ML19347D496
| ML19347D496 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/18/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8103260239 | |
| Download: ML19347D496 (2) | |
Text
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7 TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tower II March 18, 1981 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
In the Matter of the
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Docket Nos. 50-259 Tennessee Valley Authority
)
50-260 50-296 In response to D. G. Eisenhut's letters dated November 24, 1980, and February 20, 1981, to All Power Reactor Licensees With Plants Licensed Prior to January 1, 1979, regarding the fire protection rule, enclosed is TVA's request for an exemption to the requirements listed in Appendix R to 10 CFR Part 50. This exemption request complies with the guidelines set forth in paragraph 50.48 of 10 CFR Part 50.
Therefore, we urgently request a response to our exemption request.
Very truly yours, TENNESSEE VALLEY AUTHORITY lOM
/
Lf M. Mills, Manager Nuclear Regulation and Safety Subscribedandsw3rgto before me this IX day of 981.
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ENCLOSURE TVA REQUEST F07 EXE!'PTIO'! TO APPF.NDIX R OF 10 CFR PART 30 (FIRE PROTECTION PFCORA" FOR ??UCLEAR FACILTTIES OPERATI'TO PRIOR TO JA'UARY 1, 167c)
BROWS FERRY "UCLEAR PLANT Our reviev of Title 10, Code of Federal Reculations, Part 50, Appendix R.
Fire Protection Rule indicates three sections contain naw requirements that are to be retreactively applied to plants of Brovn? Ferry's vintage which have NRC approved fire protection programs.
~he follouine discussions state our position on the three sections as they appiv to Browns Ferry:
1.
Section III.G - Fire Protection for Safe Shutdown Caoability During the recovery from the March 22, In75 flee, numarous nodifications were made relative to the isspa of saparation of circuits in redundant divisions.
The modifications included physical moving of certain conduits, the application of a fire rasistant cable coating, and the addition of extensive fire protection systems. These changes coupled with tha plant's originni sepa-ation criteria for class IE circuits as outlined in our Final Safety Analysis Report led the URC staff to conclude in their Safety Evaluation Report on the Plan for Evaluation, Repair, and Return to Service of Browns Ferry Units 1 and 2 as a Result Of the March 22, 1975 Fire (Recovery Plan) that our approach "provides sufficient protection against loss of more than one division of safety equipment-in the event of a postulated fire."
TVA believes that these approved features provide an adequate level of fire safety and that further nodifications to satisfy Section III.G requirements would not sienificantly enhance the Browns Ferry design.
We therefore request an exenption from the requirements of this section.
2.
Section III.J
.Ecertency Lichting The emergency lighting design at Browns Ferry consists of a 250 volt de system installed in. areas needed for safe shutdown.
The systen does not cover all fire access or e.eress routes and does not have an 8-hour capacity. TVA therefore commits to providing self-contained lighting units which will satisfy the requirements of this section.
3 Section III.o - 011 Collection systen for Reactor Contant Punos Since the Brouns Ferry containnent has an inerted atmosohere during normal operation, the requirements of'this section ara not applice51e.
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