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: 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

=

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.

=

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 (ifneeded) when generic resolution defined 7

Closing Remarks

_ 4,;

-7 , __w- . = -$. -_- I-:., - I-, ..... I. _ -

..................... . -, -_ _, 7...........

T- , 7,:. .- - .-_:. : :_: ., : :. _ . _ :.=__ : s . .

8