already large uncertainties associated with long-range utility planning,. and flexibility heightens a utility's ability to respond to events'as they unfold.
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D.S. Nuclear Regulatory Commission Page.7 July 1, 1998 Insofar asLth'e status-of BFN Unit 11 is concerned,' the IRP
-concluded.that the decision whether to complete or replace the. unit should be' deferred for the'near term in order to
-maximize flexibility to adapt lto-significantly different futures.
This would allow TVA^to' gain 1 additional'information' about.important factors such as future-load growth and
. nuclear performance.
The'IRP-alsolrecognized;thatiseveral other factors'should be considered in making any final cde' cision on the unit's status, including the cost and operating performance:of other options.that could' replace its operation, long;and:short. term costs-including impact on
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rates, and the environmental effects of-various resource options.. It is clear from the decisions reached by TVA through the IRP process that any. decision to cancel,the Unit l' operating license as the UCS petition urges, and certainly.any; decision to require.TVA to submit a
'decommis.sioning: plan'for the unit, would.be entirely.
. premature:and' wholly inappropriate.
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'Weiappreciate;the.' opportunity.'to respond to the UCS petition.
N If'you need any-further information or have any questions, please 'do not hesitate to call me. at- (256) 729-3675.
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.C. M. C ane
'cc:1See page 7 l
U.S. Nuclear Regulatory Commission Page 8 July 1, 1998 cc:
Regional Administrator U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.
Suite 23T85 Atlanta, Georgia 30303 Mr. H.O. Christensen, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.
Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant j
10833 Shaw Road Athens, Alabama 35611
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Mr. A. W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North i
11555 Rockville Pike Rockville, Maryland 20852 Union of Concerned Scientists 1616 P Street, NW, Suite 310 Washington, DC 20036-1495 l
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