Text

Application for Amends to Licenses DPR-33,DPR-52 & DPR-68, Consisting of TS Change 373,revising TS to Implement Guidance of GL 87-09 & NUREG-1433,Rev 1
	ML20117H513
Person / Time
Site:	Browns Ferry
Issue date:	05/20/1996
From:	Salas P; TENNESSEE VALLEY AUTHORITY
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20117H516	List: ML20117H513; ML20117H523;
References
	RTR-NUREG-1433 GL-87-09, GL-87-9, TVA-BFN-TS-373, NUDOCS 9605280236
	Download: ML20117H513 (8)
	v • d • e

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1 nessee Valley Authority, Post Office Box 2000. Decatur, Alabama 35609 May 20, 1996 4

l l TVA-BFN-TS-373 10 CFR 50.90

! U.S. Nuclear Regulatory Commission 4 ATTN: Document Control Desk Washington, D.C. 20555 l

Gentlemen: 1 In the Matter of. ) Docket Nos. 50-259

. Tennessee Valley Authority ) 50-260 50-296 i;

! BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

j TECHNICAL SPECIFICATION (TS) CHANGE 373 - GENERIC LETTER (GL)

, 87-09 GUIDANCE INPLENENTATION l i 1 In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment (TS-373) to

licenses DPR-33, DPR-52, and DPR-68 to change the TS for Units 1, 2,'and 3. The proposed change is a BFN TS Line Item Improvement according to the guidance provided in GL 87-09,

! Sections 3.0 And 4.0 Of The Standard Technical Specification on The Applicability Of Limiting Conditions For Operation And j Surveillance Requirements. The proposed TS wording is in

accordance with NUREG 1433, Revision 1, " Standard Technical 2

Specifications in General Electric Boiling Water Reactors i (BWR/4)." Specifically, this change revises the BFN

surveillance definition 1.0.LL to incorporate a 24-hour delay in implementing the action requirements due to a missed surveillance requirement when the action requirements provide a restoration time that is less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This change also clarifies that the time limit of the action requirements applies from the point in time it is identified a surveillance has not bean performed and not at the time that the allowed surveillance interval was exceeded.

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PDR ADOCK 05000259 Ou P PDR-

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U.S. Nuclear' Regulatory Commission ,

Page 2 J May 20, 1996 l TVA has determined that there are no significant hazards

, considerations associated with the proposed change and that i

the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). The BFN Plant Operations i Review Committee and the BFN Nuclear Safety. Review Board have

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reviewed this proposed change and determined that operation of BFN Units 1, 2, and 3 in accordance with the proposed change will not endanger the health and safety of the public.

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

< Enclosure 1 to this letter provides the description and evaluation of the proposed change. This includes TVA's !

determination that the proposed change does not involve a i significant hazards consideration, and is exempt from i environmental review. Enclosure 2 contains copies of the l 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.

TVA requests that the revised TS be made effective within 30 days of NRC approval. If you have any questions about this change, please contact me at-(205) 729-2636.

Sincerel , - - l

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l A$d alas Manager of Site Licensing ,

1 Enclosures '

cc: See page 3 Subscribed and sworn ( before me

g this 90th dag of AL 1996.

Bnd

- Notary Public RB0aA My Commission Expires 4

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9 U.S. Nuclear Regulatory Commission Page 3 May 20, 1996 i

Enclosures cc (Enclosures): i Mr. W. D. Arndt I General Electric Company 735 Broad Street Suite 804, James Building Chattanooga, Tennessee 37402 Mr. Johnny Black, Chairman Limestone County Commission 310 West Washington Street

. Athens, Alabama 35611 Mr. Mark S. Lesser, Section Chief l U.S. Nuclear Regulatory Commission I Region II 101 Marietta Street, NW, Suite 2900 l Atlanta, Georgia 30323

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NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 i Athens, Alabama 35611 l 1

- Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017 i

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ENCLOSURE 1 l TENNESSEE VALLEY AUTHORITY

j. BROWM8 FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-373 ,

DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE i

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I. DESCRIPTION OF THE PROPOSED CHANGE

! TVA is revising BFN Units 1, 2, and 3 TS definition 1.0.LL

.to implement the guidance of Generic Letter (GL) 87-09, i Sections 3.0 And 4.0 Of The Standard Technical 1

Specification On The Applicability of Limiting Conditions For Operation And Surveillance Requirements. The proposed change.is consistent with GL 87-09 and the proposed TS I wording is in accordance with NUREG 1433, Revision 1, 4

" Standard Technical Specifications in General Electric

Boiling Water Reactors (BWR/4)." Specifically, this change i

revises the BFN surveillance definition 1.0.LL to i l

l incorporate a 24-hour delay in implementing the Action l

! requirements due to a missed surveillance requirement when j the Action requirements provide a restoration time that is

, less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Additionally, this change also j clarifies that the time limit of the Action requirements t applies from the point in time it is identified a surveillance has not been performed and not at the time j that the allowed surveillance interval was exceeded.

The specific changes are described below:

1. Units 1, 2, and 3 TS Surveillance definition 1.0.LL, TS pages 1.0-11.

Paragraph 1.0.LL currently reads:

" Surveillance - Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other conditions specified for individual limiting conditions for operation unless otherwise stated in an individual Surveillance Requirements. Each Surveillance Requirement shall be performed l within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

It is not intended that this (extension) provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillance that are not performed during refueling outages.

Performances of a surveillance Requirement within the specified time interval shall constitute

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9 compliance and OPERABILITY requirements for a limiting condition for operation and associated action statements unless otherwise required by these specifications. Surveillance Requirements do not have to be performed on inoperable equipment."

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The proposed change to TS definition 1.0.LL adds a

third and Fourth paragraph to read

" Surveillance - Surveillance Requirements shall

be met during the OPERATIONAL CONDITIONS or other conditions specified for individual limiting i

conditions for operation unless otherwise stated in an individual Surveillance Requirements. Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

It is not intended that this (extension) provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages.

Performance of a Surveillance Requirement within the specified time interval shall constitute compliance and OPERABILITY requirements for a limiting condition for operation and associated action statements unless otherwise required by these specifications. Surveillance Requirements do not have to be performed on inoperable equipment.

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II. REASON FOR THE PROPOSED CHANGE The proposed change will make BFN's TS consistent with the l guidance provided in GL 87-09 and the proposed TS wording l in accordance with NUREG 1433, Revision 1. DFN's current i TSs do not contain provisions similar to GL 87-09. l Specifically, GL 87-09 allows the flexibility to defer declaring effected equipment inoperable or an effected variable outside the specified limits when a su:veillance has not been completed within the specified frequency.

GL 87-09 allows a delay' period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the point in time that it is discovered that the surveillance i has not been performed and not at the time that the specified frequency was not met. This delay time allows adequate time to complete surveillances that have been missed and permits completion of the surveillances before complying with required actions or other remedial measures that might preclude completion of the surveillances.

i III. SAFETY ANALYSIS In GL 87-n9, NRC stated that it is overly conservative to assume th L systems or components are inoperable when a l surveillance reqc. ement has not been performed. Because j the vast majority si surveillances demonstrate that systems or components in fact are operable. In addition, NRC j stated that the allowable outage time limits of some Action ;

requirements do not provide an appropriate time 11rit far performing a missed surveillance before chutdown requirements apply. GL 87-09 provides 6 24-hour time limit 1 for a missed surveillance. This time limit allows a delay of the required Actions to permit the performance of the missed surveillance.

The time limit is based on considerations of plant conditions, adequate planning, availability of personni,1, the time required to performed the surveillance requirement, as well as the safety significance of the delay in completing the surveillance requirement. GL 87-09 concludes that the 24-hour time limit adequately balances the risks associated with an allowance for completing the surveillance within this period against the risks associated uith the potential for a plant upset and challenge to safety systems when the alternative is a plant shutdown to comply with Action statements before t.he surveillance can be completed.

TV. NO SIGNIFICAF. HAEARDS CONSIDERATION DETERMINATION TVA has concluded that operation of BFN Units 1, 2, and 3, in accordance with the proposed change to the technical specifications.do not involve a significant hazards consideration. TVA's conclusion is barmf on its evaluation, in accorda57e with 10 CFR 50.91(a) (1) , of the three standards set forth in 10 CFR 50.92(c).

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d A. The proposed amendment does not involve a sianificant increase in the erobability or conseauences of an 1 accident creviousiv evaluated.

The proposed amendment to TS definition 1.0.LL is in accordance with the guidance of GL 87-09 and NUREG i 1

. 1433, Revision 1. The proposed change will allow BFN 4

to continue operation for an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after discovery of a missed surveillance. The change being proposed does not affect the precursor for any accident or transient analyzed in Chapter 14 of the BFN Updated Final Safety Analysis Report. The proposed change does not reflect a revision to the j physical design and/or operation of the plant.

Therefore, operation of the facility in accordance with the proposed change does not affect the ;

probability or consequences of an accident previously '

evaluated.

B. The prooOsed amendment does not create the nossibility of a new or different kind of accident from any accident previous 1v evaluated.

The proposed amendment to TS definition 1.0.LL is in accordance with the guidance of GL 87-09 and NUREG 1433, Revision 1. The proposed change will allow the i plant to continue operation for an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after discovery of a missed surveillance. The change being proposed will not change the physical plant or the moaer of operation defined in the facility license. The change does not involve the addition or l moditication of equipment, nor do they alter the 1 design or operation of plant systems. Therefore, !

operation of the facility in accordance with the proposed change does not create the possibility of a new or different kind of accident from any previously I evaluated.

C. The nroposed amendment does not involve a sianificant reduction in a marain of safety.

The proposed amendment to TS definition 1.0.LL is in j accordance with the guidance of GL 87-09 and NUREG 1433, Revision 1. The proposed change does not affect plant safety analysis or change the physical design or operation of the plant. The proposed change will ;

alloa the plant up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed l surveillance. The overall effect is a net gain in plant safety by avoiding unnecessary shutdowns and the associate system transients due to missed 1

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l surveillance. Therefore, operation of the facility in accordance with the proposed change does not I involve a significant reduction in a margin of safety. I V. ENVIRONMENTAL IMPACT CONSIDERATION l l

I 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 l may be released,offsite, or a significant increase in )

individual or cumulative occupational radiation exposure. l Therefore, the proposed change meets the eligibility I criteria for categorical exclusion set forth in 10 CFR

51. 22 (c) (9) . Uterefore, pursuant to 10 CFR 51.22 (b) , an >

environmental assessment of the proposed change is not j required. I l

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ML20117H513

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