ML063610039

Technical Specifications Change 456 - Request for Adoption of TSTF-484 Revision 0 - Use of TS 3.10.1 for Scram Time Testing Activities

ML063610039
Person / Time
Site:	Browns Ferry
Issue date:	12/21/2006
From:	Crouch W Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TVA-BFN-TS-456
Download: ML063610039 (15)

Text

Tennessee Valley Authority, Post Office Box 2000, Decatur, Aabama 35609-2000 December 21, 2006 TVA-BFN-TS-456 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 456 - REQUEST FOR ADOPTION OF TSTF-484 REVISION 0 - USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Pursuant to 10 CFR 50.90, the Tennessee Valley Authority (TVA) is submitting a request for a TS change (TS-456) to licenses DPR-33, DPR-52, and DPR-68 for BFN Units 1, 2, and 3, respectively.

The proposed amendment would revise Limiting Condition for Operation 3.10.1 and the associated TS Bases to expand its scope to include provisions for temperature excursions greater than 212'F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to TS Task Force (TSTF) Improved Standard Technical Specifications Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of this TS 3.10.1 revision was TxY-3 C)

U.S. Nuclear Regulatory Commission Page 2 December 21, 2006 announced in the Federal Register on October 27, 2006, (71 FR 63050) as part of the consolidated line item improvement process. provides an evaluation of the proposed change. provides the existing Unit 2 TS pages marked-up to show the proposed changes. Identical changes are being requested for the Units 1 and 3 TS. Enclosure 3 provides the existing Unit 2 TS Bases pages marked-up to show the proposed changes. Identical changes are being proposed for the Units 1 and 3 TS Bases.

TVA is asking that this TS change be approved by April 1, 2007, 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 no regulatory commitments contained in this submittal.

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 December 21, 2006.

Sincerely, William D. Crouch Manager of Licensing and Industry Affairs

Enclosures:

1. Evaluation of Proposed Change

2. Proposed Technical Specifications Changes (mark-up)

3. Changes to Technical Specifications Pages (mark-up)

U.S. Nuclear Regulatory Commission Page 3 December 21, 2006 Enclosures cc: (Enclosures)

State Health Officer Alabama State Department 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 30303-8931 Mr. Malcolm T. Widmann, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite Atlanta, Georgia 30303-8931 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Ms. 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 456 Request for Adoption of TSTF-484 Revision 0 Use of TS 3.10.1 for Scram Time Testing Activities Evaluation of Proposed Change

1.0 DESCRIPTION

The proposed amendment would revise Limiting Condition for Operation 3.10.1 and the associated TS Bases to expand its scope to include provisions for temperature excursions greater than 212'F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to TS Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF- 484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of this TS improvement was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, "Inservice Leak and Hydrostatic Testing Operation." Proposed revisions to the TS Bases are also included in this application.

Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

This application is being made in accordance with the CLIIP.

TVA is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the NRC staff's model safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

4.0 TECHNICAL ANALYSIS

TVA has reviewed the SE published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

TVA has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to BFN Units 1, 2, and 3 and, therefore, justify this amendment for the incorporation of the proposed changes to the BFN TS.

5.0 NO SIGNIFICANT HAZARD CONSIDERATION 5.1 No Significant Hazards Determination TVA has reviewed the no significant hazards determination published on August 21, 2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

TVA has concluded that the 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).

5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

6.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the SE published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. 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.

E1-2

7.0 REFERENCES

1. Federal Register Notice, Notice of Availability published on October 27, 2006 (71 FR 63050).

2. Federal Register Notice, Notice for Comment published on August 21, 2006 (71 FR 48561).

3. TSTF-484 Revision 0, "Use of TS 3.10.1 for Scram Times Testing Activities."

E1-3

Enclosure 2 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 456 Request for Adoption of TSTF-484 Revision 0 Use of TS 3.10.1 for Scram Time Testing Activities Proposed Technical Specifications Changes (mark-up)

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," ma. be susl ended, to allow p e

=90f ay in vice Ieaor h dr tati-tes ovied Me ollowing MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212 0 F.

0 As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or

• As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, BFN-UNIT 2 3.10-1 Amendment No. 253

Enclosure 3 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 456 Request for Adoption of TSTF-484 Revision 0 Use of TS 3.10.1 for Scram Time Testing Activities Changes to Technical Specifications Pages (mark-up)

Insert 1 or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212'F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212'F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.

Insert 2 However, even with required minimum reactor coolant temperatures < 2127F, maintaining RCS temperatures within a small band during the test can be impractical.

Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Insert 3 The RCS hydrostatic and/or RCS system leakage tests require increasing reactor pressure to approximately 1050 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures > 800 psig. Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212°F (normally corresponding to MODE 3)XE Inservice hydrostatic testing and system leakage pressure tests required by Section Xl of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (PIT) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure.

Periodic updates to the RCS P/T limit curves are performed as necessary, based upon the results of analyses of irradiated surveillance specimens removed from the vessel. Hydrostatic and leak testin eventually be required with minimum reactor coolant temperatures > 212 0 F.

,c (continued)

BFN-UNIT 2 B 3.10-1 Revision 0

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES (continued)

APPLICABLE Allowing the reactor to be considered in MODE 4  !

SAFETY ANALYSES (h ost, or I"e , when the reactor coolant tem erature is > 212°F ,effectively provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems. Since the stto.a"ests are during, or as a consequence of, performed nearly water solid (except for an air bubble for hydrostatic or leak testing, or as pressure control), at low decay heat values, and near MODE 4 a consequence of control rod conditions, the stored energy in the reactor core will be very scram time testing initiated in low. Under these conditions, the potential for failed fuel and a conjunction with an inservice leak subsequent increase in coolant activity above the LCO 3.4.6, orhydrostatic test, '"RCS Specific Activity," limits are minimized. In addition, the

- - secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS - Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

(continued)

BFN-.UNIT 2 B 3.10-2 Revision 0

Insert 4 Additionally, even with required minimum reactor coolant temperatures < 212TF, RCS temperatures may drift above 212TF during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE For the purposes of this test, the protection provided by SAFETY ANALYSES normally required MODE 4 applicable LCOs, in addition to the (continued) secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other, LCOs. A discussion of the criteria.

satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures > 212 0 F, while the ASME inservice test itself requires the safety/rel, valves to be gagged, preventing their OPERABILITY. I se , T If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolaEttemperatures

> 212'F for the purpose of performing ' an inservice leak or hydrostatic testy (continued)

BFN-UNIT 2 Revision 0

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO This LCO allows primary-containment to be open for frequent (continued) unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirementso, y----*

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APPLICABILITY The MODE 4 requirements may only be modified for the

- performance of inservice leak or hydrostatic tests so that these or as a consene o0 ns can e considered as in MODE 4, yven though the o-as aconsequenac colant temperature is> . additional conto rd s ti , requirement for secondary containment OPERABILITY Sinitiated according to the imposed MODE 3 requirements provides testing conjunction with with anan conservatism in the response of the unit to any event that may inervce leak or ,( occur. Operations in all other MODES are unaffected by this hdservice leak or hydrostatic test LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered,"subsequent divisions,-'subsystems; components, or variables expressed in the Condition discovered-to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

(continued)

BFN-UNIT 2 B 3.10-4 Revision 0