ML18038B407

Submits Rev to Commitments Concerning SMART & Vertical Drop of Rv Ref Legs

ML18038B407
Person / Time
Site:	Browns Ferry
Issue date:	09/05/1995
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-84-23, NUDOCS 9509120250
Download: ML18038B407 (12)

Text

PR10RITY 1

(ACCELERATED RZDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9509120250 DOC.DATE: 95/09/05 NOTARIZED: NO DOCKET g

FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 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)

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SUBJECT:

Submits rev to commitments concerning SMART

& vertical drop of RV ref legs.

DISTRIBUTION CODE:

D030D COPIES RECEIVED:LTR I ENCL SIZE: 6 TITLE: TVA Facilities Routine Correspondence NOTES:

0 RECIPIENT ID CODE/NAME PD2-3 WILLIAMS,J.

INTERNAL: ACRS NRR/DSSA RES/DE/SSEB/SES EXTERNAL: NOAC COPIES LTTR ENCL 1

1 1

1 6

6 1

1 1

1 1

1 RECIPIENT ID CODE/NAME PD2-3-PD CEDER 1

OGC HDS3 NRC PDR COPIES LTTR ENCL 1

1 1

1 1

0 1

1 D

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL

DESK, ROOM OWFN 5D8 (415-2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 15 ENCL 14

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Tennessee Valley Authority. Post Office Box 2000. Decatur, Alabama 35609 Sept:ember 5,

1995 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 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1 AND 3 - REVISION TO COMMITMENTS CONCERNING THE SENIOR MANAGEMENT ASSESSMENT OF READINESS TEAM (SMART)

AND THE VERTICAL DROP OF REACTOR VESSEL LEVEL REFERENCE LEGS (GENERIC LETTER 84-23)

BFN is a participant in a pilot program for managing NRC commitments.

This program uses guidelines developed by the Nuclear Energy Institute (NEI) which include a uniform process for changing commitments.

The NEI guidelines provide for timely notification to the NRC when changing commitments which meet specified criteria.

Where timely notification is

required, the guidelines recommend this notification be accomplished by supplementing the docketed correspondence containing the original commitment.

Two commitments, originating from the referenced correspondence and described in the enclosure, have been evaluated for revision using the NEI Guidelines.

Results of these evaluations indicate the revision of these commitments is justified.

This letter provides the results of our evaluations and provides notification of the revision of these commitments.

9509i20250 950'F05 PDR ADOt K 05000259 P

PDR

U..S. Nuclear Regulatory Commission Page 2

September 5,

1995 There are no commitments contained in this correspondence.

If you have any questions, please contact me at (205) 729-2636.

Sine l,'/

Salas Manager of Site Licensing Enclosure cc (Enclosure):

Mr. Mark S. Lesser, Acting Branch Chief U.S. Nuclear Regulatory Commission Region II 101 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 E. V. Imbro, NRR/RSIB U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 E. J.

Leads, NRR/DRPW U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

U.S. Nuclear Regulatory Commission Page 3

September 5,

1995

References:

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TVA letter to NRC dated July 6,

1992, "Browns Ferry Nuclear Plant (BFN)

Units 1 and 3 Operational Readiness Program and Employee Concerns" TVA letter to NRC dated March 12, 1986, Final Modification Plans and Schedule, Generic Letter 84-23

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1 AND 3 REVISION TO COMMITMENTS Senior Mana ement Assessment of Readiness Team SMART Current Commitment Statement:

The SMART review will be repeated as part of the return to service of BFN Units 1 and 3.

The direction, seniority of membership, and objective of

'he SMART overview of Units 1 and 3 will remain unchanged.

Revised Commitment Statement:

The SMART review will be repeated as part of the return to service of BFN Units 1 and 3.

The direction and objective of the SMART overview of Units 1 and 3 will remain unchanged.

The SMART review for Units 1 and 3 will be performed by the Nuclear Safety Review Board (NSRB).

Source Document:

TVA letter to NRC dated July 6,

1992, "Browns Ferry Nuclear Plant (BFN)

Units 1 and 3

Operational Readiness Program and Employee Concerns" Affected Units:

1 and 3

Basis for Commitment Change:

The membership of the SMART for Unit 2 restart was detailed in the BFN Nuclear Performance Plan (NPP),

Volume 3.

As stated in the BFN NPP, the SMART for Unit 2 restart was chaired by the Vice President, Nuclear Power Production and was composed of the seven Vice Presidents,.reporting to the Senior Vice President, Nuclear Power.

In the July 6, 1992 letter addressing the Units 1 and 3 Operational Readiness

Program, TVA stated that the direction, seniority of membership,. and objective of the SMART overview would not change.

Since the, submittal of this correspondence, TVA has decided to transfer the function of the SMART from the Vice Presidents to NSRB.

Other than the membership, the direction and objective of the SMART overview of Units 1 and 3 will remain unchanged.

The composition and qualifications of the members of the NSRB are delineated by the BFN Technical Specifications.

The members of NSRB are appointed in writing by the President, TVA Nuclear and Chief Nuclear Officer.

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. Use of the NSRB will facilitate the accomplishment of the restart review by providing a forum with pre-established processes for review and meetings while still providing a senior review team that is knowledgeable and experienced for Units 1 and 3 restart.

This change in commitment to revise the membership of the SMART is not significant to the performance of the Operational Readiness program.

The review performed by NSRB will allow excellent overview for multi-unit operation and will provide appropriate recommendations for the restart of Units 1 and 3.

Therefore, the quality of review and objective of the SMART review will not be affected by this change.

Vertical Dro of Reactor Vessel Level Reference Le s'eneric Letter GL 84-23 Current Commitment Statement:

Modify the vertical drop of the reference legs inside the drywell to be no more than two feet.

This will be accomplished by bringing the reference legs outside the drywell at higher elevations utilizing a drywell ventilation penetration and an unused piping penetration.

Revised Commitment Statement:

Modify the vertical drop of the reference legs inside the drywell to be no more than two feet, five inches.

This will be accomplished by bringing the reference legs outside the drywell at higher elevations utilizing a drywell ventilation penetration and an unused piping penetration.

Source Document:

TVA letter to NRC dated March 12,

1986, Final Modification Plans and Schedule, GL 84-23 Affected Unit:

3 Basis for Commitment Change:

Neither GL 84-23 nor NRC letter to TVA dated November 18,

1986, "NUREG 0737, Item II.F.2, Inadequate Core Cooling Instrumentation (Generic Letter 84-23)," accepting the TVA proposed modification included criteria for a maximum reference leg vertical drop.

GL 84-23 requested TVA's plan and schedule for implementing improvements to reduce level indication errors caused by high drywell temperature.

One option described included reduction of the vertical drops in the drywell.

GL 84-23 was partially based on S. L. Levy, Inc. report SLI-8211 which contained analyses for typical Boiling Water Reactor (BWR) plants.

One analysis defined a two-foot maximum reference leg vertical drop for the specific BWR 4 E-2

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., plant analyzed.

The report does not prescribe a limiting criterion for maximum vertical drop generic to BWRs.

The commitment to 'the maximum two-foot vertical drop was apparently based on the information in SLX-8211.

A two-foot vertical drop cannot be attained due to the physical restraints of the existing penetration elevations.

Plant specific setpoint and scaling calculations for the associated instruments have been completed which demonstrate the acceptability of the modest increase in the reference leg vertical drop inside the drywell.

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