Text

Forwards Supplemental Info in Support of TS-362 Amend Request Re Section 3.3, Instrumentation. NRC Questions on Section Provided as Ref in RAI
	ML18039A226
Person / Time
Site:	Browns Ferry
Issue date:	12/29/1997
From:	Abney T; TENNESSEE VALLEY AUTHORITY
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A227	List: ML18039A226;
References
	TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9801150071
	Download: ML18039A226 (118)
	v • d • e

C Enclosure ITS Section 3.3 Instrumentation Enclosnre Contents Enclosed?

~

Response

to NRC questions

~

Summary Description of ITS/ITS BASES Changes.

~

ITS Revised Pages

~

ITS BASES Revised Pages

~

CTS Hark-up Revised Pages.

~ Justifications for Changes to CTS (DOCs)

Revised Pages NUREG-1433 BWR/4 STS Mark-up Revised Pages.

~

NUREG-1433 BWR/4 STS Bases Hark-up Revised Pages.

Justification for Changes to NUREG-1433

{JDs)

Revised Pages

~

No Significant Hazards Considerations Revised Pages

~

Cross-Reference Matrix Correlating Changes Between the

CTS, ITS, and NUREG-1433.

Yes Yes Yes Yes

. Yes Yes Yes Yes Yes Yes Yes

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT8 3.3.1.1-1 3.3.1.1-2 3.3.1.1-3 3.3.1.14 DESCRIPTION OF ISSUE CTS TABLE3.1.A, NOTE IAALLOWSONE HOUR BEFORE INITIATIONOF CONTROL ROD INSERTION. ITS 3.3.1.1, REQUIRED ACTIONH.l DOES NOT ALLOWTHIS I HOUR PERIOD.

THE UNITI CALIBRATIONFREQUENCIES OF CTS TABLE 4.1.B ARE CHANGED FROM 3 MONTHS TO 18 MONTHS TO DUPLICATETHE UNIT2 &3 LESS RESTRICTIVE FREQUENCIES OF CTS TABLE4.1.B AS AN ADMINISTRATIVECHANGE RESULTING IN ITS TABLE 3.1.1-1 FUNCTIONS 3,4,&6 RATHER THANAS A LESS RESTRICTIVE CHANGE.

THE TSV ANDTCVAPPLICABILITYIS CHANGETO 230%

RTP FROM 1ST STAGE PRESSURE (1 54 PSIG. A STATEMENTIS MADETHATTHE TWO LIMITSARE IDENTICALWITHOUTAPPROPRIATE REFERENCES OR JUSTIFICATIONS TO CONCLUDE THE CHANGE IS ADMINISTRATIVE DOC A12 DISCUSSES THATHIGI.IREACTOR PRESSURE, HIGH DRYWELLPRESSURE ANDLOWWATERLEVEL FUNCTIONARE DELETED FOR MODE 5. NOTES 8 & 10 DO NOT APPLYTO LOWWATERLEVEL. THE NOTES STATE THATREFUEL MODEDOESN'T APPLYIF CONTAINMENTIS NOT REQUIRED (NOTE 8) OR IF THE HEAD IS UNBOLTED (NOTE 10). DOC A12 DOES NOTACCURATELYDISCUSS THE CHANGES THATARE BEING PROPOSED.

PROPOSED RESOLUTION THE REDUCTION FROM I HOUR TO IMMEDIATELYFOR INSERTION OF ALLCONTROL RODS IF REQUIRED OPERABLE OR TRIPPED FUNCTIONS FOR REFUEL MODEARE NOT MAINTAINEDIS MADETO BE CONSISTENT WITHNUREG-1433. SINCE SUFFICIENT TIMEFOR ACTIONS ASSOCIATED WITHCONDITIONSA, B, ANDC IS PROVIDED (AND EXTENDEDFROM THE CTS ALLOWEDTIMES)IT IS CONCLUDEDTHATTHE REDUCTION OF THIS SPECIFIC TIME IS ACCEPTABLEFOR BFN.

THIS IS A GENERIC QUESTION ON HOWTO HANDLEUNITl.

A GENERIC RESPONSE THATSTATES MAKINGUNITI CONSISTENT WITHUNITS UNIT2 &3 IS DONE FOR CONSISTENCY ANDTHAT THE UNIT I TECHNICAL SPECIFICATIONS WILLBE VERIFIEDCORRECT PRIOR TG UNIT] STARTUP. THIS WILLBE ACOMMENT TO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITI'ALSHOULD BE RE URED.

SPECIFIC QUESTION ADDRESSED BYADDINGADDITIONAL INFO TO NOTE A6 PAGE I OF JFC 3.3.1.1.

THE UFSAR SECTION 14.5.1.5 ADDRESSES THE SETPOINT BEING 154 PSIG AND30% RATED POWER BEING THE BYPASS POINT WHICH DEMONSTRATES THATTHE TWO VALUESARE INTERCFIANGEABLEFOR THESE PERMISSIVE APPLICATIONS. THIS INFORMATIONWAS ADDEDTO NOTE A6 BYADDINGASHEET la TO THE SECTION 3.3.1.1 JFC.

DOC A12 WILLBE REWIUTTENTO MORE CLEARLYSHOW THATTHE EXISTINGNOTE 7 WHICHSTATES "WHENTHE.

REACTOR IS SUBCRITICALANDTHE REACTOR WATER TEMPERATURE IS LESS THAN212'F, ONLYTHE FOLLOWING TRIP FUNCTIONS NEED TO BE OPERABLE:

A. MODE SWITCH IN SHUTDOWN B. MANUALSCRAM C. HIGHFLUXIRM C. SCRAM DISCHARGE VOLUMEHIGH LEVEL" NOTE 7 NEGATES THE NEED FOR THE DELETED REQUIREMENTS WHERE BECAUSE REFUEL MODE ASSURES THATTHE REACTOR IS SUBCRITICALANDTHE REACTOR WATERTEMPERATURE IS LESS THAN212'F.

INCORP Y/N COMPLETE DATE 8/28/97 8/28/97 8/29/97 5/2/97-PAGE

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT8 3.3.1.1-5 3.3.1.14 3.3.1.1-7 3.3.1.1-8 3.3.1.1-9 DESCRIPTION OF ISSUE THIS DOC DISCUSSES AMXTUREOF CHANGES TO ACTIONSTATEMENTS FOR RPS TRIPS. THE DOC STATES THATACTION 1.A HAS BEEN DELETED SINCE IT CONTAINS AN OBVIOUS REQUIREMENT. ACTION I.AIS AN OPTIONALACTIONFOR THE OPERATOR ANDITS DELETIONRESULTS INA LESS RESTRICTIVE SINCE OPTIONALREQUIREMENTS ARE REMOVED. PROVIDE REVISED DISCUSSION THATADDRESS PROPOSED CHANGES.

THE IS NO DESIGN CHANGE FROM CTS TO ITS. BUT, THE ITS PROPOSES 8 (REQUIIRED) CHANNELS PER TRIP SYSTEM WHILETHE CTS IS 4 (MINMUMOPERABLE)

CHANNELPER TRIP SYSTEM. EXPLAINWHYTHIS CHANGE IS CONSIDERED ADMMSTRATIVE.

THE M-DOC DISCUSSIONS LACKASAFETY IMPACT JUSTIFICATIONFOR THE PROPOSED CHANGES.

THE IRMHIGH FLUXSR CALIBRATIONDISCUSSION DOES NOT INCLUDEDISCUSSION OF THE NOTES THATARE ALSO ADDEDAS PART OF TIIE SR.

VERIFICATIONOF THE IRM/APRMOVERLAP DURING SHUTDOWNTHATIS NOT REQUIRED BYTHE CTS IS AN ADDITIONALRESTRICTION ON PLANTOPERATION.

PROPOSED RESOLUTION JUS11FICATION (A14) WAS CHANGED TO L6 AND JUSTIFICATION BASE D ON THE LESS RESTRICTIVE OPTIONS BEING ACCEPTABLEANDTHEREFORE THE REQUIREMENT TO INSERT RODS UNNECESSARY BUT STILLAVAILABLETO THE OPERATOR IF DESIRED.

A7 ADDRESSES THE NUMBEROF CKQBKLSREQUIRED..

THIS NOTE NEEDS TO BE REVISED TO BETTER EXPLAIN THAT THE CTS USED 4 CHANNELS BASED ON RPS CHANNELSAl,A2, Bl dc B2 WHEREAS INTHE ITS TO BETTER MEETTHE DEFMTIONOF "CHANNELSPER TRIP SYSTEM" THE TOTALNUMBEROF INPUTS FROM THE VALVELIMIT SWITCHES WILLBE USED.

M2ANDM3 ARE DESCRIPTIONS OF MORE RESTRIC11VE CHANGES. M2 ADDRESSES ADDINGA4 HOUR TIMELIMT ON TABLE3.).A ACTION I.D WHICHPREVIOUSLYHADNO TIMELIMIT. M2 ADDRESSES ADDINGANEW SURVEILLANCETO VERIFYTHAT SRM ANDIRMCHANNELS OVERLAP PRIOR TO WITHDRAWINGTHE SRMs FROM THEIR FULLYINSERTED POSITION.

JFC M2 ANDJFC M3 WILLBE REVISED TO ADDRESS SAFETY MPACT.

THE NOTES ADDEDWITHTHE SURVEILLANCE REQUIREMENT 3.3.1.1.9 ARE CONSISTENT WITHTHE NOTES FOR SR 3.3.1.1.11 AND3.3.1.1.13 WHICHIS FROM WHICHSR 3.3.1.1.9 WERE TAKENAS DOCUMENTEDBY JFC P55. M4 WILLBE REVISED TO ADDRESS THE NOTES AS WELLAS THE SR.

VERIFICATIONOF IRM/APRMOVERLAP HAS BEEN CHANGED FROM STARTUP ( CTS) TO SHUTDOWN (ITS).

THIS CHANGE IS ADDRESSED BYAREVISED JFC M5 ANDA NEW JFC L7 WHICHADDRESSES BOTH THE MORE RESTRICTIVE ASPECTS OF THE NEW REQUIREMENTAND THE LESS RESTRICIVE ASPECTS OF DELETINGTHE OLD, RE UIREMENT.

INCORP Y/N COhfPLETE DATE 5/2/97 9/3/97 11/18/97 9/3/97 9/3/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT8 3.3.1.1-10 OOS 3.3.1.1-1 I 3.3.1.1-12 3.3.1.1-13 3.3.1.1-14 DESCRIPTION OF ISSUE DELETION OF VERIFICATIONOF OVERLAP DURING STARTUP IS LESS RESTRICTIVE ON PLANTOPERA11ON.

AN RPS CIIANNELTEST SWITCH FUNCTION IS ADDEDTO THE LIST OF FUNCTIONS IN ITS TABLE3.3.1.1-1, FUNCTION 12.

INCORRECT DOC. THE APRM FLOW BIASED CFIANNEL CALIBRATIONFREQUENCY IS CHANGETO QUARTERLY FROM ONCE PER OPERATING CYCLE.

PROVIDE ATABLELISTINGEACH ITEMTHATIS MOVED TO AN OWNER-CONTROLLED DOCUMENT. FOR EACH ITEMDESCRIBE TFIE NAMEOF THE DOCUMENTTHAT THE ITEMIS MOVEDTO ANDTHE REGULATORY CONTROL MECHANISMWFIICHWILLCONTROL FUTURE PROPOSED CHANGES.

NOTE 2 OF ITS SR 3.3.1.1 HAS TFIE REVISED WORDING "THEASSOCIATED FUNCllONS MAINTAINSRPS TRIP CAPABILITY"THATASSURES TRIP FUNCTION CAPABILITY FOR ALLDESIGNS. THIS CHANGE APPEARS ADMINISTRATIVE,RATHER TING LESS RESTRICTIVE.

PROPOSED RESOLUTION THIS IS TIEDTO ISSUE 3.3.1.1-9 BECAUSE THE DELETIONOF IRM/APRMOVERLAP DURING STARTUP WAS DELETED BASED ON THE ADDITIONOF IRM/APRMOVERLAP DURING SHUTDOWN. ITIS TRUE THATTHE DELETIONIS LESS RESTRICTIVE ANDTHUS JFC M5 WILLBE REVISED AND L7 WILLBE ADDED.

THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED TO THE NRC FOR APPROVAL. NO CHANGES THE CTS OR ITS MARKUPS ARE REQUIRED.

THE FREQUENCY OF CALIBRATIONFOR THE APRM FLOW BIAS INSTRUMENTATIONHAS BEEN CHANGED FROM ONCE PER OPERATING CYCLE TO ONCE PER 92 DAYS. THIS WAS AN ERROR INTHE CTS MARKUPS AS IS EVIDENCEDBYTHE REFERENCE TO JFC A4 WHICHINDICATESA NOMENCLATURECHANGE FROM REFUELING CYCLETO 18 MONTHS. ALSO, INTHE ITS BASES SR 3.3.1.1.11 ON PAGE B3.3-30 k 31 ADDRESS THE BASES FOR THE APRM FLOW BIASED FUNCTION STATES THE 18 MONTHFREQUENCY IS BASED ON SYSTEM DESIGN.

CTS TABLE 4.1.B WILLBE REVISED TO CHANGE 92 DAYSTO 18 MONTHS ANDCHANGE REFERENCED SR FROM 3.3.1.1.9 TO SR 3.3.1.1.11.

THIS TABLE(MATIRX)IS BEING PREPARED BYBILLY THIBADEAUX.THIS SHOULD NOT IMPACTTHE CTS OR ITS

~UPS BUT WILLBE SUBMI1TEDAS A RESPONSE TO THIS ISSUE.

CONCUR THATTHE CHANGE IS ADMINISTRAllVEBECAUSE ITIS A CLARIFICATIONOF EXISTINGNOTE. JFC LBI WILLBE CHANGEDTO JFC A15.

INCORP Y/N COMPLETE DATE 9/5/97 9/5/97 9/9/97 9/8/97 PAGE 3

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT¹ 3.3.1.1-15 OOS 3.3.1.1-16 OOS 3.3.1.1-17 DESCRIPTION OF ISSUE THE CHANNELFUNCTIONALTEST INTERVALOF RPS CHANNELSANDTRIP SYSTEMS (ITS TABLE3.3.1.1-1, FUNCTIONS 2, 3, 4, 5, 7, 8, 9, AND 11) ARE EXTENDEDTO 92 DAYS FROM THE MONTHLYREQUIREMENT OF CTS TABLE4.1.A, BASED ON THE RELIABILITYANALYSISOF "TECHNICALSPECIFICATION IMPROVEMENTANALYSES FOR BWR REACTOR PROTECTION SYSTEM," (NEDC-30851-P-A, MARCH 1988) ANDAN UNREFERENCED BANREPORT "TECHNICALSPECIFICATION MPROVEMENTANALYSES FOR BROWNS FERRY NUCLEARPLANT, UNIT2," (MED 0286, OCTOBER 1995.)

THE ITS 3.3.1.1, CONDITIONA, COMPLETIONTIMEIS EXTENDED FROM 1 HOUR IN CTS TABLE3.1>, NOTES I AND23, TO 12 HOURS.

THE ITS 3.3.1.1, CONDITIONB, COMPLETIONTME IS EXTENDED FROM I HOUR IN CTS TABLE3.1.A, NOTES I AND23, TO 6 HOURS.

THE AOT FOR PLACINGA CHANNELINTRIP FOR REQUIRED SURVEILLANCETESTING IS EXTENDEDFROM THE 4 HOURS OF CTS TABLE3.1.A, NOTE 23, TO 6 HOURS IN ITS TABLE3.3.1.1-1.

THESE CHANGES ARE BASED ON THE RELIABILITY ANALYSISOF "TECHNICALSPECIFICATION IMPROVEMENTANALYSESFOR BWR REACTOR PROTECTION SYSTEM," (NEDC-30851-P-A, MARCH 1988)

ANDANUNREFERENCED BANREPORT "TECHNICAL SPECIFICATION IMPROVEMENTANALYSESFOR BROWNS FERRY NUCLEARPLANT, UNIT2," (MED-32-0286, OCTOBER 1995.)

Ll DOES NOT DISCUSS CHANGES PROPOSED TO CTS NOTE (7).

L2 DOES NOT DISCUSS MANUALSCRAM FUNCTION CHANGES.

PROPOSED RESOLUTION THE REQUESTED DOCUMENTATIONWILLBE SUBMTTED TO THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

JFCs Ll ANDL2 WILLBE REVISED TO ADDADDITIONAL DETAILSON THE PROPOSED CHANGES.

MODE 5 " WILLBE ADDEDTO ITS TABLE3.3.1.1-1 FUNCTIONS 2a AND2e AS INDICATEDBY CTS TABLE3.1.A NOTE 21 MARKUPANDADD JFC P92 TO JUSTIFY STS CHANGE.

INCORP Y/N COMPLETE DATE 9/5/97 9/8/97 9/15/97 PAGE 4

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT4 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.1.1-18 3.3.1.1-19 3.3.1.1-20 3.3.1.1-21 ANOTE IS ADDEDTO THE HEATBALANCECALIBRATION WHICHALLOWSDELAYIN PERFORMING THE SR UNTILA PRESCRIBED POWER LEVELIS REACHED. THE SAFETY BASIS EVALUATIONSTATES ACCEPTANCE BASED ON OPERATING EXPERIENCE. BFNP HAS NEVER PERFORMED THE SURVEILLANCEWITHTHE PROPOSED NOTE. WHAT IS THE BASIS FOR THE OPERATING EXPERIENCE JUSTIFICATION?

LB2 &L5 BOTH APPLYTO THE SAME BALLOONEDTEXT INTHE~UP OF TABLE3.1.A, NOTE (I). LS AS STATED DOES NOT PROVIDE APPROPRIATE JUSTIFICATIONFOR THE BALLOONEDTEXT.

THE FUNCTION OF THE TIMECONSTANT CIRCUITOF STS SR 3.3.1.1.14 IS TO SIMULATEFLOW COAST DOWN FOR THE APRM. ITS 3.3.1.1 DOES NOT IMPLEMENTTHIS SURVEILLANCE. DELETINGTHE TIMECONSTANT TESTING IN STS SR 3.3.1.1.14 OF THE APRM FLOW BIASED SIMULATEDTHERMALPOWER CIRCUIT IS NOT SUFFICIENTLYSUPPORTED.

STS SR 3.3.1.1.17 REQUIRES RPS 1lME RESPONSE TESTING.

ITS 3.3.1.1 DOES NOT IMPLEMENTTHIS SURVEILLANCE.

DELETINGTHE RPS TIMERESPONSE TESTING IN ITS 3.3.1.1 IS NOT SUFFICIENTLYSUPPORTED BYJFC OR BASES.

JFC L4 WILLBE REVISED TO ADDADDITIONAL JUSTIFICATIONFOR ALLOWINGTHE 12 HOURS AFTER EXCEEDING25% RTP TO PERFORM THE HEATBALANCE CALIBRATION.

CTS TABLE3.1.A NOTE I MARKUPWILLBE REVISED TO DELETE LB2 JFC FOR SECTION THATLISTS BOTH LB2 AND LS. FOR THE UNIT I MARKUPA SECTION BELOWTHATHAS NO JFC FLAG WILLHAVBLB2 FLAG ADDED. JFC LS WILL BE REVISED TO BETfER REFLECT THE APPROPRIATE JUSTIFICATIONFOR THE CHANGE.

JFC P58 WILLBE REVISED TO PROVIDE ADDITIONAL JUSTIFICATIONFOR DELETION OF CALIBRATIONOF THE APRM FLOW BIASED SIMULATEDTHERMALPOWER CIRCUIT TIMECONSTANT.

JFC P4 PROVIDES ADEQUATE JUSTIFICATIONFOR NOT INCLUDINGRESPONSE TIME TESTING AS ASURVEILLANCE REQUIREMENT. BFN DOES NOT CURRENTLYPERFORM RESPONSE TIMETESTING ANDTHE BENEFITS OF ADDING THIS SR BASED ON THE UNLKELYPOSSIBILITYOF THE RESPONSE TIMES SIGNIFICANTLYCHANGING THATWOULD IMPACTTHEABILITYOF THE RPS TO PERFORM ITS SAFETY FUNCTION WITHOUTBEING IDENTIFIEDDURING OTHER REQUIRED FUNCTIONALTESTS ANDCALIBRATIONS DOES NOT JUSTIFY THE ADDITIONALOUT OF SERVICE TIMEFOR TI.IE RPS INSTRUMENTATIONOR ADDITIONAL BURDEN ON THE PLANTSTAFF.

(NOTE REQUESTED BERT MORRIS GUIDANCEON THIS 9/17/97 Y

9/16/97 Y

9/17/97 N

9/17/97 3.3.1.1-22 TIKLOWSCRAM PILOTAIRHEADER PRESSURE JFC P60 WILLBE REVISED TO DOCUMENTTHATTHE LOW SURVEILLANCE OF ff$ SR 3 3 I I I6 APPLIES TP UNITS 2 & SC~ PROT~~ER P~S~ NSW~MATION 3 BUTNOT UNrr1 No JUSTIFICATION OR EXPLANATION HAS NOT BEEN IMPLEMENTEDON UNIT I ANDTHEREFORE THIS SURVEILLANCEWAS NOT APPLICABLE.

Y 9/18/97 PAGE 5

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT P 3.3.1.1-23 3.3.1.1-24 3.3.1.1-25 DESCRIPTION OF ISSUE THE DELETION OF THE STS BASES FOR THE SR 3.3.1.1.16 REQUIREMENTTHATTHE MAINTURBINEBYPASS VALVESMUST BE CLOSED WHEN CALIBRATIONIS PERFORMED AT> 30% RTP SHOULD BE RECONSIDERED IF ACTUALSTEAM PRESSURE IS USED TO VERIFYTHE CALIBRATION. ITS BASES SR 3.3.1.1.15, FUNCTIONS 8 &9, DO NOT HAVETHIS REQUIREMENT. WHILETHE JUSTIFICATIONTHATAN ISOLATEDSENSOR CAN BE TESTED WITHA GAGE CALIBRATORINDEPENDENT OF BYPASS VALVEPOSITION IS TRUE, THE CALIBRATIONTHATIS ADDRESSED BYITS SR 3.3.1.1.15 IS NOT ONLYSTEAM PRESSURE BYPASS TRIP SETPOINT ANDFUNCTION, BUTALSO DEMONSTRATES THATTHE FUNCTION IS VERIFIEDBYPARTIAL MOVEMENTOF THE TURBINEVALVESAFTER THE SENSOR IS RI:"mRNED ON-LINE.

CTS REQUIRE A CHANNELCALIBRATIONONCE PER OPERATING CYCLE. THE CTS MARKUPSHOWS THIS FREQUENCY IS CHANGEDTO 92 DAYSAND IS RENAMED SR 3.3.1.1.9.

INTHE ITS THE SAME SR IS 3.3.1.1.11 AND CARIUES A 184 DAYFREQUENCY. JFC P89 STATES THAT THE APRM DESIGN IS SUCH THATTHE FUNCTIONCAN ONLYBE TESTED ATREFUELING WITHOUTCAUSING MULTIPLEINOPERABLEAPRMS ANDA REACTOR TRIP.

RECONCILE THE APPARENT DISCREPANCIES BETWEEN THE CTS MARKUP,ITS MARKUPANDJFC 89.

THIS SR APPLIES A 92 DAYCALIBRATIONFREQUENCY TO RPS APRM TRIP FUNCTIONS WHICHOTHERWISE HAVE EITHERA 7 DAYOR REFUELING INTERVAL.

PROPOSED RESOLUTION PREVIOUS JUSTIFICATIONIN JFC P16 AND P79 ARE APPLICABLE. RETURNING THE SENSORS ONLINEWILL HAVENO IMPACTUPON THE TURBINEVALVESAS THE ONLYLOGIC TIE IS INTHE REACTOR PROTECTION SYSTEM SUCH THATTO RECEIVE A HALFSCRAM REQUIRES A CLOSURE SIGNALFROM THE TURBINESTOP VALVESOR TURBINECONTROL VALVESANDTHE INDICATIONOF >30%

RTP FROM THE TURBINE FIRST STAGE PRESSURE SWITCHES. SINCE THE CALIBRATIONWILLNOT VERIFY ANY FUNCTION OTHER THAN APOTENTIAL RPS HALF SCRAM ANDTHE PRESSURE SWITCHES ARE REMOVED FROM THE PROCESS ANDCALIBRATEDWITHA PRESSURE SOURCE (NEGATINGANYIMPACTA BYPASS VALVEWOULD HAVEON THE CALIBRATION)THERE IS NO AFFECT FROM THE BYPASS VALVES(AS STATED INJFC P79) AND THEREFORE THE DELETION OF REQUIREMENTFOR THE BYPASS VALVESTO BE CLOSED WHEN CALIBRATION OCCURS IS ACCEPTABLE THIS WAS PREVIOUSLYADDRESSED IN RESPONSE TO ISSUE 3.3.1.1-12 AS FOLLOWS:

THE FREQUENCY OF CALIBRATIONFOR Tl&APRM FLOW BIAS INSTRUMENTATIONHAS BEEN CHANGED FROM ONCE PER OPERATING CYCLETO ONCE PER 92 DAYS. THIS WAS AN ERROR INTHE CTS MARKUPS AS IS EVIDENCED BYTHE REFERENCE TO JFC A4 WHICH INDICATESA NOMENCLATURECHANGE FROM REFUELING CYCLE TO 18 MONTHS. ALSO, INTHE ITS BASES SR 3.3.1.1. I I ON PAGE B3.3-30 &31 ADDRESS THE BASES FOR THE APRM FLOW BIASED FUNCTION STATES THE 18 MONTHFREQUENCY IS BASED ON SYSTEM DESIGN.

CTS TABLE 4.1.B WILLBE REVISED TO CHANGE 92 DAYSTO 18 MONTHS ANDCHANGE REFERENCED SR FROM 3.3.1.1.9 TO SR 3.3.1.1.11.

JFC P91 WILLBE REVISED TO ADDRESS THE DEVIATION FROM THE STS.

INCORP Y/N COMPLETE DATE 9/18/97 9/18/97 9/19/97 PAGE 6

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENTII 3.3.1.1-26 3.3.1.1-27 OOS 3.3.1.1-28 3.3.1.1-29 3.3.1.1-30 DESCRIPTION OF ISSUE CHANNELCHECKS ARE NOT ADOPTED AS PART OF THE ITS FOR DRYWELLPRESSURE HIGHANDSDV TRIP FUNCTIONS.

ADDITIONOF CHANNELTEST SWITCHES WAS CREDITED INTI-IEANALYSISOF NEDO-3851 FOR EXTENDING AUTOMATICSCRAM FUNCTION FREQUENCIES.

ABLOCKOF TEXTIS MOVEDFROM STS BASES, REQUIRED ACTIONS C.I, TO ANUNIDENTIFIEDPL@K DOCUM'.NT. ITS BASES, REQUIRED ACTIONS C. I, DOES NOT~AINTMS INFORMATION.

NOTE 17 PROVIDES EXCEPTIONS TO CTS APRM OPOERABILITYREQUIREMENTS. LA2 PROPOSES TO RELOCATE THESE EXCEPTIONS.

NOTE 19 ESTABLISHES ALTERNATEREMEDIALACTIONS PROPOSED RESOLUTION SINCE THE ADDITIONOF CHANNELCHECKS WOULDBE A NEW REQUIREMENTTHATBFN IS NOT PRESENTLY REQUIRED TO MEETTHE CHOICE NOT TO IMPLEMENT DOES NOT REQUIRE FURTHER JUSTIFICATION. THE CONVERSION FROM CTS TO ITS WAS NOT TO IMPOSE NEW RE UIREMENTS.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

DISCUSSION OF MINMUMREQUIREMENTS FOR FUNCTIONS TO MAINTAINTRIP CAPABILITYARE TYPICALLYINCLUDED INTHE BASES INOTHER LCOs. THEREFORE, THE DISCUSSION OF MINIMUMREQUIREMENTS FOR THE RPS FUNCTIONS TO MAINTAINTRIP CAPABILITYHAS BEEN ADDEDBACKTO THE BASES FOR ACTIONC.l OF LCO 3.3.1.1.

REVISIONS HAVEBEEN MADETO THE NUREG WORDING TO REFLECT BFN DESIGN ANDJFC P15 HAS BEEN REVISED TO ADDRESS THESE CHANGES.

THE APPLICABILITYOF JFC LA2WILLBE DELETED FROM NOTE 17 ANDJFC M8 WILLBE ADDEDTO ADDRESS THE REMOVALOF EXCEPTION TO OPERABILTY OF THE APRM FUNCTIONS, THATREFERTONOTE17, DURING "LOW POWER PHYSICS TESTS".

NOTE 19 IS SPECIFIC TO THE TURBINE FIRST STAGE PERMSSIVE FUNCTION WHICHWAS RELOCATED BASED ON JFC LAS. SINCE NOTE 19 HAS NO PURPOSE OTHER THAN CLARIFICATIONOF ACTIONS FOR THE TURBINEFIRST STAGE PERMSSIVE THE JUSTIFICATIONFOR THE RELOCATION OF THE REQUIREMENTS IN NOTE 19 WILLBE CHANGEDTO LA5 WHICHBETTER DESCRIBES THE RATIONAL.

INCORP Y/N COMPLETE DATE 9/18/97 9/19/97 9/9/97 5/19/97 5/19/97 3.3.1.1-31 NOTE 21 IS SHOWED TO BECOME TABLE3.3.1.1-1 NOTE (A)

IN ESPONSE TO ISSUE 3.3.1.1-17 MODE 5(a) WAS ADDEDTO ANDAPPLIES TO FUNCTIONS 2.A AND2.E. INTABLE ITS FUNCTIONS 2 a AND2 e WHICH INCORPORATED THE I NOTE (A)DOES NPTAPPLY TP FUNCTIONS 2 A NOTE 21 EQ~~. ALL EQUIRED CHANGES TO THE ITS TO CORRECT THIS OMISSION WERE MADE IN RESPONSE TO ISSUE 3.3.1.1-17.

5/19/97 PAGE 7

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT¹ 3.3.1.1-32 DESCRIPTION OF ISSUE NOTE I STATES THATTHE MINIMUMFREQUENCY FOR THE TEST SHALLBE ATLEASTONCE PER MONTH.

PROPOSED RESOLUTION NOTE I STATES "INI'IIALLYTHE MINIMUMFREQUENCY FOR THE INDICATEDTESTS SHALLBE ONCE PER MONTH".

THIS NOTE REFERRED TO FIGURE 4. I-l WHICHPROVIDED A BASES FOR THE CALIBRATIONINTERVALSELECTION BASED ON FAILUREINTERVAL. THE BASES FOR THE TEST INTERVALSIS INCLUDEDINTHE ITS BASES ANDTHUS JFC LA2 IS APPLICABLEBECAUSE THE DETAILSOF SELECTION OF TEST INTERVALSIS INCLUDEDINTHE BASES. NO CORRECTIONS ARE RE UIRED DUE TO THIS ISSUE.

INCORP Y/N COMPLETE DATE N

5/19/97 PAGE 8

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.1.2-1 3.3.1.2-2 3.3.1.2-3 3.3.1.24a OOS ITS 3.3.1.2, Conditions A, B and C, allow up to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Conditions A and B and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Condition C) before the reactor must be in Mode 3 when SRM OPERABILITY requirements are not satisfied versus the CTS 3.3.B.4 requirement ofbeing in MODE 4 withinthe following30 hours.

The change ofgoing to Mode 3 rather than MODE 4 is less restrictive, even ifmore time is allowed.

The change ofgoing to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months rather than 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months is a more restrictive change.

The requirement that "The SRM shall be inserted to the normal operating level'as not carried into the Bases as stated.

Each discussion ofchange should be revised to discuss the justification or the basis for concluding the change are an appropriate enhancement to TS.

The proposed ITS make use ofspiral oflload procedures and adopt a revision to SR 3.3.1.2.4 Note 2 for count rate verification during spiral loading. These are changes to the CTS allowances and the revision to the SR Note is a change to the STS.

JFC Mg WILLBE REVISED TO CORRECT A MSINTERPRETATIONTHAT CTS 3.3.B.4 DEFAULTSTO CTS 1.0.C. I WHICHWOULDREQUIRE PLANTTO BE IN COLD SHUTDOWN WITIK430 HOURS. CTS 1.0.C.1 IS NOT APPLICABLEINTHIS CASE BECAUSE THE ASSOCIATED REQUIREMENTS WOULDBE FULFILLEDBYNOT WITHDRAWINGANY CONTROL RODS IF TWO SRM CHANNELS DO NOT HAVEAN OBSERVED COUNT RATE OF 3 CPS (THE REQUIRMENTIS TO NOT WITHDRAWCONTROL RODS).

THUS THE INCLUSIONOF TIMELIMITSON ACTIONS FOR CONDITIONSA, B, ANDC IS MORE RESTRICTIVE SINCE ATIMELIMITDIDNOT EXIST PREVIOUSLY.

THE WORDS "THESRM SHALLBE INSERTED TO THE NORMALOPERATING LEVEL"ARE NOT SPECIFICALLY STATED INTHE ITS BASES BUTTHE INTENTIS STATED IN THE ITS BASES BACKGROUNDAS "THESRMs ARE MAINTAINEDFULLYINSERTED UNTILTHE COUNT RATE IS GREATER THANAMNIMUMALLOWCOUNT RATE...

AFTER SRM TO INTERMEDIATE RANGE MONITOR(IRM)

OVERLAP IS DEMONSTRATED... THE SRMs ARE NORMALLY FULLYWITHDRAWNFROM THE CORE". INADDITION OTHER PARTS OF THE ITS BASES SPECIFY THE REQUIRED LOCATIONOF THE SRM SENSOR.

FOR EXAMPLETHE LCO BASES STATES "COVERAGE IS PROVIDED BYONE SRM TO BE OPERABLE INTINQUADRANTOF THE REACTOR CORE WHERE CORE ALTERATIONSARE BEING PERFORMED, AND THE OTHER SRM TO BE OPERABLE INANADJACENT QUADRANTCONTAININGFUEL". THUS ITIS CONCLUDED THATTHE BASES ADEQUATELYADDRESSES THE LOCATION OF THE SRM IN ORDER TO DECLARE ITOPERABLE ANDNO CHANGES ARE NECESSARY.

ALEADIN TO THE MORE RESTRICTIVE JFCs WILLBE ADDED TO PROVIDE JUSTIFICATIONFOR THE CHANGES BEING AN ENHANCEMENT.

SEE ATfACHMENTI FOR PROPOSED RESOLUTION Y

9/23/97 N

9/25/97 Y

11/19/97 N

11/1/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR 3.3.1.2Mb DESCRIPTION OF ISSUE CTS core monitoring surveillances require periodic verification of signal to noise ratio once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during core alterations. The ITS include this requirement and an additional verification ofonce per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during applicable modes.

The required 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months testing is not dispositioned in either the DOCs or the JFC.

PROPOSED RESOLUTION CTS 4.10.B.2 WILLBE MARKEDUP TO ADDTHE 24 HR REQUIREMENTANDJFC M9 WILLBE ADDEDTO DESCRIBE THE MORE RESTRICTIVE CHANGE.

INCORP Y/N COMPLETE DATE 9/26/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR ATTACHMENT1 3.3.1.2-4a PROPOSED RESPONSE There is no NRC staff acceptance review for operations allowing spiral loading/off-loading. The followingis a technical justification for the practice ofusing a spiral off-loading/loading process A spiral off-loading involves off-loading the sub~ritical core (the reactor is shutdown) by removing fuel from the outer edges of the core in a spiral sequence around the core. The core size is continuously reduced thus decreasing reactivity from the already subwritical configuration. By followinga spiral off-loading pattern, reactivity is guaranteed to decrease as the core size gets smaller. No positive reactivity changes to the core willbe made during spiral off-loading. Therefore, the core monitoring surveillance is not required to be followed during a spiral off-load as it is not ncedcd to monitor the decreasing reactivity.

The safety analysis associated with all ofthe intermediate configurations ofthe core during a spiral off-load is bound by the safety analysis ofthe starting configuration including fuel loading errors and control rod withdrawal errors.

Control rods remain inserted until adjacent fuel has been removed.

Since shutdown margin calculations assume that the strongest worth rod is withdrawn from the core, leaving all control rods inserted provides substantial analytical margin to criticality.

A spiral loading involves loading the core by placing four fuel assemblics around a source range monitor and successively adding fuel assemblies around the fueled region building a larger core until the final, analyzed core loading pattern is achieved.

The final, loaded core is more reactive than the intermediate configurations. The core is continuously monitored by the source range monitor in the center ofthe fueled region and by the other source range monitors as the fueled region includes these locations.

During the spiral, bridges to the other source range monitors can be builtproviding additional assurance that the core is appropriately monitored. A reduction in the number ofrequired operable source range monitor channels is acceptable when using a spiral pattern because the use ofa spiral pattern centered about an source range monitor provides assurance that the erable source range monitor is in the optimum position for monitoring changes in neutron fluxlevels resulting from the core eration.

The suety analysis associated with all ofthe intermediate configurations ofthe core during a spiral load is bound by the safety analysis ofthe final configuration.

PAGE 3

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCKINSTRUMENTATION COMMENT8 3.3.2.1-1 3.3.2.1-2 3.3.2.1-3 3.3.2.14 3.3.2.1-5 DESCRIPTION OF ISSUE The deletion ofthe CTS Table 3.2.C surveillance requirements for the Rod Block Logic has been justified by observing that other functional tests can test it. In order to be an Administrative change, itwould be implemented in the ITS, essentially unchanged.

The CTS requires a operating cycle test ofthe logic whereas the ITS requires a quarterly test. Provide a statement that all components tested by the CTS requirements are included in the ITS SRs, but at a more frequent interval.

Each discussion ofchange should be revised to discuss the justification or the basis for concluding the change are an appropriate enhancement to TS.

Portions ofthe note limitthe use ofchannel bypass for SRMs or RBMs during repair or calibration are proposed to be placed in the Bases using a justification that they are operational details.

Because the statements establish allowed outage times for repair or test they are instead, operational limits.

LAI is applied to a change which cannot be distinguished from other marks on the page.

Provide clarifying documentation.

Note 7.a provides "operational restraints" to use ofRBM bypasses.

The restraint stated as "or when a peripheral control rod is selected" is not incorporated in the ITS applicability as noted in the CTS markup.

Documentation ofRBM operational constraints in Note 7.c related to the allowance for bypassing only one channel from the console" is not incorporated into ITS Actions A&B as stated.

PROPOSED RESOLUTION JFC A3 WILLBE REVISED TO BETTER DESCRIBE THE RATIONALFOR THE EXISTINGROD BLOCKLOGIC BEINGA DUPLICATIONINTHE CTS THAT IS ADDRESSED INTHE ITS.

ALEADINTO THE MORE RESTRICTIVE JFCs WILLBE ADDED TO PROVIDE JUSTIFICATIONFOR THE CHANGES BEINGAN ENHANCEMENT.

THE PORTION OF THE NOTE PERTAININGTO SRMs, IRMs, ANDAPRMs ARE ADDRESSED BYJFC Rl ANDTHUS LA1 IS NOT APPLICABLETO THOSE FUNCTIONS.

THUS ONLYTHE RBM PART OF THE NOTE REMAINSASSIGNED TO JFC LAI.

SINCETHE REMAINING(LAI)PARTOF THE NOTE DOES ADDRESS THE SAME OPERATIONALLIMITS,FORTHE RBM, AS NOTE 7.c &7.d WHICHARE ASSIGNED TO ACTIONS A &B OF THE ITS THE PART OF THE NOTE FLAGGED TO LA1 WILL INSTEAD BE ASSIGNED TO ACTIONS A&B.

NOTE 7 WILLBE MARKEDUP TO REFER TO JFC M3 WHICH WILLBE REVISED TO BEITER DESCRIBE THE INCORPORATION OF THE NOTE ANDCHANGES TO ITINTO THE ITS. INADDITONTHE PART OF NOTE 7.a WHICHSTATES "OR WHENAPERIPHERAL CONTROL ROD IS SELECTED" IS SYSTEM DESIGN ANDIS ADDRESSED INTHE ITS BASES THUS JFC LAI IS APPROPRITAT E FOR THATSECTIONOF THE NOTE..

THE PARTOF TABLE3.2.CNOTE7.c THAT STATES "...AND ONLYONE OF THESE MAYBE BYPASSED WITHTHE CONSOLE SELECTOR" IS ADESIGN FEATURE OF THE SYSTEM ANDWILLAPPROPRIATELY BE ASSIGNED TO JFC LA2. THE FSAR CURRENTLYSTATES "ONE OF THE TWO RBMs CAN BE BYPASSED ATANYTIMEBYOPERATOR ACTION. EffHER RBM CAN INHIBITCONTROL ROD WITHDRAWAL."THE DESIGN PRECLUDES BYPASSING MORE THANONE CHANNEL ATATIME.NOTE7.cWILLBEREVISEDTOADDJFCLA2 FLAGTO THE SUBJECT PART.

INCORP Y/N COMPLETE DATE 9/30/97 11/19/97 10/I/97 10/2/97 10/6/97 PAGE I

~

I I

~ '

~ '

~

o

~

I

~

I

~

~ '

I '

~

IgggggQQ I

~

~ ~

I I i ~

~ ~

~

~ '

~

~ ~ ~

~ I I

~

I I

~

I ~

I 'l I

I

~ '

~

I

~

I

~ I

I ~

~

I

~

I

~

t

~

I

~

I

~ ~

~

I I

~

I '

~

I

~

~,

~

I I

~

I

~

I II

~

I

~

t

~

I I

~

I

~

I '

~

I

~ ~

~

~ ~ t

~

~ ~

I

~

I II'

~

I

~

~ I I

~

I I

~ '

~

. Ii I I I II

~

I'

~

4 I I'

~ '

I I

~

~ '

~

~ ~

I

~

I

~

~ ~

I~

~

~ ~

I

~

I

~

I

~

~ ~

~

I'

~

I

~

t ~

~

~ t

~

I I

~ ~

I

~

~ '

~

I

~

+ ~

a

~

I

~

~ I ~

~

I I

~ ~ ~

~

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCKINSTRUMENTATION COMMENT¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.2.1-8 3.3.2.1-9 OOS 3.3.2.1-10 OOS Both DOCs are applied to this table note which discusml methods for perforining functional tests.

The CTS Table 3.2.C, Test interval ofRBM CHANNEL FUNCTIONALTEST (function I) is extended from I month to 92 days in ITS SR 3.3.2.1.1, based on the reliabilityanalysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1,

October 1988) and an unreferenced BANreport "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2" (MED-32-0286, October 1995).

Adoption ofthe 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months delay time limitfor entry into associated Conditions and Required Actions during perfonnance ofrequired SRs is based on the reliabilityanalysis ofGENE-770-06-1, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed-Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.

NOTES 8 AND 13 ARE APPLICABLETO SRM, IRM,APRM, AND RBMFUNCTIONS. THE SRM IRMANDAPRM FUNCTIONS WERE COMPLETELYRELOCATED TO PLANTDOCUMENTS.

THE RBM FUNCTIONS WERE RETAINEDINTHE ITS.

FOR NOTE 13 THE RELOCATION OF THE DETAILSOF THE FUNCTIONALTEST FOR SRM, IRM, ANDAPRM FUNCTIONS ARE ADDRESSED BYJFC Rl DUE TO THE TOTAL RELOCATIONANDTHE SAME IS ADDRESSED BYJFC LA2 FOR THE RBM FUNCTION WHICHJUSTIFKS THE RELOCATIONOF THE DETAILSOF PERFORMING THOSE FUNCTIONALS. THUS THE APPLICATIONOF BOTH OF THE JFCs TO NOTE 13 IS ACCEPTABLE.

SIMILARLY,JFC Rl ADDRESSES THE RELOCATIONOF INSTRUMENTCHECKS FOR THE SRM, IRM, ANDAPRM FUNCTIONS THE DETAILS OF WHICHARE DESCRIBED IN NOTE 8.

THE DETAILRELOCATION FOR THE INSTRUMENT CHECKS FOR RBMFUNCTIONS ARE ADDRESSED IN JFC R2 RATHER THANIN LA2AS INDICTEDBYTHE FLAGS ON THE NOTE ITSELF (CORRECT INTHE TABLE). THUS THE LA2 FLAG TO NOTE 8 WILLBE CHANGEDTO JFC R2.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITfEDTO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPSARE REQUIRED.

Y 10/7/97, N

10/3/97 N

10/3/97 PAGE 3

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCKINSTRUMENTATION COMMENT8 3.3.2.1-1 I OOS 3.3.2.1-12 OOS 3.3.2.1-13 3.3.2.1-14 OOS DESCRIPTION OF ISSUE The ITS SR 3.3.2.1.2 requirement for a CHANNELFUNCTIONAL TEST is less restrictive because the Surveillance Test is not required until I hour after the RWM is required OPERABLE while CTS 4.3.B.3.b. 1 required a test within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to withdrawal of control rods. This is based on the reliabilityanalysis of"Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement I, October 1988) and an unreferenced BANreport "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2 (MED-3241286, October 1995).

The ITS SR 3.3.2.1.3 requirement for a CHANNELFUNCTIONAL TEST is less restrictive because the Surveillance Test is not required until I hour after the THERMALPOWER is E 10% in MODE2 while CTS 4.3.B.3.b.2 required a test within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to the THERMALPOWER being E 10% in MODE 2. This is based on the reliabilityanalysis of"Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement I, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit2" (MED-324286, October 1995).

This DOC discusses extending proposed completion times for blocking control rod withdrawal ifone control rod is inoperable.

The proposed changes appear to result in more restrictive operations.

In addition, the justification does not adequately discuss why the proposed change willnot result in a significant safety issue for operation ofthe plant.

The proposed change eliminates CTS 4.3.B.S which requires a Functional Test ofthe Rod Block Monitor (RBM) "prior to withdrawal ofthe designated rod(s)" during operation with CMFCP or CMFLPD equal to or greater than 0.95 and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter is eliminated. ITS Table 3.3.2.1-1 relies on the Functional Test, required every 92 days. This is based on the reliabilityanalysis of"Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1, October 1988) and an unreferenced BAN report "Technical Specification hnprovement Analyses for Browns Ferry Nuclear Plant, Unit 2," (MED-324286, October 1995.)

PROPOSED RESOLUTION THE REQUESTED DOCUMENTATIONWILLBE SUBMITEDTO THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTEDTO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

JFC L3 WILLBE REVISED TO BETTER DESCMBE THE BASIS FOR THE CHANGES TO RBMLCO TIMELIMITS.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTEDTO THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

INCORP Y/N N

N N

COMPLETE DATE 10/3/97 10/3/97 10/10/97 10/3/97 PAGE 4

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCKINSTRUMENTATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.2.1-15 3.3.2.1-16 3.3.2.1-17 3.3.2.1-18 The APRM, SRM, IRMand scram discharge volume control rod blocks prevent a control rod withdrawal error at power transient.

The CTS Table 3.2.C and Notes 1-6, 8, 10, I I, and 12 and CTS Table 4.2.C and Notes 13, 15, and 20 requirements are moved to plant documents.

The justification includes the evaluation summarized in NEDO-31466 and the lack ofcredit taken for this feature in design basis accident or tmnsient analysis. NUMAC PRNM (ARTS) plant-specific changes in Enclosure I, Attachment 2; deletes the RPS APRM downscale trip. This change is not reflected in ITS Table 3.3.1.1-1.

The CTS requires daily instrument channel checks. The STS has no equivalent check for the RBM so performance ofthis test is relocated to plant procedures.

Justification for these less restrictive changes are that they were not already in the STS. The lack of equivalent surveillance in the STS is insufIicientjustification for removing the requirement.

JFC P90 states the intent to implement APRM/RBMtech specs concurrent with installation ofthe power range neutron monitor upgrade forARTS. RWE analysis associated with ARTS is credited where applicable and the associated RBM setpoints are flow-biased, rather than power dependent until ARTS hardware is installed. The ITS SRs retain power dependent setpoints.

In addition, STS Table 3.3.2.1-1 functions for RBM on IRM upscale, high power range upscale and bypass time delays are deleted.

These changes are not sufficiently discussed in P90. Staffapproval ofproposed ARTS implementation is not adequately documented and it is not obvious from the docketed discussions and markup ofITS that use ofpower dependent trip setpoints are proposed as stated in P90.

The flowbiased RBM upscale block Allowable Value is stated as "less than or equal to the value specified in the COLR." Provide documentation ofstaff approval ofcycle dependent AVs for this rod block.

THE APRM DOWNSCALETRIP IS ADDRESSED IN TECHNICAL SPECIFICATIONS CHANGE 353S I THIS WAS A SUPPLEMENT TO TECHNICAL SPECIFICATION CHANGE 353 WHICHWAS TO MODIFYTHE CTS FOR THE POWER RANGE NEUTRON MONITORUPGRADE ANDPROVIDED MARKUPS OF THE PROPOSED ITS FOR THE SAME SUBJECT.

BFN IS CURRENTLY INTHE PROCESS OF IMPLEMENTINGTHE POWER RANGE NEUTRON MONITORUPGRADE. THE APRM DOWNSCALE TRIP WILLBE DELETEDAS PART OF THOSE CHANGES. IT SHOULD BE NOTED THATA SER HAS ALREADYBEEN PREPARED FOR THE UNIT2 CHANGES BASED ON THE CTS MARKUP(AMENDMENT249) FOR UNIT2. CHANGES TO THE ITS SUBMHTAL353S I DUE TO NRC ISSUES BEING ADDRESSED WILLBE MADEANDTHE PROPOSED CHANGES RESUBMITTEDIN ITS ENTIRITY.

JFC R2 WILLBE REVISED TO PROVIDE ADDITIONAL JUSTIFICATION FOR THE RELOCATIONOF THE INSTRUMENT CHANNELCHECKS.

JFC P90 WILLBE EXPANDEDTO BETTER EXPLAINTHE STATUS OF POWER RANGE NEUTRON MONITORUPGRADE IMPLEMENTATION.

CURRENI'LYTINRBM UPSCALE BLOCKVALUEIS SPECIFIED IN CTS TABLE3.2.C NOTE 13 WHICHSTATES "THETRIP LEVELSETTING ANDCLIPPED VALUEFOR THIS SEITING SHALLBE AS SPECIFIED INTHE CORE OPERATING LIMITS REPORT" WHICH DOCUMENTS THE STAFF APPROVAL OF THE CYCLEDEPENDENT Avs.

N 10/10/97 Y

10/14/97 Y

10/15/97 N

10/7/97 PAGE 5

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCKINSTRUMENTATION COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COhfPLETE DATE ISTS-PROBLEM // 53 ITS SR 3.3.2.1.4 HAS AFREQUENCY OF 92 DAYS,WHILETHE BASES FOR SR 3.3.2.1.4 STATES THE FREQUENCY IS 184 DAYS.

BASED ON RMS // R70970605990 THE CALIBRATION FREQUENCY SUPPORTED BYTHE SETPOINT CALCULATION IS 92 DAYSANDTHUS THE BASES NEEDS TO BE MARKEDUP TO SHOW 92 DAYS. NOTE THATCALCULATIONED-22092-900118, RO, STATES IN SECTION 5.2.2 "ALLDRIFT ALLOWANCESFOR ALLCHANNELCOMPONENTS ARE BASED UPON TECHNICALSPECIFICATION SURVEILLANCE VALUES...". THE VALUEINTHE CTS IS CURRENTLY6 MONTHS BUT 3 MONTHS (92 DAYS)WILLBE UTILIZEDTO BE CONSISTENT WITHTHE APRM SURVEILLANCE REQUIREMENTS WHICHARE THE SAME TYPE INSTRUMENTS.

JFC AS WILLBE DELETED ANDJFC M4 ADDEDTO ADDRESS THE MORE RESTRICTIVE CHANGE.

Y 10/16/97 PAGE 6

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.2.2, FEEDWATER ANDMAINTURBINEHIGHWATERLEVELTRIP COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.2.2-1 3.3.2.2-2 A new requirement is added to the CTS requiring two channels per trip system offeedwater and main turbine high water level trip instrumentation OPERABLE when THERMALPOWER is '25%

RTP. The justification ofACTIONS and SRs is based on GENE-77046-1 (ITS 3.3.2.2, Reference 2).

STS Condition A is two or more trip channels inoperable.

The proposed ITS replace this conditon with one or more trip channels inoperable in each trip system.

These are equivalent statements.

THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

BFN design for Feedwater and Main Turbine High Water Level Trip Instrumentation is such that there are.two trip systems, each with two-out-of-two logic, and each capable oftripping the three feedwater.

pump turbines and the main turbine. The NUREG-1433 specification for Feedwater and Main Turbine High Water Level Trip Instrumentation is based on a tw~utwf-three logic trip system as described in the NUREG-1433 Bases. With the BFN design, iftwo feedwater and main turbine high level trip channels are inoperable in the same trip system but the remaining two channels in the other trip system are OPERABLE, Feedwater and Main Turbine High Water Level Trip capability is maintained. Thus, the wording in NUREG-1433, Specification 3.3.2.2, Condition B is inappropriate for BFN, since itwould require Condition entry withtrip capability maintained.

Proposed ISTS 3.3.2.2, Condition B states "one or more feedwater and main turbine high level trip channels inoperable in each trip system" since in this condition Feedwater and Main Turbine High Water Level Trip capability is lost until the required inoperable channels are restored to OPERABLE status or placed in trip. Similarly, to address the condition where two feedwater and main turbine high level trip channels are inoperable but Feedwater and Main Turbine High Water Level Trip capability is maintained, proposed ISTS 3.3.2.2, Condition A has been changed to require its entry for each inoperable channel (NUREG-1433, Condition A addresses one inoperable channel and proposed ISTS Condition A now addresses one or more inoperable channels).

N 10/20/97 N

10/20/97 PAGE 1

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.3. 1, POST-ACCIDENT MONITORIN COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.3.1-1 3.3.3.1-2 3.3.3.1-3 3.3.3.14 3.3.3.1-5 Proposed Note 3 is added in conjunction with table function 6, PCIV isolation position indication. The proposed note would allow separate condition entry for each containment penetmtion.

The note is generic change to the STS. Generic changes require a staff approved TSTF.

A4 does not dicuss the proposed surveillance requirement changes from once per operating cycle to once per 18 months.

CTS Table 3.2.F, Note 7, requires a Special Report ifone ofthe two monitors is inoperable for more than 7 days. ITS 3.3.3.1 requires a Special Report within 14 days ofone channel being inoperable for more than 30 days (Required ACTIONB) or two channels being inoperable for more than 7 days (Required ACTION G).

The Frequency for the CHANNELCALIBRATIONofCTS Table 4.2.F is 184 days in ITS SR 3.3.3.1.3 for the Reactor Pressure indicators.

ITS 3.3.3.1, REQUIRED ACTIONB.1, increases the submittal time from withinthe CTS Table 3.2.F, Note 7, 7 days ofexceeding the time limitfor an inoperable Primary Containment Area Radiation channel, to within 14 days ofexceeding the time limit.

ATSTF IS IN PROCESS.

TRAVELLERBWROG-22 IS TRACKING THE RECOMMENDED CHANGE TO LCO 3.3.3.1 NOTE 2 WHICHMODIFIES NOTE 2 "TO ALLOWSEPARATE CONDITIONENTRYFOR EACH PENETRATION" WHICHHAS THE SAME INPACTAS PROPOSED NOTE 3.

THE STATUS OF THE TRAVELERIS "UNDER TSTF CONSIDERATION".

SHOULD THE CHANGENOT BE APPROVED GENERICALLYIT IS BFN's INTENTIONTO JUSTIFY THE CHANGE FROM THE NUREG BASED ON PLANTSPECIFIC NEEDS. BFN CTS DO NOT CONTAINTHIS FUNCTIONANDBELIEVES THATITS INCORPORATON AS WIUITENWOULDBE OVERLY RESTRICTIVE. JFC P80 WILLBE REVISED TO PROVIDE ADDITIONALJUSTIFICATIONFOR THE CHANGE.

JFC A4 WILLBE REVISED TO ADDRESS CHANGING ONCE/CYCLE TO 18 MONTHS.

JFC LS ADDRESSES CHANGE FROM 7 DAYSTO 30 DAYSTO ALLOWFOR RESTORATION OF ASINGLE INOPERABLE CHANNEL. JFC L6 ADDRESSES REQUIRED ACTIONS IF TWO CHANNELS ARE INOPERABLE. JFC L7 ADDRESSES THE CHANGE INTHE SUBMfITALTIMEFOR THE SPECIAL REPORT FROM 7 DAYSTO 14 DAYS. TAKENTOGETHER THESE JFCs ADEQUATELYADDRESS THE LESS RESTRICTIVE ASPECTS OF THE INCORPORATION OF TABLE3.2.F INCORPORATION INTOTHE ITS.

THE VALUEOF 184 DAYS (6 MONTHS) INTHE ITS IS CORRECT FOR THE CALIBRATIONFREQUENCY OF THE REACTOR PRESSURE INDICATORSBASED ON PLANT SPECIFIC ANALYSIS. THE CTS MARKUPWILL BE REVISED TO CHANGE 18 MONTHS TO 184 DAYS. JFC A4 WILLBE REVISED TO ADDRESS THE EQUIVALENCEOF 184 DAYSTO 6 MONTHS. INADDITIONTHE ITS BASES WILLBE REVISED TO ADDRESS THE 184 DAYCALIBRATIONFREQUENCY FOR THE REACTOR PRESSURE INDICATIONINSTRUMENTATION WITHASSOCIATED JFC P56 BEING REVISED TO JUSTIFY.

JFC L7 WILLBE REVISED TO PROVIDE FURTHER JUSTIFICATIONFOR THE LESS RESTRICTIVE CHANGE.

Y 10/16/97 Y

10/17/97 N

10/17/97 Y

10/21/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.3.1, POST-ACCIDENT MONITORING COMMENT8 3.3.3.14 3.3.3.1-7 3.3.3.1-8 DESCRIPTION OF ISSUE Additional PAM functions are added to the ITS table. Provide a revised DOC that includes a reference to the staff SER approving the plant speci fic PAM functions.

LA2 states the relocated alternate monitoring methods requirements are in the Bases and plant procedures.

The ITS uses the PAM Report in Specification 5.6.6 to specifiy the reqirement to establish alternate monitoring methods with the details located in ownerwontrolled documentation.

Proposed changes are replace STS "installed control room indication channel" with "active PCIV." These are generic changes and require staff approval ofan industry TSTF. Aplant specific justification based on operational limitations or design difference from the STS was not provided.

PROPOSED RESOLUTION JFC Ml WILLBE REVISED TO PROVIDE REFERENCE TO THE SER REFERENCES.

The followingLA2DOC is provided in place ofthe original LA2 DOC:

The statement in Note (8) ofCTS Table 3.2.F relative to the initiation ofalternate monitoring methods when the Primary Containment Area Radiation monitors are inoperable has not been included in proposed ACTIONS offfS Section 3.3.3.1. However, the requirement for initiationofalternate monitoring is implied by proposed ITS 5.6.6, "PAMReport," which is required to be initiate by proposed ACTIONS B.l and G.l ofLCO 3.3.3.1 when inoperable channels have not been returned to operable status within the allowed Completion Times. Proposed ff8 5.6.6 requires a report to be submitted which outlines the alternate method ofmonitoring. The proposed 1TS Bases forACTIONS B. I and G.l ofLCO 3.3.3.1 provide additional discussion ofproposed Specification 5.6.6 and the initiation ofalternate monitoring methods.

THE PROPOSED CHANGE WAS ANATTEMPTTO BETTER CLARIFYTHE TYPE OF VALVESREQUIRING INDICATIONIN THE CONTROL ROOM. THE CHANGE WAS NOT TO CHANGE THE INTENTOF THE NOTE BUT RATHERTO ASSURE ONLY THE INTENDEDINDICATIONSARE REQUIRED. TI.IUS THE "active PCIV"WILLBE REMOVED FROM THE MARKUPAND "installed control room PAM Category I indication channel" shall replace it. THE PAM CATEGORY I IS TO CLARIFYTHE INTENT OF THE NOTE AS ITPERTAINS TO BFN ANDTHUS JFC Pl I IS APPLICABLETO THE CHANGE.

INCORP COMPLETE Y/N DATE Y

10/22/97 Y

9/29/97 Y

10/22/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.3.2, BACKUP CONTROL SYSTEM COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.3.2-1 The ITS changes SR 3.3.3.2.1 to require channel checks of functions that are normally energized and which provide indication during normal plant operation. The proposed change represents a

generic change to the STS.

SINCE THERE ARE NO REQUIREMENTS INTHE CTS TO PERFORM CHANNELCHECKS FOR BACKUP CONTROL INSTRUMENTS ANDBFN DOES NOT BELIEVETHATTHIS ADDITIONBEYONDNORMALINDICATIONOBSERVATION ADDS SIGNIFICANTBENEFITTO PLANTSAFETY SR 3.3.3.2-1 REQUIRING CHANNELCHECKS FOR INSTRUMENTATION WILLBE DELETEDANDJUSTIFICATIONPROVIDED INA REVISED JFC P30.

Y 10/3 I /97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.4.1, END OF CYCLE RECIRCULATIONPUMP TRIP COMMENT¹ 3.3.4.1-1 DESCRIPTION OF ISSUE New Surveillance Requirements are added to CTS Table 4.2.B.

ITS SR 3.3.4.1.3 requires a CHANNELCALIBRATIONand a verification that the Allowable Values are set properly. ITS SR 3.3.4.1.2 verifies the bypass capability is properly functioning.

PROPOSED RESOLUTION JFC MI WILLBE REVISED TO PROVIDE ADDITIONAL JUSTIFICATIONFOR THE ADDITIONOF THE MORE RESTRICTIVE REQUIREMENTS OF SR 3.3.4.1.2 AND SR 3.3.4.1.3.

INCORP Y/N COh(PLETE DATE 11/6/97 3.3.4.1-2 OOS The CTS RPT Initiate LOGIC CFIANNELFUNCTIONALTEST Frequency is changed from I month to 92 days in the ITS. Browns Ferry has performed a plant specific evaluation (not referenced) and concluded that this instrumentation is consistent with the GE analysis performed in GENE-77046-1.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

N 11/5/97 3.3.4.1-3 OOS 3.3.4.14 OOS 3.3.4.1-5 OOS 3.3.4.14 CTS Table 3.2.8, Note 17, allows testing for up to two hours prior to declaring that the channel INOPERABLE and REQUIRED ACTIONS taken. AITS 3.3.4.1 Surveillance Requirements Note allows testing for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instead of2 hours.

CTS Table 3.2.B, Note 17, only allows declaring the system inoperable within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ifone or more channels are INOPERABLE. This is reflected in ITS 3.3.4.1 REQUIRED ACTIONA.l. An option is provided in ITS 3.3.4.1, REQUIRED ACTIONA.2, for one or more INOPERABLE channel(s) to place all INOPERABLE channels in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, ifthis action would result in system actuation, then declaring the system inoperable per ITS 3.3.4.1, REQUIRED ACTIONA.1, is the preferred action.

CTS Table 3.2.8, Note 17, requires an orderly power reduction to be initiated immediately ifboth trip systems are INOPERABLE.

ITS 3.3.4.1, REQUIRED ACTIONB.I, allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore one trip system to OPERABLE status ifboth trip systems are INOPERABLE ITS 3.3.4.1.b and REQUIRED ACTION8.2 add an option to CTS Table 3.2.B to allow increasing the MCPR limitby an appropriate amount (specified in the COLR) ifthe instrumentation is INOPERABLE.

THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

JFC L2 WILLBE REVISED TO PROVIDE ADDITIONAL DISCUSSION ANDJUSTIFICATIONOF THE NOTE TO ITS 3.3.4.1 ACTIONA.2.

JFC L3 WILLBE REVISED TO PROVIDE FURTHER DISCUSSION OF THE CHANGE FROM IMMEDIATELYTO 2 HOURS FOR BOTH TRIP SYSTEMS INOPERABLE.

JFC L4 WILLBE REVISED TO ADDRESS APPLICATIONOF THE COLR INCREASE IN MCPR IF EOC-RPT LCO IS NOT MET AS ANALTERNATEACTION.

N 11/5/97 11/6/97 11/6/97 11/6/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.4.1, END OF CYCLE RECIRCULATIONPUMP TRIP COMMENT8 3.3.4.1-7 DESCRIPTION OF ISSUE STS BASES SR 3.3.4.1.5 statement that bypass valves are to be closed during calibration has been deleted in ITS 3.3.4.1. The Bases is modified to state that opening the bypass valves may affect operability ofthe Function ifthe valves are open above 30%

RTP. The statement to consider the Function inoperable under these conditions is deleted in ITS 3.3.4.1.

PROPOSED RESOLUTION JFC P16 WILLBE REVISED TO PROVIDE FURTHER JUSTIFICATIONFOR THE DEVIATIONFROM THE STS. THE BASES WILLBE REVISED TO CLARIFYTHE INTENTOF THE DEVIATIONIS TO ONLYDECLARETHE FUNCTIONS INOPERABLE WHENTHE BYPASS VALVESARE OPEN AND BYPASS OF FUNCTIONS DUE TO RTP OCCURS.

INCORP Y/N COhtPLETE DATE 11/7/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.4.2, ANTICIPATEDTRANSIENTS WITHOUTSCRAM-RECIRCULATIONPUMP TRIP COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.4.2-1 3.3.4.2-2 OOS 3.3.4.2-3 OOS 3.3.4.24 3.3.4.2-5 ITS SR 3.3.4.2.4 adds requirements for LOGIC SYSTEM FUNCTIONALTESTS. Since CTS Table 4.2.L does not specifically require this testing, the addition ofthis Surveillance is an additional restriction on plant operation.

The CTS Table 4.2.L ATWS-RPT Initiate LOGIC CHAI4NEL FUNCTIONALTEST Frequency is changed from I month to 92 days in ITS SR 3.3.4.2.2. A plant specific evaluation (not referenced) concluded that this instrumentation is consistent with the GE analysis performed in GENE-77046-1.

CTS Table 3.2.L, Note 2 requires the plant to be in HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the condition ofone trip system inoperable for72 hours or forthe condition ofboth trip systems inoperable.

ITS 3.3.4.2, REQUIRED ACTIONB requires a the plant to be in STARTUP within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the condition ofone ATWS trip function inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.3.4.2 Action C allows I hour to restore the ATWS-RFI'ripcapability for one function prior to initiating action to be in STARTUP. The CTS to ITS changes related to conditions ofinoperability based on trip system vice trip function arc not discussed in DOC L.2. The additional hour to repair the condition ofboth trip systems inoperable is not discussed in DOC L.2. The different shutdown track, to Mode 2 in the ITS vice Mode 3 in the CTS is not discussed in L.2. Finally, DOC L.2 discusses the option to remove the associated recirculation pump from service, yet this option was not adopted in thc proposed ITS.

CTS Table 3.2.L, Note 2 provides a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AOTfor channel repair before the channel must be declared inoperable or placed in trip.

The DOC M.l is used to justifythe change to this CTS requirement.

The L.l DOC is the appropriate.

STS SR 3.3.4.2.1 is modified in ITS SR 3.3.4.2.1 to apply only to the Reactor Vessel Water Level-LowFunction. This, in effect, deletes the CHANNELCHECK ofthe Reactor Steam Dome Pressure.

This change is not justified.

JFC M2 WILLBE REVISED TO PROVIDE ADDITIONAL JUSTIFICATIONFOR THE MORE RESTRICTIVE CHANGE.

THE REQUESTED DOCUMENTATIONWILLBE SUBMTTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPSARE REQUIRED.

JFC L2 WILLBE REVISED TO CLARIFYTHE TIME REQUIREMENTS ANDDIFFERENCE BETWEEN MODES.

REQURED ACTIOND.l WAS DELETED BECAUSE BFN IS NOT LICENSED FOR I LOOP OPERATION ANDTHEREFORE THE REFERECE IN JFC L2 WILLBE DELETED.

THE CTS MARKUPWILLBE REVISED TO SHOW JFC Ll TIED TO THE PORTION A NOTE 2 DEALINGWITHCHANNEL OPERABILITYANDJFC LI WILLBE REVISED TO PROVIDE SPECIFIC DETAILOF THE CHANGES.

JFC P50 WILLBE REVISED TO PROVIDE JUSTIFICATION Y

11/6/97 N

11/6/97 Y

11/8/97 Y

11/8/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM COMMENT8 3.3.5.1-1 OOS 3.3.5.1-2 OOS 3.3.5.1-3 OOS 3.3.5.14 OOS 3.3.5.1-5 OOS DESCRIPTION OF ISSUE The Unit I CTS Table 4.2.B calibration frequencies of3 months for Reactor LowWater Level, Reactor Low Pressure, and Reactor High Water Level functions are not consistent with Units 2 and 3 with a interval of 18 months for level and 6 months for pressure.

These frequencies are reflcctcd in ITS Table 3.3.5.1-1 for Unit I as the same as those in the ITS for Units 2 and 3. The change to the Unit I Surveillance test interval is justified as "willbe validated prior to Unit I recovery."

An allowed out ofservice time (AOT) for testing of6 hours is added to CTS Table 3.2.B. ITS 3.3.5.1, SR Note 2, allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for testing prior to entry into associated Conditions and Required Actions.

The CTS Table 3.2.B, Note I.A,AOT for repair, which allows placing CS, LPCI, and HPCI channels in trip or restoring the channel to OPERABLE status, remains at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for all Functions except the minimum flowFunctions, and is extended to 7 days for the minimum flowFunctions in ITS Table 3.3.5.1-1.

The AOT for placing ADS channels in trip, or to restore the channel to OPERABLE status, is extended to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months ifHPCI or RCIC is also INOPERABLE, or 8 days ifboth HPCI and RCIC are OPERABLE.

The CHANNELFUNCTIONALTEST frequency (STI) is extended to once per 92 days from monthly.

PROPOSED RESOLUTION THIS IS A GENERIC QUESTION ON HOWTO HANDLEUNITl.

AGENERIC RESPONSE THATSTATES MAKINGUNIT I CONSISTENT WITHUNITS UNIT2 8'c 3 IS DONE FOR CONSISTENCY ANDTHAT THE UNITI TECHNICAL SPECIFICATIONS WILLBE VERIFIEDCORRECT PRIOR TO UNITI STARTUP. THIS WILLBE ACOMMITMENTTO REVIEWUNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITTALSHOULD BE REQUIRED.

THE REQUESTED DOCUMI:NTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPSARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBMBTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPSARE RE UIRED.

INCORP Y/N N

N N

N COMPLETE DATE 10/20/97 10/20/97 10/20/97 10/20/97 10/20/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COhtPLETE DATE 3.3.5.14 3.3.5.1-7 ITS 3.3.5.1, REQUIRED ACTIONS B.3, D.2.1, and F.2, are added to CTS Table 3.2.B, Note I, to allow placing an inoperable channel in the tripped condition rather than declaring the associated supported feature inoperable.

This compensates for the inoperable status ofthe channel, restores the single failure capability and provides the required initiation capability ofthe instrumentation.

Therefore, providing this option does not impact safety. However, ifthis action would result in system actuation, then declaring the system inoperable is preferred.

Required Action D.2.1 is deleted by JFC P81. DOC L.l is incomplete in that it does not identify and discuss the difference between the CTS requirements ofAction A and the proposed replacement actions in the ITS, Actions B, C, D, F, and G. The Action repair AOT in the STS are based on NEDC-30936.

ITS Table 3.3.5.1-1, Functions I.c and 2.c required actions are changed from STS 3.3.5.1, Required Action C. I to Required Actions B.l for Modes 1,2 and 3. ITS 3.3.5.1, RA C.l requires restoring channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS 3.3.5.1, RA B. 1 requires placing channel in trip after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The changes to the Required Action from restoring operabiltiy to placing the channel in trip is not justified and deviates from the CTS and from the STS. Bases insert B3.3-101A states that there are two reactor steam dome pressure (permissive) transmitters per system arranged in a one<ut-of-two logic. The required channels column in Table 3.3.5.1-1 is 4 JFC DOC Ll has been revised to delete the reference to Required Action D.2.1. This action has been addressed in JFC P81 as not being applicable at BFN. JFC LB1 provides the discussion ofthe changes made to the CTS ActionA and incorporated into O'S as Actions B, C, D, F, and G. The action repair AOTs are based on NEDC-30936.

THE REQUESTED DOCUMENTATIONWILLBE SUBMTITED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

Y 11/19/97 N

10/20/97 The STS is based on the staff approved Topical Report NEDC-30936.

PAGE 2

t BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.5.1-8 3.3.5.1-9 3.3.5.1-10 3.3.5.1-1 I 3.3.5.1-12 3.3.5.1-13 3.3.5.1-14 The STS 3.3.5.1, REQUIRED ACTIONG. I, Note that describes APPLICABILITYfor functions 4.c, 4.e, 4.f, 4.g, S.c, S.e, S.f, and S.g is deleted.

Justification for deleting the APPLICABILITYfor ITS Table 3.3.5.1-1, functions 4.g, and S.g only is presented.

No justification for deleting the APPLICABILITYfor functions 4.c, 4.e, 4.f, S.c, S.e, and S.f is given.

Manual initiation channel requirements are deleted because these channels are not currently required at BF and because single switch logic design does not exist at BF. The staff requires the manual initiation functions.

CTS ActionA is changed to ITS Action B, C, D, F, and G. In the ITS format CTS ActionA is only equivalent to Action C.

Channel check requirements are not adopted from the STS because they are not current licensing basis requirements.

Proposed footnote (e) clarifies the trip system channel assignments.

The footnote discussed relays without providing a connection to the TS requirement for required channels per function.

The Rev.A submittal stated LPCI low flowbypass function is not included because the analysis assumptions willacheive rated injection with the bypass valve open.

NEDC-30936 is incorporated by refeince The core spray low level (function l.a) and the HPCI level 8 (function 3.c) are proposed iSTS functions that have no corresponding CTS table entry.

As stated in JFC P35 manual initiation channel requirements have been deleted for the ECCS syatems, ADS, RCIC, PCIVs, and SCIVs.

P35 provided clarification that appropriate STS Notes have been revised to remove any reference to manual initiation channel requirements.

Various BFN FSAR Sections describe manual isolation capability, however, the design is such that a single switch in the logic cannot initiate the ECCS system or subsystem. As stated in the NUREG Bases for the Manual Initiation Function, there is no speci fic FSAR safety analysis that takes credit for the Function. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion ofthe manual functions from the ITS.

See response to Item 3.3.5.14. The CTS has been revised to add a JFC flag whichjustifies the Changed action.

As stated in JFC P59, CTS does not require a channel check for these. Based on this, BFN maintains the exclusion ofthe channel check r uirement for these functions from the ITS.

Footnote (e), ffS Table 3.3.5.1-1, has been revised to clarify that a relay corresponds to a trip system.

ISTS Function 2.g was not included in ITS, as discussed in JFC P82, since TVAhas an analysis that proves that the LPCI pumps have the capability to provide the required flowto the vessle with the

'inimium flowvalve in the open position. Since this analysis did not cause any licensing documentation to change, it was not sent to the NRC for their review. This analysis can be made available for stafl review.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE RE UIRED.

The CTS tables have been revised to depict the corresponding ITS Table 3.3.5.1-1 functions I.a and 3.c.

N 11/20/97 Y

11/19/97 N

11/20/97 Y

11/20/97 N

11/19/97 N

10/20/97 Y

I 1/19/97 PAGE 3

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM COMMENT¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.5.1-15 The LA.I DOC discusses relocating trip setpoints to owner documents and retaining the CTS Alloivable Values in the ITS.

For this CTS table the "triplevel settings" column is simply renamed "AllowableValue" in the ITS format. The Allowable Values do not exist in the CTS.

The LA1 DOC has been revised to clarify that the values in the CTS heading "TripLevel Settings" are equivalent to allowable values.

TVA's methodology fordetermination ofsetpoints utilizes the CTS "TripLevel Settings" as the allowable value in establishing the nominal trip setpoint. The selection ofnominal trip setpoints plus associated inaccuracies ensures the "TripLevel Settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 which endorses ISA Std ISA467.04-1982 "Setpoint For Nuclear Safety Related Instrumentation Used in Nuclear Power Plants" and has been reviewed by the NRC in previous submittals, e.g. NRC Letter to Mr. Oliver D. Kingsley dated Jan 2, 1991, Issuance of Amendment TAC No. 77279 S 291 Y

11/19/97 PAGE 4

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION COMMENT8 3.3.6.1-1 DESCRIPTION OF ISSUE CTS Table 3.2.A, Note 15, defines the Reactor Building Ventilation Radiation (RBVR) trip functions for the refueling zone and the reactor zone as each being composed oftwo divisional trip systems with each trip system having one channel which contains two sensors, both ofwhich must be OPERABLE. ITS Table 3.3.6.1-1 depicts each trip system as having two channels, meaning each sensor is considered a channel.

PROPOSED RESOLUTION BFN agrees with the comment. The original DOC A.II for proposed ISTS 3.3.6.1 has been designated as not used and the CTS markup of CTS Table 3.2.A Note 15 (forUnits I and 3) and Note 14 (for Unit2) has been revised to reference markup for proposed ISTS 3.3.6.2 and 3.3.7.1.

INCORP Y/N COMPLETE DATE 9/30/97 3.3.6.1-2 The justification for change documented a change to ITS Table 3.3.6.1-1, when the change was implemented in ITS Table 3.3.7.1-

1. The RBVR trip functions are located in ITS Table 3.3.7.1-1 not 3.3.6.1-1.

The RWCU Temperature functions in CTS Table 4.2.A for Unit I are not consistent with those listed in CTS Table 4.2.A for Units 2 and 3. The Unit I CTS Table 4.2.A calibration frequency ofthese functions is an operating cycle versus 4 months for Units 2 and 3.

However, ITS Table 3.3.6.1-1 for Unit I is consistent withUnits 2 and 3.

The change modifies the Unit I action requirements without identifying what changed and without presenting a safety justification for proposed requirements.

The CTS markup ofUnit I Table 4.2.A for the Reactor Water Cleanup System high temperature functions has been revised to reference DOC A13 for the change in calibration frequency requirements. The original CTS marhwp ofUnit I Table 3.2A and 4.2.A provided reference to DOC A12 for the difference between the Unit I versus the Unit 2 and 3 Reactor Water Cleanup System high temperature functions. The followinggeneric response is provided in reference to DOC A12 and A13:

THIS IS A GENERIC QUESTION ON HOWTO HANDLEUNITl.

A GENERIC RESPONSE THATSTATES MAKINGUNITI CONSISTENT WITHUNITS 2 4 3 IS DONE FOR CONSISTENCY ANDTHATTHE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIEDCORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE ACOMMITMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART.

10/20/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION COMMENT8 3.3.6.1-3 OOS 3.3.6.14 DESCRIPTION OF ISSUE The Unit I CTS Table 4.2.B calibration frequencies for the RCIC and HPCI Turbine Steam Line Low Pressure functions are 3 months. This is not consistent with the 18 month interval ofUnits 2 and 3. These frequencies are included in ITS SR 3.3.6.1.5 a 18 month intervals for all units.

The change is presented as a administrative change rather than a less restrictive change ofthe surveillance testing ofUnit I.

The Unit I CTS Table 4.2.B CHANNELCHECK requirements for the RCIC and HPCI Turbine Steam Line High Flow and Exhaust Diaphragm High Pressure functions are daily. These Unit I CHANNELCHECKS are deleted from ITS Table 3.3.6.1-1.

The change is presented as a administrative change rather than a less restrictive change ofthe surveillance testing ofUnit l.

PROPOSED RESOLUTION The CTS marhwp ofUnit I Table 4.2.A for the Reactor Water Cleanup System high temperature functions has been revised to reference DOC A13 for the change in calibration frequency requirements. The original CTS marhwp ofUnit I Table 3.2.A and 4.2A. provided reference to DOC A12 for the difference between the Unit I versus the Unit 2 and 3 Reactor Water Cleanup System high temperature functions. The followinggeneric response is provided in reference to DOC A12 and A13:

THIS IS AGENERIC QUESTION ON HOW TO HANDLEUNITl.

AGENERIC RESPONSE THATSTATES MAKINGUNIT I CONSISTENT WITHUNITS 2 &3 IS DONE FOR CONSISTENCY ANDTHATTHE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIEDCORRECT PRIOR TO UNIT 1 STARTUP. THIS WILLBE A COMMITMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART.

The comment is believed to be addressing the Unit I RCIC and HPCI Turbine Steam Supply Low Pressure and Turbine Exhaust Diaphragm High Pressure functions rather than the RCIC and HPCI Steam Line High Flow and Turbine Exhaust Diaphragm High Pressure functions (Unit I CTS Table 4.2.B requires a channel check ofthe RCIC and HPCI Steam Supply Low Pressure functions but not the RCIC and HPCI Turbine Steam Line High Flow functions). The following generic response is provided:

THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNITI.

A GENERIC RESPONSE THATSTATES MAKINGUNITI CONSISTENT WITHUNITS 2 & 3 IS DONE FOR CONSISTENCY ANDTHATTHE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIEDCORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMfIM1NTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMfITAL SHOULD BE RE UIRED.

INCORP Y/N N

COMPLETE DATE 10/20/97 10/20/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENT ISOLATION COMMENT¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.6.1-5 3.3.6.1-6 OOS The CTS Table 3.2.A, Note I,Action for ITS Table 3.3.6.1-1, Functions 2.a (Reactor Low Water Level) and 2.b (High Drywell Pressure) and the corresponding Group 2 initiating logic requires Table 3.2.A, Note 1.A actions (initiate an orderly shutdown...) or Note I.B actions (to initiate an orderly load reduction and have the MSLs isolated) along withNote I.E actions (to initiate primary containment isolation within24 hours).

The ITS Table 3.3.6.1-1, REQUIRED ACTIONS A.I (Place channel in trip within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ), B. I (Restore isolation capability within I hour), and G.l (Be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ), for these Functions are consistent with the STS. CTS Table 3.2.A, Note I, does not include the ITS 3.3.6.1, REQUIRED ACTIONG.l.

This change deletes the CTS Table 3.2.A, Note I.E Action and adds the third option ofITS 3.3.6.1 REQUIRED ACTIONG.l.

This is a less restrictive change that was addressed as a more restrictive change.

The allowed out ofservice time (AOT) for placing a channel in trip when one trip system has inoperable, untrippcd channels, as defined in CTS Table 3.2.A, Note I, is extended from immediate to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in ITS 3.3.6.1, REQUIRED ACTIONA.I, for those channels common to RPS, and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in ITS 3.3.6.1, REQUIRED ACTIONA.2, for all other channels. Ajustification for this AOT extension was not provided.

The AOTs for placing a channel in trip for required surveillance testing is defined in CTS Table 3.2.A, Note 11, and is extended from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.6.1, Surveillance Requirements Note 2. Ajustification for this AOT extension was not provided.

The monthly CHANNELFUNCTIONALTEST Surveillance Test Interval (STI) in CTS Table 3.2.A is extended in ITS SR 3.3.6.1.2, to once per 92 days. Ajustification for this STI extension was not provided.

SEE A1TACHMENTI FOR RESPONSE THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

N 9/29/97 N

9/30/97 PAGE 3

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COhIPLETE DATE 3.3.6.1-7 3.3.6.1-8 ITS 3.3.6.1, REQUIRED ACTION F. I allows I hour to isolate the affected Reactor Water Cleanup (RWCU) penetration flowpath(s),

whereas CTS Table 3.2.A, Note I.C, requires immediately isolating the RWCU valves and CTS Table 3.2.B, Note I.B requires immediately declaring the HPCI/RCIC inoperable.

Note E markup for Table 3.2.B deletes the allowance to place the channel in trip. Note E marhwp should show that the option to repair the channel or place it in trip is equivalent to ffS Action A.l.

The RWCU Temperature functions in CTS Table 4.2.A for Unit I are not consistent with those listed in CTS Table 4.2A for Units 2 and 3. The Unit 1 functions temperature functions use the RWCU floor drain temperature and RWCU space temperature.

Units 2 and 3 uses 6 area space temperatures.

The STS assumes six space temperatures.

This deviation from the STS was not addressed.

However some discussion was provided in the justification for an administrative change.

The justification indicated that the diflerences would bc addressed before Unit I recovery.

The CTS markup, CTS page 3.2/4.2-22 (Unit 3) and page 3.2/4.2-23 (Units I &2), has been corrected to show that the CTS Table 3.2.B, Note I.E action is equivalent to proposed ISTS Required Action A.l.

The CTS markup for Unit I and DOC A12 indicate that the Unit I CTS RWCU Space Temperature High functions are different than the Unit 2 and 3 CTS RWCU Space Temperature High functions. DOC A12 also indicates that the proposed ISTS for Unit Iis made consistent with the proposed ISTS for Units 2 and 3 and that the differences willbe resolved prior to Unit I recovery. The NUREG-1433 markup addresses the six area space temperatures for BFN (with Unit I considered the same as Units 2 and 3 as addressed in DOC A12) and provides JFC PI I for changes between the proposed ISTS and NUREG-1433:Based on the above, the followinggeneric response is provided:

THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNITl.

A GENERIC RESPONSE THATSTATES MAKINGUNIT I CONSISTENT WITHUNITS 2 &3 IS DONE FOR CONSISTENCY ANDTHATTHE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIEDCORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMTMENTTO REVIEW UNIT 1 TECH SPECS PRIOR TO RESTART. NO REVISION OF TI.IE SUBMITTAL SHOULD BE RE URED.

Y 10/20/97 N

10/20/97 PAGE 4

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION COMMENT8 3.3.6.1-9 OOS 3.3.6.1-10 3.3.6.1-1 1

DESCRIPTION OF ISSUE System design and opemtional details found in CTS Tables 3.2.A, 3.2.B, and 4.2.a, are moved to the ITS Bases and plant procedures Trip setpoints are an operational detail not directly related to the operability ofthe instrumentation.

The Allowable Value is the required limitation ofthe parameter and this value is retained in ITS Table 3.3.6.1-1.

The LA.I DOC discusses relocating trip setpoints to owner documents and retaining the CTS Allowable Values in the ITS.

For this CTS table the "triplevel settings" column is simply renamed "AllowableValue" in the ITS format. The Allowable Values do not exist in the CTS.

Details ofthe methods for performing surveillances found in CTS Table 4.2.A, are moved to the ITS 3.3.6.1 Bases and plant procedures.

CTS markup on page 3.2/4.243 RWCU floordrain and Space Temperature high should be LB.1 NOT la.2 Proposed change delete manual initiation functions and "automatic" from loss ofisolation capability action because the functions are not current requirements and single switch isolation is not consistent with the BFN design. The staff position is that manual actuation capability was a licensing basis ofthe design and without which the design would not be meet regulatory design criteria. The absence ofCTS manual requirements is an oversight which should be corrected.

Further, current TS logic testing requirements require a complete test ofthe circuitry including the manual actuation functions.

PROPOSED RESOLUTION The LAI DOC willbe revised to clarifythat the values in the CTS heading "triplevel settings" are equivalent to Allowable Values.

The CTS "triplevel settings" are equivalent to ISTS "Allowable Values". TVA's methodology for determination ofsetpoints utilizes the CTS "triplevel settings" as the allowable value in establishing the nominal trip setpoint. The selection ofnominal trip setpoints plus associated inaccuracies ensures the CTS "trip level settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 which endorses ISA Standard ISA467.04-1982 "Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants" and has been reviewed by the NRC in previous submittals, e.g. NRC letter to Mr. Oliver D. Kingsley dated January 2, 1991, Issuance of Amendment TAC No. 77279 S291 The CTS markup for Unit I, on CTS page 3.2/4.243, has been revised to replace the LA.2 DOC reference with a LB.I DOC reference for the change in functional test frequency for the RWCU floor drain and space temperature high functions.

The BFN design is such that manual isolation capability is provided as indicated in FSAR 7.3.3 Safety Design Bases 10 and discussed in FSAR 7.3.4.5 (discussion ofthe fulfillmentofSafety Design Bases 10). However, the BFN design docs not include handswitches in the logic for generation ofprimary containment isolation signals. Manual isolation ofthe PCIVs is typically accomplished by means of handswitches for the individual PCIVs. In addition to these normal means ofmanual isolation, typically other means are available to initiate the required isolations (i.e., removal ofpower for normally energized logic, etc.). As stated in the NUREG Bases for the Manual Initiation Functions, their is no specific FSAR safety analysis that takes credit for the Functions. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion ofthe manual functions from the ISTS.

INCORP Y/N N

N COMPLETE DATE 11/8/97 10/20/97 10/20/97 PAGE 5

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.6.1-12 3.3.6.1-13 3.3.6.1-14 3.3.6.1-15 RWCU isolation functions are added to the current TS functions.

The SRs proposed include the same SRs as the CTS RWCU leve 3 isolation except a 122 day channel calibration is proposed and no channel check is included.

Proposed ITS markup is not identical to the CTS bypass allowance.

CTS provide the bypass for conditions ofnormal steam tunnel ventilation becoming inoperable.

The proposed ITS provides an allowance to bypass the trip ofFunction I.d (Main Steam Tunnel Temperature High) for conditions ofloss oftrip capability.

Deleted TS for RHR shutdown cooling isolation in Modes 4 and 5.

Licensee agreed to revise the ITS to include the isolation functions The CTS note requires the affected system to be declared inoperable a(ter closing the RHR shutdown cooling isolation valves. The justification states "an action requiring the affected system to be declared inoperable is an unnecessary reminder that other TS may be affected.

The NUREG-1433 marhwp for the RWCU Isolation Temperature Functions (NUREG-1433, 3.3.6.1, Functions S.b and S.c) has been revised to address the proposed changes in SRs. As indicated in the marhwp, the change to 122 day channel calibration is addressed in JD P42 and the absence ofthe channel check requirement is addressed in JD P59. Also, as indicated in response to Question 3.3.6.1-2, the CTS marhwp ofUnit I Table 4.2.A for the Reactor Water Cleanup System high temperature functions has been revised to reference DOC A13 for the change in calibration frequency requirements. The original CTS markup ofUnit I Table 3.2.A and 4.2.A provided reference to DOC A12 for the difference between the Unit I versus the Unit 2 and 3 Reactor Water Cleanu S

tcm hi tern erature functions.

SEE ATTACHMENT3 FOR RESPONSE The Reactor Vessel Water Level - Low, Level 3 Function has been added as Function 6.b to the proposed ISTS 3.3.6.1. The proposed applicability for this Function is Modes 3, 4, and 5. Necessary changes to the CTS Markups, DOCs, NUREG-1433 markup, and JDs have been made to su rt this chan e.

The intent ofthe referenced statement in DOC A.7 is to indicate that it is unnecessary to create a Required Action F.2 (logically connected by ANDto the proposed Required Action F. I)which would state that the aIfected system must be declared inoperable. The addition ofsuch an action would be a deviation from the format ofNUREG-1433 for this Condition and would be an unnecessary reminder ofproposed LCO 3.0.1. Proposed LCO 3.0.1 requires LCOs to be met during the MODES or other specified conditions in the Applicability. For example, proposed ISTS 3.0.1 would require proposed LCO 3.4.7, RHR Shutdown Cooling System - Hot Shutdown, to be met during its Applicability.Thus, ifduring the Applicabilityofproposed LCO 3.4.7 the RHR Shutdown Cooling Isolation Valves were isolated to comply with proposed ISTS 3.3.6.1 Required Action F. 1, proposed LCO 3.0.2 would r uire the Re uired Actions of ro sed LCO 3.4.7 to be met.

Y 10/20/97 N

10/20/97 Y

10/26/97 N

10/20/97 PAGE 6

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/Ã COMPLETE DATE 3.3.6.1-16 3.3.6.1-19 3.3.6.1-20 Proposed Action F. I requires the licensee to isolate the affected penetration flowpath for specific HPCI and RCIC functions rather than declare the system or component inoperable. ITS Action A.1 requires the channel to be tripped in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months vice the CTS requirement to repair the channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The difference between the trip versus repair actions is not discussed.

Evaluate the marhwp for revision. Deleted text is retained in ITS.

DOC discussion is missing for deleted text.

CTS 3.2.A requires primary containment isolation instrumentation OPERABLE when primary containment integrity is required.

CTS 3.7.A.2.a, primary containment integrity is required OPERABLE at all times when the reactor is critical or when the reactor water temperature is above 212'F and fuel is in the vessel.

The ITS 3.3.6.1 Applicabilityfor most functions is MODES I, 2, and 3.

This is more restrictive since CTS 3.7.A.2.a, does not require the primary containment integrity when in MODE 2, not critical and (

212'F. This change is consistent with the STS.

The justiiflicationdid not justifyadding the Applicabilityfor(

212F.

SEE ATTACHMENT2 FOR RESPONSE.

The text which was marked as deleted addressed the option to place the inoperable channel(s) in trip. This option is equiva! ent to the actions in proposed ISTS Required ActionA.l. Therefore, the CTS marhwp, CTS page 3.2/4.2-22 (Unit 3) and page 3.2/4.2-23 (Units I k2), has been corrected to add back the previously deleted text in CTS Table 3.2.B, Note I.E.

THIS MORE RESTRICTIVE CHANGE IS CONSIDERED TO BE ACCEPTABLE SINCE THE ANTICIPATEDDURATIONAND FREQUENCY OF BEING IN MODE 2, NOT CRITICALAND<212

'F, IS VERYSHORT ANDINFREQUENCT ANDWILLAHVENO ADVERSE IMPACTON THE OPERATION OF THE UNIT. THIS CHANGE IS CONSISTENT WITHNUREG-1433.

Y 10/20/97 Y

10/20/97 N

9/29/97 PAGE 7

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION

RESPONSE

ATTACHMENT1 RESPONSE TO ISSUE 3.3.6.1-5 CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions specifies when the rcquircd channels are not met for one trip system and the function is not tripped or when the required channels cannot bc met for all trip systems that one ofthc followingactions must bc taken: 1) the reactor placed in the COLD SHUTDOWN CONDITIONin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; OR 2) the operator initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Proposed ISTS LCO 3.3.6.1 Required Actions for Reactor Vessel Water Level - Low, Level 3 and DiywellPressure-High Functions require these channels when inoperable to be placed in trip in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (proposed LCO 3.3.6.1 Required Action A.I) and ifnot tripped within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or ifinitiation capability is lost and not restored in I hour (proposed LCO 3.3.6.1 Required Action B.l) the reactor to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Mode 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (proposed LCO 3.3.6.1, Condition G).

e The less restrictive 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance for tripping channels is addressed in DOC LBI for proposed ISTS LCO 3.3.6.1.

The replacement ofthe CTS requirement to initiate required actions when the required channels are not met for all trip systems with the less restrictive proposed ISTS requirement to initiate required actions within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when initiation capability is lost is addressed in DOC Ll for proposed ISTS LCO 3.3.6.1. The less restrictive change from the CTS allowed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months before being required to be in Cold Shutdown is addressed in DOC L2 for proposed ISTS LCO 3.3.6.1. The additional requirement to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is addressed in DOC Mlfor proposed ISTS LCO 3.3.6.1. The deletion ofthe CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is addressed in DOC M3 for proposed ISTS LCO 3.3.6.1. BFN maintains that the additional requirement to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and the deletion ofthe CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are morc restrictive changes as further discussed in the folloiving.

When inoperable channels arc not tripped in thc allowed out ofservice time, proposed LCO 3.3.6.1, Required Action G. I willrequire a reactor shutdown in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months where the CTS would allow power operation to continue past 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months provided the reactor could be placed in Mode 4 in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Under the proposed ISTS iftwo channels ofReactor Vessel Water Level - Low, Level 3 or two channels ofDrywell Pressure - High in the same trip system were inoperable and not tripped (automatic isolation capability lost) the reactor would be required to be shutdown in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months (I hour for Completion time ofproposed ISTS Required Action B. I plus 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Completion time ofproposed ISTS Required Action G. 1). Under the same conditions the CTS would allow power operation to continue past 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months provided the reactor could be placed in Mode 4 in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Ifa single channel ofReactor Vessel Water Level - Low, Level 3 or Drywell Pressure - High werc inoperable and not tripped both the CTS (first option) and proposed ISTS would require the reactor to bc shutdown to the specified Mode in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (for the CTS, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to be in Mode 4 per Table 3.2.A Note 1.A; for the ISTS, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for allowed out ofservice time (proposed ISTS Required Action A.l) plus 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to be in Mode 3 (proposed Required Action G.l)). Under these conditions the extended allowed out of service time results in the proposed ISTS being slightly less restrictive since under thc CTS the reactor would have to be shutdown at some point prior to expiration ofthe 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months completion time in order to cool down to Cold Shutdown conditions. As indicated above, the less restrictive 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance for tripping channels is addressed in DOC LBI for proposed ISTS LCO 3.3.6.1, and overall, the additional requirement to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (proposed LCO 3.3.6.1, Required Action G. I) is morc restrictive.

The CTS option requiring the operator initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Option 2) does not require a shutdown ofthe reactor. The CTS option requiring the reactor be placed in the COLD SHUTDOWN CONDITIONin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Option

1) as well as the proposed ISTS shutdown requirements would allow power generation longer than CTS Option 2 (Main Stcam Lines could be maintained open longer than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ). Thus, comparing the options to one another there are more restrictive and less restrictive aspects associated with both options. However, since the shutdown requirement is maintained (and the addition ofproposed LCO 3.3".6.1, Required Action G. I is overall more restrictive as discussed above) the deletion ofOption 2 reduces operation flexibilityand is thus more restrictive.

PAGE 8

RESPONSE

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION ATTACHMENT2 RESPONSE TO ISSUE 3.3.6.1-16 CTS Table 3.2.B, Note 1.A requires the specific HPCI and RCIC Function channels to be repaired in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Ifthe channels are not repaired in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , CTS Table 3.2.B, Note 1.B is entered which requires the system or component to be declared inoperable. Proposed ISTS LCO 3.3.6.1 Required Action A.I requires these channels when inoperable to be restored to OPERABLE status or tripped in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . IfRequired Action A. 1 and its associated Completion Time is not met, proposed ISTS LCO 3.3.6.1 Required Action F.1 is entered for the functions as directed by proposed ISTS Table 3.3.6.1-1. Proposed ISTS LCO 3.3.6.1 Required Action F. 1 requires the affected penetration flowpath(s) to be isolated in one hour. The change in the subsequent actions required when thc initial allowed out ofservice time is not met (i.e., change from the CTS action ofdeclaring the system or component inoperable to the proposed ISTS action of isolating the aflected penetration flowpath) is addressed in DOC M8. Relative to the initial required actions, the addition ofthe option to trip the inoperablc channels in lieu ofrepairing them is a less restrictive change and is addressed in DOC L7.

Based on the above, the difference between the trip versus repair actions is discussed in the appropriate DOC (i.e.,

DOC L7) and no revision to the M8 DOC is required. The original DOC L7 indicated that proposed ISTS Required Action A.I allows an inoperable channel to be placed in the tripped condition rather than declaring the associated supported feature inoperable. Since the CTS action ofdeclaring the associated supported feature inoperable has been replaced with proposed ISTS Required Action F. I, DOC L7 has been revised to indicate that proposed ISTS Required Action A.I allows an inoperable channel to be placed in the tripped condition rather than restored to OPERABLE status.

PAGE 9

SPONSE:

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARYCONTAINMENTISOLATION ATTACHMENT3 RESPONSE TO ISSUE 3.3.6.1-13 The inclusion ofFunction l.d (Main Steam Line Space Temperature - High) in the list of "other than Functions" in the second Completion Time for proposed ISTS 3.3.6.1 Required Action A.1 was in error and has been deleted. With Function 1.d included in the list of"other than Functions" in the second Completion Time for proposed ISTS 3.3.6.1 Required Action A.1, no requirement existed to place inoperable Function l.d channels in trip when 14 or less Function I.d channels were OPERABLE. Relative to the CTS allowance for bypass ofthe Main Steam Tunnel Temperature High Function for conditions ofnormal stcam tunnel ventilation becoming inoperable, BFN maintains the proposed ISTS incorporates this allowance without additional relaxations. CTS Table 3.2.A, Note 12, states that in the event that normal ventilation is unavailable in the main steam line tunnel, the high temperature channels may be bypassed for a period ofnot to exceed four hours. In the proposed ISTS 3.3.6.1, when multiple Function I.d channels are inoperable such that isolation capability for Function I.d is not maintained, proposed Required Action B. I is entered. The proposed ISTS 3.3.6.1 Required Action B.I Completion Time, is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Function l.d when normal ventilation is not available. The proposed Bases for this Required Action clarifies this second completion time by stating it is provided to allow the plant to avoid an MSL isolation transient when recovering from a temporary loss ofventilation in the MSL tunnel area (e.g., during performance ofthe secondary containment leak rate tests). Thus, when proposed Required Action B. 1 is cntercd for Function 1.d, four hours are allowed to restore isolation capability ifthe Function 1.d channels were made inoperable to avoid an MSL isolation transient due to a temporary loss ofventilation in the MSL tunnel area. Ifthe Function I.d channels were inoperable with normal ventilation to the MSL tunnel area available, the second completion time ofproposed ISTS 3.3.6.1 Required Action B. 1 would not apply and only I hour would be allowed to restore isolation capability. As indicated in DOC LA3, the compensatory actions associated with CTS Table 3.2.A, Note 12 have been incorporated into thc proposed Bases for ISTS 3.3.6.1 Required Action B.l.

PAGE 10

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COh(PLETE DATE 3.3.6.2-1 3.3.6.2-2 3.3.6.2-3 CTS 3.2.A combined with CTS 3.7.A.2.a, Primary Containment, requires primary containment integrity at all times when the reactor is critical or when the reactor water temperature is above 212F and fuel is in the vessel.

ITS Table 3.3.6.2-1 requires the secondary containment isolation instrumentation OPERABLE in MODES 1, 2, and 3. Since the CTS does not require primary containment integrity when in ITS 3.3.6.2 MODE2 conditions of not critical and < 212'F, this is a more restrictive change

. No ustification is rovided for this more restrictive chan e.

CTS 3.7.A.2.a does not require primlycontainment integrity "whileperforming 'open vessel'hysics tests at power levels not to exceed 5 MW(t)." ITS 3.3.6.2 does not contain this exception.

The justification is based on the provisions ofITS 3.0.8, which indicates Special Operations in ITS 3.10 allow changing specified TS requirements.

However ITS 3.10 does not address "open Vessel" physics tests.

ITS 3.3.6.2, SR Note 2, deletes "secondary containment" from STS SR Note 2.

ITS 3.3.6.2, ACTIONB modifies STS 3.3.6.2 ACTIONB by removing the words "secondary containment".

The changes werc made based on being unnecessary since they are a

art ofthe title for ITS 3.3.6.2.

THIS MORE RESTRICTIVE CHANGE IS CONSIDERED TO BE ACCEPTABLE SINCE THE ANTICIPATEDDURATIONAND FREQUENCY OF BEING IN MODE2, NOT CRITICALAND

<212'F, IS VERYSHORT ANDINFREQUENTANDWILLHAVE NO ADVERSE IMPACTON THE OPERATION OF THE UNIT.

THIS CHANGE IS CONSISTENT WITHNUREG-1433.

The AS DOC was incorrect and the proposed change is a more restrictive change. The AS DOC has been deleted and replaced with the followingM3 DOC:

CTS 3.7.A.2.a allows "Open Vessel" physics testing at power levels not to exceed S MW(t).The proposed ISTS does not include provisions for this activity, therefore this change is more restrictive.

BFN is past the point in plant lifewhere this type oftesting would be performed. This change is consistent with the BWR Standard Technical S ecifications, NUREG 1433.

The words "secondary containment" have been added back to proposed ISTS 3.3.6.2, Condition B, Required Action B.l, and SR Note 2.

N 9/27/07 CHECK WITH OPS &

MECH Y

10/20/97 PAGE I

e

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT8 3.3.6.24 3.3.6.2-5 DESCRIPTION OF ISSUE CTS Table 3.2.A, for Reactor LowWater Level and High Dryweil Pressure, for less than the minimum required OPERABLE channels, provides the options when ACTIONNote I are met.

These option are: I) place the reactor in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (ACTIONNote I.A)or 2) initiate a load reduction and isolate the Main Steam Lines within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (ACTIONNote I.B)and initiate primary containment isolation within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (ACTIONNote I.E). For the same Functions ITS 3.3.6.2, Required Actions C.l.I, C.1.2, C.2.1 and C.2.2, do not require entering cold shutdown or isolating the Main Steam Lines but, provide options, when Required Actions A.I and B.I arc not met, allowing isolation ofthe affected lines (zones) and starting the affected SGT subsystems (ITS 3.3.6.2 Required Actions C.l. 1 and C.2.1). Ifthis option is not chosen, then the affected components must be declared inoperable (ITS 3.3.6.2, Required Actions C.1.2 and C.2.2).

No justification, based upon safety analyses, is provided for deleting the CTS requirement to shutdown or isolate the Main Steam Lines.

CTS Table 3.2.A and Table 4.2.A provide separate ACTIONS and SRs for Secondary Containment Isolation Instrumentation initiating and isolation logic (Reactor Building Isolation Logic, SGTS Trains A, B, and C Logic and Group 6 Logic). ITS 3.3.6.2 deletes the Reactor Building Isolation and SGTS Logic functions (including ACTIONS) and incorporates the SRs required by the CTS for these functions into required SRs ofITS Table 3.3.6.2-1.

The discussion and justification does not demonstrate that 1TS Required Actions and SRs encompass the CTS Required Actions and SR for the logic functions.

PROPOSED RESOLUTION SEE ATI'ACHMENTI FOR RESPONSE SEE ATTACHMENT3 FOR RESPONSE.

INCORP Y/N COMPLETE DATE 5/29/97 10/20/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT8 3.3.6.2-6 DESCRIPTION OF ISSUE ITS 3.3.6.2 SR 3.3.6.2.2, CHANNELFUNCTIONALTEST, extends the Surveillance Test Interval for the CTS Table 4.2.A Channel Functional Tests from monthly to once per 92 days.

ITS 3.3.6.2, Required ActionA, extends the time in CTS Table 3.2.A, ACTION I, for tripping an inoperable channel from immediately to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for those channels common to RPS and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for all other channels.

ITS 3.3.6.2, SR Note 2, extends the Allowed Outage Time for performing surveillances in CTS Table 3.2A, Note 11, from 4 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

PROPOSED RESOLUTION THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

INCORP Y/N N

COMPLETE DATE 9/30/97 3.3.6.2-7 3.3.6.2-8 3.3.6.2-9 These changes are based on maintaining an acceptable risk in accordance with previously conducted reliabilityanalysis (NEDC 30851-P-A, Supplement 2, March 1989 and NEDC-31677-P-A, Jul 1990

. This is an extension ofAllowed Outa e Time.

ITS 3.3.6.2, Required Actions C.1.2 and C.2.2, add ACTIONS to CTS Table 3.2A that require declaring the associated systems inoperable within I hour ifsecondary containment isolation or starting the SGT System is not possible or desired.

The addition of more restrictive requirements is not administrative. Additionally, no ustification is rovided for the I hour corn letion time.

ITS 3.3.6.2, SR Note 3, extends the Allowed Outage Time for performing surveillances in CTS Table 3.2.A, Note 11, from 4 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for a CHANNELFUNCTIONALTEST. These changes are stated to be based on maintaining an acceptable risk in accordance with previously conducted reliabilityanalysis (NEDC 30851-P-A, Supplement 2, March 1989 and NEDC-31677-P-A, July 1990).

This is an extension ofAllowed Outa e Time.

ITS Table 3.3.6.2-1, Functions I and 2, Reactor Vessel Water Level - Lowand Dr@veil Pressure - High, respectively, increase the CTS Table 4.2.A Unit I CHANNELCALIBRATIONSurveillance Test Interval, for the same functions, from 3 montlis to 18 months.

This change is implemented to make the Unit I ITS be consistent with Units 2 and 3 ITS. This is an extension ofSurveillance Test Interval for Unit I is not justified.

SEE ATTACHMENT2 FOR RESPONSE THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THIS IS AGENERIC QUESTION ON HOW TO HANDLEUNITl.

A GENERIC RESPONSE THATSTATES MAKINGUNIT 1 CONSISTENT WITHUNITS 2 4 3 IS DONE FOR CONSISTENCY ANDTHATTHE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIEDCORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMffMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITTAL SHOULD BE RE UIRED.

N N

9/29/97 9/30/97 9/29/97 PAGE 3

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.6.2-10 3.3.6.2-1 1

3.3.6.2-12 3.3.6.2-13 CTS Table 4.2.A does not require an Instrument Check for the High Dryweil Pressure Function. ITS Table 3.3.6.2-1, Function 2, Drywell Pressure - High, requires SR 3.3.6.2.1, CIIANNEL CHECK every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Nojustification is provided for adding this surveillance test or deviating from the ISTS test frequency.

The Completion Time for STS 3.3.6.3, Required ActionA.l, is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Function 2 and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the other Functions.

ITS 3.3.6.2, Required Action A.I, modifies the Completion time to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Functions I and 2 and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months forthe other Functions.

This change is based on NEDC-30851-P-A, Supplement 2, March 1989, NEDC-31677-P-A, July 1990 and GENE-77046-1, February 1991.

ITS 3.3.6.2 adds SR Note 3 to STS 3.3.6.2 Surveillance Notes.

ITS 3.3.6.2, SR Note 3, allows one inoperable channel ofthe Reactor Zone and Refueling Zone Exhaust Radiation System for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for CHANNELFUNCTIONALTESTING and for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for CHANNELCALIBRATIONand maintenance as long as the downscale trip ofthe inoperable channel is placed in the tripped condition. The CTS provides the same allowance except only 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is allowed for the CHANNELFUNCTIONALTEST.

Extending 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is based on reliabilityanalyses in NEDC-30851-P-A NEDC-31677-P-A and GENE-77046-1.

CTS 3.2 and 4.2 System design and operational details are moved to the ffS 3.3.6.2 Bases and plant procedures.

Trip setpoints are an operational detail not directly related to the operability ofthe instrumentation.

The Allowable Value is the required limitation ofthe parameter and this value is retained in ITS Table 3.3.6.2-1.

The LA.I DOC discusses relocating trip setpoints to owner documents and retaining the CTS Allowable Values in the ITS.

For this CTS table the "trip level settings" column is simply renamed "Allowable Value" in the ITS forinat. The Allowable Values do not exist in the CTS.

Since a channel check is not currently required by the CTS for the High DrywellPressure function, the proposed SR 3.3.6.2.1 channel check requirement has been deleted for proposed ISTS 3.3.6.2, Function 2, Dryweil Pressure - High. The proposed ISTS Tables 3.3.6.2-1, NUREG markup, and JD P59 have been revised to address this chan e.

THE REQUESTED DOCUMENTATIONWILLBE SUBMI1TED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

THE REQUESTED DOCUMENTATIONWILLBE SUBMfITED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

The LA1 DOC willbe revised to clarifythat the values in the CTS heading "triplevel settings" are equivalent to Allowable Values.

The CTS "triplevel settings" are equivalent to ISTS "Allowable Values". TVA's methodology for determination ofsetpoints utilizes the CTS "triplevel settings" as the allowable value in establishing the nominal trip setpoint. The selection ofnominal trip setpoints plus associated inaccuracies ensures the CTS "trip level settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 which endorses ISA Standard ISA-S67.04-1 982 "Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants" and has been reviewed by the NRC in previous submittals, e.g. NRC letter to Mr.Oliver D. Kingsley dated January 2, 1991, Issuance of Amendment TAC No. 77279 TS291 N

10/20/97 N

9/30/97 N

11/8/97 PAGE 4

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE 3.3.6.2-14 Proposed change delete manual initiation functions and "automatic" from loss ofisolation capability action because the functions are not current requirements and single switch isolation is not consistent with the BFN design. The staffposition is that manual actuation capability was a licensing basis ofthe design and without which the design would not be meet regulatory design criteria. The absence ofCTS manual requirements is an oversight which should be corrected.

Further, current TS logic testing requirements require a complete test ofthe circuitry including the manual actuation functions.

The BFN design is such that manual isolation capability is provided as discussed in FSAR 5.3.3.1, 5.3.3.2, 7.3.3 Safety Design Bases 10, and 7.3.4.5. However, the BFN design is such that a single switch in the logic can not initiate the secondary containment features in even one division. Sepamte handswitches are provided for the inboard refueling zone isolation logic systems, outboard refueling zone isolation logic systems, each inboard reactor zone isolation logic system, each outboard reactor zone isolation logic system, and each of the three SGT Train Logic Systems. In addition to these normal means ofmanual isolation, typically various other means are available to initiate the required features (i.e., removal oflogic power, utilization ofhandswitches for individual dampers, etc.). As stated in the NUREG Bases for the Manual Initiation Function, their is no specific FSAR safety analysis that takes credit for the Function. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion ofthe manual functions from the ISTS.

N 10/20/97 PAGE 5

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION

RESPONSE

ATTACHMENTI FOR ISSUE 3.3.6.2-4 The same Reactor Vessel Water Level - Low, Level 3 and D~vell Pressure - High channels and initiation portions oflogic arc used in Primary Containment Isolation, Secondary Containmcnt Isolation, and CREV System Initiation. Based on the commonality ofthe instruments, the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) provides the required actions for this instrumentation. However, the required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation. In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the affects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure - High Functions require the reactor to be in the COLD SHUTDOWN CONDITIONin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. The compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure - High Functions require these channels when inoperable to be placed in trip in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (proposed LCO 3.3.6. 1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or ifinitiation capability is lost and not restored in 1 hour: 1) thc reactor to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Mode 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (proposed LCO 3.3.6.1, Condition G);

2) in I hour isolate the associated SC zone or declare associated SCIVs inoperablc ANDplace SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3) in I hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E).

As evident from the above compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell ressurc - High Functions, the requirement to shutdown the reactor has not been deleted and is maintained in proposed ISTS CO 3.3.6.1 since this is the appropriate required action for loss ofprimary containment isolation capability from these unctions. Dclction ofthe CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the change from the CTS allowed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months before being required to be in Cold Shutdown, and the additional requirement to bc in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months arc addressed in DOCs for proposed ISTS LCO 3.3.6.1. Other changes from thc CTS requirements (such as the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance for tripping channels, etc.) are addressed in DOCs for proposed ISTS LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1.

Based on the above and comment resolution for Comments 3.3.6.2-7, 3.3.7.1-1, 3.3.7.1-2, and 3.3.7.1-5, BFN proposes that deletion ofthe CTS requirements for Reactor Vessel Water Level - Low, Lcvcl 3 and Drywell Pressure - High Functions arc best described as an administrative change in the CTS markup and DOCs for proposed ISTS 3.3.6.2. Therefore, DOC L2 has been deleted, DOC A11 has been created to address the deletion ofthe CTS requirements for Reactor Vessel Water Level-Low, Level 3 and Drywell Pressure - High Functions, and DOC M2 has been created to address the addition ofproposed ISTS LCO 3.3.6.2, Condition C requirements forReactor Vessel Water Level - Low, Level 3, Drywell Prcssure - High, and Refueling Floor Exhaust Radiation - High Functions.

PAGE 6

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION

RESPONSE

ATTACHMENT2 FOR ISSUE 3.3.6.2-7 Since CTS Table 3.2.A Note 1.G is not applicable to Reactor Vessel Water Level - Low, Level 3, Drywell Prcssure - High, and Refueling Floor Exhaust Radiation - High Functions, proposed ISTS 3.3.6.2, Required Actions C.1.2 and C.2.2 as well as Required Actions C.l. I and C.2.1 are new requirements for proposed ISTS 3.3.6.2 Functions I, 2, and 4. Proposed DOC M2 has been created to address this more restrictive change.

Since CTS Table 3.2.A Note 1.G is applicablc to Reactor Zone Exhaust Radiation - High Function, proposed DOC A6 is still applicable to proposed ISTS 3.3.6.2 Functions 3. However, the original DOC A6 was incorrect. Currently, reactor shutdown per CTS I.C.1 would be required ifthe required action to isolate the reactor building and start the standby gas treatment system (CTS Table 3.2.A Note 1.G) could not be performed. Under the proposed ISTS with the SCIVs and standby gas treatment system declared inoperable both proposed ISTS LCO 3.6.4.2 Condition C and LCO 3.6.4.3 Condition D would require the reactor to be shutdown. Specifically, proposed ISTS LCO 3.6.4.3 Required Action D. 1 would require proposed ISTS LCO 3.0.3 to be entered immediately. Changes in the generic shutdown LCO (CTS I.C. I changes relative to the proposed ISTS LCO 3.0.3) arc addressed in DOCs for proposed ISTS Section 3.0. Since both the CTS and proposed ISTS would require reactor shutdown, the addition ofthe actions ofproposed ISTS 3.3.6.2, Required Actions C.1.2 and C.2.2 are considered administrative for proposed ISTS 3.3.6.2 Functions 3. However, the added 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months completion time for declaring the equipment inoperable is less restrictive. DOC A6 and Ll have been revised to reflect the above.

PAGE 7

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION

RESPONSE

ATTACHMENT3 FOR ISSUE 3.3.6.2-5 The CTS markup for the logic systems have been revised to indicate the changes from the CTS actions. Justification for these changes are provided as indicated in DOC L2, L3, L4, and M2. DOC A8 has been revised to provide additional discussion and justification for the bases ofconsidering the ISTS Required Actions and SRs for the channels and Functions encompass required actions and surveillances for the logic systems. The revised DOC A8 provides the followingdiscussion:

When a logic system is discovered to be inoperable, the proposed LOGIC SYSTEM FUNCTIONALTEST Surveillance Requirement is not met, and thus, the proposed ISTS LCO is not met per proposed SR 3.0.1.

The proposed Bases for the LOGIC SYSTEM FUNCTIONALTEST Surveillance Requirements state that these tests demonstrate the OPERABILITYofthe required isolation logic for a specific channel. Thus, each channel which can not perform the required initiation function through the logic system is declared inoperable for the associated feature and the proposed ISTS Conditions and Required Actions for the inoperable channels are entered. For example, when one ofthe three SGT Train Logic Systems is inoperable, all ofthe channels for proposed ISTS 3.3.6.2 Functions 1, 2, 3, and 4 would be declared inoperable for the associated SGT subsystem since all ofthe channels input through logic to the inoperable SGT Train Logic System. Under these conditions proposed ISTS Required Action A.I would require the logic system to be restored to OPERABLE status in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months based on the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time for Functions 1 and 2 and that in affect the channels can not be placed in trip. Under these conditions proposed ISTS Condition B would not be entered since the Functions would still be maintaining initiation capability for two SGT subsystems. Ifthe inoperable SGT Train Logic System was not restored to OPERABLE status in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , proposed ISTS Condition C would be entered which would require in one hour the associated SGT subsystem to be placed in operation or declared inoperable. Ifin the above example two ofthe three SGT Train Logic Systems were inoperable, the required actions would be the same except that proposed ISTS Condition B would be entered which would require in one hour at least one ofthe inoperable SGT Train Logic Systems to be restored to OPERABLE status or Condition C entered.

Since the action for an inoperable logic system willrequire all channels affected by the inoperability to be declared inoperable and the Required Actions for the inoperable channels taken, and since the impact on safety from a logic system being inoperable due to a logic system failure is no more severe than a logic system being inoperable due to failure ofits input channels, the potential 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed out ofservice times for the logic systems is address in DOCs LB1.

PAGE 8

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM COMhKNT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.7.1-1 3.3.7.1-2 The CTS Actions for ITS Functions I and 2 require the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or initiate primary containment isolation within24 hours ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.

The O'S requirements for these functions is to trip inoperable channels in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or declare the associated CREV subsystem inoperable I hour from discovery of loss oftrip capability in both trip systems.

DOC A.2 does not address all ofthe proposed changes to CTS requirements.

Administrative justifications cannot not be proposed for less restrictive changes.

The CTS Actions for ITS Function 3 require the operator to isolate the reactor building and start the SGTS immediately ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.

The CTS Actions for ITS Function 4 prohibit fuel handling and all operations over spent fuel and open reactor wells ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.

The ITS requirements for these functions is to trip inoperable channels in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or declare the associated CREV subsystem inoperable I hour from discovery ofloss oftrip capability in the trip system.

SEE ATfACHMENTI TO THIS LISTFOR PROPOSED RES OLUITION.

SEE ATTACHMENTI TO THIS LIST FOR PROPOSED RES OLUITION.

Y 9/30/97 Y

9/30/97 DOC A.2 does not address all ofthe proposed changes to CTS requirements.

Administrative justifications cannot not be proposed for less restrictive changes.

PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM COMMENT8 3.3.7.1-3 DESCRIPTION OF ISSUE For two inoperable channels CTS require a functional test ofthe particulate and radiation monitors once per shift. In addition, CTS actions provide a description ofthe use ofthese alarms for high radiation conditions. The required actions for failure to repair at least one channel in 30 day is ITS Action E. 1(place the CREV in operation). The CTS requires taking the actions specified in section 3.1.E.

PROPOSED RESOLUTION SEE ATTACHMENT3 TO THIS LISTFOR PROPOSED RESOLUTION INCORP Y/N N

COMPLETE DATE 9/30/97 3.3.7.14 OOS 3.3.7.1-5 Changes to the CTS Action 3.1.E are not identified and not evaluated.

The Unit I CTS Table 4.2.A calibration frequency for the High Dwell Pressure function is changed from 3 months to 18 months in ITS Table 3.3.1.1-1 Functions 3, 4 &6 to duplicate the less restrictive frequencies ofUnits 2 &3 CTS Table 4.2A. The change is printed as an administrative change resulting in ITS Table 3.3.7.1-1, Function 2, rather than as a less restrictive change ITS 3.3.7.1, REQUIRED ACTION E. 1 allows the option ofplacing CREVS in the pressurization mode ofoperation.

CTS Table 3.2.A, Note I, does not allow this option. Required Action E. I is more restrictive on CTS page 3.2/4.2-12 and Requirol Action E is less restrictive on page 3.2/4.2-34.

The addition ofa less restrictive change is not more restrictive.

THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNITI.

AGENERIC RESPONSE THATSTATES MAKINGUNIT I CONSISTENT WITHUNITS 2 &3 IS DONE FOR CONSISTENCY ANDTHATTHE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIEDCORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE ACOMMIMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITAL SHOULD BE RE UIRED.

SEE ATTACHMENT2 TO THIS LISTFOR PROPOSED RESOLUTION.

N 9/30/97 9/30/97 PAGE 2

e

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM 0

COMMENT4 3.3.7.14 OOS DESCRIPTION OF ISSUE The allowed out ofservice time (AOT) for placing a channel in trip when one trip system has inoperable, untripped channels, is defined in CTS Table 3.2.A, Note I, is extended from immediate to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in ITS 3.3.7.1, REQUIRED ACTIONB.2, for those channels common to RPS, and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in ITS 3.3.7.1, REQUIRED ACTIONC.2; for all other channels.

The AOTs for placing a channel in trip for required surveillance testing is defined in CTS Table 3.2.A, Note 11, and is extended from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.7.1, Surveillance Requirements Note 2.

PROPOSED RESOLUTION THE REQUESTED DOCUMENTATION%ILLBE SUBMITTED TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE REQUIRED.

INCORP Y/N COMPLETE DATE 9/30/97 3.3.7.1-7 3.3.7.1-8 The CHANNELFUNCTIONALTEST Surveillance Test Interval (STI) in CTS Table 3.2.A, is extended in ITS SR 3.3.7.1.2, to once per 92 days from monthly.

CTS Table 4.2.G, Note I, calls for a Control Room AirSupply Duct Radiation Monitor FUNCTIONALTEST once per month.

ITS Table 3.3.7.1-1 only requires a 92 day test interval. This change is not justified.

ITS Functions 3 and 4 are shown to have one trip system with two channels.

CTS Table 3.2.A Note (15) to Action G states these functions are comprised of two divisional trip systems with one channel in each zone and 2 sensors in each channel.

The DOC annotation for the Functional Test interval change from monthly to 92 days for the Control Room AirSupply Duct Radiation Monitors was not provided in the CTS markup ofthe Unit 3 CTS Table 4.2.G and uus incorrectly indicated as DOC A3 in the CTS markup ofthe Unit I and 2 CTS Table 4.2.G. This change is based on the analyses ofGENE-77046-1. Thus, the appropriate DOC for this change is DOC LBI. The CTS marhwp ofthe Unit I, 2, and 3 NOTES FOR TABLES 4.2.A THROUGH 4.2.L EXCEPT 4.2.D AND4.2.K (includes the notes for CTS Table 4.2.G) correctly provided the DOC LBI annotation to the change in Note 1. Based on the above, the CTS markup ofTable 4.2.G for Units I, 2, and 3 have been revised to rovide reference to DOC LBI for the chan e in Functional Test STI.

SEE ATTACHMENT4 FOR RESPONSE 9/30/97 Explain the apparent discrepancy between the CTS and ITS required number oftrip systems.

Less restrictive changes proposed for the ITS are not administrative.

PAGE 3

0 BFN ITS NRC COMMENT'ROPOSED RESOLUTIONS SECTION 3.3.7. 1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT1 ISSUE 3.3.7.1-1 &3.3.7.1-2 RESPONSE

RESPONSE

The following DOC A.2 revision is provided to address all the proposed changes to CTS requirements for the Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions.

The same Reactor Vessel Water Level - Low, Level 3, Drpvell Pressure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High channels and initiation portions oflogic are used in Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation (proposed ISTS 3.3.7.1 Functions 1, 2, 3, and 4 for CREVS). Based on the commonality ofthe instruments, the CTS Table for Control Room Isolation Instrumentation (CTS Table 3.2.G, Note 3) refers to the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) for required actions associated with this instrumentation. The required actions forthis instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation, In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the afFects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions require thc reactor to be in the COLD SHUTDOWN CONDITIONin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. The compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure-High Functions require these channels when inoperable to be placed in trip in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (proposed LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or ifinitiation capability is lost and not restored in 1 hour: 1) the reactor to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Mode 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (proposed LCO 3.3.6.1, Condition G)<

2) in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months isolate the associated SC zone or declare associated SCIVs inoperable ANDplace SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3) in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E). The less restrictive 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance for tripping channels is addressed in DOC LB1 for proposed ISTS LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1. The replacement ofthe CTS requirement to initiate required actions when the required channels are not met for all trip systems with the less restrictive proposed ISTS requirement to initiate required actions within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when initiation capability is lost is addressed in DOCs for proposed ISTS LCO 3.3.6.1 and 3.3.6.2; however, since CTS Table 3.2.A does not require the CREV system to be declared inoperable or placed in operation the requirement to take these actions when initiation capability is loss is more restrictive and is addressed in DOC Ml ofthis section. Deletion ofthe CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the change from the CTS allowed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months before being required to bc in Cold Shutdown, and the additional requirement to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are addressed in DOCs for proposed ISTS LCO 3.3.6.1. The changes associated with LCO 3.3.6.2, Condition C are addressed in DOCs for proposed ISTS LCO 3.3.6.2. The added requirements associated with the CREV System are addressed in DOC Ml ofthis section...

PAGE 4

~BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM

RESPONSE

ATTACHMENT2 ISSUE 3.3.7.1-5 RESP.ONSE The same Reactor Vessel Water Level - Low, Level 3, Drywell Pressure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High channels and initiation portions oflogic are used in Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation (proposed ISTS 3.3.7.1 Functions 1, 2, 3, and 4 for CREVS).

Based on the commonality ofthe instruments, the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) provides thc required actions for this instrumentation. However, the required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation. In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the affects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Dtywell Pressure - High Functions require the reactor to be in the COLD SHUTDOWN CONDITIONin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and primary containment isolation initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. CTS Table 3.2.A actions for Reactor Zone Exhaust Radiation - High Function require the operator to isolate the reactor building and start the SGT immediately ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. CTS Table 3.2.A actions for Refueling Floor Exhaust Radiation - High Function prohibit fuel handling and all operations over spent fuel and open reactor wells ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot bc met for all trip systems. Thc compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and D~vcllPressure - High Functions require these channels when inoperablc to be placed in trip in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (proposed LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or ifinitiation capability is lost and not restored in 1 hour: 1) the reactor to bc in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Mode 4 in 36 urs (proposed LCO 3.3.6.1, Condition G); 2) in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months isolate the associated SC zone or declare associated SCIVs inoperable ND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3)'in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E). The compiled proposed ISTS requirement for Reactor Zone Exhaust Radiation - High and Refueling Floor Exhaust Radiation - High Functions require these channels when inoperable to be placed in trip in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (proposed LCO 3.3.6.2 and 3.3.7.1) and ifnot tripped within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or ifinitiation capability is lost and not restored in 1 hour: I) in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months isolate the associated SC zone or declare associated SCIVs inoperable ANDplace SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C) and 2) in I hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E).

As evident from the above, for Reactor Vessel Water Level - Low, Level 3, D~vcllPrcssure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High Functions the proposed ISTS adds requirements that the CREV system be declared inoperable or placed in operation as well as maintains requirements relative to reactor shutdown (for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High) and isolation ofthe associated SC zones and placement ofthe SGT in service (for Reactor Zone Exhaust Radiation - High). The replacement ofthe CTS requirement to prohibit fuel handling and all operations over spent fuel and open reactor wells with the proposed LCO 3.3.6.2, Condition C requirements for the Refueling Floor Exhaust Radiation - High Function is addressed in DOCs for proposed ISTS LCO 3.3.6.2 and is unrelated to thc addition ofthe requirements for the CREV system (Other changes to CTS requirements are addressed in DOCs for proposed ISTS LCO 3.3.6. 1, 3.3.6.2, and 3.3.7.1). Based on the above, the added requirements to place the associated CREV subsystem in service or declare the associated CREV subsystem inoperable are more restrictive changes for proposed ISTS 3.3.7.1 Functions I, 2, 3, and 4 and these changes are appropriately addressed in DOC Ml and markup ofCTS pages for CTS Table 3.2.A.

As indicated in DOC Ml,for proposed ISTS 3.3.7.1 Function 5 the requirement to declare the associated CREV subsystem inoperable when at least one Function 5 channel is not returned to OPERABLE status in the allowed out ofservice time currently exists in Note (2) ofCTS Table 3.2.G. This discussion in DOC Ml is intended to exclude Ml applicability to proposed ISTS 3.7.1 Function 5. Since the CTS currently requires the associated CREV subsystem to be declared inoperable when at least one unction 5 channel is not returned to OPERABLE status in the allowed out ofservice time, the option ofplacing the associated CREV subsystem in operation is less restrictive for proposed ISTS 3.3.7.1 Function 5 and is addressed in DOC Ll and markup of

'TS page 3.2/4.2-34 (Units 1 and 2) and page 3.2/4.2-33 (Unit 3). DOC Ll has been revised to indicate that it is only less restrictive for proposed ISTS 3.3.7.1 Function 5.

PAGE 5

RESPONSE

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT3 ISSUE 3.3.7.1-3

RESPONSE

The CTS Table 3.2.G, Note 2 requirement for functional test ofthe particulate and radiation monitors once per shift when two channels ofControl Room AirSupply Duct Radiation Monitors are inoperable and the description ofthe use ofthese alarms forhigh radiation conditions is captured by proposed ISTS LCO 3.3.7.1, Required Action D.2 and its associated Bases. The proposed ISTS Bases for Required Actions D.2 state: "... an allowed outage time of30 days is provided to restore at least one channel to OPERABLE status provided that the alternate monitoring capability is verified functional once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The alternate monitoring capability is provided by the control room particulate monitor (RM-90-53) and radiation monitor (RE-90-8). These monitors alarm in the control room on high activity. Upon receipt ofthese alarms, the operator is required to manually isolate the control room and manually initiate the emergency pressurization system". The use ofa 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency for proposed ISTS LCO 3.3.7.1, Required Action D.2 is equivalent to the CTS requirement since CTS Table 1.1 defines the surveillance frequency ofshift as at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The CTS required actions for failure to repair at least one channel in 30 days is to declare the system initiated by these monitors inoperable and take action as specified in CTS section 3.7.E. The proposed ISTS required actions for failure to repair at least one channel in 30 days is to place the associated CREV subsystem(s) in the pressurization mode of operation (proposed ISTS LCO 3.3.7.1, Required Action E. 1) OR Declare associated CREV subsystem inoperable (proposed ISTS LCO 3.3.7.1, Required Action E.2). The addition ofthe ISTS proposed option to place the associated CREV subsystem(s) in the pressurization mode ofoperation (proposed ISTS LCO 3.3.7.1, Required Action E. 1) is less estrictive for Function 5 and is addressed by DOC Ll.Ifthe ISTS proposed option to place the associated CREV bsystem(s) in the pressurization mode ofoperation is not performed, both the CTS and proposed ISTS would require both CREV subsystems to be declared inoperable under these conditions. With both CREV subsystems declared inoperable under the current Technical Specifications, CTS LCO 3.7.E, Control Room Emergency Ventilation, would be entered (with a CREV subsystem declared inoperable entry into CTS LCO 3.7.E would be required even without the CTS Table 3.2.G Note 2 direction to enter CTS LCO 3.7.E). With both CREV subsystems declared inoperable, CTS LCO 3.7.E.I (requirement fortwo CREV subsystems to be OPERABLE) would not be met, and thus, CTS LCO 3.7.E.4 would require reactor shutdowns to be initiated and all reactors to be in COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for REACTOR POWER OPERATIONS and refueling operations to be terminated within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (the other two CTS LCO actions in CTS 3.7.E, CTS LCO 3.7.E.2 and 3.7.E.3, address required results from surveillance tests and AOTfor one CREV subsystem inoperable). With both CREV subsystems declared inoperable under the proposed ISTS, proposed ISTS LCO 3.7.3, CREV System, would be entered as applicable on each Unit. Proposed LCO 3.7.3, Required Action D. I for each Unit in MODE 1, 2, or 3 would require immediate entry into proposed ISTS LCO 3.0.3 (generic LCO for reactor shutdown), and proposed LCO 3.7.3, Condition E for each unit in process ofmovement ofirradiated fuel assemblies in the secondary containment, CORE ALTERATIONS,or OPDRVs would require suspension ofthese in process activities. Since CTS Table 3.2.6, Note 2 and proposed ISTS 3.3.7.1 both provide for declaring the CREV subsystems inoperable under these conditions and rely on the CREV System LCOs to address further actions, the changes between CTS LCO 3.7.E and ISTS LCO 3.7.3 when both CREV subsystems are declared inoperable are not addressed in the markups for proposed ISTS section 3.3.7.1. However, as evident from the above, the CTS and proposed ISTS required actions for both CREV subsystem inoperable are similar, and the changes between CTS LCO 3.7.E and ISTS LCO 3.7.3 when both CREV subsystems are declared inoperable are addressed in the markups for proposed ISTS section 3.7.3.

PAGE 6

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT4 ISSUE 3.3.7.1-8

RESPONSE

The original JFC P67 and added wording to the Bases indicating that there is only one trip system for proposed ISTS LCO 3.3.7.1 Functions 3 and 4 were incorrect since there are two trip systems for these Functions as stated in CTS Table 3.2.A Note 15 (for Units 1 and 3) and Note 14 (for Unit 2). Based on DOC A4 for proposed ISTS section 3.3.7.1, the intent ofthe originally proposed ISTS Table 3.3.7.1-1 was to indicate that there are two trip systems for these Functions with each Function containing two channels (sensors) per trip system. However, based on the lack of clarity ofthe original proposed change and that the Test AOTofCTS Table 3.2.A Note 11 (proposed to be maintained as ISTS 3.3.7.1 Surveillance Requirements Note 3) is based on the channel definition in CTS Table 3.2.A Note 15 (for Units 1 and 3) and Note 14 (for Unit 2), the proposed ISTS has been revised to maintain the original CTS channel designation (i.e., two divisional trip systems with both trip systems contain one channel ofeach Function and each channel containing two sensors).

Based on the above the following changes have been made. The original JFC P67 has been deleted and replaced with a new JFC P67 which provides justification for the deletion ofthe words "...in both trip systems." Proposed ISTS Tables 3.3.7.1-1 have been revised to indicate 1 channel ofFunctions 3 and 4 are required per trip system. The original DOC A4 has been deleted and marked as not used and appropriate CTS markup revisions made. Appropriate changes to the proposed bases for ISTS 3.3.7.1 have been made. Similar changes were also made for proposed ISTS 3.3.6.2 since these channels are common for both CREV System and Secondary Containment Isolation initiation.

(Note the principal description ofthe channels is provided in the proposed Bases for ISTS 3.3.6.2, APPLICABLE SAFET YANALYSES, LCO, and APPLICABILITYfor Functions 3 and 4; the proposed Bases for ISTS 3.3.7.1 efers to the Bases for 3.3.6.2 for additional information on channel arrangements.)

PAGE 7

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.8.1, LOSS OF POWER COMMENT0 3.3.8.1-1 3.3.8.1-2 3.3.8.1-3 3.3.8.14 DESCRIPTION OF ISSUE CTS 3.9.B. I I.a provides a 10 day AOTfor inoperable Joss of voltage channels provided the degraded voltage relay channel on the same board is OPERABLE. ITS 3.3.8.1, REQUIRED Action B. I docs not require verification that the other undervoltage relay channel on the same board is OPERABLE. In addition, ITS allows multiple condition entry which means any ofthe specified condtions can exist at the same time with their own completion time clocks. As such channels can be inoperable simultaneously for both loss ofvoltage and degraded voltage functions without entering a shutdown conditon. This is a less restrictive change to the CTS which othenvise would require entry into 3.0.3. Similar changes arc made to the CTS 3.9.B. I I.b and 3.9.B.I I.c.

Less restrictive requirements, such as deletion ofCTS 3.9.B. I I.a, b and c verification requirements are not administrative changes.

Specific CTS changes must be identified and discussed.

ITS 3.3.8.1 SR Note 2 proposed a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months delay from entering into the associated Conditions and Required Actions for a channel placed in an inoperable status solely forperformance ofRequired Surveillances provided the associated Function maintains initiation capability for 3 out of4 diesel generators.

This relaxation ofrequirements is added to the requirements of CTS 3.9.A.3 without a technical justification. The proposed change does not conform to the STS allowance which provides an allowance not to enter TS Actions because individual DG trip capability is maintained.

The impact ofthis proposed note is to add two hours to the channel repair time when testing.

The A.ljustification is used for addition ofthe "separate condtion entry" note to the Actions. A.l is a discussion ofeditorial changes which is not acceptable for technical changes to the CTS.

LA.I allowable value items are incorrectly marked.

PROPOSED RESOLUTION TINITS, ITS BASES, CTS MARKUP,JFC, ISTS NUREG MARKUP,AND ISTS NUREG BASES MARKUPSECTIONS HAVEBEEN REVISED TO REQUIRE THE CTS VERIFICATION OF OPERABILITYOF THE LOP INSTRUMENTATIONNOT TAKENOUT OF SERVICE.

THE ITS, ITS BASES, ISTS NUREG MARKUP,AND ISTS NUREG BASES MARKUPHAVEBEEN REVISED TO DELETE SR NOTE 2.

DOC A2 HAS BEEN ADDEDTO PROVIDE ADDITIONAL JUSTIFICATIONFOR THE "SEPARATE CONDITION ENTRY" NOTE. THE A2 NOTE CLARIFIES THATTHE ITS NOTE IS CONSISTENT WITHTHE NUREG-1433 REQUIREMENTS AND PROVIDES CLARIFICATIONON THE CURRENT INTERPRETATION OF EXISTING SPECIFICATION.

CTS TABLE4.9A.4.C HAS BEEN REVISED TO CORRECTLY DEPICT THE LA.I APPLICABILffY.

INCORP Y/N COMPLETE DATE 10/30/97 10/30/97 10/30/97 10/30/97 PAGE I

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.8.1, LOSS OF POWER COMMENT8 3.3.8.1-5 3.3.8.1-6 DESCRIPTION OF ISSUE The licensee is not currently required to perform Loss ofoffsite power instrumentation channel checks or channel functional test.

The licensee proposed to maintain their current TS in the ITS.

This applies to functions I.a and 2.a ofTable 3.3.8.1-1. The time delay functions in the same table, functions I.b and 2.b are new requirements.

Provide supporting justification, based on operational experience, to confirm the reliabilityofthe time delay functions to perform their intended safety function without periodic channel check and channel functional test requirements.

System design and operational details are moved to the ITS 3.3.8.1 Bases and plant procedures.

Trip setpoints are an operational detail not directly related to the operability ofthe instrumentation.

The Allowable Value is the required limitation ofthe parameter and this value is retained in ITS Table 3.3.8.1-1.

The LA.I DOC discusses relocating timer trip setpoints to owner documents and retaining the CTS Allowable Values in the ITS.

For this CTS table the "triplevel settings" column is simply renamed "AllowableValue" in the ITS format. The Allowable Values do not exist in the CTS and the proposed ITS allowable values (CTS setpoints) are changed withoutjustification.

PROPOSED RESOLUTION THE TIMEDELAYFUNCTIONS I.b AND2.b IN ITS TABLE 3.3.8.1-1 ARE NOT NEW REQUIREMENTS. CTS TABLE 4.9.A.4.C LISTS THESE FUNCTIONS UNDER ITEM 1. TRIP RANGE, ANDITEM3. TIMER2-211-IA. THESE INSTRUMENTS DO NOT CUMKNTLYREQUIRE A CHANNELCHECK OR CHANNELFUNCTIONALTEST. BFN PROPOSED SURVEILLANCEREQUIREMENTS, WHICHDO NOT INCLUDE NUREG-1433 SRs 3.3.8.1.1 AND3.3.8.1.2, ARE BASED ON BFNs CURRENT LICENSING BASIS.

THE LA.1 DOC HAS BEEN REVISED TO CLARIFYTHATTHE VALUESINTHE CTS HEADING"TRIP LEVELSETTINGS ARE EQUIVALENTTO ALLOWABLE,VALUES.

TVA'S METHODOLOGYFOR DETERMINATIONOF SETPOINTS UTILIZESTHE CTS "TRIP LEVELSETIlNGS" AS THE ALLOWABLEVALUEINESTABLISHINGTHE NOMNALTRIP SETPOINT. THE SELECTION OF NOMINALTRIP SETPOINTS PLUS ASSOCIATED INACCURACIES ENSURES THE "TRIP LEVELSETIINGS" ARE NOT EXCEEDED. TVA'S SETPOINT METHODOLOGYIS CONSISTENT WlTHRG 1.105 WHICH ENDORSES ISA STD ISA-S67.04-1 982 "SETPOINT FOR NUCLEARSAFETY RELATEDINSTRUMENTATIONUSED IN NUCLEARPOWER PLANTS"ANDHAS BEEN REVIEWED BY THE NRC IN PREVIOUS SUBMITTALS,e.g. NRC LEITERTO MR. OLIVERD. KINGSLEYDATEDJAN 2, 1991, ISSUANCE OF AMENDMENT TAC NO. 77279 291 INCORP Y/N N

COht PLETE DATE 10/30/97 10/30/97 PAGE 2

BFN ITS NRC COMMENTPROPOSED RESOLUTIONS SECTION 3.3.3.2, REACTOR PROTECTION SYSTEM ELECTRIC POWER MONITORING COMMENT8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE 3.3.8.2-1 3.3.8.2-2 3.3.8.2-3 CTS 4.1.B does not specify a Channel Calibration, but ITS SR 3.3.8.2.2 adds CHANNELCALIBRATIONrequirements with an surveillance frequency of 184 days. Time delay setting requirements are added to ITS SR 3.3.8.2.2 for the undervoltage, overvoltage, and underfrequency protective devices ofthe RPS MG set. These time delay settings are not required by the CTS. Time delay settings and surveillance interval are based on previous plant practice.

These additional restrictions on plant operation are not justified as a more restrictive change.

CTS applicability requires operability oftwo RPS-EPM channels for each inservice MG Set or alternate source.

ITS applicability requires operability oftwo RPS EPM assemblies for each inservice MG Set or alternate power supply. DOC do not justifythe changing LCO terms from channels to assemblies.

CTS 4.1.B does not specify a Channel Calibration, but ITS SR 3.3.8.2.2 adds CHANNELCALIBRATIONrequirements with an surveillance frequency of 184 days. This requirement is added with a 184 day interval since this test is performed during the CFT (SR 3.3.8.2.1).

The time delay relays delay the RPS power monitoring assemblies'ignal providing a time delay to ensure minor bus fluctuations, caused by activities such as switching loads, do not cause an unnecessary trip ofthe RPS power supply. The time delay is an integral part ofthe RPS power monitoring channel and therefore its setpoint is required to be confirmed to be properly set to ensure operability ofthe power monitoring channel. DOC M2 provides adequate justification for this more restrictive change.

The followingA4 DOC is provided:

CTS 3.1.B requires two RPS power monitoring channels for each inservice RPS MG set or alternate source to be OPERABLE and CTS 3.1.B.I and 3.1.B.2 address LCO actions for inoperable RPS electric power monitoring channels. The LCO and ACTIONS ofproposed ISTS Section 3.3.8.2 are presented in terms ofRPS electric power monitoring assemblies. The change from the use ofthe term channels to the term assemblies is considered administrative since in both, specifications the intent ofthe terms are the same. Specifically, in the CTS the contactor and associated sensing logic is intended to be considered as one RPS power monitoring channel. Referring to the contactor and associated sensing logic as an assembly, as in the proposed ISTS, is more appropriate since the overvoltage, undervoltage, and underfrequency instruments are each considered as channels within each assembl CTS 4.1.B.2 does not specify a channel calibration, however it does require the trip level settings ofthe circuit protectors be verified. ITS has included this requirement under the CHANNELCALIBRATION heading consistent withNUREG 1433.

The SR 3.3.8.2.1 Note has been deleted.

N 11/05/97 Y

9/29/97 Y

11/05/97 Explain the absense ofthe SR 3.3.8.2.1 Note on SR 3.3.8.2.2 to allow a delay in required testing based on the Mode ofoperation.

PAGE I

'-0 EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3. 3 TVA is submitting a proposed supplement to TS-362 for ITS Section 3.3, INSTRUMENTATION.

This supplement makes several changes associated with NRC comments on Section 3.3 as referenced in NRC letter to Oliver D. Kingsley dated June 12, 1997, with the subject "BROWNS FERRY NUCLEAR PLANT UNITS 1,2,AND 3 REQUEST FOR ADDITIONAL INFORMATION REGARDING IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432, M96433)",

and incorporates changes resulting from internal TVA reviews.

A synopsis of the ITS and ITS BASES changes is provided below.

SECTION 3.3.1.1, RPS INSTRUMENTATION Table 3.3.1.1-1 Modified by adding applicability of MODE 5" and associated Surveillance Requirements (SRs) to FUNCTIONS 2.a, Average Range Monitors Neutron Flux High Setdown, and 2.e, Average Range Monitors Neutron Inop.

This change is to make the ITS consistent with the requirements of CTS Table 3.1.A.

This is in response to NRC comment 3.3.1.1-17.

BASES g BACKGROUND Corrected typographical errors on page B 3.3-1 to make consistent with NUREG-1433 Markup.

BASES, APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Added discussion of MODE 5 applicability in "2.a. Average Power Range Monitor Neutron Flux High, Setdown".

This incorporates CTS Table 3.1.A note 21 discussion of use of SRM noncoincidence High Flux Scram by removing the shorting links.

Added Instrument

UNIDs, as additional information, to "3. Reactor Vessel Steam Dome Pressure High".

Added Instrument UNIDs, as additional information, to "4. Reactor Vessel Water Level Low, Level 3".

Added Instrument

UNIDs, as additional information, to "6. Drywell Pressure High".

Added Instrument

UNIDs, as additional information, to "7.a, 7.b.

Scram Discharge Volume Water Level High".

Page 1 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3. 3 Added Instrument

UNIDs, as additional information, to "9. Turbine Control Valve Fast Closure, Trip Oil Pressure-Low" and changed description from "transmitter" to "switch" because BFN uses discrete switches not transmitters for this function.

Added Instrument UNIDs, as additional information, to "13.

Low Scram Pilot Air Header Pressure".

Note that this function does not exist for Unit 1.

BASES ~

ACTIONS Provided specific additional details by Function in C.1 to better define when Functions lose trip capability due to multiple inoperable/untripped channels.

BASEST SURVEILLANCE REQUIREMENTS Corrected typographical omission by adding "and APRM" to third paragraph of SR 3.3.1.1.3 to match the original NUREG-1433 mark-up.

Corrected SR 3.3.1.1.9, SR 3.3.1.1.10,and SR 3.3.1.1.13 by deleting "For the APRM Simulated Thermal Power-High

Function, SR 3.3.1.1.9 also includes calibrating the associated recirculation loop flow channel" and "also" because the calibration of the recirculation flow loop is addressed in SR 3.3.1.1.11 instead of SR 3.3.1.1.9.

Corrected typographical omission by adding "calibrated flow signal and, therefore, the APRM Function accurately reflects the required setpoint as a function of flow" in first paragraph of SR 3.3.1.1.11 to match the original NUREG-1433 markup.

Added instrument UNIDs to identify instrumentation addressed by calibration of bypass channels in SR 3.3.1.1.15.

SECTION 3.3.1.2, SOURCE RANGE MONITOR (SRM)

INSTRUMENTATION SURVEILLANCE REQUIREMENTS Deleted Note 2 to SR 3.3.1.2.4 and made associated revisions (change NOTES to NOTE and deleted number 1 for the remaining note) because Note 2 conflicts with Note b to Table 3.3.1.2-1.

The effect of this deletion is that the required SRM OPERABLE channels will still require verification of a count rate R 3.0 cps and a signal-to-noise ratio of ~ 3:1.

Page 2 of24

e

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3

BASES, SURVEILLANCE REQUIREMENTS Deleted reference and associated'text to Note 2 for SR 3.3.1.2.4.

Replaced "only" with "mainly" in second paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 to clarify that reactivity changes in MODES 3 and 4 are not due "only to control rod movement",

but control rod movement is the main cause of reactivity changes.

Replaced "the Surveillance" in fourth paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 with "SR 3.3.1.2.6" to clarify which of the SRs the note pertains to.

Replaced "Frequency" with "Allowance" in fourth paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 because the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allotted after IRMs are on Range 2 or below to perform the SR is better described as an allowance rather than a Frequency which implies a time frame between performances.

Corrected "18 month" to "92 day" in second paragraph of SR 3.3.1.2.7.

The 18 month value was not changed to 92 day value for applicability at the same time (Rev 0 markup) as the SR and other references to it.

Replaced "Frequency" with "Allowance" in second paragraph of SR 3.3.1.2.7 because the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allotted after IRMs are on Range 2 or below to perform the SR is better described as an allowance rather than a Frequency which implies a time frame between performances.

SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION

BASES, BACKGROUND Inserted "on" between based and position in third paragraph of sentence which read "The RWM determines the actual sequence based position indication for each control rod."

The insertion of "on" clarifies the intent of the sentence.

BASES, APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Changed 10%

RTP to ~

10%

RTP in fourth paragraph of "2. Rod Worth Minimizer" to agree with several other locations, including Note c to Function 2

(RWM) in ITS Table Page3 of24

0 EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3. 3 3.3.2.1-1, that use the ~

10%

RTP for when OPERABILITY of the Rod Worth Minimizer is required.

BASES, SURVEILLANCE REQUIREMENTS Changed the Frequency in third paragraph of "SR 3.3.2.1.4" from "184 day" to "92 day" to agree with the Frequency of the Channel Calibration specified in the Surveillance Requirement.

This value is based on a site specific setpoint analysis that supports the 92 day Frequency.

SECTION 3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION ACTIONS Changed CONDITION A. from one CHANNEL inoperable to one or more in the same trip system inoperable because the other trip system maintains the ability to perform the required action (trip feedwater and main turbines).

Changed CHANNEL in REQUIRED ACTION A.l to CHANNEL(S) to indicate that it could be more than one channel.

SURVEILLANCE REQUIREMENTS Changed Allowable Value for SR 3:3.2.2.3 from 588 inches above vessel zero to 586 inches above vessel zero.

This change made to agree with Analytical Limit and Scaling and Setpoint Analysis Calculations.

BASES, BACKGROUND Added Instrument UNIDs in the third paragraph to better identify the trip units which actuate the trip logic.

BASES, ACTIONS Revised the description of ACTION A.l to address acceptability of having more than one CHANNEL in the same trip system inoperable based on the plant specific trip logic.

Page 4 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3.3 SECTION 3

3 3

1 i POST ACCIDENT MONITORING (PAM) 1NSTRUMENTATION SURVEILLANCE REQUIREMENTS Corrected SR 3.3.3.1.4 from "Reactor Pressure, Drywell, and Torus H~ Analyzer Functions" to "Reactor Pressure, and the Drywell and Torus H~ Analyzer Functions" which more clearly shows that the Drywell and Torus H~ Analyzer is one Function.

TABLE 3.3.3.1-1 Revised "Active PC1V" in Note b to "installed Control Room PAM Category 1 indication CHANNEL" to more clearly define when only one position indication for a penetration flow path is required.

BASES, LCO 0

Added Instrument UNIDs, as additional information, to "1. Reactor Steam Dome Pressure".

Added Instrument UNIDs, as additional information, to "2. Reactor Vessel Water Level".

Added Instrument UNIDs, as additional information, to "3. Suppression Pool Water Level".

Added Instrument

UNIDs, as additional information, to "4. Drywell Pressure".

Added Instrument UNIDs, as additional information, to "5. Primary Containment Area Radiation (High Range)

Added "The PCIV position PAM indication instrumentation consists of the Category 1 PCIV position indications identified in Reference 4" to the beginning of the second paragraph of "6. Primary Containment Isolation Valve (PCIV)

Position".

This provides a reference for the identification of the PAM PCIV position indications.

Added Instrument UNIDs, as additional information, to "7. Drywell and Torus Hydrogen Analyzers".

Deleted "or oxygen" from "7. Drywell and Torus Hydrogen Analyzers" because hydrogen is the only parameter of concern.

This is consistent with the deletion of oxygen analyzer function from other parts of the ITS.

Pago 5 of24

0 EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3.3 Added Instrument UNIDs, as additional information,.to "8. Suppression Pool Water Temperature".

Added "For a channel to be OPERABLE, at least 7 of its 8

sensors must be OPERABLE" to "8. Suppression Pool Water Temperature".

This incorporates Note 6 from CTS Table 3.2.F into the ITS BASES.

Added Instrument UNIDs, as additional information, to "9. Drywell Atmosphere Temperature".

Changed "transmitters" to "sensors" in "9. Drywell Atmosphere Temperature" because the instruments which generate the signal (RTDs) are more appropriately described as sensors.

BASES ~

ACTIONS Added "does" to ACTION F.1 for clarity which makes the statement read "the plant must be brought to a

MODE in which the LCO does not apply".

BASEST SURVEILLANCE REQUIREMENTS Addressed SR 3.3.3.1-4 with SR 3.3.3.1-2 and SR 3.3.3.1-3.

These SRs all address CHANNEL CALIBRATION. In the original NUREG-1433 mark-up two additional SRs for CHANNEL CALIBRATIONs were added to address having 3 different calibration frequencies but only one of the additional SRs was added to the NUREG BASES markup.

Adding SR 3.3.3.1-4 and inserting "The 184 day frequency for CHANNEL CALIBRATION of the REACTOR Pressure Indication is based on plant specific analysis" will correct the omission from the Revision 0 markup.

This change addresses NRC question 3.3.3.1-4.

Page 6 of24

0 EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3. 3 SECTION 3.3.3.2, BACKUP CONTROL SYSTEM SURVEILLANCE REQUIREMENTS Deleted SR 3.3.3.2.1 and renumbered the remaining SRs.

SR 3.3.3.2.1 was to "Perform a CHANNEL CHECK for each required instrumentation channel that is normally energized and provides indication during normal plant operation".

NUREG-1433 did not include the part of the SR that states "and provides indication during normal plant operation".

The addition of the clarification was rejected by the NRC as a Generic Change to The STS.

Without the clarification CHANNEL CHECKS would be required for all of the transfer/control functions in addition to the indication functions.

There are no CTS requirements to perform CHANNEL CHECKS for the Backup Control Instrumentation.

The requirement was therefore deleted from the ITS because the benefits of performing the CHANNEL CHECKS is not sufficient to justify the additional manpower required.

BASES, SURVEILLANCE REQUIREMENTS Deleted BASES for SR 3.3.3.2.1 because the SR was deleted as stated above.

Renumbered the remaining SRs due to the deletion.

BASES, TABLE B3.3.3.2-1 Replaced existing Table 3.3.3.2-1 (Backup Control System Instrumentation and Controls) with a new one which better defined the required functions and contained notes to better explain the number of functions required.

SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT)

INSTRUMENTATION BASES ~

BACKGROUND Revised third paragraph of the BACKGROUND to delete discussion of "electronic equipment (e.g., trip relays) because the instrumentation used for EOC-RPT utilizes discrete switches not analog transmitters.

Also added "channel's pre-established" to "When the channel's re-established setpoint is exceeded,..."

as clarification.

Page7 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)= SUPPLEMENT TO ITS SECTION 3.3 BASES APPLICABLE SAFETY ANALYSES~

LCO~

AND APPLICABILITY For the "Turbine Stop Valve Closure" second paragraph change "switches" to "signals" in the sentence "There are two separate position switches associated with each stop valve..." because in actuality there is only one switch housing that provides the separate contacts for the signals.

Also added "Therefore, to consider this function operable bypass of the function must not occur when bypass valves are open".

This change will allow testing of the bypass valves without making the Turbine Stop Valve (TSV)

Closure function inoperable unless bypassing the TSV Closure function actually occurs due to decreasing the turbine first stage pressure below the bypass setpoint.

For the "Turbine Control Valve Fast Closure, Trip Oil Pressure Low" function, added UNIDs for additional information. In the second paragraph changed "transmitter" to "s~itch" because pressure switches are utilized, not transmitters.

Also in the second paragraph added "Therefore, to consider this function operable bypass of the function must not occur when bypass valves are open".

This change will allow testing of the bypass valves without making the Turbine Control Valve (TCV) Fast Closure Trip Oil Pressure Low function inoperable unless bypassing the function actually occurs due to decreasing the turbine first stage pressure below the bypass setpoint.

SECTION 3.3.4.2, ANTICIPATED TRANSIENT WITHOUT SCRAM RECIRCULATION PUMP TRIP (ATWS-RPT)

INSTRUMENTATION

BASES, BACKGROUND In the third paragraph, added "vessel" to "... either two Reactor Vessel Water Level..." for clarification.

In the fourth paragraph, replaced "both recirculation pump breakers" with "one of the two breakers for each recirculation pump" as clarification.

Added Instrument UNIDs, as additional information, to "a. Reactor Vessel Water Level Low".

Added Instrument

UNIDs, as additional information, to "b. Reactor Steam Dome Pressure High".

Page 8 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3 SECTION 3

3 5

1 ~

EMERGENCY CORE COOLING SYSTEM (ECCS)

INSTRUMENTATION ACTIONS Removed Functions 1.c and 2.c from REQUIRED ACTION B.1 and added them into REQUIRED ACTION C.1.

REQUIRED ACTION C.1 is more appropriate for these Functions for Core Spray and LPCI because they are permissives for which it is better to restore OPERABILITY than to place in trip which is non-conservative.

Also clarified REQUIRED ACTIONS and COMPLETION TIMES FOR B.1 and C.1 by adding "ECCS" modifier to "feature(s) inoperable",

changed "loss of feature" to "loss of function(s)",

changed "loss of subsystem" to "loss of function(s)",

and changed "both subsystems" to "both trip systems".

These changes were all made to provide more accurate descriptions.

For REQUIRED ACTION H.1 added "ECCS" to "feature(s) inoperable" to clarify features of concern are the ECCS features.

TABLE 3.3.5.1-1 For Function 1.c, added reference to note b which was revised to state "Channels affect Common Accident Signal Logic.

Refer to LCO 3.8.1,

'AC Sources Operating'",.

changed the Conditions Referenced from B to C, and clarified that 4 Required Channels are "2 per trip system".

The change to note b was to identify the actual logic that initiates the Diesel Generators and EECW to which the note previously referred.

The change from Conditions Referenced is to agree with the change made to the REQUIRED ACTIONS.

For Functions 2.a and 2.b, deleted note b reference and also note b on this page because is addressed under Functions l.a, 1.b, and 1.c, "Core Spray System" where the Common Accident Signal is generated.

For Function 2.c, changed the Conditions Referenced from B to C to agree with the change made to the REQUIRED ACTIONS.

For Function 2.e, added clarification that Required Channels are "1 per Subsystem".

For Function 2.f, Pumps C and D, added clarification that Required Channels are "1 per trip system" and modified note e with same information.

Page 9 of24

0 EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3. 3 For Function 3.f, changed SR 3.3.5.1.3 to SR 3.3.5.1.5 which effectively changes the calibration frequency from 92 days to 18 months.

This is acceptable based on the setpoint analysis.

Corrected the Required Channels per Function for Function 4.e to 4, Function 4.f to 8, Function 4.g to 2, Function S.e to 4, Function 5.f to 8, and Function 5.g to 8.

This was done because previously these had erroneously been listed on a per trip system basis.

BASES, BACKGROUND In the third paragraph, clarified that the Common Accident Signal is the logic generated by the ECCS instrumentation that initiates the Diesel Generators and EECW System.

For the "Core Spray System",

added clarification that Reactor Vessel Water Level and Drywell Pressure are "each" monitored by four transmitters.

Changed Subsystem to trip system.

Also clarified that the "low reactor water level" signal is sealed in.

For the "Automatic Depressurization System",

clarified that the Level 3 signal is. used as a confirmatory signal to the Level 2 signal.

Revised the description of the Core Spray and LPCI discharge pressure switches to correctly identify the appliable number.

Revised the description of the ADS logic for clarity.

For the "Diesel Generators" and "Emergency Equipment Cooling Water (EECW) System",

deleted these sections because they are not applicable to the ECCS section.

BASES ~

APPLICABLE SAFETY ANALYSESg LCD'ND APPLICABILITY In the third paragraph, deleted text on response time since BFN is not committed to do response time testing and clarified text on note b to refer to the Common Accident Signal Logic.

In the fourth paragraph, deleted references to Diesel Generators based on note b revision.

For "la, 2a Reactor Vessel Water Level Low Low Low, Level 1",

added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal and deleted associated text. pertaining to the EECW and Diesel Generator Initiation si,gnals.

l Page 10 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS,(ITS), SUPPLEMENT TO ITS SECTION 3.3 For "1.b, 2.b Drywell Pressure High", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal and deleted associated text pertaining to the EECW and Diesel Generator Initiation signals.

For "1.c, 2.c Reactor Dome Pressure Low (Injection Permissive and ECCS Initiation)", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal.

For "1.d Core Spray Pump Discharge Flow Low (Bypass)",

added instrument UNIDs as additional information.

For "1.e, 2.f Core Spray and Low Pressure Coolant Injection Pump Start, Time Delay Relay", clarified the number of relays per pump start logic.

For "2.d Reactor Steam Dome Pressure Low (Recirculation Discharge Valve Permissive)",

added instrument UNIDs as additional information.

For "2.e Reactor Vessel Water Level Level 0", added instrument UNIDs as additional information.

For "3.a Reactor Vessel Water Level Low Low, Level 2",

added instrument UNIDs as additional information.

For "3.b Drywell Pressure

,High", added instrument UNIDs as additional information.

For "3.c Reactor Vessel Water Level High, Level 8",

added instrument UNIDs as additional information.

For "3.d Condensate Header Level Low", added instrument UNIDs as additional information.

For "3.e Suppression Pool Water Level High", added instrument UNIDs as additional information.

For "3.f High Pressure Coolant Injection Pump Discharge Flow Low (Bypass)",

added instrument UNIDs as additional information and corrected "transmitter" to "switch" to agree with plant configuration.

For "4.a, S.a Reactor Vessel Water Level Low Low Low, Level 1", added instrument UNIDs as additional information.

Page llof24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS), SUPPLEMENT TO ITS SECTION 3.3 For "4.b, S.b Drywell Pressure High", added instrument UNIDs as additional information.

For "4.d, 5.d Reactor Vessel Water Level Low, Level 3",

added instrument UNIDs as additional information.

For "4.e, 4.f, 5.e, 5.f, Core Spray and Low Pressure Coolant Injection Pump Discharge Pressure High", added instrument UNIDs as additional information and replaced "transmitters" with "switches" to match plant configuration.

Also replaced "two for" with "one from" to clarify the signals from the Core Spray Pumps.

For "4.g, 5.g Automatic Depressurization System High Drywell Pressure Bypass Timer", clarified that there are. four bypass timers (two per trip system).

BASES g ACTIONS For "B.1, B.2, and B.3", deleted text pertaining to Functions 1.c and 2.c which were relocated to "C.1 and C.2".

Deleted statement about DG and EECW inoperability because the logic for Common Accident Signal, which initiates these, is located in another section.

Deleted "redundant" because it is not applicable to HPCI.

Corrected other text to improve readability.

For "C.l and C.2" added information pertaining to Functions 1.c and 2.c which were relocated from "B.1, B.2, and B.3".

For "D.l" deleted second and third sentences of second paragraph.

This change is based on Operations review comment and deletes unnecessary detail.

For "E.1 and E.2" revised the discussion of inoperability due to multiple inoperable channels for the Core Spray Pump Discharge Flow Low Bypass Function to clarify equipment affected (potentially all four CS Pumps).

Also identified the Function of concern as 1.d.

BASES SURVEILLANCE REQUIREMENTS Revised SR 3.'3.5.1.6 to delete LCO 3.8.2 as overlapping this Surveillance.

Page 12 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3.3 SECTION 3

3 5

2 g REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM INSTRUMENTATION APPLICABLE SAFETY ANALYSES~

LCOg AND APPLICABILITY Added Instrument UNIDs, as additional information, to "1. Reactor Vessel Water Level Low Low, Level 2".

Added Instrument UNIDs, as additional information, to "2. Reactor Vessel Water Level High, Level 8".

SECTION 3.3.6.1, PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION ACTIONS Revised "COMPLETION TIME" to add functions 6.b and 6.c (new functions in table) for "CONDITION A" to the functions that have 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after being declare inoperable to be placed in trip.

For "REQUIRED ACTION D.1" changed "Isolate associated main steam line (MSL)" to "Isolate the affected penetration flow path(s)".

This change is necessary because other penetration flow paths besides the Main Steam Lines are isolated by the functions which reference ACTION D from table 3.3.6.1-1.

Added REQUIRED ACTION G.1 and renumbered existing REQUIRED ACTION G.1 and G.2 to G.2.1 and G.2.2 respectively.

Also added note that specifies REQUIRED ACTION G.l, is only applicable for functions 2.a and 2.b which are inoperable as a result of inoperable actuation logic.

The added action allows isolating the affected penetration flow path(s) in 1

hour instead of being in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

This change accomplishes the required safety action (isolation of primary containment for affected penetrations) and allows more flexibilitythan shutting down if non-critical penetrations are inoperable.

Added a CONDITION I which has the REQUIRED ACTION of "I.1, Initiate action to restore channel to OPERABLE status" or "I.2, Initiate action to isolate the Residual Heat Removal (RHS)

Shutdown Cooling System".

Both actions COMPLETION TIME is Immediately.

This addition addresses the actions while in Shutdown Cooling and the Reactor Vessel Water Level Low Function is isolation capability is not maintained.

Page 13 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3. 3 TABLE 3.3.6.1-1 Added FUNCTIONS 3.f and 3.g and modified description of FUNCTION 3.e to identify the three separate areas (Exit, Midway, and Entry) for the HPCI Steam line Space Torus Area Temperature High.

Added FUNCTIONS 4.f and 4.g and modified description of FUNCTION 4.e to identify the three separate areas(Exit, Midway, and Entry) for the RCIC Steam line Space Torus Area Temperature High.

Added "-High" to FUNCTIONS 5.a, 5.b, 5.c, S.d, 5.e and 5.f to better describe that the parameter of concern is high temperature.

Added FUNCTIONS 6.b (with associated note b), Reactor Vessel Water Level Low, and 6.c, Drywell Pressure High, for Shutdown Cooling System Isolation.

This adds back requirements deleted from CTS in=original mark-up and responds to NRC comment 3.3.6.1-14.

BASES, BACKGROUND Revised "1. Main Steam Line Isolation" to provide more plant specific description and details.

Revised "2. Primary Containment Isolation" to provide more plant specific description and details.

Revised "3,4. High Pressure Coolant Injection Isolation and Reactor Core Isolation Cooling System Isolation" to provide moxe plant specific description and details.

Revised "5. Reactor Watex Cleanup System Isolation" to provide more plant specific description and details.

Revised "6. Shutdown Cooling System Isolation" to provide more plant specific description and details.

Each of the above sections was substantially revised based on input from Operations Review.

Page 14 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3.3 BASES~

APPLICABLE SAFETY ANALYSES~

LCO AND APPLICABILITY Deleted "Each channel must also respond within its assumed response

time, where appropriate".

This was deleted because BFN is not committed to do Response Time Testing and references to it have been removed from other locations in the ITS.

Added a paragraph break for fifth paragraph for clarity.

Added Instrument UNIDs, as additional information, to "1.a. Reactor Vessel Water Level Low Low Low, Level 1".

In "1.b. Main Steam Line Pressure Low", added Instrument UNIDs, as additional information. Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.

In "1.c. Main Steam Line Flow High", added Instrument

UNIDs, as additional information.

Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.

In "1.d. Main Steam Line Space Temperature High", added Instrument

UNIDs, as additional information.

Changed "Line Space" to "Tunnel" in several locations to better reflect BFN terminology.

Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.

In "2.a. Reactor Vessel Water Level Low, Level 3",

added Instrument UNIDs, as additional information.

Also clarified applicability by revising last paragraph tc "This Function is required for the isolation of the Group 2 (excluding RHR valves for SDC),

6, and 8 valves.

Portions of this instrumentation are also required for Functions 5.h and 6.b".

In "2.b. Drywell Pressure High", added Instrument

UNIDs, as additional information.

Also clarified applicability by revising last paragraph to "This Function is required for the isolation of the Group 2 (excluding RHR valves for SDC),

6, and 8 valves.

Portions of this instrumentation are also required for Function 6.c".

In "3.a.,

4.a.

HPCI and RCIC Steam Line Flow High", added Instrument

UNIDs, as additional information.

Page 15 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3. 3 In "3.b., 4.b.

HPCI and RCIC Steam Line Pressure Low",

added Instrument

UNIDs, as additional information.

Also deleted "Each Function is considered to have only one trip system since the output from the logic trips a

common relay that initiates the isolations" because this information was added to the BACKGROUND.

In "3.c., 4.c.

HPCI and RCIC Turbine Exhaust Diaphram Pressure High", added Instrument UNIDs, as additional information.

Also deleted "Each Function is considered to have only one trip system since the output from the logic trips a

common relay that initiates the isolations" because this information was added to the BACKGROUND.

In "3.d., 3.e.,

4.d.,

4.e.

Area Temperature High", added functions 3.f., 3.g., 4.f.,

and 4.g. to address the torus area having three distinct area trip functions for each system.

Added Instrument UNIDs, as additional information.

Also modified description of to clarify the number of channels and delete reference to Differential Temperature which is not utilized at BFN.

In "5.a., 5.b., 5.c.,

S.d., S.e.,5.f.

Area Temperature High", added Instrument UNIDs, as additional information.

Also indicated that areas as opposed to rooms are being monitored and deleted text on the logic which has been included in the BACKGROUND.

In "5.h Reactor Vessel Water Level Low, Level 3",

added Instrument

UNIDs, as additional information.

Added paragraph that states the Allowable Value for the Function is the same as RPS Level 3 scram Allowable Value.

Also revised applicability to state "This Function is required for the isolation of the Group 3 valves.

Portions of this instrumentation are also required for Functions 2.a and 6.b." which in effect deletes Groups 2,

6, and 8.

In "6.a. Reactor Steam Dome Pressure High", added Instrument

UNIDs, as additional information.

Also clarified that the valves to be isolated are the Shutdown Cooling Supply Isolation Valves.

Added 6.b.,

Reactor Vessel Water Level Low, Level 3 and 6.c.,

Drywell Pressure High BASES to address the new Functions added for the isolation of Shutdown Cooling valves.

Page 16 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3

BASES, ACTIONS New Functions 6.b and 6.c were added to "A.1 and A.2" and minor changes were made for clarification.

The first paragraph of "B.1" was substantially revised in response to Operations comments.

This revision clarifies the number of required channels per function required to maintain isolation capability.

"D.1, D.2.1, and D.2.2" was revised to change "MSL" to "penetration flow path(s) because lines (for example Main Steam Drain Lines) other than the Main Steam Lines could be affected which may not necessitate the isolation of a Main Steam Line.

For "G.l and G.2",

a new ACTION G.l was added and the existing ACTIONS were renumbered to G.2.1 and G.2.2.

Additional details were provided to address the actions of isolating the affected penetration flow path(s) for Functions 2.a and 2.b being inoperable due to inoperable actuation logic.

Added BASES for new ACTIONS I.1 and I.2 which address the added Functions for RHR Shutdown Cooling System Isolation.

SURVEILLANCE REQUIREMENTS Added "The LOGIC SYSTEM FUNCTIONAL TEST shall include a

calibration of time delay relays and timers necessary for proper functioning of the logic" to SR 3.3.6.1.6.

This change addresses CTS requirement for timer testing/calibration.

SECT ION 3 3

6 2 g SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION ACTIONS Added "secondary containment" in front of "isolation capability" for CONDITION B and REQUIRED ACTION B.l for clarification.

NRC comment 3.3.6.2-3 noted that "secondary containment" had been deleted from NUREG-1433.

Replace "zone(s)" with "secondary containment isolation valves" for REQUIRED ACTION C.l.l because zonal isolation is no longer required by ITS section 3.6.4.1, Secondary Containment, but the affected secondary containment Page 17 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS), SUPPLEMENT TO ITS SECTION 3.3 isolation valve must still maintain isolation capability or be isolated.

Revised REQUIRED ACTION C.2.1 to add "associated" in front of "standby gas treatment" and replaced "system" with "subsystem(s)".

This restores the original NUREG-1433 text.

Revised REQUIRED ACTION C.2.2 to add "associated" in front of "SGT" and replaced "system" with "subsystem(s)".

This restores the original NUREG-1433 text.

SURVEILLANCE REQUIREMENTS Added "secondary containment" in front of "isolation capability" for Note 2.

NRC comment 3.3.6.2-3 noted that "secondary containment" had been deleted from NUREG-1433.

Deleted SR 3.3.6.2.3 for performing a LOGIC SYSTEM FUNCTIONAL TEST every 184 days and renumbered the remaining SRs.

It was determined that the Functions (Reactor Zone Exhaust Radiation High and Refueling Floor Exhaust Radiation High) that had specified a 184-day LOGIC SYSTEM FUNCTIONAL TEST could have their LOGIC SYSTEM FUNCTIONAL TEST extended to 18 months and, therefore, the 184-day test was no longer required.

TABLE 3.3.6.2-1 Renumbered SRs due to the deletion of SR 3.3.6.2.3 and renumbering of the remaining SRs.

Deleted SR 3.3.6.2.1 (Channel Check) requirement for Function 2.

Drywell Pressure High.

The Channel Check requirement was not included in the CTS and thus deletion is acceptable.

Revised the number of required channels per trip system for "3. Reactor Zone Exhaust Radiation High" and "4. Refueling Floor Exhaust Radiation High" from 2 to 1.

This change is based on one channel of each function being required per trip system.

BASES, BACKGROUND Deleted "In addition, manual initiation of the logic is provided" from the second paragraph because BFN is not committed to have manual initiation capability.

Page 18 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3. 3 BASES I APPLICABLE SAFETY ANALYSESI LCO/

AND APPLICABILITY Deleted "Each channel must also respond within its assumed response

time, where appropriate" from the fourth paragraph because BFN is not committed to perform response t:ime testing.

For "1. Reactor Vessel Water Level Low, Level 3", added Instrument

UNIDs, as additional information.

Also added "These signals are the same that isolate the primary containment (additional information on the arrangement of these channels in the PCIS trip systems can be found in the BASES for LCO 3.3.6.1, "Primary Containment Isolation Instrumentation",

Function 2)" to provide a cross reference for other Funct'.ions performed by the same instrumentation.

Corrected title for second page to Level 3 (not Level 2).

For "2. Drywell Pressure High", added Instrument UNIDs, as additional information.

Also added "These signals are the same that isolate the primary containment (additional information on the arrangement of these channels in the PCIS trip systems can be found in the BASES for LCO 3.3.6.1, "Primary Containment Isolation Instrumentation",

Function 2)" to provide a cross reference for other Functions performed by the same instrumentation.

For "3.4. Reactor Zone and Refueling Floor Exhaust Radiation High", added Instrument UNIDs, as additional information.

The second paragraph was rewritten to bett:er describe the logic of operation.

BASES I ACTIONS Revised "B.1" to clarify minimum number of channels OPERABLE t:o assure penetration flow path isolation on a valid signal.

Added paragraph to "C.1.1, C.1.2, C.2.1, and C.2.2" to explain that REQUIRED ACTIONS C.2.1 and C.2.2 can be performed independently on each SGT subsystem.

Page 19 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)

SUPPLEMENT TO ITS SECTION 3.3 SURVEILLANCE REQUIREMENTS Corrected Functions to which Note 3 is applicable from Functions 2.c and 2.d to Functions 3 and 4 to which the Note actually refers.

Functions 2.c and 2.d do not exist.

Added "This Surveillance for Functions 3 and 4 shall consist of verifying the High Voltage Power Supply (HVPS) voltage at the Sensor and Convertors (detectors) is within its design limits.

A CHANNEL FUNCTIONAL TEST as defined in Section 1.1, "Definitions" shall be performed once per 18 months as part of the CHANNEL CALIBRATION for Functions 3 and 4" to SR 3.3.6.2.2.

This note incorporates CTS Table 4.2.A, Note 32.

For the LOGIC SYSTEM FUNCTIONAL TEST SRs, combined SR 3.3.6.2.3 and SR 3.3.6.2.5 and renumbered to SR 3.3.6.2.4.

This change was necessary because the 184 day Frequency for Functions 3 and 4 were changed to 18 months and thus only one SR for LOGIC SYSTEM FUNCTIONAL TEST is required.

Renumbered SR 3.3.6.2.4 to SR 3.3.6.2.3 and relocated to proper sequential location.

INSTRUMENTATION ACTIONS Deleted "in both trip systems" from the COMPLETION TIME for CONDITION B.

This is because each trip system initiates its own CREV subsystem.

TABLE 3.3.7.1-1 Corrected the required number of channels per trip system for Functions 3,

4, and 5 from 2 to 1 to match system logic.

Added "above background" for the Function 5, Control Room Air Supply Duct Radiation High, Allowable Value.

This is consistent with CTS value.

BASE S g BACKGROUND Significantly revised the third paragraph to provide additional description of the CREV System instrumentation.

This included a cross reference to the PCIS Function that utilize the same initiation instrumentation.

Page 20 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS),. SUPPLEMENT TO ITS SECTION 3.3

BASES, APPLICABLE SAFETY ANALYSES, LCO, AND APPLICABILITY In "1. Reactor Vessel Water Level Low, Level 3",

added Instrument UNIDs as additional information.

Added sentence that states the Allowable Value for the Function is the same as RPS Level 3 scram Allowable Value.

Also deleted reference to PCIS logic which was included in Background.

In "2. Drywell Pressure High", added Instrument

UNIDs, as additional information.

In "3., 4. Reactor Zone and Refueling Floor Exhaust Radiation High", added Instrument UNIDs as additional information.

Deleted statement on isolation of primary containment:

which is not applicable to CREVs initiation.

Made several replacements and or additions to better describe the init;iation logic.

In "5. Control Room Air Supply Duct Radiation High" added Instrument UNIDs, as additional information.

Also deleted "There is only one trip system for this Function" which was not included in the NUREG-1433 original mark-up.

BASES, ACTIONS For ACTIONS B.1 and B.2, revised first paragraph to better describe requirements to maintain CREV System initiation capability.

For ACTIONS C.1 and C.2, revised first paragraph to better describe requirements to maintain CREV System initiation capability.

For ACTIONS D.l, D.2, and D.3, corrected RE-90-8 to RM-90-8 since the discussion is for the radiation monitor, not the radiation element.

ACTIONS E.1 and E.2 were revised t:o provide additional information in the first paragraph detailing that only one CREV subsystem must be operating to meet action E.l if the other subsystem will st:art automatically upon loss of the operating unit, and to state that t:he required actions can be taken independently on each subsystem.

Page 21 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3

BASES, SURVEILLANCE REQUIREMENTS Added "This Surveillance for Functions 3 and 4 shall consist of verifying the High Voltage Power Supply (HVPS) voltage at the Sensor and Convertors (detectors) is within its design limits.

A CHANNEL FUNCTIONAL TEST as defined in Section 1.1, "Definitions" shall be performed once per 18 months as part of the CHANNEL CALIBRATION for Functions 3 and 4" to SR 3.3.7.1.2.

This note incorporates CTS Table 4.2.A Note 32.

SECTION 3.3.8.2, LOSS OF POWER (LOP)

INSTRUMENTATION ACTIONS Added a new REQUIRED ACTION A.1 to "Verify by administrative means that the other two phase-to-phase degraded voltage relays and the loss of voltage relay channel on that shutdown board are OPERABLE" and renumbered the existing REQUIRED ACTION A.1 to A.2.

The COMPLETION TIME for the new REQUIRED ACTION is Immediately.

This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.

Added a new REQUIRED ACTION B.1 to "Verify by administrative means that the degraded voltage relay channel on that shutdown board is OPERABLE" and renumbered the existing REQUIRED ACTION B.l to B.2.

The COMPLETION TIME for the new REQUIRED ACTION is Immediately.

This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.

Added a new REQUIRED ACTION C.1 to "Verify by administrative means that the loss of voltage relay channel on that shutdown board is OPERABLE" and renumbered the existing REQUIRED ACTION C.1 to C.2.

The COMPLETION TIME for the new REQUIRED ACTION, is Immediately.

This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.

Page 22 of24

e

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS

{TS) -362 IMPROVED STANDARD TS

{ITS) SUPPLEMENT TO ITS SECTION 3. 3 SURVEILLANCE REQUIREMENTS Deleted Note 2 to the SURVEILLANCE REQUIREMENTS which would have allowed a

2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months delay for entry into associated Conditions and Required Actions when a channel was made inoperable solely to perform required Surveillances.

NRC comment 3.3.8.1-2 indicated that use of the Note was a less restrictive change than CTS.

After discussion with the system engineer regarding the usefulness of the Note in the performance of associated Surveillance instructions it was determined that the Note was of little benefit and should be deleted.

BASES, BACKGROUND Added a sentence to the last paragraph stating "The channel devices for each shutdown board are listed in Table B

3.3.8.1-1".

The new table added to the end of the BASES lists UNIDs by board for the instrumentation of concern.

BASES, ACTIONS Incorporated the addition of new REQUIRED ACTION A.1 and renumbering of existing REQUIRED ACTION A.1 to A.2 into the BASES.

This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine if it is out-of-service for maintenance or other

reasons, and does not necessitate the perfcrmance of Surveillances which demonstrate its OPERABILITY.

Incorporated the addition of new REQUIRED ACTION B.1 and renumbering of existing REQUIRED ACTION B.l to B.2 into the BASES.

This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine if it is out of service for maintenance or other

reasons, and does not necessitate the performance of Surveillances which demonstrate its OPERABILITY.

Incorporated the addition of new REQUIRED ACTION C.l and renumbering of existing REQUIRED ACTION C.1 to C.2 into the BASES.

This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine if it is out of service for maintenance or other

reasons, and does not necessitate the performance of Surveillances which demonstrate its OPERABILITY.

Page 23 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -3S2 IMPROVED STANDARD TS (ITS)- SUPPLEMENT TO ITS SECTION 3.3

BASES, SURVEILLANCE REQUIREMENTS Deleted description and BASES of Note 2 which was deleted from the Surveillance Requirements.

SECTION 3

3 8

2 ~

REACTOR PROTECT ION SYSTEM (RPS )

ELECTRIC POWER MONITORING SURVEILLANCE REQUIREMENTS Deleted Note to SR 3.3.8.2.1 which stated "Only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for R 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ".

This was deleted because the CHANNEL FUNCTIONAL TEST (SR 3.3.8.2.1) and the CHANNEL CALIBRATION (SR 3.3.8.2.2) are both performed at the same 184-day frequency (and thus performed together)

and, hence, the note was not applicable to the CHANNEL CALIBRATION.

Based on the above, the note has no effect on when the CHANNEL FUNCTIONAL TEST is performed and should be deleted.

This is in response to NRC comment 3.3.8.2-3.

U'ASES

~

SURVE ILLANCE REQUIREMENTS Deleted reference to Note to SR 3.3.8.2.1 which was deleted, and added "The 184-day Frequency is based on operating experience and the need to calibrate the instrument loop and sensor".

REFERENCES Deleted Reference 2,

"NRC Generic Letter 91-09,

'Modification of Surveillance Interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System."

This reference was deleted because the suggested relaxation of the Frequency of the CHANNEL FUNCTIONAL TEST is negated by the requirement to perform the CHANNEL CALIBRATION at the same Frequency based on Setpoint Analysis.

Page 24 of24

0

v t e Letter Sequence Supplement
TAC:M96431, Administrative Controls Program Exceptions, Revise Reporting Requirements to Be Consistent with 10 CFR 20 (Approved, Closed) TAC:M96432, Administrative Controls Program Exceptions, Revise Reporting Requirements to Be Consistent with 10 CFR 20 (Approved, Closed) TAC:M96433, Administrative Controls Program Exceptions, Revise Reporting Requirements to Be Consistent with 10 CFR 20 (Approved, Closed)
Initiation Acceptance... Supplement, Supplement, Supplement, Supplement Administration Meeting, Meeting Questions 26 February 1998 Answers Results Approval Other: ML18038B898, ML18039A196, ML18039A205, ML18039A208, ML18039A262, ML18039A265, ML20149E737, ML20198F430, ML20198Q445, ML20199E118, ML20203B078, ML20211J898
MONTHYEAR1997-07-14 [Table View]

ML18039A226

Text

Response

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

Navigation menu

Search