ML18026B186

Forwards Justification Which Suppls 840612 Schedular Exemption Request Re Fire Protection Mods

ML18026B186
Person / Time
Site:	Browns Ferry
Issue date:	08/23/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8408290245
Download: ML18026B186 (16)

Text

REGULATOR)INFORMATION DISTRIBUTION OATEN (RIBS)

ACCESSB3N NBR:8408290245 DOC ~ DATE; 84/08/23, NOTARIZED:

YES FACIL:50-259 Browns Ferry Nuc'leal Power Stakionr Unit 1< Tennessee 50-260 Browns Ferry Nuclear Power Stations Unit 2<

Tennessee 50-296 Browns Ferry Nuclear Power Stations Unit 3E Tennessee AUTH,NAME AUTHOR AFFILIATION MILLSg L ~ M ~

Tennessee Valley Authority RECIP ~ NAh1E RECIPIENT AFFILIATION DENTON~H.R ~

Office of Nuclear Reactor Regulationi Director

SUBJECT:

Forwards Justification which suppls 840612 schedular exemption request re fire protection mods.

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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II August 23, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

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Docket Nos. 50-259

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50-260 50-296 Please refer to D. G. Eisenhut's June 18, 1984 letter to H. G.

Parris regarding the subject of Fire Protection Modifications at Browns Ferry Nuclear Plant.

On June 12, 1984 TVA submitted a letter to you which detailed various schedules for our compliance with Appendix R for Browns Ferry. It was our understanding that the June 12 letter addressed the various concerns of the NRC which were detailed later in the referenced June 18 letter.

However, as a result of the NRC June 18 letter, we have reevaluated our position regarding the schedular exemption request.

Enclosed is a detailed justification, including compensatory

measures, which supplements our existing schedular exemption request.

We believe the information and commitments contained in the enclosure pr ovide the necessary justification for the NRC to approve our existing schedular exemption for Appendix R modifications.

If you have any questions, please get in touch with us through the Browns Ferry Project Manager.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Licensing

~Subscribed gqdzsworn to efor e me t is

~~ay of I

1984.

Notary Public My Commission Expires Enclosure cc:

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4 Mr. Harold R. Denton August 23, 1984 cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II ATTN:

James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 Mr. R. J. Clark Browns Ferry Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue

Bethesda, Maryland

20814,

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ENCLOSURE APPENDIX R SCHEDULAR EXEMPTION JUSTIFICATION A.

A endix R Com ensator Measures Immediately following the completion of the unit 2 cycle 5 outage the following compensatory measures will be initiated.

1.

Reactor Building A roving fire watch will be posted in each unit of the Reactor Building while the unit is operating.

The fire watches will be provided until all required Appendir R modifications are completed for each specified area of that particular unit or the unit is in cold shutdown.

The fixe watches will check the following areas of the Reactor Building during each hourly round:

a.

Residual heat removal pump corner rooms (Elevations 519 and 541).

b.

Axes above the drywell access

room, south of the dxywell, Elevation 565.

c.

Area below shutdown board rooms A, C,

and E, Elevation 593.

d.

Area around the unit 3 shutdown board room transformers, Elevation 621.

In addition to the provision of roving fire watches, administrative controls will be established to prohibit the storage of transient combustibles in the above areas until all required Appendix R modifications are completed for each specified area of that paxticular unit or the unit is in cold shutdown.

Thc areas to be kept clear of the storage of transient combustibles will be clearly marke d.

2.

Intake Pumping S tation A roving fire watch will be posted in the intake pumping station, Elevation 550 while any unit is operating.

The fire watch will be provided until all required Appendix R modifications at the intake pumping station are completed or unless all three units are in cold shut down.

In addition to the provision of a xoving fire watch> administrative controls will be established to prohibit thc storage of transient combustibles in the pipe tunnel along the north wall of thc intake pumping station, 3.

Other Critical Areas Administrative controls will be established to prohibit the stoxage of transient combustibles in the following areas until all xequired Appendix R modifications are completed for that particulax'rea or the unit is in cold shutdown.

a.

Shutdown board rooms A, C,

and E, Elevation 621.25 fixed combustible loading in these rooms is very low and access is strictly contr ol 1 ed.

b.

Battery rooms and battery board rooms in the Control Building, Elevation 593 automatic suppression and detection is provided in each complex and access is strictly controlled.

c.

Auxiliary instrument rooms in the Control Building, Elevation 593 suppression and detection is provided in the rooms and access is strictly controlled.

The compensatory measures outlined above provide an additional level of fire prevention in the areas which are critical to safe operation.

These measures will provide adequate protection for the health and safety of the public during the time required to complete the modifications necessary to meet the applicable requirements of 10 CFR 50, Appendix R.

B.

Buildin Fire Proection Features Elevations 565 and 593 of the Reactor Building have complete automatic suppression provided by fixed water spray and pre-action sprinkler systems.

The accumulation of transient fire loads is rigidly controlled by administrative procedures currently in place and ignition sources are controlled by strict controls on all cutting, welding, and hot work operations.

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Fixed water spray systems were installed where thc trays of one division cross thc trays of thc other division and where two cable tray runs of opposite divisions approach each other directly to within a few feet.

In addition, they were al.so installed where nondivisional cable trays are within the boundary zone of both divisions.

Equipment which presents a special hazard to safety-related equipment in other areas of the Reactor Building are protected by fixed water spray or prc-action sprinkler systems.

Vary few redundant circuits necessary to achieve and maintain hot and cold shutdown are located in other areas of the Reactor Building.

With the protection provided for special

hazards, strict controls on transient combustibles and ignition sources, and a well trained and equipped fire brigade, thc possibility of a fire. occurring in these areas is significantly reduced.

C.

Into rated Schedule Please refer to L. M. Mills'etter to H. R. Benton dated August 14,

1984, which transmitted our integrated schedule for Browns Ferry.

TVA will complete the rcquircd Appendix R modifications consistent with the following schedules.

Unit 1 Cycle 7 1987 Unit 2 Cycle 6 1986 Unit 3 Cycle 7 1987

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All ma)or modifications at Browns Rerry are being scheduled in accordance with the referenced integrated work schedule.

This U

schedule seeks to optimize the use of available resources to complete a wide variety of projects in a coordinated fashion with no one project receiving an undue or unwarranted priority ovex anothex of similar value or importance.

Certain xesource limitations have been recognized with respect.to thc Browns Perry modification schedule.

These limitations are allowable T&L workforce levels onsite, available engineering

support, available onsite support staff, and equipment availability for the large number of high priority NRC requirements.

These limitations are in part based upon physical plant and managex'ial limitations that form the basis for the integrated work schedule.

Working within these limitations, the Appendiz R work to be performed during each designated outage period represents the optimum balance of the total regulatory work load.

To'accelerate the Appendix R work schedule would require either the postponement of other regulatory mandated modifications, (such as IEB 79-01B, Environmental Qualification, IEB 83-02, Pipe Replacement) or x'equire the significant delay of a unit's return to service beyond the presently extended outage schedule.

Either option could have a

severe adverse impact.

Therefoxe, TVA does not propose to accelerate the Appendix R modification schedule at the expense of other safety-related modifications of similar importance.

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