Text

Summary of 970521 Meeting W/Tva in Rockville,Md Re Review of Section 3.3 of Improved TS for Mentioned Plant.List of Attendance & Comments Encl
	ML20141G406
Person / Time
Site:	Browns Ferry
Issue date:	06/30/1997
From:	Williams J; NRC (Affiliation Not Assigned)
To:	; NRC (Affiliation Not Assigned)
References
	NUDOCS 9707070316
	Download: ML20141G406 (51)
	v • d • e

_ . - . - _. _ . -- __ _

i June 30, 1997 l

l J

LICENSEE: Tennessee Valley Authority FACILITY: Browns Ferry Nuclear Plant, Units 1, 2, and 3

SUBJECT:

SUMMARY

- MAY 21, 1997 MEETING WITH TENNESSEE VALLEY AUTHORITY ON BROWNS FERRY IMPROVED TECHNICAL SPECIFICATIONS On May 21, 1997, representatives of the Tennessee Valley Authority (TVA) and the Nuclear Regulatory Commission (NRC) staff met in Rockville, Maryland.

The topic of discussion was NRC staff comments from their review of Section 3.3 of the improved technical specifications for the Browns Ferry Nuclear Plant, which TVA submitted on September 6, 1996. A complete list of attendees is provided as Enclosure 1. A copy of the NRC staff's comments is included in Enclosure 2.

Original signed by Joseph F. Williams, Project Manager Project Directorate 11-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Attendance List

2. NRC comments cc w/

Enclosures:

See next page i DOCUMENT NAME: G:\BFN\M9643M4. SUM To rcceive a copy of this document, indicate in the box: "C" - Copy without attachment / enclosure "E" = Copy with attachment / enclosure _"N" - No copy 0FFICE PDII-3/PM /g , l/, PDII-3/LA ,oj 4 PDII-3/Di/ jo l l NAME- JWilliams /N BClayton F~ /I FJHebdon t ,#' '

DATF 06/ V1/97 // 06/3D/97 / 06/)4/67

ICIAL RECORD COPY P

D DON 0500b259 PDR UJUUo4 lllU(El0lllll$l$!!llllll gg gg{fgjg ggpy

_ _ ---~_

BROWNS FERRY NUCLEAR PLANT

\

cc: Mr. Timothy E. Abney, Manager Mr. Oliver D. Kingsley, Jr. Licensing and Industry Affairs President, TVA Nuclear and Browns Ferry Nuclear Plant Chief Nuclear Officer Tennessee Valley Authority Tennessee Valley Authority P.O. Box 2000 6A Lookout Place Decatur, AL 35609 1101 Market Street Chattanooga, Tennessee 37402-2801 Regional Administrator U.S. Nuclear Regulatory Commission Mr. O. J. Zeringue, Sr. Vice President Region II Nuclear Operations 61 Forsyth Street, SW., Suite 23T85 Tennessee Valley Authority Atlanta, GA 30303-3415 6A Lookout Place 1101 Market Street Mr. Leonard D. Wert Chattanooga, TN 37402-2801 Senior Resident Inspector Browns Ferry Nuclear Plant Mr. Jack A. Bailey, Vice President U.S. Nuclear Regulatory Commission Engineering & Technical Services 10833 Shaw Road Tennessee Valley Authority Athens, AL 35611

) 6A Lookout Place I

1101 Market Street Chairman

' Chattanooga, TN 37402-2801 Limestone County Commission 310 West Washington Street Mr. C. M. Crane, Site Vice President Athens, AL 35611 Browns Ferry Nuclear Plant Tennessee Valley Authority State Health Officer P.O. Box 2000 Alabama Department of Public Health Decatur, AL 35609 434 Monroe Street Montgomery, AL 36130-1701 General Counsel Tennessee Valley Authority ET 10H 400 West Summit Hill Drive Knoxville, TN 37902 Mr. Raul R. Baron, General Manager Nuclear Assurance and Licensing Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Masoud Bajestani, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Pedro Salas, Manager Licensing and Industry Affairs Tennessee Valley Authority !

4J Blue Ridge '

1101 Market Street Chattanooga, TN 37402-2801

I I

y ATTENDEES MEETING ON BROWNS FERRY IMPROVED TECHNICAL SPECIFICATIONS MAY 21. 1997 Name Affiliation Tim Abney TVA Joe Williams NRR/DRPE/PD 11-3 Carl Schulten NRR/TSB ENCLOSURE 1

i

l

]

l v

Distribution 1 1

HARD COPY (Enclosures 1 and 2)'

. Docket. File = ;

PUBLIC BFN Reading

-J. Williams .

l

-0GC ACRS-E-MAIL (Enclosure 1) -

l S. Collins /F. Miraglia (SJC1,FJM) I R.:Zimmerman (RPZ) l S. Varga (SAV) '

1

-F. Hebdon (FJH)

B. Clayton (BAC2)

D. Ross (e-mail to SAM)

C. Shulten (CSSI)

G. Tracy-(GMT)

J. Johnson, RII (JPJ) ;

1 1

i l

l I

l l'

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO Description of issue Date Date Closed COMMENTS JFC- Opened 3.3.1.1-1 A-8 CTS Table 3.1.A, CTS Table 3.1.A, note 1 A allows one hour 12/23/96 Provide justification note 1 A before initiation of control rod insertion. ITS for the more 3.3.1.1, Required ACTION H.1 does not allow restrictive change.

this I hour period. This change is more restrictive and should be justified as such.

3.3.1.1-2 A-11 CTS Table 4.1.8 The Unit I calibration frequencies of CTS Table 11/15/96 Provide discussion OOS 4.1.B are changed from 3 months to 18 months and justification for ITS Table to duplicate the Units 2 & 3 less restrictive the less restrictive 3.3.1.1-1 frequencies of CTS Table 4.1.8 as an change.

Functions 3,4 & administrative change resulting in ITS Table 6 3.3.1.1-1 Functions 3,4 & 6 rather than as a less restrictive change.

3.3.1.1-3 A6 CTS Table 3.1.A, The TSV and TCV applicability is changed to 3/21/97 Provide justification Note 4 230% RTP from 1st stage pressure < 154 that the proposed psig. A statement is made that the two limits change i,s are identical without appropriate references or administrative.

justifications to conclude the change is administrative.

3.3.1.1-4 A12 CTS 3.1.A Notes DOC A12 discusses that high reactor pressure, 3/21/97 Provide appropriate 8 & 10 high drywell pressure and low water level justification for the function are deleted for Mode 5. Notes 8 & 10 proposed changes.

do not apply to low water level. The notes state that refuel mode doesn't apply if containment is not required (note 8) or if the head is unbolted (note 10). DOC A12 does not accurately discuss the changes that are being proposed.

1 ENCLOSURE 2

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS l.CO Description of issue Date Date Closed COMMENTS JFC' Opened 3.3.1.1-5 A14 CTS Table 3.1.A This DOC discusses a mixture of changes to 3/21/97 Provide justifications action statements for RPS trips. The DOC based on proposed states that action 1.A has been deleted since it changes.

contains an obvious requirement. Action 1.A is an optional action for the operator and its deletion results in a less restrictive since optional requirements are removed. Provide revised discussion that address proposed changes.

3.3.1.1-6 A7 CTS Table 3.1.A The is no design change from CTS to ITS. But, 3/21/97 Provide additional the ITS proposes 8 (required) channels per trip clarification to system while the CTS is 4 (minimum operable) support the A7 DOC.

channel per trip system. Explain why this change is considered administrative.

3.3.1.1-7 M2 CTS Table Notes The M-DOC discussions lack a safety impact 3/21/97 Provide revised DOCS

& for Table 3.1.A, justification for the proposed changes. that include a M3 Item 1.D discussion of the

& ITS SR safety importance of 3.3.1.1.5 the proposed changes.

3.3.1.1-8 M4 Proposed SR The IRM high flux SR calibration discussion does 3/21/97 Provide appropriate 3.3.1.1.9 not include discussion of the notes that are also DOC discussion for added as part of the SR. these changes.

3.3.1.1-9 MS CTS Table 4.1.B Verification of the IRM/APRM overlap during %/97 Provide a safety note 6. shutdown that is not required by the CTS is an basis justification for ITS SR 3.3.1.1.6 additional restriction on plant operation. the more restrictive chanbe.

2

t BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO ~ Description of issue Date Date Closed COMMENTS JFC Opened 3.3.1.1-10 MS CTS Table 4.1.B Deletion of verification of overlap during startup %/97 This deleted CTS OOS note 6. is less restrictive on plant operation. Surveillance Test ITS SR 3.3.1.1.6 Interval is outside the TSB scope of review.

Provide discussion

, and justification for the less restrictive change.

3.3.1.1-11 M-6 ITS Table An RPS Channel Test Switch Function is added %/97 Acceptance of this 3.3.1.1-1 to the list of functions in ITS Table 3.3.1.1-1, change is contingent function 12 function 12. upon the NRC approval of NEDC-30851-P-A, and MED-32-0286.

3.3.1.1-12 A4 CTS page incorrect DOC. The APRM Flow Biased channel 3/21/97 Provide a M-DOC 3.1/4.1-11 calibration frequency is change to quarterly from discussion.

once per operating cycle.

3.3.1.1-13 LA2 generic to all 3.3 Provide a table listing each item that is moved to 3/21/97 Provide a relocation relocate Lxn's an owner-controlled document. For each item matrix as described describe the name of the document that the for this issue.

item is moved to and the regulatory control mechanism which will control future proposed changes.

3

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO Description of issue Date Date Closed COMMENTS JFC Opened 3.3.1.1-14 LB-1 CTS Table 3.1.A Note 2 of ITS SR 3.3.1.1 has the revised %/97 Identify as an note 23 wording "the associated Functions maintains administrative RPS trip capability" that assures trip Function change.

ITS SR 3.3.1.1 capability for all designs. This change appears Note 2 administrative, rather than less restrictive.

3.3.1.1-15 LB-2 STS SR The CHANNEL FUNCTIONAL TEST interval of 11/13/96 Acceptance of this OOS 3.3.1.1.9 RPS channels and trip systems (ITS Table change is contingent 3.3.1.1-1, functions 2, 3, 4, 5, 7, 8, 9, and 11) upon the NRC ITS SR 3.3.1.1.8 are extended to 92 days from the monthly approval of NEDC-requirement of CTS Table 4.1.A, based on the 30851-P-A, and CTS Table 4.1.A reliability analysis of " Technical Specification MED-32-0286.

Improvement Analyses for BWR Reactor Protection System," (NEDC-30851-P-A, March 1988) and an unreferenced BAN report

" Technical Specification improvement Analyses for Browns Ferry Nuclear Plant, Unit 2," (MED-32-0286, October 1995.)

4

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO : Description of issue Date Date Closed COMMENTS JFC Opened 3.3.1.1-16 LB2 ITS 3.3.1.1 The ITS 3.3.1.1, Condition A, Completion Time 11/14/96 Acceptance of this OOS is extended from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in CTS Table 3.1.A. change is contingent CTS Table 3.1.A Notes 1 and 23, to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . upon the NRC Notes 1 and 23 approval of NEDC-The ITS 3.3.1.1, Condition B, Completion Time 30851-P-A, and is extended from I hourin CTS Table 3.1.A. MED-32-0286.

Notes 1 and 23, to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The AOT for placing a channel in trip for required surveillance testing is extended from the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of CTS Table 3.1.A, Note 23, to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS Table 3.3.1.1-1.

These changes are based on the reliability analysis of " Technical Specification improvement Analyses for BWR Reactor Protection System," (NEDC-30851-P-A, March 1988) and an unreferenced BAN report

" Technical Specification improvement Analyses for Browns Ferry Nuclear Plant, Unit 2," (MED-32-0286, October 1995.)

3.3.1.1-17 L1 & Revised action L1 does not discuss changes proposed to CTS 3/21/97 Provide revised L2 statements and Note (7). discussion of applicabilities for changes.

certain RPS L2 does not discuss manual scram function functions. changes.

'I 5

i

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO Description of issue Date Date Closed COMMENTS JFC Opened 3.3.1.1-18 L4 ITS SR 3.3.1.1.2 A Note is added to the heat balance calibration 3/21/97 Provide the safety which allows delay in performing the SR until a discussion basis.

prescribed power level is reached. The safety basis evaluation states acceptance based on operating experience. BFNP has never performed the surveillance with the propcsed note. What is the basis for the operating experience justification?

3.3.1.1-19 L5 CTS Table 3.1.A LB2 & L5 both apply to the same ballooned text 3/21/97 Provide revised DOCS Note 1 inthe markup of Table 3.1.A, Note (1). L5 as for proposed stated does not provide appropriate justification changes.

for the ballooned text.

3.3.1.1-20 JFC STS SR The function of the time constant circuit of STS 11/13/96 Provide specific P-58 3.3.1.1.14 SR 3.3.1.1.14 is to simulate flow coast down justification for the for the APRM. ITS 3.3.1.1 does not implement STS deviation based this surveillance. Deleting the time constant on system design, or testing in STS SR 3.3.1.1.14 of the APRM Flow operational Biased Simulated Thermal Power circuit is not constraints.

sufficiently supported.

3.3.1.1-21 JFC STS SR STS SR 3.3.1.1.17 requires RPS TIME 11/13/96 Provide specific P-4 3.3.1.1.17 RESPONSE TESTING. ITS 3.3.1.1 does not justification for the implement this surveillance. Deleting the RPS STS deviation based TIME RESPONSE TESTING in ITS 3.3.1.1 is not on system design, or sufficiently supported by JFC or Bases. operational e

constraints.

6

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO Description of issue Date Date Closed COMMENTS JFC Opened 3.3.1.1-22 JFC ITS SR The Low Scram pilot Air Header Pressure 11/13/96 Provide specific P-60 3.3.1.1.16 surveillance of ITS-SR 3.3.1.1.16 applies to justification for the Units 2 & 3 but not Unit 1. No justification or STS deviation based A12 explanation is provided. on system design, or operational constraints.

3.3.1.1-23 JFC STS Bases SR The deletion of the STS Bases for the SR 11/13/96 Provide specific P-79 & 3.3.1.1.16 3.3.1.1.16 requirement that the main turbine justification for the P-16 bypass valves must be closed when calibration STS deviation based ITS Bases is performed at 2.30% RTP should be on system design, or SR 3.3.1.1.15 reconsidered if actual steam pressure is used to operational Functions 8 & 9 verify the calibration. ITS Bases constraints.

SR 3.3.1.1.15, Functions 8 & 9, do not have this requirement. While the justification that an isolated sensor can be tested with a gage calibrator independent of bypass valve position is true, the calibration that is addressed by ITS SR 3.3.1.1.15 is not only steam pressure .

bypass trip setpoint and function, but also demonstrates that the function is verified by partial movement of the turbine valves after the sensor is returned on-line.

7

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or - CTS /STS LCO - Description of issue Date Date Closed COMMENTS JFC Opened 3.3.1.1-24 JFC Flow biased CTS require a channel calibration once per 3/24/97 Provide DOC and P-89 APRM Scram operating cycle. The CTS markup shows this JFC changes as

& CTS Table 4.1.b frequency is changed to 92 days and is renamed necessary to resolve DOC ITS SR SR 3.3.1.1.9. In the ITS the same SR is identified A-4 3.3.1.1.11 3.3.1.1.11 and carries a 184 day frequency. discrepancies.

ITS Table JFC P89 states that the APRM design is such 3.3.1.1 Function that the function can only be tested at refueling 2.b without causing multiple inoperable APRMs and a reactor trip. Reconcile the apparent discrepancias between the CTS markup, ITS markup and JFC 89.

3.3.1.1-25 JFC-91 ITS SR 3.3.1.1.9 This SR applies a 92 day calibration frequency 3/24/97' Provide specific to RPS APRM trip functions which otherwise justification for the have either a 7 day or refueling interval. STS deviation based on system design, current license basis or operational constraints.

3.3.1.1-26 JFC-59 ITS SR 3.3.1.1.1 Channel Checks are not adopted as part of the 3/24/97 Provide specific ITS for drywell pressure high and SDV trip justification for the JFC-74 functions. STS deviation based on system design or operational constraints 8

I

\

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO Description of issue ' Date Date Closed COMMENTS JFC Opened 3.3.1.1-27 JFC-88 ITS function 12, Addition of channel test switches was credited 3/24/97 Provide staff OOS RPS Channel in the analysis of NEDO-3851 for extending approval of the Test Switches automatic scram function frequencies. referenced NEDO report. Include specific justification for the STS deviation based on system design, current licensing basis or operational constraints.

3.3.1.1-28 JFC STS BASES A block of text is moved from STS BASES, 11/25/96 Identify new location P-15 ACTIONS C.1 REQUIRED ACTIONS C.1, to an unidentified and justify moving.

plant document. ITS BASES, REQUIRED ACTIONS C.1, does not maintain this information.

3.3.1.1-29 LA2 CTS Table 3.1.A Note 17 provides exceptions to CTS APRM 3/24/97 Explain Note 17 opoerability requirements. LA2 proposes to categorization of relocate these exceptions. these requirements as system design or operational detail.

What programmatic controls will be used to control future changes to the relocated requirements.

9

BFN ITS 3.3.1.1 RPS INSTRUMENTATION Table 3.3.1.1 Rv.1 DOC or CTS /STS LCO Description of issue - Date Date Closed COMMENTS JFC Opened 3.3.1.1-30 LA2 CTS Table 3.1.A Note 19 establishes alternate remedial actions. 3/24/97 Explain Note 19 categorization of these requirements as system design or operational detail.

What programmatic controls will be used to control future changes to the relocated requirements.

3.3.1.1-31 none CTS Table 3.1.A Note 21 is showed to become Table 3.3.1.1-1 3/24/97 Explain and justify Note 21 Note (a) and applies to functions 2.a and 2.e. In the disposition of it.e Table 3.3.1.1-1 Note (a) does not apply to CTS requirements in functions 2.a and 2.e the ITS.

3.3.1.1-32 1.A.1 CTS Table 4.1.A Note 1 states that the minimum frequency for 3/24/97 Explain Note 1 the test shall be at least once per month, categorization of these requirements as detail for performing the surveillance. What programmatic controls will be used to control future changes to the relocated requirements.

10

BFN ITS 3.3.1.2 SRM INSTRUMENTATION Table 3.3.1.2 Rv.1 DOC or CTS /STS LCO Description of issue Date Opened Date Closed COMMENTS JFC 3.3.1.2-1 M8 CTS 3.3.B.4 ITS 3.3.1.2, Conditions A, B and C, allow up to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1/S/97 Each change should be for Conditions A and B and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Condition C) before the addressed and justified reactor must be in Mode 3 when SRM OPERABILITY requirements separately are not satisfied versus the CTS 3.3.B.4 requirernant of being in MODE 4 within the fo!!owing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The change of going to Mode 3 rather than MODE 4 is less restrictive, even if more time is allowed.

The change of going to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months rather than 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months is a more restrictive change.

3.3.1.2-2 LA1 CTS 3.10.B.1.s The requirement that "The SRM shall be inserted to the normal 11/25/96 Identify where this operating level" was not carried into the Bases as stated. requirement is located in ITS Bases.

3.3.1.2-3 M DOCS CTS Each discussion of change should be revised to discuss the 3/24/97 Revise the M DOCS es justification or the basis for concluding the change are an appropriate.

appropriate enhancement to TS.

3.3.1.2-4 L1 ITS Table The proposed ITS make use of spiral offload procedures and adopt 3/24/97 Provide a staff OOS Note (b) a revision to SR 3.3.1.2.4 Note 2 for count rate verification during acceptance review for P19 spiralloading. These are changes to the CTS allowances and the operations allowing revision to the SR Note is a change to the STS. spirai loadinglof f-loading.

3.3.1.2-4 none CTS 4.10.B.2 CTS core monitoring surveillances require periodic verification of 3/25/97 Provide appropriate signal to noise ratio once per 12 houts during core alterations. The DOCS for proposed CTS ITS SR ITS include this requirement and an additional verification of once changes to adopt the 3.3.1.2.4 per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during applicable modes. The required 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ITS.

testing is not dispositioned in either the DOCS or the JFC.

1

BFN ITS 3.3.2.1 - CONTROL ROD BLOCK INSTRUMENTATION Table 3.3.2.1 Rv.1 DOC- CTS /STS LCO Description of leeue Date Opened Date Closed COMMENTS orJFC 3.3.2.1-1 A3 CTS Tables The deletion of the CTS Table 3.2.C surveillance requirements for 11/27/96 Provide additional 3.2.C & 4.2.C the Rod Block Logic has been justified by observing that other discussion and confirm functional tests can test it. In order to be an Administrative equivalence of TS change, it would be implemented in the ITS, essentially requirements.

unchanged. The CTS requires a operating cycle test of the logic whereas the ITS requires a quarterly test. Provide a statement that all components tested by the CTS req 2irements are included in the I ITS SRs, but at a more frequent interval.

3.3.2.1-2 M CTS /ITS Each discussion of change should be revised to discuss the 3/25/97 Revise the M DOCS as DOCS justification or the basis for concluding the change are an appropriate.

appropriate enhancement to TS.

3.3 2.1-3 LA1 CTS Portions of the note limit the use of channel bypass for SRMs or 3/25/97 Provide appropriate 4 T w a 3.2.C. RBMs during repair or calibration are proposed to be placed in the discussion for proposed Note 5 Bases using a justification that they are operational details. changes to CTS Because the statements establish allowed outage times for repair requirements.

or test they are instead, operational limits.

3.3.2.1-4 L.A 1 CTS LA1 is applied to a change which cannot be distinguished from 3/24/97 Revise the CTS markup Table 3.2.C other marks on the page. Provide clarifying documentation. of Note 7.

none Note 7.a Note 7.a provides " operational restraints

to use of RBM bypasses. Provide appropriate The restraint stated as *or when a peripheral control rod is discussion for proposed selected" is not incorporated in the ITS applicability as noted in the chares to CTS CTS markup. requirements.

3.3.2.1-5 none CTS Documentation of RBM operational constraints in Note 7.c related 3/24/97 Table 3.2.C to the allowance for bypassing only one channel from the console" Provide appropriate Note 7.c is not incorporated into ITS Actions A & B as stated. discussion for proposed changes to CTS d

'* O '****'**

1

BFN ITS 3.3.2.1 - CONTROL ROD BLOCK INSTRUMENTATION Table 3.3.2.1 Rv.1

~ DOC CTS /STS LCO Description of Issue Date Opened Data Closed COMMENTS or JFC 3.3.2.1-6 LA1 CTS Both the R1 and the LA1 DOCS are applied to tNs CTS 3/24/97 Provide a revised CTS Table 3.2.C requirement. markup.

R1 Note 10 Revise the markup to specify the appropriate DOC.

3.3.2.1-7 R1 Table Note 12 R1 is applied to this note which provides test requirements for 3/24/97 Provide a revised markup page 3.2/4.2-59 incere detectors. Less restrictive DOCS apply to proposed and DOC as appropriate.

changes that delete requirements that are not entire LCOs.

3.3.2.1-8 LA2 Table Notss Both DOCS are applied to this table note which discussed methods Provide a revised CTS 8 & 13 found on for performing functional tests. markup.

R1 page 3.2/4.2-59 3.3.2.1-9 LB2 CTS Table 4.2.C The CTS Table 3.2.C. Test interval of RBM CHANNEL 11/27/96 Acceptance of this OOS FUNCTIONAL TEST (function 1)is extended from 1 month to 92 change is contingent STS/ITS SR days in ITS SR 3.3.2.1.1. based on the reliability analysis of upon the NRC approval 3.3.2.1.1 Table " Technical Specification Improvement Analyses for BWR Control of NEDC-30851-P-A, Sup 3.3.2.1-1 Rod Block Instrumentation." (NEDC-30851-P-A, Supptoment 1, 1, and MED-324286.

Function 1 October 1988) and an unreferenced BAN report " Technical Specification improvement Analyses for Browns Ferry Nuclear Plant. Unit 2" (MED-324286, October 1995).

3.3.2.1-10 L1 ITS Note 2 to Adoption of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months delay time limit for entry into associated 3/24/97 Acceptance of this OOS Surveillance Conditions and Required Actions during performance of required change is contingent Requirements SRs is based on the reliability analysis of GENE-770-06-1 upon the NRC approval

Addendum to Bases for Changes to Surveillance Test intervals of GENE-770-06-1.

and Allowed-Out-of-Service Tirnes for Selected instrumentation Technical Specifica: ions." February 1991.

2

I BFN ITS 3.3.2.1 - CONTROL ROD BLOCK INSTRUMENTATION Table 3.3.2.1 Rv.1 DOC CTS /STS t.CO Description of lesue Cate Opened Date closed COMMENTS orJFC.

3.3.2.1-11 L2 CTS 4.3.B.3.b.1 The ITS SR 3.3.2.1.2 requirement for a CHANNEL FUNCTIONAL 12/2/96 Acceptance of this OOS TEST is less restrictive because the Survoeis.nce Test is not change is contingent ITS SR required until I hour efter the RWM is required OPERABLE while upon the NRC approval 3.3.2.1.2 CTS 4.3.B.3.b.1 required a test within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to withdrawal of NEDC-30851-P-A, Sup of control rods. rhis is based on the reliability analysis of 1, and MED-32-0286.

" Technical Specification improvement Analyses for BWR Control Rod Block Instrumentetion," (NEDC-30851-P-A, Supplement 1 October 1988) and an unreferenced BAN report " Technical Specification Impravement Analyses for Browns Ferry Nuclear Plant, Unit 2" (MED-32-C286. October 1995).

3.3.2.1-12 L2 CTS 4.3.B.3.b.2 The ITS SR 3.3.2.1.3 regJremsnt for a CHANNEL FUNCTIONAL 12/2/96 Acceptance of this 005 TEST is less restrictive because the Surveillance Test is not change is contingent required unta 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after the THERMAL POWER is 510% in upon the NRC approval ITS SR MODE 2 wNie CTS 4.3.B.3.b.2 req. sired a test witNn 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior of NEDC-30851-P-A, Sup 3.3.2.1.3 to the THERMAL POWER being s 10% in MODE 2. TNs is based 1 and MED-32-0286.

on the reliability analysis of

Technical Specification improvement Analyses for BWR Control Rod Block Instrumentation." (NEDC-30851-P-A. Supplement 1 October 1988) and on unreferenced BAN report

Technical Specification improvement Analyses for Browns Ferry Nuclear Plant Unit 2* (MED-32-0286 October 1995).

3.3.2.1-13 L3 ITS Conditions TNs DOC discusses extending proposed completion times for 3/24/97 Provide appropriate A&B blocking control rod withdrawal if one control rod is inoperable. discussion in a revised The proposed changes appear to result in more restrictive DOC.

operations. In addition, the justification does not adequately discuss why the proposed change will not result in a significant safety issue for operation of the plant.

3

V b

i BFN ITS 3.3.2.1 - CONTROL ROD BLOCK INSTRUMENTATION Table 3.3.2.1 Rv.1 DOC' CTS /STS LCO Description of lasue Date Opened Data Closed COMMENTS orJFC 3.3.2.1-14 L4 CTS 4.3.B.5 The proposed change eliminates CTS 4.3.B.5 which requires a 12/2/96 Acceptance of tNs OOS Functional Test of the Rod Block Monitor (RBM)

prior to change is contingent ITS Table withdrawal of the designated rod (s)* during operation with CMFCP upon the NRC approval 3.3.2.1-1 or CMFLPD equel to or greater than 0.95 and at least once per 24 of NEDC-30851-P-A, Sup hours thereafter is ehminated. ITS Table 3.3.2.1-1 relies on the 1, and MED-32-0286.

Functional Test, required every 92 days. This is based on the reliability analysis of " Technical Specification Irns,.nvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1, October 1988) and en unreferenced BAN report " Technical Specification Irnprovement Analyses for Browns Ferry Nuclear Plant, Unit 2,* (MED-32-0286 October 1995J 3.3.2.1-15 R1 CTS Table 3.2.C The APRM, SRM, IRM and scram discharge volume control rod 3/24/97 Evaluate the licensing

& Notes 1-6. 8, blocks prevent a control rod withdrawal error et power transient. basis assumptions for the 10,11, and 12 The CTS Table 3.2.C and Notes 1-6,8,10,11, and 12 and CTS APRM downscale RPS Table 4.2.C and Notes 13,15, and 20 requirements are moved to trip. Provide supportmg CTS Table 4.2.C plant documents. The justification includes the evaluation change documentation

& Notes 13,15, summarized in NEDO-31466 and the lack of credit taken for this and revise iTS Table and 20 feature in design basis accident or transient analysis. NUMAC 3.3.1.1-1 as appropriate.

PRNM (ARTS) plant-specific changes in Enclosure 1. Attachment 2; deletes the RPS APRM downscale trip. This change is not reflected in ITS Table 3.3.1.1-1.

3.3.2.1 16 R2 CTS Table 4.2.C The CTS requires daily instrument channel checks. The STS has 12/2/96 Provide further no equivalent check for the RBM so performance of tNs test is justification why moving relocated to plant procedures. Justification for these less this requirement is within restrictive changes are ther e.*v w:..a not e: ready in the STS. The the current hcensing lack of equivalent surveillance in the S15 is insufficient justification basis and safety analysis.

for removing the risqrirement.

m 4

9

F t

BFN ITS 3.3.2.1 - CONTROL ROD BLOCK INSTRUMENTATION Table 3.3.2.1 Rv.1 DOC CTS /STS LCO Description of issue ' Date Opened Date Closed COMMENTS or JFC 3.3.2.1-17 P90 ITS SRs and JFC P90 states the intent to implement APRM/RBM toch specs 3/25/97 Provide additional Table 3.3.2.1 1 concurrent with installation of the power range neutron rnonitor supporting upgrade for ARTS. RWE analysis associated with ARTS is credited documentation for where applicable and the associated RBM setpoints are flow- changes proposed by and biased, rather than power dependent until ARTS hardware is discussed in JFC P90.

insta!!ad. The ITS SRs retain power dependent setpoints. In addition. STS Table 3.3.2.1-1 functions for RBM on IRM upscale, high power range upscale end bypass time delays are deleted.

These chtnges are not sufficiently discussed in P90. Staff approval of proposed ARTS implementation is not adequately documented and it is not obvious from the docketed discussions and markup of ITS that use of power dependent trip setpoints are proposed as stated in P90.

3.3.2.1-18 P3 ITS Table The flow biased RBM upscale block Allowable Value is stated as 3/25/97 Provide additional 3.3.2.1 "less than or equal to the value specified in the COLR." Provide justification for proposed footnota (e) documentation of staff approval of cycle dependent AVs for this changes.

rod block.

5

BFN ITS 3.3.2.2 FEEDWATER AND MAIN TURBINE TRIP INSTRUMENTATION Tabis 3.3.2.2 Rv.1 DOC or CTS /STS LCO Description of Ism . Date Date Closed - COMMENTS JFC Opened 3.3.2.2-1 M1 ITS 3.3.2.2 A now requirernent is added to the CTS requiring two channels per 12/2/96 Acceptance of this trip system of feedwater and main turbine high water level trip change is contingent

, instrumentation OPERABLE when THERMAL POWER is 2: 25% RTP. upon the NRC approval

, The justification of ACTIONS and SRs is based on GENE-77046-1 of GENE-770-06-1.

(ITS 3.3.2.2, Reference 2).

3.3.2.2-2 P11 ITS 3.3.2.2 STS Condition A is two or more trip channels inoperable. The 3/25/97 Provide a design basis, proposed ITS replace this conditon with one or more trip channel operational constraint inoperabie in each trip avstem. Thes are ' valent statements. or industry TSTF 4

change basis justification for not adopting the STS.

i 1

, _ ._ . - ._ _ . - - - = _ _ _ . _._ . - - - ._--- ------- - _ - - - - - - - - - - - - - - . - - - - -- - - - _

j t

i BFN ITS 3.3.3.1

} POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION

!' Table 3.3.3.1 Rv.1 4

4 l DOC l CTS /STS 1.C0 -

Desenption of issue - -

. , Date Opened Date Closed COMhENTS 3 JFC' i

, 3.3.3.1-1 A2 ITS Actione Proposed Note 3 is added in congunction with table function 6, 3/25/97 Sulmut en NEl TSTF for

! P90 Note 3 PCIV isolecon possoon indication. The proposed note would snow staff review and

! separate condition entry for sech contairwnent penetration. The approval.

note le genenc change to the STS. Generic changes require e i

staff approved TSTF.

f 3.3.3.1-2 A4 CTS Tatdo 4.2.F A4 does not dcues the proposed survedlance requerement 3/25/97 Provide an appropriate

{ markup p. 55 changes from once per operating cycle to once per 18 monthe. dicussion of change.

i 3.3.3.1-3 A5 CTS Table 3.2.F CTS Tatdo 3.2.F. Note 7. requires a Specsal Report if one of the 12/05/96 The less restrictive l t two rnonitors is inoperalde for more then 7 days. ITS 3.3.3.1 espects of this change j ITS Tatde requires a Specsal Report within 14 days of one channel being should be addressed as a j 3.3.3.1 1 inoperable for more than 30 days (Required ACTION 8) or two less restrictive type channels being inoperable for more then 7 days (Required change.

ACTION G).

I i

3.3.3.1-4 L1 ITS SR The Frequency for the CHANNEL CAUBRATION of CTS Tabie 12/10/96 Provide discussion and i 3.3.3.1.3 4.2.F is 184 days in ITS SR 3.3.3.1.3 for the Reactor Pressure justification for the less 1 JFC indicators. a restrictive change.

P57-l 1

3.3.3.1-5 L7 CTS Tatde 3.2.F ITS 3.3.3.1 REQUIRED ACTION 8.1 increases the outmuttal time 12/9/96 Provide discussion and l note 7 from within the CTS Tatde 3.2.F. Note 7. 7 days of exceedmg the justification for the less l time limit for en inoperable Primary Containment Area Radiamon restrictive change.

4 ITS 3.3.3.1 channel, to within 14 days of exceeding the time Smit.

REQUIRED 4 ACTION 8.1 1

3.3.3.1-6 M1 ITS Table Additional PAM functions are added to the ITS table. Provide a '3/25/97 Provide a revised DOC.

1 3.3.3.1 1 revised DOC that includes a reference to the staff SER approving 4

the plant specific PAM functions.

I 1

]-

i e

, vmom- vyy, , ,- -e w ~-,,m.. -

gg mnu g ,- , , mm ,.,,w've,-,.,..,m, ~ , , - - . .w,,- s -rn, ,, w , ,,.n,

,-..&- n-.,.., ,, ~ , ---,r, -m --% w. = , - ,

l l BFN ITS 3.3.3.1

! POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION Table 3.3.3.1 Rv.1 l

DOC CTS /STS LCO ' C-- O i ofleeue Date Opened Date Closed COMMENTS '

or-JFC l

j 3.3.3.1-7 . LA2 ITS PAM report LA2 states the relocated efternete monitoring methode ,

3/25/97 Provide e DOC which j requiremente are in the Beses and plant procedures. The ITS uses discusses the proposed the PAM Report in Specification S.6.6 to specifiy the regirement changes.

to estatseh alternete monitoring methods with the details located in owner-controlled documentation.

3.3.3.1-8 P11 ITS Table Proposed changes are replace STS instelled control room 3/25/97 Provide en NEl TSTF

I 3.3.3.1-1 indication channel

with " active PCIV." These are generic package for staff review

! Note (b) changes and require staff approval of en industry TSTF. A plant and approval.

opecific justification beoed on operational limitations or design

. difference from the STS wee not provided.

4 t

4 4

9 i

i 2 L______1__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ._ _ _ _ ._ _. _ . . _ _ _ _ _ . _ _ . _ . _ . _ _ _ _ _ _ _ _ _ . . - _ _ _ _ _ _ _ _ _

1 l

, BFN ITS 3.3.3.2 - BACKUP CONTROL SYSTEM

.)

Table 3.3.3.2 Rv.1

' DOC or ' CTS /STS LCO - Deeceiption of leece Date Opened Date cosed ' COMMENTS -

sc J'

3.3.3.2-1 JFC STS Table The IT3 changee SR 3.3.3.2.1 to require channel checke of 3/25/97 Provide a NEl TSTF

,' P-30 3.3.3.2-1 functione that are normally energized and which provide indication for staff review and

- during normel plant operation. The proposed change represente e approvel.

2 M-1 generic change to the STS.

1 k

I a

I i

l j

4 l!

i 4

,3 t

4 4

4 5

4 1

. - _ , _ _ _ - . - - _ = _ - _ _ _ _ _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - - .

i

\

l' j BFN ITS 3.3.4.1 - EOC-RPT INSTRUMENTATION 4 Table 3.3.4.1 Rv.1 i

i

! DOCl; CTS /STS LCO I

~

Desonpelon of'leeue - -

Date Opened Data Cloeod COMMENTS $

i or .

I JFC L .

t I 3.3.4.1 1 M1 CTS Table 4.2.8 New Survedlance Reqciremente are added to CTS Table 4.2.B. 12/12/96 Provide justification for l ITS SR 3.3.4.1.3 requires a CHANNEL CAL 18 RATION and a demonstrating adequacy

! ITS SR venficecon that the Allowable Values are set property. ITS SR of the more restrictive i 3.3.4.1.2 ITS 3.3.4.1.2 verifies the bypass capability is property functioning. changes. Note:

, SR 3.3.4.1.3 Consistent with STS STI.

I 3.3.4.1 2' LB1 CTS Table 4.2.8 The CTS RPT Initiate LOGIC CHANNEL FUNCTIONAL TEST 12/12/96 Acceptance of this l OOS Frequency is changed from 1 month to 92 days in the ITS. change is contingent i ITS SR Browns Ferry hee performed a plant specific evaluenon (not upon the NRC approval 3.3.4.1.1 eeforenced) and concluded that this instrumentation is consistent of GENE-77046-1 and

with the GE enslysis performed in GENE-77046-1. the BFN counterpart

report.

i Note: Consistent with STS STI.

! 3.3.4.1-3 L1 ITS 3.3.4.1 CTS Table 3.2.B. Note 17 allows testing for up to two hours 12/12/96 Acceptance of this .

OOS prior to declaring that the channel INOPERA8LE and REQUIRED change is contingent CTS Table ACTIONS taken. A ITS 3.3.4.1 Surveslience Requirements Note upon the NRC approval

3.2.8, Note 17 allows testing for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . of GENE-77046-1 and

' the BFN counterpart

! report. .

I' Note: Consistent with j' STS STI.

1 1

3 4

c 1

1 4 -

-._._..___..m_ _ . _ _ _ _ _ . _ _ . . . . _ _ _ _ . _ _ . . _ . _ _ . ...__.__m_- .. _._ _ . __. _ _ _ _ . _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ ._ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _._._m___.__--_-__%e, . _.___m______ . _ _ _ _ . _ _ _ _

i 1'

i l'

BFN ITS 3.3.4.1 - EOC-RPT INSTRUMENTATION

{ Table 3.3.4.1 Rv.1 DOC:; CTS /STS LCO 1 Deseeipenm of leeue -

Date Opened 'Dete Closed COMMENTS

.jFC X. .

i 3.3.4.1 4 L2 CTS Table CTS Table 3.2.8, Note 17 only allows declaring the system 1/17/97 Provide additional

!, OOS 3.2.8, Note 17 inoperable within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if one or more channels are docuesson and

! INOPERA8LE. This is reflected in ITS 3.3.4.1 REQUIRED ACTION justificecon for the note

! ITS 3.3.4.1, A.I. An option is provided in ITS 3.3.4.1, REQUIRED ACTION to proposed Action A.2.

t" REQUIRED A.2, for one or rnore INOPERA8LE channel (s) to place all 1

. ACTION A.2 INOPERABLE channels in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Note: Consistent with However, if this action would result in system actuamon, then STS AOT.

f declenne the system inoperable per ITS 3.3.4.1, REQUIRED

ACTION A.1, is the preferred action. -

3.3.4.1-5 L3 CTS Table CTS Table 3.2.8, Note 17, requires an orderfy power reduction to 1117/97 Provide additional l OCS 3.2.8, Note 17 be initiated imme&stely if both trip systems are INOPERABLE.

discussion and ITS 3.3.4.1, REQUIRED ACTION 8.1, allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore justification for why the ITS 3.3.4.1 one trip system to OPERABLE statue if both trip systems are changes do not pose a

, REQUIRED INOPERA8LE eignificant safety

. ACTION 8.1 problem in the operation I of the plant.

4 Note: Consistent with

, STS AOT.

. 3.3.4.1-6 L4 CTS Table 3.2.8 ITS 3.3.4.1.b and REQUIRED ACTION B.2 add an option to CTS 1/17/97 Provide additional

, Table 3.2.8 to allow increasing the MCPR limit by an appropriate discussion and 2'

ITS 3.3.4.1.b amount (specified in the COLR) if the instrumentation is justification for why the and REQUIRED INOPERABLE. addition of an MCPR ACTION 8.2 adjustment obviates a potential significant safety problem in the 1

operation of the plant.

Note: Consistent with

j, STS AOT.

)

!- 2 t

_ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ , . . . , - .~ ._______

i t

I1 BFN ITS 3.3.4.1 - EOC-RPT INSTRUMENTATION Table 3.3.4.1 Rv.1 1

1 ' TN DOC CTS /STS LCO : Deecaption of leave Date Opened Date Closed - COMMENTS -

'or i' JFC l 3.3.4.1-7 JFC ITS BASES STS BASES SR 3.3.4.1.5 statement that bypees valves are to be 12/13/96 Provide specific l P16 3.3.4.1 TSV closed during cohbration has been deleted in ITS 3.3.4.1. The justification for the STS j ,

Close Bases is modified to state that opening the bypass veives may devienon based on

, & offect operability of the Function if the velves are open above current Econsing basis.

3 STS BASES SR 30% RTP. The statement to consider the Function inoperable system design. or

? 3.3.4.1.5 unck- these conditions is deleted in ITS 3.3.4.1. operational constraints.

4 4

l 4

1 4

T 4

4 1

1 3

. i i

I BFN ITS 3.3.4.2 - ATWS-RPT INSTRUMENTATION TABLE 3.3.4.2 Rv.1

{

i DOC or L CTS /STS LCO) Deecription of losue c ^

Date Opened Date Closed ' COMMENTS '

JFC 3.3.4.2-1 M2 CTS Table 4.2.L ITS SR 3.3.4.2.4 adde requirements for LOGIC SYSTEM 1117/96 Provide justification that FUNCTIONAL TESTS. Since CTS Table 4.2.L does not specificaby the more restrictive

} ITS SR require this testing, the addition of this Survedience is an additional changes are within j' 3.3.4.2.4 restriction on plant operation. licensing basis i.

g .

assunptions.

i Note: Consistent with

, STS STL 3.3.4.2-2 LB1 CTS Table 4.2.L The CTS Table 4.2.L ATWS-RPT Initiate LOGIC CHANNEL 12/22/96 Acceptance of this t OOS FUNCTICNAL TEST Frequency is changed from 1 month to 92 change is contingent ITS SR days in ITS SR 3.3.4.2.2. A plant specific evaluation inot upon the NRC approval J 3.3.4.2.2 referenced) concluded that this instrumentation is consistent with of GENE-770-061 and t

the GE analysis performed in GENE-77046-1. the BFN counterpart report.

l 3.3.4.2-3 L2 ITS 3.3.4.2 CTS Table 3.2.L. Note 2 requwes the plant to be in HOT 2/27/97 Revise the DOC OOS REQUIRED SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the condition of one trip system justifications to address i ACTION C.1 inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or for the condition of both trip systems the proposed changes

. inoperable. ITS 3.3.4.2, REQUIRED ACTION 8 requires a the plant provided in the iTS j

CTS Table to be in STARTUP within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the condition of one ATWS ' markup.

i 3.2.L. Note 2 trip function inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.3.4.2 Action C allows I hour to restore the ATWS-RPT trip capability for one function

!. ; prior to initiating action to be in STARTUP. The CTS to ITS changes related to conditions of inoperability based on trip system vice trip function are not discussed in DOC L2. The additional hour to repair the condition of both trip systems inoperable is not docussed in DOC L2. The different shutdown tracit to Mode 2 in the ITS vice Mode 3 in the CTS is not discussed in L.2. Final' -

DOC L2 discusses the option to remove the associated

recirculation pump from service, yet this option was not adc54 in the proposed ITS.

1 i'

= _ - _ = _ _ _ - _ _ _ _ - _ - - _ - _ _ _ _ - _ _ _ - _ - - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - - _ - . . - - . - _ _ _ _

i 1

BFN ITS 3.3.4.2 - ATWS-RPT INSTRUMENTATION 2

TABLE 3.3.4.2 Rv.1 DOC or :.. CTS /STS LCO Description of issue Date Opened Date Closed COMMENTS JFC :

3.3.4.2-4 M.1 ITS 3.3.4.2 CTS Table 3.2.L. Note 2 provides a 6 hout AOT for channel repair 2/27/97 Provide a revised L1 4

REQUIRED before the channel must be declared inoperable or pieced in trip. DOC that specificany ACTION A The DOC M.1 is used to justify the change to tNs CTS includes discussion of requiremert. The L1 DOC is the appropriate. tNs proposed change.

CTS Table

, 3.2.L. Note 2 4

3.3.4.2-5 PSO STS SR STS SR 3.3.4.2.1 is modified in ITS SR 3.3.4.2.1 to apply only to 12/24/96 Provide specific 3.3.4.2.1 the Reactor Vessel Water Level-Low Function. TNs in effect. justification for the STS deletes the CHANNEL CHECK of the Reactor Steam Dome deviation based on Pressure. TNs change is not justified. current licensing basis.

systern design. or operational constraints.

4 2

_ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ . . . _ _ _ _ . _ . _ _ - _ _ _ . . . . _ _ _ _ . . _ _ _ _ _ __ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ . - . _ _ _ _ _ _ . _ _ _ . . - _ . _ . _ _ _ _ _ _ _ _ _ _ . _ . . __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ . _ . . . _ _ . _ . _ _ _ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ __-m * - r_ _ _ _ _ _ _ _ _ _ _ _ _ _

I 1.

4 l BFN ITS 3.3.5.1 INSTRUMENTATION l Table 3.3.5.1 Rev.1 t

i i _

DOC [ CTS /STs Leo r -~ , j- of Issue . Date Opened Dme Closed COMMENTS '

!- Or JFC-j 3.3.5.1-1 A3 CTS TaWe 4.2.B The Unit 1 CTS Table 4.2.8 calibration frequencies of 3 months for 1/20/97 This change to CTS 4

OOS Reactor Low Water Level, Reactor Low Pressure, and Reactor High Suvemence Test t i '

Water Level functions are not consistent with Unite 2 and 3 with e Interval is outside

enterval of 18 months for level and 6 months for preneure These theTS8 ocope of ,

--: are reRected in ITS Table 3.3.5.1-1 for Unit 1 as the j -: - - . . review.

same as these in the ITS for Unite 2 and 3. The change to the Provide h- and Unit 1 Survemence test intervalis jusefied as "wm be vm =8 '- ~- - for the less prior to Unit 1 recovery.* restrictive change.

] Note: Coneestent with !

STS STI. ,

t 4 3.3.5.1-2 LB1 CTS Table 3.2.8 An aNowed out of service time (AOT) for testing of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is 1/24/97 This change to CTS j OOS added to CTS Table 3.2.B. ITS 3.3.5.1, SR Note 2. allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Allowed Outage Time is i for testing prior to entry into -+ted Conditions and Requered :wtside theTSS scope of

] Actione. convereson review.

Acceptance of this

- change is contingent j , upon the NRC approval of NEDC-30936-P-A Note: Consistent with STS. 7

3.3.5.1-3 L81 CTS Table 3.2.8 The CTS Table 3.2.B. Note 1.A. AOT for repair, which allows 1/24/97 This change to CTS t

OOS pieceng CS, LPCI and HPCI channels in trip or restoring the channel Mowed Outage Twne is l to OPERABLE status, remains at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for aR Functions exceot outside theTSB ocope of !

l the menemum flow Functions, and is extended to 7 days for the conversson review.

- mirumum flow Functione in ITS Table 3.3.5.1-1. Acceptance of this l change is contmgent i upon the NRC approval of NEDC-30936-P-A

^

Note: Coneestent with STS.

I 2

i '

i t

i 1 9

g

y. , - -' ,,~mm.*-=.~w ,, ,,r, ne--~v--,-, ,,e,,,.- e e -Aw.m w ,..,w., =~,-r--.. ,,.w,, ..-,,,,% ..%.~.., .,,,..-.w,--...v.~.,- ..,.~,.-n-,. .w . 4 e=wr w- s."- --+','.r---- -e,.'- =+ ==

j . . .

?

i f -\

DOC CTS /sTS LCo Description of I u. Deie Opened D.te Closed ' COMMENTS

. Or JFC 1

3.3.5.1-4 L81 CTS Table 3.2.B The AOT for placing ADS channels in trip, or to restore the channel 1/24/97 This change to CTS 4

OOS to OPERABLE etetus, is extended to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months if HPCI or RCIC is Allowed Outage Twne is also INOPERABLE. or a deve if both HPCI and RCIC are OPERABLE. outside theTSB scope of c:r_.c . review.

9 Acceptance of this j change is conungent upon the NRC apswoval of NEDC-30936-P-A Note: Consistent with

) STS.

I 3.3.5.1-5 L81 CTS Table 3.2.8 The CHANNEL FUNCTIONAL TEST frequency (STI)is extended to 1/24/97 This change to CTS j OOS once per 92 days from monthly. Survedience Test 1

Interval is outside theTS8 scope of

conversion review.

4 Acceptance of this 4 change is contingent .

upon the NRC approval of NEDC-30936-P-A Note: Consistent with j STS.

i 3.3.5.1-6 Lt CTS Table 3.2.8 ITS 3.3.5.1, REQUIRED ACTIONS 8.3, D.2.1, and F.2 are added 1/24/97 Provide a corrected L1 I to CTS Table 3.2.8, Note 1. to allow placing an inoperable channel DOC.

in the tripped condition rather than declenng the associated

supported feature inoperable. This compensates for the inoperable i status of the channel, restores the single failure capability and

provides the required initiation capability of the instrumentation.

l Therefore, providing this option does not impact safety. However, i if this action would result in syster: actuation. then declaring the system inoperable is preferred.

1

] Required Action D.2.1 is deleteJ by JFC P81. DOC L1 is j incomplete in that it does not iJentify and discuss the difference i between the CTS requirements of Action A and the proposed l replacement actions in the ITS, Actions B. C, D. F. and G. The Action repair AOT in the STS are based on NEDC-30936.

i.

2

,.__- . ~ . _ _ _ _ _ . . - - - . . , _ __ . - _ - . - - - .

, t 4 6 4

I i

4 i

i DOC L CTS /sTS LCO ' Description of leave Date Opened Date Closed COMMENTS i Or JFC.

i J_ 3.3.5.1-7 JFC P11 ITS Table ITS Table 3.3.5.1-1. Functions 1.c and 2.c required actions are 3/3/97 Reject proposed 3.3.5.1-1 and changed from STS 3.3.5.1 Regiered Action C.1 to Required changes, base approval

! ITS Functions Actione B.1 for Modes 1.2 and 3. ITS 3.3.5.1 RA C.1 requires of ITS on NEDC-30906 5

1.c. 2.c restoring channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.3.5.1 ,

i RA 8.1 requires pieceng channelin trip after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The s changes to the Required Action from restoring operabiltiy to ,

piecmg the channelin trip is not justified and deviates from the CTS and from the

. STS. Bases insert 83.3-101 A states that there are two reactor

) ,

steem dome preneure "e . _._ _;) trenervetters per system

]- arranged in a one-out-of-tyro logic. The required channels column .

! in Table 3.3.5.1 1 is 4 The STS is bened on the staff approved Topical Report NEDC-30936.

l 3.3.5.1-8 JFC P35 JFC P35 The STS 3.3.5.1 REQUIRED ACTION G.I. Note that describes 3/3/97 Reject proposed ITS.

j APPLICABluTY for functione 4.c. 4.e. 4.f. 4.g. 5.c. 5.e. 5.f. and Provide Rev.B submittel i STS Table 5.g is deleted. Justification for deleting the APPLICABIUTY for ITS pages that include l 3.3.5.1-1 and Table 3.3.5.1-1 functione 4.g, and 5.g only is presented. No manuelirutseson i STS REQUIRED justification for deleting the APPUCABluTY for functione 4.c. 4.e. requiremente.

i ACTION G.I. 4.f. 5.c. 5.e. and 5.f is given.

Manuel initiation channel requiremente are deleted because these

, channels are not currently required at BF and because eingle switch

} logic design does not exist at BF The staff requires the manuel i initiation functione.

i 4

3 e

t

._____.___._sm__ _ _ _ _ _ . . _ . _ . _ . . . _ _ _.m__.__ _ _ _ _ _ _ _ _ _ _ . . . . _ . _ . _ . - .

m_ m ._.._..._.-..m_m. -

DOC. CTS /STS LCo Description of issue Det. open.d Dete closed COMMENTS or JFC 3.3.5.1-9 none CTS Table 3.2.8 CTS Action A is changed to ITS Action B. C. D, F, and G. In the 3/3/97 Provide Rev.B subettal Actions ITS format CTS Action A is only equivalent to Action C. pages that include discussions of changes to existing CTS action requirements.

3.3.5.1-10 P59 ITS Table Channel check requirements are not adopted from the STS 3/3/97 Reject proposed ITS.

3.3.5.1-1 because they are not current licensing basis requirements.

Provide Rev.B submittal pages that include manual initiation requirements.

3.3.5.1-11 P-76 ITS Table Proposed footnote (e) clarifies the trip system channel 3t3/97 Provide Rev.B submittal P-74 3.3.5.1-1 assignments. The footnote discussed relays without providing a pages that include a connection to the TS requirement for required channais per reworded footnote (e).

function.

3.3.5.1-12 P-82 STS function The Rev.A submittal stated LPCilow flow bypass function is not 3/3/97 Provide e copy of the 2.g included because the analysis assumptions will acheive rated staff SER that accepts iriection with the bypass valve open. this accident analysis assumption.

3.3.5.1-13 P-8 Bases NEDC-30936 is incorporated by refemco 3/3/97 Provide a copy of the References strJf SE approving this Topical Report for BFN Units 1,2, and 3.

3.3.5.1 14 none ITS Table The core spray low level (function 1.a) and the HPCI level 8 3/4/97 Provide CTS merkup 3.3.5.1-1 (function 3.c) are proposed iSTS functions that have no references with functions 1.a. corresponding CTS table entry. associated DOCS.

3.c 3.3.5.1-15 LA.1 CTS Table 3.2.B The LA.1 DOC discusses relocating trip setpoints to owner 3/4/97 Prowse Allowable documents and retaining the CTS Allowable Values in the ITS. For Values for the iTS.

this CTS table the " trip level settings" column is simp!y renamed Show that proposed

" Allowable Value" in the ITS format. The Allowable Values do not limts are based on en exist in the CTS. approved methodology 4

2 BFN ITS 3.3.5.2 RCIC SYSTEM INSTRUMENTATION Table 3.3.5.2 Rv.1 i

DOC or.. CTS /STS LCO ~ Desenption of leeue ' Date Opened Dete Closed COMMENTS JFC

. 3.3.5.2-1 LB1 CTS Table 3.2.8 A 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months aNowed out of service time (AOT) for testing is added to 1/24/97 This change to CTS 1 OOS CTS Table 3.2.B. ITS 3.3.5.2. SR Note 2. aNows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for ANowed Outage Time is testing Prior to entry into associated Conditions and Required outside theTSB scope of Actions. conversion review.

The CHANNEL FUNCTIONAL TEST surveinance test interval (STI) is Acceptance of this extended from the CTS Table 3.2.8 monthly to once per 92 days. change is contingent j upon the NRC approval of GENE.770-06 2 February 1991 Note:

Consistent with STS.

3.3.5.2-2 LA.1 CTS The LA.1 DOC discusses relocating trip setpoints to owner 3/4/97 Prowde Allowable Table 3.2.B documents and retaining the CTS Allowable Values in the ITS. For Values for the ITS.

this CTS table the " trip level settings" column is simply renamed Show that proposed

ANowable Value* in the ITS format. The Allowable Values do not limits are based on an exist in the CTS. approved methodology.

3.3.5.2-3 none CTS Table 4.2.8 CTS requirements to perform a channel calibration at 3 month 3/4/97 Provide a DOC for the j intervals is changed to 18 months without a justification. proposed change and a ITS SR revised ITS markup if 3.3.5.2.3 necessary.

3.3.5.2-4 none ITS Table - Function 5. Manual initiation is deleted frorn the ITS adoption of 3/4/97 Reject proposed ITS.

3.3.5.2-1 the STS. Manual initiation channel requirements e,re deleted Prowde Rev.B submittal because these channels are not currently required at BF and pages that include because single switch logic design does not exist at BF. The staff manual initiation requires the manual initiation functions. requirements.

e 1

4

}

_ _ _ __. , . . , . . ,, , . - . , . - - . - - -~, -

i . .

3 i

BFN ITS 3.3.6.1 PRIMARY CONTAINMENT ISOt.ATION INSTRUMENTATION i Table 3.3.6.1 Rv.1 i

4 5 - - -

_( ,

! Docor CTstsTs LCo e - of leeue i Date Opened Date Closed COMMENTS i

g-.

-1 3.3.6.1-1 All CTS Taide CTS Table 3.2.A. Note 15, dennes the Reector Buddmg Ventilemon 2/3/97 Provide a not used 3.2.A. Note 15 Rademon (R8VR) trip functions for the refueling zone and the ' yr_% for the All i reactor zone se each being : . M of two dvisional trip DOC iri Table 3.3.6.1-1 systems with sech trip system having one channel which containe two sensors, both of which must be OPERABLE. ITS Table 3.3.6.1-1 depicto each trip system as hovmg two channele,

, meenmg each eeneer is considered a channel.

1 1

The justification for change documented a change to ITS Table j 3.3.6.1 1, when the change was irnplemented in ITS Table j 3.3.7.1 1. The RSVR trip functione are located in ITS Teble j 3.3.7.1-1 not 3.3.6.1-1, 3.3.6.1-2 A12 CTS Table 4.2.A The RWCU Temperature functions in CTS Table 4.2.A for Unit 1 3/5/97 Provide discussion and are not consistent with those listed in CTS Table 4.2.A for Units 2 justification for the

)

and 3. The Unit 1 CTS Table 4.2.A cahbration frequency of these proposed changes functions is en operating cycle versus 4 months for Units 2 and 3.

However, ITS Table 3.3.6.1-1 for Unit 1 is consistent with Units 2 and 3.

i j The change modfies the Unit 1 oction requirements without

] :' - . ?,h ;i what changed and without presenting a safety justification for proposed requiremente.

l 3.3.6.1-3 A13 CTS Table 4.2.8 The Unit 1 CTS Table 4.2.8 cabbretion frequeness for the RCIC 2/4/97 This change to CTS STI l OOS and HPCI Turbine Steam Line Low Pressure functions are 3 is outside theTSB scope j months. This is not consistent with the 18 month interval of Units of conversion review.

2 and 3. These frequencies are included in ITS SR 3.3.6.1.5 e 18 l month intervals for all units. Provide discussion and d

justification for the less l The change is presented as e administrative change rather then a restrictive change.

less restrictive change of the surveillance testing of Unit 1.

i i

1 1-i 8FN ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION I

Table 3.3.6.1 Rv.1 t

. DOCer: CTS /STS LCO L t -- a : ofleeue Date opened Date Closed COMMENTS

, JFC1 3.3.6.1-4 A14 CTS Table 4.2.8 The Unit 1 CTS Table 4.2.8 CHANNEL CHECK requerements for the 2/4/97 Prowle discuseson and i RCIC and HPCI Turbine Steam Une High Flow and Exhaust justificecon for the lees j JFC Diaphragm High Pressure functione are daily. These Unit I restrictive change.

, P74 CHANNEL CHECKS are deleted from ITS Table 3.3.6.1-1.

4 The change is presented se e admwustrative change rather then e lose restrictive change of the surveslience testing of Unit 1.

i 3.3.6.1-5 M3 CTS Table The CTS Table 3.2.A. Note 1. Action for ITS Table 3.3.6.1-1, 2/4/97. Provide discussion and

3.2.A. Note 1.A. Functions 2.e (Reactor Low Water Level) and 2.b (High DryweN jusefication for the lose i 1.8.1.E Preneurel and the w _;: ./.;..,, Group 2 initiating logic requires restrictive change.

Table 3.2.A. Note 1.A actione (initiate en orderly shutdown . . .) or Note 1.8 octione (to initiate en orderly load reduction and have the

'- MSLe isoleted) along with Note 1.E actione (to initiene pnmery 1~ containment isolation within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

1 The ITS Table 3.3.6.1-1 REQUIRED ACTIONS A.1 (Place charmet l in trip within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). 8.1 (Restore iscianon - ; '- - :p within 1 [

hour). and G.1 (Be in MODE 3 in 12 house). for these Functione are -l

consistent with the STS. CTS Table 3.2.A. Note 1. does not j j include the ITS 3.3.6.1. REQUIRED ACTION G.I.

t .

This change deletes the CTS Table 3.2.A. Note 1.E Action and r adde the third option of ITS 3.3.6.1 REQUIRED ACTION G.I. This I is a lose restrictive change that wee addressed as e enore i j restrictive change.

i i

4 l

t i

i 1 . e t

W T - * *WFe y'*Fw--'i7et.' =mws me-W*- 'MT.-es em y a y=-y.er g p yy_'yy yygir% 1 T-geg gg ,9 gwwy.,-ag -g.+.. *-.gw gg. .opm iag-t%*"^5"'W"W'-WTTF*'-d">eeM't F='PM"B"'*rvM-+b'=h'WE'=p*tr-t'P-"'+-' PM-1111 TWTMb 7 "+99--' T*"t *T9'i#"'F'*I"~9' . T 1 '4">- *" **W

(

BFN ITS 3.3.6.1 PRIMARY CONTAINMENT ISOt.ATION INSTRUMENTATION Table 3.3.6.1 Rv.1 DOCor' CTS /STS LCO r[ '-; t oflocue Date Opened Date Closed COMMENTS i y,

3.3.6.1 6 LB1 CTS Table The allowed out of service time (AOT) for placeng a channelin trip 2/1/97 This extension of AOT OOS 3.2.A. when one trip system has inoperable, untripped channels, ao le outside theTSB ocope h te 1; denned in CTS Table 3.2.A. Note 1 is extended froen immedsete to of ca._ _ -. review.

hte 11; 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in ITS 3.3.6.1, REQUIRED ACTION A.1, for those Provide discussion and channele common to RPS, and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in ITS 3.3.6.1, REQUIRED justificamon for the less ACTION A.2. for all other channels. A .'-- " _ for this AOT restrictive change extensson wee not provided. Acceptance of thie change is contingent The AOTs for piecmg a channel in trip for required survesilence upon the NRC approval

. testing is defined in CTS Table 3.2.A. Note 11, armi is extended of NEDC 30651.P-A, from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.6.1, Survemance Requirements 9. 2:2.

Note 2. A justification for this AOT extension wee not provided.

The monthly CHANNEL FUNCTIONAL TEST Survemence Test interval (STIl in CTS Table 3.2.A is extended in ITS SR 3.3.6.1.2, to once per 92 days. A justification for this STI extensson was not provided.

3.3.6.1 7 LS CTS Table ITS 3.3.6.1, REQUIRED ACTION F.1 allows I hour to isolete the 3/5/97 Provide revised 3.2.A. Note 1.C affected Reactor Water Cleanup (RWCU) penetration flow path (el, submittal pages.

wheroes CTS Table 3.2.A. Note 1.C. requires immediately isolating CTS Table the RWCU valves and CTS Table 3.2.8 Note 1.8 requires 3.2.8, Note 1.8 emmediately declaring the HPCl/RCIC inoperable.

Note E markup for Table 3.2.8 deletes the allowance to place the channelin trip. Note E markup should show that the option to repair the channel or piece it in trip is equivalent to ITS Action A.1.

4

i BFN ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION Table 3.3.6.1 Rv.1 I

i DOC or CTS /STS LCO Description of losue Date Opened Date Closed COMMENTS JFC l

j 3.3.6.1 -8 None CTS Table 4.2.A The RWCU Temperature functions in CTS Table 4.2.A for Unit 1 2/7/97 Provide a justification are not consistent with those listed in CTS Table 4.2.A for Units 2 for proposed changes STS 3.3.6.1 and 3. The Unit 1 functions temperature functions use the RWCU based on current 1

floor drain temperature and RWCU space temperature. Units 2 and licensing basis. plant 3 uses 6 eroe space temperatures, design, or operational constraints.

The STS assumes six space temperatures. This deviation from the STS was not addressed. However some discussion was provided

, in the justification for en administrative change. The justification indicated that the differences wouM be addressed before Unit 1 I recovery.

3.3.6.1-9 LA1 CTS Tables System design and operational details found in CTS Tables 3.2.A. 3/5/97 Provide Anowable OOS 3.2.A. 3 2.B. 3.2.8. and 4.2.a. are moved to the ITS Bases and plant Values for the ITS.

4.2.a procedures. Trip setpoints are an operational detail not directly Show that proposed related to the operability of the instrumentation. The AHowable limits are based on en Value is the required limitation of the parameter and this value is approved methodology.

retained in ITS Table 3.3.6.1 1.

The LA.1 DOC discusses relocating tnp setpoints to owner documents and retaining the CTS ARowable Values in the ITS. For this CTS table the "tnp level settings" column is simply renamed

ANowable Velve* in the ITS format. The Allowable Values do not exist in the CTS.

3.3.6.1 10 LA2 CTS Tables Details of the methods for performing surveillances found in CTS 3/5/97 Provide revised 4.2.A Table 4.2.A. are moved to the ITS 3.3.6.1 Bases and plant submittal pages.

procedures.

f CTS markup on page 3.2/4.2-43 RWCU floor drain and Space Tomperature high should be LB.1 NOT la.2 i

1 i

i s

BFN ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION Table 3.3.6.1 Rv.1 DOC or ' CTS /STS LCO Description of leeue Date Opened Date Closed COMMENTS JFC

3.3.6.1-11 P11 & ITS Cordtion B Proposed change delete manuelirutistion functions and 3/6/97 Reject proposed i P35 & Manual *eutomatic* from loss of isolation capability action because the changes to the iSTS.

initiation functions are not current requirements and single switch isolation Provide revised functions is not consistent with the BFN design. The staff position is that submittal pages that manual actuation capability was a licensing basis of the design and include the manual without which the design would not be meet regulatory design actuation features.

criteria. The absence of CTS manual requirements is an oversight which should be corrected. Further. current TS logic testing requirements require a complete test of the circuitry includmg the manual actuation functions.

I 3.3.6.1-12 P11 Table 3.3.6.1-1 RWCU isolation functions are added to the current TS functions. 3/6/97 Provide a discussion of Function 5.a The SRs proposed include the same SRs as the CTS RWCU leve 3 change that justifies the through 5.f isolation except a 122 day channel caiibration is proposed and no 122 day channel channel check is included, calibration interval and the absence of the channel check requirement.

3.3.6.1-13 P25 ITS Condition A. Proposed ITS markup is not identical to the CTS bypass allowance. 3/6/97 Provide revised Completion Time CTS provide the bypass for conditions of normal steam tunnel submittal pages and LA.3 logical OR, R ventilation becorrung inoperable. The proposed ITS provides an discussion of changes phrase allowance to bypass the trip of Function 1.d (Main Steam TunneI to accommodate the Temperature High) for conditions of loss of Inp capability. CTS allowance without additional relaxations to the operating limits for MSL Tunnel Temperature high.

3.3.6.1-14 P83 ITS Function 6.a Deleted TS for RHR shutdown cooling isolation in Modes 4 and 5. 3/6/97 Provide corrected Licensee agreM to revise the ITS to include the isolation functions. submittat pages es past of Rev. B.

i

BFN ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION Table 3.3.6.1 Rv.1

?

DOC or CTS /STS LCO Description of losue Date Opened Date Closed COMMENTS a

.lFC 3.3.6.1-15 A.7 CTS Table 3.2.A The CTS note requires the affected system to be declared 3/6/97 Please explain the Note 1.D inoperable efter closing the RHR shutdown cooling isolation valves. intended meaning of The justification states "an action requiring the effected system to this justification.

be declared inoperable is en unnecessary reminder that other TS may be affected.

3.3'.6.1 16 M.8 CTS Table 3.2.8 Proposed Action F.1 requires the licensee to isolate the effected 3/6/97 Prr, vide revised

, penetration flow path for specific HPCI and RCIC functions rather httal pages for M8.

than declare the system or component inoperable. ITS Action A.1 requires the channel to be tripped in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months vice the CTS requirement to repair the channelin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The difference between the trip versus repair actions is not discussed.

3.3.6.1-19 none CTS Table 3.2.B Evaluate the markup for revision. Deleted text is retained in ITS. 3/6/97 Provide appropriate Note 1.E DOC discussion is missing for deleted text. justification es necessary.

3.3.6.1-20 M.9 CTS 3.2.A CTS 3.2.A requires primary containment isolation instrumentation 2/7/97 Provide OPERABLE when primary containment integrity is required. CTS discussion 3.7.A.2.a. primary containment integrity is required OPERABLE at and all times when the reactor is critical or when the reactor water justification temperature is above 212T and fuelis in the vessel. The ITS for the more 3.3.6.1 Applicability for most functions is MODES 1,2. and 3. restrictive This is more restrictive since CTS 3.7.A.2.a. does not require the change.

primary containment integrity when in MODE 2. not critical and < Note:

212T. This change 6s consistent with the STS. Consistent with STS The justification did not justify adding the Applicability for < AOT.

, 212T.

1

-,e- - - ,. - ,, , , - - . , . , . - , -v-

BFN ITS 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION Table 3.3.6.2 Rv.1 DOC or CTS /STS LCO Description of issue Date Opened Date Closed COMMENTS JFC 3.3.6.2-1 M1 CTS 3.2.A CTS 3.2.A comtuned with CTS 3.7.A.2.a, Pnmery Containment. 02/10/97 Provide justificaton for requires pnmary contamment integrity at su times when the reactor the more restrictive is critical or when the reactor water temperature is above 2121 change addmg and fuel is in the vessel. ITS Table 3.3.6.21 requires the applicatulity in MODE 2 secondary containment isolenon instrumentation OPERABLE in conditions of not critical MODES 1, 2 and 3. Since the CTS does not require primary and < 212T.

contamment integrity when in ITS 3.3.6.2 MODE 2 conditions of not critical and < 212T. this is a more restrictive change . No justification is provided for this more restrictive change.

3.3.6.2-2 A5 CTS 3.7.A.2.a CTS 3.7.A.2.a does not require pnmery contamment integrity 02/10/97 Provide discussion and

while performing 'open vessel

physics tests at power levels not justification that to exceed 5 MWit).* ITS 3.3.6.2 does not contain this exception. addresses open vessel The justification is based on the prowseons of ITS 3.0.8 which physics tests.

Indecotes Special Operations in ITS 3.10 allow chenyng specified TS requirements. However ITS 3.10 does not address "open Vessel

physecs tests.

3.3.6.2-3 P44 STS 3.3.6.2 SR ITS 3.3.6.2. SR Note 2. deletes " secondary containment

from 02/10/97 Provide justification for Note 2 STS SR Note 2. the STS deweben bened on Current Licename STS 3.3.6.2 ITS 3.3.6.2. ACTION 8 modifies STS 3.3.6.2 ACTION 8 by Beeis, system design, or ACTION B.1 removing the words

secondary containment *. operemonal constreints.

The changes were made based on being unnecessary since they are a part of the title for ITS 3.3.6.2.

3.3.6.2-4 L2 CTS Table CTS Table 3.2.A. for Reactor Low Water Level and High Drywell 02/10/97 Provide justification for 3.2.A. Pressure, for less then the minimum required OPERABLE channels, deleting the CTS Note 1 provides the options when ACTION Note 1 are met. These option requirement to Shutdown are: Il place the reactor in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (ACTION or isolete the Main Note 1.A) or 2) initiate a load reduction and isolete the Mesn Steam Steam Lines.

Lines within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (ACTION Note 1.Bl and initiate primary containment isolation within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (ACTION Note 1.E). For the same Functions ITS 3.3.6.2. Required Actions C.1.1. C.1.2. C.2.1 and C.2.2 do not require entering cold shutdown or isolating the Mein Steam Lines but, provide options, when P.equired Actions A.1 and 8.1 are not rnet. allowing isolation of the effected lines (zones)

j _

j . .

1, l

l BFN ITS 3.3.6.2 SECONDARY CONTAINMENT ISOt.ATION INSTRUMENTATION j Table 3.3.6.2 Rv.1 and starting the affected SGT subsystems (ITS 3.3.6.2 Required

Actions C.1.1 and C.2.1). If this option is not chosen, then the effected c- _.;s must be declared inoperable (ITS 3.3.6.2,

Requwed Actione C.1.2 and C.2.21.

1

! No justificatioc, bened upon safety analyses,is provided for i delseng the CTS requirement to shutdown or isolete the Main I Stearn Lines, j

i 3.3.6.2-5 AS CTS Table 3.2.A ' CTS Table 3.2.A and Table 4.2.A provide separate ACTIONS and 02/12/97 Provide addmonal j and Table 4.2.A SRs for Secondary Contamment loolomon instrumentation wetieteng h m and i . and isolation logic (Reactor Buddmg isolabon Logic SGTS Traine A. }-

' ^ -

a 8, and C Logic and Group 6 Logic). ITS 3.3.6.2 deletes the demonstrating that the -

Reactor Buddmg W~n and SGTS Logic functione (including ITS Required Actione and

. ACTIONS) and incorporates the SRs required by the CTS for these Survedlances encompees i functions into required SRs of ITS Tatde 3.3.6.2-1. The discussion the CTS Required and justification does not demonstrate that ITS Required Actions Actione and

. - and SRs encompose the CTS Required Actions and SR for the logic Survedlances.

functions.

3.3.6.2-6 L81 CTS Table 4.2.A ITS 3.3.6.2 SR 3.3.6.2.2, CHANNEL FUNCTIONAL TEST, extends 02/13/97 Extensson of Surveillance i OOS _

the Survesliance Test interval for the CTS Table 4.2.A Channel Test intervale is outside i' CTS Table Functonal Teste from monthly to once per 92 days. theTSB ocope of

{ 3.2.A. ACTION c -. _ c review.

l 1 ITS 3.3.6.2, Requered Action A, extends the time in CTS Table *

3.2.A. ACTION 1, for tnppeng en inoperable channel from Acceptance of this

, CTS Table immedsetely to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for those channels common to RPS and change is conangent j 3.2.A. Note 11 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for all other channels. upon NRC approval of i .

NEDC-3OSSI-P-A, 'i l

ITS 3.3.6.2, SR Note 2, extends the Allowed Outage Time for Supplement 2, March "

j performme survediences in CTS Table 3.2.A. Note 11, from 4 to 6 1989, NEDC.31677-P- A, t - hours. July 1990 and NEDC-

i. 31677-P-A, July 1990, j These changes are based on maintaining an acceptable riset in for thse application.

}' accordance with previously conducted reliability analysis (NEDC

, 30851-P-A, S ,, * . .t 2, March 1989 and NEDC-31677-P-A, This change is consistent l July 1930). This is en extension of Allowed Outage Time, with the STS bracketed ;

l value. ,

i . 3.3.6.2 7 A6 CTS Table 3.2.A ITS 3.3.6.2, Required Actions C.1.2 and C.2.2, add ACTION 3 to 02/13/97 Provide discussion and 4

' CTS Table 3.2.A that require declaring the associated systems justification for the 1

inoperable within 1 hout if secondary containment isolation or . hout COMPLETION TIME.

starting the SGT System is not possible or deswed. The addition of 4 . i e

t

4 1

1 i i 4

BFN ITS 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION i, Table 3.3.6.2 Rv.1 t

more restrictive requirements is not administrative. Additionally, no justification is provided for the 1 hout completion time.

4 3.3.6.2-8 LSI CTS Table ITS 3.3.6.2. SR Note 3. extends the Allowed Outege Tune for 02/13/97 Extension of Allowed

{ OOS 3.2.A. Note 11 perform.no survediences in CTS Table 3.2.A. Note 11. from 4 to 6 Outage Time is outside

?

hows for a CHANNEL FUNCTIONAL TEST. These changes are the TS8 ocope for stated to be bened on maintaining en acceptable risk in accordance conversinn Review.

with previously conducted reisetuhty onelysis (NEDC 30851-P-A.

j S,, . 4 2. Merch 1989 and NEDC-31677-P-A July 1990). ' Acceptance of ins i This is an extension of Allowed Outage Twns. change is contmgent

, upon NRC approval of PIEDC-30851-P- A.

1~

9.._ _ - 2. March

j. 1989. NEDC-31677-P-A.

July 1990 and NEDC-1 31677-P-A. July 1990, 4

for tNo =;-;--

_^ . and agreeing tNs proposed change is included in the I

scope of the NEC topical reviews.

l This change is not i

consistent with the STS.

3.3.6.2-9 A10 CTS Table 4.2.A ITS Table 3.3.6.2-1, Functions 1 and 2. Reactor Vessel Water 02/13/97 Extensson of Survedlance Level- Low and Drywell Pressure High, respectively, increase the Test Intervel (for Unit 1)

CTS Table 4.2.A Unit 1 CHANNEL CAU8 RATION Surveillance Test is outside theTS8 scope q interval, for the same functions, from 3 months to 18 months. of corwersion review.

j TNs change is implemented to make the Unit 1 ITS be consistent with Units 2 and 3 ITS. TNs is an exteneson of Surveillance Test TNs change is consistent Interval for Unit 1 is not justified, with the STS bracketed value.

3.3.6.2-10 None CTS Table 4.2.A CTS Table 4.2.A does not require ea Instrument Check for the High 02/14/97 Provide discuseson and i Drywell Pressure Function. ITS Table 3.3.6.2-1. Function 2. justification for adding Drywell Pressure - High. requires SR 3.3.6.2.1 CHANNEL CHECK the survesitance test and

f. overy 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . No justification is genvided for adding this the proposed survedience survedlance test or deviating from the ISTS rest frequency. interval.

3.3.6.2 11 P23 STS 3.3.6.2. The Completion Twne for STS 3.3.6.3. Required Action A.I. is 12 02/14/97 Acceptance of this OOS ACTION A ' hours for Function 2 and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the other Functions. ITS change is contingent 4

z 2

i t

k i

BFN ITS 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION j -Table 3.3.6.2 Rv.1 j .

' 3.3.6.2 Required Action A.1, modifies the Completion time to 12 upon NRC approval of

hours for Functions 1 and 2 and 24 houre for the other Functione. NEDC-30851-P-A, i This change is based on NEDC-30851-P-A,9. . . ; 2. March I ,. .._. t 2. March j 1989, NEDC-31677-P-A July 1990 and GENE-770-06-1, February 1989, NEDC-31677-P-A, i 1991. July 1990 and GENE-

!. 770-06-1,Falwuery j 1991, for this 2

i 3.3.S.2-12 P63 STS 3.3.6.2 SR ITS 3.3.6.2 adde SR Note 3 to STS 3.3.6.2 Survedlance Notes. 02/14/97 Acceptance of thie l* OOS Notee ITS 3.3.6.2. SR Note 3, allows one inoperable channel of the change is contmoent Remotor Zone and Refuelme Zone Exhaust Pa% System for up upon NRC approval of

! to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for CHANNEL FUNCTIONAL TESTING and for up to 24 NEDC-30851-P-A, hours for CHANNEL CALIBRATION and maintenance as long as the " .. ..Z 2, March downscale trip of the inoperable channel is placed in the tripped 1989, NEDC-31677-P-A,

, condition. The CTS provides the same allowance except ordy 4 July 1990 and GENE-l hours is allowed for the CHANNEL FUNCTIONAL TEST. Extending 770-06-1, Felwwery j 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is based on rehabihty analysee in NEDC-30851- 1991, for this P-A, NEDC-31677-P-A and GENE-770-06-1. .. ---

, 3.3.6.2 13 LA1 CTS 3.2/4.2 CTS 3.2 and 4.2 System dessen and operamonal details are moved 02/17/97 Provide Allowable Values

OOS to the iTS 3.3.6.2 Bases and plant procedures. for the ITS. Show that

. proposed limits are bened

( Trip setpointo are an operobonal detail not directly related to the on an approved

operability of the instrumentanon. The Allowable Value is the - .cl '- 7;.

requwed limitation of the parameter and this value is retained in ITS Table 3.3.6.2-1.

i .

{ The LA.1 DOC discusses relocating trip setpoints to owner l documents and retaining the CTS Amowabis Values in the ITS. For j this CTS table the " trip level settmos" column is sempty renamed i " Allowable Value" in the ITS format. The ANowable Values do not i exist in the CTS.

3.3.6.2-14 P35 none Proposed change delete manual wumanon functions and 3/6/97 . Reject proposed changes

" automatic" from loss of isolomon eacMty action because the to the iSTS. Provide

functione are not current requirements and single switch isoletion is revised submittal pages not consistent with the BFN design. The staff position is that that include the manual I manual actuohon capability was e licenomg beeis of the design and actuamon features.

without which the doesgn would not be meet reguietory design

[ criteria. The absence of CTS manual requirements is an oversight i .. which should be corrected. Further, current TS logic testing ,

requirements require a complete test of the circuitry including the i'

4 s

4 2

t BFN ITS 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION Table 3.3.6.2 Rv.1 manual actuation functione.

e e

l l

4 4

4 k

4 Y

1

__--- +

__w-__-___---,--------___.u- _. - --- - - - - , - - - - ----- _ . _ _ - - - --a-----

I '

l r

4 i I i

l BFN ITS 3.3.7.1 - CONTROL ROOM EMERGENCY l VENTILATION SYSTEM INSTRUMENTATION i Table 3.3.7.1 Rv.1 4

l DOCor CTS /STS LCO ; Desonption of leeue . Date Opened Date Closed COMMENTS

JFC.

i j 3.3.7.1-1 A.2 CTS Table 3.2.A The CTS Actions for ITS Functions 1 and 2 require the operator to Provide revised DOC l Action Notes for initiste en orderly load reduction and have Main Stoem Lines filee to justify proposed ITS functione 1, isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or initiete pnmery containment isolation changes and 2 witun 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the required channels are not met for one trip system and the function is not tnpped or if the required channels cannot be met for all trip systems. The ITS requirements for these ,

i functione is to trip inoperable channels in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or declare the - t essociated CREV subsystem inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of I loss of trip creebility in both trip systems.

DOC A.2 Joes not address oil of the proposed changes to CTS requironwnts. Administrative justifications cannot riot be proposed for less rest:ictive changes.

l.

3 I

i !

1 a

4 6 t e i

, 1 i

i

. . t i.

i

! - BFN ITS 3.3.7.1 - CONTROL ROOM EMERGENCY j VENTILATION SYSTEM INSTRUMENTATION i

Table 3.3.7.1 Rv.1 i DOC or; CTS /STS LCO Deecaption of leave Date Opened Date Cloose COMMENTS g ' c 3.3.7.1-2 A.2 CTS Table 3.2.A The CTS Actione for ITS Function 3 require the operator to isolete 3/7/97 Provide revise DOC files

, Action Notes for the reactor taaldmg and start the SGTS immedsetely if the to justify proposed j P46 ITS functions 3, required channels are not met for one trip system and the function changes

! and 4 is not tripped or if the required channels cannot be met for all trip 1 systems.

4 The CTS Actions for ITS Function 4 prohibit fuel handling and all operations over opent fuel and open roector wolle if the required i channels are not rnet for one trip system and the function is not j tripped or if the required channels cannot be met for all trip ,

systems.

i The ITS requiremente for these functions is to trip inoperable l channels in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or declare the associated CitEV subsystem ,

j_ inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of trip capetJity in the trip $

j system.

. DOC A.2 does not address all of the proposed changes to CTS i requirements. Administrative justificatione cannot not be proposed

for less restrictive changes.

1 3.3.7.1-3 DOC- CTS Table 3.2.G For two inoperable channels CTS require a functional test of the 3/7/97 Provide appropriate j none Action 2 is ITS particulate and radiation monitors once per shift. In addition. CTS discussion of change a function S actions provide a description of the use of these alarms for high justifications. ;

P46 radiation conditions. The required actions for failure to repair at I least one channel in 30 day is ITS Action E.1(place the CREV in operation). The CTS requires talting the actions specified in section 3.1.E.

Changes to the CTS Action 3.1.E are not identified and not evaluated.

i 4

2

J 1 . .

i.

I 1

4 4

, BFN ITS 3.3.7.1 - CONTROL ROOM EMERGENCY VENTILATION SYSTEM INSTRUMENTATION 1

Table 3.3.7.1 Rv.1 1

i DOC or CTS /STS LCO > Description of leeue f Dete' Opened Dete Closed COMMENTS .

JFC' - l ':

, 3.3.7.1-4 A-5 CTS Table 4.1.8 h Unit 1 CTS Table 4.2.A calibration frequency for the High 1/31/97 This change to CTS l OOS Drywell Pressure function is changed from 3 rnonths to 18 months Survedlance Test

, in ITS Tatde 3.3.1.1 1 Functions 3,4 & 6 to duplicate the less Interval is outside the

restrictive frequencaos of Unite 2 & 3 CTS Tatdo 4.2.A. The TSB ocope of

{ change is presented as en admmistrative change resulting in ITS -x-c_ -_ review.

i Table 3.3.7.1-1. Function 2. rather then as a lose restrictive Provide discussion and i change. justification for the less i restrictive change.

3.3.7.1-5 M1 CTS Table 3.2.A ITS 3.3.7.1. REQUIRED ACTION E.1 allows the option of placing 1/31/97 Provide justification for Note 1 CREVS in the pressurization mode of operation. CTS Table 3.2.A. the more restrictive

Note 1. does not allow this option. Required Action E.1 is more change.

! restrictive on CTS page 3.2/4.2-12 and Required Action E is less restrictive on page3.2/4.2-34.

h addition of a less restrictive change is not more restrictive.

3.3.7.1-6 L81 CTS Toble 3.2.A The ellowed out of service time (AOT) for placing a channelin trip 1/31/97 This change to CTS 4 OOS when one trip system hoe inoperable, untripped channels, is Allowed Outage Twne l' JFC defined in CTS Table 3.2.A, Note 1. is extended from immedsete to (AOT)is outside the P63 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in ITS 3.3.7.1. REQUIRED ACTION B.2 for those TSB ocope of channels common to RPS and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in ITS 3.3.7.1 REQUIRED conversion review.

ACTION C.2. for all other channels Provide discussion and ;

justification for the less The AOTs for placing a channelin trip for required surveillance restrictive change.

I testing is defined in CTS Table 3.2.A, Note II, and is extended Acceptance of this 1 from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.7.1 Surveillance Requirements change is contingent Note 2. upon the NRC approval of NEDC 30851.P.A.

l The CHANNEL FUNCTIONAL TEST Surveillance Test Intervel (STI) '

S ,; cct 2. NEDC- >

in CTS Table 3.2.A, is extended in ITS SR 3.3.7.1.2. to once per 31677-P-A, and GENE-92 days from monthly. 770-06-1.

l

! 3 .

1' w--..--.w. _w _ . - - - - _ . _ - _ _ _ _ . - . . . - _ . _ - .

4 . ,

4

\

BFN ITS 3.3.7.1 - CONTROL ROOM EMERGENCY 4

VENTil.ATION SYSTEM INSTRUMENTATION Table 3.3.7.1 Rv.1 DOC or CTS /STS LCO Description of leeue Date oper.ad Date Closed COMMENTS JFC 3.3.7.1-7 none CTS Table CTS Table 4.2.G. Note 1, calls for a Control Room Air Supply Duct 1/31/97 TNe change to CTS 4.2.G. Note 1 Radiation Monitor FUNCTIONAL TEST once per month. ITS Tabte Surveillance Test 3.3.7.1 1 only requires a 92 day test interval. This change is no* Int:.sval is outside the Natified. TSB ocope of conversion review.

Provide discussion eruf Natification for this less restrictive change.

3.3.7.1-8 A4 CTS Table 3.2.A ITS Functions 3 and 4 are shown to have one trip system with two 3/7/97 Provide revised channois. CTS Table 3.2.A Note (15) to Action G states these discussion for P67 P67 functions are comprised of two divisional trip systems with one channelin each zone end 2 sensors in each channel.

Explain the apparent discrepancy between the CTS and ITS required number of trip systems. Less restrictive changes proposed for the ITS are not administrativs.

4 i

I.

I i

4 i

BFN ITS 3.3.8.1 LOSS OF POWER INSTRUMENTATION 1 Table 3.3.8.1 Rv.1 1

DOCot) CTS /STS LCO - Description of Issue ' Date Opened Date Closed COMMENTS '

JFC 1

3.3.8.1-1 A2 CTS 3.9.B.11.e CTS 3.9.8.11.a providet a 10 dev AOT for inoperable loss of 3/7/97 This deleted CTS Action CTS 3.9.B.11.b voltage channels proved the degraded voltage relay channel on is outside the INEL JFC CTS 3.9.8.11.c the same board is O/ERABLE. ITS 3.3.8.1, REQUIRED Action B.1 scope of review.

PS1 CTS 3.9.B.11.d does not require verification that the other undervoltage relay Provide justification for channel on the sarne board is OPERABLE. In addition, ITS allows the changed CTS j ITS 3.3.8.1 multiple condition entry which means any of the specified requirement. Note:

REQUIRED condtions can exist at the same time with their own completion inconsistent with STS.

ACTIONS A.1, time clocks. As such channels can be inoperable simultaneously B.1, C.1, D.1 for both loss of voltage end degraded voltage functions without and D.2 entering a shutdown conditon. This is a less restrictive change to the CTS which otherwise would require entry into 3.0.3. Similar changes are made to the CTS 3.9.8.11.b and 3.9.B.11.c.

Less restrictive requirements, such as deletion of CTS 3.9.B.11.e.

b and c verification requirements are not administrative changes.

Specifio CTS changes must be identified and discussed.

3.3.8.1-2 L2 CTS 3.9.A.3. ITS 3.3.8.1 SR Note 2 proposed a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months delay from entering into 1/29/97 Provide justification for the associated Conditions and Required Actions for a channel the less restrictive JFC placed in en inoperable status solely for performance of Required change.

4 P71 Surveillances provided the associated Function maintains initiation capability for 3 out of 4 diesel generators. Note: Inconsistent with i STS.

This relaxation of requirements is added to the requirements of CTS 3.9.A.3 without a technical justification. The proposed change does not conform to the STS ellowance which provides an allowance not to enter TS Actions because individual DG trip capatxhty is maintained. The impact of this proposed ate is to add two hours to the channel repair time when testing.

i 3.3.8.1-3 A.1 CTS 3.9.8 The A.1 justification is used for addition of the " separate condtion 3/7/97 Provide a DOC which entry" note to the Actions. A.1 is a discussion of editorial changes discusses the proposed which is not acceptable for technical changes to the CTS. changes.

I

BFN ITS 3.3.8.1 LOSS OF POWER INSTRUMENTATION Table 3.3.8.1 Rv.1 DOC or : CTS /STS LCO ' Deecription of leeue Date Opened - Date Oooed . COMMENTS JFC 3.3.8.1-4 LA.1 CTS Table LA.1 allowable value items are incorrectly rnerked. 3.7.97 Provide revised 4.9.A.4.C submittal pages.

3.3.8.1-5 JFC ITS The licensee is not currendy required to perform Loss of offsite 3/27/97 Provide operational data

, P68 SR 3.3.8.1.1 power inst.urnentation channel checks or channel functional test. to support the proposed SR 3.3.8.1.2 The licensee proposed to maintain their current TS in the ITS. This TS.

i applies to functions 1.s and 2.a of Table 3.3.8.1-1. The time delay functions in the same table, functions 13 and 2.b are new requirements. Provide supporting justification. based on operational experience, to confirm the reliability of the tirne delay functions to perform their intended safety function without periodic channel check and channel functional test requirements.

3.3.8.1-6 LA.1 CTS Table System design end operational details are moved to the ITS 3/7/97 Provide AHowable 4.9.A.4.C 3.3.8.1 Bases and plant procedures. Values for the ITS.

Show that proposed Trip setpoints are en operational detail not directly related to the kmits are based on en operability of the instrumentation. The Asowable Value is the approved methodology.

required limitation of the parameter and this value is retained in ITS Table 3.3.8.1-1.

The LA.1 DOC discusses relocatmg timer trip setpoints to owner documents and retaining the CTS Allowable Values in the ITS. For this CTS table the " trip level settings

column is simply renamed "Alloweble Value"in the ITS format. The Allowable Values do not exist in the CTS and the proposed ITS allowable values ICTS setpoints) are changed without justification.

2

]

i 8FN ITS 3.3.8.2 - RPS ELECTRIC POWER MONITORING INSTRUMENTATION l

Table 3.3.8.2 Rv.1 i.

4

Doc orJ CTSisTs LCo Descripeton of issue , pote opened Date Closed COMMENTS JFC- ,

1

3.3.8.2-1 M2 CTS 4.1.8 CTS 4.1.8 does not specsfy a Channel Calibration, but ITS SR 1/30/97 Provide further I 3.3.8.2.2 adde CHANNEL CALIBRATION requirements with an discuseson and justification for the ITS SR survesliance frequency of 184 days. Time deley setting 3.3.8.2.2 requiremente are added to ITS SR 3.3.8.2.2 for the undervoltage, more restrictive change.

overvoltage, and underfrequency protective devices of the RPS MG ;

set. These time deley settings are not required by the CTS. Twne

~

deley settings and survedence interval are beoed on previous plant l practice. These additional restrictions on plant operation are not justified as a more restrictive change.

3.3.8.2-2 none ITS Condsons CTS applicability requires operability of two RPS-EPM channele for 3/7/97 Provide plant specific A&B oech incorvice MG Set or alternate source. ITS applicabsiity justification booed on requires operability of two RPS EPM sesemblies for sech inservice eyotem dessen.

l MG Set or altemete power supply DOC do not justify the changing LCO terms from channele to ensembises.

i 3.3.8.2-3 M.2 CTS 4.1.b.2 CTS 4.1.8 does not specify a Channel Calibration, but ITS SR 3/7/97 Provide additonal ,

' 3.3.8.2.2 adde CHANNEL CALIBRATION requirements with an justification for M.1 4 ITS survedlance frequency of 184 days. This requirement is added SR 3.3.8.2.2 with a 184 day interval since this test is performed during the CFT Frequency (SR 3.3.8.2.1L l i Explain the cibeense of the SR 3.3.8.2.1 Nots on SR 3.3.8.2.2 to

. allow a deley in required testing based on the Mode of operation.

i 1

d o

4 i

i 4

+

1 W

- - , _ _ _ -- . _ _ _ _ _ . _ _ _ , _ . , . . _ _ . , _ _ , __ - . . _ - . _ _ . . - ~ . _ _ _ _ _ _ , . . _ . , ._ _ -_- - . . . . .

ML20141G406

Contents

Text

SUBJECT:

SUMMARY

Enclosures:

Enclosures:

Navigation menu

ML20141G406

Text

SUBJECT:

SUMMARY

Enclosures:

Enclosures:

Navigation menu

Search