ML060370176
| ML060370176 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/03/2006 |
| From: | O'Grady B Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC8826 | |
| Download: ML060370176 (8) | |
Text
February 3, 2006 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 Nos. 50-259 Tennessee Valley Authority )
BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1- RESPONSE TO NRC REQUEST FOR INFORMATION REGARDING FIRE PROTECTION PROGRAM (TAC NO. MC8826)
By letter dated January 3, 2006 (Reference 1), NRC requested TVA to provide information regarding the fire protection program that will be implemented at Browns Ferry Nuclear Plant upon restart of Unit 1.
TVA is committed to upgrade the fire protection program for BFN Unit 1 to bring Unit 1 into compliance with 10 CFR 50.48 by complying with the applicable sections of 10 CFR 50, Appendix R. The Unit 1 program is based on the program that was implemented for Units 2 and 3 as described in Reference 2 and approved by NRC in Reference 3.
The program for Unit 1 will be fundamentally the same as the one for Units 2 and 3 with some changes in modifications and manual actions due to physical differences in plant configuration. Five exemptions from Appendix R requirements for Units 1, 2, and 3 were approved by NRC in Reference 4.
No new exemptions are required.
U.S. Nuclear Regulatory Commission Page 2 February 3, 2006 The enclosure to this letter provides additional information on Unit 1 commitments for Fire Protection / Appendix R. TVA will submit the Unit 1, 2 and 3 BFN Fire Protection Report by February 28, 2006.
If you have any questions regarding this information, please contact William D. Crouch at (256) 729-2636.
Sincerely, Original signed by R. G. Jones for:
Brian O'Grady
References:
- 1. NRC letter, Margaret H. Chernoff to TVA, Browns Ferry Nuclear Plant, Unit 1 - Request for Information Regarding Fire Protection Program (TAC NO. MC8826), dated January 3, 2006
- 2. TVA letter, Pedro Salas to NRC, Browns Ferry Nuclear Plant (BFN) - Unit 2 and 3 Browns Ferry Nuclear Plant Fire Protection Report (FPR), dated December 20, 1994
- 3. NRC letter, Joseph F. Williams to TVA, Safety Evaluation of Post-Fire Safe Shutdown Capability and Issuance of Technical Specification Amendments for the Browns Ferry Nuclear Plant Units 1, 2, and 3(TAC NOS. M85254, M87900, M87901 and M87902) (TS 337), dated November 2, 1995
- 4. NRC letter, Suzanne Black to TVA, Appendix R Exemptions for Browns Ferry Nuclear Plant, Units 1, 2 and 3 (TAC 61124, 61125 and 61126), dated October 21, 1988
U.S. Nuclear Regulatory Commission Page 3 February 3, 2006 Enclosure cc (Enclosure):
State Health Officer Alabama Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, Alabama 35611 (Via NRC Electronic Distribution)
Enclosure cc (Enclosure):
U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 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, Alabama 35611-6970 NRC Unit 1 Restart Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970
U.S. Nuclear Regulatory Commission Page 4 February 3, 2006 cc: (Enclosure)
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 5 February 3, 2006 JEM:TLE:BAB Enclosure cc (Enclosure):
B. M. Aukland, POB 2C-BFN M. Bajestani, NAB 1A-C A. S. Bhatnagar, LP 6-C J. C. Fornicola, LP 6A-C R. G. Jones, POB 2C-BFN G. W. Morris, LP 4G-C B. J. OGrady, PAB 1E-BFN K. W. Singer, LP 6A-C E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS, WT CA-K S:lic/submit/subs/Appendix R Response.doc
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 1 DOCKET NO. 50-259 RESPONSE TO NRC REQUEST FOR INFORMATION REGARDING FIRE PROTECTION PROGRAM By letter dated January 3, 2006 (Reference 1), NRC requested TVA to provide information regarding the fire protection program that will be implemented at Browns Ferry Nuclear Plant upon restart of Unit 1.
In Reference 2, TVA stated TVA has committed to issue a Unit 1 Appendix R Safe Shutdown submittal prior to that units startup. TVA did not consider this to be a new commitment. It was a reference to a commitment which was provided in the enclosures to Reference 3 for Units 1 and 3.
Reference 3 provided the original plans for the restart of BFN Units 3 and 1. The commitment was improperly closed (i.e., the Unit 1 portion had not been addressed) with the submittal of the plan and schedule for the Unit 3 Appendix R program in Reference 4.
In Reference 5, TVA proposed the regulatory framework for the restart of Unit 1. One of the special programs to be implemented for Unit 1 is Fire Protection Improvement. This program includes the requirements of Appendix R. The open commitments related to 10 CFR 50.48 and Appendix R compliance pertinent to the operation of Unit 1 and a reference to the document that initiated the commitment are as follows:
- The program for compliance with the applicable sections of Appendix R as required by 10 CFR 50.48, with approved technical exemptions, will be complete prior to restart of each unit. (Reference 6)
- Unit 1 reactor building - automatic sprinkler upgrades.
(Reference 7)
- Unit 1 reactor building - upgrade fire detection/alarm.
(Reference 7)
- The fire pump flow/pressure requirements for Unit 1 will be reviewed and confirmed to be adequate prior to the startup of the unit. (Reference 8)
E-1
- For the Fire Protection Program, the Fire Protection Report will be updated to incorporate Unit 1 as an operating unit rather than a shutdown unit. The program will be fully implemented on Unit 1. (Reference 9)
- For the Fire Water System Program, the Fire Protection Report will be updated to incorporate Unit 1 as an operating unit rather than a shutdown unit. The program will be fully implemented on Unit 1. (Reference 9)
A search of the Tracking and Reporting of Open Items Database for Unit 1 commitments yielded three closed commitments:
- 1. Implement requirements / actions identified in Appendix R submittals dated January 31, 1986, and November 21, 1986.
This commitment was made in References 10 and 11. These documents were an early attempt to submit the BFN Appendix R program that was superseded by the Fire Protection Report submittals.
- 2. A detailed review of all fire protection surveillance instructions to ensure they are technically accurate and to verify compliance with Technical Specifications is ongoing and will be completed prior to restart of the applicable unit. This commitment was made in Reference 6.
In 1987, it was determined that the fire protection surveillance instructions were common to all BFN units and this commitment was cancelled to another commitment.
- 3. TVA will add air supervision to the Reactor Building preaction sprinkler systems on all three units prior to their respective restart. This commitment was made in Reference 12. This is a redundant commitment and is part of TVAs commitment for the Unit 1 reactor building -
automatic sprinkler upgrades (DCN 51180).
References:
- 1. NRC letter, Margaret H. Chernoff to TVA, Browns Ferry Nuclear plant, Unit 1 - Request for Information Regarding Fire Protection Program (TAC NO. MC8826), dated January 3, 2006
- 2. TVA letter, O. J. Zeringue to NRC, Browns Ferry Nuclear Plant (BFN) - TVA BFN Technical Specification (TS)
No. 306 Removal of Fire Protection Requirements from TS Withdrawal of Request to Remove Definition NN from TS, dated March 19, 1993 E-2
- 3. TVA letter, Mark O. Medford to NRC, Browns Ferry Nuclear Plant (BFN) - Plans for the Return to Service of BFN Units 1 and 3, dated January 9, 1991
- 4. TVA letter, E. G. Wallace to NRC, Browns Ferry Nuclear Plant (BFN) - Overall Action Plan and Schedule for the Appendix R Program for Unit 3, dated July 11, 1991
- 5. TVA letter, T. E. Abney to NRC, Browns Ferry Nuclear Plant (BFN) - Unit 1 - Regulatory Framework for the Restart of Unit 1, dated December 13, 2002
- 6. TVA letter, S. A. White to NRC dated August 28, 1986
- 7. TVA letter, O. J. Zeringue to NRC, Browns Ferry Nuclear Plant (BFN) - Fire protection Report (FPR), dated January 15, 1992
- 8. TVA letter, E. G. Wallace to NRC, Browns Ferry Nuclear Plant (BFN) - TVA BFN Technical Specification (TS)
No. 292 - Revision to Fire Pump Surveillance Requirements, dated August 7, 1990
- 9. TVA letter, William D. Crouch to NRC, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Consolidated List of Commitments for License Renewal (TAC NOS. MC1704, MC1705 and MC1706), dated August 9, 2005
- 10. TVA letter, R. Gridley to NRC dated January 31, 1986
- 11. TVA letter, R. Gridley to NRC, Browns Ferry Nuclear Plant (BFN) - 10 CFR 50 Appendix R, dated November 21, 1986