ML20062F954
| ML20062F954 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/16/1990 |
| From: | Wallace W TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9011280282 | |
| Download: ML20062F954 (4) | |
Text
TENNESSEE VALLEY AUTHORITY
$N 157B Iookout Place NOV 161990 Noven:ber 16, 1990 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C.
20555 centlement In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 2 - REVISED TEST SCOPE FOR THE SHUTDOWN FROM OUTSIDE THE CONTROL ROOM TEST Referencest 1.
Letter from Patrick P. Carier to NRC dated August 10, 1990,
" Power Ascension Testing Program Review and NRC Hold Poin':s."
2.
Letter from B. A. Wilson to 0. D. Kingsley dated July 6, 1990, " Browns Ferry Power Ascension Testing Program Review and NRC Hold Points."
3.
Letter from S. Black to 0. D. Kingsley, Jr. dated February 12, 1990, " Request for Information Regarding the Power Ascension Program of Browns Ferry Nuclear Plant, Unit 2."
4.
Letter from R. Cridley to NRC dated February 14, 1989 " Power Ascension Program."
l S.
Letter from M. J. Ray to NRC dated October 30, 1989, " Power Ascension Hold Points."
The purpose of this letter is to inform NRC of our decision to revise the scope of the power ascension test program and provide the bases for this decision. IVA will utilize several tests to demonstrate the ability to perform a reactor shutdown from outside the control room.
BFN will-delete the at-power test described in References 1-5, and will perform'a remote shutdown demonstration during the Integrated Cold Functional test sequence. We believe the combination of restart test system / component testing,' operator training and this Integrated Cold Functional Test meets the intent of the previous test.
The principal objectives of the shutdown from ouimide the control room test were tot 1.
Demonstrate the adequacy of the procedure for control room abandonment.
2.
Provide for operator training under realistic plant conditions.
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An Equal Opportunity Employer
- U.S. Nuclear Regulatory Consnission H0V 161990 3.
Perf4rm a check-out of the consounications and operatioss crew coordination nectssary to perform this procedure.
4.
Demoni.t-ate proper operation of the equipment required to place,the plant in shutdown cowl %g.
WA is confident these test objectives will be met by a Integrated Cold Functional Test.
This test is an integrated systems functional test performed at cold shutdown conditions after the reactor pressure vessel hydro and prior to criticality.
The remote shutdown demonstration will augment BFN's licensed and non-licensed operator training program. This training requires annual main control room abandonment procedure classroom ' *aining and in-plant walkdowns of the backup control system. This training adoresses remote shutdown utilizing both the abnormal operating instruction and the 10 CFR 50 Appendix R safe shutdown procedures.
Main control room abandonment and the initiation of residual heat removal shutdown cooling will be accomplished in accordance with the abnormal operating instruction (AOI) for main control room abandonment.
(The control room abandonment will be performed by the on-shift operating crew. A backup j
operating crew will remain in the control room during the performance of this test.) Plant conditions will allow most portions of the A01 to be performed (instruction steps such as main turbine trip and main steam relief valve operation will be simulated). The test will take advantage of the elevated post-hydro temperatures to demonstrate plant cooldovr. capability.
The performance of the AOI will fully exercise the backup control systems i
functions required to place residual heat removal shutdown cooling in service. WA has additional testing as part of the restart test program which will verify proper operation of the backup control system (control panel and emergency transfer switches).
This reotart test, which is essentially complete, verified the safe chutdown fur.ctions of unit 2 and common equipment from the remote shutdown control system.
The adequacy of the consnunications and personnel coordination required to implement the abnormal operating instruction will be fully demonstrated.
Sound-powered telephones and radio-communications will be employed in accordance with the A01.
i U.S. Nuclear Regulatory Commission H0V 10 GS0 i
An additional basis for our decision to perform this test prior to criticality resulted from several BFN staff concerns which arose during the preparation of l
the at-power test.
First, the test is not adequately described in the FSAR.
FSAR Chapter 13 lists the test as a unit 3 test (FSAR Tables 13.5-5 and 6),
and the test description contained in FSAR section 13.5 does not describe the cooldown portion of the test. Another aspect of the test which has not been j
addressed in the FSAR is the fact that the reactor core isolation cooling, low j
pressure coolant injection, automatic depressurization systems, and the drywell blowers will not per'orm their automatic accident functions following transfer to the backup control system.
Second, TVA views the scram from the backup control panel at power as an unnecessary plant transient / challenge to the safety systems. The BFN procedure for abandonment of the main control room requires that the reactor be scrammed from the main control room. This is consistent with the operation of the backup control system as described in FSAR, Chapter 7.
A final concern arose as a result of our review of the Pilgrim restart effort. Due to the low core exposure at which the test is performed, tight controls are required to prevent exceeding design cool down rates.
While the BFN design and licensing basis was developed prior to the issunnee of Regulatory Guide 1.68, this guidance has been considered by the test program. The test program described above demonotrates the plant can be maintained in a hot standby condition from outside the control room, and that the plant has the potential for being safely cooled from hot standby to cold shutdown conditions from outside the control room. Therefore, TVA believes the intent of Regulatory Guide 1.68, as clarified by Regulatory Guide 1.68.2 has been addressed to the extent allowable by the design basis.
In summary, TVA believes this test program will meet the original test objectives, satisfy the intent of the regulatory guidance, and will resolve the concerns associated with performing the test at power.
Very truly yours, TE NESSEE VALLEY AUTil0RITY
- t.
- E. G. Wallace, Manager
. Nuclear Licensing and Regulatory. Af f airs
_.u cc See page 4 l
a e
4 U.S. Nuclear Regulatory Commission NOV 161990 cc Ms. S. C. Black, Deputy Director I
Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 1
11555 Rockville Pike, 3
Rockville, Maryland 20852 I
FRC Resident Inspector Browns Ferry h aclear Plant Route 12, Box 637 i
Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Coamission Region II 101 Marietta Street, RW, Suite 2900 Jtlanta, Georgia 30323 l
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