ML20039A491
| ML20039A491 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/24/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20039A490 | List: |
| References | |
| NUDOCS 8112170700 | |
| Download: ML20039A491 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION np WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORT LiG AMENDMENT N0.78 TO FACILITY OPERATING LICENSE N0. DPR-33 AMENDMENT NO. 74 TO FACILITY OPERATING LICENSE N0. DPR-52
' AMENDMENT N0. 47 TO FACILITY OPERATING LICENSE NO. DPR-68_
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS NOS. 1, 2 AND 3 DOCKET N05. 50-259, 50-260 AND 50-296 1.0 Introduction By letter dated March 4,1981 (TVA BFNP TS 160) and supplemented by letter dated April 29, 1981, the Tennessee Valley Authority (the licensee or TVA) requested amendments to Facility Operating License Nos. DPR-33 DPR-52 and DPR-68 for the Browns Ferry Nuclear Plant, Unit Nos.1, 2 and 3.
The proposed amendments would revise the Technical Specifications appended to the above Facility Operating Licenses to add operability requirements for fire dampers and fire doors and add surveillance requirements for fire barrier penetrations. The proposed amendments would also modify an existing license condition on the fire suppression systems in the cable spreading room to make the wording consistent with the design approved by NRC and actually installed at the Browns Ferry Nuclear Plant (BFNP).
2.0 Discussion The Technical Specifications (Section 6.2.8.j) require that an inspection and audit of the fire protection and loss prevention program at BFNP shall be performed by an outside qualified fire consultant at no greater than 3-year intervals. The audit report was issued October 2,1980. The audit report noted that two of the license conditions included in the operating licenses for Units 1 and 2--specifically, paragraphs 2.D.(1). (c) and 2.D.(1).(d)--required TVA to have installed, by the first refueling outage, a manual sprinkler system in the cable spreading room and to have changed the manual carbon dioxide system in this area to automatic actuation.
Contrary to these license requirements, the cable spreading rooms at all three Browns Ferry units are equipped with automatic water sprinkler systems and manual CO2 systems.
Subsequent to issuance of the above license conditions, the NRC staff concluded as a result of an incident at another plant that an automatic C02 system presented a serious potential problem with respect to worker safety. Most cable spreading rooms contain equipment that must be routinely 8112170700 811124' PDR ADOCK 05000259 P
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2 checked and/or maintained.
If workers in the room were generating heat or a flame, such as during welding, a CO2 system that activated automatically could asphyxiate them. We concluded that an automatic water sprinkler system, augmented by a manually controlled C02 system, would provide adequate fire suppression capability while significantly reducing the potential personnel safety problem. Accordingly, we requested TVA to install an automatic sprinkler system in each cable spreading room and to leave the manual CO2 system as is.
In their letter of April 20, 1978 (J. E. Gilleland, TVA, to G. Lear, NRR/NRC), TVA connitted to install the systems in accordance with our request. TVA's letter, however, did not specifically request amendment of the license conditions to conform with the revised arrangement, and we did not take any action to correct the discrepancy.
We did inspect the systems after the automatic sprinkler system was installed. And since the systems were installed and functioned as we requested, we concluded they were acceptable and the license conditions had been satisfied. We still conclude that the fire suppression systems as installed in the cable spreading room, namely, an automatic sprinkler and manual C07 system, provide adequate fire protection and should remain as instalTed.
One of the changes being accomplished by these amendments is to conform the license conditions for Units 1 and 2 to agree with the approved, as-installed plant configuration. The operating 2.E.(2) and 2.E.(3)previously contained similar conditions (paragraphs license for Unit 3
).
Since the license conditions were concluded to have been satisfactorily completed, these conditions were deleted when the license was changed by Amendment No. 22 to License DPR-68 issued May 4, 1979.
As a result of the outside fire protection audit noted above and the routine and special inspections conducted by the NRC's Office of Inspection and Enforcement, a number of violations and deviations were noted at BFNP in the fire protection / prevention program.
As discussed in IE Inspection Report Nos. 50-259/81-01, 50-260/81-01 and 50-296/81.:01, dated March 23, 1981, there were also conditions that were not in full conformance with National Fire Protection Association standards. The inspection found several fire doors that were either blocked open and fire doors on which the auto-matic closure mechanism was inoperative or which had improper latching hardware. There was also questions on the fire dampers installed in the fire doors to the battery rooms.
It was noted that the present Technical Specifications describe the actions to be taken if a fire stop or cable penetration is breached, including posting a fire watch. The Technical Specifications do not specify the actions to be taken if a fire door, damper or other barrier is inoperative. TVA's proposed corrective action was to revise the Technical Specifications; the proposed revisions sub-mitted by their letter of April 29, 1981 would add operational requirements on all fire tarriers, including doors and dampers, along with requirements for a fire watch if a barrier is not functional. The proposed revisions would also add surveillance requirements on all barriers to check that I
items such as automatic door closures are functioning as intended.
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3 3.0 Evaluation As discussed above, one of the proposed changes as submitted by TVA is to change conditions 2.D.(1).(c) and 2.D.(1).(d) in the operating licenses for Units 1 and 2 to reflect that the primary fire suppression system in the cable spreading rooms is the automatically actuated water spray system and that the backup system is the manually activated carbon dioxide system.
The basis for the change has been discussed above. While the proposed change as submitted by TVA is acceptable, these and the other conditions in paragraph D.(1) and D.(2) of the Unit 1 and 2 licenses are no longer apropos. The conditions in paragraph D.(1) and D.(2) were added to the Unit 1 and 2 licenses by Amendment Nos. 27 and 24 issued August 20, 1976. This paragraph enumerated the modifications and other 1
requirements we required TVA to complete as a result of our " Safety Evaluation Supporting the Operation Af ter the Restoration and Modification of the Browns Ferry Nuclear Plant, Units 1 and 2, Following the March 22,
,1975 Fire" issued July 3,1976. All of the modifications and specified actions were required to be completed by February 1978.
We have previously reviewed the modifications and trainir;g program and concluded that they were satisfactorily completed.
In the interest of keeping the licenses unencumbered with conditions that are no longer appropriate, our proposed action is to delete paragraphs 2.D.(1) and 2.D.(2) from the licenses.
We nave discussed this with the TVA staff and they agree with the proposed cction.
As discussed in Section 2.0, the proposed change to the Technical Specifications is to add additional LC0 and surveillance requirements in Section 3.ll.E to clearly enunciate that all fire barrier penetrations, including fire doors and fire dampers, must be maintained operab7e and that a fire watch must be established if a barrier is not functional.
The proposed changes were requested by us and are acceptable.
4.0 Environmental Considerations We have determined that the amendments do not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that the amendments involve an action which is insignificant from the standpoint of environmental impact and pursuant to 10 CFR 51.5(d)(4) that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of the amendments.
5.0 Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments
4 do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations, and the issuance
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of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
Dated: November 24, 1981 d
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