ML20125C848
| ML20125C848 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/02/1992 |
| From: | Hebdon F Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9212140106 | |
| Download: ML20125C848 (13) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION o
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December 2, 1992 Docket Nos. 50-259, 50-260, and 50-296 LICENSEE: Tennessee Valley Authority FACILITY:
Browns Ferry Nuclear Plant, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF A MEETING WITH THE LICENSEE REGARDING COMBINED ZONE SECONDARY CONTAINMENT On September 29, 1992, representatives of the Tennessee Valley Authority (TVA) met with the NRC staff in Rockville, Maryland, to discuss their plans for changing the way in which they had been complying with the Technical Specifications (TS) operability and surveillance requirements (i.e., TS 3.7.C) for secondary containment integrity at the Browns Ferry Nuclear Plant (BFN).
Meeting attendees are listed in Enclosure 1.
A copy of TVA's presentation handouts is provided as Enclosure 2 which includes TVA's responses to prior staff questions.
Historically, NA considered the BFN secondary containment volume to be segregated into four distinct zones - Unit 1 Reactor Zone, Unit 2 Reactor i
Zene, Unit 3 Reacter Zone, and Refueling Zone.
Each zone was assigned a portion of the total Standby Gas Treatment System (SGTS) flowrate (i.e.,
secondary containment inleakage) that would still allow the system to draw down and maintain the secondary containment at -0.25 inch of pressure.
However, due to scheduler constraints on Unit 3, TVA notified the staff that it intended to combine the allowed inleakage of 2.11 zones into one aggregate sum that would be representative of the secondary containment at large. This would, in effect, provide TVA with the flexibility to breach the walls of the Unit 3 Reactor Zone up to 189 square inches and still maintain secondary containment integrity. TVA intended to use this allowed breach margin to expedite modifications of secondary containment penetrations inta the Unit 3 Reactor Zone while Unit 2 was still operating.
During the meeting, the staff expressed a number of reservations regarding TVA's proposed " combined zone secondary containment configuration." The staff was particularly concerned about TVA's ability to comply with the TS surveillance requirement for secondary containment (i.e., TS 4.7.C).
The staff was not at all certain that the previous surveillance test for confirming secondary containment integrity would be relevant for the combined zone configuration.
Further complicating this concern were the difficulties associated with conducting this kind of surveillance during plant operation.
In all likelihood, such testing would cause a reactor scram.
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At the conclusion of the meeting, the' staff indicated that it would need additional time to further review TVA's proposed secondary containment' configuration change, and to examine TVA's calculations for assigning allowable breach margin, including procedures for controlling breaches in secondary containment.
It should be noted that shortly atter this meeting, Region II conducted a special inspec~. ion (see Inspection Report 50-259, 50-260, and 50-296/92-36 dated October 29,1992) of TVA's proposed configuration change of secondary containment and TVA's method for determining total allowable breach margin.
Region 11 concluded that TVA's proposed configuration changes and breach margin methodology were acceptable.
Fre[er1N"). Nel"8ok,bhroject Director rI Project Directorate 11-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosures:
- 1. Attendees
- 2. Agenda cc w/ enclosures:
See next page Dittribution Docket File NRC & Local PDRs BFN Rdg. File T. Murley/F. Miraglia 12-G-18 J. Partlow 12-G-18 S. Varga 14-E-4 G. Lainas 14-H-3 F. Hebdon T. Ross J. Williams M. Sanders 0GC 15-B-18 E. Jordan MNBB-3302 J. Hayes 10-D-4 B. L'il son RII P. Aeliogg RII C. Patterson RII E. Christnot RII ACRS(10)
L. Plisco 12-G-18 E. Herschoff RII 0FC PDII-4/LA PDII-4/PM PDII-4/P U PDIl-4/D NAME MSandersAhl TRoss:aNL JWilliamh Fi$ don DATE 12/l /92 12/*/92 12/ vf 92 12/ L/92
?C Browns Ferry Nuclear Plant cc:
Mr. John B. Waters, Chairman State Health Officer Tennessee Valley Authority Alabama Dept. of Public Health ET 12A 434 Monroe Street 400 West Summit Hill Drive Montgomery, Alabama 36130-1701 Knoxville, Tennessee 37902 Mr. J. R. Bynum, V1:e President Regional Administrator Nuclear Operations U.S.N.R.C. Region II 3B Lookout Place 101 Marietta Street, N.W.
1101 Market Street Suite 2900 Chattanooga, Tennessee 37402-2801 Atlanta, Georgia 30323 Mr. Charles Patterson Site Licensing Manager Senior Resident Inspector Browns Ferry Nuclear Plant Browns Ferry Nuclear Plant Tennessee Valley Authority U.S.N.R.C.
P.O. Box 2000-Route 12, Box 637 Decatur, Alabama 35602 Athens, Alabama 35611 Mr. O. J. Zeringue, Vice President Site Quality Manager Browns Ferry Nuclear Plant Browns Ferry Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority P.O. Box 2000 P. O. Box 2000 Decatur, Alabama 35602 Decatur, Alabama 35602 Dr. Mark 0. Medford,- Vice President Mr. M. J. Burzynski, Manager Nuclear Licensing and Regulatory Affairs eea[9
- e. Licensing & Fuels s
99 5B Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Chattanooga, Tennessee 37402-2801 TVA Representative Tennessee Valley Authorit,y 11921 Rockville Pike Suite 402 Rockville, Maryland 20852 General Counsel Tennessee Valley Authority ET 11H 400 West Sumit Hill Drive Knoxville, Tennessee 37902 Chairman, Limestone County Comission P.O. Box 188 Athens, Alabama 35611 1
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DISTRIBUTION Docket or Central File NRC & Local PDRS BFN Rdg. File T. Murley/F. Miraglia 12-G-18 J. Partlow.
12-G-18 F. Hebdon T. Ross-J. Williams OGC 15-B-18 E. Jordan MNBB-3701 W. Beckner 10-E-4 R. Hernan 14-C-7 ACRS(10)
L. Plisco 17-G-21
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E. Herschoff RII D. Wheeler 12-D-22 J. Flack NLS-324 E. Rodrick NLS324 J. Schiffgens 10-E-4
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HN Enclosure'1 I
g ATTENDEES
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- BRDWNS FERRY EXPANDED-INDIVIDUAL PLANT > EXAMINATION MEETING OCTOBER'I5. 1992 Hamg Oroanization
-Thierry Rossi NRR/PDII-4 William Beckner-
- NRR/SPSB John Schiffgens-
' NRR/SPSB Ron Hernan.
NRR/PDI-4" Paul,Kellogg Region II-(Phone conferee).
- Duke Wheeler RES/SAIB John Flack RES/SAIB' Ed Rodrick RES/SAIB
- Greg Pierce TVA/BFN: Licensing-.
Mike Hellums TVA/ Corporate Licensing-Henry' Jones
- TVA/BFN. Engineering Richard McMahon TVA/ Corporate.PRA 1
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ENCLOS1JRE 2 AGENDA'FOR TVA/NRC-MEETING
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OCTOBER-15, 1992 e
EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS-FERRY
. TOPIC SPOKESMAN-BACKGROUND G. D.-PIERCE NRC COMMENTS (NRC's 7/22/92 LETTER)
H. L. JONES:
RESPONSE TO NRC COMMENTS H. L. JONES-CONCLUSION G. D. PIERCE i
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TVA/NRC.NEETING OCTOBER-15, 1992 EXPANDED-INDIVIDUAL PLANT EXAMINATIONS FOR. BROWNS FERRY-TOPIC SPOKESMAN BACKGROUND G.- D. PIERCE I
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OCTOBER 15, 1992 EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS FERRY l
SPOKESMAN TOPIC H. L. JONES NRC COMMENTS (NRC's 7/22/92 LETTER)
UNITS 1 AND 3 SUFFICIENTLY SIMILAR TO UNIT 2 SUCH THAT UNIT 2 IPE IS APPLICABLE TO UNITS 1 AND 3 SIGNIFICANT VULNERABILITIES ENVELOPED BY THE ANALYSIS OF THE TEN SHARED SYSTEMS SYSTEMATIC EVALUATION OF SHARED SYSTEMS AND BASIS FOR ELIMINATION ANALYSIS LIMITED TO TWO INITIATING EVENTS BASIS FOR ELIMINATING ANY INITIATORS EFFECT OF SHUT DOWN UNITS ON OPERATING UNITS 3
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TVA/NRC MEETING OCTOBER 15, 1992 EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS FERRY TOPIC SPOKESMAN H. L. JONES RESPONSE TO NRC COMMENTS COMMENT:
UNITS 1 AND 3 SUFFICIENTLY SIMILAR TO UNIT 2 SUCH THAT UNIT 2 IPE IS APPLICABLE TO UNITS 1 AND 3 l
ALL THREE UNITS HAVE A HIGH DEGREE OF
RESPONSE
SIMILARITY AND SHARE A COMMON FSAR 1
OVERALL REGULATORY FRAMEWORK FOR UNITS 1 AND 3 IS BASED ON SIMILARITY IN PLANT CONFIGURATION AND REQUIRED CORRECTIVE ACTIONS DESIGN BASELINE PROGRAM FOR UNITS 1 AND 3 WILL VERIFY CRITERIA ARE ADEQUATE AND PROPERLY IMPLEMENTED PRIOR TO THE RESTART OF EACH UNIT DIFFERENCES BETWEEN UNITS I AND 3 SYSTEMS AND SYSTEM MODELS IN THE IPE WILL BE EVALUATED, AND MODELED, IF SIGNIFICANT PROCEDURAL CONTROLS 4
TVA/NRC MEETING l
OCTOBER 15, 1992 EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS FERRY
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SP0KESMAN TOPIC i
H. L. JONES 1
RESPONSE TO NRC COMMENTS COMMENT:
SIGNIFICANT VULNERABILITIES ENVELOPED BY THE ANALYSIS OF THE TEN SHARED SYSTEMS (SYSTEMATIC EVALUATION OF ALL SHARED SYSTEMS AND BASIS FOR ELIMINATION)
ENCLOSURE 2 TO TVA'S 2/07/92 LETTER:
RESPONSE
PROVIDED CRITERIA USED FOR DESIGN OF SHARED SYSTEMS IDENTIFIED SHARED SYSTEMS 1
l DESCRIBED SHARED FUNCTIONS JUSTIFIED THE ELIMINATION OF ANY l
I SHARED SYSTEM TOP SYSTEMS IN UNIT 2 IPE WILL BE MODELED 5
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TVA/NRC MEETING
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OCTOBER 15,;1992.
EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS FERRY i.
TOPIC SPOKESMAN
-RESPONSE TO NRC COMMENTS H. L. JONES COMMENT:
ANALYSIS LIMITED TO.TWO INITIATING EVENTS (BASIS FOR ELIMINATING'ANY INITIATORS).
RESPONSE
LOSS OF OFFSITE POWER'AND LOSS 0F PLANT AIR CONSIDERED REASONABLE AND
-REPRESENTATIVE INITIATING-EVENTS BOTH EVENTS DIRECTLY RESULT IN THE SHUTDOWN OF ALL THREE UNITS LOSS.0F OFFSITE POWER WAS LEADING
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l TVA/NRC MEETING OCTOBER 15, 1992 EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS FERRY l
TOPIC SPOKESMAN H. L. JONES RESPONSE TO NRC COMMENTS COMMENT:
EFFECT OF SHUT DOWN UNITS ON OPERATING UNITS BFN IPE CONSIDERED EFFECTS OF UNITS 1
RESPONSE
AND 3 SHUTDOWN AND-UNIT 2 IN OPERATION TVA'S 2/07/92 LETTER JUSTIFIED THREE UNIT OPERATION AS MOST LIMITING CASE
TVA/NRC MEETING OCTOBER 15, 1992 EXPANDED INDIVIDUAL PLANT EXAMINATIONS FOR BROWNS' FERRY TOPIC SPOKESMAN-CONCLUSION G. D. PIERCE
' EVALUATION OF SYSTEMS SHARED BETWEEN UNITS WAS NOT REQUIREMENT.OF' GENERIC' LETTER 88-20 t
. ~NUREG-1335 STATES THAT-ONLY POWER OPERATION AND HOT STANDBY NEED-BE CONSIDERE7 FOR THE PURPOSES OF THE IPE BFN'S PROPOSAL IS PROACTIVE, RESPONSIVE TO'NRC COMMENTS, AND IS A' GOOD FAITH EFFORT q
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