ML20246F801

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Exemption from 10CFR50.71(e) Requiring Annual Update of Updated Fsar.W/Design Mods Currenting Underway to Support Unit 2 Restart,Update in Jul 1989 Would Not Reflect Unit 2 Configuration at Projected Time of Startup
ML20246F801
Person / Time
Site: Browns Ferry  
Issue date: 07/07/1989
From: Liaw B
Office of Nuclear Reactor Regulation
To:
TENNESSEE VALLEY AUTHORITY
Shared Package
ML20246F806 List:
References
NUDOCS 8907140039
Download: ML20246F801 (4)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of TENNESSEE VALLEY AUTHORITY

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Docket Nos. 50-259, 50-260

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and 50-296 (Browns Ferry Nuclear Plant,

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Units 1, 2 and 3)

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EXEMPTION I.

The Tennessee Valley Authority (TVA or the licensee) is the holder of Operating License Nos. DPR-32, DPR-52 and DPR-69 which authorize operation of Units 1, 2 and 3, respectively.

These licenses provide, among other things, that Browns Ferry is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.

Browns Ferry (BFN), Units 1, 2 and 3 are boiling water reactors (BWR)- at the licensee's site located near Decatur, Alabcma.

II.

10 CFR Part 50.71(e) requires, in part, that licensees shall update periodically the final safety analysis report (FSAR) originally submitted as part of the application for the operating license, to assure that the information in the FSAR contains the latest material developed.

Revisions to the original FSAR shall be filed no less frequently than annually and shall reflect all changes up to a maximum of six months prior to the date of filing.

This ' regulation requires the annual updated FSAR (UFSAR) for Browns Ferry to be submitted on July 22, 1989.

o gDR907140039 890707 p

ADOCK 05000259 PDC

2 III.

J By letter dated May 23, 1989, the licensee requested a temporary exemption from certain requirements of 10 CFR Part 50.71(e).

Specifically, the licensee requested a temporary exemption from the requirements to submit an annual update of the Browns Ferry UFSAR on July 22, 1989.

A revised UFSAR would be submitted on July 22, 1990.

Deficiencies regarding the accuracy of the Browns Ferry UFSAR were identified by the licensee through the Employee Concerns Program.

The last updated UFSAR was provided to the staff by letter dated July 19, 1988.

Corrective actions have been implemented which include establishing improved controls for maintaining an accurate UFSAR and performance of a program to review relevant documentation to update and verify the UFSAR.

The licensee has recently implemented a new UFSAR update program that provides a corporate

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standard and site prot.edures necessary to coordinate the updating of the UFSAR with the responsible organizations.

A verification program has also been initiated. This UFSAR verification program will utilize the output of the Design Baseline and Verification Program (DBVP) to ensure that the UFSAR is consistent with the latest as-configured drawings and design changes, as well as the existing Technical Specifications, fuel load analysis, and current administrative and operational programs.

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TVA has updated the Browns Ferry UFSAR,anually for the past six years, With the many design modifications currently underway to support Unit 2 I

restart, an update in July 1989 would not reflect the Un.it 2 configuration relative to the time of its projected start-up (currently projected for

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3 late 1989).

Units 1 and 3 are currently defueled and will not be restarted until after the next annual updated UFSAR of July 1,1990.

In order to ensure that users of the UFSAR have available the latest information which could l

affect the UFSAR (e.g.,10 CFR 50.59 determinations, Engineering Change Notices dnd Design Change Notices), the licensee has put in place programs and procedures to maintain a 10 CFR 50.59 library and a file on UFSAR changes.

These compensatory measures should assist UFSAR users by providing the latest information concerning any part of the UFSAR.

As part of the licensee's DBVP program, operation personnel are being provided with up-to-date configuration drawings which are utilized in the control room as source material.

Therefore, the requested temporary exemption will not affect plant operation and safety.

The staff has concluded that the requested temporary exemption is adminis-trative in nature and would not affect plant equipment, operations or proce-dures.

The Commission has determined that special circumstances, as provided in l

10 CFR 50.12(a)(2)(v), are present justifying the exemption, namely; that the 1

exemption would provide only temporary relief.from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation.

This exemption would provide Browns Ferry with only temporary relief from compliance with the annual UFSAR update.

The licensee is making good faith efforts to comply with the intent of the regulation which is to ensure a complete, updated and a single integral document (UFSAR) on file for each power l

reactor license.

TVA's verification / update program is indicative of their recognition of problems with the updated UFSAR process and their good faith efforts to correct these problems.

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IV Accordingly, the Commission has determined, pursuant to 10 CFR Part 50.12, l

that (1) this temporary exemption is authorized by law, will not present an l

l undue risk to the public health and safety, and is consistent with the comon defense and security, and (2) in this case, special circumstances are present as described in Section II.

In light of this determination and as reflected in the Environmental Assessment and Notice of Finding of No Significant Environmental Impact pre-pared pursuant to 10 CFR 51.21 and 51.32 (July 6,1989) (54 FR 28523), it is determined that the intended action will have no significant impact on the environment.

A copy of the licensee's request for exemption dated May 23, 1989 related to this action is available for public inspection at the Commission's Public Document Room, 2120 L Street, N.W., Washington, D.C., and at the Local Public Document Room located at Athens Public Library, South Street, Athens, Alabama 35611.

This Exemption is effective upon issuance.

Dated at Rockville, Maryland this 7th day of July 1989.

FOR THE NUCLEAR REGULATORY COMMISSION 1

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\\ ]D. Liaw, Director i

T A Projects Division Office of Nuclear Reactor Regulation l

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