ML18038B934

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Forwards Response to 970717 RAI Re TS Changes TS-376 & TS-391T,requesting Extension of EDG AOT
ML18038B934
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 08/15/1997
From: Abney T
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18038B935 List:
References
TAC-M99061, TAC-M99062, TVA-BFN-TS-376, TVA-BFN-TS-391T, NUDOCS 9708210401
Download: ML18038B934 (9)


Text

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ACCESSjON NBR:9708210401 DOC.DATE: 97/08/15 NOTARIZED: YES DOCKET FACIL,50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION ABNEY I T.".

Tennessee Valley Authority RECIP.NAME-RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)A~

SUBJECT:

Forwards response to 970717 RAI TS changes TS-376 a TS-391T, requesting extension of DG allowed outage time.

DISTRIBUTION CODE:

D030D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: TVA Facili'ties

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PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)

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Tennessee Valley Authority, Post Office Box 2000, Decatur, Ahbama 35609-2000 August 15, 1997 TVA-BFN-TS-376 TS-391T 10 CFR 50.4 10 CFR 50.90 10 CFR 50.91 U.ST Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 2 AND 3 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING TEMPORARY EXTENSION OF DIESEL GENERATOR ALLOWED OUTAGE TIME (TAC NOS.

M99061 AND M99062)

AND SUPPLEMENT 1

TO TECHNICAL SPECIFICATION (TS)

CHANGE 376 AND 391T EXTENDED EMERGENCY-DIESEL GENERATOR (EDG)

ALLOWED OUTAGE TIME (AOT)

Enclosure 1 to this letter provides responses to the three NRC questions in the subject July 17,

1997, request for additional information (RAI) on TS-391T.

Also included in this submittal are supplemental changes to TS-376 and TS-391T.

The supplemental changes are related to question 3 of the RAI.

TS-376 and TS-391T both request TS changes to extend the existing 7-day EDG AOT in TS 3.9.B to 14 days.

TS-376 was submitted on March 12,

1997, and requests a

TS change to permanently extend the AOT to accommodate vendor recommended preventive maintenance (PM) outages and for unexpected major corrective maintenance outages.

Subsequently,

however, NRC indicated that the review of TS-376 would not be completed prior to the scheduled start of a series of major EDG PM outages in October 1997.

Therefore, TVA submitted a request for a temporary TS change (TS-391T, submitted June 19, 1997) of the AOT for the express purpose of completing the pending 12-year PM outages.

As discussed in the TS-391T submittal, the primary benefit of the TS-391T change is a reduction of 97082i040i 9708i5 PDR, ADQCK 05000260 P

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U.S. Nuclear Regulatory Commission Page 2

August 15, 1997

'the net EDG unavailability associated with the completion of the vendor recommended maintenance.

In TS-391T, TVA had indicated that in regard to TS 3.9.D.1 (Shared System EDGs), for the circumstances when an EDG was temporarily inoperable on an operating unit, TS 1.C.2 was applicable for the purposes of operability considerations for the shared equipment.

Therefore, the AOT for inoperable EDGs as specified in TS 3.9.B was governing in accordance with TS 1.C.2.

Thus, the requested 14-day AOT proposed by TS-391T to TS Section 3.9.B could be directly applied to the shared systems listed in TS 3.9.D.1.

Accordingly, no changes were deemed necessary to TS Section 3.9.D to apply the re'quested extended AOT.

In question 3 of the RAI, NRC indicated that TVA's position regarding the direct application of TS 1.C.2 to TS 3.9.D.1 for inoperable shared system EDGs on operating units was not clearly supported by the current TS provisions.

To address the RAI concern over a possible misreading of TS 3.9.D.1 for an extended EDG AOT, TVA agreed to clarify TS 3.9.D.1 to explicitly reference 1.C.2 for shared system EDGs on operating units.

Therefore, a supplemental change to TS-391T is enclosed to ensure a clear and common understanding of the appropriate application of TS 3.9.D.1 for the requested extended EDG AOT.

Since the same issue is pertinent to TS-376, it is also being revised in a like manner.

Enclosure 2 to this letter provides the description and evaluation of the proposed supplemental change which applies to both TS-376 and TS-391T.

Enclosures 3 and 4 contain marked-up copies and word processed copies of the appropriate pages from current Units 2 and 3

TS for TS-376.

Enclosures 5 and 6 forward the marked-up and word processed TS for TS-391T.

Enclosure 7 provides copies of the original version of TS 3.9.D and supports the supplemental changes as referenced in Enclosure 2.

TVA has determined that the supplemental TS changes as presented in Enclosures 2-6 do not affect the original no significant hazards determinations and environmental review determinations provided in TS-376 and TS-391T.

The BFN Plant Operations Review Committee and the BFN Nuclear Safety Review Board have reviewed this proposed change and determined that operation of BFN Units 2 and 3 in accordance with the proposed supplemented change will not endanger the health and safety of the public.

Additionally, in

U. S. Nuclear Regulatory Commission Page 3

August 15, 1997 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.

As discussed in the TS-391T submittal, if TS-391T is

approved, then combined 12-year mechanical/electrical PM outages will be undertaken for each of the eight EDGs starting in early 1998 and completing in late 1998.

If TS-391T is not approved, 16 separate mechanical and electrical PM outages would be conducted starting in early October 1997 and continuing over the course of a year.

Separate outages will result in longer overall EDG out-of-service times compared to combined outages.

In order to reschedule the EDG PMs as combined outages, TVA requested approval of the TS-391T change by September 1,

1997.

In this submittal, we would like to restate our interest in obtaining approval of the change as soon as possible.

If you have any questions about this change, please telephone me at (205) 729-2636.

x cerel S'

T. E. Abn Manager o

icensin and I dustry Affa rs Subscribe d

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day of A,v,CusY 1997.

Notary Public

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. My. Commission Expires

.,Enclosures See page 4

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U.S. Nuclear Regulatory Commission Page 4

August 15, 1997 Enclosures cc (Enclosures):

Chairman Limestone County Commission 310 West Washington Street

Athens, Alabama 35611 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street, S.W.

Suite 23T85

Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road
Athens, Alabama 35611 Mr. J.

F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama