ML18037A508
| ML18037A508 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/30/1993 |
| From: | Salas P TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TVA-BFN-TS-345, NUDOCS 9310190037 | |
| Download: ML18037A508 (23) | |
Text
ACCELERATED OCU MENT DISTRIBUTION S YSTEM REGULAT INFORMATION DISTRIBUTION'STEM (RIDE)
ACCESSION.NBR:9310190037 DOC.DATE: 93/09/30 NOTARIZED: YES DOCKET t FACIJ".50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 P 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION SALAS,P. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Request for Amend TS-345 to Licenses DPR-33,DPR-52 & DPR-68, revising security plan license conditions.
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: General Distribution NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-4 1 1 PD2-4-PD 1 1 TRIMBLE,D 2 2 WILLIAMS,J. 2 2 INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC LEDCB 1 0 OGC/HDS3 1 0 REG FILE 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 YOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMEY1'OYTROI DESV, ROOM I'1-37 (EXT. 504-2065) TO ELIMIHATEYOUR YAME PROD! D)S1'RIIIU'I'ION LISTS FOR DOCUI IENTS YOU DON'1'EED!
gy TOTAL NUMBER OF COPIES REQUIRED: LTTR ~ ENCL
I I Tennessee Valley Authority, Post Olfice Box 2000, Decatur. Alabama 36609 TVA-BFN-TS-345 10 CFR 50.90 SEP 3 0 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter Of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - TECHNICAL SPECIFICATION (TS) NO ~ TS-345 - REVISION TO SECURITY PLAN LICENSE CONDITIONS - UNITS 1( 2( AND 3 In accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90, TVA is submitting a request for an amendment (TS-345) to operating licenses DPR-33, DPR-52, and DPR-68 to revise certain license conditions (Enclosure 1). Specifically, the proposed administrative change would revise the operating licenses to delete the second paragraph of BFN Units 1( 2, and 3 license conditions 2.C.(8), 2.C,(8), and 2.C.(4),
respectively, which reads as follows:
"Notwithstanding the statement in Section 9.1 of the physical security plan, the licensee shall maintain positive access control over containment in accordance with the requirements of 10 CFR 73.55(d)(8)."
TVA also proposes to revise the Unit 3 operating license to delete existing license condition 2.C.(8), which is essentially identical to the first paragraph of license condition 2.C.(4).
] 5{3072 ifg I 9310190037 'st30'st30 PDR ADOCK 05000259 P PDR
U.S. Nuclear Regulatory Commission Page 2
~~~ ~ O l993 TVA has evaluated the proposed operating license amendment against the criteria provided by 10 CFR 50.92 and has determined that no significant hazards considerations are involved. The reason, description, and justification for the proposed change are provided in Enclosure 2. The proposed determination of no significant hazards considerations is contained in Enclosure 3. TVA requests that this change be made effective within 30 days after issuance.
If you have any (205) 729-2636.
questions,,please telephone me at Since e Pedro Salas Manager of Site Licensing Enclosures cc: See page 3 Suscribed and sworn to before me nn 'this~~ ay of enp~w 1993.
Notary Public My Commission Expires 7
U. S. Nuclear Regulatory Commission Page 3 SEP 30 1993 Enclosure cc (Enclosure):
Mr. W. D. Amdt General Electric Company 735 Broad Street Suite 804, James Building Chattanooga, Tennessee 37402 American Nuclear Insurers Town Center, Suite 300S 29 South Main Street West Hartford, Connecticut 06107-2445 Mr. Johnny Black, Chairman Limestone County Commission 310 Washington Street Athens, Alabama 35611 Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident. Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama ;35611 Mr. J. F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36194
ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1i 2i AND 3 PROPOSED OPERATING LICENSE AMENDMENT TS-345 - REVISION TO SECURITY PLAN LICENSE CONDITIONS REVISED OPERATING LICENSE PAGES
APR 01, 1993 (6) The facility may be modified by drilling bypass flow holes in Type 2 and Type 3 fuel assemblies as described in NED0-21091, "Browns Ferry Nuclear Plant, Units 1 & 2 Safety Analysis Report for Plant Modifications to Eliminate Significant In-Core Vibrations;" and NEDE-21156, "Supplemental Information for Plant Modification to Eliminate Significant In-Core Vibrations," dated January 1976.
(7) The facility may be modified as described in "Browns Ferry Nuclear Plant Units 1 and 2 Emergency Core Cooling Systems Low Pressure Coolant Injection Modifications for Performance Improvement (December 1975)" submitted by application dated December 1, 1975 and supplements dated February 12, 1976, March 24, 1976, March 30, 1976, May 21, 1976, June and July 21, 1976.
ll, 1976, (8) The licensee shall maintain in effect and fully implement all provisions of the Commission approved physical security plan including amendments made pursuant to the authority of 10 CFR 50.54(p). The approved plan, which contains information protected under 10 CFR 73.21, is entitled "Browns Ferry Nuclear Plant Physical Security Plan," dated May 15, 1982 (TVA letter dated June ll, 1982)'and revisions submitted by TVA letters dated August 31, 1982 and October 19, 1982.
(9) The facility may be modified as described in "Browns Ferry Nuclear Plant Units 1 and 2 Emergency Core Cooling Systems Low Pressure Coolant Injection Modifications For Performance Improvement (October 1977)" submitted by letter dated December 28, 1977 and supplemented by letter dated December 13, 1978.
(10) The licensee shall follow all provisions of the NRC approved Guard Training & Qualification Plan, including amendments and changes made pursuant to 10 CFR 50.54(p). The approved Guard Training & Qualification Plan is identified as "Browns Ferry Nuclear Power Station Guard Training & Qualification Plan,"
dated August 17, 1979, as revised by pages dated January 24, 1980, May 21, 1980, October 1, 1980, and March 9, 1981 and as may subsequently be revised in accordance with 10 CFR 50.54(p). The Guard Training & Qualification Plan shall be followed, in accordance with 10 CFR 73.55(b), 60 days after the date of this amendment.
BFN Unit 1
APR Ol, 1993 (8) The licensee shall maintain in effect and fully implement all provisions of the Commission approved physical security plan including amendments made pursuant to the authority of 10 CFR 50.54(p). The approved plan, which contains information protected under 10 CFR 73.21, is entitled "Browns Ferry Huclear Plant Physical Security Plan," dated May 15, 1982 (TVA letter dated June ll, 1982) and revisions submitted by TVA letters dated August 31, 1982 and October 19, 1982.
(9) The facility may be modified as described in "Browns Ferry Huclear Plant Units 1 and 2 Emergency Core Cooling Systems Low Pressure Coolant I+ection Modifications For Performance Improvement (October 1977)" submitted by letter dated December 28, 1977 and supplemented by letter dated December 13, 1978.
(10) The licensee shall follow all provisions of the HRC approved Guard Training 8c Qualification Plan, including amendments and changes made pursuant to 10 CFR 50.54(p). The approved Guard Training Sc Qualification Plan is identified as "Browns Ferry Huclear Power Station Guard Training 6c Qualification Plan,"
dated August 17, 1979, as revised by pages dated January 24, 1980, May 21, 1980, October 1, 1980, and March 9, 1981 and as may subsequently be revised in accordance with 10 CFR 50.54(p). The Guard Training & Qualification Plan shall be followed, in accordance with 10 CFR 73.55(b), 60 days after the date of this amendment.
The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Browns Ferry Physical Security Plan", with revisions submitted through May 24, 1988; "Browns Ferry Security Personnel Training and Qualification Plan", with revisions submitted through April 16, 1987; and "Browns Ferry Safeguards Contingency Plan", with revisions submitted through June 27, 1986. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.
BFH Unit 2
APR Ol, 1993 (4) The licensee shall maintain in effect and fully implement all provisions of the Commission 'approved physical security plan including amendments made pursuant to the authority of 10 CFR 50.54(p). The approved plan, which contains information protected under 10 CFR 73.21, is entitled "Browns Ferry Nuclear Plant Physical Security Plan," dated May 15, 1982 (TVA letter dated June ll, 1982) and revisions submitted by TVA letters dated August 31, 1982 and October 19, 1982.
(5) The licensee shall follow all provisions of the NRC approved Guard Training & Qualification Plan, including amendments and changes made pursuant to 10 CFR 50.54(p). The approved Guard Training &
Qualification Plan is identified as "Browns Ferry Nuclear Power Station Guard Training & Qualification Plan," dated August 17, 1979, as revised by pages dated January 24, 1980, May 21, 1980, October 1, 1980, and March 9, 1981 and as may subsequently be revised in accordance with 10 CFR 50.54(p). The Guard Training & Qualification Plan shall be followed, in accordance with 10 CFR 73.55(b), 60 days after the date of this amendment.
(6) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Browns Ferry Physical Security Plan", with revisions submitted through May 24, 1988; "Browns Ferry Security Personnel Training and Qualification Plan", with revisions submitted through April 16, 1987; and "Browns Ferry Safequards Contingency Plan", with revisions submitted through June 27, 1986.
Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.
(7) Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report. for BFN as approved in the SEs dated December 8, 1988, March 6, 1991, March 31, 1993 and Supplement dated November 3, 1989 subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
BFN Unit 3
APR 01, 1993 (8) The li.censee is authorized to temporarily store low-level radioactive waste in an existing covered pavilion that is situated outside the security fence, as presently located, but inside the site exclusion area. The total amount of low-level waste to be stored shall not exceed 1320 curies of total activity. This authorization expires two years from the effective date of this amendment and is subject to all the conditions and restrictions in TVA's application dated January 21, 1980.
D. This license is subject to the following additional conditions:
(1) The licensee is required to assure that:
(a) The plant unique analysis for torus support, structures and attached piping for the facility meets the approved Mark I Owners Group short-term acceptance criteria when subjected to dynamic loads associated with a postulated loss-of-coolant accident. Should the licensee determine that the results of the plant unique analysis are not in conformance with the approved Mark I Owners Group short-term acceptance criteria, a specific action plan will be developed by the licensee for the facility and presented to the Commission.
This action plan will include as a minimum the following information:
(1) The value of the load factor for which the criteria are satisfied.
(2) A description of proposed plant modifications or other action which will result in reduced loads or increased capacities that would satisfy the criteria.
(3) If a plant hardware modification is made, the acceptance criteria will be described on a plant unique basis.
(b) Upon completion of the Mark I Owners Group long-term program related to dynamic loads associated with a postulated loss-of-coolant accident, areas of design found not meeting the original design safety margins approved for the construction permit will be modified on a timely schedule to restore the original design safety margins.
BFN Unit 3
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1q 2i AND 3 PROPOSED OPERATING LICENSE AMENDMENT TS-345 - REVISION TO SECURITY PLAN LXCENSE CONDITIONS REASON DESCRXPTION AND JUSTIFICATION FOR THE PROPOSED CHANGE
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1q 2q AND 3 OPERATING LICENSE AMENDMENT TS-345 - PROPOSED REVISION TO SECURITY PLAN LICENSE CONDITIONS REASON DESCRIPTION AND JUSTIFICATION FOR THE PROPOSED CHANGE REASON FOR THE PROPOSED CHANGE By letter dated September 2, 1993, TVA submitted to NRC two cost beneficial licensing actions. The first cost beneficial from 10 licensing action, RLA-01, requested a temporary exemption CFR 73.55(d)(8) to permit positive access control measures without the necessity of posting a guard or watchmen during the time either BFN Unit 1 or 3 is shutdown and recovery work is being performed.
In Section III of Enclosure 1 to that letter, TVA discussed the conditions in the Units 1, 2, and 3 operating licenses which require maintenance of positive access control over containment in accordance with the requirements of 10 CFR 73.55(d)(8). These license conditions were added by NRC in 1984 when Amendments 115, 109, and 83 to BFN Units 1, 2, and 3 Operating Licenses, respectively, were approved. These conditions were added to preclude TVA from designating containment as a non-vital area during extended maintenance outages when all fuel was removed from the reactor vessel (the then-current revision of BFN's Physical Security Plan contained a statement in Section 9.1 which would have permitted designating containment as a non-vital area) .
Since these amendments to the operating licenses were approved, TVA has revised the security plan to delete the discussion in the plan which would permit designating containment as a non-vital area. Therefore, the statement in the operating licenses requiring maintenance of containment in accordance with 10 CFR 73.55(d)(8) is no longer necessary. Furthermore, is if TVA's these requested exemption from 10 CFR 73.55(d)(8) approved, license conditions could cause unnecessary confusion.
Additionally, TVA proposes to delete a duplicative license condition in the Unit 3 license.
DESCRIPTION OF THE PROPOSED CHANGE 1 ~ Unit 1 license condition 2.C.(8), Unit 2 license condition 2.C.(8), and Unit 3 license condition 2.C.(4) delete the second paragraph of the license condition which reads as follows:
"Notwithstanding the statement in Section 9.1 of the physical security plan, the licensee shall maintain positive access control over containment in accordance with the provisions of 10 CFR 73.55(d)(8)."
2 ~ Delete Unit 3 license condition 2.C.(8), which reads as follows:
"The licensee shall maintain in effect and fully implement, all provisions of the security Commission's Staff-approved physical plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
The approved security plan consists of a proprietary document titled, "Browns Ferry Nuclear Plant Physical Security Plan," which was submitted with the licensee's letter dated April 23, 1974, as supplemented by information submitted with letters dated June 27, 1974, and August 27, 1974."
- 3. Renumber existing Unit 3 license condition 2.C.(9) as 2.C.(8) .
JUSTIFICATION FOR THE PROPOSED CHANGE The proposed change is an administrative change to (1) delete a duplicative license condition and (2) delete the second paragraph in BFN Unit 1 license condition 2.C.(8), Unit 2 license condition 2.C.(8), and Unit 3 license condition 2.C.(4). The second paragraph in these license conditions was added by NRC when Amendments 115, 109, and 83 to BFN Unit 1, 2, and 3 operating licenses, respectively, were approved (NRC letter dated October 29, 1984). NRC added these license conditions to preclude TVA from designating containment as a non-vital area during refueling or major maintenance, since a section of TVA's then-current security plan for BFN would permit such an action. The NRC added the license conditions to reinforce its determination that positive access control over containment should be maintained as required by 10 CFR 73.55(d)(8).
However, since these amendments were issued, TVA has revised the BFN security plan to delete the language which would have permitted containment to be designated a non-vital area.
Therefore, this statement is no longer necessary. Deletion of the above noted statement from the licenses will not diminish TVA's recognition that it is required to maintain positive access control over containment in accordance with 10, CFR 73.55(d)(8).
Furthermore, if TVA's requested exemption from 10 CFR 73.55(d)(8) is approved, these license conditions could cause unnecessary confusion.
Unit 3 license condition 2.C.(8) is essentially identical to existing Unit 3 license condition 2.C.(4). License condition 2.C.(8) apparently should have been deleted at the time Amendments 115, 109, and 83 to the BFN Units 1, 2, and 3 operating licenses, respectively, were approved. Therefore, deleting this statement removes unnecessary duplication in the license.
Finally, as a result of deleting Unit 3 license condition 2.C.(8), the following license condition, 2.C(9), must be renumbered as 2.C.(8).
0 ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY'ROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1i 2 i AND 3 PROPOSED OPERATING LXCENSE AMENDMENT TS-345 REVISXON TO SECURITY PLAN LXCENSE CONDITIONS PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATXON
t II
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
PROPOSED UNITS ii 2g AND 3 OPERATING LICENSE AMENDMENT TS-345 - REVISION TO SECURITY PLAN LICENSE CONDITIONS PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMZNATION DESCRIPTION OF THE PROPOSED OPERATING LICENSE CHANGE 1~ Unit 1 license condition 2.C.(8), Unit, 2 license condition 2.C.(8), and Unit 3 license condition 2.C.(4) delete the second paragraph of the license condition which reads as follows:
"Notwithstanding the statement in Section 9.1 of the physical security plan, the licensee shall maintain positive access control over containment in accordance with the provisions of 10 CFR 73.55(d)(8 2 ~ Delete Unit 3 license condition 2.C.(8), which reads as follows:
"The licensee shall maintain in effect and fully implement all provisions of the Commission's Staff-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
The approved security plan consists of a proprietary document titled, "Browns Ferry Nuclear Plant Physical Security Plan," which was submitted with the licensee's letter dated April 23, 1974, as supplemented by information submitted with letters dated June 27, 1974, and August 27, 1974."
- 3. Renumber existing Unit 3 license condition 2.C.(9) as 2.C.(8) .
BASIS FOR PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATZONS DETERMINATION The NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license involves no significant hazards considerations if operation of the facility in accordance increase with the proposed amendment would not (1) in the probability or consequences involve a significant of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident
previously evaluated, or (3) involve a significant reduction in a margin of safety. The proposed TS change is judged to involve no significant hazards considerations based on the following:
1~ The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed administrative change to the operating licenses does not involve any physical alterations of plant configuration, changes to setpoints, or changes to any operating parameters. The proposed change does not increase the frequency of the precursors to design basis events or operational transients analyzed in the Browns Ferry Final Safety Analysis Report. The change does not alter the designation of BFN containment as a vital area, or alter the NRC-approved measures set forth in the BFN Physical Security Plan pertaining to the requirements of 10 CFR 73.55(d)(8).
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed administrative change to the operating licenses does not change any security requirements currently in place at BFN. The proposed change does not alter the requirement to comply with 10 CFR 73.55(d)(8). The change only deletes a duplicative license condition and removes a statement which is no longer necessary to ensure compliance with the requirements of 10 CFR 73.55(d)(8). Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3 ~ The proposed change does not involve a significant reduction in a margin of safety.
The proposed administrative change to the operating licenses does not change or reduce the effectiveness of any security/safeguards measures currently in place at BFN. The proposed change would not remove the requirement to comply with 10 CFR 73.55(d)(8). Therefore, the proposed change does not involve a significant reduction in a margin of safety.
CONCLUSION TVA has evaluated the proposed operating license change described above against the criteria given in 10 CFR 50.92(c). Based on this evaluation, TVA has determined that the proposed amendment will not. (1) involve a significant increase in the probability create or the consequences of an accident previously evaluated, (2) possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Thus, TVA has concluded that the proposed amendment does not involve a significant hazards consideration.
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