ML20085D589

Application for Amends to Licenses DPR-33,DPR-52 & DPR-68, Revising TS to Be Consistent W/Planned Replacement of Current Power Range Monitoring Portion of Existing Nms,Per GL 94-02.Proprietary GE Rept NEDC-32433P Encl.Rept Withheld

ML20085D589
Person / Time
Site:	Browns Ferry
Issue date:	06/02/1995
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18038B294	List: ML20085D589 ML20085D634
References
GL-94-02, GL-94-2, TVA-BFN-TS-353, NUDOCS 9506160280
Download: ML20085D589 (55)

Text

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nl l nn i Tenne ,ve Valley Authority. Post Office Box 2000. Decatur. Alabama 35609 l

l l June 2, 1995 I

TVA-BFN-TS-353 10 CFR 50.90 c' 10 CFR 2.790 (b) (1)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

i In the Matter of ) Docket Nos. 50-259 l Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

TECHNICAL SPECIFICATION (TS) 353 - POWER RANGE NEUTRON MONITOR (P l.NM) UPGRADE WITH IMPLEMENTATION OF AVERAGE POWER RANGE MONITOR (APRM) AND ROD BLOCK MONITOR (RBM) TS (ARTS) i IMPROVEMENTS AND MAXIMUM EXTENDED LOAD LINE LIMIT (MELLL)

ANALYSES In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment (TS-353) to licenses DPR-33, DPR-52, and DPR-68 to change the TSs for i

Units 1, 2, and 3. The proposed changes are described below.

1 I The proposal revises the TSs to be consistent with a planned replacement of the current power range monitoring portion of the existing Neutron Monitoring System (NMS). This change is consistent with our response to Generic Letter (GL) 94-02, and v ll allow TVA to proceed with implementation of the long-term solution designated as Option III in NEDO-31960 and NEDO-31960, Supplement 1, "BWR Owners' Group Long Term Stability Solution Licensing Methodology."

Additionally, the proposal reflects TVA's planned implementation of ARTS /MELLL improvements. The purpose of the AR7S/MELLL changes is to enhance operating flexibility and efficiency by implementing RBM design improvements, incorporating APRM/RBM TS improvements, and expanding the current allowable operating domain to the MELLL region of the power / flow chart.

9506160280 950602 PDR ADOCK 05000259 20 P PDR

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l U.S. Nuclear Regulatory Commission .

Page 2 l June 2, 1995 i I

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l TVA has determined that there are no significant hazards considerations associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9) . The BFN Plant Operations Review Committee and.the BFN Nuclear Safety Review j Board have reviewed this proposed change and determined that operation of BFN Units 1, 2, and 3 in accordance with the i proposed change will not endanger the health and safety of the public. Additionally, in accordance with 10 CFR 5 0. 91(b) (1) , TVA is sending a copy of this letter and

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enclosures to the Alabama State Department of Public Health.

Enclosure 1 to this letter provides the description and evaluation of the proposed change. Enclosure 2 contains copies of the appropriate TS pages from Units 1, 2, and 3 marked-up to show the proposed change. Enclosure 3 forwards the revised TS pages for Units 1, 2, and 3 which incorporate the proposed change.

As supporting documentation for the proposed ARTS /MELLL change, Attachment 1 of Enclosure 1 provides an engineering report prepared by GE to document results of analysis to support the proposed change. This engineering report contains information proprietary to GE. GE requests that the document be withheld from public disclosure in accordance with 10 CFR 2.790(a) (4) . An affidavit supporting this request in accordance with 10 CFR 2.790(b) (1) is provided in Attachment 1 of Enclosure 1.

As described in our response to GL 94-02, TVA plans to have the PRNM upgrade with the Option III trip in the " indicate only" mode installed in Unit 2 during the Cycle 8 refueling outage. TVA intends to implement the PRNM upgrade first on Unit 2, followed by Unit 3, then by Unit 1. TVA plans to install the PRNM upgrade on Unit 3 during its first refueling outage following restart from its current extended outage. As stated in Reference 1, TVA expects to confirm its implementation schedule for the stability long term solution for BFN Units 1, 2 and 3 within 30 days of NRC issuance of a safety evaluation report (SER) approving the GE licensing topical report, Reference 2.

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U.S. Nuclear Regulatory Commission Page 3 June 2, 1995 l l

TVA requests that the revised TS be approved by i February 19, 1996, (i.e., 30 days prior to shutdown of Unit 2 for its Cycle 8 refueling outage which is currently scheduled for March 22, 1996). TVA requests that the revised TS be ,

made effective per the following milestone schedule Unit 1 - Effective at the start of the Unit 2 Cycle 8 ,

refueling outage (March 1996).

Unit 2 - Effective at the start of the Unit 2 Cycle 8 refueling outage (March 1996).

Unit 3 - Effective at the start of the Unit 3 Cycle 7 refueling outage (March 1997).

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

Sincer y,/

n j Salas Mdnager of Site Licensing l r

Enclosures cc: See page 4 Subscribed and sworn tg before me '

on his JZ day of #4ad/ 1995.

n &?b ei dw Notary Public 10/06/98 g whslon Expires ,

My Commission Expires a

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t U.S. Nuclear Regulatory Comnission Page 4 June 2, 1995 i

cc (Enclosures):

American Nuclear Insurers Town' Center, Suite 300S 29 South Main Street I West Hartford, Connecticut 06107-2445  !

l Mr. W. D. Arndt General Electric Company 735 Broad Street Suite 804, James Building Chattanooga, Tennessee 37402 Mr. Johnny Black, Chairman Limestone County Commission 310 Washington Street ]

Athens, Alabama 35611 Mr. Mark S. Lesser, Acting Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Drowns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission l One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson i State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36194 l

a

General Electric Company AFFIDAVIT I, George B. Stramback, being duly sworn, depose and state as follows:

(1) I am Project Manager, Licensing Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in the GE proprietary report NEDC-32433P, Maximum Extended Load Line Limit and ARTS Improvement Program Analysesfor Browns Ferry Nuclear Plant Unit 1, 2 and 3, Class III (GE Proprietary Information), dated April 1995. The proprietary information is delineated by bars marked in the margin adjacent to the specific material.

(3) fn making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information",

and some portions also qualify under the narrower definition of" trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory CommissioA 975F2d871 (DC Cir.1992), and Public Citizen Health Research Grouo v. FDA, 704F2dl280 (DC Cir.1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of ,

resources or improve his competitive position in the design, manufacture,  ;

shipment, installation, assurance of quality, or licensing of a similar product; i l

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c. Information which reveals cost or price information, production capacities, ,

budget levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons ,

set forth in both paragraphs (4)a. and (4)b., above.  !

l (5) The inf>rmation sought to be withheld is being wbmitted to NRC in confidence. The informatien is of a sort customarily held in confidence by GE, and is in fact so held.

The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not rvailable in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of ,

the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of uternal release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and i by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory previsions or proprietary agreements.

l (8) The information identified in paragraph (2), above, is classified as proprietary because j it contains current hardware and sof1 ware anangement justified from numerous tests and applications, detailed results of analytical methods including computer codes, which GE has developed, obtained NRC approval of, and applied to perform transient conditions for the BWR.

C:\uscrdata\winword\proj\LaSaAfLdoc Affidavit Page 2 l

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The development and approval of the BWR computer codes used in this analysis was I achieved at a significant cost, on the order of several million dollars, to GE.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database ,

that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial valut, extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difIicult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost ifits competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

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i STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

I George B. Stramback, being duly sworn, deposes and says:

That he has read the foregoing afTidavit and the matters stated therein are tnie and correct l to the best of his knowledge, infonnation, and belief. l Executed at San Jose, California, this 6 day of b 1995.

1

/b.

G(orge B/Stramback ~

General Electric Company i

Subscribed and sworn before me this day of fik 1995. j

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. .. PAULA F. HU$SEY r

- N ' Noto P e orNo kM_

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oEc $ e Notary Public, State of Califodia l

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

,.. UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-353 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE INDEZ I. DESCRIPTION OF THE PROPOSED CHANGE . . . . . . . . El-2 II. REASON FOR THE PROPOSED CHANGE . . . . . . . . . . El-20 III. SAFETY ANALYSIS . . . . . . . . . . . . . . . . . El-27 IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION El-32 V. ENVIRONMENTAL IMPACT CONSIDERATION . . . . . . . . El-35 VI. REFERENCES . . . . . . . . . . . . . . . . . . . . El-35 VII. ATTACHMENTS Attachment 1 GE Report, Maximum Extended Load Line Limit and ARTS Improvement Program Analypss for Browns Ferry Nuclear Plant Unit 1, 2 and 3, NEDC-32433P.

Attachment 2 Plant Specific Information Required for NUMAC PRNM Retrofit

I. DESCRIPTION OF THE PROPOSED CHANGE This proposed change to BFN Technical Specifications (TS) consists, broadly, of two groups of changes, Group A and Group B. A brief description of each group, together with a detailed listing of the proposed changes, is provided.

Groun A: The following proposed changes support a planned replacement of the power range portion of the existing Neutron Monitoring System (NMS) with a General Electric (GE) digital Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) retrofit design. As part of the planned modification, the number of Average Power Range Monitor (APRM) instrument channels will be l

reduced from six to four. The Local Power Range Monitor (LPRM) inputs to the APRMs will be reconfigured. The four ,

APRM instrument channels will be combined in four 2-out-of- l 4 trip logic channels which provide input to the Reactor Protection System (RPS) trip channels. The number of recirculation flow instrument channels associated with the APRMs will be increased from two total-flow channels (four transmitters) to four total-flow channels (eight transmitters).

BFN TS changes proposed in support of the planned modification are provided below. These changes are consistent with the TS changes recommended in Section 8 of reference 2 for implementation of the NUMAC PRNM retrofit.

TS page numbers are presented in the format "Page x.z/y.z-U1/U2/U3" where U1, U2 and U3 are the respective Unit 1, Unit 2, and Unit 3 page numbers. Where only one number is given, the TS page number is the same in all three units.

1. Page 3.1/4.1-3/3/2. For the APRMs, Table 3.1.A currently reads:

Min. No. of Operable Instr.

Channels Per Trip Trip Level Shut- Startup/

Svet em (1) (23) Triri Purmt ion Set t inq d^wn Pefuel l '1 ) Hot Frandby By,n Action (1)

APRM (16 ) (24 )

(25) 2 High Flux See Spec. X 1.A or 1.B (Flow Biased) 2.1.A.1 2 High Flux s 120% X 1.A or 1.B (Fixed Trip) 2 High Flux 115% rat.ed X (21) X (17) (15) 1.A power 2 Inoperative (13) X (21) X (17) X 1.A 2 Downscale 23 (11) (11) X (12 ) 1.A or 1.B Indicated on Scale El-2

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I The proposed change revises the minimum operability i requirements and actions, deletes the APRM Downscale l trip function, deletes requirements for APRM trip l functions in the Refuel mode, adds a 2/4 Trip Voter trip function, and adjusts associated notes. The revised i table is provided below. ,

M1 . No. of Operable Instr.

Channels <

I Per Trip Trip Level dnut- Startup/

Syst em (1) (? 3) Trio Function Set t iner n dpqwn Pafuel (?) Hot Standby M Action (1) {

APRM (16) (24 )

(25) 3 (11) High Flux See Spec. X 1.A or 1.D (Flow Biased) 2.1.A.1 or 1.E 3 (11) High Flux  ; 120% X 1.A or 1.B (Fixed Trip) or 1.E 1 'll) High Flux 115% rated X(17) (15) 1.A or 1.E power 3 (11) Inoperative (33) X (17) X 1.A or 1.E 2 2/4 Trip (12) X X 1.A or 1.F Voters

2. Page 3.1/4.1-5/5/4. The proposed change adds the following actions to Note 1 of " Notes for Table 3.1.A":

E. For the APRM functions only, if only two APRM +

channels are OPERABLE, restore a third APRM ,

channel to OPERABLE status or trip one of the inoperable APRM channels within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If only one APRM channel is OPERABLE, trip one inoperable i APRM channel immediately and restore an  ;

inoperable APRM channel to OPERABLE status or initiate alternative action within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

F. For the APRM functions only, if one voter channel is inoperable in one trip system, restore the voter channel to OPERABLE status or trip the inoperable channel or the entire trip system within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If one voter channel is inoperable in both trip systems, restore the inoperable voter channels to OPERABLE status or  ;

initiate alternative action within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

In Note 7 of " Notes for Table 3.1.A", the proposed change deletes Note 7.E ("APRM 15 percent scram"). This 3 reflects deletion of the requirement for the APRM scram function in the Refuel mode.

El-3

3. Page 3.1/4.1-6/6/5. Notes 11,- 12 and 13 in " Notes for Table 3.1.A" currently read:

11. The APRM downscale trip function is only active when the reactor mode switch is in RUN.

12. The APRM downscale trip function is automatically bypassed when the IRM instrumentation.is OPERABLE and not high.

13. Less than 14 OPERABLE LPRMs will cause a trip system trip.

The proposed change revises Notes 11, 12 and 13 to read:

11. The same three (3) required APRM channels are shared by both RPS trip systems.

12. Any combination of APRM upscale or inoperative trips from two different (non-bypassed) APRMs will trip all of the 2/4 voter units.

13. Less than the required minimum number of OPERABLE LPRMS will cause an instrument channel inoperative alarm.

4. Page 3.1/4.1-3/3/2 and Page 3.1/4.1-6/6/5. In Table 3.1.A, the proposed change adds application of Note 21 to IRM High Flux in the Refuel mode, and revises Note 21 in " Notes for Table 3.1.A" as specified below.

Note 21, which currently provides an indirect requirement for enabling the SRM noncoincidence High Flux scram, reads as follows:

(21) The APRM High Flux and Inoperative Trips do not have to be OPERABLE in the REFUEL Mode if the Source Range Monitors are connected to give a noncoincidence, High Flux scram at 5 x 105 cps.

The SRMs shall be OPERABLE per Specification 3.10.B.1. The removal of eight (8) shorting links is required to provide noncoincidence high flux scram protection from the Source Range Monitors.

The proposed change revises Note 21 to be a direct requirement for shorting link removal. The revised Note 21 reads:

(21) In the REFUEL Mode unless adequate shutdown margin has been demonstrated per Specification 3.3.A.1, whenever any control rod is withdrawn from a core cell containing one or more fuel assemblies, shorting links shall be removed from El-4

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the RPS circuitry to enable the Source Range Monitor (SRM) noncoincidence high-flux scram function. The SRMs shall be OPERABLE per Specification 3.10.B.1. The removal of eight (8) shorting links is required to provide noncoincidence high-flux scram protection from the SRMs.

5. Page 3.1/4.1-8/8/7. In Table 4.1.A the Surveillance Requirements (SRs) for APRMs currently read as follows:

Roup (2) Functional Tast Minimum Frerraency O)

APRM High Flux (15% Scram) C Trip Output Relays (4) Before Each Startup and Weekly When Required to be Operable High Flux (Flow Blamed) B Trip Output Relays (4) Once/ Week High Flux (Fixed Trip) B Trip Output Relays (4) Once/ Week Inoperative B Trip Output Relays (4) Once/ Week Downscale B Trip Output Relays (4) Once/ Week Flow Bias B (6) (6)

The proposed change deletes the APRM functional testing

" group" assignments, deletes requirements for the APRM Downscale and Flow Bias trip functions, revises the minimum functional test frequency for the APRM trip functions, adds testing requirements for the 2/4 voter Logic function, specifies a weekly test of the scram contactors initiated from the 2/4 voters, and adjusts associated notes. The revised table is provided below:

or~ m iM n mer i nn 41 Tant Minimum Fraouanev 0)

APRM High Flux (15% Scram) Trip output Relays (4) (S) Every 6 months (9) 2/4 Voter Logic (10) Each Refueling Outage High Flux (Flow Biased) Trip Output Relays (4) (6) Every 6 months 2/4 Voter Logic (10) Each Refueling Outage High Flux (Fixed Trip) Trip Output Relays (4) (5) Every 6 months 2/4 voter Logic (10) Each Refueling Outage Inoperative Trip Output Relays (4) (6) Every 6 months 2/4 Voter Logic (10) Each Refueling Outage 2/4 Trip Voter Trip Scram Contactors (11) Once/ Week

6. Page 3.1/4.1-10/10/9. In " Notes for Table 4.1.A" the proposed change replaces Note 5 and Note 6 and adds new Notes 9 and 10.

Notes 5 and 6 currently read as follows:

5. (Deleted)

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6. The functional test of the flow bias network is performed in accordance with Table 4.2.C.

The proposed change reads as follows:

5. The channel functional test shall include both the APRM channels and the 2/4 voter channels.

6. The channel functional test shall include both  !

the APRM channels and the 2/4 voter channels plus the flow input function, excluding the flow transmitters.

9. Not required to be performed when entering the STARTUP/ HOT STANDBY Mode from RUN Mode until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the STARTUP/ HOT STANDBY Mode.  ;

10. Functional test consists of simulating APRM trip conditions at the APRM channel outputs to check all combinations of two tripped inputs to the 2/4 ,

voter logic in each voter channel. -

12 . Functional test consists of manually tripping the 2/4 voter trip output, one voter channel at a time, to demonstrate that each scram contactor for each RPS trip system channel (A1, A2, B1 and B2) operates and produces a half-scram.  ;

7. Page 3.1/4.1-11/11/10. In Table 4.1.B, the proposed change deletes group designations for APRM High Flux

" Output Signal", " Flow Bias Signal" and "LPRM Signal", s The proposed change also indents "LPRM Signal" parallel with " Output Signal" and " Flow Bias Signal".

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8. Page 3.1/4.1-12/12/11. Note 7 currently reads:

The Flow Bias Signal calibration will consist of calibrating the sensors, flow converters, and signal offset networks during each operating cycle. The instrumentation is an analog type with redundant flow signals that can be compared. The flow comparator trip and upscale will be functionally tested according to Table 4.2.C to ensure the proper operation during the operating cycle. Refer to 4.1. Bases for further explanation of calibrating frequency.

The proposed change revises Note 7 to read:

The flow bias signal calibration will consist of calibrating the analog differential pressure flow sensors once per operating cycle. Calibration of the flow bias processing system is done once per operating El-6

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i cycle as part of the overall APRM instrumentation calibration.

9. Page 3/1/4.1-14/14/13. The proposed change deletes the last sentence of the sixth paragraph which reads:

Three APRM instrument channels are provided for each protection trip system.

Following deletion, the proposed change adds:

The APRM system is divided into four APRM channels and four 2-out-of-4 trip voter channels. Each APRM channel provides input to each of the four voter channels. The four voter channels are divided into two groups of two each, with each group of two providing inputs to one RPS trip system. The APRM system is designed to allow one APRM channel, but no voter channels, to be bypassed. A trip from any one unbypassed APRM will result in a " half-trip" in all four of the voter units, but no trip inputs to either RPS trip system. A trip from any two unbypassed APRM channels will result in a full trip in each of the four voter channels, which in turn results in two trip inputs into each RPS trip system resulting in a full scram.

Each APRM instrument channel receives input signals from forty-three (43) Local Power Range Monitors (LPRMs). A minimum of twenty (20) LPRM inputs with three (3) per axial level is required for the APRM instrument channel to be OPERABLE. Fewer than the required minimum number of LPRM inputs generates an instrument channel inoperative alarm and a control rod block but does not result in an automatic trip input to the 2-out-of-4 voters.

10. Page 3.1/4.1-15/15/14. The proposed change revises the first two sentences of the first paragraph on this page, and deletes the third sentence of the paragraph.

The paragraph currently reads:

Each protection trip system has one more APRM than is necessary to meet the minimum number required per channel. This allows the bypassing of one APRM per protection trip system for maintenance testing or calibration. Additional IRM channels have also been provided to allow for bypassing one such channel. The bases for....

The revised paragraph will read:

Each protection trip system has one more IRM than is necessary to meet the minimum number required per El-7

p-

+

channel. This allows the bypassing of one IRM per ,

protection trip system for maintenance testing or calibration. The bases for.... ,

11. Page 3.1/4.1-16/16/15. The proposed change revises the e sentence (approximately middle of the page) describing the APRM downscale function which currently reads:

Because of the APRM downscale limit of 2 3 percent when ,

in the RUN mode and high level limit of s 15 percent when in the STARTUP Mode, the transition between the STARTUP and RUN Modes must be made with the'APRM  :

instrumentation indicating between 3 percent and 15 i

percent of rated power or a control rod scram will occur.

The proposed change revises the sentence to read:

Because of the APRM downscale rod block limit of 2 3 percent when in the RUN mode and high level flux scram limit of s 15 percent when in the STARTUP Mode, the transition between the STARTUP and RUN Modes must be  ;

made with the APRM instrumentation indicating between 3 percent and 15 percent of rated power.

12. Page 3.1/4.1-17/17/16. A sentence currently reads:

The channels listed in Tables 4.1.A and 4.1.B are divided into three groups for functional testing.

The proposed change revises this sentence to read:

Except for the APRMs which take credit for self-test capability, the channels listed in Tables 4.1.A and 4.1.B are divided into three groups for functional testing.

13. Page 3.1/4.1-19/19/18. The proposed change deletes the paragraph describing calibration of the APRM Flow Biasing Network which currently reads:

The frequency of calibration of the APRM Flow Biasing Network has been established at each refueling outage.

There are several instruments which must be calibrated and it will take several hours to perform the calibration of the entire network. While the calibration is being performed, a zero flow signal will I be sent to half of the APRMs resulting in a half scram ,

and rod block condition. Thus, if the calibration were l performed during operation, flux shaping would not be possible. Based on experience at other generating stations, drift of instruments, such as those in the Flow Biasing Network, is not significant and therefore, El-8 i

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~to avoid spurious scrams, a calibration frequency of l each refueling outage is established.

The proposed change adds the following paragraphs describing the APRM self-test functions and periodic  :

manual test requirements before the paragraph beginning  :

"The sensitivity of LPRM detectors...": j The APRM and 2-out-of-4 voter channel hardware is  !

provided with a self-test capability which automatically checks most of the critical hardware at  ;

least once per 15 minute interval whenever the APRM channel is in the operate mode. This provides a  :

virtually continuous monitoring of the essential APRM l trip functions. In the event a critical fault is detected, an " inoperative" trip signal results. A fault detected in non-critical hardware results in an i

" inoperative" alarm. Following receipt of an

" inoperative" trip or alarm signal, the operator can employ numerous diagnostic testing options to locate ,

the problem.

The automatic self-test function is supplemented with a '

manual APRM trip functional test, including the 2-out-of-4 voter channels and the interface with the RPS trip systems. In combination with the virtually continuous self-testing, the manual APRM trip functional test ,

provides adequate functional testing of the APRM trip function. Therefore, the six-month test frequency for  !

the manual testing provides an acceptable level of  ;

availability of the APRM.

In addition to the above tests, the 2-out-of-4 voter is used to test the RPS scram contactors. The output of each voter channel is tripped to produce a scram signal  ;

into each of the RPS trip system channels (A1, A2, B1 ,

and B2) to individually operate the respective scram contactors. The weekly test interval provides an acceptable level of availability of the scram contactors.

Each APRM receives the output signals from two analog differential pressure flow transducers, one associated with recirculation loop A and the other with i recirculation loop B. These differential pressure signals are converted into representative digital loop flow signals within the same hardware that performs the APRM functions and are added to determine a total recirculation flow. The total recirculation flow value is used by the APRM to determine the flow biased setpoints. Each total recirculation flow signal developed by an APRM is compared in the hardware that performs the RBM functions to the signals from the remaining three APRMs. An alarm is given if a preset El-9

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3 i

compare level setpoint is exceeded. The flow processing is integrated with the APRM processing and ,

is covered by the same self-test and alarm functions  !

described earlier. As a result of the virtually continuous monitoring of the equipment performing the  :

flow processing, and the automatic comparison of redundant flow signals, it is acceptable to calibrate ,

this equipment once per operating cycle. j

14. Page 3.2/4.2-25/25/24. In Table 3.2.C, for the APRM rod  ;

block functions the proposed change revises the Minimum  !

Operable Channels Per Trip Function from "4" to "3" and  ;

deletes requirements for the " Flow Bias Comparator" and

" Flow Bias Upscale" rod block functions.

Additional proposed changes in Table 3.2.C are described ,

under the second group of changes. Group B. l

15. Page 3.2/4.2-26,27/26,27/25,26. In " Notes for Table 3.2.C" the propose.d change revises Note 5, Note 10.b and Note 10.c as described below.

Note 5 currently reads: +

5. During repair...not more than one SRM or RBM channel nor more than two APRM or IRM channels may be bypassed....

The proposed change revises Note 5 to read: [

i

5. During repair...not more than one SRM, RBM or  :

APRM channel nor more than two IRM channels may be bypassed....

Note 10.b, APRM inoperative trips (2) and (3) currently ,

read: 4 (2) Less than 14 LPRM inputs.  !

(3) Circuit boards not in circuit.

The proposed change revises these notes and adds Note i 10 . b . ( 4 ) . The proposed change reads as follows:

(2) Less than the required minimum number of LPRM  !

inputs.

(3) APRM module unplugged.

(4) Self-test detected critical fault.

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Note 10.c, RBM inoperative trip (2) currently reads: ,

(2) Circuit boards not in circuit. .

The proposed change revises this note and adds Note  !

10.c.(5). The proposed change reads as follows:

(2) RBM module unplugged.

(5) Self-test detected critical fault.

t Additional proposed changes in Notes for Table 3.2.C are ,

described under the second group of changes, Group B.

16. Page 3.2/4.2-50/50/49. In Table 4.2.C, the proposed change deletes surveillance requirements for " Flow Bias '

Comparator" and " Flow Bias Upscale" and revises test frequency requirements as follows:

Calibration frequency changes from "once/3 months" to "once/ operating cycle" for the APRM Upscale and Downscale rod block trip functions.

Calibration frequency changes from "once/6 months" to -

"once/ operating cycle" for the RBM Upscale and Downscale rod block trip functions.

Instrument check frequency changes from "once/ day" to "N/A" for the RBM Upscale, Downscale and Inoperative rod block trip functions.

The additional proposed change in Table 4.2.C is .

t described under the second group of changes, Group B.

^

17. Page 3.2/4.2-59/59/58. In " Notes for Tables 4.2.A Through 4.2.L, Except 4.2.D and 4.2.K", Note 1 currently reads:

(1) Functional tests shall be performed once per month.

The proposed change revises Note 1 to read: ,

(1) For IRMs and SRMs functional tests shall be performed once per month. For APRMs and RBMs functional tests shall be performed once per  :'

6 months.

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18. Page 3.2/4.2-60/60/59. In " Notes for Tables 4.2.A Through 4.2.L, Except 4.2.D and 4.2.K", the proposed change deletes Note 15 and Note 20 which currently read:

15. The flow bias comparator.will be tested by putting one flow unit in " Test" (producing 1/2 scram) and adjusting the test input to obtain comparator rod block. The flow bias upscale will be verified by observing a local upscale trip light during operation and verified that it will produce a rod block during the operating cycle.

20. Calibration of the comparator requires the inputs from both recirculation loops to be interrupted, thereby removing the flow bias signal to the APRM and RBM and scramming the reactor. This calibration can only be performed during an outage.

19. Page 3.2/4.2-68/68/67. The proposed change revises a sentence in "3.2 Bases" describing control rod block functions. The sentence currently reads as follows:

The trip logic for this function is 1-out-of-n: e.g.,

any trip on one of six APRMs, eight IRMs or four SRMs will result in a rod block The revised sentence will read:

The trip logic for this functicn is 1-out-of-n: e.g.,

any trip on one of four APRMs, eight IRMs or four SRMs will result in a rod block.

20. Page 3.2/4.2-73/73a/72. The proposed change adds the following new discussion of APRM and RBM rod block function test frequency at the end of the current "4.2 Bases" section:

The electronic instrumentation comprising the APRM rod block and Rod Block Monitor functions together with the recirculation flow instrumentation for flow bias purposes is monitored by the same self-test functions as applied to the APRM function for the RPS. The functional test frequency of every six months is based on this automatic self-test monitoring at 15 minute intervals and on the low expected equipment failure rates. Calibration frequency of once per operating cycle is based on the drift characteristics of the limited number of analog components, recognizing that most of the processing is performed digitally without drift of setpoint values.

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i Group B: The following proposed changes are related to planned implementation of APRM and RBM technical specification (ARTS) improvements recommended by GE and proposed operation in an expanded core power / flow domain, the Maximum Extended Load Line Limit (MELLL) region. RBM modifications and APRM setpoint changes required to implement the proposed ARTS /MELLL operation are included in the NUMAC PRNM design. The proposed expanded operating  ;

region above the rated (design) power / flow control line is bounded by the rated (100%) power line and the power / flow ,

control line which passes through the 100% power /75% core '

flow point (approximately the 121% rod line).

BFN TS changes proposed in support of ARTS /MELLL operation are provided below. These changes are supported by analyses performed for BFN by GE as documented in reference 3 and are consistent with the recommendations contained therein. TS page numbers are presented in the format "Page x.z/y.z-U1/U2/U3" where U1, U2 and U3 are the respective Unit 1, Unit 2, and Unit 3 page numbers. Where only one number is given, the TS page number is the same in all three units.

21. Pages 1.0-7 and 1.0-8: The proposed change deletes the following definitions under the heading of " Thermal Parameters":

3. Core Maximum Fraction of Limitino Power Density (CMFLPD) -- ....

5. Core Maximum Fraction of Critical Power (CMFCP) -

22. Page 1.1/2.1-2. Under Limiting Safety System Setting (LSSS) 2.1.A.1.a, the APRM flow biased scram setpoint equation currently reads:

Ss (0. 58W+62%) .

The proposed change revises this equation to read:

Ss(0.66W+71%).

23. Page 1.1/2.1-3. Under the note in LSSS 2.1.A.1.b. the proposed change deletes the following sentence:

Surveillance requirements for APRM scram setpoint are given in Specification 4.5.L.

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24. Page 1.1/2.1-7. The proposed change revises Figure 2.1-  !

2 to show the new APRM Flow Bias Scram Setpoint. j

25. Page 1.1/2.1-16. Under Bases Section 2.1.L the proposed l change adds a new reference:  ;

Maximum Extended Load Line Limit and ARTS Improvement Program Analyses for Browns Ferry Nuclear Plant Unit 1, 2 and 3, NEDC-32433P.

26. Page 3.1/4.1-20/20/19. The proposed change deletes the .

term "CMFLPD" from the sentence which currently reads, "The technical specification limits of CMFLPD, CPR, and  !

APLHGR are determined...."

27. Page 3.2/4.2-25/25/24. In Table 3.2.C requirements for ,

the RBM functions currently read as follows:

I Minimum Operable Channels Per Trip Function (5) Function Trin Level Settina 2 (7) RBM Upscale (Flow Bias) (13) 2(7) RBM Downscale (9) 23%

The proposed change revises the RBM functions to reflect a change from flow-biased to power-biased setpoints.

The revised table entries are provided below: 4 Minimum operable Channels Per Trip Function (5) Function Trio Level-Settina 2(7) RBM Upscale (Power Bias)

Low Power Range (13) (14)

Intermediate Power Range (13) (14)

High Power Range (13) (14) 2(7) RBM Downscale (9) (13) (15) 1 El-14 ,

7

28. Page 3.2/4.2-26/26/25. In Note 7 of " Notes for Table 3.2.C" the proposed change adds, as Note 7.c, new conditions of power and MCPR where the RBM is not required to be operable. Previous Notes "7.c" and "7.d" are relabeled as "7.d" and "7.e", respectively, but their text is not changed.

7.c The RBM need not be OPERABLE if either of the following two conditions is met:

(1) Reactor thermal power is 190 percent of rated and MCPR is 21.40, or (2) Reactor thermal power is <90 percent of rated and MCPR is 21.70.

29. Page 3.2/4.2-27/27/26. Note 13 in " Notes for Table 3.2.C" currently reads: ,

13. The trip level setting and clipped value for this setting shall be as specified in the CORE OPERATING LIMITS REPORT.

The proposed change revises Note 13 and adds new Notes 14 and 15. The revised notes read as follows:

13. The RBM rod block trip setpoints and applicable power ranges are specified in the CORE OPERATING LIMITS REPORT (COLR).

14. Less than or equal to the setpoint allowable value specified in the COLR.

15. Greater than or equal to the setpoint allowable  ;

value specified in the COLR.  ;

30. Page 3.2/4.2-50/50/49. In Table 4.2.C the parenthetic ,

description of the RBM Upscale function is changed from

" Flow Bias" to " Power Bias".

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0 9 1 ng m. >

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31. Page13.3/4.3-8. The proposed change deletes LCO 3.3.B.5  !

-and SR 4.3.B.5 which read: j 3.3.B.5 During operation with CMFCP or CMFLPD equal.to '

I or greater than 0.95, either: j

.a. .

Both RBM channels shall-be OPERABLE; or:

~ b. Control rod withdrawal shall be blocked. -!

!. l 4.3.B.5-During operation with CMFCP or CMFLPD equal to-  !

or greater than 0.95, an instrument functional test of the RBM shall be performed prior to control rod withdrawal 1and at least once per 24 ,

hours thereafter.

32. Page 3.3/4.3-17. The proposed change deletes the bases section 3.3/4.3-B 5 which reads: l l

The Rod Block Monitor (RBM) is designed....The l' specified restrictions with one channel out of service conservatively assure that fuel damage will not occur _ '

due to rod withdrawal errors when this condition exists.

33. Page 3.5/4.5-18.. The proposed change revises LCO 3.5.I  :

to implement flow-dependent and power-dependent APLHGR-l limits.  ;

l LCO 3.5.I currently reads: {

...the Average Planar Linear Heat Generation Rate l (APLHGR) of any fuel assembly at any axial location i shall not exceed.the appropriate APLHGR limit provided j in the CORF, OPERATING LIMITS REPORT.

The proposed change ~ revises LCO 3.5.I to read:

...the Average Planar Linear Heat Generation Rate  !'

(APLHGR) of any fuel assembly at any axial location '

shall not exceed the appropriate rated, flow-dependent or power-dependent APLHGR limit provided in the CORE  ;

OPERATING LIMITS REPORT.  !

- 34. Page 3.5/4.5-19. The proposed change revises.LCO 3.5.K and SR 3.5.K to implement flow-dependent and. power-  !

dependent MCPR operating limits.

LCO 3.5.K currently-reads:

The minimum critical power ratio (MCPR) shall be equal to or greater than the operating limit MCPR (OLMCPR) as provided in the CORE OPERATING LIMITS REPORT. ....

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-- - . - .. ~

. r . . - . . . _ . . . _. r ,r .inr

i The proposed change revises LCO 3.5.K to read:

The minimum critical power ratio (MCPR) shall be equal to or greater than the appropriate rated, flow-dependent or power-dependent operating limit MCPR (OLMCPR) as provided in the CORE OPERATING LIMITS i REPORT. ....

SR 4.5.K.2 currently reads:

The MCPR limit at rated flow and rated power shall be determined as provided in the CORE OPERATING LIMITS REPORT....

The proposed change revises SR 4.5.K.2 to read:

The operating limit MCPR shall be determined as provided in the CORE OPERATING LIMITS REPORT....

35. Page 3.5/4.5-20. The proposed change deletes the APRM setpoint setdown requirements of LCO 3.5.L and SR 4.5.L.

These requirements currently read as follows.

3.5.L. APRM Setooints

1. Whenever~the core thermal power is 225% of rated, the ratio of FRP/CMFLPD shall be 21.0, or the APRM scram setpoint equation listed in Lection 2.1.A and the APRM rod block setpoint equation listed in the CORE OPERATING LIMITS REPORT shall be multiplied by FRP/CMFLPD. ,

2. When it is determined that 3.5.L.1 is not being met, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to correct the condition.

3. If 3.5.L.1 and 3.5.L.2 cannot be met, the reactor power shall be reduced to 52 5% of rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.5.L APRM Setooints FRP/CMFLPD shall be determined daily when the reactor is 2 25% of rated thermal power.

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36. Page 3.5/4.5-33/31/34. In Bases 3.5.I the proposed change adds the following description of power-dependent and flow-dependent APLHGR limits at the end of the current section:

At less than rated power conditions, the rated APLHGR limit is adjusted by a power dependent correction factor, MAPFAC(P). At less than rated flow conditions, the rated APLHGR limit is adjusted by a flow dependent correction f actor, MAPFAC (F) . The most limiting power-adjusted or flow-adjusted value is taken as the APLHGR operating limit for the off-rated condition.

The flow dependent correction factor, MAPFAC(F),

applied to the rated APLHGR limit assures that (1) the 10 CFR 50.46 limit would not be exceeded during a LOCA initiated from less than rated core flow conditions and (2) the fuel thermal mechanical. design criteria would be met during abnormal operating transients initiated from less than rated core flow conditions. MAPFAC(F) values are provided in the CORE _ OPERATING LIMITS REPORT.

The power dependent correction factor, MAPFAC(P),

applied to the rated APLHGR limit assures that the fuel thermal mechanical design criteria would be met during abnormal operating transients initiated from less than rated power conditions. MAPFAC(P) values are provided in the CORE OPERATING LIMITS REPORT.

37. Page 3.5/4.5-33/31/34. In Bases 3.5.K the proposed change adds the following description of power-dependent and flow-dependent MCPR limits at the end of the current section:

At less than rated power conditions, a power dependent MCPR operating limit, MCPR(P), is applicable. At less than rated flow conditions, a Flow dependent MCPR operating limit, MCPR(F), is applicable. The most limiting power dependent or flow dependent value is taken as the MCPR operating limit for the off-rated condition.

The flow dependent limit, MCPR(F), provides the thermal margin required to protect the fuel from transients resulting from inadvertent eore flow increases.

MCPR (F) values are provided in the CORE OPERATING LIMITS REPORT.

The power dependent limit, MCPR(P), protects the fuel from the other limiting abnormal operating transients, including localized events such as a rod withdrawal error. MCPR(P) values are provided in the CORE OPERATING LIMITS REPORT.

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38. Page 3.5/4.5-33,34/31,32/34,35. The proposed change ~

deletes Bases Section 3.5.L, which reads:

3.5.L. APRM Setnoints Operation is constrained to the LHGR limit....

.... additional margin gained by the setdown adjustment is above and beyond that ensured by I the safety-analysis.

39. Page 6.0-26a,b/26a/26a. The proposed change revises the '

description of the content of the CORE OPERATING LIMITS REPORT as indicated below:

Current Description Revised Description (1) The APLHGR for The rated APLHGR limit; Specification 3.5.I. the Flow Dependent APLHGR Factor, MAPFAC(F); and the Power Dependent APLHGR Factor, MAPFAC(P) for Specification 3.5.I.

(2) The LHGR for The LGHR limit for Specification 3.5.J. Specification 3.5.J.

(3) The MCPR Operating The rated MCPR Operating Limit for Limit; the Flow Dependent Specification 3.5.K/ MCPR Operating Limit, MCPR(F);

4.5.K. and the Power Dependent MCPR Operating Limit, MCPR (P) for Specification 3.5.K/4.5.K.

(4) The APRM Flow Biased The APRM flow biased rod block Rod Block Trip trip setting for Specification Setting for 2.1.A.1.c and Table 3.2.C.

Specification 2.1.A.1.c, Table 3.2.C, and Specification 3.5.L.

(5) The RBM Upscale (Flow The RBM downscale trip Bias) Trip Setting and setpoint, high power trip clipped value for this setpoint, intermediate power setting for Table trip setpoint, and low power 3.2.C. trip setpoint, and applicable reactor thermal power ranges for each of the setpoints for Table 3.2.C.

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1 II. REASON FOR THE PROPOSED CHANGE All proposed TS changes described under Group A, above, are required to support replacement of the existing power range neutron monitoring equipment. As discussed in reference 1, BFN is planning to replace the power range monitor portion of the NMS with a GE digital NUMAC PRNM retrofit system.  !

The new equipment will include capability for an automatic  !

Oscillation Power Range Monitor (OPRM) trip to detect and suppress possible thermal hydraulic instabilities in the plant. The new OPRM trip function, when enabled, will implement the Boiling Water Reactor Owners Group (BWROG) 7 defined " Stability option III" alternative. However, the  :

OPRM trip function will not be enabled during the first cycle of operation with the new equipment, and this proposed change in technical specifications does not include revisions to incorporate the Stability Option III automatic trip function.

The proposed modification involves replacement of all of the existing power range monitor electronics with new NUMAC digital PRNM hardware. The current equipment is mounted in a 5-bay panel in the main control room of each reactor unit. The modification removes and replaces virtually all of the existing power range monitor equipment within the confines of the main control room panels, but with minor exceptions leaves the plant level cabling and interfaces undisturbed.

All power range monitor functions are maintained, including LPRM detector signal processing, LPRM averaging, APRM trips, and RBM logic and interlocks. Recirculation flow signal processing, previously accomplished using separate hardware within the power range monitor control panels, is integrated into the APRM chassis in the new PRNM system.

The six existing APRM channels in the current system are replaced with four APRM channels, each using 1/4 of the total LPRM detectors. The APRM function is retained, but four 2-out-of-4 trip output voters are added to the input to the RPS, two in each RPP trip system. The trip outputs from all four APRM channels are sent to each voter so that each of the inputs to the RPS is a voted result of all four APRM channels. The number of recirculation flow instrument inputs to the APRMs is increased from two total-flow instrument loops (four transmitters) to four total-flow instrument loops (eight transmitters), permitting one recircul.ition total-flow instrument loop to be assigned to each APRM channel.

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E l 1

The reasons for the various individual proposed TS changes described in Group A are as follows:

The required minimum number of operable instrument channels for the APRM scram trip functions is changed to 3 because the new configuration will have 4 total APRM channels combined in a 2-out-of-4 logic. In the proposed configuration, a minimum of 3 of the 4 channels is required operable to meet single failure criteria for the RPS trips initiated by APRMs. Note 11 is added to the minimum channel number in Table 3.1.A to highlight the way in which the proposed APRM instrument channel configuration is different from the rest of the RPS instrument channels. 1 l

Note 13 in Table 3.1.A is revised because in the '

proposed configuration the minimum required number of operable LPRMs changes, and fewer than the required minimum number results in an inoperative alarm, not an inoperative trip. The new required minimum number is provided in a description added to Bases 3.1. This new requirement is based on analyses performed for BFN by GE  ;

which cover the worst case combinations of LPRM input '

failures and LPRM bypass conditions. Fewer than the required minimum number of LPRM inputs (20 total, with 3 per axial level) causes an instrument channel  !

inoperative alarm and control rod block, but does not result in an automatic inoperative trip input to the 2-out-of-4 voters. An automatic APRM inoperative trip is required to occur when the APRM channel is incapable of providing a trip based on normal functions. However, when the minimum number of LPRM detectors is reached, the APRM still is capable of providing normal protective  !

trips. Thus, applicable LCO action times are allowed to evaluated and correct the situation. This is consistent with the requirements of reference 2. ,

The 2/4 APRM trip voters require a minimum operable  !

number of 2 instrument channels per RPS trip system.

This requirement is consistent with the proposed new hardware configuration. There are 2 voters per RPS trip system, and requiring 2 voters operable in each of the two RPS trip systems ensures that single failure criteria is met. Note 12 is revised to provide details

• of the logic of the 2/4 voter trips.

New action statements associated with inoperability of the APRM trip functions or the 2/4 voters are added. If fewer than the required minimum number of APRM trip-functions are operable, the new action requirements permit a maximum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to restore the configuration to one that will withstand single failure (by either repairing or tripping an inoperable channel). Use of 6 El-21

i hours for this action is consister.t with Standard TS  !

requirements when fewer than the required number of .

instrument channels is operable in both RPS trip systems. One 2/4 voter interfaces with only one RPS trip system. Thus, the required actions for 2/4 voter  :

inoperability reflect Standard TS action time limits for !

instruments inoperable in one RPS trip system (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) or for instruments inoperable in both RPS trip systems  !

(6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />). These requirements are consistent with the  :

recommendations of reference 2.  :

Requirements for an APRM downscale scram trip and for operability of APRMs in the Refuel mode are deleted, i consistent with the recommendations of reference 2.

However, reference 2 maintains requirements associated ,

with SRM/IRM scram functions in Refuel mode. The proposed change revises Note 21 to replace the previous indirect requirement for removing shorting links with a direct requirement which ensures that shorting links are removed to enable the SRM high flux scram function under appropriate conditions. Conditions requiring the SRM high flux scram function in Refuel mode are that a ,

control rod be withdrawn from a cell containing fuel and >

that shutdown margin has not been demonstrated. If shutdown margin has been demonstrated, then the one-rod-out interlock provides assurance that the reactor will not become critical in the Refuel mode.

Surveillances frequencies associated with the APRM scram '

functions are changed to the values recommended in and supported by reference 2. These increases in APRM surveillance intervals take credit for the self-test features of the GE NUMAC PRNM equipment to reduce the administrative burdens, the manpower requirements and the risks of spurious trips associated with more frequent surveillances. Testing of the RPS scram contactors is performed by a weekly functional test of t the 2/4 voter trip output. For the APRM High~ Flux (15 f percent) scram function, application of new Note 9, Table 4.1.A, is consistent with the recommendations of reference 2; the wording is consistent with a similar change proposed in TVA-BFN-TS-355, reference 10. New requirements for functional testing of the 2/4 voter trip logic, described in new Note 10, Table 4.1.A, are consistent with the recommendations in reference 2.

APRM functional testing " group" assignments are deleted [

because the existing Bases discussions of these " groups !

will no longer apply for testing of the NUMAC APRM  :

equipment. New, separate discussions of the basis for  !

APRM surveillance requirements are added into the I appropriate TS Bases sections.  !

Because the proposed modification deletes separate flow i bias networks by integrating all of the flow-related l l

i El-22 i

1 logic into the APRM/RBM chassis, there are no longer separate operability or surveillance requirements associated with the APRM flow bias function. All of these functions are tested as part of the APRM/RBM functional tests and calibrations. Thus, most ,

requirements previously associated with separate APRM  !

flow bias networks are deleted. A requirement for once per cycle calibration of the flow bias signal is  ;

retained in Table 4.1.B, consistent with recommendations  :

of reference 2.

Bases sections and various notes applicable to the RPS instrumentation are changed to properly reflect details of the proposed NUMAC hardware. Changes 8, 9 and 13 provide new details consistent with the proposed configuration and requirements for the NUMAC APRM '

equipment. Changes 10, and 11 adjust existing TS Bases descriptions consistent with the proposed APRM configuration and functional changes.

The control rod block operability and surveillance requirements for APRMs and RBMs are changed consistent with the proposed new APRM/RBM hardware configuration.

Reason for the changes are, in general, similar to the reasons for changes in the requirements for APRM scram trip functions described above.

The minimum required number of APRM rod block trip channels is changed from "4" to "3" consistent with the proposed capability to bypass one of the four APRM instrument channels. As noted in reference 2, a minimum of only two APRM rod block trip channels is needed.

Functional and surveillance requirements for Flow Bias i Comparator and Flow Bias Upscale are deleted, consistent with recommendations of reference 2.

Bases sections and various notes for the Control Rod Block Instrumentation are changed to properly describe the configuration and features of the proposed NUMAC PRNM hardware.

All proposed TS changes described under Group B, above, are related to implementation of ARTS /MELLL improvements.

These changes are proposed concurrent with the NUMAC PRNM related changes because equipment design, interface and setpoint modifications required to implement these proposed TS changes will be included as part of the NUMAC PRNM design.

Implementation of the ARTS improvements requires modification of the RBM system. The proposed modification changes the RBM trip setpoints from flow-biased to power-biased values and reconfigures the LPRM inputs to the RBMs. '

These proposed changes are intended to eliminate El-23

limitations of the current RBM system, which was designed in the mid-1960s. Since that time there have been significant advances in the fields of two-phase heat transfer and electronics. The current RBM signals do not l always correlate well with thermal margin changes during control rod withdrawal, and the system performs its function only at the expense of significant operational i penalties due to excessive conservatism inherent in the design of the current system. The modified RBM system will provide improved correlation of RBM response with changes in fuel thermal margin and will enhance operator confidence in the system by reducing the frequency of nonessential rod blocks. The proposed changes will upgrade the performance of the RBM system and will provide new RBM setpoint and operability requirements such that the Rod Withdrawal Error j (RWE) will never be the limiting transient.

In addition to changes in the RBM system's configuration, setpoints and operability requirements, ARTS improvements eliminate the current TS requirement to lower (setdown) the flow-biased APRM scram and rod block trips when the Core Maximum Fraction of Limiting Power Density (CMFLPD) exceeds the Fraction of Rated Power (FRP). To support elimination l of this requirement, as well as to support the change to power-biased RBM setpoints, new power-dependent and flow-dependent fuel thermal limits are proposed to be j implemented. The proposed replacement of the current APRM l trip setdown requirement by more meaningful power- and flow-dependent thermal limits eliminates a need for manual setpoint adjustments and is anticipated to enhance administration of thermal limits compliance.

The proposed expansion of allowable operation to the MELLL region provides enhanced ability to achieve and maintain operation at rated power. Because rated power can be maintained with recirculation flow adjustments over a wider flow range, less frequent control rod adjustments are required to compensate for reactivity depletion, and the need for power reductions to perform control rod withdrawal is decreased. The plant will be able to operate longer at rated power, will have more flexibility to schedule load reductions and will be able to operate in a more efficient l and economical manner.

The reasons for the various individual proposed TS changes described in Group B are as follows:

The TS " Definitions" section is revised to delete '

definitions for Core Maximum Fraction of Limiting Power Density (CMFLPD) and Core Maximum Fraction of Critical Power (CMFCP). These definitions are no longer needed because the LCOs and SRs which use these definitions are deleted as part of the proposed change.

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l The LSSS APRM flow-biased setpoint equation is changed.

This change is needed to support operation in the MELLL region by providing adequate operating margin between boundaries of the MELLL region and the flow biased APRM scram. Figure 2.1-2 is revised to show the revised APRM flow-biased setpoint. The APRM flow-biased rod block setpoint, in the Core Operating Limits Report (COLR),

will also be revised as part of the proposed change.

A note in LSSS 2.1.A.1.b is deleted because the referenced LCO section (4. 5. L) is deleted as part of the proposed change.

The LSSS Bases Section 2.1.L is revised to add a new reference to GE's ARTS /MELLL analysis for BFN which forms the analytical basis for the proposed changes.

In Bases Section 4.1 a reference to "CMFLPD" is deleted, consistent with its deletion from definitions, LCOs and SRs.

Table 3.2.C for Control Rod Block Instrumentation, is revised to reflect the change from flow-biased to power-biased RBM setpoints. As discussed in reference'3, the change to power-biased RBM setpoints improves the correlation of RBM rod blocks with available thermal margin. At low core power levels where thermal margins are high, long rod withdrawals are permitted; while at high core powers where thermal margins are relatively low, only short rod withdrawals are allowec.. The new RBM Upscale power-biased setpoints apply over three power ranges, low, intermediate and high. These three power-range-dependent upscale trip functions are listed under the existing RBM Upscale trip function heading.

The existing flow-biased RBM setpoints are provided in the COLR. Note 13 for Table 3.2.C is revised to say that the proposed power-biased RBM Upscale trip function setpoints and applicable power ranges will be provided in the COLR. New Note 14 to Table 3.2.C is provided to specify that the RBM Upscale Trip Level Settings must be less than or equal to the setpoint allowable values provided in the COLR. The RBM Downscale Trip Level setpoint value is replaced by a new Note 15, which [

requires that the Downscale Trip Level Setting be greater than or equal to the setpoint allowable value provided in the COLR. This proposed change results in all RBM setpoints being located in the COLR.

Note 7 for Table 3.2.C is revised to add new conditions of reactor thermal power and MCPR where operability of the RBM is not required. This requirement is consistent l with the discussion in Section 10.5 of reference 3. '

In Table 4.2.C the RBM Upscale function description is El-25 l

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revised to reflect the change from flow-biased to power-biased setpoints.

In the " Reactivity Control" section of TS, the proposed change deletes LCO 3.3.B.5, SR 4.3.B.5, and Bases Section 3.3/4.3-B.5. The deleted LCO is, in effect, an additional RBM operability requirement. The requirement was instituted as part.of an earlier revision of flow-biased RBM setpoint values. With the proposed implementation of power-biased RBM setpoints, this additional requirement on RBM is overly restrictive and is not required by the ARTS analysis. Deleting the requirement provides more operational flexibility by allowing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to repair a single failed RBM channel, and it consolidates all RBM operability requirements in LCO Table 3.2.C and associated notes.

s LCO 3.5.I is revised to reflect the proposed implementation of flow-dependent and power-dependent APLHGR limits. LCO 3.5.K is revised to reflect the proposed implementation of flow-dependent and power-dependent operating MCPR limits. SR 5.4.K.2 is revised to reflect the proposed LCO change. Bases Sections 3.5.I and 3.5.K are revised to add new discussions of the proposed flow-dependent and power-dependent APLHGR and MCPR limits. As discussed in reference 3, implementation of these flow- and power-dependent thermal limits permits more direct administration of thermal limits compliance and supports deletion of the APRM setpoint setdown requirement.

LCO 3.5.L (the APRM setpoint setdown requirement) and I associated SR and Bases sections are deleted as justified by the evaluation in Section 5.3 of reference 3. The proposed deletion of-this LCO '

eliminates the need to make APRM setpoint adjustments under certain conditions. Eliminating this requirement reduces administrative and manpower burdens and eliminates the risks of spurious trips associated with the previously required APRM setpoint adjustments.

In TS Section 6.9.1.7 the description of the Core Operating Limits Report is changed to reflect the proposed change to flow- and power-dependent APLHGR and MCPR operating limits, the proposed elimination of the APRM setpoint setdown requirement, and the proposed changes from flow-biased to power-biased RBM setpoints.

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III. SAFETY ANALYSIS Group A Chances: These proposed TS changes are all associated with replacement of the existing power range neutron monitoring system with a GE digital NUMAC PRNM retrofit design. The NRC has separately received and is reviewing a " generic" licensing topical report (reference 2) which provides detailed information needed to perform a licensing review and safety evaluation of the planned NUMAC PRNM retrofit. Reference 2 provides descriptions, discussions and data which are applicable for all GE NUMAC PRNM retrofit designs. Reference 2 also identifies specific utility actions required in order to take credit of the evaluations provided in reference 2.

Attachment 2 of this enclosure provides TVA's responses to the utility actions required by reference 2. Evaluations of the proposed TS changes are summarized below:

For the functions addressed by the proposed TS change, the NUMAC PRNM has the same design basis requirements as the original power range neutron monitoring system. The original system was designed to meet IEEE 279-1971 compliance; therefore the requirements of this standard apply to the replacement design. In addition, USNRC Reg. Guide 1.152 -1985 is applied as a requirement, and reference 2 includes a " compliance matrix" that correlates the requirements of the Reg. Guide to the NUMAC PRNM implementing program. Section 4 of reference 2 further discusses the design bases and regulatory requirements applicable for the NUMAC PRNM system.

All previous ARPM upscale scram trips are retained in the new design. The proposed design and related LCOs permit one APRM instrument channel to be bypassed at any time for maintenance or testing while retaining the ability to withstand single failure of one of the remaining instrument channels. However, because of requirements to meet single failure criteria, bypass of any 2/4 voter is not permitted. LCO action times and required actions for fewer than the required number of APRM trip functions or 2/4 voter functions are consistent with what has been previously approved for Standard Technical Specifications.

The proposed TS change deletes the previous requirement for APRM operability in Refuel mode. In eliminating the APRM operability requirement in Refuel mode, the proposed TS change makes explicit the requirement to enable the SRM high flux scram function under appropriate conditions in the Refuel mode. The proposed change also deletes the previously required APRM downscale scram trip in the Run mode. No postulated event takes credit for this downscale trip, and eliminating the logic for the trip reduces the potential El-27 I

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for spurious acrams in testing, maintenance or operation.

i The proposed TS change extends required surveillance intervals of the APRM and RBM equipment to the maximum periods supported by reference 2. This reduction in i surveillance frequency is supported by the increased reliability and the extensive self-test capability of i the new hardware. Testing of the RPS scram contactors via the APRM system is retained and is performed by weekly testing of the 2/4 voter trip output function.

Extending APRM surveillance intervals reduces the potential for spurious trips while testing is being performed, thus enhancing the overall reliability of plant operations.

Group B Chances: These proposed TS changes are all associated with implementing ARTS improvements and with extending operation to the MELLL region of the power / flow map. The NRC has previously approved implementation of ARTS /MELLL changes at other BWRs (references 4, 5, 6 and 7) and has also approved extension of BFN's original operating region to the Extended Load Line Limit (ELLL) region (references 8 and 9).

Reference 3 documents results of analyses and evaluations performed for BFN by GE to support the proposed ARTS /MELLL changes. Appendix A of reference 3 discusses major -

features of the modified RBM system, and Section 10 of reference 3 provides an in-depth discussion of the RBM system evaluation and requirements to support the ARTS improvement. Sections 4 and 5 of reference 3 provide a description of APRM improvements and a detailed discussion of the new power- and flow-dependent thermal limits which support elimination of the previous APRM setpoint setdown requirement. Reference 3 provides documentation of extensive analyses of operation in the MELLL region performed for BFN based on the Unit 2, Cycle 8 fuel schedule.

The safety and system evaluations documented in reference 3 to justify the safety of operation in the MELLL region consist of two portions, the portion which is not fuel-dependent, and the portion that is fuel dependent and ,

therefore fuel cycle dependent. In general, the limiting anticipated operational occurrences (AOOs) MCPR calculation and the reactor vessel overpressure protection analysis are fuel cycle dependent. These analyses as presented in reference 3 are based on BFN Unit 2, Cycle 8, refueling schedules at the current rated core thermal power of 3293 MWt. For non-fuel dependent evaluations such as containment responses, an uprated power level of 3458 MWt (105% of the current rated core thermal power) is used.

The non-fuel dependent evaluations are mostly based on >

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f hardware design, geometries, and system performance which are similar among the BFN units. Thus, these non-fuel dependent evaluation are considered applicable to BFN Units 1, 2 and 3 for MELLL region operation.

Evaluations of the proposed TS changes associated with ARTS /MELLL implementation are summarized below:

The proposed TS change revises the flow-biased APRM scram setpoint from Ss(0.58W+62%) to Ss(0.66W+71%). The flow-biased APRM scram setpoint maximum (clamped) value of 120% does not change. The proposed change revises Figure 2.1-2 to show the proposed flow-biased APRM scram setpoint. In addition, the flow-biased APRM rod block setpoints documented in the COLR will be changed. These changes incorporate new setpoints for the flow-biased APRM scram and rod block functions based on the MELLL analysis documented in reference 3. The TS setpoints are allowable values consistent with the analytical limits presented in reference 3. These setpoint allowable values are documented in calculations performed for BFN by GE and are based on the proposed configuration of NUMAC PPJGIM equipment.

For original plant operation with the maximum load line limited to the rated rod line, the setpoint for the flow-biased APRM scram line was Ss(0.66W+54%). With the first expansion of the power / flow map to allow operation up to the 108% rod line (references 8 and 9), the flow-biased APRM flux scram line was modified to Ss (0. 58W+62%) . With the proposed expansion of the power / flow map to include the MELLL region depicted in Figure 2-1 of reference 3, the upper boundary of the analyzed operating domain is further extended to the 121% rod line. The proposed change in flow-biased APRM setpoints maximizes plant operating flexibility, restores the slopes of the flow-biased APRM scram and rod block setpoints to their original design basis values, and restores the original design basis operating margin between the maximum extended load line and the APRM flow-biased scram setpoint.

The purpose of the flow-biased APRM rod block is to block control rod withdrawal when core power exceeds design bases and approaches the scram level. Should operation continue in a manner such that the power / flow condition exceeds that specified by the ARPM rod block setpoint, the flow-biased APRM scram trip setpoint would initiate a scram. Credit for the flow-biased APRM rod block or scram is not taken in analysis of any design basis event.

The proposed TS change revises LCO Table 3.2.C to reflect the change from flow-biased to power-biased RBM El-29

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setpoints. The RBM system is explicitly designed to mitigate the consequences of the rod withdrawal error (RWE) event and is not assumed The current to be available RBM system to mitigate any other AOOs.

configuration The is described in detail in Section 10 of modified RBM system configuration is reference 3.

described in Section 10 and Appendix A of reference 3.

The modified RBM system uses advances in electronics to enhance instrumentation accuracy and improve the signal to thermal margin correlation. The RBM modifications incorporate power-biased setpoints and provide a system response which more accurately reflects the actual margin to the safety limit at various power conditions.

Coincident with the analyses of the modified RBM system, a generic RWE approach was taken such that neither the safety limit MCPR nor the fuel thermal-mechanical design basis is jeopardized. This approach included determining appropriate MCPR requirements and corresponding RBM power dependent setpoints forBy the modified RBM system for current fuel designs. the RWE will not appropriate selection of the setpoints, be the limiting event and will not determine the In this respect, the RBM operating limit MCPR.

setpoints are dependent upon the operating limit values which depend on the cycle-specific conditions; thus the setpoint values are proposed to be documented in the COLR. Using an MCPR operating limit of 1.25 and setpoint calculations applicable for the proposed configuration, the power-biased RBM setpoints and applicable reactor thermal power (RTP) ranges are as follows:

28% and < 63%;

Low Trip Setpoint $118.5% for RTP 3 63% and < 83%;

Intermediate Trip Setpoint 5113.7% for RTP 1 High Trip Setpoint $108.7% for RTP 2 81% and s 100%; and Downscale Trip Setpoint 289%/125% for RTP 2 28% and s 100%.

The proposed TS change revises Note 7 for Table 3.2.C to specify RTP and MCPR conditions where operability of the RBM system is not required. Section 10.5 of reference 3 documents that with RTP 2 90% and operating 1.70,MCPR 21.40, withdrawal or with RTP < 90% and operating MCPR 2 of any single control rod from the full-in to the full-in violation of the MCPR out position will not resultThus, under these conditions the RBM safety limit.

system is not required to function in order to assure that an RWE has acceptable results.

The proposed TS change deletes LCO/SR 3.3/4.3.3.5 These and revises the Bases to reflect this change.

specifications are, in effect, additional requirements l El-30

setpoints. The RBM system is explicitly designed to mitigate the consequences of the rod withdrawal error (RWE) event and is not assumed to be available to mitigate any other AOOs. The current'RBM system )

configuration is described in detail in Section 10 of reference 3. The modified RBM system configuration is described in Section 10 and Appendix A of reference 3.

The modified RBM system uses advances in electronics to f- enhance instrumentation accuracy and improve the signal to thermal margin correlation. The RBM modifications incorporate power-biased setpoints and provide a system response which more accurately reflects the actual L margin to the safety limit at various power conditions. 1 Coincident with the analyses of the modified RBM system, l l q l a generic RWE approach was taken such that neither the '

l safety limit MCPR nor the fuel thermal-mechanical design l basis is jeopardized. This approach included determining appropriate MCPR requirements and corresponding RBM power dependent setpoints for the modified RBM system for current fuel designs. By I appropriate selection of the setpoints, the RWE will not {

be the limiting event and will not determine the i operating limit MCPR. In this respect, the RBM setpoints are dependent upon the operating limit values i

which depend on the cycle-specific conditions; thus the l setpoint values are proposed to be documented in the COLR. Using an MCPR operating limit of 1.25 and setpoint calculations applicable for the proposed configuration, the power-biased RBM setpoints and applicable reactor thermal power (RTP) ranges are as follows:

Low Trip Setpoint s118.5% for RTP 2 28% and < 63%;

Intermediate Trip Setpoint s113.7% for RTP 263% and < 83%;

High Trip Setpoint $108.7% for RTP 2 81% and 5 100%; and Downscale Trip Setpoint 289%/125% for RTP 2 28% and 5 100%.

The proposed TS change revises Note 7 for Table 3.2.C to specify RTP and MCPR conditions where operability of the RBM system is not required. Section 10.5 of reference 3 documents that with RTP 2 90% and operating MCPR 21.40, or with RTP < 90% and operating MCPR 21.70, withdrawal of any single control rod from the full-in to the full-out position will not result in violation of the MCPR safety limit. Thus, under these conditions the RBM system is not required to function in order to assure that an RWE has acceptable results.

The proposed TS change deletes LCO/SR 3.3/4.3.B.5 and revises the Bases to reflect this change. These specifications are, in effect, additional requirements El-30

on the RBM system to require both RBM channels operable or block control rod withdrawal when within 5% of thermal limits. This additional RBM specification is not required by the ARTS analyses documented in reference 3. The proposed RBM LCOs in Table 3.2.C permit rod withdrawal only for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with one RBM channel inoperable (or bypassed) when operability of the RBM system is required. This LCO action time is consistent with Standard TS requirements, and the added constraint of LCO/SR 3.3/4.3.B.5 is not necessary.

The proposed TS change deletes the flow-biased APRM scram and rod block setpoint setdown requirement (LCO 3.5.L); and it implements flow- and power-dependent thermal limits by revising LCO 3.5.I and LCO/SR 3.5.K to reflect the change to flow- and power-dependent APLHGR and MCPR limits. Related Bases sections are revised to reflect deletion of LCO 3.5.L and to include discussion of this new treatment of thermal limits. The proposed change eliminates the requirement for setdown of the flow-biased APRM scram and rod block trip setpoints when the CMFLPD is greater than the FRP and substitutes adjustments to the rated MCPR and APLHGR operating limits that are flow and power dependent. Reference 3 documents results of analyses to justify implementation of flow- and power-dependent APLHGR and MCPR operating limits and elimination of the flow-biases APRM setpoint setdown requirement. Analyses documented in reference 3 demonstrate that with the setpoint setdown requirement eliminated and flow- and power-dependent thermal limits implemented 1) MCPR safety limit will not be violated as a result of any AOOs, 2) all fuel thermal-mechanical design bases will remain within the licensing limits described in the GE generic fuel licensing report GESTAR-II, and 3) peak cladding temperature and maximum cladding oxidation fraction following a LOCA will remain within the limits defined in 10CFR50.46.

The proposed TS change revises the description of the Core Operating Limits Report (COLR). The COLR already included the APLHGR and MCPR operating limits and the RBM trip setpoints. The proposed change to the COLR description is an administrative revision to reflect the changes in these limits and setpoints as described )

above.

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IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3 in accordance with the proposed change to the technical specifications 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) .

1. The proposed amendment does not involve a sianificant increase in the probability or consecuences of an accident previousiv evaluated.

Group A Chances: This proposed TS change is associated with the NUMAC PRNM retrofit design. The proposed TS change involves modification of the LCOs and SRs for equipment designed to mitigate events which result in power increase transients. For the APRM system mitigative action is to block control rod withdrawal or initiate a reactor scram which terminates the power increase when setpoints are exceeded. For the RBM system mitigative action is to block continuous control rod withdrawal prior to exceeding the MCPR safety limit during a postulated Rod Withdrawal Error. The worst case failure of either the APRM or the RBM systems is failure to initiate mitigative action (failure to scram or block rod withdrawal). Failure to initiate mitigative action will not increase the probability of an accident. Thus, the proposed change does not increase the probability of an accident previously evaluated.

For the APRM and the RBM systems, the NUMAC PRNM design, together with revised operability requirements (LCOs) and revised testing requirements (SRs), results in equipment which continues to perform the same mitigation functions under identical conditions with reliability equal to or greater than the equipment which it replaces. Because there is no change in mitigation functions and because reliability of the functions is maintained, the proposed change does not involve an increase in the consequences of an accident previously evaluated.

Group B Chances: This proposed change is associated with implementation of the ARTS /MELLL analysis. The proposed change will permit expansion of the current allowable power / flow operating region and will apply a new methodology for assuring that fuel thermal and '

mechanical design limits are satisfied. Reference 3 evaluates operation in the MELLL region with assumed implementation of the ARTS changes. The conclusion of reference 3 is that for all events and parameters El-32 '

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4 considered there is adequate design margin for operation in the MELLL region. Because operation in~ l the MELLL~ region maintains adequate design margin, the  ;

proposed change does not significantly increase the probability of an accident previously evaluated.

In support of operation in the MELLL region, the proposed change modifies flow-biased APRM scram and rod i block setpoints and implements new RBM power-biased  :

setpoints. This potentially changes the way in which ,

the APRM and RBM systems, perform their mitigation ,

functions. However, no credit for the flow-biased APRM scram or rod block is taken in mitigation of any design  !

basis event; thus, changing the APRM setpoints does not  ;

impact the consequences of any accident previously evaluated. The proposed changes to the RBM system potentially impact mitigation of the RWE. However, per discussion in reference 3, the proposed RBM changes will assure that the RWE is not a limiting event; thus, the consequences of the RWE are not increased. The proposed change does not increase the consequences of '

an accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident I previously evaluated.

The proposed changes (Group A and Group B) involve i modification and replacement of the existing power  ;

range neutron monitoring equipment, modification of the setpoints and operational requirements for the APRM and -

RBM systems, implementation of a new methodology for '

administering compliance with fuel thermal limits, and i operation in an extended power / flow domain. These proposed changes do not modify the basic functional l requirements of the affected equipment, create any new  !

system interfaces or interactions, nor create any new system failure modes or sequence of events that could lead to an accident. The worst case failure of the affected equipment is failure to perform a mitigation action, and failure of this mitigative equipment does ,

not create the possibility of a new or different kind of accident. The proposed change does not create the  !

possibility of a new or different kind of accident from any accident previously evaluated. '

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i The proposed amendment does not involve a sienificant 3.

l

' reduction in a marcin of safety.

Group A Chances: This proposed TS change is associated with the NUMAC PRNM retrofit design. The NUMAC PRNM change does not impact reactor operating parameters nor the functional requirements of the power range neutron The replacement equipment continues monitoring system.

enforce control rod blocks and to provide information, initiate reactor scrams under appropriate specified conditions. The proposed change does not revise any The replacement APRM/RBM safety margin requirements.

equipment has improved channel trip accuracy compared to the current system and meets or exceeds system requirements previously assumed in setpoint analysis.

Thus, the ability of the new equipment to enforce compliance with margins of safety equals or exceeds The the ability of the equipment which it replaces. involve a reduction in a proposed change does not margin of safety Groun B Chances:

This proposed change is associated with implementation of recommendations presented in the Operation in the MELLL region ARTS /MELLL analysis.does not affect the ability of northe plant safety-related does trips or equipment to perform their functions, increase in offsite radiation it cause any significant Analyses doses resulting from any analyzed event.

documented in reference 3 demonstrate that for operation in the MELLL region adequateofmargin Implementation to design the ARTS limits is maintained.

improvements provides flow- and power-dependent thermal limits which maintain existing margins of safety in normal operation, anticipated operational occurrences Implementation of power-biased and accident events.

RBM setpoints improves the margin of safety in a postulated RWE by assuring that the RWE is notinvolve a a limiting event. The proposed change does not significant reduction in a margin of safety.

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3. The crocosed amendment does not involve a sianificant j E reduction in a maroin of safety. +

Grouc A Chances: This proposed TS change is associated with the NUMAC PRNM retrofit._ design. The NUMAC.PRNM  ;

change does not impact reactor operating parameters'nor the functional requirements of.the power range neutron

. monitoring system. The replacement equipment continues- !

to provide information, enforce: control rod blocks and ,

-initiate reactor scrams under appropriate specified l conditions. The proposed change does not revise any i safety margin requirements. The replacement APRM/RBM equipment has improved channel trip accuracy compared to the currentLsystem and meets or exceeds system requirements previously assumed in setpoint analysis.

Thus, the ability of the new equipment to enforce ,

compliance with margins of safety equals or exceeds the ability of the equipment which it replaces. The '

proposed change does not involve a reduction in a margin of safety Groun B chances: This proposed change is associated with implementation of recommendations presented in the  ;

ARTS /MELLL analysis. Operation in the MELLL region does not affect the ability of the plant safety-related i trips or equipment to perform their functions, nor does it cause any significant increase in offsite radiation doses resulting from any analyzed event. Analyses  :

documented in reference 3 demonstrate that for operation in the MELLL region adequate margin to design j limits is maintained. Implementation of the ARTS l improvements provides flow- and power-dependent thermal i limits which maintain existing margins of safety in  !

normal operation, anticipated operational occurrences.  !

and accident. events. Implementation of power-biased  !

RBM setpoints improves the margin of safety in a postulated RWE by assuring that the RWE is not a  :

limiting event. The proposed change does not involve a

• significant reduction in a margin of safety.  !

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.V.. ENVIRONMENTAL IMPACT CONSIDERATION r The. proposed change does not involve a significant hazards  ;

consideration, a significant change in the types of'or  ;

significant increase in the amounts of any effluents that i may be-released offsite, or a significant increase in  ;

individual or cumulative occupational radiation exposure. r Therefore, the proposed change meets the eligibility  :

criteria for categorical exclusion set forth in 10 CFR l 51.22 (c) (9) . Therefore, pursuant to 10 CFR 51.22 (b) , an  !

environmental assessment of the proposed change is not t required. ,

VI. REFERENCES

1. TVA letter to NRC, dated September 8, 1994, Response to

~

NRC Generic Letter (GL) 94 Long-Term Solutions and  !

Upgrade of Interim Operating Recommendations for Thermal  ;

Hydraulic Instabilities in Boiling Water Reactors.

2. Licensing Topical Report, Nuclear Measurement Analysis -

And Control Power Range Neutron Monitor (NUMAC PRNM) i Retrofit Plus Option III Stability Trip Function, .

Volumes 1 and 2, NEDC-32410P, March 1995.

3. GE Report, Maximum Extended Load Line Limit and. ARTS Improvement Program Analyses for Browns Ferry. Nuclear i Plant Unit 1, 2 and 3, NEDC-32433P (Attachment 1).  ;

4. Letter from NRC to Carolina Power & Light Company, dated  ;

October 23, 1990, Issuance of Amendment No. 147 to.

Facility Operating License No. DPR-71 Regarding Maximum }

Extended Operating Domain. l

5. Letter from NRC to Carolina Power & Light Company, dated ,

October 12, 1989, Issuance of Amendment No. 168 to  ;

Facility Operating License No. DPR-62 Regarding Maximum j Extended Operating Domain.  :

6. Letter from NRC to Detroit Edison Company, dated May 15, l 1991, Amendment No. 69 to Facility Operating License No. i I

NPF-43.

7. Letter from NRC to PECO Energy Company, dated August 10, i 1994, Expanded Operating Domain (ARTS /MELLLA) Technical  !

Specifications, Peach Bottom Atomic Power Station, Unit 2 (TAC No. M86132). l i

i i

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8. Letter from NRC to TVA, dated December 18, 1990, Issuance of Amendment (TAC No. 76934) (TS 285) [ Extended Load Line Limit Analysis - Amendment 181 to BFN Unit 2 Technical Specifications]

9. Letter from NRC to TVA, dated February 24, 1995, Issuance of Technical Specification Amendment for the Browns Ferry Nuclear Plant Units 1, 2 and 3 (TAC Nos.

M89251, M89252, and M89253) (TS 339) [ Extended Load Line Limit and Revised Rod Block Monitor Operability Requirements (Units 1 and 3) ; Deletion of Specific Values.... (Units 1, 2, and 3)]

10. Letter from TVA to NRC, dated January 4, 1995, Browns Ferry Nuclear Plant (BFN) - Units 1, 2 and 3 - Technical Specification (TS) No. 355 - Reactor Protection System TS Requirements for Intermediate Range Monitor (IRM) and Average Power Range Monitor Trip Functions (APRM).

I 1

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Enclosure 1  !

l, ATTACIIMENT 2 '

Plant-Specific Information Required for NUMAC PRNM Retrofit l I

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Plant-Specific Information Required for NUMAC PRNM Retrofit Section No. Utility Action Required Response 2.3.4 Confirm that the actual plant configuration is included The actual, current plant configuration and the in the variations covered in the Power Range Neutron proposed replacement PRNM are included in the Monitor (PRNM) Licensing Topical Report (LTR) PRNM LTR as follows: (Applicable LTR sections are

[NEDC-32410P], and the configuration ahernative(s) listed.)

being applied for the replacerrant PRNM are covered by the PRNM LTR. Document in the plant specific Current Prooosed licensing submitral for the PRNM project the actual, APRMs 2.3.3.1.1.2 2.3.3.1.2.2 current plant cor, figuration of the replacement PRNM, RBM 2.3.3.2.1.1 2.3.3.2.2.1 and document confirmation that those are covered by Flow Units 2.3.3.3.1.1 2.3.3.3.2.2 the PRNM LTR. Rod Cntri. 2.3.3.4.1.1 2.3.3.4.2.1 ARTS 2.3.3.5.1.2 2.3.3.5.2.1 Panel Inter. 2.3.3.6.1.1 2.3.3.6.2.1 For any cht.,ges to the plant operator's panel, document m the submittal the human factors review actions that lluman Factors Engineering review will be performed were taken to confirm compatibility with existing plant as part of the normal design change process.

commitments and procedures.

3.4 As part of the plant specifie licensing submittal, the 1) The current flow channel configuration consists of utility should document the following: two flow channels, four transmitters (3.2.3.1.1).

The post modification configuration will be four

1) The pre-modification flow channel configuration, and flow channels, eight transmitters (3/L3.2.2). Four any changes planned. transmitters which meet or exceed rcquirements of

2) Document the APRM trips currently applied at the the Note in PRNM LTR Section 3.4 will be added.

plant. If different from those documented in the 2) APRM trips currently at the plant are the same as PRNM LTR, document plans to change to those in those identified in PRNM LTR Sections 3.2.4, the LTR. 3.2.5, 3.2.6 and 3.2.7.

3) Document the current status related to ARTS and the 3) ARTS currently is not inclemented. ARTS will be planned post modification status. implemented concurrently with the PRNM. Tech spec changes proposed in support of ARTS are included in the PRNM submittal.

4.4.1.11 The PRNM LTR identifies requirements that are Review of applicable BFN general and system design expected to encompass most specific plant commitments criteria documents confirms that BFN's relative to the PRNM replacement project. The utility requirements / commitments for the replacement PRNM must confirm that the requirements identified in the are consistent with the requirements described in PRNM LTR address all of those identified in plant Section 4.4 of the PRNM LTR. As part of the normal specific commitments. The plant specific licensing design process, applicable system design criteria submittal should identify the specific requirements documents will be revised to appropriately reflect the applicable for the plant, confirm that any clarifications proposed modifications in APRM and RBM hardware included in the PRNM LTR apply to the plant, and configuration.

document the specific requirements that the replacement PRNM is intended to meet.

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I Plant-Specific Informatim Required for NUMAC PRNM Retrafit Section Utility Action Required Response 4.4.2.2.1.4 Plant specific action will confirin that the maximum The PRNM control room electronics is qualified for control room temperatures plus mounting panel continuous operation under the following temperature temperature rise, allowing for heat load of the PRNM conditiens: 5 to 50 *C [41 to 122 'F]. Normal control equipment, does not exceed the temperatures presented roo n temperature is 76 'F, and maximum abnormal in the PRNM LTR, and that control room humidity is temperature is 104 'F. Thus, allowing for any i maintained within the limits stated in the PRNM LTR. temperature differences between the ambient room and l Documentation of the above action, including the the mounting panels plus reasonable heat loads l specific method used for the required confirmation expected of the PRNM equipment, the PRNM control should be included in plant specific licensing room electronics is expected to be within the qualified submittals. range. Measurements and/or calculations will be completed during the design process to confirm that the PRNM temperature environment is within the qualified range.

The PRNM control room electronics is qualified for continuous operation under the following relative humidity conditions: 10 to 90% (non-condensing).

Normal control room relative humidity is in the range of 40% to 60%, which is well within the range for which the PRNM equipment is qualified.

4.4.2..'.2.4 Plant specific action will confirm that the maximum The PRNM control room electronics is qualified for control room pressure does not exceed the limits continuous operatien under the following pressure presented in the PRNM LTR. Documentation of this conditions: Maximum (above ambient) = 1.0

• of action and the required confirmation should be included water and Minimum (below ambient) = -1.0* of in plant specific licensing submittals. water. Normal control room pressure is maintained between 0.125' and approximately 0.5" of water which is within the qualified pressure range.

4.4.2.2.3.4 Plant specific action will confirm that the maximum The PRNM control room electronics is qualified for control room radiation levels do not exceed the limits continuous operation under the following conditions:

stated in the PRNM LTR. Documentation of this action Dose Rate 1001 Rads (carbon)/hr and Total Integ ated and the required confirmation should be included in Dose (TID)11000 Rads (carbon). The BFN control plant specific licensing submittals. room dose rates and TID are within the qualified ranges.

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1 Plant-Specific Information Required for NUMAC PRNM Retrcfit Section Utility Action Required Response j 4.4.2.3.4 Plant specific action or analysis will confirm that the Evaluations to confirm that the maximum seismic maximum seismic accelerations at the mounting accelerations at the mounting locations of the locations of the equipment (control room floor equipment do not exceed qualification limits of the acceleration plus panel amplification) do not exceed the equipment will be completed as part of the normal ,

limits stated in the PRNM LTR. Documentation of this design change process. i action and the required confirmation should be included in plant specific licensing submittals.

4.4.2.4.4 With regard to electromagnetic interference (EMI), the TVA has previously provided information to the NRC utility will establish or document practices to control by letter dated December 23,1993, Browns Ferry emission sources, maintain good grounding practices Nuclear Plaat (BFN) Units 1,2 and 3 - Reply to NRC and maintain equipment and cable separation. The Request to Provide Results of BFN Electromagnetic plant specific licensing submittals should identify the Interference / Radio Frequency Interference (EMI/RFI) practices that are in place or will be applied for the Tests and On-Site Surveys for the Reactor Building PRNM modification to address each of the above items. Ventilation Radiation Monitoring System (TAC Nos. ,

M84161, M84162 and M84163). Based on the previously provided test results, the BFN environment satisfies the conditions and limitations defined in EPRI TI-102323 and is within the qualification envelope of the PRNM equipment. ,

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Pl nt-Specific Information Required for NUMAC PRNM R:trofit Section Utility Action Required Response 6.6 The utility must confirm applicability of the failure a) Events analyzed for BFN in which credit for the analysis conclusions contained in the PRNM LTR by APRM scram function is taken, as documented in the following actions. (These confirmations and the Final Safety Analysis Report and the Safe conclusions should be documented in the plant specific Shutdown Analysis, are encompassed by the events licensing submittal for the PRNM modification.) listed in Reference 11, Appendices F and G.

a) Confirm that the events defined in EPRI report No. b) The proposed PRNM configuration is included NP-2230 or in Appendices F and G. Reference 11 of among the configurations described in the PRNM the PRNM LTR, encompass the events that are LTR, as itemized under Section 2.3.4, above. The  ;

analyzed for the plant; proposed configuration is being designed by GE and b) Confirm that the configuration implemented by is within the limits described in the LTR.

the plant is within the limits described in the LTR; and c) A plat,t specific 10CFR50.59 evaluation of the c) Prepare a plant specific 10CFR50.59 evaluation of proposed modiGcation will be prepared and approved the modification per the applicable plant procedures, as part of the normal design process. .

[ Reference 11 of the LTR is NEDC-30851P-A,

" Technical Specification Improvement Analysis for BWR Reactor Protection system," dated March 1988.]

7.6 The plant specific action required for FSAR updates Applicable sections of the FSAR will be reviewed and will vary between plants. In all cases, however, appropriate revisions of those sections will be prepared existing FSAR documents should be reviewed to and approved as part of the normal design process.

identify areas that have descriptions specific to the Following implementation of the design modification, current PRNM using the general guidance of and closure of the design package, the FSAR revisions paragraphs 7.2 through 7.5 of the PRNM LTR to will be submitted to the NRC and included in the identify potential areas impacted. The utility should updated FSAR as part of the routine FSAR ur sate include in the plant specific licensing submittal a submittal.

statement of the plans for updating the plant FSAR for the PRNM project.

1 8.3.1.4 Utility actions necessary to implement technical a) The proposed technical specification changes include specification changes to APRM RPS Trip Function: deleting the APRM Downscale Trip, related SRs, setpoints, and Bases descriptions.

a) Delete the APRM Downscale Trip . . from the RPS b) BFN technical specifications do not include the Instrumentation

• function" table, the related "APRM Flow Biased Neutron Flux Upscale surveillance requirements and . . the related setpoint [ instantaneous) Trip" as this term is applied in the and the related descriptions in the bases sections. PRNM LTR. The flow biased APRM fiux scram b) Delete the APRM Flow Biased Neutron Flux trip in BFN TS LSSS 2.1.A.l.a and its maximum Upscale Trip if currently used, , related (clamped) value in LSSS 2.1.A.1.b include a surveillance requirements, . . setpoint, and . . bases nominal 6 second time delay representing the fuel sections. Replace these with the corresponding time constant and are comparable to the " Simulated entries for the APRM Simulated Thermal Power Thermal Power" trips as used in the PRNM LTR.

Upscale Trip and the APRM Neutron Flux Upscale The "APRM Neutron Flux Upscale [ instantaneous)

Trip. Perform analysis necessary to establish Trip" in the PRNM LTR is comparable to the setpoints for added trips. APRM fixed high neutron flux scram trip in BFN c) Add the APRM Neutron Flux Upscale, Setdown TS LSSS 2.1.A.I.d. BFN will continue to use its Trip, if not currently used, . . related surveillance current terminology. APRM setpoints have been requirements and . . related descriptions in the bases recalculated by GE and results of these calculations sections. Perform analysis necessary to establish are reficcted in the proposed TS changes. No other setpoints for added trips. change in this area is needed to satisfy requirements of the PRNM LTR.

c) The APRM Neutron Flux Upscale, Setdown Trip is in BFN's current TS in LSSS 2.1. A.2.a. No change is needed to satisfy requirements of the PRNM LTR.

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Plant-Specific Inf:rmati:n Required fer NUMAC PRNM Retr: fit Section Utility Action Required Response 8.3.2.4 Utility actions necessary to implement technical a) BFN's proposed TS changes include the items specification changes for the Minimum Operable described in the PRNM LTR. BFN's proposed RPS 2 APRM Channels: Instrumentation Requirements Table presents each APRM function and the 2/4 Voters as single line a) For the 4 APRM channel replacement configuration, item entries, consistent with BFN's current TS revise the RPS Instrumentation " function" table, format.

either by footnote or directly, to show 3 APRM channels si'ared by both trip systems and two 2-out- b) BFN's current action requirements for inoperable of-4 voter channels under the " minimum operable channels in both RPS logic system require action to channels" for each APRM function shown (after any be taken within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Per the PRNM LTR, the additions or deletions per PRNM LTR Paragraph APRM insturment channel and the 2/4 Voter 8.3.1.4). For plants with Tech Specs that include a instrument channel action requirements are changed footnote calling for removing shorting links, remove to reflect the 12-hour and 6-hour operation times for the references to the footnote related to APRM fewer than the minimum number of required (retain references for SRM and IRM) . , For smaller channels.

core plants, delete the notes for and references to special conditions related to loss of LPRMs from the c) This proposed TS change includes the items "other" APRM. described in the PRNM LTR.

b) Review action statements to see if changes are required. If the improvements documented in Reference 11 have not been implemented then changes will likely be required to implement the 12-hour and 6-hour operation times discussed above for fewer than the minimum required channels. If Improved Tech Specs are applied to the plant, action statements remain unchanged, c) Revise the Bases section as needed to replace the descriptions of the current 6 or 8 APRM channel systems and bypass capability with a corresponding description of the 4 APRM system,2-out-of-4 Voters (2 per RPS system), and allowed one APRM bypass total.

8.3.3.4 Utility actions necessary to implement technical a) The proposed BFN TS change implements the specification changes for APRM Applicable Modes of PRNM LTR requirements. This includes deleting Operation: application of the ARPM Upscale, Setdown Trip in the REFUEL mode.

a) APRM Neutron Flux Unscale. Setdown Trin.

Cha se Tech Spec " applicable modes" entry, if b) No change to BFN TS is required to implement the seguired, to be Mode 2 (startup). Delete references to PRNM LTR requirement.

Tctions and surveillance requirements associated with otner modes. Delete any references to notes c) No change to BFN TS is required to implement the issociated with "non-coincidence mode and correct PRNM LTR requirement.

no'es as required. Revise " bases" descriptions as regered. d) The proposed BFN TS change implements the b) APRid Simulated Thermal Unscale Trin. Retain as PRNM LTR requirements. This includes deleting is unless this function is being added.. application of the APRM Inop Trip in the REFUEL c) APRM Neutron Flux Unscale Trio. Retain as is mode.

unless th!s function is being added.. .

d) APRM inon Trin. Delete requirements for operation in modes other than Mode 1 and Mode 2 (run and start-up). Revise the " bases" descriptions as needed.

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PI:nt-Specific Informati n Required fcr NUMAC PRNM Retrofit Section Utility Action Required Response Utility actions necessary to implement technical specification changes for APRM Required Channel Check / Instrument Test:

Surveillances and Calibrations:

a) BFN TS currently require APRM channel checks 8.3.4.1.4 Channel Check / Instrument Test: (" instrument checks") daily per SR Table 4.2.C.

a) For plants without Channel Check requirements, add The proposed TS change does not revise this once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel check requirement for the requirement, three APRM trip functions. No Channel Check requirements are added for APRM inop Trip. b) The proposed TS change implements the b) For plants with 4 full recirculation flow channels and requirements described in the PRNM LTR.

with Tech Specs that call for daily or other channel check requirements for now comparisons under Channel Functional Test:

APRM Flow Biased Simulated Thermal Power Trip, delete those requirements. Move any note reference a) The proposed TS change implements the related to verification of How signal to Channel requirements described in the PRNM LTR.

Functional Test entry, b) The proposed TS change implements the 8.3.4.2.4 Channel Functional Test: requirements described in the PRNM LTR.

a) Delete existing channel functional test requirements and replace with a requirement for a Channel Channel Calibrations:

Functional Test frequency of each 184 days (6 months) [delet: any specific requirement related to a) The proposed TS change revises APRM channel start-up or shutdown except for the APRM Neutron calibration frequency to once per operating cycle.

Flux-Iligh (Setdown) function as noted in Paragraph Because operating cycles are anticipated to be no 8.3.4.2.2(1) of the PRNM LTR]. Add a notation greater than 24 months long, this is consistent with that both the APRM channels and the 2-out-of-4 the requirements described in the PRNM LTR.

Voter channels are to be included in the Channel Functional Test, b) The proposed TS change implements the b) Add a notation for the APRM Simulated Thermal requirements described in the PRNM LTR.

Power Upscale function that the test shall include the 8.3.4.3.4 recirculation How processing, excluding the Dow c) Current BFN TS require an APRM heat balance transmitters, calibration on a frequency of once/7 days (LCO Table 4.1.B). This is consistent with the Channel Calibrations: requirements described in the PRNM LTR.

a) Replace current calibration interval with either 18 or 24 months except for APRM Inop. Retain Inop d) The proposed TS change revises appropriate Bases requirement as is, sections.

b) Delete any requirement for flow calibration and calibration of the 6 second time constant separate Response Time Testinn:

from overall calibration of the APRM Simulated Thermal Power Upscale Trip. Current BFN TS do not require APRM response time c) Replace every 3 day frequency for calibration of testing. This is consistent with the requirements APRM against thermal power with a 7 day frequency described in the PRNM LTR.

8.8.4.4.4 if applicable.

d) Revise Bases text as required.

Response Time Testing:

Delete response time testing requirements for APRM functions.

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Plant-Specific Information Required for NUMAC PRNM Retrofit Section Utility Action Required Response 8.3.5.4 Utility actions necessary to implement technical The proposed TS change adds functional testing of the specification changes for APRM Logic System 2/4 Trip Voter Logic to be performed each refueling Functional Testing (LSFr): outage.

Revise Tech Specs to change the interval for LSFT from 18 months to 24 months unless the utility elects to retain the 18-month interval for plant scheduling purposes.

8.3.6.1 Utility actions necessary to implement technical The proposed TS change includes revisions necessary specification changes for APRM Setpoints: to implement ARTS. ARTS implementation is based on GE engineering report NEDC-32433P, which is Add to or delete from the appropriate document any included as part of the TS change package. New changed RPS setpoint information. If ARTS is being PRNM setpoints for flow-biased APRM scram and rod implemented concurrently with the PRNM modification, block and for power-biased RBM trips have been either include the related Tech Spec submittal calculated by GE using NRC approved setpoint information with the PRNM information in the piant methodology. The flow-biased APRM scram setpoint specific submittal, or reference the ARTS submittal in equation is included explicitly in BFN tech specs. The the PRNM submittal. In the plant specific submitral, flow-biased APRM rod block equation and the power-identify what changes, if any, are being implemented biased RBM setpoints are included in the Core and identify the basis or method used for the calculation Operating Limits Report (COLR).

of setpoints and where the setpoint information or changes will be recorded.

8.4 Utility actions necessary to implement technical Because the proposed TS change does not request specification changes for OPRM Related RPS Trip changes to implement the OPRM (Oscillation Power Functions: Range Monitor) trip functions, no confirmations of action are required at this time.

The required actions are in Sections 8.4.1.4, 8.4.2.4, 8.4.3.4, 8.4.4.4, 8.4.5.4 and 8.4.6.1 of the PRNM LTR.

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7 Plant-Specific Information Required for NUMAC PRNM Retrcfit Section Utility Action Required Response 8.5.1.4 Utility actions necessary to implement technical a) BFN is implementing ARTS concurrently with the specification changes for APRM/RBM Related NUMAC PRNM design change. The proposed TS Control Rod Block Functions: change includes revisions necessary to implements the ARTS improvements.

If ARTS will be implemented concurrently with the PRNM modification, include or reference those changes b) The Recirculation Flow Upscale, Compare and in the plant specific PRNM submittal. Implement the INOP control rod block funtions and related l applicable portion of the below described changes via information are deleted as part of the proposed TS l modifications to the Tech Specs and related procedures change. l and documents. In the plant specific submittal, identify  !

I functions currently in the plant Tech Specs and which c) N/A. This function was not identified in BFN tech changes are being implemented. NOTE: A utility may specs; no action is required. I choose not to delete some or all of the items identified in the PRNM LRT fru . .he plant Tech Specs. d) These APRM control rod block functions are still to be included in BFN tech specs; they are not deleted as l a) Some plants may implement ARTS concurrently with part of the proposed change. The functions will be the PRNM modification. For those plants, deleted from tech specs, as appropriate, when BFN appropriate changes should be made to the plant's converts to Improved Tech Specs.

Tech Specs..

b) For ARTS plants, delete the Recirculation Flow Upscale, Compare and inop control rod block trip <

functions from the Tech Specs, and their related information (if currently in the Tech Specs).

c) For ARTS plants, delete the Tech Spec functional entry for Bypass Time Delay.

d) For plants that currently have not implemented Improved Tech Specs, delete the APRM Flow Biased Neutron Flux Upscale, APRM Neutron Flux Upscale, Setdown, APRM Downscale and APRM Inop control rod block trip functions from the Tech Specs.  !

I 8.5.2.4 Utility actions necessary to implemeat technical See 8.5.1.4 above. No additional confirmation of specification changes for Minimum Number of action required.

Operable APRM/RBM Related Control Rod Block Channels:

No action required relative to minimum operable channels beyond that required by 8.5.1.4 above.

8.5.3.4 Utility actions necessary to implement technical See 8.5.1.4 above. No additional confirmation of specification changes for Applicable Modes of action required.

Operation for APRM/RBM Related Control Rod Blocks:

No action required relative to modes during which he function must be available beyond that required by 8.5.1.4 above.

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Plant-Specific Information Required for NUMAC PRNM Retrofit Section Utility Action Required Response Utility actions necessary to implement technical specification changes for APRM/RBM Related Control Channel Check:

Block Required Surveillances and Calibrations:

For the APRM rod block fus&,ns, the instrument 8.5.4.1.4 Channel Check: check currently in tech sners '1 continued on a frequency of once i,cr day. This is comparable to the Delete any requirements for instrument or channel APRM trip function channel check called for in checks related to RBM and, where applicable, Section 8.3.4.1.2 of the PRNM LTR.

recirculation flow rod block functions (non-ARTS plants), and APRM functions. Identify in the plant For the RBM rod block functions, the proposed TS specific PRNM submittals if any checks are currently change deletes the current requirement for an included in Tech Specs, and confirm that they are being instrument check once/ day.

deleted.

Channel Functional Test:

8.5.4.2.4 Channel Functional Test:

The APRM and RBM rod block channel functional test Change Channel Functional Test requirements to frequency is changed to once per 6 months. Changes in test frequency are as identified in Section I, identify a frequency of every 184 days (6 months).

In the plant specific licensing submittal, identify Enclosure 1 of this TS change package, current Tech Spec test frequencies that will be changed to 184 days (6 months). Channel Calibrations:

8.5.4.3.4 Channel Calibrations: APRM and RBM rod block channel calibrations are changed to once/ operating cycle.

Change channel calibration requirements to identify a frequency of every 24 months. In the plant specific Response Time Testine:

licensing submittal, identify current Tech Spec test frequencies that will be changed to 24 months. N/A 8.5.4.4.4 Response Time Testing:

None. [There currently are no response time testing requirements; none are proposed by the PRNM LTR.]

8.5.5.4 Utility actions necessary to implement technical N/A specification changes for APRM/RBM Related Control Block Logic System Functional Testing:

None. [There currently are no logic system functional testing requirements; none are proposed by the PRNM LTR.]

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Plant-Specific Information Required for NUMAC PRNM Retrofit Section Utility Action Required Response 8.5.6.1 Utility actions necessary to implement technical ARTS is being implemented concurrently with the specification changes for APRM/RBM Related Control NUMAC PRNM modification, and appropriate setpoint Block Setpoints: changes are included as part of the TS change package.

RBM and APRM rod block setpoints are based on Add to or delete from the appropriate document any setpoint calculations performed for BFN by GE using changed control rod block setpoint information. If NRC approved setpoint methodology. The APRM ARTS is being implemented concurrently with the flow-biased setpoint equation and the power-biased PRNM modification, either include the related Tech RBM setpoints will be contained in the Core Operating Spec submittalinformation with the PRNM information Limits Report, as discussed in Enclosure 1 of the TS in the plant specific submittal, or reference the ARTS change package.

submittal in the PRNM submittal. In the plant specific submittal, identify what changes, if any, are being implemented and identify the basis or method used for calculation of setpoints and where the setpoint information or changes will be recorded.

9.1.3 Utility Quality Assurance Program: Quality assurance requirements for work performed at BFN are defined and described in TVA Nuclear As part of the plant specific licensing submittal, the Quality Assurance Plan, TVA-NQA-PLN89-A.

utility should document the established program that is applicable for the project modification. The submittal For the PRNM modification, TVA has contracted with should also document for the project what scope is GE to include the following PRNM scope: 1) design, r being performed by the utility and what scope is being 2) hardware / software. 3) modification instruction, supplied by others. For scope supplied by others, 4) licensing support,5) training,6) O & M manuals '

document the utility actions taken or planned to define and design documentation,7) stability indicator, or establish requirements for the project, to assure those 8) seismic qualification of the NMS panel,9) EMl/RFI requirements are compatible with the plant specific qualification, and 10) NMS se point calculations, configuration. Actions taken or planned by the utility ,

to assure compatibility of the GE quality program with On-site engineering work to incorporate the GE-the utility program should also be documented, provided design information into a Design Change i Notice (DCN) or to provide any supporting, interface Utility planned level of participation in the overall V&V design changes will be performed per requirements of process for the project should be documented, along applicable TVA/BFN procedures. Modification work with utility plans for soft ware configuration to implement the design change will be performed per management and provision to support any required TVA/BFN procedures or TVA/BFN-approved changes after delivery should be documented. contractor procedures. TVA has participated and will continue to participate in appropriate reviews of GE's design and V&V program for the PRNM modification.

For software delivered in the form of hardware (EPROMs), TVA currently intends to have GE maintain post delivery configuration control of the actual source code and handle any changes. TVA will 1 then handle any changes in the EPROMs as hardware changes under its applicable hardware modification  ;

procedures.

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