ML070400566

Response to Request for Additional Information Regarding Generic Letter 2003-01, Control Room Habitability.

ML070400566
Person / Time
Site:	Browns Ferry
Issue date:	02/08/2007
From:	Crouch W D Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, TAC MB9776, TAC MB9777, TAC MB9778
Download: ML070400566 (6)

Text

February 8, 2007 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop OWFN, P1-35 Washington, D. C. 20555-0001 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 2003-01, "CONTROL ROOM HABITABILITY" (TAC NOS. MB9776, MB9777, AND MB9778) This letter is in response to NRC's January 9, 2007, Request for Additional Information (ADAMS Accession No. ML063550049) regarding Generic Letter (GL) 2003-01, Control Room Habitability. TVA's original response to GL 2003-01 was submitted on December 8, 2003 (ML033430322).

NRC RAI In a December 8, 2003, letter, Tennessee Valley Authority (TVA) responded to questions concerning Generic Letter (GL) 2003-01, Control Room Habitability. TVA stated that Technical Specification (TS) surveillance requirement (SR) 3.7.3.4 calls for periodic testing of each Control Room Emergency Ventilation subsystem to verify that a Control Room Habitability Zone (CRHZ) pressure of greater than 0.125 inch

water gauge can be maintained. TVA stated that this SR quantifies the CRHZ unfiltered in-leakage, that this testing has been performed on a periodic basis since 1991, and that

U.S. Nuclear Regulatory Commission Page 2 February 8, 2007 the testing is adequate to demonstrate CRHZ integrity such that no TS changes are required.

Additional information concerning the complex testing/

in-leakage quantification testing is required in order for the staff to complete its review of GL 2003-01 Item 1c.

Provide information about this testing in sufficient detail

such that the Nuclear Regulatory Commission staff is able to evaluate and determine if it is an acceptable method to demonstrate control room envelope integrity as described in Regulatory Guide 1.197 "Demonstrating Control Room Envelope Integrity At Nuclear Power Reactors" and Nuclear Energy Institute document, NEI 99-03 "Control Room Habitability Assessment Guidance."

TVA Response In the original submittal letter, TVA indicated that the periodic testing of each Control Room Emergency Ventilation subsystem, which verifies that a CRHZ pressure of greater than 0.125 inch water gauge can be maintained, satisfactorily quantified the CRHZ unfiltered inleakage. In light of subsequent industry efforts on the development of Technical

Specifications Task Force (TSTF) Traveler 448, which provides model TS for an acceptable method to demonstrate control room envelope integrity as described in Regulatory Guide 1.197 "Demonstrating Control Room Envelope Integrity At Nuclear Power Reactors" and Nuclear Energy Institute (NEI) document, NEI 99-03 "Control Room Habitability Assessment Guidance", TVA will evaluate the testing elements recommended in

TSTF-448 and will submit a proposed license amendment request based on TSTF-448 by March 1, 2008. The Notice of Availability of TSTF-448 Revision 3 was posted in the Federal Register on January 17, 2007, under the Consolidated Line Item Improvement Program.

TVA does not consider this a high priority activity in that tracer gas testing on the BFN CRHZ shows significant unfiltered inleakage margin (measured value of 600 cubic feet

per minute (CFM)) to the analysis value assumed in the BFN Alternate Source Term design and licensing basis of 3717 CFM.

U.S. Nuclear Regulatory Commission Page 3 February 8, 2007 If you have any questions about this submittal, please contact me at (256) 729-2636.

Sincerely, Original signed by:

William D. Crouch Manager of Licensing and Industry Affairs

Enclosure:

List of Regulatory Commitments cc: See page 3 U.S. Nuclear Regulatory Commission Page 4 February 8, 2007 Enclosure cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415

NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Margaret Chernoff, Project Manager

U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 U.S. Nuclear Regulatory Commission Page 5 February 8, 2007 DTL:BCM:BAB Enclosure cc (Enclosure):

M. Bajestani, NAB 1A-BFN A. S. Bhatnagar, LP 6A-C R. H. Bryan, BR 4X-C R. G. Jones, POB 2C-BFN

G. V. Little, NAB 1D-BFN R. A. DeLong, SAB 1A-BFN B. J. O'Grady, PAB 1E-BFN K. W. Singer, LP 6A-C P. D. Swafford, LP 6A-C E. J. Vigluicci, WT 6A-K NSRB Support, LP 5M-C

EDMS WT CA - K s:lic/submit/subs/GL 2003-01.doc

Enclosure Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Request For Additional Information Regarding Generic Letter 2003-01 Control Room Habitability List of Regulatory Commitments

1. TVA will evaluate the testing elements recommended in TSTF-448 and will submit a proposed license amendment request based on TSTF-448 by March 1, 2008.