ML18039A446

Provides Revised Description & Evaluation of Proposed Change & No Significant Hazards Determination.Encl 2 Contains mark- Up of Affected Units 2 & 3 TS Pages

ML18039A446
Person / Time
Site:	Browns Ferry
Issue date:	07/17/1998
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A447	List: ML18039A446 ML18039A448
References
NUDOCS 9807290342
Download: ML18039A446 (11)

Text

CATEGORY 1 REGULAT . INFORMATION DXSTRIBUTIO YSTEM (RIDS)

ACCESSION NBR:9807290342 DOC.DATE: 98/07/17 NOTARIZED: YES DOCKET FACIL:50-2'60 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-2/6 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIAT10N ABNEY,T.E. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Provides revised description & evaluation of proposed change no significant hazards determination. Encl 2 contains mark-up of affected Units 2 E 3 TS pages.

DISTRIBUTION CODE: D030D COPIES RECEIVED:LTR J ENCL l SIZE:

TITLE: TVA Facilities - Routine Correspondence E

NOTES:

RECIPIENT COPIES RECXPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 1 1 PD2-3-PD 1 1 DEAGAZIO,A 1 1 INTERNAL: ACRS 1 1 1 1 OGC/HDS3 1 0 RES/DE/SSEB/SES 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

U E

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO'HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 9 ENCL 8

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Tennessee Valley Authority, Post Olfice Box 2000, Decatur, Alabama 35609 July 17, 1998 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-260 Tennessee Valley Authority ) 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 2 AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE-384 REQUEST FOR LICENSE AMENDMENT FOR POWER UPRATE SUPPLEMENT 2 r REVIS ION 1 Supplement 2 to TS-384 was submitted on June 26, 1998, .and incorporated Limiting Condition for Operation (LCO) 3.4.10 (Reactor Steam Dome Pressure), an associated Surveillance Requirement 3.4.10.1, and corresponding Bases changes into the y/

proposed power uprate TS-384 package. LCO 3.4.10 had been added to the base Improved Technical Specifications (ITS) conversion package by Supplement 5 to TS-362, dated November 14, 1997. Since this was later than the original submittal of TS-384 (October 1, 1997), it was necessary to also add the subject LCO to TS-384 to maintain consistency with ITS. Note that TS-362, ITS, was recently approved by NRC on July 14, 1998.

In response to NRC staff comments, we have revised Enclosure 1 of Supplement 2 to better describe and justify the proposed TS Section 3.4.10 changes as applied to power uprate. Also, a specific no significant hazards determination has been added.

Enclosure 1 to this letter provides the revised description and evaluation of the proposed change, and the no significant hazards determination. Enclosure 2 contains a mark-up of the affected Unit 2 and Unit 3 TS pages. These mark-ups are the same as those provided in the June 26, 1998, submittal and are included for completeness. Revised (word processed) pages

'F8072'Il0342 980717 PDR .,ADOCK 050002b0 P " PDR

U.S. Nuclear Regulatory Commission

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Page' July 17, 1998 will be provided prior to NRC issuance of the power uprate license amendment.

TVA has determined that there are no significant hazards considerations associated with the proposed changes and that the changes do not alter the originally submitted Environmental Assessment. The BFN Plant Operations Review Committee and the BFN Nuclear Safety Review Board have previously reviewed this proposed change and determined that operation of BFN Units 2 and 3 in accordance with the proposed change will not endanger the health and safety of the public.

Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health.

There are no commitments contained in this letter. If you have any questions, please contact me at (265) 729-2636.

Sincerely, T. E. Abn Manager of Lice sin and Industry ffa rs Subscribed and sworn efore me this I 94/ day of 1998.

No ary Public My Commission Expires ~ CceeHe8ee Exphes CNoseo cc: See page 3

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U.S. Nuclear Regulatory Commission

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'Page 3 July 17, 1998 Enclosures cc (Enclosures):

Chris Christensen, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street, S.W.

Suite 23T85 Atlanta, Georgia 30303 Albert W De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Limestone County Commission 310 West Washington Street Athens, Alabama 35611 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 L. Raghavan, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY, NUCLEAR PLANT (BFN)

UNITS 2 AND 3 PROPOSED TECHNICAL SPECIFICATIONS (TS) CHANGE TS-384 SUPPLEMENT 2, REVISION 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. DESCRIPTION OF THE PROPOSED CHANGES:

The proposed change adds Limiting Condition for Operation (LCO) 3.4.10, and accompanying TS and Bases provisions from the Improved TS (TS-362) conversion package as adapted for power uprate conditions. Specifically, in LCO 3.4.10, the operating limit for reactor steam dome pressure is increased from < 1020 psig to < 1050 psig. In the Bases, the initial pressure assumed in the analysis of the reactor overpressure event is changed to reference the 1055 psig value used in the corresponding analysis for power uprate.

Also, in the Bases, the values for the nominal operating pressure at which design basis accident and other transient analyses are performed for power uprate are modified to reflect 1035,psig and 1040 psig which correspond to the values used in the uprate analyses respectively.

II. REASON FOR THE CHANGES:

As discussed in the original TS-384 submittal dated October 1, 1997, nominal reactor operating pressure for uprated conditions increases 30 psi from 1005 psig to 1035 psig. Subsequent to the original submittal of TS-384, a change to the Improved Technical Specifications (ITS) conversion package (TS-362, Supplement 5, dated November 14, 1997) added a new TS Section, 3.4.10, Reactor Steam Dome Pressure, which provides requirements for maintaining reactor pressure below a prescribed value. To maintain consistency with the ITS, it is necessary to also adopt the same ITS Section 3.4.10 modified to reflect the appropriate operating conditions and analytic basis for power uprate conditions.

Accordingly, LCO 3.4.10, the accompanying Surveillance Requirement (SR), and TS Bases have been added as proposed in this supplement for power uprate conditions.

III EVALUATION OF

. THE CHANGES:

Proposed LCO 3.4.10 and SR 3.4.10.1 provide restrictions on maximum allowed reactor steam dome pressure which are increased from a pre-uprate limit of 1020 psig to 1050 psig for power uprated conditions. The 30 psi increase in the maximum reactor steam dome pressure operating limit is, consistent with the increase in nominal reactor operating pressure from 1005 psig at pre-uprated conditions to 1035 psig at uprated conditions, as evaluated in NEDC-32751P (See Reference, Enclosure 5). This increase in LCO steam dome pressure from 1020 psig to 1050 psig maintains the same operating margin (15 psi) between the nominal operating pressure and the LCO pressure value.

The reactor steam dome pressure is an initial condition for the vessel overpressure analysis for which the main steam isolation closure transient-flux scram is the limiting transient. For power uprate, a value of 1055 psig was utilized as the initial condition in the overpressure protection analysis as presented in Section 3.2 of NEDC-32751P and the ITS Bases have been revised to reflect this value. This initi'al condition input assumption is 20 psi above the revised power uprate nominal reactor operating dome pressure of 1035 psig and 5 psig above the LCO/SR limit on reactor pressure established in LCO 3.4.10. Hence, there is adequate margin established between the transient analysis input assumption on reactor pressure for the overpressurization analysis and actual reactor pressure.

The current analysis input value for the non-uprate overpressurization analysis is slightly higher (1071 psig) which is equivalent to the existing high pressure scram setpoint analytical limit. Use of this lower input value (1055 psig) is still conservative since with the implementation o'f ITS, an LCO and an accompanying SR are in effect which limit the allowed reactor pressure. Prior to implementation of ITS, there were no TS limits on allowed reactor operating pressure, hence, use of a more conservative value (1071 psig) for the analysis was appropriate. This approach is also consistent with standard TS, NUREG-1433. As noted above, the results of the main steam isolation closure transient-flux scram have been previously provided in Section 3.2 of NEDC-32751P which shows that the peak vessel pressure remains below the ASME 1375 psig limit.

The TS 3.4.10 Bases have also been revised to reference the analytic assumptions for power uprate used for the other transient and accident analyses as presented in NEDC-32751P.

These analyses are not sensitive to reactor pressure and are performed assuming reactor pressures in the nominal expected operating ranges.

El-2

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION, TVA has concluded that operation of BFN Units 2 and 3 in accordance with the proposed change to the TS does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a)(1), of the three standards set forth in 10 CFR 50. 92 (c) .

The ro osed amendment does not involve a si nificant increase in the robabilit or conse uences of an accident reviousl evaluated.

The probability of Design Basis Accidents occurring is not affected by the establishment of an increased reactor pressure limit which corresponds to the increased power level since because the change in pressure is not an initiator of such an event. As stated in the technical justification, the results of the limiting overpressurization analysis shows that the peak vessel pressure remains below the ASME 1375 psig vessel pressure limit. Therefore, the proposed changes do not increase consequences of an accident previously evaluated.

The ro osed amendment does not create the ossibilit of a new or different kind of accident from an accident reviousl evaluated.

Equipment that could be affected by the reactor pressure change associated with power uprate has been evaluated as described in NEDC-32751P. No new operating modes, safety-related equipment line-ups, new or different accident scenario, or equipment failure modes were identified.

Based on these considerations, the change does not create the possibility of a new or different kind of accident from any previously evaluated.

The ro osed amendment does not involve a si nificant reduction in a mar in of safet As presented in NEDC-32751P, applicable accident and transient analyses have been performed for power uprate conditions which show that margins of safety are not significantly reduced. The limiting vessel pressurization transient, main steam isolation closure transient flux scram, has been performed for power uprate conditions and shows that the peak vessel pressure remains below the ASME 1375 psig vessel pressure limit. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

El-3

REFERENCES letter to

'VA NRC dated October 1, 1997, "Browns Ferry Nuclear Plant (BFN) Units 2 and 3 Technical Specification (TS) Change TS-384 Request for License Amendment for Power Uprate Operation."

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