ML042030311

(BFN) - Units 1, 2, and 3 - Technical Specifications (TS) Change 422 - Application for TS Improvement to Eliminate Requirements for Hydrogen Monitors Using the Consolidated Line Item Improvement Process

ML042030311
Person / Time
Site:	Browns Ferry
Issue date:	07/08/2004
From:	Abney T Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TVA-BFN-TS-422
Download: ML042030311 (11)

Text

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 July 8, 2004 TVA-BFN-TS-422 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 (BFN) - UNITS 1, 2, AND 3 - TECHNICAL SPECIFICATIONS (TS) CHANGE 422 - APPLICATION FOR TS IMPROVEMENT TO ELIMINATE REQUIREMENTS FOR HYDROGEN MONITORS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Pursuant to 10 CFR 50.90, the Tennessee Valley Authority (TVA) is submitting a request for a TS change (TS-422) to licenses DPR-33, DPR-52, and DPR-68 for BFN Units 1, 2, and 3, respectively.

The proposed amendment will delete the TS requirements related to hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as-part of the Consolidated Line Item Improvement Process.

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U.S. Nuclear Regulatory Commission Page 2 July 8, 2004 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Enclosure 2 provides the existing Unit 2 TS pages marked-up to show the proposed changes.

Identical changes are being requested for BFN Units 1 and 3 TS.

Implementation of TSTF-447 also involves various changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program."

TVA is asking that this TS change be approved by October 1, 2004, and that the implementation of the revised TS be made 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 Enclosures to the Alabama State Department of Public Health.

There are regulatory commitments contained in Section 6.1 of . If you have any questions about this TS change, please contact me at (256)729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 6, 2004.

Si cerel Manager of L' and I try Affa rs Enclo ures:

1. De cription and sessment

2. Prop Te al Specifications Changes (mark-up)

U.S. Nuclear Regulatory Commission Page 3 July 8, 2004 Enclosures cc: (Enclosures)

State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415 Mr. Stephen J. Cahill, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 Kahtan N. Jabbour, Senior 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

Enclosure 1 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 422 Eliminate Requirements for Hydrogen Monitors Using the Consolidated Line Item Improvement Process Description and Assessment

1.0 DESCRIPTION

The proposed license amendment deletes TS references to the hydrogen monitors in TS 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

• TS 3.3.3.1, Condition C - The Note referencing hydrogen monitors is deleted

• TS 3.3.3.1, Condition D, Inoperable Hydrogen Monitors, is deleted

• TS 3.3.3.1, Condition E, Reference to deleted Condition D is removed

• Table 3.3.3.1-1 Item 7, Drywell and Torus H2 Analyzer is deleted Existing BFN TS vary from Standard TS (STS) in that a different Channel Calibration Surveillance Requirement (SR) frequency is prescribed for the hydrogen monitors than that specified in STS as differentiated in BFN SRs 3.3.3.1.2 and 3.3.3.1.4. The deletion of the hydrogen monitors from TS likewise requires these two SRs be modified as shown in the attached TS mark-ups to remove the references to the

hydrogen monitors. These additional changes are administrative and are consistent with TSTF-447.

To avoid renumbering and formatting changes that result from the deletion of the above requirements related to hydrogen monitors, the term "deleted" will be inserted as shown in the TS mark-ups. BFN does not have hydrogen recombiners, so no changes to TS are necessary in this regard. Also, requirements for the Drywell and Torus oxygen monitors have been previously removed from BFN TS and are located in the Technical Requirements Manual (TRM). Therefore, no additional TS changes are needed for the relocation of oxygen monitors. As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements result in changes to various TS Bases sections. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program."

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416) (Reference 1), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447 (Reference 1), the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

As noted in Section 2.0, BFN does not utilize hydrogen recombiners, and the Drywell and Torus oxygen monitors have been previously removed from TS (Reference 2). In addition, NRC has approved the designation of the oxygen monitors as Regulatory Guide 1.97 Category 3 instruments (Reference 3) for BFN. In the revision to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003, NRC indicated that existing oxygen monitoring commitments for currently licensed plants were sufficient to meet the revised rule.

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TVA has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staff's SE, as well as the supporting information provided to support TSTF-447. TVA has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to BFN and justify this amendment for the incorporation of the changes to the BFN 1, 2, and 3 TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416) (Reference 1), TSTF-447, Rev. 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, TVA is making the following verifications and regulatory commitments. BFN Unit 1 is currently in a prolonged outage and the hydrogen/oxygen monitors are not in service. Therefore, the below commitments reflect the current operating status of the three BFN units.

1. TVA has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at BFN Units 2 and 3, and will be installed on Unit 1 prior to restart. TVA is making a regulatory commitment to maintain that capability to the level of Regulatory Guide 1.97, Category 3. The hydrogen monitors will be included in the TRM. This regulatory commitment will be implemented at the same time as TS-447 is implemented at BFN.

2. TVA has verified that an oxygen monitoring system capable of verifying the status of the inerted containment is installed at BFN Units 2 and 3, and will be installed on Unit 1 prior to restart. TVA is making a regulatory commitment to maintain that capability to the level of Regulatory Guide 1.97, Category 3. The oxygen monitors are currently included in the BFN Unit 1, 2, and 3 TRMs.

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7.0 NO SIGNIFICANT HAZARDS CONSIDERATION TVA has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) (Reference 1) as part of the CLIIP. TVA has concluded that the proposed determination presented in the notice is applicable to BFN Units 1, 2, and 3, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416)

(Reference 1) as part of the CLIIP. TVA has concluded that the 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.

9.0 PRECEDENT This application is being made in accordance with the CLIIP.

TVA is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416)

(Reference 1).

10.0 REFERENCES

1. Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

2. June 22, 1978, Letter from NRC to TVA, Safety Evaluation Report Approving TS Change 108 (Removal of Oxygen Monitors from TS).

3. February 8, 1990, Letter from NRC to TVA, Emergency Response Capability - Conformance to Regulatory Guide 1.97, Revision 3 (TAC Nos. 51073, 51074, 51075).

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Enclosure 2 Browns Ferry Nuclear Planit (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 422 Eliminate Requirements for Hydrogen Monitors Using the Consolidated Line Item Improvement Process Proposed Technical Specifications Changes (mark-up)

PAM Instrumentation 3.3.3.1 C.1 Restore one required days channel to OPERABLE status.

One or more Functions with two required channels inoperable.

I l II -

D. t E. Required Action and EA Enter the Condition Immediately associated Completion referenced in Time of Condition &K) Table 3.3.3.1-1 for the not met. channel.

F. As required by Required F.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action EA and referenced in Table 3.3.3.1-1.

G. As required by Required G.1 Initiate action in Immediately Action E.1 and referenced accordance with In Table 3.3.3.1-1. Specification 5.6.6.

BFN-UNIT 2 3.3-25 Amendment No. 253

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK for each required 31 days PAM instrumentation channel.

/and CHNMLCALIBRAT1I'ofth Toru H2 analyzer unctions. co"D SR 3.3.3.1.3 Perform CHANNEL CALIBRATION of the 184 days Reactor Pressure Functions.

SR 3.3.3.1.4 Perform CHANNEL CALIBRATION for each 24 months required PAM instrumentation channel except for the Reactor Pressur(1i ct nct orly -

BFN-UNIT 2 3.3-26 Amendment No. 255 November30, 1998

PAM Instrumentation 3.3.3.1 TabW 3.3.3.1- (po 1 of 1)

Post Accidernt Monoirxkg Insbimentaim CONDITIONS REQUIRED REFERENCED FUNCTION CHANNELS FROM REOUIRED ACTION El

1. RlacorPressure 2 F

2. Penctor Vaess Wese Love

&- Emergency Sysbma Rwaig 2 F

b. Post-Accident Fidod Raig. 2 F

3. Stwesim Pad Wah Lmw 2 F A. DrywW Prssure

a. Nc#nd Rai9 2 F

b. WkideRaig 2 F

5. Prirnwy Caotrvnet Afmee k~ 2 G I. PCIV Pammcx 2 per pWrj*Jfaw paO') F 7.CMY^ A9H = I- - 2 e -

F

8. Spproessio Padl Wate Terr9.bxo 2 F

9. Drywul Aknosphare Ternperatuir 2 (a) Not rertked far Idabon~vavswhosa assockI.d peneam fkiwpeiti d~atd by ~Iatl meoredo and deactvas Uteurfibc vavs. cbsead maiual v". bid flaig. et wCkAI whoo wilh flaw tirou toe V"I &curad (b) Onlyoreposition kxickdon dim-wdis requed for peetration flw pda 3iiti ony oine rsb.d td room PAMCgarqy I kkdcalon charmal.

BFN-UNIT 2 3.3-27 Amendment No. 253