ML18036A531
| ML18036A531 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/25/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9203020243 | |
| Download: ML18036A531 (7) | |
Text
ACCELERATED DISTRIBUTION DEMONSTF&TION SYSTEM REGULATO INFORMATION DISTRIBUTION STEM (RIDS)
ACCESS%ON NBR:9203020243 DOC.DATE: 92/02/25 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 ZERINGUE,O.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000259 05000260 05000296
SUBJECT:
Requests waiver of compliance from TS 3.5.B.9 requirements for RHR sys (LPCI
& containment cooling).TS do not expicitly identify manual realignment of RHR sys from shutdown cooling to LPCI mode as acceptable during cold shutdown.
DISTRIBUTION CODE:
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TITLE: OR/Licensing Submittal:
Loss of Residual Heat Removal (RHR) GL-87-12 NOTES'ECIPIENT ID CODE/NAME SANDERS,M.
ROSS,T.
INTERNAL: ACRS NRR TRAMMELLIC NRR/DST 8E2 OGC/HDS3 RES/DSIR/EIB EXTERNAL: NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME HEBDON,F WILLIAMSiJ.
NRR BALUKJIAN,H NRR/DOEA/OTSB11
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WAS'ONTACTTHE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
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Tennessee Valley Authority, Post Office Box 2000, Decatur,'Alabama 35609 FEB g5 tggp O. J. 'Ike'eringue Vice President, Browns Ferry Operations 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 BROWS FERRY NUCLEAR PLANT (BFN) WAIVER OF COMPLIANCE FOR RESIDUAL HEAT REMOVAL SYSTEM (RHRS) (LPCI and CONTAINMENT COOLING) TECHNICAL SPECIFICATION (TS)
REQUIREMENTS 3.5.B.9 As discussed with NRC on February 24, 1992, it has been determined that the LPCI function of an RHR loop in Shutdown Cooling service should be considered operable in Cold shutdown.
The interpretation is essential to effect necessary repairs to components in the second RHR/LPCI loop while maintaining BFN Unit 2 in Cold Shutdown.
It is further necessary because the BFN TS do not explicitly identify the manual realignment of RHRS from Shutdown Cooling to LPCI mode as acceptable in Cold Shutdown for operability considerations.
Manual realignment of the RHRS for this purpose is a widely accepted practice throughout the Boiling Water Reactor (BWR) industry.
The requirements for at least two RHR pumps will be satisfied with the additional substitution of operator realignment of LPCI pump suction and verifying logic reset.
BFN Unit 2 has been shutdown to identify and repair components causing an increasing amount of unidentified leakage in the Drywell.
One component repair will render an RHR/LPCI loop inoperable during the effort.
To minimize further leakage to the Drywell, to provide maximum personnel
- safety, and to continue removal of residual heat this effort should proceed as expeditiously as reasonable.
Plant operators are currently trained and have procedures which provide for realignment of the RHRS from Shutdown Cooling to LPCI configuration.
Additional training and procedures have been provided to ensure such actions will take place upon the need for LPCI injection.
020035 ttl2030 05000259 4,g ci20225 PDR ADOCK, p p
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U. S. Nuclear Regulatory Commission FEB 26 lssz The intent of TS 3.5.8.9 is to ensure that, at atmospheiic
- pressure, at least one supply of makeup water is available to the core.
Requiring two operable RHR pumps and one operable Core Spray System
- pump, per TS 3.5.A.4, ensures this redundancy.
The safety design basis for the RIIRS is that it will operate automatically except when in the Shutdown Cooling Mode.
Because of low pressure and low temperature conditions in the Cold Shutdown mode, sufficient time will be available to manually align and initiate LPCI to provide core cooling prior to postulated core uncovery.
Additional margin has been achieved since Unit 2 has been in Shutdown since 0025 February 23, 1992.
The maintenance and repair activities necessitating this request will be needed only during the repair of components in the affected LPCI loop.
This repair activity is expected to last less than 10 days.
Subsequent to this request, TVA will submit a formal request for change to the TS referenced above.
This proposed change will clearly identify the need for LPCI availability and capability in Cold Shutdown.
The requested action is viewed to have no safety significance because LPCI can be realigned manually from the RllR Shutdown cooling mode in an adequate time frame to ensure core cooling requirements for the Cold Shutdown condition.
For this reason TVA has determined that this proposed waiver will not involve a significant increase in the probability or consequences of accident previously evaluated; or create the possibility of a new or different kind of accident from an accident previously evaluated; or involve a significant reduction in a margin of safety.
TVA, therefore, requests a verbal approval for a 10-day temporary waiver of compliance for TS 3.5.B.9 until the above repairs can be completed and the affected LPCI loop can be considered operable for automatic injection without manual realignment.
Sincerely,
- 0. J. Zering cc:
See page 3
U.S. Nuclear Regulatory Commission FEB 35
~ggg NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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