**NRC INSPECTION MANUAL** IIPB

MANUAL CHAPTER 2509

BROWNS FERRY UNIT 1 RESTART

PROJECT INSPECTION PROGRAM

2509‑01 PURPOSE

01.01 To provide the policies and requirements for the Browns Ferry Unit
1 (BF1) restart inspection program during that unit\'s major renovation,
restart testing, and additional inspections prescribed by the Restart
Oversight Panel.

01.02 To establish a record of the major regulatory and licensee actions
taken and technical issues resolved leading to the licensee\'s readiness
for restart and to the eventual return of the plant to the reactor
oversight process.

2509‑02 OBJECTIVES

02.01 To verify that engineering calculations, design changes, and
modifications for the Browns Ferry Unit 1 Restart Project (BF1RP) are
completed in conformance with the facility\'s license, applicable codes
and standards, licensee commitments, and the regulations.

02.02 To verify that activities involving replacement, renovation, and
removal of equipment are conducted so as to maintain adequate nuclear
and radiological safety.

02.03 To verify the implementation of the licensee\'s design control
programs, the installation and testing of modifications for Special
Programs listed in the licensee\'s Nuclear Performance Plan and the
completion of any required actions for outstanding generic-
communication issues.

02.04 To appropriately disposition inspection findings and to close open
restart issues.

02.05 To confirm the readiness of BF1 to begin restart testing, based on
inspections of the licensee\'s programs.

6.  To verify that systems and components important to the safety of the
    plant have been fully tested to demonstrate compliance with design
    requirements, based on direct observation of restart testing,
    personnel interviews of licensee staff, and review of testing
    records.

02.07 To verify the operational readiness of BF1 for unrestricted
operation based on inspections during its renovation, restart testing,
an Operational Readiness Assessment Team Inspection (ORAT), and any
additional inspections recommended by the Restart Oversight Panel.

02.08 To effectively manage the resolution of restart issues, to
establish a Restart Oversight Panel, and to ensure that NRR and Region
II are appropriately involved in the decisions affecting the restart of
BF1.

02.09 To provide an objective basis to justify NRC approval for BF1 to
restart, and then to provide the process to transition BF1 into the
reactor oversight process (ROP).

02.10 To provide a mechanism for communicating issues and corrective
actions to the public and other external stakeholders.

2509‑03 APPLICABILITY

03.01 The inspection program for MC 2515 \"Light‑Water Reactor
Inspection Program ‑ Operations Phase\" applies to any licensed nuclear
facility assumed capable of operating safely within currently required
safety margins. That basic assumption does not hold true for BF1 because
of unique circumstances. Since its shutdown in March1985, the reactor
has been defueled, systems have not operated and have generally been
maintained in a layup condition, and outstanding regulatory requirements
have not been fully incorporated into the plant configuration.

Since BF1 is not in full compliance with the regulations for normal
power operation, just those for its present mode, and has no discernable
risk in its present defueled state, neither MC 2515 nor the present
guidance for performance indicators (PIs) is presently applicable to
BF1. In addition, MC 0305 \"Operating Reactor Assessment Program,\" is
also not applicable to BF1 since it would rely on the baseline
inspection effort under MC 2515 in order to invoke the Action Matrix and
to properly assess BF1\'s performance in conjunction with performance
indicator values which also may not be available. Therefore, the
philosophy and structure of the reactor oversight process (ROP), which
depends on baseline inspections, PIs, and the assessment of both to
determine safety performance from a risk perspective, can not be
initially applicable at BF1.

03.02 The BF1RP inspection program, in accordance with this manual
chapter, is applicable during the renovation of BF1, any restart
testing, and a post‑restart period of operation not expected to exceed
two quarters (six months). It will no longer be applicable, as decided
by the Restart Oversight Panel, once it is determined that: 1) licensee
corrective actions for restart issues have been completed, 2)
performance improvement changes have been made, and 3) all ROP
cornerstones are deemed monitorable by a

combination of inspection and PIs. Additional inspections above the
routine baseline inspections may have to be performed until the
appropriate PIs are available.

03.03 Even though MC 2515 is not applicable for Browns Ferry\'s restart,
individual inspection procedures (IPs) referenced in it will be utilized
when advantageous for the BF1RP inspection program. The frequencies of
implementation of those procedures will be in accordance with Region
II\'s overall BF1RP inspection plan and schedule. The implementation of
all IPs must be planned within the total estimated resources for the
BF1RP inspection program. This implementation should also include
inspections required to close restart items and to collect data
equivalent to that provided by performance indicators (PIs) prior to and
while transitioning to the ROP.

03.04 In addition, archived IPs and temporary instructions (TIs) may be
revised and utilized to perform the required inspections or reviews of
outstanding design, licensing, and regulatory issues for BF1.

03.05 As determined either by the Restart Oversight Panel or by
cognizant Region II management prior to the establishment of the Restart
Oversight Panel, an individual cornerstone of safety may become
monitorable by inspection and PIs under the ROP. In order to do so, the
first two conditions in Step 03.02 ( licensee corrective actions for
restart issues have been completed; performance improvement changes have
been made ) must be fulfilled to the extent required to justify
discontinuing the BF1RP inspection program for that cornerstone. The
transition of BF1 to the full oversight provided by the ROP will be a
gradual‑phased approach on an individual cornerstone basis with the
understanding that MCs 2515 and 0305 cannot be fully applied until all
cornerstones are monitorable by the ROP. Once a cornerstone is
monitorable by the ROP, MC 0609 \"Significance Determination Process\"
(SDP) will be utilized to characterize the significance of findings
resulting from the routine inspection effort of MC 2515 for that
cornerstone.

03.06 BF1 is not considered to fall within the scope of the
Commission\'s current Enforcement Policy for commercially operating
nuclear power plants. Traditional enforcement, as utiIized for BF3\'s
restart (prior to adoption of the ROP), and not as defined in the
Commissions\'s current Enforcement Policy, will be applicable to any
Severity Level IV and above noncompliances that are identified in
inspections for a BF1 cornerstone of safety. This will only be
applicable prior to the point when that cornerstone becomes monitorable
by the ROP in accordance with the conditions identified in Step 03.05.
Once a cornerstone has been determined by the NRC to be monitorable by
the ROP , then the enforcement for any findings from NRC inspections for
that cornerstone should be administered in accordance with the
Commission\'s current Enforcement Policy.

2509‑04 DEFINITIONS

04.01 [Full Oversight of the ROP]{.underline}. For this manual chapter,
this will mean when all cornerstones are monitored by baseline
inspection and either PIs or compensatory inspections above the baseline
in accordance with MC 2515. The regulatory response for findings
resulting from such inspections will be by the Action Matrix in MC 0305.

04.02 [Limited Oversight of the ROP]{.underline}. For this manual
chapter, this will mean when some but not all the cornerstones are
monitorable by baseline inspection and either PIs or compensatory
inspections above the baseline in accordance with MC 2515. The
regulatory response for findings resulting from such inspections for any
of these cornerstones will be determined by the Restart Oversight Panel
or Region II management.

04.03 [Monitorable Under the ROP]{.underline}. For an individual
cornerstone, it means that baseline inspection and either PIs or
compensating inspections above baseline performed due to the
unavailability of PIs can provide sufficient information for determining
licensee performance for that cornerstone of safety.

04.04 [Restart Testing]{.underline}. Testing performed as part of the
licensee\'s Restart Test Program for Unit 1 in accordance with its
modification process and which resembles the testing program for the
Unit 3 restart. This program includes the testing categories normally
identified as verification tests, and restart tests, as defined below.

a.  [Verification Tests]{.underline}. Tests performed under the
    direction of management personnel before system or component
    turnover to the operating group for restart testing. These tests
    include those activities such as chemical cleaning, flushing,
    continuity testing, and initial calibration of instrumentation
    necessary to prepare a system for operation. They also include tests
    such as containment integrity and hydrostatic testing of piping
    systems necessary to demonstrate component, system, or structure
    design and construction adequacy. Baseline in-service inspection is
    also included in this category.

b.  [Restart Tests]{.underline}. Tests performed by or under the
    direction of the licensee or the licensee's contractors to
    demonstrate the proper functioning, and conformance to design
    requirements of SSCs. Form the basis for declaring systems,
    structures, and components operationally ready.

04.05 [Renovation Work Activities]{.underline}. The following work
activities performed for the renovation of BF1‑ design, planning, and
implementation of changes to plant hardware and procedures; and
equipment removal/replacement and/or refurbishment.

04.06 [Restart Oversight Panel]{.underline}. Functional equivalent to
the Oversight Panel in MC 0350, \"Oversight of Operating Reactor
Facilities in a Shutdown Condition with Performance Problems.\"

04.07 [Restart or Restart Project Activities]{.underline}. Consists of
all licensee activities to support the restart of BF1.

04.08 [Restart Project Inspection]{.underline}. Any NRC inspection
conducted to monitor and evaluate licensee restart activities for BF1.

04.09 [Transition Matrix]{.underline}. The justification developed by
Region II for why a particular cornerstone can be deemed to be ready to
be monitorable under the ROP.

04.10 [Transition Plan]{.underline}. The justification developed by
Region II for why all the cornerstones of safety can be deemed to be
ready to be monitorable under the ROP. The Transition Plan mainly
consists of all the Transition Matrices.

04.11 [Transitioning to the ROP]{.underline}. When BF1 transitions to
the full oversight of the ROP.

2509‑05 RESPONSIBILITIES AND AUTHORITIES

05.01 [Director, Office of Nuclear Reactor Regulation]{.underline}

a.  Provides overall program direction for the BF1RP inspection program.

b.  Develops policies, programs, and procedures for inspecting the
    licensee within or in addition to the BF1RP inspection program.

c.  Assesses the effectiveness, uniformity, and completeness of
    implementation of the BF1RP inspection program.

d.  Notifies, in conjunction, with the Regional Administrator for Region
    II, the EDO and the Commission of the high‑level NRC actions taken
    for the BF1RP.

e.  Discusses with the Regional Administrator for Region II any pending,
    important decisions concerning the restart of BF1.

f.  Concurs with the decision of the Regional Administrator for Region
    II to allow the licensee to restart BF1, following a Commission
    briefing.

g.  Concurs with the decision of the Regional Administrator for Region
    II, the transition of BF1 into the full oversight of the ROP.

05.02 [Associate Director for Inspection and Programs]{.underline}.
Directs the development of the BF1RP inspection program within the
Office of Nuclear Reactor Regulation (NRR).

05.03 [Director, Division of Inspection Program Management
(DIPM]{.underline})

a.  Manages BF1RP inspection program development within NRR.

b.  Develops and prepares revisions to this manual chapter and other
    applicable inspection program documents.

c.  Oversees regional implementation of BF1RP inspection program.

d.  Serves as the NRR contact with the Region II office for BF1RP
    inspection program development and implementation.

e.  In conjunction with Region II management, provides information to
    the Restart Oversight Panel on the status of restart issues.

f.  Approves , in conjunction with the Chief, IIPB/DIPM, the Region II
    inspection plan and any changes that significantly affect the
    resources required to implement it.

g.  Decides, in conjunction, with the Regional Administrator for Region
    II, when the Restart Oversight Panel should be established to
    oversee the final restart activities of BF1 and when it should be
    dissolved.

05.04 [Director, Division of Projects (DLPM)]{.underline}

a.  Serves as NRR contact in regard to licensing and licensing policy
    issues related to the BF1RP inspection program.

b.  Assigns a Project Manager to address day‑to‑day matters concerning
    licensing issues for BF1RP.

05.05 [Regional Administrator for Region II]{.underline}

a.  The Regional Administrator has responsibility and authority for
    overall direction of the implementation of the BF1RP inspection
    program.

b.  Establishes contacts with licensee on inspection‑related issues and
    any required corrective actions either directly or through the
    assigned Region II Branch Chiefs in regard to those same issues.

c.  Maintain contacts with NRR on inspection related issues and the
    overall BF1RP inspection program either directly or through the
    assigned Region II Branch Chiefs in regard to those same issues.
    Ensures routine assessment of licensee performance in restart
    activities is considered.

d.  Decides, in conjunction with the Director, DIPM, when the Restart
    Oversight Panel should be established to oversee the restart
    activities of BF1 and when it should be dissolved.

e.  Notifies, in conjunction, with the Director, Office of Nuclear
    Reactor Regulation, the EDO and the Commission of the high‑level NRC
    actions taken for the BF1RP .

f.  Discusses with the Director, Office of Nuclear Reactor Regulation
    any pending, important decisions concerning the restart of BF1.

g.  Makes decision to allow licensee to restart BF1 with the concurrence
    of the Director, Office of Nuclear Reactor Regulation based on a
    written recommendation from the Restart Oversight Panel, following a
    Commission briefing.

h.  Makes decision to allow BF1 to transition completely to the full
    oversight of the ROP with the concurrence of the Director, Office of
    Nuclear Reactor Regulation based on a written recommendation from
    the Restart Oversight Panel.

05.06 [Region II, Director, Division of Reactor Safety]{.underline}

a.  Serves as the contact point for inspections performed by regional
    specialists and also for technical issues with NRR related to those
    inspections.

b.  Appoints a Region II DRS Branch Chief as his delegate in the
    day‑to‑day matters concerning the BF1RP.

05.07 [Region II, Director, Division of Reactor Projects]{.underline}

a.  Serves as the contact point for inspections performed by residents
    and also for technical issues with NRR related to those inspections.

b.  Appoints a Region II DRP Branch Chief as his delegate in the
    day‑to‑day matters concerning the BF1RP.

05.08 [Region II Branch Chiefs]{.underline}

a.  In conjunction with NRR management, provide information to the
    Reactor Oversight Panel.

b.  Act as appointed delegates of their respective Region II Division
    Directors in the day to day matters related with the implementation
    of the BF1RP inspection program. Ensures routine assessment of
    licensee performance in restart activities is considered and
    promulgated in periodic public meetings and inspection report cover
    letters.

c.  Perform similar activities to those outlined in items c. through f.
    of Step 05.10 prior to the formation of the Restart Oversight Panel.

d.  Develop and then submit the Region II inspection plan and schedule
    to the Director, DIPM and the Chief, IIPB/DIPM for their approval.

e.  Develop the Transition Plan that provides the justification for why
    cornerstones can become monitorable by the ROP.

05.09 [Chief, Inspection Program Management (IIPB)/DIPM]{.underline}

a.  Approves , in conjunction with the Director, DIPM, the Region II
    inspection plan and any changes that significantly affect the
    resources required to implement it.

b.  Concurs with the decision of either Region II or the Restart
    Oversight Panel to allow a cornerstone to be monitorable by the ROP.

05.10 [Restart Oversight Panel]{.underline}

a.  Develops the functional equivalents of the Panel Process Plan and
    Restart Checklist referred to in MC 0350 in accordance with this
    manual chapter.

b.  Overviews licensee performance and provides licensee performance
    assessment beginning at about 12 months from actual restart.

c.  Determines the inspection effort necessary to review
    safety‑significant restart issues and to compensate for the lack of
    PI data for the individual ROP cornerstones of safety.

d.  Assesses licensee corrective actions and performance improvements to
    determine the operational readiness of BF1 for restart.

e.  Keeps all stakeholders informed on the status of the BF1 restart.

f.  Determines when any of the seven ROP cornerstones of safety are
    ready to be monitorable by the ROP with the concurrence of the
    Chief, IIPB/DIPM.

g.  Provides post‑restart oversight until all issues concerning restart
    activities are closed.

h.  Sends written recommendations to the Regional Administrator of
    Region II and to the Director of NRR that the licensee should be
    allowed to restart BF1.

i.  Sends written recommendations to the Regional Administrator of
    Region II and to the Director, DIPM and to Chief, IIPB/DIPM/NRR that
    BF1 should be allowed to transition into the full oversight provided
    by the ROP.

2509‑06 BACKGROUND AND OVERVIEW

Browns Ferry Units 1, 2, and 3 were voluntarily shutdown in March 1985
for management and regulatory issues. TVA committed to obtain NRC
approval prior to the restart of any unit. TVA submitted the Browns
Ferry Nuclear Performance Plan, Volume 3, in August 1986, outlining the
steps needed to recover the Browns Ferry units. NRC issued NUREG‑1232,
Volume 3, and its supplements, concluding that TVA\'s actions acceptably
addressed Browns Ferry Nuclear Plant deficiencies. BF2 and BF3 were
started up in the 1990s. BF1 commenced a 5‑year restart program in May,
2002. Once BF1\'s startup program is completed, all three units will be
similar in their respective plant configurations, and will have
implemented corrective actions for outstanding regulatory and generic
safety issues.

This manual chapter will establish policy for the BF1RP inspection
program covering BF1\'s renovation, and restart testing including power
ascension. IPs or TIs, documented in Region II\'s inspection plan and
schedule, will provide inspection requirements for these main inspection
areas that comprise the BF1RP inspection program.

Since BF1 has an operating license, the old and new construction
programs under 10 CFR Part 50 and 10 CFR Part 52, respectively, for site
evaluation, construction of a plant, testing, and power ascension are
not appropriate. The current Reactor Oversight Process (ROP) cannot be
initially applied for the reasons previously stated until the entry
conditions for each cornerstone are met as stated in Step 03.05.

Although MC 0350 is normally intended for plants with performance
problems which is not the case for BF1, various parts of it will be
utilized in this manual chapter as appropriate with any exceptions
noted.

Initially, all aspects of the BF1RP will be inspected in accordance with
the Region II inspection plan and this manual chapter. Region II will
manage all elements of the BF1RP inspections, i.e., reviews, assessment
of licensee correction actions, evaluation of findings, and tracking
open items. Until the Restart Oversight Panel is formed, Region II, with
concurrence by the Chief, IIPB/DIPM, will also determine which , if any,
of the seven ROP cornerstones of safety are ready to be monitorable
under the ROP. Allowing cornerstones to become monitorable under the ROP
individually prior to BF1\'s startup is advantageous for two reasons.
The first is that it is less cumbersome and more efficient to employ
cornerstones rather than individual structures, systems, and components
(SSCs). The second is that the objective, risk‑informed inspection
practices of the ROP are applied earlier, rather than later, to some
inspectable areas.

A Restart Oversight Panel, consisting of participants from both Region
II and NRR, will be established approximately 12 months prior to plant
startup by the combined decision of the Regional Administrator for
Region II and the Director, DIPM of the Office of Nuclear Reactor
Regulation. Organizationally, the Restart Oversight Panel will report
directly to the Regional Administrator of Region II. The purpose and
responsibilities of the Restart Oversight Panel will be stated in this
manual chapter. This panel will ultimately decide whether the required
corrective actions and performance improvement changes have been
implemented successfully by the licensee so that BF1 meets the relevant
regulatory requirements and can be safely operated. The actual decision
to permit the licensee to restart BF1 will be made by the Regional
Administrator of Region II with the concurrence of the Director, Office
of Nuclear Reactor Regulation based on a written recommendation of the
Restart Oversight Panel, following a Commission briefing. The panel will
also decide which of the remaining cornerstones are ready to be
monitorable under the ROP. The decision to permit BF1 to transition into
the full oversight of the ROP will be made by the Regional Administrator
of Region II with the concurrence of the Director, Office of Nuclear
Reactor Regulation, based on a written recommendation of the Restart
Oversight Panel. Even though various parts of MC 0350 will be utilized
in this manual chapter, the policies controlling the restart of BF1 will
be in accordance with this manual chapter only.

2509‑07 GENERAL INSPECTION POLICY

07.01 [Inspection Program Scheduling and Planning]{.underline}

a.  Region II will develop a 5 year (2003 through 2007) site‑specific
    inspection plan and schedule (IP&S) which selects the appropriate
    IPs or equivalent criteria to review the licensee\'s restart
    activities and to implement inspections. The IP&S should be detailed
    but flexible and minimize the number of inspections (group various
    issues and programs together). It should allow for rescheduling
    inspections to accommodate licensee schedule changes.

b.  Region II will submit the IP&S to the Director of DIPM and the
    Chief, IIPB/DIPM/NRR for approval as to whether it provides
    sufficient oversight for safety‑significant restart activities.
    Region II can alter the sample sizes and frequencies of IPs or TIs
    as appropriate without IIPB/DIPM concurrence if budgeted resources
    will still envelope the estimated resources to be expended after
    allowances for any alterations are made.

c.  The IP&S should allow for additional inspections that may be
    identified by Region II or by the Restart Oversight Panel. Region II
    should establish the means for tracking open items, (i.e.,
    Inspection Follow-up Items (IFIs) or the Reactor Programs System
    (RPS) open items list), that can be rolled over later into the
    Restart Checklist.

d.  The Region II IP&S should be a public document to support any
    interface with stakeholders, the Commission, and other agencies,
    following the same guidelines for such communications as presented
    in MC 0350 for the Restart Oversight Panel. The coordination and
    management of licensing and technical support activities may be in
    accordance with the procedures followed by both Region II and NRR
    project management organizations.

e.  The IP&S should be so configured as to group inspections according
    to the SSCs, licensee Special programs, and outstanding
    generic-communication issues associated with a particular
    cornerstone since the transition of BF1 into the ROP will be on a
    cornerstone by cornerstone basis. Ordering the inspections in this
    manner will allow easier determination that the inspections for a
    particular cornerstone have been completed.

07.02 [Inspection Policy and Scoping]{.underline}

a.  The IP&S should identify what licensee program areas, major
    modifications, regulatory issues (i.e., licensee's Recovery Program
    implementation on Unit 1 and resolution of generic issues after
    1985), and generic and open items are being verified by an
    inspection, when the inspection will be performed, and the relevant
    IPs or TIs from those listed in Appendix A of this manual chapter.
    The IPs to be utilized will be reactivated if previously archived.
    Prior to reactivating any archived TIs, not fully implemented at
    BF1, it must be determined whether their original issues were
    resolved and/or are not relevant anymore. If both or either are the
    case, then merely close out the TI without reactivating it. This
    will establish the overall scope of the BF1RP inspection program
    from which the total inspection effort can be estimated.

b.  The assigned branch chiefs from Region II will manage and coordinate
    the BF1RP inspection program, required technical support, and the
    verification that inspection hours are being properly charged. IIPB
    will assist in the latter effort by ensuring that inspection hours
    are being properly assigned to the appropriate IPs or TIs in the
    RPS.

c.  The IP&S should address inspections for BF1\'s renovation, the
    restart testing, and also additional inspections identified either
    by Region II management or by the Restart Oversight Panel to address
    restart issues and the transition of BF1 into the full oversight of
    the ROP.

d.  Some of the IPs or TIs of Appendix A are keyed to renovation work
    activities at the plant site. Region II management and inspectors
    must be cognizant of the status of those renovation work activities
    in order to achieve appropriate inspection planning. The IP&S should
    coordinate NRC inspection activities with licensee restart
    activities. The IPs in Appendix B and the tests in the licensee's
    Restart Test Program should be treated similarly so that inspections
    of the restart tests can properly scheduled per the IP&S.

e.  The renovation work activities of the IP&S for BF1RP will comprise
    two major types of restart activities: One is design, planning, and
    implementation of changes to plant hardware and operation; and the
    other is equipment removal/replacement and/or refurbishment.

f.  For the renovation work activities, inspectors will mainly review
    restart activities that originated due to issues with design,
    licensing, regulations, generic safety, and NRC inspection findings.
    The appropriate IPs or TIs are identified in Appendix A with the
    applicable licensee Special programs listed in the first reference
    in Section 13 of this manual chapter.

g.  For the restart testing, Region II shall determine which tests
    identified in the licensee\'s Restart Test Program will be witnessed
    or evaluated by the corresponding IPs listed in Appendix B.

h.  The IP&S shall verify that the licensee\'s BF1RP processes for
    identifying, tracking, and resolving problems are comparable with
    those for BF2 and BF3 for problem identification and resolution.

i.  The IP&S should focus on performance‑based inspections (performance
    of SSCs and the results of the implementation of licensee programs)
    rather than the review of procedures and records.

j.  This manual chapter will establish the basis for allowing each
    cornerstone to be monitored by the ROP. However, Region II will
    develop a sufficiently detailed Transition Plan based on the
    Transition Matrices for the cornerstones so that the major steps are
    identified and defined.

k.  The IP&S should either refer to or include the detailed Transition
    Matrices to be developed by Region II for the seven cornerstones of
    safety. Each Transition Matrix shall deal with two primary
    concerns: 1) what IPs were performed to verify the resolution of
    outstanding restart items (open items and licensee program impacts)
    for a particular cornerstone and 2) that restart items were resolved
    by effective licensee corrective actions. This will establish
    traceability to show that a particular cornerstone warranted being
    monitored by ROP baseline inspection and PIs.

07.03 [Use of Inspectors]{.underline}

> a\. Region II should assign inspectors based on their qualifications.
> Generally, resident inspectors should verify licensee performance for
> all general activities while the regional specialists should perform
> more specialized activities ( technical reviews associated with
> specific types of inspections for each specialist).
>
> b\. Programs and procedures should be reviewed once a performance
> problem is identified to ensure the licensee determines the root cause
> and extent of condition. Focus on the licensee\'s efforts to implement
> long‑term resolutions.
>
> c\. The IP&S will emphasize the inspections of specific SSCs and
> licensee programs. Region II should focus more on safety and/or
> risk‑significant inspections of both SSCs and licensee programs with
> allowances for changes in emphasis due to scheduling, inspector
> availability, and licensee changes.

2509‑08 BASIC REQUIREMENTS/POLICY FOR INSPECTION PROGRAM

This section provides the three phases of the BF1RP inspection program.
The intent is not to imply that all inspections for a particular phase
must be completed before entering the next phase.

08.01 [Level of Effort]{.underline}. To be determined by Region II in
its IP&S as long as the total estimated resources for all inspection
activities are in agreement with allotted budget developed jointly by
Region II and NRR. Inspectors should charge to the IPs and TIs listed in
Appendices A and B and to the applicable activity codes referenced in
Appendix A.

a.  Every licensee program, (i.e., Special Programs, testing, or
    maintenance) affecting either SSCs in a single system or multiple
    systems will be inspected per the following:

    1.  For each licensee program, inspect its programmatic aspects
        (review of the administrative processes for implementing a
        program or ensuring quality assurance is instilled in a program
        ) only once. All licensee Special programs are listed in the
        first reference in Section 13 of this manual chapter. If the
        programmatic aspects of a program were verified by NRC
        inspections for the restarts of Browns Ferry Units 2 or 3 or
        during the commercial operation of those two units, then that
        program does not have to be re-verified for Unit 1 if it has not
        been altered. For those procedures and programs already utilized
        at BF2 and BF3 (i.e., security and emergency preparedness (EP),
        etc.), inspection requirements should focus on monitoring the
        results of their implementation, and any BF1‑specific adopted
        revisions to them.

    2.  An appropriate number of representative samples of the results
        of the implementation of each licensee Special program shall be
        inspected for safety‑ significant SSCs, including any
        interfacing non‑safety‑significant SSCs. That goal can be
        achieved by inspecting the SSCs for one system or several
        systems in which changes were made due to the implementation of
        a licensee Special program. The acceptance criteria for those
        results for each Special program will be as stated in the
        respective modification package, test procedure verifying the
        functionality of the results, or in the basis document for a
        specific licensee Special program.

b.  Region II shall develop a detailed Transition Plan, as part of or in
    addition to the IP&S, that defines the total inspection effort
    expended and the projected schedule in order for all seven
    cornerstones to be within the full oversight provided by the ROP.
    That full oversight is not available until all cornerstones are
    monitorable by a combination of the baseline inspection program and
    either PIs or compensating inspections above the baseline so that
    the Action Matrix can be invoked.

    1.  This Transition Plan shall reference inspection reports which
        will document IPs and inspection criteria that were performed.
        The Transition Plan shall state the inspection criteria
        completed entirely or just in part with any exceptions or
        deviations noted; and any significant open items, licensing
        actions, or regulatory issues resolved by a particular IP or
        inspection criterion for each cornerstone.

    2.  Region II will develop a detailed Transition Matrix to address
        the items listed in Step 08.01b.1. for each cornerstone.

    3.  The IP&S and Transition Plan should be clearly cross-referenced
        to the inspection reports. Normal NRC processes and databases
        for tracking and closing out open and restart items will be
        utilized and will support development of a Restart Checklist
        after the Restart Oversight Panel is established.

    4.  An open item closeout inspection shall be performed for each or
        several cornerstones at a time to verify that all warranted
        licensee corrective actions have been completed. The inspection
        shall be implemented prior to permitting any cornerstone to be
        monitorable under the ROP by inspection or PIs.

    5.  The Transition Plan shall indicate when each cornerstone is
        placed under the limited oversight of the ROP. A cornerstone can
        become monitorable as stated in Step 03.05 at any time during
        the restart of BF1, including its actual startup.

08.02 [Renovation Work Activities]{.underline}. In addition to plant
design modifications for the implementation of the Special Programs
outlined in Browns Ferry\'s Nuclear Performance Plan and approved by NRC
in NUREG‑1232, Vol. 3, and its supplements ( which are a compilation of
SERs), the inspection program should sample BF1 design modifications
which should be similar to those completed for BF2 and BF3, planned
design changes in the current 5 year Browns Ferry Nuclear Project Plan,
corrective/preventive maintenance issues, regulatory issues (i.e.,
licensee Recovery Program implementation on Unit 1), licensing actions,
in-service inspection issues, and any NRC noncompliances resulting from
inspections. The majority of these issues will be docketed by the
licensee and should be placed on the IP&S for tracking as appropriate.

a.  The inspection of these modifications may be combined along with the
    programmatic reviews of Special Programs to increase inspection
    efficiency by reducing the number of inspections required. These
    inspections may be accomplished by implementing the applicable IPs
    from Appendix A.

b.  For line item 08.01a., an inspection noncompliance, incorporated in
    the list for tracking opens items, may increase the scope of the
    inspection for a particular issue by the review of additional
    samples. If there are multiple findings for one generic issue, then
    only the verification that the licensee is addressing corrective
    actions will be required since the existence of the problem has
    already been verified and the inspection of additional samples is
    unwarranted.

08.03 [Restart Testing]{.underline}. Appendix B lists IPs to verify that
SSCs important to the safety of the plant are fully tested to
demonstrate they can perform their safety functions. In accordance with
the IP&S, the appropriate IPs will be selected from Appendix B so
inspectors can witness and/or evaluate the performance and the results
of a representative sample of the tests contained in the licensee\'s
pre‑approved and submitted Restart Test Program for BF1, which is
similar to the test programs conducted at BF2 and BF3.

a.  The NRC inspection of the restart testing program will be invoked
    after affected SSCs are declared ready for testing or as defined in
    the objectives of this manual chapter.

b.  Region II may increase the scope and sample sizes of either
    individual IPs or the overall inspection policy for the pre‑restart
    test program itself, as appropriate, if some licensee tests cannot
    be verified as satisfactorily completed.

c.  The inspections of Restart Testing verify the functionality of
    accident mitigation and safe shutdown systems. Region II will select
    a sample of tests to review from the licensee\'s Restart Test
    Program and the corresponding IPs from Appendix B. For each test,
    there are different IPs for procedure review, witnessing, and
    results evaluation. The IPs for procedure review should be
    implemented only if significant changes have been made to the
    corresponding licensee test procedures.

d.  The licensee may conduct restart testing during power ascension
    which the NRC will monitor using routine oversight (likely by using
    baseline IPs). However, the NRC will conduct an ORAT inspection as
    defined below:

> An, corrective action programs, the maintenance program, operator
> response to annunciators and general plant Operational Readiness
> Assessment Team Inspection will be performed during power escalation
> of BF1. The exact timing of the inspection and its overall scope
> should be tailored to the circumstances and the past performance of
> BF1. This inspection should not duplicate the reviews of licensee
> processes and programs performed in prior inspections under the
> BF1RPwithout sufficient justification. The purpose of this inspection
> effort is to focus on the effectiveness of licensee management
> oversight, safety‑significant activities, operator training and
> experienceconditions impacting safety, and the readiness to support
> operations. Third party self-assessment should be reviewed and the
> scope of the ORAT should be adjusted to avoid repeating previous
> inspections. Results from this inspection will provide a major input
> and basis for an NRC determination of startup readiness.

2509‑09 OVERSIGHT OF RESTART ACTIVITIES

The NRC oversight of BF1 restart activities will be conducted per this
manual chapter by referencing MC 0350 and noting any exceptions with it
below. Routine assessment of licensee restart performance will be
provided by the Restart Panel in periodic public meetings and in routine
inspection cover letters and other correspondence. Prior to
establishment of the Restart Panel, routine assessment will be performed
by the cognizant RII management.

09.01 The following exceptions are either generic to all of MC 0350 or
more broader than the other exceptions.

a.  The basis for the shutdown of BF1 in 1985 was due to management and
    regulatory issues rather than performance problems or events.

b.  Only Region II and NRR will be involved in any BF1 restart
    decisions.

c.  Sections 04 and 05 should not be used for BF1 except for the portion
    in the latter on the Restart Checklist.

d.  The full oversight of the ROP is not in effect until all
    cornerstones are monitorable and transition to the ROP.

09.02 The Restart Checklist will be listing of issues as stated in MC
0350, Section 05.03 but with the following clarifications:

a.  The Restart Checklist will be a listing of open, unresolved
    regulatory issues. Thus, a working tool for the oversight and
    resolution of the remaining BF1 open issues beginning with its
    origination. Only the Transition Matrices will contain the complete
    documentation of the NRC oversight effort for BF1.

b.  A risk significance of "white" or higher will be equal to a safety
    significance as characterized by Severity Level III and above issues
    when traditional enforcement is in affect for some cornerstone(s).

c.  A cited violation may mean Severity Level III and above issues when
    traditional enforcement is in affect for some cornerstones not just
    for "white" or higher issues when findings are evaluated by the SDP.

09.03 Section 06 of MC 0350 on \'Oversight Review Activities\' is
appropriate with the following exceptions:

a.  The "oversight panel" will be called the "restart oversight panel."

b.  The Regional Administrator for Region II and the Director of DIPM
    will decide when to establish and dissolve the Restart Oversight
    Panel.

09.04 Section 07 of MC 0350 on \'Post‑Restart Activities \' may be used
but this manual chapter will override MC 0350 if there are any
conflicts.

09.05 Section 09 of MC 0350 on \'Records\' is appropriate except for
item 2 on the list of records to be kept (Item 2 record should not be
kept for BF1).

09.06 For Appendix A of MC 0350, the following exceptions are noted:

a.  For Step B.1, the Restart Oversight Panel should focus its restart
    review efforts on issues as defined in Step 09.02.

b.  For Step B.3, the establishment of the Restart Oversight Panel and
    the content of the Restart Checklist should be in accordance with
    this manual chapter.

c.  For Step B.3.c, safety-significant issues, as determined by staff
    review/evaluation, may also be placed on the Restart Checklist, when
    traditional enforcement is in effect for some cornerstone(s).

d.  For Step B.4.1a., the references to AIT and IIT are not appropriate.

e.  For Step B.5, items c. and d. should be in accordance with this
    manual chapter.

f.  Topics covered in Steps B.7 and B.8 may be used as long as they do
    not conflict with this manual chapter.

g.  For Step C.1, the issues on the Restart Checklist will be as stated
    in Step 9.02.

h.  Any relevant exceptions noted elsewhere in Section 09 of this MC.

2509‑10 INSPECTION FINDINGS AND ENFORCEMENT

10.01 For those cornerstones not being monitored by the ROP baseline
inspection program and either PIs or compensatory inspections above the
baseline inspection program, MC 0610 will be implemented to evaluate and
document inspection observations and to classify them as findings, if
appropriate, after they have been placed in context and assessed for
significance. The findings will then be categorized as violations,
noncited violations, minor violations, deviations, open items, or
unresolved items.

Traditional enforcement, similar to that used for BF3\'s startup, will
be in effect for the restart of BF1 only for those cornerstones which
are not monitorable by the ROP. Findings from inspections will be
processed in accordance with 10 CFR Part 2 and other applicable
enforcement guidance using traditional enforcement tools. This includes
use of severity levels, NOVs for severity level III and above, NCVs for
severity level IV, and civil penalties as appropriate. The severity
level of an apparent violation will be dependent on its safety
significance per MC 0610, Section 05.04b and only Section IV.B. (except
for any references to risk significance) and Supplement II of the
Commissions current Enforcement Policy. Any references in MC 0610 to
providing input to SALP or PPR should be ignored since they are not
appropriate.

10.02 Any findings on the licensee's QA program should be based on its
implementation not its adequacy since that program is either the same or
comparable to the QA program utilized in the other two units.

10.03 Minor violations will be assessed and documented using the
criteria of MC 0610 for those associated with cornerstones which are not
monitorable by the ROP.

10.04 For those cornerstones monitorable by the ROP in accordance with
Step 03.05 of this MC, any noncompliances will be documented and
reported under MC 0612 with no exceptions. The significance of
noncompliances will be assessed in accordance with the significance
determination process (SDP) per MC 0609. Any findings will be
dispositioned in accordance with the ROP for such cornerstones with
enforcement of these findings being handled in accordance with
Commission\'s current Enforcement Policy.

10.05 The same inspection report may have one noncompliance being
assessed by MC 0610 , if the ROP is not applicable, and another
noncompliance being assessed by MC 0612 , if its cornerstone is
monitorable by the ROP.

10.06 The treatment of open items will deviate some from what is stated
in MC 0610, Section 06.04, based on the exceptions noted below.

a.  Region II may administratively close out an open item that does not
    warrant inspection resources. For example, Region II may review the
    proposed corrective action plan for a Unit 1 open item and compare
    it with what was done for either of the other two operating units.
    If all of the following questions are answered affirmatively about
    the open item, it can be administratively closed and the basis for
    its closure documented in an inspection report:

    1.  Is it being effectively tracked in the licensee\'s corrective
        action program or other formal tracking system?

    2.  Is the licensee proposing the same corrective action or
        equivalent for it that was done for a similar open item for
        either Unit 2 or 3?

    3.  Will essentially the same procedures, process, or design change
        be used to correct the issue?

    4.  Does the inspection record indicate that the item was
        sufficiently inspected and closed on Unit 2 or 3 with no
        problems?

    5.  Would performance deficiencies associated with the licensee\'s
        corrective actions likely be detected by the licensee\'s
        oversight or testing programs or have only minor consequences?

2509‑11 POST‑RESTART AND THE TRANSITION TO THE ROP ACTIVITIES

11.01 Post‑restart activities and the overall approach for transitioning
to the ROP will be in accordance with this manual chapter as stated
below.

a.  The transition of BF1 to the ROP will be a gradual‑phased approach
    on an individualized cornerstone basis. The basis for why a certain
    cornerstone will be declared ready to be monitorable under the ROP
    will be contained in the BF1 ROP Transition Plan which shall be
    developed by Region II.

b.  The Region II Transition Plan will adhere to the guidelines stated
    in this manual chapter and will be composed of Transition Matrices,
    one for each cornerstone. Each Transition Matrix will contain all
    the records that verify that a cornerstone is fully monitorable
    (what inspection criteria were performed and when; whether
    inspection criteria were completed in their entirety or just in part
    with any exceptions or deviations noted; what significant open
    items, restart issues, licensing actions, or regulatory issues were
    resolved; the identified inspection findings and the corresponding
    licensee corrective actions). Based on the decision of either Region
    II management or the Restart Oversight Panel with the concurrence of
    the Chief, IIPB/DIPM, that cornerstone will be placed under the
    limited oversight of the ROP.

c.  The ROP Transition Plan should also specify the required inspection
    procedures to be performed, when one or several cornerstones appear
    to be ready to be monitorable by the ROP, and to verify that all
    restart issues have been resolved with the licensee corrective
    actions being effective. The status of the cornerstones for
    BF1should be comparable to the status of the same cornerstones for
    BF2 and BF3, prior to each of them implementing the ROP in April of
    2000 but taking into account any new issues (design, licensing, or
    regulatory) that have developed between then and now.

d.  If all cornerstones are not monitorable by the ROP, the appropriate
    corrective actions for some inspection findings will not be
    determinable. Therefore, the ROP Web Site will not be updated for
    either inspection findings or available PI results until all
    cornerstones are monitorable by the ROP and the Action Matrix is put
    into effect.

e.  The regulatory responses allowed in accordance with the Action
    Matrix may be used even though the Action Matrix is not in effect at
    the discretion of the Restart Oversight Panel or Region II
    management prior to the transition of BF1 to the ROP.

f.  The transfer of BF1 to the full oversight of ROP will be by written
    approval of the Regional Administrator with the concurrences of the
    Director of DIPM and the Chief, IIPB/DIPM, based on recommendations
    of the Restart Oversight Panel. This transfer may occur even if all
    PIs are not available, provided compensatory inspections are
    conducted as provided for by IMC 2515. The Restart Oversight Panel
    may be dissolved at that time or may be maintained for up to two
    additional quarters per MC 0350, Section 07, if necessary in order
    to deal appropriately only with outstanding restart issues. Prior to
    this point in time, identifying the need for additional NRC
    inspections and determining the response to inspection findings or
    events will either be by the assigned Region II branch chiefs or by
    the Restart Oversight Panel in accordance with this manual chapter.
    Subsequently the ROP will dictate what inspections should be
    implemented and what PIs should be reviewed in determining the
    performance of BF1 and also what will be the regulatory response for
    inspection findings or events.

2509‑12 INTERFACE WITH RELATED PROGRAMS

12.01 [Security and Safeguards Inspections]{.underline}. As with all
other cornerstones, Region II will determine, as early as possible, when
the physical protection cornerstone is ready to be monitored under the
ROP baseline and PIs. NRR and Region II will work closely with NSIR to
ensure the physical protection inspections are appropriate for any
specific BF1 activities that are unique to BF1 and different from those
of Units 2 and 3.

2509‑13 REFERENCES

T.E. Abney to U.S. Nuclear Regulatory Commission, "Browns Ferry Nuclear
Plant (BFN) - Unit 1 - Regulatory Framework For The Restart of Unit 1\",
dated December 13, 2002.

(ADAMS #ML023600026)

END

Appendices:

A. Applicable IPs and TIs for Renovation Phase and Applicable Activity
Codes

B. Restart Testing

APPENDIX A

APPLICABLE IPs AND TIs FOR RENOVATIONS PHASE,

AND APPLICABLE ACTIVITY CODES

(The IPs or TIs listed below are available for use in Region II's
inspection plan and schedule. It is not intended that they all be
utilized.)

Inspection

[Procedure No.]{.underline} [Inspection Procedure Title]{.underline}

71111.02 Evaluation of Changes, Tests, or Experiments

71111.05 Fire Protection

71111.12 Maintenance Rule Implementation

71111.17 Permanent Plant Modifications

71111.21 Safety System Design and Performance Capability

71111.23 Temporary Plant Modifications

71121.01 Access Control to Radiologically Significant Areas

71121.02 ALARA Planning and Controls

71152 Identification and Resolution of Problems

37550 Engineering

37551 Onsite Engineering

38703 Commercial Grade Dedication

40500 Effectiveness of Licensee Controls

49001 Inspection of Erosion-Corrosion/Flow-Accelerated-Corrosion
Monitoring Programs

50090 Pipe Support and Restraint Systems

50100 HVAC Systems

51053 Electrical Components Work Observation

51055 Electrical Components Record Review

51061 Electric Cable Procedure Review

52001 Digital Retrofits Receiving Prior Approval

52002 Digital Retrofits Not Receiving Prior Approval

55050 Nuclear Welding General Inspection Procedure

55100 Structural Welding General Inspection Procedure

57050 Nondestructive Examination Procedure Visual Examination Procedure
Review/Work Observation/Record Review

57060 Nondestructive Examination Procedure Liquid Penetrant

> Examination Procedure Review/Work Observation/Record Review

57070 Nondestructive Examination Procedure Magnetic Particle

> Examination Procedure Review/Work Observation/Record Review

57080 Nondestructive Examination Procedure Ultrasonic Examination
Procedure Review/Work Observation/Record Review

57090 Nondestructive Examination Procedure Radiographic

> Examination Procedure Review/Work Observation/Record Review

61720 Local Leak Rate Testing

61726 Surveillance Observations

62002 Inspection of Structures, Passive Components, and Civil
Engineering Features at Nuclear Power Plants

64704 Fire Protection Program

70370 Testing Piping Support and Restraint Systems

71707 Plant Operations

71715 Sustained Operations Observations

71750 Plant Support Activities

81064 Compensatory Measures

82701 Operation Status of EP Program

83727 Facilities & Equipment

83729 Occupational Exposure Ctrl Ext Outgas

83750 Occupational Radiation Exposure

84750 Rad Waste Trtmnt & Effl & Envr Mntrg

92701 Follow-up

92901 Plant Operations

92902 Follow-up - Maintenance

92903 Follow-up - Engineering

92904 Follow-up - Plant Support

93801 SSFI

93803 Safety Systems Outage Modifications Inspection

93804 PRA Team

93810 Service Water System Operational Performance Inspection (SWSOPI)

93811 Electrical Distribution System Functional Inspection (EDSFI)

Temporary

[Instruction (TI) No.]{.underline} [Temporary Instruction
Title]{.underline}

2500/020, Rev. 2 Inspection to Determine Compliance with ATWS Rule, 10
CFR 50.62

2515/111 Electrical Distribution System Followup Inspection

APPLICABLE ACTIVITY CODES FOR BF1RP

Time and Labor reporting for inspection-related effort at Browns Ferry 1
prior to restart.

The following activity codes are to be used for time and labor reporting
for inspection-related effort at Browns Ferry, Unit1, prior to the date
of Brown Ferry, Unit 1, restart:

Activity Code Description

OA Direct inspection effort - Time spent actually conducting inspections
related to Browns Ferry, Unit 1, restart activities. This includes
conducting any baseline IPs, supplemental procedures or any other IPs as
determined by the Browns Ferry, Unit 1, restart panel.

AT Browns Ferry, Unit 1, restart inspection related travel - Time spent
traveling to and from Browns Ferry, Unit 1, to support Browns Ferry,
Unit 1, restart inspections

SEP Browns Ferry, Unit 1, restart inspection preparation - Time spent
preparing for Browns Ferry, Unit 1, restart inspections. Preparation may
occur before or during an inspection.

SED Browns Ferry, Unit 1, restart inspection documentation - Time spent
documenting the results of Browns Ferry, Unit 1, restart inspections,
writing inspection reports and documenting inspection findings.

ENF Browns Ferry, Unit 1, restart inspection enforcement - Time spent
processing Browns Ferry, Unit 1, restart inspection findings.

COM Browns Ferry, Unit 1, restart inspection routine communication -
Time spent by SRI/RI in non-inspection related activities such as
drop-in visits by plant management, tours with NRC management,
teleconferences and discussions with NRC management.

REG Browns Ferry, Unit 1, restart inspection regional assistance - Time
spent providing non-direct inspection support for an ongoing Browns
Ferry, Unit 1, restart inspection. Used primarily by regional inspectors
to charge in-office reviews in response to general technical questions.
(Direct inspection support by regional inspectors for a specific
inspection is charged to activity code OA).

PS Browns Ferry, Unit 1, plant status - Time spent by SRI/RI in
gathering and analyzing information regarding current plant status and
ongoing activities that are directly applicable to inspection planning.
Control room and plant walkdowns, attendance at licensee status
meetings, and inspection entrance and exit meetings.

Resource requirements for these inspection activities will be budgeted
in the appropriate PA budget code and will be tracked during the period
prior to Browns Ferry 1 restart. After the date of Browns Ferry 1
restart, time and labor reporting for inspection-related effort will be
done according to standard ROP reporting procedures.

APPENDIX B

RESTART TESTING

This Appendix describes the inspection program to verify systems,
structures, and compo­nents important to safety of the plant are fully
tested to demonstrate that they satisfy their design requirements. The
IPs listed are for test procedure review, witnessing of test, and
evaluation of test results. The IPs for a specific test are on the same
line as test title and the following two to three lines as applicable.

Inspection

Procedure

[No.]{.underline} [Inspection Procedure Title]{.underline}\*

35301 Quality Assurance for Pre-restart Testing

IP Numbers for

Procedure Witnessing Evaluations of [Inspection Procedure
Title]{.underline}

[Review]{.underline} [of Test]{.underline} [Test Results]{.underline}

70304 70315 70322 Engineered Safety Features Test