ML20214N891
| ML20214N891 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/19/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8612040005 | |
| Download: ML20214N891 (3) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place NOV 191986 US NOV 25 A 8y U.S. Nuclear Regulatory Comission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY - RHR-CROSSTIE AMENDMENT REQUEST FOR ADDITIONAL INFORMATION As requested in G. G. Zech's letter to S. A. White dated October 16, 1986, we are providing the enclosed response to your questions regarding technical specification amendments.
The questions relate to NRC's review of a technical specification amendment request submitted on February 25, 1985 deleting the Limiting Condition for Operations and Surveillance Requirements associated with the RHR system inter-unit Crosstie. That amendment was withdrawn on January 13, 1986.
Very truly yours.
TENNESSEE VALLEY AUTHORITY R. G idley, Dir ctor Nuclear Safety nd Licensing Enclosure cc (Enclosure):
Mr. C. E. Gears Browns Ferry Project Manager U.S. Nuclear Regulatory Comission Bethesda, Maryland 20814 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Reaulatory Comission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington, D.C.
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ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION BROWNS FERRY NUCLEAR PLANT RHR CROSSTIE AMENDMENT REQUEST NRC OUESTION 1.
The Browns Ferry Technical Specifications contain requirements for safety features which are not taken credit for in any accident or transient analysis, are not described in the NRC Standard Review Plan, and are not contained in Standard Technical Specifications. The RHR crosstle is an example of this. What program is in place to assure that the original plant licensing basis for these features is fully discussed in any future licensing submittals?
TVA Response Section II.1.2.7 of the Browns Ferry Nuclear Performance Plan describes changes in the TVA licensing organization to improve the responsiveness and quality of licensing submittals. Specifically, a dedicated licensing staff is now in place at the site. Previously, responsibilities for preparing submittals were not consolidated but rather were distributed among several site suborganizations.
The Manager of site Licensing is now responsible for ensuring technical specification submittals are accurate and address pertinent licensing bases.
The licensing staff supervisory and engineering personnel are skilled in the preparation of technical specification amendments including reseafch of licensing bases.
NRC Ouestion 2.
For proposed changes to technical specifications which are being concurrently reviewed by the Nuclear Safety Review Board (NSRB), what controls exists to ensure a timely review and what mcchanism exists to inform the NRC of questions identified by the NSRB review?
TVA Response Technical specifications changes which are submitted with concurrent Nuclear Safety Review Board (NSRB) review will be earmarked to ensure exped,ited review.
Concurrent reviews are utilized only for emergency technical specifications changes. For routine technical specification changes, NSRB review is required before submittal to NRC. The NSRB advises the Manager of Nuclear Power who in turn may refer any questions not resolved during the review process to the Manager of Site Licensing for resolution.
Site Licensing would inform NRC of any changes in TVA position which results from NSRB review. Note that the site directors are members of the respective NSRBs and, therefore, each site always has a direct involvement in NSRB affairs.
NHC'Ouestion 3.
The primary NSRB concern with the subject amendment request,was a question of compensating measures to provide equivalent administrative control of the availability of safety features which are proposed to bn deleted from the technical specification but are to be maintained fully operable. What is the TVA policy for compensating management controls in such cases?
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.. TVA Response TVA. requires strict management controls over safety related operations, maintenance, and modifications. For cases where tr.chnical specifications are deleted or relaxed for a safety related feature which is to remain installed in the plant, alternate administrative controls are available. Typical vehicles for this type of control include operating and maintenance instructions, clearance procedures, and stand alone programs. For example, a number of radiological effluent requirements are presently being removed from technical specifications by a proposed amendment. These will be controlled in the future by the Offsite Dose Calculation Manual, the Radiological Effluent Manual and the Process Control Program. The type of administrative control to be excercised is highly dependent on the specific equipment or features involved and must be stipulated on a case-by-case basis.
The issue as to whether a corporate policy on this subject would be appropriate is still under consideration by NSRB. The NSRB will review this matter and report to the Manager of Nuclear Power in January 1987.
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