ML040580261
| ML040580261 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/26/2004 |
| From: | Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML040580261 (20) | |
Text
I X : I TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT RESOLUTION OF UNIT 1 LICENSE CONDITION 2.C(4)
TVA / NRC Meeting February 26, 2004 Rockville, Maryland
Agenda
- Purpose of Meeting
- History of License Condition
- Purpose of License Condition
- Issues with Wording of the License Condition
- Proposed Resolution of License Condition
- Discussion 2
Purpose of Meeting
- The purpose of this meeting is to establish an approach for satisfying Browns Ferry Unit 1 License Condition 2.C(4)
- Unit 1 License Condition 2.C(4):
"The licensee shall review the Technical Specification (TS) changes made by License Amendment No. 234 and any subsequent TS changes, verify that the required analyses and modifications needed to support the changes are complete, and submit them for NRC review and approval prior to entering the mode for which the TS applies. This amendment is effective immediately and shall be implemented prior to entering the mode for which the TS applies."
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_ r History of License Condition All three BFN units were voluntarily shutdown by TVA in March 1985.
Unit 2 restarted in May 1991 and Unit 3 in November 1995. Several modifications and the resulting changes to the Units 2 and 3 Technical Specifications were made during the recovery efforts.
On September 6,1996, TVA submitted Units 1, 2, and 3 Technical Specifications Change 362 - Improved Technical Specifications, which was TVA's conversion package from Custom Technical Specifications to Improved Technical Specifications. The Units 1, 2 and 3 Improved Technical Specifications were based on NUREG-1433, Standard Technical Specification for BWR/4 Plants, Revision 1. At the time, Units 2 and 3 were operating and Unit 1 was is long-term lay-up with no plans for return to service.
- During the conversion process, if a value was the same in the Custom Technical Specifications for all three units, the same value was used in the conversion to the Improved Technical Specifications.
- During the conversion process, several Unit 1 specific setpoints or configurations adopted the Improved Technical Specification values used for Units 2 and 3 (listed on the next page).
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- i History of License Condition (Cont.)
TVA's application stated that following changes for Unit 1 must be validated prior to Unit 1 recovery or necessary changes made.
- Justification for Change Al 1 in Section 3.3.1.1:
Calibration frequencies for High Reactor Pressure, High Drywell Pressure and Reactor Low Water Level.
- Justification for Change A3 in Section 3.3.5.1:
Calibration frequencies for Reactor Low Water Level, Drywell High Pressure, Reactor Low Pressure, and Reactor High Water Level.
- Justification for Change A8 in Section 3.3.5.2:
Calibration frequencies for Reactor Low Water Level and Reactor High Water Level.
- Justification for Changes in Section 3.3.6.1:
o Change A12 - The RWCU temperature functions (Cleanup System Floor Drain and Space High Temperatures).
o Change Al 3 - The Reactor Low Water Level, High Drywell Pressure, RWCU temperature function, and RCIC and HPCI Turbine Steam Line High Flow calibration frequencies.
o Change A14 - The Instrument Checks for RCIC and HPCI Steam Supply Low Pressure and Turbine Exhaust Diaphragm High Pressure.
o Change Al5 - The RCIC and HPCI Torus and Pump Room High Temperature trip functions.
- Justification for Change AlO in Section 3.3.6.2:
Calibration frequencies for Reactor Low Water Level and High Drywell Pressure.
- Justification for Change A5 in Section 3.3.7.1:
Calibration frequencies for High Drywell Pressure.
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History of License Condition (Cont.)
These differences existed because the Units 2 and 3 recovery programs and modifications had not been implemented on Unit 1.
Specifically:
o Installation of Analog Transmitter / Trip System o Updated High Energy Line Break analyses and modifications to temperature monitoring systems
- Since TVA was proposing Unit 1 Technical Specification values that were not supported by design basis documentation, on July 14, 1997, NRC requested TVA to provide a description of the controls, including license requirements, which would ensure that BFN Unit 1 could not be put into an operating configuration before all required activities were completed. NRC also noted that the BFN Units 2 and 3 Improved Technical Specifications cannot be issued independently of the Unit 1 Improved Technical Specifications because of the systems and equipment common to all three units.
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History of License Condition (Cont.)
- On December 29, 1997, in response to the NRC letter, TVA stated that it planned to perform the required analyses and modifications on Unit 1 such that on restart, the Unit 1 plant configuration and analysis basis will be the same or similar to Units 2 and 3. Hence, in TS-362, the proposed Unit 1 ITS were the same as those proposed for Units 2 and 3 except for minor intrinsic unit differences. TVA proposed the following License Condition be added to the Unit 1 License as follows:
"TVA shall review the Technical Specification (TS) changes made by TS-362 and subsequent TS changes for Unit 1, and verify that required analyses and modifications needed to support the changes are complete prior to entering the mode for which the TS applies."
This would ensure that the appropriate modifications and analyses were in place prior to entering modes of operation for which the TS apply.
- As part of License Amendment number 234, dated July 14, 1998, NRC imposed license condition 2.C(4). The cover letter for the NRC Safety Evaluation states:
"With respect to BFN Unit 1 ITS, an additional condition is imposed which requires Tennessee Valley Authority (TVA) to validate the Unit 1 ITS and submit the validation, and any changes to the ITS, to the NRC for its review and approval before entering Mode 5."
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History of License Condition (Cont.)
Page 12 of the Safety Evaluation states:
"Unit 1 Restart Issues:
The Unit 1 license will contain a restart license condition to require staff acceptance of Unit 1 channel calibration and channel check frequency changes for CTS Tables 3.2.A, 3.2.B, 4.11.B, 4.2.A, 4/2/B made to be consistent with Units 2 and 3.
These changes to frequencies have been reflected in the proposed BFN ITS for Unit 1 as the same as those in the proposed ITS for Units 2 and 3. The Unit 1 Calibration frequencies for these functions will be validated prior to Unit 1 recovery and changes to the proposed BFN ITS for Unit 1 will be made as necessary. [The DOCS that are affected for this example are 3.3.1.1, Al1; 3.3.5.1, A3; 3.3.5.2, A8; 3.3.6.1, A12, A13, A14, A15 (partial); 3.3.6.2 Al0; and 3.3.7.1, A5.] Staff acceptance of these calibrations and frequencies are shown here as an example of the kinds of reviews that will be required before Unit 1 restarts. Additional issues that will require staff acceptance before Unit 1 restarts exist in other sections of the ITS."
[The above Unit 1 actions are also documented in Table L, Matrix of Less Restrictive Changes, of the NRC Safety Evaluation, Pages 30 and 31 of 75.]
- NOTE: No other open Unit 1 issues were identified during a review of the NRC Safety Evaluation.
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History of License Condition (Cont.)
- Also note that there is a significant difference between the action prescribed by the text of the Safety Evaluation (above) and the action prescribed by wording of the License Condition (below):
"The licensee shall review the Technical Specification (TS) changes made by License Amendment No. 234 and any subsequent TS changes, verify that the required analyses and modifications needed to support the changes are complete, and submit them for NRC review and approval prior to entering the mode for which the TS applies. This amendment is effective immediately and shall be implemented prior to entering the mode for which the TS applies."
- As part of TVA's December 13, 2002 proposal for the overall regulatory framework for the restart of Unit 1:
"To meet this condition, TVA will submit a list of those TS changes previously made on all three BFN units for which Unit 1 specific analyses had not been completed. That submittal will verify that the Unit 1 analyses and associated plant modifications for those TS changes have been completed. In the unlikely event that changes to Unit 1 TS are required, those changes will be requested under 10 CFR 50.90."
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History of License Condition (Cont.)
- NRC's August 14, 2003 response stated:
"This issue should be reviewed in detail to determine, among other things, if a revision to License Condition 2.C.4 is required.
The NRC and TVA staffs will pursue this issue as a separate action."
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Purpose of License Condition The purpose of the License Condition was to:
- Allow issuance of the conversion to ITS for all three units with Unit 1 being in a long-term lay-up condition.
- To ensure the changes to the Unit 1 Technical Specifications identified in the application as lacking the required analysis were supported and reflected by the plant's design basis prior to returning the associated equipment to service.
- Allow future Technical Specification changes to be made to all three units without requiring Unit 1 supporting analyses be performed prior to submittal or requiring additional license conditions be added for each amendment.
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Issues with Wording of the License Condition Could be interpreted to require submittal and NRC review of more information that that typically included in a proposed Technical Specification change (i.e., "... the required analyses and modifications needed to support the changes are complete, and submit them for NRC review and approval).
- Licensees typically summarize the supporting analysis for a proposed Technical Specification change.
- Licensees typically receive approval of proposed Technical Specification changes before completion of the modifications.
Verification of modification completion is done internally by the Licensee prior to implementation of the approved change.
- Could be interpreted to require submittal and NRC re-review of all changes made by the ITS conversion (i.e., "... shall review the Technical Specification (TS) changes made by License Amendment No. 234). This was not the intent of the License Condition.
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Proposed Resolution of License Condition SCOPE OF ITEMS INTENDED TO BE INCLUDED INTHE LICENSE CONDITION:
- Unit 1 Technical Specification changes approved after the ITS conversion that did not have the required analyses complete at the time of submittal DISPOSTION OF ITEMS WITHIN THIS SCOPE:
- Unit 1 required analyses identified during conversion to ITS are being addressed:
- A separate proposed Unit 1 Technical Specification change (TS 433 - 24 Month Fuel Cycle) will be submitted to address the calibration frequencies / instrument checks identified during the ITS conversion process as requiring validation (consistent with Units 2/3 TS 390, which was approved by NRC on November 30, 1998).
Calculations have been performed to support the 184 day (6 month) calibrations frequencies for High Reactor Pressure and Low Reactor Pressure instruments. Statements supporting these frequencies will be included in TS 433.
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Proposed Resolution of License Condition (Cont.)
- Proposed Technical Specification changes will be submitted to address RWCU Cleanup System Floor Drain and Space High Temperatures (consistent with Units 2/3 TS, which was approved by NRC on November 26, 2002) and / or the RCIC and HPCI Torus and Pump Room High temperature functions (Units 1, 2 and 3 TS 447 which is scheduled for submittal 2nd quarter 2004).
Confirmation that the HPCI / RCIC instrument checks are not required will also be included.
- Only one Unit 1 Technical Specification has been submitted without all required supporting analyses after the ITS conversion:
- Alternative Source Term (TS 405) - Summary of remaining analyses to be submitted separately.
- A separate letter will be submitted prior to fuel load confirming completion of the associated modifications.
SUMMARY
- Unit 1 specific differences during conversion to ITS identified and will be individually addressed through submission of proposed Technical Specification changes.
- Only Unit 1 Alternative Source Term analysis results remain to be submitted for Technical Specifications proposed after the ITS conversion.
- Future Unit 1 Technical Specification changes will be treated just like any other operating unit.
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Proposed Resolution of License Condition (Cont.)
- As part of TVA's December 13, 2002 proposal for the overall regulatory framework for the restart of Unit 1, TVA proposed the following interpretation of License Condition 2.C(4):
'To meet this condition, TVA will submit a list of those TS changes previously made on all three BFN units for which Unit 1 specific analyses had not been completed. That submittal will verify that the Unit 1 analyses and associated plant modifications for those TS changes have been completed. In the unlikely event that changes to Unit 1 TS are required, those changes will be requested under 10 CFR 50.90."
- TVA's proposed resolution satisfies the intent of the License Condition:
To ensure the specified changes to the Unit 1 Technical Specifications identified during ITS conversion are supported and reflected by the plant's design basis prior to returning the associated equipment to service.
- Unit 1 Technical Specification changes made without supporting analysis are well defined.
- Proposed resolution clearly defines the scope required to satisfy the License Condition.
- The proposed resolution is consistent with information typically provided by licensees for Technical Specification changes.
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Proposed Resolution of License Condition (Cont.)
ALTERNATE RESOLUTION 1 As an alternative, NRC could delete the License Condition or TVA could request deletion of the License Condition
- The License Condition is a duplication of existing regulatory requirements, which apply to other operating units o 10 CFR 50.36(b) - The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted
,pursuant to Part 50.34.
o 10 CFR 50.90 - Whenever a holder of a license or construction permit desires to amend the license (including the Technical Specifications incorporated into the license) or permit, application for an amendment must be filed with the Commission, as specified in Part 50.4, fully describing the changes desired, and following as far as applicable, the form prescribed for original application.
o Section 1.C of Operating License DPR The Atomic Energy Commission (the Commission) having found that the facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.
o Section 2.C.(2) of Operating License DPR The licensee shall operate the facility in accordance with the Technical Specifications.
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Proposed Resolution of License Condition (Cont.)
ALTERNATE RESOLUTION 2 As a second alternative, TVA could submit:
- A summary of the remaining Unit 1 analyses for the Alternative Source Term as specified in TS 405.
- TS 433 (24 month fuel cycle) to address calibration frequencies /
instrument checks identified during ITS conversion as requiring supporting analyses.
- TS 447 to address RCIC and HPCI Torus and Pump Room High temperature functions.
- TS 440 to address the RWCU Main Steam Valve Vault Area High Temperature Isolation channel calibration frequency.
TVA would request removal of the License Condition as part of the approval of the last submittal.
Revision to License Condition 2.C(4) required?
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Discussion 18
Backup Information Unit 1 Technical Specification changes approved after the ITS conversion (Amendment 234) have been reviewed to identify any outstanding Unit 1 supporting analyses:
- 24 Month Fuel Cycle (Amend 235) - No additional analyses required.
- Single Loop Operation (Amend 236) - To be included with reload analysis.
- Update of License Conditions (Amend 237) - No additional analyses required.
- Secondary Containment Access Doors (Amend 238) - No additional analyses required.
- Incorporation of Generic TS Changes (Amend 239) - No additional analyses required.
- TSTF Item 318 - LPCI Inoperable in Each of Two ECCS Divisions (Amend 240) - No additional analyses required.
- RHR Suppression Pool Cooling (Amend 241) - No additional analyses required.
- Fuel Movement with Inoperable Refueling Equipment Interlocks and Use of Control Rod Withdrawal Blocks and Control Rods Inserted (Amend 242) - No additional analyses required.
- Revise Surveillance Requirement 3.0.3 to Extend the Period before Entering an LCO for a Missed Surveillance (Amend 243) - No additional analyses required.
- Deletion of Pressure Regulator Downscale Failure as an Operational Transient (Amend 244) - No additional analyses required, but TVA committed to upgrade Unit 1 EHC system prior to return to power operation.
- Eliminating Post-Accident Sampling System Requirements (Amend 245)
- No additional analysis required, but TVA committed to develop plans for analyzing samples and classifying fuel damage events prior to Unit 1 fuel load.
- Control Room Ventilation System Envelope AOT (Amend 246) - No additional analysis required.
- Framatome Fuel Design and Storage (Amend 247) - No additional analysis required.
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History of License Condition (Cont.)
Differences between the three BFN units and the requirements for common equipment are explicitly identified and discussed throughout the Safety Evaluation. Examples include:
- Table A - Matrix of Administrative Changes (Page 27 of 82)
Core Spray has one timer per pump with normal and diesel power. Units 1 and 2 LPCI has two times on two pumps (C & D on Unit 2 and A & B on Unit 1) and one timer on two pumps (A & B on Unit 2 and C & D on Unit 1) with normal and diesel power. Unit 3 LPCI has two timers on each of the four pumps with normal and diesel power.
- Table A - Matrix of Administrative Changes (Page 67 of 82)
The Unit 1 and 2 diesel generator requirements for Unit 3 Technical Specifications to support Standby Gas Treatment (SGT) and Control Room Emergency Ventilation (CREVS) are presented in ITS 3.8.1.c. Unit 1 and 2 ITS will require the operability of all Unit 1 and 2 diesel generators and provide appropriate compensatory actions for inoperable Unit 1 and 2 diesel generators in support of Unit 1 and 2 operations. To support the operation of Unit 3, the Unit 3 LCO for AC Sources -
Operating also requires the necessary Unit 3 diesel generators to support SGT and CREVS required by LCO 3.8.7, Distribution Systems - Operating, for supplying the Unit 1 and 2 4.16kV shutdown boards. Since the Unit 3 Custom Technical Specifications only impose Actions for an inoperable Unit 1 and 2 diesel generator when Unit 1 and 2 are in cold shutdown, refueling or defueled, this presentation is consistent with current requirements.
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