ML050590036

Enclosure 2, 02/01/2005 Conference Call with TVA Presentation Slides on TS Changes Using Method 3 for Interim Solution

ML050590036
Person / Time
Site:	Browns Ferry
Issue date:	02/16/2005
From:	Chernoff M NRC/NRR/DLPM/LPD2
To:	Tennessee Valley Authority
Brown E, NRR/DLPM, 415-2315
Shared Package
ML050480652	List: ML050380283 ML050590036
References
ISA-S67.04-1994, ML041690604, TAC MC1330, TAC MC1427, TAC MC2305, TAC MC3743, TAC MC3744, TAC MC3812, TAC MC4070, TAC MC4071, TAC MC4072, TAC MC4161 10 CFR 50.36, 10 CFR 50.59, TS-418, TS-431, TS-434, TS-437, TS-443, TS-447
Download: ML050590036 (8)

Text

Agenda

• • Purpose

• Background

• Proposed Resolution

• Open Discussion/Conclusion 1

Introduction

• - Significant Issue Potential cost to TVA in millions Potential delay to Unit 1 restart

• Resolution Needed Expeditiously to Prevent Further Delays 2

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Background===

• NEI Letter to NRC Dated December 5, 2003 White paper addressing technical basis of Method 3 and Standard Technical Specification (STS) structure Requested NRC not hold-up review of in-process license amendments

• NRC Letter to NEI Dated February 20, 2004 Setpoint issue does not raise significant generic concerns that would prevent issuance of amendments Longer term actions to resolve generic issue to be addressed with NEI, ISA, and other interested stakeholders

• NRC Letter to NEI Dated June 17, 2004 Reviews of license amendments continuing Concerns identified by NRC for further consideration on generic issue

• NEI Letter to NRC Dated December 17, 2004 Provided independent review of Method 3 Concluded Method 3 is acceptable method to establish setpoints and allowable values (AVs)

Requested meeting with NRC management to discuss conclusions

• BFN Status Method 3 Plant ITS based on Rev 1 NUREG-1433 BWR/4 STS (Modern Format STS)

SR Procedures require trip setpoints be adjusted to within established calibration tolerance band 3

Background (cont'd)

• NRC Letter to TVA Dated January 6, 2005 Put hold on six BFN TS changes based on TVA use of Method 3 NRC not able to accept TS changes that are based upon the use of Method 3, unless the method is modified to alleviate the staffs technical concerns Each setpoint limit in the TS must ensure at least 95% probability with at least 95% 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 Operability of each instrument channel addressed in the setpoint-related TS must be ensured by the TS Reliance on settings or practices outside the TS and not mandated by them is inadequate Indicated alternative approach (Performance-Based TS) similar to recent Ginna TS acceptable. 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.

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Background===

• BFN TS on Hold

> TS-437 - Lower SDV Float Switch Level AVs (Unit 1)

> TS-434 - Lower Reactor Vessel Water Level - Low Level 3 AV (Unit 1)

> TS-418-Extended Power Uprate (Units 2 and 3)

> TS-431 - Extended Power Uprate (Unit 1)

> TS-433 Month Operating Cycle (Unit 1)

> TS-447 - Extend HPCI/RCIC/RWCU Area Temperature Surveillance Calibration Frequencies (Units 1, 2, and 3) 5

Proposed Resolution

• Interim Solution Needed for BFN TS Changes Objectives of Interim Solution Maintain assurance of compliance with TS Maintain consistency for all AVs Maintain consistency of BFN Units 1, 2, and 3 TS Provide assurance that current practice cannot be changed without NRC approval Minimize rework required to implement generic resolution Proposed Bases Change to Applicable SR Bases Readjustment provision is basically a procedural requirement Typical of type of provisions that go into TS Bases STS NUREGs Rev.3, March 2004, includes provisions on readjustments TS Bases changes are subject to 50.59 review in accordance with TS 5.5.10 Draft change developed to make it definitive that setpoint methodology depends on readjustment Bases changes can be implemented locally - reduces licensee expense If NRC needs additional assurances, recommend referencing Bases change in TS SER TS changes should be initiated generically through industry STS Committees Consensus approach via TSTF Consistency of usage via STS and NEI 01-03 Cost sharing Could apply change to all affected TS 6

Proposed Resolution (cont'd)

• Proposed Bases Change Meets all Objectives and Requirements Use of AVs to satisfy 10 CFR 50.36 requirements is a well-established position as endorsed in the STS NUREGs Procedural details for meeting TS Requirements are included in UFSAR, TS Bases, Programs, or plant procedures Common practice throughout STS to provide detail regarding Operability requirements in the TS Bases BFN Interim Solution explicitly defines basis for TS AV and relationship to Method 3 Applies to all TS AVs (not only ones being changed by current TS change)

Can be implemented in all 3 units' TS to maintain consistency and eliminate confusion Provides assurance that cannot be changed without NRC approval TS 5.5.10, TS Bases Control Program requires 50.59 evaluation for Bases changes 50.59(c)(2)(viii) states "change in methodology" requires license amendment Proposed Bases change can be done expeditiously Can be easily revised (if needed) when generic resolution defined 7

Closing Remarks

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