ML20070K053
| ML20070K053 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/06/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20070K046 | List: |
| References | |
| NUDOCS 9103180286 | |
| Download: ML20070K053 (4) | |
Text
- - -
g, e4 o.
UNITED STATES
\\
l-f NUCLE AR REGULATORY COMMISSION e
g f
WASMNGT ON, D, C, M555
%....+/
i 1
l j
ENCLOSURE 2
{
SAFETY EVALUATION BY THE OFFICE 0F NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.192 TO FACILITY OPERATING LICENSE NO. DPR-52 TENNESSEE VALLEY AUTHORITY
_BROWHS FERRY NUCLEAR PLANT. UNIT 2 t
DOCKET No. 50-260 l
1.0 INTRODUCTION
a l
By letter dated April 14, 1989, the Tennessee Valley Authority (TVA, the licensee) submittedanapplicationtoamendthelicenseandtheTechnicalSpecifications.(TS) of the Browns Ferry Nuciecr (BFN) Plant Unit 2.
The purpose of this application wastoaddLicenseCondition2.C.(5)(a),andincorporateadministrativecontrols needed to impicment the SFt:, Unit 2, Appendix R Safe Shutdown Program. The 4
Appendix R Safe Shutdown Program was submitted to the NRC under separate cover letter, also on April 14, 1989. The staff reviewed this submittal-along with TVA's amendrent application as part of NRC's overall evaluation of TVA's program to comply 4
with Appendix R of 10 CFR 50.
By letter dated November 3,1989, the staff issued a supplemental Safety Evaluation (SE) report regarding Appendix R for BFN, Unit 2.
As a consequence of this SE, the staff did not asprove TVA's amendment application because of an unresolved concern identified by tae staff regarding TVA's proposed j
requirements for maintaining fire watches in the-shutdown board rooms on Elevation i
621 feet. The licensee responded to the staff's concern by a letter dated January 30, 1990, which was later superseded by a letter dated December 11,1990.
The December 11, 1990 submittal contains the latest revision of TVA's Appendix R Safe St utdown Program for EFN, Unit 2.
9 l-2.0 EVALUATION The intent of TVA's emendment application is to incorporate the Appendix R Safe Shutdown Program into the BFN license and TS in accordance with the philosophy of HRC Generic Letter (GL) 86-10. The wording of TVA's proposed license condition
-is the same as that specified in Section F of the Generic Letter, and would albw.
i the licensee to make changes in the fire protection program without prior approval of the Comission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
In addition to the license condition, TVA proposed adding the Appendix R Safe Shutdown Program to TS Section 1.0.NN, " Definitions," aid adding three other TS changes to Section 6.0, " Administrative Controls." One of these three proposed changes was to add a TS 6.5.1.6.1, which would recMre the Plant Operations Review Comittee (PORC) to review the Appendix R Program and impleaenting procedures to i
ensure that the program receives a high level of plant ranagement-attention as well as ensuring changos are reviewed by the affected plant organizations for 9:t03180286 910306 ADOCK 0500gf.)
PDR P
444.eend..
6A3.-,hus.,.f raL 4 44e e.
a 4MAAe
=
a
,,v.J__,
,g,t,frt
,,wg4 9 disu mse.,, p @. - z; m.
p,a, a a, s m...,4mu,Ame_mema,e.rmangr.-4%gsamas.gaa_,.,aha.c-.wwam,mensJ.ame a
n-
't.4-i.m esuim-e-o' mis-4._.=ardiem-
. 1 a
9 1
J7 s
4 l
1 i
j 1
4 4
4
+.-
y..,-w=-
4-
,,y -g, gy voy,...-*
y-c e
,vy-- g m,~w t.y.m r. y.,b w y.
9,-w g,,.egag,,,
pre,_.,n,_.p, y
,,4--ygy.
uyy,,,
w7*,.7
,.,,,mypm,we
~,
overall safety implications. The second change would affe u TS 6.5.2.8.h by l
l including the Appendix R Safe Shutdown Program as part of the fire protection progrannatic controls which are auditable on a 24-month basis. The third change would revise TS 6.8.1.1.f to include the ' Appendix R Safe Shutdown Program" so as to ensure that written procedures are established, implemented and maintained for this program.
The staff concludes that all of these changes are in accordance with the guidance of GL 86-10 and are therefore acceptable.
TVA's Appendix R Safe Shutdown Program contains the following elements:
(1) A list of required safe shutdown equipment.
(2) A list of compensatory measures for unavailable equipment.
(3) A list of testing requirements and imp 1cnienting procedures for required equipment; and (4) A technical basis for (1), (2), and (3),
(5) A method by which this program interacts with the design outputs documents referenced in it.
(6) A method by which this program interacts with the SSIs [ Safe Shutdown Instructions).
(7) A method for tracking the compensatory measures listed by (2).
The list of required safe shutdown equipment was reviewed by the staff and found to be acceptable.
Compensatory measures for unavailable equipment were also reviewed. The compensatory measures are stated as follows:
(A) Action must be taken in accordance with the referenced Technical Specific 6. tion.
(B) Restore the equipment function in 7 days or provide equivalent shutdown captility by one of the following methods.
(1) A temporary alteration in accordance with plant procedures that allows the equipment to perform its intended function.
(2) A firewatch in accordance with the site impairment program in the affected areas / zones as specified in Section !!I.
If the affected areas / zones are listed below otherwise it may be hourly., the firewatch must be continuous, (3) A temporary change to the SI's which provides safe shutdown without the required function.
If the equivalent shutdown '.apability is used, restore the equipment function in 60 days cr prryide an engineering evaluation and a change e
--,m.,
...---e,,
n-.,
F a
j to this pro Appendix R < gram that provide an alternate method to perform the unction, otherwise provide PORC r(view and Plant Manager 4
a pproval of the equivalent shutdown capability to ensure its adequacy.
T11s review shall be conducted every 60 days until an alternate method is in place.
Compensatory measure A pertains to TS requirements, and applies to primary containsent isolation equipment instrumentation, core and_ containment cooling.and auxiliary electrical systems equipment. Other equipment, primarily j
for the-purpose of post-fire shutdown come under compensatory measure B (restore within 7 days or provide equivalent shutdown capacity).
In the SE dated Noventer 3,1989, the NRC staff had questioned the lack of a continuous-fire watch being required in some fire areas-that.did not have automatic fire detection:(other than Fire Area 9 and the cable spreading. room). To address-l this concern, the licensee supplemented its originel Appendix R Safe Shutdown submittal dated April-14,19E9, by letter dated January 30, 1990. Both'of 1-these.submittals were subsequently superseded by the revised Appendix R Safe Shutdown Piogram submitted by letter dated Decesbar 11, 1990. Tito staff's j
evaluation of TVA's response is detailed below.'
TVA established three shutdown board rooms for each Unitt each room is considered i
L an individual fire zone and separated from each other by rated fire barriers with-i fire doors. The licensee had agreed to establish =a continuous fire watch in-each of the fire zone combi.1ations [5, 6, and 7) or [9,10, and 11) or-[13,14, r.nd 15), for Units 1 2 and 3, respectively, as compensatory measures-whenever~
' a required piece of e,quIpment was nd able to perform its function.- Literal-I compliance with this requirement for a continuous fire watch would have required three individuals in each combination of shutdown board rooms. Because the rooms are relatively small and are interconnected in a straight line by i
means of fire doors in the rated seperating partitions, the licensee proposed
[
maintaining the twolfire doors open in each coebination of rooms [5, 6, and 7):
i or[9,10,and11]or[13,14,and-15). Each combination of three rooms would j-then be censidered by the licensee as-a single fire zone for' detection purposes and as such only recuire one-individual to establish a continuous ~ fire watch.
The staff did not accept this proposal.
. After further discussion with TVA, an agreement was reached that the fire doors would be kept closed, and that the licensee would maintain a continuous-roving.
[
fire watch. This continuous-roving fire watch would rsmain in the required fire j
zonecombinetton,andwouldvisiteachofthethreeshutdownboard1 rooms-[5,6,1 and 7) or [9,10, and 11) or [13,14, and.15) every 15'* 5 minutes. ' The staff
)
concurs with this resolution'of its previous :oncern, and considers-it to be an j
acceptable level of protection in each of the affected shutdown board rooms.
i TVA included this provision for continous-roving fire watches in-its Appendix R Safe Shutdown program and confirmed by letter dated December 11,1990.
Consequently, the staff concludes, based upon the November 3,1989 SE and-i resolution.of the staff's outstanding concern regarding fire watches,'that:TVA's'
[
Appendix R Safe Shutdown Program is acceptable.
[
F
. - =.
O
~.
0 4
4
3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The amendment also involves a change in a requirement with respect to administrative procedures or requirements. The staff has determined that the amendment involves no significent increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no signifcantIncreaseinindividualorcumulativeoccupationalradiationexposure.
The Commission has previously issued a pro)osed finding that this amendment involves no significant hazards consideration and there has been no public comment on such a finding. Accordingly, the amendment sects the eli exclusion set forth in 10 CFR 51.22(c)(9) and (10)gibility criteria for categorical Pursuant to 10 CFR 51.22(b) no environmental impact statement nor cnvironmental assessment need be prepared In connection with the issuance of the amendment.
A.0 CONCLUSION The NRC staff concludes that the Appendix R Shfe Shutdown Prograe proposed by the licensee on April 14, 1989, with the enhanced fire watch requirements as cocumented in th( revised program submitted on December 11,1990, is acceptable.
Furthermore, the amendment application of April 14, 1989 is consistent with teidance of GL 86-10, and as such is also acceptable.
The NRC nade a prorcsed determination that the amendment does not involve significant h6rerds consideration, >
ch was published in the Federal Register (54 FR 29413) en July 12, 1989, and cenoticed January 15, 1991, (56 FR 1545).
The staff also consulted with the State of Alabana.
No public comments were received and the State of Alabama did not have any comments.
The staff has concluded, based on the considerations discussed above, that:
(1) there is reascnable assurance that the health and safe V of the public will not be endangered by operation in the proposed manner, (2) such activities willbeconductedincompliancewiththeCommission'sregulations,and(3)the i
issvence of the amendt.ent will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributors:
R. Wescott and D. Notley 4
Dated: March 6,1991 i
e 4
h a
4 e
w w.,
m - g r-rw
. -..,,, - +
-.e.-.e
,--g-w
-%r-,vr' v