ML18033B151

Forwards Changes to App R Safe Shutdown Program,Per Agreement in Response to NRC Reviewer Questions Re Fire Watches

ML18033B151
Person / Time
Site:	Browns Ferry
Issue date:	01/30/1990
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9002070055
Download: ML18033B151 (8)

Text

ACCELERATED D UTION DEMONS TION SYSTEM

>4 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9002070055 DOC.DATE: 90/01/30 NOTARIZED: NO DOCKET FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 AUTH. NAME AUTHOR AFFILIATION RAY,M.J. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards changes to App R safe shutdown program.

DISTRIBUTION CODE: A006D COPIES RECEIVED LTR ENCL SIZE: D TITLE: OR/Licensing Submittal: Fire Protection NOTES:1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, 05000260 R.Pierson,B.Wilson RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LA 1 0 PD 5 5 D GEARS,G 1 1 D

INTERNAL: ACRS 3 3 NRR WERMEIL,J 1 0 NRR/DET/ECMB 9H 2 2 NRR/DST SE2 1 1 NRR/DST/SPLBSD1 1 1 NUDOCS-ABSTRACT 1 1' OC/LFMB 1 0 OGC/HDS2 0 E 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES: 5 5 D

A D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP, US TO REDUCE WASTE! CONTACT THE. DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISIRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 23

t TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 t

5N 157B Lookout Place U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 Gentlemen:

In the Matter of ) Docket No. 50-260 Tennessee Valley Authority 'I BRONNS FERRY NUCLEAR PLANT (BFN) UNIT 2 APPENDIX R SAFE SHUTDONN PROGRAM

Reference:

TVA letter to NRC dated April 14, 1989 The above referenced letter submitted the TVA-BFN Appendix R Safe Shutdown Program for NRC review and approval. In reviewing this submittal, the NRC reviewer raised some concerns pertaining to the fire watches. As a result of discussions between TVA and NRC, it was agreed that the enclosed changes be made to the program.

If you have any questions please, telephone Patrick P. Carier at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY Manager, Nuclear icensing and Regulatory Affa>rs Enclosure cc: See page 2 9002070055 900i30 PDR.

F ADOCK 0 000260 PDC

,of An Equal Opportunity Employer

U.S. Nuclear Regulatory Commission cc (Enclosure):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Nhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Hilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

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Gir29i1998 le: 39 SITE LICENSING BFN 5 729 3111 P.C5 I.'NCLOSURE APPENDIX R If the listed piece af equipment is not able to perform one of its functio>.s the compensatory measure next ta the unavailable function must be implemented. ~

If the listed piece of equi.pment is not able to perform a~n of its functions, the compensatory measures for all functions af that equipment must be implemented.

The compensatory measures are identified by letters which are defined beloi.

The listed compensatory measures may be removed when and if the required m~ d oi operation is restored ta service. In addition to restoring the mode of opt ration, the compensatory measures may be removed if an engineering analysis i: periormed, this program is changed and the Safe Shutdown Instructions are changed to Irovide an alternative shutdown path. Compensatory measure A will be documented ard tracked in accordance with PMI-15.10. Compensatory measure B will be docunented and tracked in accordance with SDSP-12.ll.

COMPENSATORY MEASURES A. Action must be taken in accordance with the referenced Technical Specifi:ation.

B. Restore the equipment function in 7 days or provide equivalent shutdowr capability by one of the following methods.

1) A temporary alteration in accordance with plant procedures that allows the equipment to perform its i.ntended function.

2) A firewatch in accordance with the site impairment program in the affected areas/zones as specified in Section III. If the affected areasjzores are listed below, the firewatch must be continuous, otherwise it may be hourly, NOTE:

Fire Zones (5, 6, and 7] or (9, 10, and 11] or [13, 14, and 15] may be covered by a single 'continuous'ire watch. This can be accomplished by the breaching of Ei.re door(s) so that any or a11 oE the rooms ((5, 6, and 7] or (9, 10, and 1'..] or 13, 14, and 15]) can be considered a single fire zone for detection purposes.

Continuous Fire Match Fire Area/Zone Unit Elevation 4 593 5, 6, 7 621 8 593 9, 10) 11 621 12 593 13,. 14, 15 621 16 spreading room 606

3) A temporary change to the SSI's whi.ch provide safe shutdown without the required function..

If equivalent shutdown capability is used, restore the equipment functi>n in 60 days 'or provide an engineering evaluation and a change to this program that provides an alternate method to perform the Appendix R function, otherwise provide PORC review and Plant Manager approval of the equi. valent shutdown capability to ensure i.ts adequacy. This review shall be conducted every 60 days until an alternate method is in place.

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81rr29rrr1998 16> 48 SITE LICENSING BFN 5 729 311 1 P.C6 ra e>a>rsr rsl 4

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APPENDIX I ~

SECTION VX - TECHNICAI BASIS This section describes the bases for the compensatory measures listed in,",ection I I I and the moni toring and tes t'.ing xequfi remen ts listed in Section V. Eacl>> system is addressed separately. However, cex'tain bases fox'ompensatory measurer are ~

generic to most al 1 the systems ~ These axe discussed below and wil1 not l e repeated for each system.

C~om ensator Meesnse A Several components and sys tems required in this program are addresse>>i by <,n exis ting Unit Technical Specif ication (TS ) ~ If the TS operability requ! rements are equiva 1 ent or more stx'i ngent than the Appendix R requ irements, th'en tl,e limiting conditions for operation provide adequate compensatory measures. Zhese TS are 1 is ted in parenthes is for each piece of equipment when app 1 1 crrble . The bases for this compensatory measure can be found in the TS and wil1 not b<

repeated here.

Com ensator rrIeasure B For tha t equipment where Technical Spec I f icat ion LCO ' do not provid>>. ade< uate measures to mee t the Appendix R analysis a separate compensatox y measure I as been es tab 1 is hed . The spec ified measure is intended to assure safe shutd<>wn c>I p rrbi 1 ty i is restored within 7 days by either rescoring the failed equipment Euncticn or by taking temporary measures to assure equivalent shutdown capab 1 i ty e:xists, i Equivalent shutdown capabi 1 i ty is defined as 1 ) providing temporary>>:quipn ent or procedures which wil1 ensure the ouc of service equipment function does nc t affect saf e shutdown capability or ) p>;oviding adequate fire watch capabi 1 I ty to ensure f ixes are prevented and/or discovered in a time frame which w!. 1 1 as sure the out of service equipment is not needed to support reactor safe shutdo>n in case oi f ix'e . Dependence on temporax'y rrreasures is acceptable for only a ] imi ted period of r.'ime ~ In ordex'o prevent the indef ini te use of temporary measx res a PORC review and Plant >rlanager approval of the adequacy oE the temporary measures is required eve ry 60 days unti 1 an alternative shutdown path is developed.

The above compensatory measures are to be taken if requi.red safe shutdown i

equipment would not be able to perform ts functi on(s ) during an App<<ndix R fire event ~ A continuous fixe watch Eor E ire area 1 6-cab le spreading room is required because of the large potential f ixe damage that could result Erom a fixe in this area. he shutdown board rooms within the reactor bui.lding (Eire areas 4 through 15 ) do not have f i re detection/suppression but are in close proximi t) to each other, and contain re latively smal l combus tible loadings ~ ThereEore,. continuous Eire watches are x equired for these areas wi th one person on each elevatic n (593 and 621 ) Eox each reactox'nit (a total of 6 Eire watch personnel) . This number of fire watch personnel i s sufficient to provide adequate f ire prevention/

detection with assux'ance that an Append:lx R f ire event can be avoi.ded and does not jeopardize p lant safe shutdown when a required safe shutdown equipment i s out of service.

Fire detection/suppression exists for or;her fire areas listed in Section IZT

( i.. e., other than f i re areas 4 through 16 ) . Thus, an houri y f ire watch it these areas would provide sufficient assuranc>> that a Eire would not occur or wculd be detected and rr>i tiga ted bef ore it px ogresses to an Appendix R f ire event ~ Ar; a result, spurious operations of 'critical equipment and serious plant degradation wi1 1 be prevented .

An alternative shutdown path is def ined as a change to this program <<nd tt e saf e

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