ML083090105
| ML083090105 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/30/2008 |
| From: | Brandon M Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TSTF-475, Rev 1, TVA-BFN-TS-462 | |
| Download: ML083090105 (14) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 October 30, 2008 TVA-BFN-TS-462 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE 462 - REQUEST FOR ADOPTION OF TSTF-475 REVISION 1 - REVISION OF CONTROL ROD NOTCH SURVEILLANCE TEST FREQUENCY AND A CLARIFICATION OF A FREQUENCY EXAMPLE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Pursuant to 10 CFR 50.90, TVA is submitting a request for a TS change (TS-462) to licenses DPR-33, DPR-52, and DPR-68 for BFN Units 1, 2, and 3, respectively.
The proposed amendment would: (1) revise the TS surveillance requirement frequency in TS 3.1.3, "Control Rod Operability," and (2) revise Example 1.4-3 in TS Section 1.4, "Frequency,"
to clarify the applicability of the 1.25 surveillance test interval extension. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing Unit 1 TS pages marked-up to show the proposed change. The same exact TS changes are being requested for Units 2 and 3. Enclosure 3 provides the existing Unit 1 TS Bases pages marked-up to show the proposed changes. Identical changes are being proposed for the Unit 2 and 3 TS Bases. Enclosure 4 provides a summary of the regulatory commitments made in this submittal.
ThO?0
U.S. Nuclear Regulatory Commission Page 2 October 30, 2008 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.
TVA requests approval of this TS change by April 1, 2009, and that the implementation of the revised TS be made within 60 days of NRC approval.
If you have any questions about this TS change, please contact me at (256)729-7658.
I declare under penalty of perjury that the foregoing is true and correct. Executed on October 30, 2008, Sincerely, M. K. Brandon Interim Manager of Licensing and Industry Affairs
Enclosures:
- 1. Description and Assessment
- 2. Proposed Technical Specifications Changes (mark-up)
- 3. Proposed Changes to Technical Specifications Bases Pages (mark-up)
U.S. Nuclear Regulatory Commission Page 3 October 30, 2008 Enclosures cc (Enclosures):
State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 Ms. Eva Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Eugene F. Guthrie, 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 Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Browns Ferry Nuclear Plant (BFN)
Units 1, 2, and 3 Technical Specifications (TS) Change 462 Request for Adoption of TSTF-475 Revision 1 Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process Description and Assessment-
1.0 DESCRIPTION
The proposed amendment would: (1) Revise the TS surveillance requirement (SR) 3.1.3.2 frequency in TS 3.1.3, "Control Rod Operability," and (2) revise Example 1.4-3 in TS Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension.
The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard TS (STS) change TSTF-475, Revision1.The Federal Register notice published on November 13, 2007, announced the availability of-this TS improvement through the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation TVA has reviewed the safety evaluation dated November 5, 2007, as part of the CLIIP.
This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-475, Revision.-T-VA-has-concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to BFN Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the BFN TS.
2.2 Optional Chanaes and Variations TVA is not proposing any variations or deviations from the TS changes described in the modified TSTF-475, Revision 1 and the NRC staff's model safety evaluation dated November 5, 2007.
The approved TSTF-475 included three changes:
):( t-eIpropbs c86d ge tothe frequency of SR 3.1.3.2, (2) clarifies the requirement to fully insert all insertable control rods for the Limiting Condition for Operation in TS 3.3.1.2, Required Action E.2, "Source Range Monitoring Instrumentation," and (3) revises Example 1.4-3 in TS Section 1.4, "Frequency", to clarify the applicability of the 1.25 surveillance test interval extension.
E1-i
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination TVA has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. TVA has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to BFN Units 1, 2, and 3 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on November 13, 2007 for this TS improvement, the TVA verifies the applicability of TSTF-475 to BFN Units 1, 2, and 3, and commits to establishing Bases for TS as proposed in TSTF-475, Revision 1.
These changes are based on TSTF change traveler TSTF-475 Revision 1 that proposes revisions to the STS by: (1) Revising the frequency of SR 3.1.3.2, notch testing of fully withdrawn control rods, from "7 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM" to "31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM," and (2) revising Example 1.4-3 in TS Section1.4 "-F'requency". to clarify that the 1.25 surveillance test interval extension in SR 3.0.2is i-pplicable to. time peioids discussed in NOTES in the "SURVEILLANCE" column in addition to the time periods in the "FREQUENCY" column.
4.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the model safety evaluation dated November 5, 2007, 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.
E1-2 Browns Ferry Nuclear Plant (BFN)
Units 1, 2,.and 3 Technical Specifications Change.462 Request for Adoption of TSTF-475 Revision 1 Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process Proposed Technical Specifications Changes (mark-up)
Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
- - N O TE ---------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after Ž> 25% RTP.
Perform channel adjustment.
7 days The interval continues whether or not the unit operation is
< 25% RTP between performances.
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches > 25% RTP to perform the Surveillance. The Surveillance is still considered to be within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power Ž: 25% RTP.
Once the nit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing e Surveillance. If the Surveillance were not performed wit l-this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform r'44veillance wi, i~n the specified Frequency and the provisionsof S
.* w Id apply.
(continued)_
BFN-UNIT 1Amendment No. 234-, 2 November 21, 2000
0 Q ontrol Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION
-.- '--*TIME A. (continued)
A.3 Perfo m...--
/
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from SR 3....
discovery of withdrawn OPERABLE Condition A control rod.
concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM AND A.4 Perform SR 3.1.1.1.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Two or more withdrawn B.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 /> control rods stuck.
C. One or more control rods C.1 NOTE inoperable for reasons RWM may be bypassed other than Condition A or as allowed by B.
LCO 3.3.2.1, if required, to allow insertion of inoperable control rod and continued operation.
Fully insert inoperable 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> control rod.
AND C.2 Disarm the associated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CRD.
(continued)
BFN-UNIT 1 3.1-8 Amendment No. 234--
0 Q ontrol Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SR 3.1.3.4 Verify each control rod scram time from fully withdrawn to notch position 06 is < 7 seconds.
In accordance with SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)
BFN-UNIT 1 3.1-10 Amendment No. -
Browns Ferry Nuclear Plant (BFN)
Units 1, 2, and 3 Technical Specifications Change 462 Request for Adoption of TSTF-475 Revision 1 Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item. Improvement Process Proposed Changes to Technical Specifications Bases Pages (mark-up)
Oontrol Rod OPERABILITY B 3.1.3 BASES ACTIONS A.1, A.2, A.3, and A.4 (continued)
Hydraulically disarming does not normally include isolation of the cooling water. The allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is acceptable, considering the reactor can still be shut down, assuming no additional control rods fail to insert, and provides a reasonable time to perform the Required Action in an orderly manner. The control rod must be isolated from both scram and normal insert and withdraw pressure. Isolating the control rod from scram prevents damage to the CRDM.
Monitoring of the insertion capability of each withdrawn control rod must also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> fro i 0VDof Condition A concurrent with THERMAL Pj VVR greater than the low power se oThitLPSP) of the RV M.,aSR-m2-and-
",)
SR 3.1.3.3 perf rm4perijdic tests of the c in ertion capability of wit draw control rods. Testing each withdrawn control rod ensures that a generic problem does not exist. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." The Required Action A.3 Completion Time only begins upon discovery that THERMAL POWER is greater than the actual LPSP of the RWM since the notch insertions may not be compatible with the requirements of rod pattern control (LCO 3.1.6) and the RWM (LCO 3.3.2.1). The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition A concurrent with THERMAL POWER greater than the LPSP of the RWM provides a reasonable time to test the control rods, considering the potential for a need to reduce power to perform the tests.
(continued)
BFN-UNIT 1 B 3.1-19 Revision 0
0 Control Rod OPERABILITY B 3.1.3 BASES (continued)
SURVEILLANCE REQUIREMENTS SR 3.1.3.1 The position of each control rod must be determined to ensure adequate information on control rod position is available to the operator for determining control rod OPERABILITY and controlling rod patterns. Control rod position may be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR is based on operating experience related to expected changes in control rod position and the availability of control rod position indications in the control room.
,,R 2 -aJR 3.1.3.3 IKI~e~r (D~le+ecL').
Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves. The control rod may then be returned to its original position. This ensures the
"-hi-h I surveilI*4-e 5 control rod is not stuck and is free to insert on a scram signal.
These Sti--ehanees-*e* not required when THERMAL POWER
- e. v is less than or equal to the actual LPSP of the RWM, since the notch insertions may not be compatible with the requirements of banked position withdrawal sequence (BPWS) (LCO 3.1.6) and the RWM (LCO 3.3.2.1). ITFvr v Fr*ciu`pcv)SR MM Ms, rýdaye F~ttýr-eqtuency taenoacunt operating experience related to changes in CRD performance.
At any time, if a control rod is immovable, a determination of that control rod's trippability must be made and appropriate action taken.
(continued)
BFN-UNIT 1 B 3.1-23 Revision 0
0 q
ontrol Rod OPERABILITY B 3.1.3 BASES SURVEILLANCE SR 3.1.3.5 (continued)
-3 REQUIREMENTS notch and then returned to e "'full out" position during the performance of SR 3.1.3.,2. This Frequency is acceptable, considering the low probability that a control rod will become uncoupled when it is not being moved and operating experience related to uncoupling events.
REFERENCES
- 1.
10 CFR 50, Appendix A, GDC 26, GDC 27, GDC 28, and GDC 29.
- 2.
FSAR, Section 3.4.6.
- 3.
FSAR, Section 14.5.
- 4.
FSAR, Section 14.6.
- 5.
NEDO-21231, "Banked Position Withdrawal Sequence,"
Section 7.2, January 1977.
- 6.
NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.
BFN-UNIT 1 B 3.1-25 Revision 0 Browns Ferry Nuclear Plant (BFN)
Units 1, 2, and 3 Technical Specifications (TS) Change 462 Request for Adoption of TSTF-475 Revision 1 Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process Regulatory Commitments
- 1. TVA will establish the TS Bases consistent with those shown in TSTF-475, Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action" as indicated in Enclosure 3 at the same time the TS-chahge isjimplemented: