Text

(BFN) Units 1, 2, & 3 - Technical Specifications (TS) Change 462 - Request for Adoption of TSTF-475 Revision 1 of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line
	ML083300545
Person / Time
Site:	Browns Ferry
Issue date:	11/20/2008
From:	; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TVA-BFN-TS-462
	Download: ML083300545 (17)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 November 20, 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

)

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 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 (CLIIP) - UNITS 2 AND 3 TS AND TS BASES PAGE MARK-UPS By letter dated October 30, 2008 (ADAMS Accession No. ML0830901051), TVA submitted a request for a TS change (TS-462) for BFN Units 1, 2 and 3. The proposed TS change was submitted in accordance with the CLIIP and adopts the changes from TSTF-475 Revision 1 to: (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.

In the October 30, 2008, submittal, TVA provided mark-ups of the current Unit 1 TS and Unit 1 TS Bases pages to show the proposed changes with a statement that the same exact changes were being requested for Units 2 and 3. As part of NRC's acceptance review, NRC requested that TVA also submit mark-ups of the existing Unit 2 and Unit 3 TS and TS Bases pages showing the proposed changes. These are provided in Enclosures 1 and 2.

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U.S. Nuclear Regulatory Commission Page 2 November 20, 2008 TVA has determined that the additional information provided by this letter does not affect the no significant hazards considerations associated with the proposed TS changes. The proposed TS changes still qualify for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

No new regulatory commitments are made in this submittal. If you have any questions about this TS change, please contact me at (256)729-2636.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on this 20th day of November, 2008.

Sincerely, M. K. Brandon Manager of Licensing and Industry Affairs

Enclosures:

1. Proposed Unit 2 and 3 Technical Specifications Changes (mark-up)

2. Proposed Unit 2 and 3 Changes to Technical Specifications Bases Pages (mark-up)

U.S. Nuclear Regulatory Commission Page 3 November 20, 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 Eva A. Brown, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08G9A One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2738 Eugene F. Guthrie, Branch Chief U.S. Nuclear Regulatory Commission Region il Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Senior 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 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 Unit 2 and 3 Technical Specifications Changes (mark-up)

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-NOTE.-.----.-------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after _> 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after power reaches Ž 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with power > 25% RTP.

Once the u it reaches 25% RTP, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months would be allowed for completing t Surveillance. If the Surveillance were not performed wit this 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval there would then be a failure to perfor Surveillance w, in the specified Frequency and the provisions R 3.0.3 uld apply.

(continued)

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Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.3 Perfor4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from SR 3.1.3.3 for each 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Two or more withdrawn B. 1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months control rod.

AND C.2 Disarm the associated 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months CRD.

(continued)

BFN-UNIT 2 3.1-8 Amendment No.

Control Rod OPERABILITY 3.1.3 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 2 3.1-10 Amendment No. 2

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

NOTE --------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after _> 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with power > 25% RTP.

Once the utreaches 25% RTP, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months would be allowed for completing t Surveillance. If the Surveillance were not performed with this 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval, there would then be a failure to perform Surveillance w in the specified Frequency and the provisions o R 3.0.3 uld apply.

(continued) i,/a e ef,e1epn-s/c' trU/o6sed 02 BFN-UNIT 3 Amendment No. 24-2 924--s-November 21, 2000,

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.3 Perform 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from SR 3.1.3.3 for each 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Two or more withdrawn B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months control rod.

AND C.2 Disarm the associated 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months CRD.

(continued)

. J BFN-UNIT 3 3.1-8 Amendment No. -242-2--

Control 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 3 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 Unit 2 and 3 Technical Specifications Bases Pages (mark-up)

Control 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition A concurrent with THERMAL POWER greater than the low power se pin LPSP) of the RWM.

SR 3.1.3.3 perf rn~p odic tests of the control rod insertion capability of witw 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 2 B 3.1-19 Revision 0

Control Rod OPERABILITY B 3.1.3 BASES (continued)

SURVEILLANCE REQUIREMENTS

ý F'e ed 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR is based on operating experience related to expected changes in control rod position and the availability r__of control rod position indications in the control room.

S-*

9 1-2.3d. R 3.1.3.3 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 control rod is not stuck and is free to insert on a scram signal.

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$qrw/i//allCe g "e'hec Suvci,nc__ -

not required when THERMAL POWER 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 se!ýguence BPWS (LCO 3.1.6 and the RWM (LCO 3.3.2.1). ifhe 7 lav-F reuenov ofSR 3A.3.2 is xperience 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 2

.B 3.1-23 Revision 0

Control Rod OPERABILITY B 3.1.3 BASES SURVEILLANCE SR 3.1.3.5 (continued)

REQUIREMENTS notch and then returned to/e "full out" position during the performance of SR 3.1.3. 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 2 B 3.1-25 Revision 0

Control 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition A concurrent with THERMAL POWE..*gfeaterthan the low power sein (LPSP) of the RWM SR 3.1.3.3 perfolnm peiodic tests of the controd insertion capability of withr an control rods. Testing each withdrawn control rod ensures that a generic problem does not exist. This ComI.pleon Time also allows for an exception to the normal "tim~o" for beginning the allowed outage time "clock." The 6ifd Action A.3 Completion Time only begins upon J d~~I*very that THERMAL POWER is greater than the actual

ýSP of the RWM since the notch insertions may not be compatible with the requirements of rod pattern control

... (...* O 3.1.6) and the RWM (LCO 3.3.2.1). The allowed Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 3 B 3.1-19 Revision 0

Control Rod OPERABILITY

.B 3.1.3 BASES (continued)

SURVEILLANCE REQUIREMENTS (1e&I eeleJ)

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

,,,9 R 8. 49.2 -

R 3.1.3.3 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

(-',

Sufvejace " J.control rod is not stuck ang is free to insert on a scram signal.

Te, ei,,nes-ar-r not required when THERMAL POWER 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.

ad the RWM (LCO 3.3d2.ay 1equcy*

S T.1.3 is...

aFurtrmore eFrequein-cy-takes into account 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 3 B 3.1-23 Revision 0

Control Rod OPERABILITY B 3.1.3 BASES SURVEILLANCE SR 3.1.3.5 (continued)

REQUIREMENTS notch and then returned to e "full out" position during the performance of SR 3.1.3. 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 3 B 3.1-25 Revision 0

v t e Letter Sequence Request
TAC:ME0024, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action (Approved, Closed)
Initiation Request, Request Acceptance... Administration Questions Answers Results Approval Other: ML091760260
MONTHYEAR2008-11-20 [Table View]

ML083300545

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