ML20215L039
| ML20215L039 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/16/1986 |
| From: | Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8610280437 | |
| Download: ML20215L039 (2) | |
Text
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OCT 161986 Docket Nos. 50-259, 50-260, and 50-296 License Nos. DPR-33, DPR-52, and DPR-68 Tennessee alley Authority ATTN:
- r. S. A. White Manager of Nuclear Power 6N 38A Lcokout Place 1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:
SUBJECT:
BROWNS FERRY RHR - CROSSTIE AMENDMENT QUESTIONS TVA is requested to provide clarification of procedures implemented for the review of Technical Specification amendment changes.
Specifically, changes in regard to the residual heat removal (RHR) system crosstie Technical Specifica-tion submittal as referenced below should be clarified.
TVA submitted on February 25, 1985, an amendment request to delete the limiting condition for operation (LCO) and surveillance requirements associated with the RHR system crosstie between adjacent reactor units from the Browns Ferry Tech-nical Specifications. The safety analysis associated with the proposed change was incomplete in that it failed to address the licensing basis for the crosstie feature as discussed in paragraphs F.7.16 and I.3.3.2. of the Final Safety Analysis Report (FSAR).
These paragraphs describe the original plant licensing concerns related to flooding of the reactor building corner rooms which could possibly render all of the affected unit's emergency core cooling systems (ECCS) inoperable. This information was important to the NRC's amendment request review process as evidenced by publication in the Federal Register of the notice of intent to approve the proposed change. After the original plant licensing basis was identified the amendment request was denied pending further justification by the licensee.
The NRC is concerned that future licensing submittals may not contain complete and accurate safety analyses which fully address the design basis for plant features important to safety.
l Within 30 days, please answer the questions below to assist the staff in the review of this issue as noted in I.E. Report 86-20.
I 1.
The Browns Ferry Technical Specifications contain requirements for safety features which are not taken credit for in any accident or transient analy-sis, are not described in the NRC Standard Review Plan, and are not con-tained in Standard Technical Specifications. The RHR crosstie is an example of this. What program is in place to assure that the original plant licens-ing basis for these features is fully discussed in any future licensing submittals?
2.
For proposed changes to Technical Specifications which are being concur-rently reviewed by the Nuclear Safety Review Board (NSRB), what controls exist to ensure a timely review and what mechanism exists to inform the NRC of questions identified by the NSRB review?
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OCT 16 1986 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 be deleted from the Technical Specification but are to be maintained fully operable. What is the TVA policy for compensating management controls in such cases?
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC Public Document Room.
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The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act 6f 1980, PL 96-511.
Should you have any questions concerning this letter, please contact us.
l Sincerely, ORIGINAL SIGNED BY GARY G. ZECH Gary G. Zech, Director Division of TVA Projects cc d. P. Pomrehn, Browns Ferry uclear Plant Site Director I.L. Lewis,PlantManager L. Gridley, Director g Juclear Safety and Licensing W. A. Kirkebo, Director Nuclear Engineering l
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