ML18033A771
| ML18033A771 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/23/1989 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906010178 | |
| Download: ML18033A771 (9) | |
Text
A.C CE1Z P>TED Dl BUZION DEMONSTATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8906010178 DOC.DATE: 89/05/23 NOTARIZED: NO FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION RAY,M.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Requests temporary exemption from 10CFR50.71(e) for annual update of UFSAR.
DISTRIBUTION CODE: A053D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal:
Updated FSAR (50.71) and Amendments NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black R.Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson 1 Copy each to:
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05000259 05000260 05000296 05000259l 05000260~
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RECIPIENT ID CODE/NAME SIMMS,M GEARS,G INTERNAL: ACRS NRg/9)E ADS 7E 01 EXTERNAL: IRM/DISS/DCB NRC PDR SAIC LINER,R NOTES C COPIES LTTR ENCL 1
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2 1
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5 RECIPIENT ID CODE/NAME PD, AEOD/DOA/IRB NUDOCS-ABSTRACT RGN2 LPDR NSIC COPIES LTTR ENCL 1
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TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 17
TENNESSEE VALLEYAUTHORITY CHATTANOOGA, TENNESSEE 3740'I 5N 157B Lookout Place MAYIS $ 89 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROHNS FERRY NUCLEAR PLANT (BFN) UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR)
REQUEST FOR TEMPORARY EXEMPTION FROM 10 CFR 50.71(e)
In accordance with the requirements of 10 CFR 50.12 this letter is to request a temporary exemption from the requirements of 10 CFR 50.71(e) for an annual update of the BFN UFSAR.
This temporary exemption would permit TVA to withhold the annual UFSAR update due on July 22, 1989 while implementing a
verification program for unit 2 of the UFSAR which would be included in the July 22, 1990 annual update.
The verification program goes beyond the scope of a normal 1'0 CFR 50.71(e)'nnual update and is aimed at assuring unit 2 of the UFSAR is consistent with plant configuration and supporting documentation.
Enclosure 1 provides a more detailed description of the temporary exemption request and supporting
)ustification.
Enclosure 2 contains a summary of the commitments made in this submittal.
Please refer any questions regarding this submittal to Patrick P. Carier,
- Manager, BFN Site Licensing, (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosures cc:
See page 2
Man ger, Nucle r Licensing and Regulatory Affairs 35'06020i78 85'0523 PDR ADOCQ 05000255' PD An Equal Opportunity Employer
U.S. Nuclear Regulatory Commission cc (Enclosures):
Ms. S.
C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Hhite Flint, North 11555 Rockville Pike Rockvi lie, Maryland 20852 Mr. B. A. Nllson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street",
NN, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000
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Enclosure 1
Updated Final Safety Analysis Report (UFSAR) Temporary Exemption from 10 CFR 50.71(e)
TVA is requesting a
12 month exemption from the requirements of 10 CFR 50.71(e).
The next annual update for the BFN UFSAR will be July 22, 1990.
This exemption will allow TVA to complete a
UFSAR verification or baselining program similar to the program recently completed for the Sequoyah Nuclear Plant UFSAR.
TVA has determined that the verification should be conducted in parallel with the update process.
~Back round Deficiencies regarding the accuracy of the BFN UFSAR was identified by TVA through our Employee Concerns
- Program, and corrective action to
- address this problem is now being tracked through the Conditions Adverse
.-'o Quality Program.
The corrective actions include establishing improved controls for maintaining an accurate UFSAR and performance of a program to review relevant documentation to update and verify the UFSAR.
TVA has implemented a
new UFSAR update program that provides a corporate standard and site procedures necessary to interface updating the UFSAR with the responsible organizations.
These procedures provide guidance for the lead and support organizations as to their responsibilities, what to include in an update, and how a UFSAR change is submitted.
The verification program will include documentation for future reference of what was included in the review as well as deficiencies which were identified.
This program will also provide the basis on which future updates will be prepared.
The UFSAR verification will-utilize the output of the Design Baseline Verification Program (DBVP) and ensure the UFSAR is consistent with:
Latest as-configured drawings Latest fuel load analysis Past licensing submittals including "AEC Questions and Responses"
- Existing Technical Specifications Current administrative and operational programs Past design changes Justification for Exem tion The provisions of 10 CFR 50.12 have been reviewed and TVA's exemption request'eets the circumstances described in Sections (a)(2)(iv) and (a)(2)(v) as follows:
"The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the extension."
The proposed exemption affects only the required date for updating the UFSAR and does not affect the public health and safety.
As described below, appropriate compensatory measures will be taken in the interim to safely compensate the UFSAR function.
The filing date extension will allow TVA to concentrate engineering resources on unit 2 restart activities and then complete the UFSAR verification project.
The UFSAR verification project goes beyond the requirements of 10 CFR 50.71(e) in regard to what must be included in the annual UFSAR revisions.
It includes a detailed technical review of the entire UFSAR and wi 11 result
- in a better defined and more comprehensive licensing basis, which will
'- enhance the effectiveness of the UFSAR in support of safety-related activities.
No decrease in safety is expected and a benefit to the health and safety of the public through a more complete licensing basis in the conduct of safety-related activities will be realized.
"The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation."
TVA has updated the BFN UFSAR annually for the past si'x years.
Currently there are many modifications in progress to be implemented for restart of unit 2.
An'pdate at this time would not reflect the plant configuration relative to what will be accomplished for restart.
The extension would facilitate the incorporation of these modifications and more accurately reflect the existing design.
Also as part of the restart activities, TVA has performed an extensive design basis study at BFN.
The results of this study provide required information for updating the UFSAR.
The proposed exemption will allow sufficient time for the results of this study to be reflected in the next UFSAR amendment.
Presently TVA's engineering and technical support personnel necessary for providing inputs to the UFSAR are heavily engaged in restart activities and the current schedule for the annual update of July 22, 1989 would not include all UFSAR changes resulting from these activities.
TVA has determined that the BFN UFSAR verification should be conducted in parallel with the update process and is requesting a temporary exemption from the requirements of 10 CFR 50.71(e) for the limited time period between July 22, 1989 and July 22, 1990.
TVA will submit the combined update/verification as Amendment 7 to the BFN UFSAR on or before July 22, 1990.
Com ensator Measures.
A new corporate level standard (STD-6.1.3) has been written which covers 10 CFR 50.59 evaluations.
This standard was made effective March 31, 1989 and requires that a 50.59 library be made available to users of the UFSAR.
These libraries are provided for research during screening reviews and safety evaluations.
In addition to the 50.59 libraries there is a
program in place that requires all Engineering Change Notices (ECN),
and Design Change Notices (DCN) that affect the UFSAR to be distributed to Site Licensing.
This file has changes received by Site Licensing since the last update.
By maintaining the 50.59 library and a file on UFSAR changes it is possible to research the latest information concerning any part of the UFSAR in the performance of 10 CFR 50.59 evaluations.
Guidance has been provided to 50.59 preparers as to the USFAR's appropriate usage.
Engineering and plant procedures for safety evaluations have been revised to include instructions to not rely entirely on the UFSAR as the design basis.
Operations personnel are provided up-to-date plant configuration drawings and these are utilized in the control room as source material.
Additionally, any commitments made.to'evise the UFSAR in the amendment due July 22, 1989 will be revised to reflect a due date of July 22, 1990.
Conclusion Based on this evaluation of the criteria of 10 CFR 50.12 TVA requests NRC to grant a temporary exemption for BFN from the requirements of annually updating the UFSAR as set forth in 10 CFR 50.71(e).
This temporary exemption is being requested for a limited time period and will not pose an undue risk to the health and safety of the public.
This exemption would allow TVA to concentrate its efforts on restart and then complete the verification/update effort by July 22, 1990.
Enclosure 2
Commitment Summary Updated Final Safety Analysis Report (UFSAR) Temporary Exemption From 10 CFR 50.71(e) 1.
TVA will submit the combined update/verification as Amendment 7 to the BFN UFSAR on or before July 22, 1990.