ML18033B203
| ML18033B203 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/06/1990 |
| From: | Carier P TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003140326 | |
| Download: ML18033B203 (4) | |
Text
SUBJECT:
Requests for extigent review of Tech Spec change s waiver of compliance.
DISTRIBUTION CODE:
D030D COPIES RECEIVED:LTR l
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TITLE: TVA Facilities Routine Correspohdence S
05000259 05000260 A.
05000296 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:
S. Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson A.c CELEBRATED D1 BUTION DE MONS TION SYSTEM REGULAT INFORMATION DISTRIBUTIO STEM (RIDS)
ACCESSION NBR:9003140326 DOC.DATE: 90/03/06 NOTARIZED: NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260, Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-29b Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION CARIER,P.P.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
RECIPIENT ID CODE/NAME LA ROSSiT.
INTERNAL: ACRS OC/L COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD NUDOCS-ABSTRACT OGC/HDS2 COPIES LTTR ENCL ILE 01 EXTERNAL: LPDR NSIC NRC PDR NOTES:
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TENNESSEE VALLEYAUTHORITY 5N 157B Lookout Place MAR 06 1980 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) REQUEST FOR EXIGENT REVIEW OF TECHNICAL SPECIFICATION CHANGE AND WAIVER OF COMPLIANCE
Reference:
TVA letter to NRC dated March 6, 1990, "Browns Ferry Nuclear Plant (BFN) TVA BFN Technical Specification No. 276 Standby Gas Treatment/Secondary Containment Systems BFN docketed a request for an exigent technical specification change via the referenced letter.
This letter supplies additional information to support NRC exigent review and a temporary waiver of compliance.
BFN needs to make the secondary containment inoperable to perform modifications to the Emergency Equipment Cooling Water (EECW) system.
EECW is required for operability of the Emergency Diesel Generators to supply the Standby Gas Treatment System (SGTS).
The SGTS is required to be operable whenever secondary containment is operable.
Technical Specification LCO 3.7.C.2 provides actions to be taken if secondary containment integrity cannot be maintained.
The present, technical specifications require the following actions:
1.
The reactor shutdown and reactivity margin (TS 3.3.A) met, 2.
Reactor cooled down and reactor coolant system vented, 3.
Fuel movement not permitted in the reactor zone and, 4.
Primary containment integrity maintained.
All reactors are currently shutdown, cooled down, and defueled.
No fuel movements are in progress.
BFN cannot meet item 4 (TS 3.7.C.2.d) in that the design of the plant precludes primary containment integrity being maintained during an outage because the containment head is removed and the drywell is open.
Therefore, the EECW modifications are presently having to be performed utilizing a system outage concept where a portion of the EECW system is in operation at all times to provide the necessary cooling water to the diesel generators.
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U.S. Nuclear Regulatory Commission Because of its effect on the EECW system operability, maintaining secondary containment integrity will extend the outage modification schedule approximately four weeks.
Allowing a temporary waiver of compliance of TS 3.7.C.2.d for primary containment will increase the efficiency of modifications work without degrading plant safety.
Accidents are minimized by requiring all reactors to remain shutdown and cooled down and not permitting any fuel movement in the reactor zone.
With these requirements it is unnecessary to maintain primary or secondary integrity.
The General Electric Boiling Water Standard Technical Specification (NUREG 0123) does not require primary or secondary containment integrity under these circumstances.
In addition the fuel has not been irradiated for approximately 5 years and there is no appreciable decay heat.
We request the temporary waiver of compliance until the technical specification change is approved and implemented.
If there are any questions, please telephone Joseph E. McCarthy at (205) 729-3604.
Very truly yours, TE SSEE VALLEY AUTHORITY Patrick P. Carier, Manager Site Licensing cc:
See page 3
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U.S. Nuclear Regulatory Commission
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Ms. S.
C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000