ML20041A988
| ML20041A988 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/17/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8202230127 | |
| Download: ML20041A988 (7) | |
Text
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TENNESSEE VALLEY AOTHORITY co CH ATTANOOG A, TENNESSEE 37401 M
g 400 Chestnut Street Tower II Clyg February 17, 1982 2
fgg08Jg A Mr. Harold R. Denton, Director g3 k%p' y
Office of Nuclear Reactor Regulation 7
U.S. Nuclear Regulatory Commission to -
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Washington, DC 20555 pj D
Dear Mr. Denton:
In the Matter of the
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 Numerous requests for amendments.to Operating License Nos. DPR-33, -52, and
-68 to change the technical specifications of Browns Ferry Nuclear Plant units 1, 2, and 3 have been submitted and are presently under review by your staff. The enclosure lists the requested license amendments still pending on the Browns Ferry dockets arranged according to need.
Included for each is additional information regarding the impact on TVA and operaticn of Browns Ferry of not having the requested technical specifications approved. In general, we have found that a lengthy delay in approval of requested technical specification revisions creates problems for plant operation and complicates handling and issuance of approved technical specifications and new requests for technical specification revisions.
We hope that the enclosed will be useful to your staff in assessing the relative priority of each request and in assigning appropriate review effort to each. If we can be of any assistance, please get in touch with us through the Browns Ferry Project Manager.
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Regulation and 9afety Subscribe fore
.me this/g nd sworn to
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day of 1982.
' Notary Public My Commission Expires
- h-Enclosure oc:
U.S. Nuclear Regulatory Commission (Enclosure) 4 dp (*
0 Region II ATTN: James P. O'Reilly, Regional Administrator b
101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 8202230127 820217 PDR ADOCK 05000259 An Equal Opportunity Employer P
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ENCLOSURE PRIORITY / ADDITIONAL INFORMATION PENDING REQUESTED LICENSE AMENDMENTS BROWNS FERRY NUCLEAR PLANT (DOCKET NOS. 50-259, -260, -296)
All requested license amendments which are presently outstanding on the Browns Ferry dockets are listed herein to be in one of two categories.
The first category, entitled " Technical Specifications Significantly Impacting Plant Operations," lists those requested license amendments which are c'ther needed for continued operation or which would significanty improve plant availability. Additional discussion of how each requested amendment impacts or could impact plant operation is provided. The various requests are listed in order of decreasing priority, with the one of highest priority listed first. Approval of all requested amendments in this category is needed as soon as possible.
The second category, entitled " Technical Specifications Impacting TVA Operations and Future Requests," lists those requested license amendments which are needed to clear up the backlog of outstanding technical
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specifications and alleviate the problems this creates in handling and issuing future technical specification changes. As in the first category, additional discussion of each requested amendment is provided.
These requested amendments have not been prioritized since they are all needed with approximately the same urgency. Approval of these amendments is needed as soon as feasible since their issuance will remove numerous minor ambiguities and discrepancies.
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Technical Specifications Significantly Impacting Plant Operations 1.
TVA BFNP TS 170 - TVA letter from L. M. Mills to H. R. Denton dated December 9, 1981. These proposed changes are needed to accommodate unit 3 reload 4 and cycle 5 operation.
IMPACT ON PLANT OPERATION The requested technical specifications are needed to allow unit 3 to restart after the current refuel outage.
2.
TVA BFNP TS 171 - TVA letter from L. M. Mills to H. R. Denton dated December 11, 1981. These proposed changes reflect modifications being made to the unit 3 electrical distribution system.
IMPACT ON PLANT OPERATION Approval of these requested technical specifications is needed to allow unit 3 to restart with the modified electrical system.
3.
TVA BFNP TS 167 - TVA letter from L. M. Mills to H. R. Denton dated September 21, 1981. These proposed changes remove FRP/CMFLPD equations from the Limiting Safety System Settings section of the technical specifications and insert them into the Limiting Conditions for Operation section.
IMPACT ON PLANT OPERATION Adherence to the total peaking factor (R factor) limits as a limiting safety system setting requires that the control rod pattern during a plant startup power ascension be reestablished in several steps. This requires a power reduction between steps to accomplish the next step. This typically doubles or triples the time to reach full power depending upon how long the reactor has remained in the shutdown condition before startup. The nominal cost of such extra maneuvering of power level is about 10 full-power hours for each startup. The cost of one full-power hour depends upon power demand conditions but is
$20,000 as a minimum. In addition, the proposed changes will make units 2 and 3 consistent with unit 1.
We are currently in the process of responding to D. B. Vassallo's letter to H. G. Parris dated February 9,1982 and will submit the requested information separately.
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4.
TVA BFNP TS 146 - TVA letter L. M. Mills to H. R. Denton dated August 19, 1980.. These proposed specifications request =
changes in the areas of integrated and local leak rate testing. One part of the request involves reduction of the duration of the Containment Integrated I.eak Rate Test from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
NOTE:. Tables 3.7.D, 3 7.E, 3 7.F, and 3 7.0 for all three units from TS 146 should not be approved. Because of the time-elapsed since submittal, these tables are no longer correct. The correct tables for unit 3 are in TS 170. Correct tables for unit 1 and 2 will be provided in future submittals.-
IMPACT ON PLANT OPERATION Containment-integrated leak-rate test is usually a critical path activity; therefore, reducing the duration by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> eliminates'an eventual 16-hour delay in startup and power ascension. The cost for 16 full-power hours is a minimum of
$320,000 (depending upon system load demand.)
5.
TVA BFNP TS 133 - TVA letter L. M. Mills to H. R. Denton i
dated December 5, 1979.' These proposed specifications clarify requirements regarding isolation of main steam lines, and a change to the table of primary containment isolation valves.
IMPACT'ON PLANT OPERATION TS 133 would clarify the technical specification-requirements regarding isolation of main steam lines following main steam
'line high temperature logic actuation. The variation in inter-pretation led to a reportable occurrence on Browns Ferry.
(See Reportable Occurrence Report BFRO-50-259/7925 submitted by
- - *-letter from J. R. Calhoun (TVA) to James P. O'Reilly (NRC/ Region II) dated October 9, 1979.) This technical specification revision is a corrective action committed to in that RO.
These revisions will eliminate the variation in interpretation and help to decrease the number of reportable occurrence reports-filed.
NOTE: The proposed revision to Table 3 7.A for unit 3 should Jnot be approved. Table 3 7. A in TS 170 (Browns Ferry ' unit 3 reload 4) is correct and should be approved instead of Table 3 7.A change in TS 133.-
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TVA BFNP TS 144 - TVA letter L. M. Mills to H. R. Denton dated August 12, 1980. These' proposed changes delete require-ments for steam line space high temperature isolations of High Pressure Coolant Injection, Reactor Core Isolation Cooling, and Main Steam Isolation systems, while retaining alarm functions.
WITHDRAWAL OF TS 144 TVA requests that TS 144 be withdrawn from NRC staff review with.
one exception. In proposed changes for unit 3, Table 3 2.B, page 69, it is proposed to change the Minimum No. Operable Per Trip System from "2" to "1" for the Function:
" Instrument Channel - Suppression Chamber High Level." We continue to need that change for the reasons given below. Justification for that change was provided in the original submittal.
IMPACT ON PLANT OPERATION The change to Table 3.2.B from TS 144 discussed above is needed to make the unit 3 technical specifications consistent with units 1 and 2.
Consistency of license requirements among all three units is essential.
7.
TVA BFNP TS 90 - TVA letter J. E. Gilleland to E. G. Case dated August 3, 1977. The specifications propose to remove the trip functions of " Main Steam Line Isolation Valve Closure" and
" Turbine Condenser Low Vacuum" from the Refuel and Startup/ Hot Standby modes.
WITHDRAWAL OF TS 90 TVA requests that TS 90 be withdrawn from NRC staff review.
8.
TVA BFNP TS_74 - TVA letter J. E. Gilleland to B. C. Rusche dated December 6, 1976. The proposed specifications change the required number of RHRSW pumps assigned to RHRSW and EECW service.
WITHDRAWAL OF TS 74 TVA requests that TS 74 be withdrawn from NRC staff review.
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II.
Technical Specifications Impacting TVA Operations and Future Requests The following requested amendments are needed to resolve minor inconsistencies and remove ambiguities now occurring in the technical specifications. They are not prioritized because they are all needed with the same level of urgency. Approval is needed as soon as reasonable. Submittals made in response to NRC requests are indicated by an asterisk (#) in the left-hand margin.
1.
TVA BFNP TS 89 - TVA letters J. E. Gilleland to E. G. Case, July 29, 1977; J. E. Gilleland to T. A. Ippolito, April 24, 1979; L. M. Mills to H. R. Denton, July 20, 1979.
Subject:
Browns Ferry Unit 3 Inservice Inspection Program TVA BFNP TS 169 - TVA letter from L. M. Mills to H. R. Denton dated November 17, 1981.
Subject:
Browns Ferry Units 1 and 2 Inservice Inspection Program Approval of these specifications, along with the submitted pro-gram, is needed to clear the record regarding what inservice inspections are required. Formal approval of the program and specifications is needed to give clear and unambiguous guidance to TVA. Performing these ongoing inspections without formal approval creates a condition of uncertainty and confusion.
2.
TVA BFNP TS 124-Various TVA submittals, NRC request for submittal of license amendment regarding 10 CFR 50 Appendix I (Radiological Effluents).
n.
3 TVA BFNP TS 125 - TVA letter L. M. Mills to H. R. Denton dated July 20, 1979.
Subject:
Browns Ferry units 1 and 2 Inservice Pump and Valve Testing Program
. TVA letter from J. E. Gilleland to E. G. Case dated May 25, 1977
Subject:
Browns Ferry unit 3 Inservice Pump and Valve Testing Program - Technical Specifications provided in of May 25, 1977 letter
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At.the present time TVA is following a program of inservice pump and valve testing as described in submittals made to NRC.
This program has not been approved by NRC. Following such an unapproved program creates uncertainty regarding acceptability of the inspect' nus we are now doing. Approval of these specifi-cations along with the submitted program is urgently needed to, resolve that uncertainty.
4.
TVA BFNP TS 153 - TVA letter L. M. Mills to H. R. Denton dated October 16, 1980 - NRC Request for submittal of license.
amendment regarding Scram Discharge Volume Vent and Drain Valves.
5.
TVA BFNP TS 157 - TVA letter L. M. Mills to H. R. Denton dated April 24, 1981. These proposed changes clarify the definition of secondary containment integrity.
As documented in the April 24, 1981 letter, we are operating on the basis that TS 157 is approved. However, this request should be finalized and formally approved by amendment of the license.
6.
TVA BFNP TS 158 - TVA letter L. M. Mills to H. R. Denton dated April 28, 1981. NRC Request for submittal of license amendment regarding snubber surveillance.
7.
TVA BFNP TS 162 - TVA letter L. M. Mills to H. R. Denton-dated May 15, 1981. Supplement 1 - TVA letter L. M. Mills to H. R. Denton dated June 16, 1981.
TS 162 consists of miscellaneous changes which will make the technical specifications more consistent with actual practice and remove ambiguities.
NOTE: The revisions to Tables 3.7.A and 3 7.D for unit 3 from TS 162 should not be approved. The tables in TS 170 (Browns Ferry unit 3 reload 4) are correct and shoald be approved instead of the tables in TS 162 Supplement 1.
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