ML051050580

Technical Specifications Change 427, Response to Request for Additional Information Regarding Deletion of the Low Pressure Coolant Injection Motor-Generator Sets

ML051050580
Person / Time
Site:	Browns Ferry
Issue date:	04/15/2005
From:	Abney T Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC3822, TVA-BFN-TS-427
Download: ML051050580 (6)

Text

April 15, 2005 TVA-BFN-TS-427 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:

In the Matter of ) Docket No. 50-259 Tennessee Valley Authority )

BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 - TECHNICAL SPECIFICATIONS (TS) CHANGE 427 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING DELETION OF THE LOW PRESSURE COOLANT INJECTION MOTOR-GENERATOR SETS (TAC NO. MC3822)

This letter provides TVAs responses to the NRC request for additional information (Reference 1) regarding proposed Technical Specification (TS) 427.

On July 8, 2004 (Reference 2), TVA requested a TS change (TS 427) to incorporate the necessary TS revisions for the removal of the requirement to maintain an automatic transfer capability for the power supply to the Low Pressure Coolant Injection (LPCI) inboard injection and recirculation pump discharge valves. NRC requested additional information to support the review of the submittal. The NRC requests and TVAs responses are enclosed.

TVA has determined that the additional information provided does not affect the no significant hazards considerations associated with the proposed amendment and TS changes. The proposed amendment and TS changes still qualify for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

U.S. Nuclear Regulatory Commission Page 2 April 15, 2005 If you have any questions about this submittal, please contact me at (256) 729-2636.

Sincerely, Original signed by:

T.E. Abney Manager of Licensing and Industry Affairs

References:

1. NRC letter, M.H. Chernoff to K.E. Singer, dated March 28, 2005, Browns Ferry Nuclear Plant, Unit 1 -

Request for Additional Information Regarding Technical Specification Change Request (TS-427) Deletion of Low Pressure Coolant Injection Motor-Generator Sets (TAC No. MC3822).

2. TVA letter, T.E. Abney to NRC, dated July 8, 2004, Browns Ferry Nuclear Plant (BFN) - Unit 1 - Technical Specifications (TS) Change 427 - Deletion of the Low Pressure Coolant Injection Motor-Generator Sets.

U.S. Nuclear Regulatory Commission Page 3 April 15, 2005 Enclosure cc (Enclosure):

State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415 Mr. Stephen J. Cahill, 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 Margaret Chernoff,Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 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 15, 2005 Enclosure cc (Enclosure):

A. S. Bhatnagar, LP 6A-C J. C. Fornicola, LP 6A-C D. F. Helms, BR 4T-C R. F. Marks, PAB 1C-BFN R. G. Jones, NAB 1A-BFN K. L. Krueger, POB 2C-BFN J. R. Rupert, NAB 1A-BFN K. W. Singer, LP 6A-C M. D. Skaggs, PAB 1E-BFN E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS WT CA - K S:lic/submit/TS/TS 427 PRNM LPCI MG SETS formal rai.doc

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BROWNS FERRY NUCLEAR PLANT, UNIT 1 TECHNICAL SPECIFICATION CHANGE REQUEST (TS 427)

DELETION OF LPCI MOTOR-GENERATOR SETS NRC REQUEST

1. Table 2 on page E1-16 of Enclosure 1 to the ATechnical Specifications (TS) Change Request@, provides the number of Emergency Core Cooling Systems (ECCS) (such as High Pressure Coolant Injection, Automatic Depressurization System (ADS), Low Pressure Core Spray (LPCS) and Low Pressure Coolant Injection (LPCI) actually available before the proposed change, and the number of systems available after the proposed change for the Recirculation Suction Line Break Loss of Coolant Accident (LOCA) concurrent with a single-failure. It is not clear how the number of ECCS available (such as 1LPCS, 3LPCI) before the change, and after the change have been determined for each single-failure case. Please discuss how the number of ECCS available have been determined.

TVA RESPONSE The ECCS equipment available following the postulated pipe break and single failure were determined by performing a detailed single failure analysis based on the physical configuration of the ECCS. The analysis started with the identification of ECCS equipment available prior to the postulated break. Then, each of the postulated break locations was evaluated. (Note: Break location plays a part in the analysis because, the recirculation pump discharge pipe break results in the direct loss of a LPCI loop, whereas recirculation pump suction pipe breaks do not result in the direct loss of any ECCS pump capability). A loss of offsite power was also postulated to occur.

One active single failure within the plant is postulated to occur concurrent with the pipe break. The single failure was determined based on ensuring that it results in the largest amount of equipment being lost. (For example, if two LPCI pumps (one loop) were lost as a result of the break location, a Diesel E1-1

Generator supplying power to another pump in the opposite (unbroken) recirculation loop was selected as the single failure. This resulted in the largest amount of equipment lost due to the single failure). This analytical approach resulted in the identification of the minimum equipment remaining available for postulated break mitigation.

NRC REQUEST

2. Table 3 on page E1-17 of Enclosure 1 to the ATechnical Specifications (TS) Change Request@, provides the number of ECCS (such as ADS, 1LPCS, 1LPCI) actually available before the proposed change, and the number of systems available after the proposed change for the Recirculation Discharge Line Break LOCA concurrent with a single-failure. It is not clear how the number of ECCS available before the change, and after the change have been determined for each single-failure case. Please discuss how the number of ECCS available have been determined.

TVA RESPONSE Same as the response to NRC Request 1, above.

NRC REQUEST

3. Please confirm that the implementation of the subject TS change will not adversely impact the loading of the emergency diesel generator sets under LOCA and Loss Of Offsite Power (LOOP) operating conditions.

TVA RESPONSE The loads from RMOV Boards 1D and 1E will be relocated to RMOV Boards 1A and 1B respectively. Figures 1 and 4 of TS 427 show that the normal and alternate feeds to RMOV Boards 1A and 1B are the same as RMOV Boards 1D and 1E, respectively. Therefore, the design change will not impact the loading of the diesel generators.

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