ML18036A266

Provides NRC Requested Response to SER on TVA Tech Spec 251 & Withdraws Request for NRC Review of Amend Request Re Primary Containment Isolation Valves & App J Program

ML18036A266
Person / Time
Site:	Browns Ferry
Issue date:	06/27/1991
From:	Wallace E TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9107020212
Download: ML18036A266 (9)

Text

ACCELERATED DI TRIBUTION DEMON ATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)

ACCESSION NBR:9107020212 DOC.DATE: 91/06/27 NOTARIZED: NO DOCKET g

FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION WALLACE,E.G.

Tennessee Valley Authority RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides NRC requested response to SER on TVA tech spec 251

& withdraws request for NRC review'f amend request re primary containment isolation valves

& App J program; DISTRIBUTION CODE:

AOOID COPIES RECEIVED:LTR

[ ENCL L SIZE:

TITLE: OR Submittal:

General Distribution NOTES:

D RECIPIENT ID CODE/NAME KREBS,M.

ROSS,T.

INTERNAL: ACRS NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB8H7 NUDOCS-ABSTRACT OGC/HDS3 RES/DSIR/EIB EXTERNAL: NRC PDR COPIES LTTR ENCL 1

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1 RECIPIENT ID CODE/NAME HEBDON,F WILLIAMS,J.

NRR/DET/ECMB 7D NRR/DOEA/OTSB11 NRR/DST/SELB 7E NRR/DST/SRXB 8E OC LEMB E

01 NSIC COPXES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS:

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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P!-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISI'RIBUTION LINIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 26 ENCL

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Tennessee Vattey Authority, 1101 Martlet Street. Chattanooga, Tennessee 37402 JUNIOR tagl U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Mashington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) TECHNICAL SPECIFICATION (TS) NO. 251 WITHDRAWAL OF TS FOR UNITS 1 AND 3 AND COMMENTS ON SAFETY EVALUATION REPORT (SER)

FOR UNIT 2 PRIMARY CONTAINMENT ISOLATION VALVES AND BFN APPENDIX J PROGRAM

References:

1.

TVA letter to NRC dated August. 2, 1988, BFH Technical Specification No.

251 for Units 1, 2, and 3 Table 3.7.A Containment Isolation Valves 2.

TVA letter to NRC dated July 13, 1989, BFN Technical Specification No.

251 Supplement 1

3.

TVA letter to NRC dated September 17, 1990,

Response

to NRC Recommendat,ions Regarding Primary Containment Isolation 4.

HRC letter to TVA dated March 22, 1991, Issuance of Amendment and Compliance Review of 10 CFR 50 Appendix J, and TMI Item II.E.4.2.1-4 (TS 251)

The purpose of this letter is to provide the HRC requested response to the (SER) on TVA TS 251 and to withdraw the request for NRC review of the amendment request for Units 1 and 3.

By Reference 1,

TVA submitted TS 251 for Units 1, 2, and 3 to revise Table 3.7.A "Primary Containment Isolation Valves" to reflect changes due to plant modifications and the BFN Appendix J program.

TVA supplemented TS 251 with Reference 2.

Meetings were subsequently held between TVA and the HRC staff to discuss containment isolation configurations at BFN.

By Reference 3,

TVA responded to the NRC staff recommendations regarding primary containment isolation at BFN and made several commitments to implement recommendations.

To support the Unit 2 restart schedule, the TS change request was reviewed by NRC for Unit 2 only.

HRC approved by Reference 4

the Unit 2 TS amendment (No. 193).

9107020212 910627 PDR,,ADOCK 05000259 P

PDR

U.S. 'uclear Regulatory Commission JUN-S7 ms>

By this letter, TVA officiallywithdraws the request for HRC review of TS 251 for Units 1 and 3.

At a future date, BFN intends to remove the primary containment valve list from the TS in accordance with the guidance of Generic Letter 91-08.

The enclosure to this letter identifies discrepancies and corrections for the referenced supporting SER for the Unit 2 TS amendment.

TVA has reviewed the discrepancies discussed in the enclosure and determined that the validi'ty and conclusions of the SER are unaffected.

There are no commitments contained in this letter. If you have any questions, please telephone Patrick P. Carier at (205) 729-3566.

Very truly yours, TEHNESSEE VALLEY AUTHORITY E.

G.

1 l ace, anage Huclear censing and Regulatory Affairs Enclosure cc (Enclosure):

Ms. S.

C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One ophite Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637

Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One Mhite Flint, Horth 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Milson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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ENCLOSURE (1)

~EER

. 6:

"The Main Steam Lines and Main steam Drains have two air-operated globe valves on each, one inside and one outside of containment...they utilize an air supply to open and a spring to close..."

Correction:

Main Steam drain valves are Limitorque motor operated valves.

The drain valves are not air-operated, spring-loaded valves as described in the SER.

(2)

~SER

. 7:

"Demineralized WaterP, enetration 20, is classified as a non-essential system.

The Demineralized Water System has an inboard remote-manually operated globe valve and an outboard simple check valve."

I Correction:

The inboard isolation valve is a manual valve with no remote operation capability.

(3)

~SER

. 8:

"The Reactor Peedwater System has a downstream remote manual valve.

To provide a more positive means of isolation the staff suggested that this valve be identified in the BFN Emergency Operating Instructions (EOIs) as a valve that should be closed in some reasonable period of time.

This added focus on the importance of the valve as a containment isolation valve should improve the assurance of long term isolation.

TVA has committed to revise 2-EOI-3 to identify these valves."

Correction:

TVA's commitment in the letter dated September 17, 1990 required that 2-EOI-3 be revised to identify the valves which potentially could be used for isolation of leaks from high energy primary systems into secondary containment.

This information has been incorporated into 2-EOI-3.

This commitment was completed on February 28, 1991.

The valves in the feedwater system were evaluated as a part of this update.

The manual valves inside of containment would not be accessible for postaccident conditions and therefore are not identified as potential isolation sources in the secondary containment control section of 2-EOI-3.

The next valves in the feedwater system piping that represent a potential isolation source are the outlet valves from the high pressure feedwater heaters.

These valves are physically located in the turbine building and therefore would not represent an isolation point for high energy primary systems into secondary containment.

Based on this analysis, the valves were not identified in 2-EOI-3.

(4)

~SER

. 9:

"In response to the staff's recommendation, TCA committed by letter dated September 17, 1990 to add this globe valve (2-133-1070), to the locked valve program."

Correction:

The valve identified as 2-133-1070 should be 2-33-1070.

Page 2 of 3 ENCLOSURE (5)

~SER

. 10:

"Recirculation System, Penetrations 370 and 360, are classified as a non-essential system.

Penetrati.ons 37C and 38C have double check valve arrangements as isolation barriers, one inside and one outside containment which are Appendix J tested for leakage...The downstream remote-manual valve has been identi.fied in the EOIs as a final isolation boundary and this isolation arrangement is acceptable on the basis stated above in the Reactor Feedwater Section."

Correction:

There is no remote manual valve located downstream of penetration 37C/38C and the double check valves.

Thus, no valves were identified in the revised EOIs for the )recirculation system for such long-term isolation purposes.

(6)

~SER 10:

"Reactor Water cleanup (RW00) injection, Penetration PB, is classified as a non-essential system...It has an inboard and an outboard motor operated gate valve as containment isolati.on barriers.

These valves isolate upon a Group 1 signal.

The parameters that input i.nto the si.gnal are listed above in the Main Steam Line/Drain section.

The parameters that i.nput into the group isolation signal meet the requirements of a diverse isolation signal.

This arrangement meets the criterion set forth in GDC 55 Part 4 and is acceptable."

Correction:

These gate valves isolate on a Group 3 si.gnal, not a Group 1

signal.

(7)

~SER 11:

"fhe RC10 system also has a downstream (uemote manual) valve that would provide a more positive means of isolation...the additional valve downstream should be added to provide long-term protection.

This valve i.s presently Appendix J tested so further qualification of the valve would not be needed.

By letter dated September 17,

1990, TVA committed to include thi.s valve in the EOIs..."

Correction:

This discussion implies 2-FCV-71-39 will still be tested.

This confli.cts with page 3 of the SER which states "Delete [from Table 3.7.A] HPCI/RCIC pump discharge isolation valves (FCV-73-44 and 71-39)."

The valve was deleted from the LLRT program upon implementation of TS 251.

This valve has been identified in the revised EOIs as a potential additional isolation valve for long-term protecti.on i.n accordance with TVA's commitment.

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~V age 3 of 3 ENCLOSURE

~SER

. 12:

"The HPCZ system also has a downstream

)remote manual) valve that would provide a more positive means of isolation...the additional valve downstream should be added to provide complete protection in the long term.

This valve is presently Appendix J tested so further qualification of the valve would not be needed.

By letter dated September 17,

1990, TVA committed to include this manual valve in the EOI8..."

I Correction:

This discussion implies 2-FCV-73-44 will still be tested.

This conflicts with page 3 of the SER which states "Delete [from Table 3.7.A] HPCZ/RCIC pump discharge isolation valves (FCV-73-44 and 71-39)."

The valve was deleted from the LLRT program upon implementation of TS 251.

This valve has been identified in the revised EOZs as a potential additional isolation valve for long-term protection in accordance with TVA's commitment.

(9)

~sER

. 12:

HRHR shutdown cooling supply, penetration 12, is classified as a non-essential system.

The penetration has an inboard and an outboard motor-operated gate valve as isolation barriers.

These valves isolate upon a Group 2 signal.

The parameters that input into the group isolation signal meet the requirements of a diverse isolation signal.

This arrangement meets the criterion set forth in GDC 55 Part 4 and is acceptable."

Correction:

Although Outboard Shutdown Cooling valve (2-FCV-74-47) receives a Group 2 isolation signal, the valve is normally closed with power removed to meet the requirements of our Appendix R program.

Thus, isolation is maintained by administrative controls during power operation, not by a Group 2 isolation signal.

The inboard valve isolates upon a Group 2 isolation signal.

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