ML110660349

Request for Additional Information Regarding Technical Specification Change TS-474

ML110660349
Person / Time
Site:	Browns Ferry
Issue date:	03/10/2011
From:	Gratton C Plant Licensing Branch II
To:	Krich R Tennessee Valley Authority
Gratton C, NRR, DORL, 415-1055
References
TAC ME4668, TAC ME4669, TAC ME4670
Download: ML110660349 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Ma rc h 10, 2011 Mr. R. M. Krich Vice President, Nuclear licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION CHANGE TS-474 (TAC NOS. ME4668, ME4669, AND ME4670)

Dear Mr. Krich:

By letter dated August 27,2010, Tennessee Valley Authority (TVA) submitted a request for a change to Technical Specification (TS) 3.7.3, "Control Room Emergency Ventilation (CREV)

System," for the condition when both CREV subsystems are inoperable due to an inoperable High Efficiency Particulate Air (HEPA) filter, or when one or more CREV subsystems are inoperable due to an inoperable charcoal adsorber. TVA also requested a completion time of 90 days to restore the HEPA filter and charcoal adsorber to operable status.

Based on our review of your submittal, the U. S. Nuclear Regulatory Commission staff finds that a response to the enclosed request for additional information (RAI) is needed before we can complete the review.

This request was discussed with your staff on March 2 and 4, 2011, and it was agreed that a response would be provided within 30 days of the issuance of this letter.

In addition to the RAI that is enclosed, TVA also agreed to address in the response to this RAI an inaccurate phrase in the application regarding the discussion of the dose consequences that was identified after the application was submitted.

If you have any questions, please contact me at (301) 415-1055.

Christopher Gratton, Senior Project Manager Plant licensing Branch 11-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosure:

Request for Additional Information cc w/encl: Distribution via listserv

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING CONTROL ROOM EMERGENCY VENTILATION ALLOWED OUTAGE TIME BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296 TAC NOS. ME4668, ME4669, AND ME4670 By letter dated August 27, 2010 (Agencywide Documents Access and Management System Accession No. ML102430528), Tennessee Valley Authority (TVA), the licensee for Browns Ferry Nuclear Plant (BFN) Units 1,2, and 3, requested a change to Technical Specification (TS) 3.7.3, "Control Room Emergency Ventilation (CREV) System," for the condition when both CREV subsystems are inoperable due to an inoperable High Efficiency Particulate Air (HEPA) filter, or when one or more CREV subsystems are inoperable due to an inoperable charcoal adsorber.

TVA also requested a completion time of 90 days to restore the HEPA filter and charcoal adsorber to operable status.

Your letter also stated that the CREV system, including the HEPA filters, is credited in the BFN Units 1, 2, and 3, licensing basis analysis of design basis accident consequences to control room occupants. In addition, you stated that recent analyses show that the post loss-of-coolant accident (LOCA), 30-day control room dose, with no credit for either the HEPA filters or the charcoal adsorbers, results in a minimal increase in dose consequences (a 9.5 percent increase),

with a final dose of 1.94 rem. You state that this remains well below the regulatory limit of 5 rem.

The Nuclear Regulatory Commission (NRC) staff believes that the BFN Units 1, 2, and 3, current accident analysis does not support the requested change because the CREVS, including the HEPA filters, are credited in the current licenSing basis and the requested change may invalidate the conclusion that BFN Units 1, 2, and 3, are in compliance with the requirements of Appendix A to Title 10 of the Code ofFederal Regulations, Part 50, Criterion 19, "Control room." Consequently, in order for the NRC staff to proceed with its review of your request please provide the following:

The current design basis LOCA radiological consequence analysis assumes credit for the CREV HEPA filter. The application changes this assumption in the LOCA analysiS by removing the credit taken for the HEPA filtration. Provide additional information describing all the basic parameters used in the LOCA dose consequence analyses. For each parameter, please indicate the current licensing basis (CLB) value, the revised value where applicable, as well as the basis for any changes to the CLB. Also describe any methodologies that may have changed based on the proposed amendment. In addition, provide the resulting change to the calculated radiological consequence of the design basis LOCA. The staff requests that the information be presented in a table as was done for the Browns Ferry alternative source term amendment request.

Enclosure

March 10, 2011 Mr. R. M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 11 01 Market Street Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION CHANGE TS-474 (TAC NOS. ME4668, ME4669, AND ME4670)

Dear Mr. Krich:

By letter dated August 27,2010, Tennessee Valley Authority (TVA) submitted a request for a change to Technical Specification (TS) 3.7.3, "Control Room Emergency Ventilation (CREV)

System," for the condition when both CREV subsystems are inoperable due to an inoperable High Efficiency Particulate Air (HEPA) filter, or when one or more CREV subsystems are inoperable due to an inoperable charcoal adsorber. TVA also requested a completion time of 90 days to restore the HEPA filter and charcoal ad sorber to operable status.

Based on our review of your submittal, the U. S. Nuclear Regulatory Commission staff finds that a response to the enclosed request for additional information (RAI) is needed before we can complete the review.

This request was discussed with your staff on March 2 and 4, 2011, and it was agreed that a response would be provided within 30 days of the issuance of this letter.

In addition to the RAI that is enclosed, TVA also agreed to address in the response to this RAI an inaccurate phrase in the application regarding the discussion of the dose consequences that was identified after the application was submitted.

If you have any questions, please contact me at (301) 415-1055.

Sincerely, IRA!

Christopher Gratton, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv Distribution:

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