ML18036B033
| ML18036B033 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/27/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18036B034 | List: |
| References | |
| NUDOCS 9210060075 | |
| Download: ML18036B033 (6) | |
Text
.".iCLOSL'Ri 0, J. 'Ike'eringve
<et~~,~ Fary Ooea&re SEP g7 g@
U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Centlemen:
In the Matter of Tennessee Valley Authority Docket No. 50-260 BROWNS FBRRX NUCLEAR PLANT (BFN) WAIVER OF COMPLIANCE FOR RESIDUAL HEAT REMOVAL SXSTEM (RHRS)
LOW PRESSURE COOLANT INJECTION (LPCI) AND CONTAINMENT COOLINC TECHNICAL SPECIFICATION (TS)
REQUIREMENTS 3.5.B.9)
REVISION l BFN Unit 2 was shutdown on September 26, 1992, at 0457 hours0.00529 days <br />0.127 hours <br />7.556217e-4 weeks <br />1.738885e-4 months <br /> to identify and repair components causing an increasing amount of unidentified leakage in the Dryvell.
Component repairs will render RHR/LPCI loop l inoperable during the effort.
In order to maintain the plant in Cold Shutdown the remaining loap needs to be aligned to Shutdown Cooling made.
The BFN TS do not explicitly recognize the manual re-alignment of the RHRS fram Shutdown Caoling to LPCI mode as acceptable for satisfying TS 3.5.B.9.
Therefore, in order to affect repairs in the safest manner
- possible, a TS waiver of camplfance is needed.
9210060075 920928 PDR ADQCK 05000259 P
V. S. Nuclear Regulatory Car...issian
$EP 27 892 During the repair activities both Core Spray loops vill be maintained
- operable, affording approximately 12,500 gal/min makeup vatcr for automatic in)ection.
The RHR loop in shutdovn, cooling vill maintain the availability to be manually realigned and i+ect in thc LPCI mode.
Plant operators are currently trained and have procedures vhich provide for realignment of the RHRS from Shutdovn Cooling to LPCI configuration.
Plant operators vill be rebriefed on the aforementioned procedures prior to utilising the requested vaiver.
Thc intent of TS 3.5.B.9 is to ensure that, at atmospheric
- pressure, at least ane supply of makeup vater is available to thc core.
Requiring tvo aperable RHR pumps and one operable Core Spray System pump, per TS 3.5.A.4, ensures this redundancy.
The safety design basis for the RHRS is. that it vill operate automatically except when, in the Shutdown Caoling
- Mode, Because of lov pressure and low temperature conditions in the Cold Shutdovn mode, sufficient time vill be available to manually align and initiate. LPCI 'to provide core cooling prior to postulated core uncovery.
Additional margin has been achieved since all Unit 2 control rods vere fully inserted at 0457 on September 26, 1992.
Thc maintenance and repair activities necessitating this request vill be needed only during the repair of components in the affected LPCI loop.
This repair activity is expected to last less than 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.
TVA is processing a farmal request for change to the TS referenced above.
The permanent change vhich is being initiated as a result of a similar vaiver of compliance vhich vas approved on February 25, 1992, vill clearly identify the need far LPCI availability and capability in Cold Shutdovn.
Pursuant to HRC guidance for.temporary vaiver of compliance, the Plant Operations Reviev Coaanittee (PORC) has revievcd and approved the vaiver request for this activity.
The requested action is vicved to have no safety significance because LPCI can bc realigned manually from the RHR Shutdovn cooling mode in an adequate time frame to ensure core cooling requirements for the Cold Shutdown condition along vith both operable Core Spray loops.
tor this reason TVA has determined that this proposed vaiver vill not involve a significant increase in,thc probability or consequences oi accident previously evaluated; or create the possibility of a nev or different kind of accident from an accident previously evaluated; ar involve a significant reduction in a margin of safety.
The Proposed Bo Significant Hatards Consideration is enclosed.
Further, this proposed change does not involve any adverse environmental consequences.
U.S. Huclear
'.atory Co;.;.,ission
$P 87 1992 TVA,.therefore, requests a verbal approval fcr a maximum 60-hour temporary vaiver of compliance for TS 3.5.B.9 commencing at the time LPCI Loop 1 becomes Inoperable and until the above repairs can be completed and the affected LPCI Loop 1 can be considered operable for automatic injection without manual realignment.
S incerely, Enclosure cc (Enclosure):
HRC Resident Inspector Brovns Ferry Huclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. Thierry M. 'Ross, Project Manager U.S. Huclear Regulatory Conmission One White Flint, Horth 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Milson, Project Chief V.S. Huclear Regulatory Commission Region II 101 Marietta Street, 5W, Suite 2900 Atlanta, Georgia 30323
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Ei~CLOSURE o os Bo za "d de The 5RC has promulgated standards in 10CFR50.92(c) for determining vhether a
proposed amendment to a facility operating license involves no significant hazards consideration.
A discussion of each of the three standards follovs for the proposed vaiver of compliance (ROC) for. Technical Specifications (TSs) 3.5.B.9:
l.
This ROC does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The probability of a previously evaluated accident is not increased because no nev accident precursors are introduced, no new operating modes are established and no significant procedure changes are,to be promulgated.
The consequences of a previausly analyzed accident are not increased because adequate core cooling vill be assured for tvo reasons:
a.
Low Pressure Coolant In)ection (LPCI) can be realigned in time to perform its function considering current (shutdown since 0457 on September 26, 1992) residual heat loads.
b.
This change does not chang,e the Core Spray availability requirements in TSs.
2.
This MOC does not create the possibility of an accident of a nev or different kind than previausly evaluated.
There have been na new plant configurations or failure modes introduced.
3.
This ROC does nat significantly reduce the margin af safety.
The time frame for respanding to a requirement for LPCI i+ection is sufficient for manual aperatar actions to provide this function so that the fuel temperature does not exceed design limits.
hdditionally, other safety limits are not potentially compromised.
o en ide The proposed ROC has been reviewed against the criteria of 10CFR51.22 for environmental consideratians.
The proposed change does not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or ccwlative occupational radiation exposures.
Thus the proposed MOC meets the criteria for categoricaL exclusion fram the requirement for an environmental impact statement.
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