ML18033B215

Grants Temporary Waiver of Compliance from Limiting Condition for Operation 3.7.C.2.d for Secondary Containment & Standby Gas Treatment Sys,Per Util 900306 Request

ML18033B215
Person / Time
Site:	Browns Ferry
Issue date:	03/08/1990
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
TAC-76097, NUDOCS 9003220078
Download: ML18033B215 (4)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 8, 1990 Docket Nos.

50-259, 50-260 and 50-296 Mr. Oliver D. Kingsley, Jr.

Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

TEMPORARY WAIVER OF COMPLIANCE FROM LCO 3.7.C.2.d FOR BROWNS FERRY NUCLEAR PLANT, UNIT 2 (TAC 76097)

By letter dated March 6, 1990, the Tennessee Valley Authority (TVA) requested exigent review and appr oval of certain changes to the Browns Ferry Nuclear Plant (Units 1, 2 and 3) Technical Specifications (TS) concerning the require-ments prescribed by the Limiting Condition of Operation (LCO) for Secondary Containment and Standby Gas Treatment Systems (SGTS).

In addition, TVA requested a temporary waiver of compliance from LCO 3.7.C.2. d for Unit 2 until such time as the Nuclear Regulatory Commission (NRC) staff evaluated their request.

After initial deliberation, the staff notified TVA that further information regarding their temporary waiver request was necessary.

Conse-

quently, TVA submitted another letter dated March 6, 1990 to address NRC staff inquiries.

After an evaluation of both TVA submittals the NRC staff determined that plant safety would not be unduly compromised and that denying a temporary waiver of compliance would unnecessarily delay plant startup which may not be in the best interest of the general public.

The staff notified TVA by a telephone conference call on March 8, 1990 that their request for a temporary waiver of compliance from LCO 3.7.C.2.d was granted.

Current TS require Secondary Containment to be operable at all times.

If secondary containment integrity cannot be maintained, then LCO 3.7.C.2 requires the following actions to be taken:

a.

The reactor shutdown and reactivity margin (TS 3.3.A) met, b.

Reactor cooled down and reactor coolant system vented, c.

Fuel movement not permitted in the reactor zone and, d.

Primary containment integrity maintained.

'og TVA wants to relax the secondary containment operability requirements in order to expedite performance of support modifications on the common portions of the Emergency fquipment Cooling Water (EECM) system EECM.is required for operability t

9003220078 900308 PDR ADOCIs: 05000259 P

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Me. Oliver D. Kingsley, Jr.

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.

However, TVA is unable to meet the requirements of LCO 3.7.C.2.d with the plant in its present condition during the ongoing outage (i.e. containment head removed and the drywell open).

As such, performing modifications on EECW systems are severely restrained by the TS requirements for ensuring at least one train of EECW is operable at all times.

Replacing the containment head and closing the drywell would only further delay the plant restart and is not necessary for plant safety under present conditions.

One purpose of the secondary containment and SGTSs is to mitigate any inadver-tent release of radioactive materials to the environment from a fuel handling accident.

Currently, all three units at BFN are defueled (this fuel has not been irradiated for approximately five years, 'thus;:decay,-heat~i s,","extreme'ly~~~

low).

Furthermore, LCOs 3.7.C.2.c and 3.7.C.4.a preclude any fuel handling "or movement while secondary containment integrity is not being maintained.

These TS provisions and existing plant conditions minimize the potential risks of fuel handling related accidents.

Consequently, primary and secondary containment TS operability requirements can be relaxed without adversely affecting public health and safety.

Additionally, the General Electric Boiling Water Standard TS (NUREG-0123) would not require maintaining primary or secondary containment integrity under current plant conditions.

Based upon the NRC staff's review of TVA's request, and the conclusions detailed

above, the staff grants TVA a temporary waiver of compliance from TS 3.7.C.2.d.

This waiver shall remain in effect until March 30, 1990 or the staff issues an exigent TS amendment, whichever occurs sooner.

The staff's evaluation of the proposed amendments to the BFN TS will be issued to TVA in a future letter.

Sincerely, Original signed by C. Grimes for Dennis M. Crutchfield, Associate Director for Special Projects Office of Nuclear Reactor Regulation cc:

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Document Name:

BFN WAIVER

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Mr. Oliver Q. Kingsley, Jr. CC:

General Counsel Tennessee Valley Authority 400 West Summit Hill Drive ET 11B 33H Knoxville, Tennessee 37902 Mr. F. L. Moreadith Vice President, Nuclear Engineering Tennessee Valley Authority 400 West Summit Hill Drive WT 12A 12A Knoxville, Tennessee 37902 Dr. Mark 0. Medford Vice President and Nuclear Technical Director Tennessee Valley Authority 6N 38A Lookout Place Chattanooga, Tennessee 37402-2801 Mr. Edward G. Wallace

Manager, Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 5N 157B Lookout Place Chattanooga, Tennessee 37402-2801 Mr. 0. J.

Zeringue Site Director Browns Ferry Nuclear Plant Tennessee Valley Authority P.

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Box 2000

Decatur, Alabama 35602 Mr. P. Carier Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.

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Box 2000

Decatur, Alabama 35602 Mr.

G.

Campbell Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.

Box 2000

Decatur, Alabama 35602

Chairman, Limestone County Commission P.

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Box 188

Athens, Alabama 35611 Claude Earl Fox, M.D.

State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36130 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W.

Atlanta, Georgia 30323 Mr. Danny Carpenter Senior Resident Inspector Br owns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Route 12, Box 637

Athens, Alabama 35611 Dr. Henry Myers, Science Advisor Committee on Interior and Insular Affairs U.S.

House of Representatives Washington, D.C.

20515 Tennessee Valley Authority Rockville Office 11921 Rockville Pike Suite 402 Rockville, Maryland 20852