ML050030361

Ltr, Request for Information for Status of Amendment (Tac No. MC1330, MC1427, MC2305, MC3812, MC4070, MC4071, MC4072, MC4161, MC3743, MC3744)

ML050030361
Person / Time
Site:	Browns Ferry
Issue date:	01/06/2005
From:	Marshall M NRC/NRR/DLPM/LPD2
To:	Singer K Tennessee Valley Authority
Pickett , NRR/DLPM, 415-1364
References
TAC MC1330, TAC MC1427, TAC MC2305, TAC MC3743, TAC MC3744, TAC MC3812, TAC MC4070, TAC MC4071, TAC MC4072, TAC MC4161
Download: ML050030361 (5)

Text

January 6, 2005 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY UNITS 1, 2, AND 3 - REQUEST FOR INFORMATION REGARDING STATUS OF AMENDMENTS USING METHOD 3 (TAC NOS. MC1330, MC1427, MC2305, MC3812, MC4070, MC4071, MC4072, MC4161, MC3743, AND MC3744)

Dear Mr. Singer:

The Tennessee Valley Authority (TVA, the licensee) has submitted six license amendment requests (TS-418, TS-431, TS-434, TS-437, TS-443, TS-447) since November 2003 using instrumentation setpoints established by means of the Instrumentation, Systems and Automation Society of America (ISA) Standard, ISA-S67.04-1994, Setpoints for Nuclear Safety-Related Instrumentation. The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the setpoint Allowable Values (AV) established by means of ISA 67.04 Part 2 Method 3 (Method 3) do not provide adequate assurance that a plant will operate in accordance with the assumptions upon which the plant safety analyses have been based. The NRC staffs safety concerns have been described in a letter from Mr. Ledyard Marsh to Mr. Alex Marion of the Nuclear Energy Institute (NEI), which is available on the public website under ADAMS Accession Number ML041690604. The issue has also been discussed in various public meetings held in June and July 2004.

The NRC staff is currently in discussions with the industry and other external stakeholders formulating generic action on this subject. It is presently clear, however, that the NRC staff will not be able to accept any requested Technical Specification (TS) changes that are based upon the use of Method 3, unless the method is modified to alleviate the NRC staffs technical concerns. In particular, each setpoint limit in the TS must ensure at least 95 percent probability with at least 95 percent confidence that the associated action will be initiated with the process variable no less conservative than the initiation value assumed in the plant safety analyses. In addition, the operability of each instrument channel addressed in the setpoint-related TS must be ensured by the TSs. That is, conformance to the TS must provide adequate assurance that the plant will operate in accordance with the safety analyses. Reliance on settings or practices outside the TS and not mandated by them is inadequate.

The NRC staff has determined that AV computed in accordance with ISA Method 1 or 2 do provide adequate assurance that the safety analysis limits will not be exceeded and that an entirely different approach can be adopted that provides the required assurance. This alternative approach is based upon the performance of an instrument channel rather than

K. Singer directly upon the measured trip setting and is designated Performance-Based TS. The Performance-Based TS sets limits on acceptable nominal setpoints, and the observed deviation in the measured setpoint from the end of one test to the beginning of the next. This approach has been accepted for use at Ginna (ADAMS Accession Number ML041180293). In conversations with TVA, the NRC staff has discussed several alternative approaches similar to the Ginna approach that provide a reasonable assurance of safety. As always, TVA is welcome to propose other alternative approaches that provide the indicated confidence, but such alternatives must be presented in detail and must be shown explicitly to provide adequate assurance that the safety analysis assumptions will not be violated.

In a discussion with the TVA staff, the possibility of delaying a revision to these submittals until completion of generic actions by the NEI was discussed. NEI has recently submitted a White Paper concerning this mater for NRC consideration on December 17, 2004. As always, TVA may choose to endorse whatever approach and justification is described in that White Paper, or to act independently of the NEI. However, the NRC staff has six amendment requests tied to the resolution of the issue. Since these requests, as currently submitted, are based on a methodology that the NRC staff has found unacceptable, the NRC staff requests that TVA revise the applications to address the NRC staffs safety concerns or provide a schedule for submittal of the revised applications, or withdraw the requests and resubmit when the generic issue has been resolved. Otherwise, the NRC staff can proceed regarding the ongoing reviews with the current approach. The NRC staff discussed this request with Mr. Tim Abney on January 04, 2005, and he agreed that a response would be provided within 30 days of the date of this letter.

If you have any questions, please contact Ms. Eva Brown, at (301) 415-2315 or Ms. Margaret Chernoff at (301) 415-4041.

Sincerely,

/RA MChernoff for/

Michael L. Marshall, Jr., Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260 and 50-296 cc: See next page

ML050030361 NRR-106 OFFICE PDII-2/PM PDII-2/PM PDII-2/LA PDII-2/SC NAME EBrown MChernoff BClayton MChernoff for MMarshall DATE 1/5/05 1/5/05 1/5/05 1/6/05

Mr. Karl W. Singer BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, General Manager Nuclear Engineering Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Michael D. Skaggs Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority ET 11A 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Kurt L. Krueger, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Jon R. Rupert, Vice President Browns Ferry Unit 1 Restart Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Robert G. Jones Browns Ferry Unit 1 Plant Restart Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Fredrick C. Mashburn Senior Program Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611