ML18033A736

Safety Evaluation Supporting Operatiion After Restoration & Mod of Facilities Following 750322 Fire

ML18033A736
Person / Time
Site:	Browns Ferry
Issue date:	06/18/1976
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML18033A737	List: ML18033A736 ML18033A739 ML20246J144
References
NUDOCS 8905170005
Download: ML18033A736 (37)

Text

SUPPLEMENT NO.

1 TO THE SAFETY EVALUATION BY THE DIVISION OF OPERATING REACTORS SUPPORTING THE OPERATION AFTER THE RESTORATION AND MODIFICATION OF THE BRONNS FERRY NUCLEAR PLANT, UNITS 1 AND 2 FOLLOWING THE MARCH 22, 1975 FIRE DATE:

JUN 1 8 )9T6 T

v aq0517000 0>ppp2 5 V60Si:~

@gal PADDOCK pgt" P

~ '%ABLEOF CONTENTS

~ae 1 0 Introduction 2.4.1 Stainless Steel Piping and Tubing and Surveillance Programs 2

2.4.2 Cable Encapsulation 6.2 Procedures (Fire-related) 6.4 ality Assurance 7.5.1 Fixed Water Systems 7.5.2 Heat and Detection Systems 7.5.3 Heat and Detection Systems 10 7.6.1 Automatic Fixed Fire Water Systems 7.6.2 Automatic Fixed Fire Water Systems 13 8.0 Technical Specifications P

9.1 Fire Protection Systems Preoperational Retest Program 9.2 Program for Component and System Retests 14 15 16 ACRS Items 17 11.1 Surveillance of Encapsulated Cables 11.2 Chemical Behavior of Fire Retardent Coating on a Fire 18 20 11.3 Use of an Outside Fire Protection Review Agency 21 11.4 Results of the Retest Program 22 11.5 11.6 Results of Chooride Contamination Surveillance Program Fire Protection Procedures and Training 23 24 11.7 Special Review Group Recommendations 25 12.0 13.0 Consultants'eport Environmental 26 27

TABLE OF CONTENTS (continued 14.0 Common Defense and Security 15.0 Financial Qualification 16.0 Conclusions Appendix A Chronology Appendix B ACRS Report Appendix C ARL, Inc. Report Appendix D Comparison with SRG Report 28 29 30 A-1 B-1 C-1 D-I

1.0 Introduction The Safety Evaluation Report by the Division of Operating Reactors Supporting the Operation After the Restoration and Modification of the Browns Ferry Nuclear Plant Units 1 and 2 Following the March 22, 1975 Fire (SER) was issued on February 23, 1976.

The SER identified matters requiring additoinal submittals by the Tennessee Valley Authority (TVA) with subsequent NRC evaluation.

Since the date of the SER

issuance, there have been meetings with TVA, additional revisions to the "Plan for Evaluation, Repair and Return to Service of Browns Ferry

. Units 1 and 2 (March 22, 1975 Fire)" dated April 13, 1975 (the Plan),

and meetings with the ACRS resulting in an ACRS report dated March 11, 1976.

The purpose of this supplement is to 'update the SER based on the NRC evaluation work performed since February 23, 1976.

The section numbers of this supplement are the section numbers of the SER wherein the matter

'as identifed except for Sections 11, 12, 13, 14, 15 and 16.

Section ll discusses ACRS items which were identified for additional information or evaluation in the ACRS report dated March <<ll, 1976.

Sections 12 through 16 are new sections.

In addition, the supplement contains an updated chronology as Appendix A, the report of the Advisory Committee on Reactor Safeguards (ACRS) as Appendix B, a report by the Anal'ytical Re'search Laboratories, Inc; on combustion.

test results for Flamemastic 71A as Appendix C, and a comparison of the Browns Ferry Plant with the "Recommendations Related to Browns Ferry. Fire, Report by Special Review Group" (NUREG-0050) as Appendix D.

2.4.1 Stainless Steel Piping and Tubing and Surveillance Programs We have evaluated the additional metallographic and surface replication test results provided by TVA.

These results have confirmed our findings that TVA has conducted an adequate program of investigation of the effects of soot contamination, component cleaning, cleanliness verification, evaluation and testing.

The initial.sampling program of stainless steel piping and piping compon-ents exposed to the fire residues disclosed only one sample that had indications of stress corrosion cracking initiation.

This sample. was a

1/4 inch diameter thin wall tube.

To determine the extent of corrosion on the small instrument lines, TVA removed at least one tube sample from each of the critical instrument panels.

Six of the samples were found to have indications of the initiation phase of stress corrosion cracking.

The instances of corrosion displayed a general pattern that indicated that a major concentration of fire residue had moved from the fire area and proceeded around the west side of the drywell to a stairwell in the southwest corner of the reactor building.

All the affected panels were along the residue path to the stairwell or adjacent to the stairwell on lower elevations.

In the six panels in which corroded tubes were observed, all the instruments were retubed.

In addition, instruments'.'n three other panels adjacent to the six.affected ones were also retubed.

None of the other sampled panels were located in the path of the residue and none had signs of corrosion.

The sampling program will be continued so that a sample tube will be removed for evaluation from each of these remaining unretubed critical panels during the first refueling outage of Unit l and again during the fourth refueling outage.

This is in addition to the visual surveillance that these lines will receive.

We find TVA's instrument line sampling, testing, replacement and surveillance programs to be satisfactory.

In the SER, we stated that we were in basic agreement with TVA's surveillance program approach, but would evaluate the need for an increased scope and longer period of surveillance.

As a result of our review, the surveillance program to be set forth in the Technical Specifications has been extended through the fifth refueling outage.

At each refueling outage, prior to the fifth, penetrant examination will be performed on the stainless steel piping and components on a sampling basis in accordance with Browns Ferry Mechanical Maintenance Instruction Number 53.

During the fifth. refueling the penetrant examination will have the same scope as the examination performed to qualify the plant to return to power according to Browns Ferry Mechanical Maintenance Instruction Number 46.

Reports of

results of these examination will be submitted to NRC.

Ne conclude that this program will provide adequate assurance that any deleterious effects of residual chlorides will be detected prior to causing a safety hazard.

4 2.4.2 Encapsulation of Fire Residue in Cable Trays In Revision 38 to the Plan, TVA reported that cleaning of the fire residue from cables in cable trays was found to be impractical because the large number of cables in the tray and the short intervals between tie-down points precluded access.

In addition, the use of steam cleaning or high velocity sprays would have led to recontamination of the reactor building and possible damage to cables.

The encapsulation action of the Flamemastic coating provides an effective barrier to any transport of possible chloride residue from the tray area to other parts of the reactor building.

This is the most important consideration, since the greatest concern is the effect of chlorides on primary coolant system piping and tubing.

We have evaluated, any possible adverse effects due to residual chlorides that might remain in the cable trays.

The PVC cables themselves would be uneffected by any chlorides present.

The Flamemastic coating limits the moisture ingress thereby minimizing the possibi].ity of corrosion on the trays and supports.

Any corrosion or rusting would be inhibited by the chemical neutralizing action of the calcium carbonate content of the Flamemastic.

The electrical cables, cable trays, and supports would not be, adversely affected by the products of the neutralizing actions of the Flamemastic.

Further, all cable trays and supports will be inspected annually for five years for indication of degradation of the cable tray systems.

If degradation of the trays and supports are found, they will be replaced.

In addition, at the first and second refueling outages of Unit 1

and at approximately every three years thereafter, a cable tray on elevation 593 ft. in Unit 1 that has fire residue in the cable bundle shall have a portion of the Flamemastic cocoon opened and the cables and Flamemastic inspected for any signs of deterioration.

We conclude that encapsulation of the chloride containing residue within the cable trays by the Flamemastic coating provides reasonable assurance against any adverse affects of the residue so contained and that the surveillance of cable trays, cable tray supports, and cables will ensure that any degradation of the components will be detected and corrected, if found, prior to causing a safety hazard.

6. 2 Procedures (Fire-related)

In Section 6.2 of the SER we stated a concern regarding the development of procedures for assessing transient fire loads in critical areas of the plant and the additional fire protection requirements that may be required, if any.

Our specific concern related to taking credit for fire protection systems installed to protect critical systems or cab1.ing in the transient fire load procedure.

Ãe further stated that we would.require a continuous fire watch with charged fire hose where transient fire loads could be located in critical areas

where, due to obstructions, the installed fire protection system may not be effective for the transient fire load.

L TVA has proposed a procedure for control of transient fire loads at nuclear plants in Revision 43, Part XlI of the Plan.

The criteria set forth in these proposed guides for the procedure which are now required by the Technical Specifications remove our concern in that no credit will be taken for fixed fire water spray or sprinkler systems in regard to extinguishing capability for transient fire loads.

Another section of the procedure specifies the fire load limits and when additional fire protection methods must be provided with relation to these limits.

The procedure further requires a periodic inspection of the area for low.

loads and 'a continuous fire watch f0r medium arid high fire loads:

Our requirement as stated in the 'SER included the need for charged fire hoses in the area of the transient fire loads.

Based on our evaluation of the transient fire load procedure we find that the charged fire hose requirement is not necessary but that the hoses be laid out, if required.

The charged hose does represent a personnel safety hazard.

The valves that are used to charge the fire hose are located at the hose rack or reel and are quickly accessible by the fire watch that would be stationed in the area.

Therefore, based upon a determination by the Office of Insp'ection and Enforcement (OI5E) that TVA has established procedures that fully conform to the criteria set forth in Revision 43, Part XII of the Plan, we concluded that our concern and requirements stated in the SER have been resolved.

6. 4 Quality Assurance General The description of the quality assurance (QA) program for the Browns Ferxy Nuclear Plant, Units No.

1 5 2 for the operation phase is contained in Appendix D of the Final Safety Analysis Report (FSAR) through Amendment 62 and in the docketed J.

E. Gilleland's letter to B.

C. Rusche dated June 7, 1976.

This letter commits TVA to interpret the "shoulds" contained in the ANSI standards referenced in the QA programs as requirements and will be implemented accordingly.

Our evaluation of the QA program is based on a review of this information and discussions with Tennessee Valley Authority (TVA) personnel to determine that the QA program meets with the requirements of Appendix B to 10 CFR Part 50 and the acceptance criteria described in Section '17.2; "Quality.Assurance During the Operating Phase,"

of the Standard Review Plan.

The QA program for the restoration of the damaged facilities at the Browns Ferry Plant is described. in the Browns Ferry Recovery Plan Part XIII. This program contains additional controls especially in the areas of design, procurement, installation and inspection associated with the restoration phase beyond those in the QA program prior to March 1975.

These additional controls and requirements are contained in NASH documents 1284 "Guidance on Qality Assurance During the Operations Phase of Nuclear Power Plants,"

1309 "Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plant," and 1283 "Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants."

Ne find that this QA program is acceptable and satisfactorily addresses each of the criteria of Appendix B to 10 CFR Part 50.

Organization The Office of Power has overall responsibility for the TVA power program, and the Manager of Power who heads the Office of Power has responsibility for the implementation and effectiveness of the QA program for operations.

Figure 17,2<<1 shows the TVA organizations which directly affect the QA program for the operations phase.

Reporting 'to the Manager of Power is the QA Manager who is responsible for establishing and controlling the QA program manual, assuring its implementa-tion, measuring its effectiveness through audits, documenting and reporting deficiencies, verifying effective corrective action, developing and coordi-nating QA training programs and keeping upper management abreast of quality probl'ems.

The onsite QA coordinatoxs, reporting independent of plant super-vision, to the QA Manager, have primary responsibility for monitoring and evaluating the implementation and effectiveness of the onsite QA program.

When quality assurance problems are identified (such as through the onsite QA coordinator),

the QA Manager has the responsibility and authority to initiate the appropriate corrective action, including that necessary to stop work through appropriate managerial

action, when manufacturing, maintenance, repair, refueling, operator or modification work fails to comply with approved specifications and plans.

The primary responsibility and authoxity for reactoroperation and safety of Browns Ferry is vested in the Power Plant Superintendent.

Xnplant QA and quality control (QC) are his responsibilities.

The supervisor of the Plant QA staff is at, the same organizational level but independent from the Supervisor for Plant Operations who is directly responsible for maintenance, operations, and engineering, Both superviyors report directly to the Power Plant Superintendent.

The.QA staff supervisor gas thy responsibility for developing, planning, initiating, and directing a comprehensive QA/QC program which implements the Office of Power QA program.

He also reviews the plant procedures and instructions and signs them off prior to their use, attesting that they contain the necessary QA requirements.

Further,,

his responsibilities include developing and implementing an inspection program covering operations, maintenance,

repairs, and testing of safety-related items.

When QA problems are identified, the QA staff supervisor has the responsibility and authority to initiate corrective action, including that necessary to stop work through the Power Plant Superintendent when manufacturing, maintenance, repair, refueling, operation, or modification activities fail to comply with approved specifications and plans.

Should the plant superintendent fail to follow the recommendations of the plant QA staff supervisor, the supervisor has the authority to report directly to the Nuclear Generation Branch Chief to whom the Power Plant Superintendent reports.

We find that there are sufficient responsibilities delegated to the QA organization to assure that the QA program can be 'carried out effectively in accordance with controlled procedures without undue influence from other groups.

Quality As'surance Program The Office of Power Quality Assurance Manual, prepared and controlled by the QA Manager, sets forth. the QA policies and requirements on how each of the eighteen criteria of Appendix B to 10 CFR Part SO are to be followed by each division.

From this manual, the Division of Power Production is guided in structuring their detailed QA operating control procedures forming the basis for their Operational Quality Assurance Manual.

The Browns Ferry QA program has been upgraded to include those controls (with acceptable exceptions) described in Regulatory Guides and ANSI standards provided in NASH document.

1284 (Orange Book), "Guidance on Quality Assurance During the Operations Phase of Nuclear Power Plants,"

dated October 26, 1973; NASH document 1309 (Green Book), "Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants," dated May 10, 1974; and NASH document-1283 - Revision 1

(Gray Book), "Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants,"

dated May 24,

1974, These QA provisions are in such areas as design control, procurement control, qualifications of inspection, examination and testing personnel and controls for the installation, inspection and testing of instrumentation and electric equipment.

These additi,onal requirements and controls, which were not previously, addressed in the QA program, provide further definition on the impIementation of important elements of Appendix B to 10. CFR Part 50.

This upgraded QA program is extended to cover the installation, testing, surveillance testing and administrative controls for the fire prevention and protection program and equipment for safety related areas during the operational phase.

The Browns Ferry program provides for routine inservice and installation inspection of safety-related structures,

systems, and components in accordance with preestablished and approved procedures, instructions, or checklists which identify the operation or characteristics to be inspected and the accept/reject criteria, and also provides for documenting the inspection results.

The QA program requires that personnel performing the inspection activity be independent of the individual or group that performed the work being inspected.

The program provides for the identification of material, equipment, and parts throughout receipt, installation, operation, maintenance, modification and refueling phases which indicates their inspection, test, and operating status.

Nonconforming items are controlled under the QA program, TVA's QA Manager is responsible to establish procedures for retention and storage of the QA records.

A system of planned and documented audits, described in the FSAR, will be used by TVA to verify compliance with all aspects of the QA program and to assess its effectiveness.

The QA Manager is responsible for the audit system.

In addition, the Manager of Power requires an independent review of the Office of Power QA program to be performed every two years to evaluate its overall effectiveness and identify any weaknesses.

Conclusion'ur review of the Browns Ferry QA program description for the operations phase has verified that all applicable requirements of Appendix B to 10 CFR Part 50 are included in the QA program requirements.

Further, this review has determined that the QA organizations are structured such that they can effectively carry out their responsibilities related to qu'ality without undue influence from other groups.

Based on our detailed review and evaluation of the QA program description contained in the FSAR for Browns Ferry Nuclear Plant, Units No.

1 5 2, we conclude that:

1.

The QA organization of the TVA is provided sufficient independence from cost and schedule when opposed to safety considerations, authority 'to effectively carry out the QA pxograms, and sufficient access to management at a level necessary to perform their QA functions.

2.

The QA program description contains adequate QA requirements and controls which address each of the criteria of Appendix B to 10 CFR Part

50. in an acceptable manner.

Section 7.5.1 Fixed Wa'ter Systems The hydraulic calculational methods that TVA has used in the design of the fixed water systems in the plant are not in exact conformance with the methods set forth in the NFPA Code.

TVA's consultant questioned these methods and recommended that all calculations be performed by the NFPA code methods.

We and our consultant have made a review of TVA's calculational methods and compared them with the NFPA code methods.

One specific system which we reviewed in detail was one of the zones of the fixed deluge system being installed prior to restart.

The results of this review indicate that TVA's methods are comparable to the NFPA methods and result in an adequate design.

This is based on water flow and pressure being available to the system as used in the calculational methods.

The preoperational testing to be performed will assure that 'the flows and pressures will be available.

(See Section 9.1 of this report)

Therefore, based on our review of the calculational methods-used and comparison with NFPA code methods, we conclude that the systems designed using TVA's methods are camparable.with the NFPA code methods and 'are acceptable.

9ur concern set forth in the SER Section 7:5.1 and in Attachment 2 to the report has been resolved based on this review.

As stated in Section 6.2 of the SER, the fixed fire water system will be added to the semi-annual chemical treatment procedure, already existing for other water systems, for the control of crustacean growth in the system.

This procedure also requires complete flushing of the systems up to the closed valves in the dry pipe spray systems.

The chemical treatment and flushing will also remove build-up of other materials, such as sludge from the river water, to provide assurance that the systems are clean.

Crustacean control is important to assure that spray nozzle performance is not degraded.

TVA's experience with the control of crustacean growth in water systems at Browns Ferry has been good and therefore, by adding the fire water system to the chemical treatment procedure will provide the necessary assurance that the spray nozzles will perform as designed.

Ne have incorporated in the Technical Specifications a

surveillance requirement for the twice per year chemical treatment and system flush.

In addition, the specifications also require a yearly spray header and nozzles blockage test for detection of any degradation of the headers and nozzles flow paths.

7.5.2 5 3 Heat and Smoke Detection Systems Section 7.5.2 and 7.5.3 of the staff's SER stated that the designs for the heat detection and the smoke detection systems were acceptable for restart, pending resolution of the concern raised by TVA's fire consultant (Attachment 2 to SER) regarding the design and installation meeting NFPA Class 1 requirements.

TVA has taken the following actions to show conformance with the NFPA Class 1 requirements:

TVA has modified the electrical power supply for the detection systems such that power is available from the offsite and onsite emergency power sources.

The onsite capability exceeds NFPA Class 1 requirements.

2.

TVA has installed ad'ditional detectors to improve coverage.

3.

TVA has, demonstrated that the installation techniques which are used at Browns Ferry are superior to the NFPA Class 1 requirements.

Ne have reviewed the modifications which have been made and the installation techniques which are used by TVA.

As a result of this review we find that the designs meet the requirements for NFPA Class 1 systems and are, therefore',

acceptable.

TVA has also committed to installing additional NFPA Class 1 supervised smoke detection systems in the general plant areas.

These systems will, by definition, meet the TVA fire consultant's recommendations.

However, TVA has taken exception to providing supervised smoke detection systems in place of the existing systems and TVA also takes exception to purchasing a supervised heat detection system to replace the non-supervised system they recently obtained.

The purpose of a supervisory circuit is to continuously monitor the detector circuits to detect a break or ground fault condition which prevents the required operation of the system and to detect a failure of the main power source.

The design of the Class 1E onsite power system is such that the onsite power system annunciates the loss of offsite power as well as onsite power.

Ne conclude, therefore, that the fire detection systems have adequate power supervision and TVA has satisfied the consultant's recommendations.

Nith regard to the detection of ground faults, TVA has demonstrated that their systems will operate in spite of the existence of a single unintentional ground.

NFPA 72B specifically states that "A multiple ground condition is considered the equivalent'of a short circuit fault" and "Electrical supervision of conductors for a short circuit fault is not contemplated" by the supervisory requirements.

As a result we conclude that automatic ground supervision is not required at Browns Ferry and, therefore, the present and proposed designs are acceptable with respect to ground supervision.

-12 With respect to the lack of continuous supervision for the detection of breaks in the signal circuits, TVA has pointed out that their use of less flammable electrical insulation, larger gauge wires, wire

lugs, and conduit and the controlled access to the Browns Ferry site provide additional protection for the fire detection circuitry over that which is provided in a public building for systems which meet the minimum installation requirements of the NFPA standards.

Therefore, TVA contends that supervision is not required in the Browns Ferry fire protection system.

In considering this argument, we noted that the fire detection circuits at Browns Ferry are installed to more stringent requirements similar to reactor protection systems (which could also be exposed to open circuits) and we concluded that the fire detection circuits need not be continuously supervised for open circuits if they are subjected to periodic manual testing on the same basis as the reactor protection system (including testing after installation, modification, maintenance, or repair).

We find that the periodic testing required by the Technical Specifica-tions will ensure adequate reliability of the smoke and heat detection systems.

>> 13-Section 7.6.1 ;Automatic Fixed Fire Water Systems 6 7.6.2 In Sections 7.6.1 and 7.6.2 of the SER we took the position that TVA must use preaction valves for the automatic deluge

~

and sprinkler systems that have been tested and approved by an independent laboratory to be acceptable for their intended function.

In Revision 41 to Part X of the Plan TVA has revised the design criteria to include the criterion that all automatically actuated

. valves used in these systems will be Factory Mutual (FM) approved or Underwriters Laboratory (UL) listed.

With this revision to the design criteria for the automatic deluge and sprinkler systems, we conclude that the design criteria for these systems are acceptable.

We will review the final design of these systems prior to their installation.

14

8. 0 Technical Specifications In Section 8.0 of the SER we stated that proposed Technical Specifications for the fire protection systems had been submitted by, TVA.

We stated that these specifications were curxently being reviewed and final specifications would be developed prior to restart of Units 1 and 2.

We have been working with TVA to complete the Technical Specifications that will be issued with a license amendment to authorize restart of Units 1 and 2.

The new specifications incorporate limiting conditions for operation for (1) operability of the high pressure fire pumps and unit shutdown requirements if the system does not meet these limits, (2) minimum system pressure and flow limits, (3) minimum storage limits for C02 in the storage

tank, (4) limits for C02 system operability and unit shutdown requirements if the system does not meet these limits, (5) limits on the minimum fire detection system operability and requirements for a fire watch if the detector system limits are not met, (6) requirements for a roving fire watch during the period between restart and the first xefueling, (7) requirements Nor an annual independent fire protection and loss prevention inspection, (8) 'requirements for an.inspectiori and

'udit by an outside qualified fire consultant every three years, and (9) requirements for the minimum in-plant fire protection organization and duties to be maintained.

Surveillance requirements are also incorporated in the specifications to require periodic testing and inspection of the fire protection systems and the fire detection systems that must be performed at specified time intervals to ensure that the fire protection systems are operable.

The majority of the surveillance intervals are consistent with the NFPA code.

The other intervals were determined based on the as-built plant systems and unique requirements for the Browns Ferry Plant.

We conclude that the Fire Protection Technical Specifications will provide for fire protection operability and maintenance to assure acceptably fire protection for plant operations,

- 15 9.1 Fire Protection Systems Preoperational Retest Program In Section 9.1. of the SER we stated that TVA had provided retest outlines and criteria for those parts of the fire protection systems that have been modified or where additions were made to the original system.

We also stated that TVA would provide a total preoperational testing program.

By Revision 40 to the Plan, TVA has provided in Part XI the outline for the total preoperational program to be performed prior to restart of Units 1 and 2; We have evaluated the retest and total preoperational testing program to determine that the fire protection systems will be thoroughly tested for the total plant.

In addition, other features of the plant design that performed a fire protection function were also reviewed to assure adequate testing will be performed.

The preoperational testing will demonstrate that the systems, controls and equipment required for the fire protection of the plant will meet manufacturer's operational requirements, design objectives and applicable NFPA code testing requirements.

As a result of our evaluation, three items were noted as not being clearly set forth in the preoperational testing criteria.

These items were~discussed with TVA and we have been informed that the preoperational testing procedures

. have been modified to include them.

These items are:

1) in conducting the yard hydrant flow and residua'1 pressure tests for the main plant loop and the cooling'ower loop, the residual pressure measurements will be taken at the first hydrant upstream of the hydrant being flow tested,

2) in addition to the stated systems within the plant where Flow and pressure curves will be generated from the testing, curves will also be generated for the conditions at the top of each riser in the plant and

3) each fire hose will be tested to demonstrate flow capability. 01'as verfied that the preoperational testing procedures were modified. to include these items.

Based on our evaluation and the addition of the items described above to the testing procedures, we conclude that the retest and preoperational testing program for the fire protection features of the plant are acceptable and will form an adequate basis for future surveillance testing as required by the Technical. Specifications.

16 9.2 Program for Component and System Retests TVA has proposed a program for component and system retest which is described in Part XI of the Plan.

The program included testing of all systems and components that.'(1) sustained direct or indirect fire

damage, (2) were disrupted to comply with interim license requirements, (3) were potentially damaged by cleanup and restoration work, or (4) have received significant modifications or maintenance.

Ãe have completed our review of the tests that will be conducted prior to fuel loading and the tests that will be conducted during the initial rise to full power operation. 'e requested that TVA conduct load discharge tests of the 250V 'unit batteries prior to fuel loading and TVA has conducted such tests.

Ne now conclude that the test program proposed for

Browns Ferry Units 1 and 2 is acceptable and-is sufficiently comprehensive to provide assurance that systems and components that were disrupted or damaged by the fire will function in accordance with design requirements.

17-11.0 ACRS Items The ACRS reviewed the proposed restoration and operational testing of Browns Ferry Nuclear Plant, Units 1 and 2, at a March 4, 1976 meeting and has reported its findings to the Commission.

The ACRS report dated March 11, 1976 is attached as Appendix B.

Specific items that were identified in 'the ACRS report are addressed in the following subsections of this supplement.

- 18 11.1 Survei11ance of Encapsulated Cables The ACRS expressed a concern that the gross application of the fire retardant

coating, Flamemastic 71A, might involve long-term effects that warrant surveillance.

The cocooning of the electrical and control cables with Flamemastic 71A changes the working environment, and an arrangement for opening some portion of the cable bundles to inspect their condition periodically would seem appropriate.

We requested TVA to propose a surveillance program for periodic inspection of the coated cables.

In Revision 42 to the Plan, TVA proposed that "In response to an ACRS concern that the Flamemastic cocooning of electrical cables changes the working environment, approximately every three years during the nearest refueling outage, a nondivisional low-voltage power cable tray on Unit 1 (floor elevation 593) shall have a portion of the Flamemastic cocoon.

opened, the cables inspected, and a sample of the cable jacketing removed.

The jacket sample shall be given an ASTiif D412 physical and dimensional test for elongation and tensile strength.

The test values shall be compared to previously obtained values to determine the aging of the cable materials.

Repairs to the cable jacket shall be made with a cable jacket repair kit, and the open area shall'be recoated with Flamemastic."

TVA maintains that the jacket sample is a more sensitive indicator of insulation aging because the PVC jacketing material has a rating of 75 C and the conductor insulating material (cross linked polyethelehe) has a 90 C rating.

In order to demonstrate that the jacket sample will be valid, TVA tested a typical power cable of similar materials at 335 amperes and measured a

12 F (6.67 C) temperature difference from the conductor to the inside of the jacket.

This test current represents'he heaviest type duty that would be experienced by a continuously energized nondivisional power circuit.

This test compares favorably with a calculated average value of 3.47 C which TVA expects to experience with the divisional control and power cables which will only see periodic operation under normal circum-stances.

After discussions with the staff, TVA has agreed to an accelerated surveillance schedule in which the first sample will be made at the first refueling of Unit 1 (6 months-12 months) and the second sample taken at the next refueling outage (about 18 months-24 months).

- 19 As a result of our review, we have concluded that there should not be any perceptible increase in the aging rate of the insulation material covered by Flamemastic 71A.

We have also concluded that, even if there is a perceptible increase, the proposed test has a sufficient sensitivity to detect accelerated thermal aging, that a jacket sample is a valid indicator of insulation damage, and that the test frequency is sufficiently high to provide timely warning of any deterioration prior to causing a

safety hazard.

Therefore, we find that the resolution proposed by TVA is acceptable.

- 20 11.2 Chemical Behavior of Fire Retardant Coating in a Fire The ACRS expressed a concern that more information about the chemical behavior of the fire retardant

coating, Flamemastic 71A, in the presence of a fire would be desirable.

As a result of this concern we requested the supplier of the coating, Flamemaster Corporation, to provide us with a more detailed breakdown of the products of com-busthn of Flamemastic 71A.

In response to our request the supplier provided the results of a test performed by Analytical Research Laboratories, Inc., which were suma~zed as follows:

"Combustion tests indicate that Flamemastic 71A does not propagate flame but burns only with difficulty and is self extinguishing upon removal of the heat source.

The pyrolosis-combustion process evolves a white smoke and leaves a dense char that makes complete combustion difficult.

Chemical analysis of the products of combustion indicates carbon dioxide, water, antimony chlorides, some hydrogen chloride and tra'ces of various chlorinated and

. other organic compounds."

A description and the results of this test are set forth in Appendix C

of this report.

Based on the test results and the already known products of combustion of the coating material we find no compound that would be a significant detriment to safety related equipment.

The hydrogen chloride and it's resultant hydrochloric acid formation was taken into account in our original evaluation of the use of the coating.

The amount of chloride contamination from this source is greatly reduced compared to the chlorides that would be produced by the burning of the cable insulation ifit were not protected with Flamemastic 71A, such as occurred during the March 22, 1976 fire.

Therefore, based on this test and information already available in the literature, we conclude that the products of combustion of the coating do riot preclude the use of the coating as it is being applied to Browns Ferry Plant.

In fact, the use of the coating as applied will greatly reduce any potential fire from producing large quantities of combustion products from the electrical cabling it is protecting.

21 11.3 Use of an Outside Fire Protect@on Review Agency The ACRS expressed a concern that, "Since the TVA is self-insured in accordance with federal policy, its installations do not have the normal fire insurance surveillance used by private installations.

The TVA...should be supplemented by an outside review agency to assure a broad and unconstrained evaluation of fire protection requirements."

In response to this concern, TVA has committed, in Revision 42, Part XII of the Plan, to procure'the services.of a qualified fire protection engineering consultant or firm to conduct audits at the plant at three year intervals.

We have incorporated the audit as a limiting condition of operation requirement in the Technical Specifications and established the date for the first audit to be during the period of June-September 1977.

This audit in conjunction with the annual audit, also required by the Technical Specifications, will adequately cover the concern expressed by the ACRS.

22 11.4 Results of the Retest Program The ACRS wishes to be informed of the results of the retest program prior to startup of Units 1 and 2.

OX'ave reports on the results of the retest program completed up to the time of the June 4,

1976 ACRS meeting.

The results at this time show that 69 out of the 95 retest procedures have been completed and reviewed with no deficiencies found.

Of the 26 tests remaining to be performed, two tests are common to both Units 1 and 2, one involves Unit 2 and the remaining 23 involve Unit 1.

Upon satisfactory completion of the remaining tests, the OZZIE will inform the Office of

. Nuclear Reactor Regulation by memorandum, a copy of which wil1. be sent to the ACRS.

23-11.5 Results of Chloride Contamination Surveillance Program The ACRS wishes to be kept informed, of the results of the surveillance program for detection of any future deterioration that might be caused by chloride contamination.

We have added this surveillance program to the inservice inspection program in the Technical Specifications and copies of the reports of the results after each of the inspections will be forwarded to the ACRS.

- 24 11.6 Fire Protection Procedures and Training The ACRS letter stated that verification of the adequacy of the fire protection training programs proposed by TVA should be part of the NRC regulatory plan and that the training program should include both initial training and periodic retraining of personnel.

The Office of Inspection and Enforcement (015E) inspects the procedures and training course content of the licensee to ensure their adequacy.

A fire protection consultant was engaged by NRC to provide guidance and criteria for 015E personnel to perform this function.

He is completing his review and recommendation with respect to these subjects.

These are expected shortly and will be covered by a further safety evaluation covering the adequacy of training and procedures for return to operation of the Browns Ferry facility that will be verified by OIQE.

Such safety evaluation will form the basis for our final position with respect to these subjects.

11.7 Special Review Group Recommendations The ACRS wished to be kept informed of the specific application of the Special Review Group's recommendations as they apply to Browns Ferry.

Appendix D presents a tabulation of the comparison of Browns Ferry with the Special'eview Group's recommendations.

- 26 12.

Consultants'eports In Attachment 2 to the SER, it was stated that summary reports of the TVA and NRC consultants would be placed in the Docket File and Public Document Rooms prior to NRC authorizing return to operation.

The NRC consultant did submit a summary report.

His report's conclusion,

however, was conditioned upon the satisfactory completion of the TVA consultants'valuation and report.

lUe have not yet received a summary report by the TVA consultants; however, it is presently scheduled for submittal on June 18, 1976.

NRC and its consultant will determine that there are no unresolved items or that any that may exist are resolved prior to authorizing return to operation.

Ãe will issue a final report on this subject very shortly..

27 Environmental We have determined that the proposed amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.

Having made this determination, we have further concluded that the proposed amendment involves an action which is 'insignificant from the standpoint of environmental impact and pursuant to 10 CFR 51.5(d)(4), that an environmental statement, negative declaration, or environmental impact appraisal need not be prepared in connection with the issuance of the proposed amendment.

~

~ 14.

Common Defense and Security TVA states that the activities to be conducted would be within the jurisdiction of the United States and that all of the directors and principal officers of TVA are United States citizens.

TVA is a corporate agency of the Federal Government.

1'ind nothing in the application to suggest that TVA is owned, controlled, or dominated by an alien, a foreign corporation or a foreign government.

The activities to be conducted do not involve any restricted data, but TVA has agreed to safeguard any such data which might become involved in accordance with the requirements of 10 CFR Part 50.

TVA will obtain fuel as it is needed from sources of supply available for civilian purposes, so that no diversion of special nuclear material from military purposes is involved.

For these

reasons, and in the absence of any information to the contrary, we have found that the activities to be performed will not be inimical to the common defense and security.

29 Financiil Qualification We prepared a financial analysis for the Safety Evaluation Report (dated June 26, 1972) which concluded that the Tennessee Valley Authority (TVA) was financially qualified to operate Browns Ferry Nuclear Plant, Unit Nos. 1, 2 and 3, and to permanently shut down the facility and maintain it in a safe shutdown condition, should that become necessary.

We have recently updated the review of the financial condition of TVA and have determined that there have been no developments that would alter earlier favorable. conclusion.

The funds necessary to meet the costs noted above will be provided from operating revenues.

Recent operating results indicate significant increases in TVA's operating revenues and net income.

TVA has statutory authority, independent any regulatory body, to set its own rates with the objective that they be as low as feasible, but requiring that they be high enough to meet the total of its financial obligations, including all operating costs.

In addition, the U.S. Congress recently increased TVA',s debt ceiling authorization from $ 5 billion to

$ 15 billion.

TVA's power revenue bonds are rated "Aaa" (highest quality) by both Moody's Investors Service and Standard and Poor's.

Consequently, we reaffirm its finding that TVA is financiaLly qualified to operate the Browns Ferry. Nuclear Plant, Units Nos.

1, 2 and 3, if necessary, to permanently shut down the facility and maintain it in a safe shutdown condition.

16.

Conclusions Based on our analysis of the restoration and modifications of the Browns Ferry Nuclear Power Plant Units 1 and 2, we have determined that upon favorable resolution of the outstanding matters set forth in Sections 11.6 and 12.0, we will be able to conclude that:

(1) the application for amendment filed by Tennessee Valley Authority dated August 13,

1975, complies with the. requirements of the Atomic Energy Act of 1954, as amended (Act), and the Commission's regulations set forth in 10 CFR Chapter 1; (2) Restoration and construction of the Browns Ferry Nuclear Plant Unit 2 has been substantially completed and of Unit 1 will be substantially completed in conformity with "Plan for Evaluation, Repair and Return to Service of Browns Ferry Units 1 and 2 (March 22, 1975 Fire)" dated April 13,

1975, as revised, the provisions of the Act, and the rules and regulations of the Commission; (3) The facility will operate in conformity with the application as

amended, the provisions of the Act, and the rules and regulations of the Commission;

'.(4) There is reasonable assurance (i) that the activities authorized by '.

the operating license can be conducted without endangering the liealth and safety of the public, and (ii) that such activities will be conducted in compliance with the regulations of the Commission set, forth in 10 CFR Chapter 1; (5) The applicant is technically and financially qualified to engage in the activities authorized by this license, in accordance with the regulations of the Commission set forth in 10 CFR Chapter 1; and (6) The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public.

APPENDIX A February 19 1976 February 25, 1976 TVA letter transmitting Consultants'esponses to TVA Letter to TVA transmitting Safety Evaluation'dated February 23, 1976, regaxding our evaluation of the restoration and modifications at the Browns Ferry Nuclear Plant, Units 1 and 2

February 27; 1976 TVA letter transmitting Revision 38 to "Plan for Evaluation,

Repair, and Return to Service..."

March 2, 1976 TVA letter transmitting Standard Practice dated 1/21/76 for training Requirements for Operations Employees March 10, 1976 Letter to TVA transmitting Summary Report received from NRC's Fire Protection Consultant, Mr. Andrew J. Prior, USERDA, Alburquerque Operations Office March 17, 1976 TVA letter transmitting Revision 39 to "Plan for Evaluation,

Repair, and Return to Service..."

April 6, 1976

~ April 9, 1976 TVA letter transmitting Revision 40 to "Plan for Evaluation,

Repair, and Re'turn to Service..."

TVA letter transmitting requested amendment to licenses re removal of fuel pool gates April 16, 1976 Letter to TVA transmitting Amendment iNo.

21 to DPR-33 and Amendment No.

18 to DPR-.52 re removal of the canal.

gate and three canal blocks in order to allow safe transfer of the neutron sources from the reactor vessel.

to the fuel storage pool April 19, 1976 TVA letter transmitting Revision 41 to "Plan for Evaluation,

Repair, and Return to Service..."

April 23, 1976 TVA letter documenting verbal commitments re completion of certain items before startup of either of the fixe-affected units April 30, 1976 TVA letter regarding fuel loading for Units 1 and 2

Unit 1 - 6/ll/76, Unit 2 - 5/30/76 May. 10, 1976 TVA letter transmitting Revision 42 to "Plan for Evaluation,

Repair, and Return to Service..."

May 11, 1976 TVA letter requesting Amendment relating to MCPR and bfAPLHGR limits, LPGA modification, and supplement to proposed fire protection Technical Specifications

Appendix A May 21, 1976 TVA letter transmitting a report entitled "Browns Ferry Nuclear Plant Units 1-3, RHR Pump Protection Against Operation in Excess of Design Runout" May 28, 1976 I

June 10, 1976 TVA letter requesting Amendment to load fuel in Units 1 and 2

TVA letter transmitting Revision 43 to "Plan for Evaluation,

Repair, and Return to Service..."

June 15, 1976 TVA letter transmitting Revision 44 to "Plan for Evaluation,

Repair, and Return to Service..."

June 16, 1976

~ TVA letter transmitting Revision 45 to "Plan for Evaluation,

Repair, and Return to Service..."

June 16, 1976 TVA letter transmitting infinite multiplication factor for Unit 2 fuel June 17, 1976 TVA letter transmitting

'rotection systems Quality Assurance for fire.