Text

Technical Specification (TS) Change 442 - Revision to Scram Discharge Volume Vent and Drain Valve Required Actions Using the Consolidated Line Item Improvement Process
	ML032170655
Person / Time
Site:	Browns Ferry
Issue date:	07/25/2003
From:	Abney T; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TVA-BFN-TS-442
	Download: ML032170655 (16)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 July 25, 2003 TVA-BFN-TS-442 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop OWFN, P1-35 Washington, D. C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, and 3 -

TECHNICAL SPECIFICATIONS (TS) CHANGE 442 - REVISION TO SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVE REQUIRED ACTIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS In accordance with the provisions of 10 CFR 50.90, TVA is submitting a request for an amendment to licenses DPR-33, DPR-52, and DPR-68 for BFN Units 1, 2, and 3, respectively.

The proposed amendment would revise the required actions within TS 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves," for the condition of having one or more SDV vent or drain lines with one valve inoperable. These changes are based on Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-404, "SDV Actions," that has been approved generically for the BWR/4 Standard Technical Specifications, NUREG-1433, Revision 2. The availability of this TS improvement was announced in the Federal Register on April 15, 2003, as part of the Consolidated Line Item Improvement Process (CLIIP).

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U.S. Nuclear Regulatory Commission Page 2 July 25, 2003 provides a description of the proposed change and confirmation of applicability. Enclosure 2 provides the existing TS pages marked-up to show the proposed changes. provides the existing TS Bases pages marked-up to reflect the proposed TS changes. There are no new regulatory commitments made in this submittal.

TVA requests approval of the proposed TS change for Units 1, 2, and 3 by January 30, 2004, and that the revised TS be made effective within 60 days of NRC approval.

TVA has determined that there are no significant hazards considerations associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and attachments to the Alabama State Department of Public Health.

This letter is being sent in accordance with NRC Regulatory Issue Summary 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM. If you have any questions concerning this submittal, please contact me at (256) 729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 25, 2003.

Sincerely T. E. Abney Manager of L in and Indu ry Affai s Enclosur

1. Descri d Assessment

2. Proposed Technical Specifications Changes (mark-up)

3. Proposed Technical Specifications Bases Changes (mark-up)

U.S. Nuclear Regulatory Commission Page 3 July 25, 2003 cc (Enclosures):

State Health Officer Alabama State Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017

Enclosure 1 Technical Specifications (TS) Change 442 Revision to Scram Discharge Volume Vent and Drain Valve Required Actions Using the Consolidated Line Item Improvement Process Description and Assessment

1.0 DESCRIPTION

The proposed amendment would revise the required actions within TS 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves," for the condition of having one or more SDV vent or drain lines with one valve inoperable. The changes are based on Technical Specification Task Force (TSTF)

Change Traveler, TSTF-404, Revision 0, "SDV Actions," that has been approved generically for the BWR/4 Standard Technical Specifications, NUREG-1433, Revision 2. The availability of this TS improvement was announced in the Federal Register on April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation TVA has reviewed the model safety evaluation published on April 15, 2003 (68 FR 18294), as part of the CLIIP. TVA's verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-404. TVA has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to BFN Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the BFN Unit 1, 2, and 3 TS.

2.2 Optional Changes and Variations TVA is not proposing any variations or deviations from the TS changes described in TSTF-404 or the NRC staff's model safety evaluation published on April 15, 2003.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Determination TVA has reviewed the proposed no significant hazards consideration determination published on April 15, 2003, as part of the CLIIP. TVA has concluded that the proposed determination presented in the notice is applicable to BFN, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments There are no new regulatory commitments associated with this proposed change.

4.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the model safety evaluation published on April 15, 2003, as part of the CLIIP. TVA has concluded that the NRC staff's findings presented in that evaluation are applicable to BFN Units 1, 2, and 3, and the evaluation is hereby incorporated by reference for this application.

E1-2

Enclosure 2 Technical Specifications (TS) Change 442 Revision to Scram Discharge Volume Vent and Drain Valve Required Actions Using the Consolidated Line Item Improvement Process Proposed Technical Specifications Changes (mark-up)

SDV Vent and Drain Valves 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves LCO 3.1.8 Each SDV vent and drain valve shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

-NOT FlT Separate Condition entry is allowed for each SDV vent and drain line.

P. An isolated line may be unisolated under administrative control to allow draining and venting of the SDV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SDV vent or A.1 Restore valve to 7 days drain lines with one valve OPERABLE R sttus.

inoperable. Isolate the associated line.

B. One or more SDV vent or B.1 - -- NOTE --

drain lines with both An olated line y be valves inoperable. unisol d un r administr e control to allow dr in and venting of th DV.

Isolate the associated 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months line.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

BFN-UNIT I 3.1-28 Amendment No. 234

SDV Vent and Drain Valves 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves LCO 3.1.8 Each SDV vent and drain valve shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

1.

ACTIONS

- - ~ ~

.P NOTEF' Separate Condition entry is allowed for each SDV vent and drain line.

An isolated line may be unisolated under administrative control to allow draining and venting of the SDV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SDV vent or A.1 Rpctore vAlyc to 7 days drain lines with one valve OPERABLE R tatua.

inoperable. Isolate the associated line.

B. One or more SDV vent or B.1 - -NOTE -

drain lines with both An lated line m b valves inoperable. unisolad und administra control to allow dra n nd venting of the V Isolate the associated 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months line.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

BFN-UNIT 2 3. 1-28 Amendment No. 253

SDV Vent and Drain Valves 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves LCO 3.1.8 Each SDV vent and drain valve shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS E1 F -i--NOTES F* l1 Separate Condition entry is allowed for each SDV vent and drain line.

2. An isolated line may be unisolated under administrative control to allow draining and venting of the SDV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SDV vent or A.1 Restore valve to 7 days drain lines with one valve OPERABLE status.

inoperable. Isolate the associated line.

B. One or more SDV vent or B. 1 ---- NOTE drain lines with both AnKolated line m valves inoperable. uniso d und administr control to allow dr nd venting of th DV.

Isolate the associated 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months line.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

BFN-UNIT 3 3.1-28 Amendment No. 212

Enclosure 3 Technical Specifications (TS) Change 442 Revision to Scram Discharge Volume Vent and Drain Valve Required Actions Using the Consolidated Line Item Improvement Process Proposed Technical Specifications Bases Changes (mark-up)

SDV Vent and Drain Valves B 3.1.8 BASES (continued)

APPLICABILITY In MODES 1 and 2, scram may be required; therefore, the SDV vent and drain valves must be OPERABLE. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor VVhen a line is isolated, the mode switch is in shutdown and a control rod block is applied. potential for an inadvertent This provides adequate controls to ensure that only a single scram due to high SDV level control rod can be withdrawn. Also, during MODE 5, only a is increased. During these single control rod can be withdrawn from a core cell containing periods, the line may be fuel assemblies. Therefore, the SDV vent and drain valves are inisolated under not required to be OPERABLE in these MODES since the administrative control. This reactor is subcritical and only one rod may be withdrawn and allows any accumulated subject to scram. water in the line to be drained, to preclude a reactor scram on SDV high evel. This is acceptable, ACTIONS The ACTIONS Table is modified by a Note indicating that a since the administrative separate Condition entry is allowed for each SDV vent and drain controls ensure the valve line. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each -an be closed quickly, by a inoperable SDV line. Complying with the Required Actions may dedicated operator, if a scram occurs with the valve allow for continued operation, and subsequent inoperable SDV lines are governed by subsequent Condition entry and )pen.

application of associated Required Actions.

A.1 When one SDV vent or drain valve is inoperable in one or more lines, the valve must be restored to OPERABLE statue within 7 daysc. The Complotion Timt is reasonable. aiven thc level of redunR ns': In Re "lnRe aRn3 iRe 19W KrocacilF Ot a Gcrnam I occurring during the time the valve(s) are inopsrable. The SDV is still isolable since the redundant valve in the affected line is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

the associated line must be isolated to contain the reactor coolant during a scram. The 7 day Completion Time is reasonable, given the level of redundancy in the lines and the low probability of a scram occurring during the time the valve(s) are inoperable and the line is not isolated.

(continued)

BFN-UNIT 1 B 3. 1-59 Revision 0

SDV Vent and Drain Valves B 3.1.8 BASES ACTIONS B.1 (continued)

If both valves in a line are inoperable, the line must be isolated to contain the reactor coolant during a scram. When a line is isolated, the potential for an inadvertent scram due to high SDV level is increased.Requiredo c tion . 1 is modified by a Nlote that aflove periodic draining and venting of the SD' when a line i iolatted. Dringr thee periode, the linRe ay be ur;isoated under adminitrative control. T.hi, alkv.s any accumulated water in the line to be drained, to preclude a reactor scram on SDV high lee_. Thi i.sacceptable sin.e the administrative controls enure therVAle c-an be losed quirckly, by a ded cgated

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1bo kLird Yi:jr.'u Up"FM.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time to isolate the line is based on the low probability of a scram occurring while the line is not isolated and unlikelihood of significant CRD seal leakage.

C-1 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

BFN-UNIT 1 B 3.1-60 Revision 0

SDV Vent and Drain Valves B 3.1.8 BASES (continued)

APPLICABILITY In MODES 1 and 2, scram may be required; therefore, the SDV vent and drain valves must be OPERABLE. In MODES 3 and 4, Nhen a line is isolated, the control rods are not able to be withdrawn since the reactor potential for an inadvertent mode switch is in shutdown and a control rod block is applied.

scram due to high SDV level This provides adequate controls to ensure that only a single s increased. During these control rod can be withdrawn. Also, during MODE 5, only a periods, the line may be single control rod can be withdrawn from a core cell containing inisolated under fuel assemblies. Therefore, the SDV vent and drain valves are administrative control. This not required to be OPERABLE in these MODES since the allows any accumulated reactor is subcritical and only one rod may be withdrawn and

.vater in the line to be subject to scram.

drained, to preclude a eactor scram on SDV high evel. This is acceptable, ACTIONS The ACTIONS Table is modified by a Note ndicating that a since the administrative separate Condition entry is allowed for each SDV vent and drain controls ensure the valve line. This is acceptable, since the Required Actions for each -an be closed quickly, by a Condition provide appropriate compensatory actions for each dedicated operator, if a inoperable SDV line. Complying with the Required Actions may scram occurs with the valve allow for continued operation, and subsequent inoperable SDV )pen.

lines are governed by subsequent Condition entry and application of associated Required Actions.

A.1 When one SDV vent or drain valve is inoperable in one or more lines, the valve must be rFetored to OPEWRABLE status within

+ Uay5. I no mpicliun Imc Is 1c Fedb gowm..t1 nW IndYU!

e rFdundaRGnc in the linRe aRd the lew probability of a becrsA occurring during the time the valve(e) are inoperable. The SDV is still isolable since the redundant valve in the affected line is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

1 the associated line must be isolated to contain the reactor coolant during a scram. The 7 day Completion Time is reasonable, given the level of redundancy in the lines and the low probability of a scram occurring uring the time the valve(s) are inoperable and the line is not isolated.

(continued)

BFN-UNIT 2 B 3.1-59 Revision 0

SDV Vent and Drain Valves B 3.1.8 BASES ACTIONS B.1 (continued)

If both valves in a line are inoperable, the line must be isolated to contain the reactor coolant during a scram. When a line ic isolated, the potential for an inadvertent scram due to high SDV levelc inrearoaed. Required AcAtinA 8.1 i. miodiod by a Noto that alo0WE periodic draining and venting of the SDV' when a PRO is icolated. DuAing these periods, the line may be unWcolated

.nder adminietrative control This alloeyI

. any accumulated water in the line to be drained, to preclude a reactor scram on ens high levoI. This O,acceptable sinRe the adminietative-controls ensure the valve can be closed quickly, by a dedicated operator, if scram occurs with the valve open.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time to isolate the line is based on the low probability of a scram occurring while the line is not isolated and unlikelihood of significant CRD seal leakage.

C. 1 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

BFN-UNIT 2 B 3.1^60 Revision 0

SDV Vent and Drain Valves B 3.1.8 BASES (continued)

APPLICABILITY In MODES 1 and 2, scram may be required; therefore, the SDV vent and drain valves must be OPERABLE. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor hen a line is isolated, the potential for an inadvertent mode switch is in shutdown and a control rod block is applied.

cram due to high SDV level This provides adequate controls to ensure that only a single control rod can be withdrawn. Also, during MODE 5, only a s increased. During these single control rod can be withdrawn from a core cell containing periods, the line may be unisolated under fuel assemblies. Therefore, the SDV vent and drain valves are dministrative control. This not required to be OPERABLE in these MODES since the allows any accumulated reactor is subcritical and only one rod may be withdrawn and water in the line to be subject to scram. Ho drained, to preclude a reactor scram on SDV high evel. This is acceptable, ACTIONS The ACTIONS Table is modified by a Note indicating that a since the administrative separate Condition entry is allowed for each SDV vent and drain controls ensure the valve line. This is acceptable, since the Required Actions for each ,an be closed quickly, by a Condition provide appropriate compensatory actions for each dedicated operator, if a inoperable SDV line. Complying with the Required Actions may cram occurs with the valve allow for continued operation, and subsequent inoperable SDV pen.

lines are governed by subsequent Condition entry and application of associated Required Actions.

A.1 When one SDV vent or drain valve is inoperable in one or more lines, the ivalve must be restored to OPERABLE Etatuc within 7 days. The Completion Timc ic rea6onable, given the leyel of redundancy in the linae and the low probability of a Gcram ocuFrring during the time the ValVoh() aro inoporahlo. The SDV is still isolable since the redundant valve in the affected line is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

he associated line must be isolated to contain the reactor coolant during a scram. The 7 day Completion ime is reasonable, given the level of redundancy in the lines and the low probability of a scram occurring uring the time the valve(s) are inoperable and the line is not isolated.

(continued)

BFN-UNIT 3 B 3.1-59 Revision 0

SDV Vent and Drain Valves B 3.1.8 BASES ACTIONS B.1 (continued)

If both valves in a line are inoperable, the line must be isolated to contain the reactor coolant during a scram. When a line is isolated, the potential for an inadvertent scram due to high SDV 1Z1--ic -c nir. l to-i 4d- iM olfir

-A-AL., h- K-1- - - -- HdIdLW91d lot CA Hwte-that allowe periodic draining and venting of the SD! when a line is icolated. During theee period6, the line may be unicolated undcr Rdminie;trativP control This ailm rs ary acumulatedl water in the line to be drained, to preclude a reaetor scram on SDV high level. This is acceptable 6inee the administrative conntrle ensure the walve can be Glosod quickly, by a dedicated operator, if a scram occurs with the valve open.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time to isolate the line is based on the low probability of a scram occurring while the line is not isolated and unlikelihood of significant CRD seal leakage.

C. 1 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

BFN-UNIT 3 B 3.1-60 Revision 0

ML032170655

Text

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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