ML18039A803

Responds to NRC Staff Verbal Request Re TS Change TS-376, Originally Submitted on 970312, & Proposed Changes to TS to Extend Current 7-day AOT for EDGs to 14 Days

ML18039A803
Person / Time
Site:	Browns Ferry
Issue date:	06/18/1999
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M98205, TAC-M98206, NUDOCS 9906290312
Download: ML18039A803 (10)

Text

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REGULAT Y INFORMATION DISTRIBUTIOb

'YSTEM (RIDS)

ACCESSION NBR:9906290312 DOC.DATE: 99/06/18 NOTARIZED: NO FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION ABNEY,T.E.

Tennessee Valley Authority

'ECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Responds to NRC staff verbal request re TS change TS-376, originally submitted on 970312,

& proposed changes to TS to extend current 7-day AOT for EDGs to 14 days.

DI'STRIBUTION CODE:

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TITLE: TVA Facilities - Routine Correspondence NOTES:

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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 ORGANIZATIONS CONTACT THE DOCUMENT CONTROL DESK (DCD)

ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

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Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 June 18, 1999 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

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

UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CHANGE NO. 376 EXTENDED EMERGENCY DIESEL GENERATOR ALLOWED OUTAGE TIME AMENDED SUBMITTAL ADDITION OF CONFIGURATION RISK MANAGEMENT PROGRAM (TAC NOS.

M98205 AND M98206)

This is the response to a NRC staff verbal request regarding Technical Specifications (TS) change TS-376.

TS-376 was originally submitted on March 12,

1997, and proposed changes to the Units 2 and 3

TS to extend the current 7-day Allowed Outage Time (AOT) for the Emergency Diesel Generators (EDGs) to 14 days.

Item 4 of NRC's November 17,

1998, Request for Additional Information (RAI) on TS-376 asked that TVA consider adoption of a Configuration Risk Management Program (CRMP) as outlined in Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications, August 1998."

RG 1. 177 recommends that a

CRMP be developed and implemented for systems for which a Probabilistic Safety Assessment based AOT extension has been granted to identify possible risk significant configurations that could be encountered over extended periods of time.

In our April 23,

1999, response to Item 4 of the RAI, TVA indicated the use of the extended EDG AOT was expected to be a

rare occurrence,'and would be needed only for the remote possibility of major unexpected EDG corrective maintenance 9'9062'tl03i2 9'ctl06i8

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U.S. Nuclear Regulatory Commission Page 2

June 18, 1999 activities or as a contingency provision for major preventive maintenance activities should large scale unanticipated repair work be encountered.

Additionally, since the CRMP would only apply to the EDG system when using the AOT extension, and considering the low risk factors associated with an extended EDG AOT as evidenced by the small increase in Core Damage Frequency and Large Early Release Fraction provided in the April 23 submittal, TVA concluded that the existing plant risk management programs are adequate to protect plant safety during EDG outages.

Also, since addition of a CRMP may be required in conjunction with the pending change to Section a(3) of 10 CFR 50.65 (Maintenance Rule),

which would have a much broader applicability, Browns Ferry considered it more appropriate to postpone development of a CRMP pending implementation of the revised Maintenance Rule.

NRC guidance on risk management for maintenance activities is also still in draft format (Draft Regulatory Guide DG-1082).

Therefore, postponement would allow a more orderly development of a CRMP consistent with NRC standards and nuclear industry application.

However, the Staff has verbally indicated that early implementation of a CRMP is a prerequisite to NRC approval of TS-376.

Therefore, to facilitate the review of TS-376, we are amending the change request to include implementation of the CRMP delineated in Enclosure 1.

The CRMP will be incorporated into the BFN Unit 2 and 3 Technical Requirements Manuals (TRM) following approval of TS-376.

The CRMP presented in the Enclosure is the same as that recommended in RG 1.77 and is identical to the CRMP recently approved by NRC for TVA's Sequoyah Nuclear Plant

(

Reference:

December 16,

1998, NRC letter to TVA, Sequoyah Nuclear Plant).

Conversations with NRC Staff indicate that locating the CRMP in the Administrative Controls section of the TRM is acceptable.

The TRM is referenced in the BFN Final Safety Analysis Report and is subject to the 10 CFR 50.59 change control process.

Implementation of a CRMP does not alter the previous determination that there are no significant hazards considerations associated with the proposed changes for TS-376 and the determination that the changes qualify for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

U. S. Nuclear Regulatory Commission Page 3

June 18, 1999 The commitment in this letter is listed in Enclosure

2. If you have any questions, please contact me at (256) 729-2636.

S'ere

'I T. E. Abney Manager of 'ns ng and Indu try Af airs Enclosures cc:

(Enclosu Mr. Paul Frederickson, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street, S.W.

Suite 23T85

Atlanta, Georgia 30303 Mr. William O. Long, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road

Athens, Alabama 35611

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ENCLOSURE 1

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 2 AND 3 TECHNICAL SPECIFICATIONS (TS)

CHANGE 376 EXTENDED ALLOWED OUTAGE TIME (AOT)

EMERGENCY DIESEL GENERATORS (EDGs)

DESCRIPTION OF CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP)

Attached is the CRMP description that will be placed in the Administrative Controls section of the Units 2 and 3 Technical Requirements Manuals following NRC approval of TS-376.

The CRMP provisions will be applied when the EDGs are in the extended portion of the EDG AOT.

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Configuration Risk Management Program TR 5.0 ADMINISTRATIVECONTROLS TR 5.4 CONFIGURATION RISK MANAGEMENTPROGRAM 5.4.1 Configuration Risk Management Program The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk-informed allowed outage time has been granted.

The program shall include the following.

a. Provisions for the control and implementation of a Level 1 at-power internal events PRA-informed methodology. The assessment is to be capable of evaluating the applicable plant configuration.

b. Provisions for performing an assessment prior to entering the plant configuration described by the Limiting Conditions for Operation (LCO) Action Statement for preplanned activities.

c. Provisions for performing an assessment after entering the plant configuration described by the LCO Action Statement for unplanned entry into the LCO Action Statement.

d. Provisions for assessing the need for additional actions after the discovery of additional equipment-out-of-service conditions while in the plant configuration described by the LCO Action Statement.

e. Provisions for considering other applicable risk-significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 2 AND 3 TECHNICAL SPECIFICATIONS (TS)

CHANGE 376 EXTENDED ALLOWED OUTAGE TIME (AOT)

EMERGENCY DIESEL GENERATORS (EDGs)

DESCRIPTION OF CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP)

COMMITMENT LIST

1. TVA will incorporate a

CRMP into the Technical Requirements Manuals for Units 2 and 3 as shown in the Enclosure to this letter.

(This commitment is contingent on NRC approval of TS change TS-376 and will be incorporated during the implementation phase of TS-376).

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