ML19347E868
| ML19347E868 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/11/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8105140095 | |
| Download: ML19347E868 (2) | |
Text
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TENNEST,EE VALLEY AUTHORITY CH AT T ANOOG A. TENNrSSEE 37401 400 Chestnut Street 'Ibwer II May 11, 1981 f.
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Mr. Harold R. Denton, Director
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Office of Nuclear Reactor Regulation
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U.S. Nuclear Regulatory Omenission N
Washington, DC 20555
Dear Mr. Denton:
In the Matter of the
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Doc'<et Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 In my letter to you dated March 18,1981, 'IVA requested an exemption for Browns Ferry Nuclear Plant frca the requirements of section III.G of 10 CFR Part 50, Appendix R, Fire Protection Rule. We wish to redify our previous request as stated in the enclosure. 'Ihe enclosure addresses our positions on each section of 10 CFR Part 50, Appendix R, which is applicable to Browns Ferry.
Very truly yours, TBNESSEE VALLEY AUTHORITY l
L. M. Mills, tanager Nuclear Regulation and Safety
~ Sworn subscr before me this /
day of 1981 Notary Public My Chamission Dcpires fdh Enclosure F
esos,4009s An Equal Opportunity Employer L_
O ENCICSURE
'IVA REQUEST EOR EXFNFTICN 'IO SQIEDULE REQUIREMENTS OF APPENDIX R 'IO 10 CFR PARP 50 (FIRE PICTIrfION PROGRAM FOR NUCLEAR FACILITIES WITl! AN OPERATING LICENSE)
BROWNS PERRY NUCLFAR PIANT nis request for an exemption to the schedule requirements of Appendix R to 10 CFR Part 50 supercedes and revises our request subnitted on March 18, 1981.
Our review of Appendix R indicates that three sections contain new requirements that are to be retroactively applied to Browns Ferry. We following discussions state our position on the three sections as applied to Browns Ferry:
1.
Section III.G - Fire Protection for Safe Shutdown Capability The modifications made during the recovery frm the March 22, 1975 fire were intended to provide protection against the loss of more than one division of safety equipnent in the event of a fire. %e modifications included physical moving of certain electrical conduits, the application of a fire resistant cable coating, and the addition of extensive fire protection systems. Rese changes and the plant's original separation criteria for Class IE circuits,. as outlined in our Final Safety Analysis Report, are consistent with the philosophy outlined in section III.G.l.
However, the design was never intended to satisfy the stringent separation criteria outlined in section III.G.2.
Wis is not to suggest that the design is inadequate, only that the level of ccenpliance with section III.G.2 is unknown. We, therefore comit to performing an analysis to determine if further modifications would be needed, in regard to separation of safe shutdown capabilitica, to comply with the requirements of section III.G.2.
10 CFR Part 50.48(c)(5) requires that TVA subnit plans and schedules for modifications dictated by section III.G.3, if such are necessary. We request an extension until June 1, 1982 to allow us time to complete the analysis; and for any necessary modifications, to prepare plans and schedules that would not be detrimental to overall plant safety. Following completion of the analysis, we would like to meet with your staff to discuss the results of our analysis and come to an agreement as to those modifications that we and the NIC staff deem necessary in order to comply with section III.G.2.
2.
Section III.J - Dnergency Lighting The mergency lighting design at Browns Ferry consists of a 250-volt dc system installed in areas needed for safe shutdown. %e system does not cover fire access or egress routes and does not have an 8-hour capacity. 'IVA therefore commits to providing self-contained lighting units which will satisfy the requirements of this section by November 19, 1981.
3.
Section III.0 - Oil collection System for Reactor Coolant Pumps Since the Browns Ferry containment has an inerted abnosphere during normal
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operation, the requirements of this section are not applicable.
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