ML20198Q445
| ML20198Q445 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/05/1997 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20198Q451 | List: |
| References | |
| TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9711120211 | |
| Download: ML20198Q445 (13) | |
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\\b1 Tenn,some Vaney Auuony, Post once Ika M. Deats, Abbama 3%09E00 November 5, 1997 10 CFR 50.90
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F U.S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, DC 20555 Gr.tlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
)
50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS)-362 - IMPROVED TECHNICAL GPECIFICATIONS (ITS) SUPPLEMENT 3 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - ITS SECTIONS I.0, 2.0, and 3.2 (TAC NOS. M96431, M96432, AND M96433)
The enclosures to this letter provide supplemental information in support of the TS-362 amendment request relating to Section 1.0, Use and Application, Section 2.0, Safety Limits, and Section 3.2, Power Distribution Limits.
NRC questions on these three sections were included in an RAI dated September 29, 1997.
TS-362 is TVA's conversian package from Current Technical Specifications (CTS) to ITS and was originally submitted to NRC on September 6, 1996.
\\jj This supplement incorporates ITS/ITS BASES revisions and changes to supporting documentation resulting from responding to-the NRC questions. In addition, changes and corrections associated with in-house TVA reviews are included.
Y A separate enclosure is provided for each individual ITSQ section.- The standard format for enclosures includes the information-below. The enclosures will contain these subsections only if there are' changes, t 3, 'n c t : -
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9711120211 971105 } PDR ADOCK O M 259 P PDR g l1lll l1 g i I
o e U.S. Nuclear Regulatory Commission Page 2 November 5. 1997 Response to NRC questions Summary Description of ITS/ITS BASES Changes ITS Revised Pages ITS BASES Revised Pages CTS Markup Revised Pages Justification for Changes to CTS (DOCS) Revised Pages e NUREG-1433 BWR/4 S'S Mark-up Revised Pages
- NUREG-1433 BWR/4 ! 1 Bases Markup Revised Pages Justification for Changes to NUREG-1433 (JDs) Revised Pages No Significant Hazards Considerations Revised Pages Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433 Many of the NRC RAI questions request additional justification for More Restrictive, Less Restrictive, and Relocated changes in the conversion from CTS to ITS.
When possible, the additional justification will be provided in the RAI response. The associated DOCS will be revised only if the scope of the original DOC is significantly changed. This same approach will also be applied to JDs. A revision to Section 1.0 and Section 2.0 of TS-362 was previously submitted as Supplement 2 to NRC on August 14, 1997. The material provided in this submittal (Supplement 3) related to Section 1.0 and Section 2.0 includes only answers to the NRC RAI questions and related justification changes. No revisions to Section 1.0 or Section 2.0 ITS or ITS Bases were made. Regarding TSTF items, as previously agreed, TVA has reviewed the NRC approved TSTF items to determine those applicable to these three sections. TVA has established September 1,
- 1997, as the cut-off date for incorporation of TSTFs.
For the three sections in this submittal, no additional TSTF items were deemed applicable. TVA has an outstanding TS amendment (TS-353S1) request which affects ITS Sections 1.0 and 3.2.4, and ITS Bases Sections 3.2.1, 3.2.2, and 3,2.4. TS-353S1, submitted April 11, 1996, is the TS change request package in ITS format for the Power Range Neutron Monitor system installation, and implementation of the Average Power Range Monitor and Rod Block Monitor TS Improvements (ARTS) and Maximum Extended Load Line Limit
U.S. Nucle 6r Regulatory Commission 1 Page 3 November 5, 1997 (MELLL) Analysis. These modifications have been implemented on Unit 2 and the TS-353S1 ITS changes will need to be issued at the same time as TS-362 for Unit 2. The same Unit 3 modifications will be implemented in the Fall of 1998. The enclosed supplemental information does not alter the determination that there are no significant hazards considerations associated with the proposed changes and the determination that the changes qualify for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9). Additionally, in accordance with 10 CPR 50. 91 (b) (1), TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health. There are no commitments contained in this letter. If you have any questions, please contact me at (205) 729-2636. S acerel' \\ T. E.;Abney Ma - er of Licens ing and Industry Af fairs Subscribed and sworn to before me o this day of 1997 [S CLh CeAa) CM W Hy commission expires Enclosures cc: see page 4
-. - = -. - _. -. - U.S. Nuclear-Regulatory Commission Page 4 Nove.nber S.-1997 i j Enclosures cc (Enclosures): Chairman Li
- stone County Commission 31s "fest Washington Street f
Athens, Alabama 35611 Mr. MarkLS. Lesser, Branch Chief U.S. Nuclear Regulatory Commission -Region II 61 Forsyth Street, S.W. -Suite 23T85 4 . Atlanta, Georgia 30303 NRC_ Resident Inspector Browns Ferry Nuclear Plant 10033 Shaw Road Athens, Alabama 35611 Mr. J. F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E._Williamson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017 l- +-.s
0 ITS Section 1.0 Use and Application Engjpsure Contents - Enclosed? Pesponse to NRC questions. Yes Summary Description of ITS/ITS BASES Changes. N/A ITS Revised Pages. ............... N/A N/A ITS BASES Revised Pages. CTS Markup Revised Pages. N/A Justifications for Changes to CTS (Docs) Revised Pages N/A NUREG-1433 BWR/4 STS Mark-up Revised Pages. N/A NUREG-1433 BWR/4 STS Bases Markup Revised Pages N/A Justification for Changes to NUREG-1433 (JDs) Revised Pages. .................. Yes No Significant Hazards Considerations Revised Pages N/A Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433. N/A i l l l
Response to NRC Questions ITS Section 1.0 1.0 1 NRC Change' Difference statement: The DOC for CTS 1.0, defmition of CORE ALTERATION, states ". The provision added that allows control rod movement with no fuel assemblies in the core cell to not be considered a Core Alterations is less restrictive and is discussed in Comment L.3 below. However, the CTS for Core Alteration is not indicated as L.3 for this less restrictive change. NRC Comment: Revise the CTS and the L.3 less restrictive change to include the insertion of L.3 to the defmition of Core Alteration. Response: The CTS hiarkups do contain an indication that Justification for Changes (DOC) L3 provides a justification for this less restrictive change. Please see CTS markup page 8 of 43 (CTS section 1.0.S page 1.0-7) all three units. The L3 indication is below paragraph 1.0.S to the right of the handwritten, newly inserted ITS paragraph B. 1.0-2 NRC Change / Difference statement: The ITS 1.1, CHANNEL CALIBRATION, deletes the allowance for ", an inplace qualitative assessment for sensor behavior and normal calibration of the remainit:g adjustable devices in the channel. " Thejustification does not discuss system design and operational constraints that preclude using these defmitions in the ITS. NRC Comment: Provide justification and additional description for the STS deviation based on system design and opc ational constraints. Response: Justification for Changes to NUREG 1433 (JD) P5 has been revised to providejustification for this deviation. 1.0-3 NRC ChangezDiffirence statement: The STS defmitions for EhiERGENCY CORE COOLING SYSTEM RESF JNSE TlhiE, END OF CYCLE RECIRCULATION PUhtP TRIP RESPONSE TlhiE, ISOLATION SYSTEM RESPONSE TIhiE RESPONSE TIhiE, AND REACTOR PROTECTION SYSTEhi IESPONSE Tlh1E, are deleted because they are not required by the CTS. Thejustification does not discuss system design and operational constraints that would preclude using these dermitions in the ITS. NRC Comment: Providejustification and additional description for the STS deviation based on system design and operational con".raints. Response: JD P1 providesjustification for not including response time testing as a surveillance requirement (SR). BFN does not currently perform response time testing and requirements for response time testing are not being Page1
incorporated into the ITS. Since response time testing is not being incorporated into the ITS there is no need to keep the definitions associated with response time testing since leaving them may result in the impression that response time testing is required. Thus the definitions for EMERGENCY CORE COOLING SYSTEM RESPONSE TIME, END OF CYCLE RECIRCULATION PUMP TRIP RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, AND IGACTOR PROTECTION 3YSTEM RESPONSE TIME deletion isjustified as discussed in JD Pl. 1.0-4 NRC Change /D/fference statement: The ITS does not adopt the STS 1.1 definition for PRESSURE AND TEMPERATURE LIMITS REPORT because the methodology is not approved. ITS 3.4 contains those limits. The justification does not discuss system design and operational constraints that would preclude PRESSURE AND TEMPERATURE LIMITS IGPORTS. NRC Comment: Providejustification and additional description for the STS deviation based on system design and operational constraints. Reuponse: JD P4 has been revised to provide additionaljustification for this deviation. 1.3-1 NRC ChangeDifference statement: STS 1.3 (Page L3-6), Example 1.3 3, Completion Time, item C, Completion time of STS revised from 72 hours to 12 hours to restore Function X subsystem to OPERABLE status. Example 1.3-3 is ", proposed to be revised to more adequately reflect BWR specific TS ACTIONS rather than PWR specific TS ACTIONS." NRC Comment: Provide justification and additional description for the STS deviation based on system design and operationel constraints. Revise this change to a less restrictive change. Response: As stated in applicable CTS DOC A14, sections are being added to aid in the understanding and use of the ITS. The specific NRC Change / Difference statement refers to an " Example" that will aid in the understanding and use of the ITS. The NUREG-1433 Standard Technical Specification (STS) Example" is only that, an example, and does not refer to any specific BFN equipment or LCO Action. As such,it was modified slightly to be more typical of BWR specific ITS ACTIONS. The change is considered to be editorialin nature since it does not impact the discussion of the associated example. Hence, we consider the categorization of the change as administrative as appropriate. 1.3-2 NRC Change / Difference statement: STS 1.3 (Page 1.3-10), Example 1.3-5, Required Action, item A, Required Action A.2 is revised from ". Reduce THERMAL POWER to s50% RTP." This was revised to ". Place channel in trip ". Page 2
i i Example 1.3 5 is ".. proposed to be revised to more adequately ref!xt BWR specific TS ACTIONS rather than PWR specific TS ACTIONS." l NRC Comment: Provide justification and additional description for the STS deviation based on system design and operational constraints. Revise this change to a less restrictiva change. j Response: As stated in applicable CTS DOC A14, sections are being added to i aid in the understanding and use of the ITS. The specific NRC Change / Difference statement refers to an " Example" that will aid in the understanding and use of the ITS. The STS " Example" is only that, an example,- and does not refer to any specific BFN equipment or LCO Action. As such,it was modified slightly to be more typical _of BWR specific ITS ACTIONS. The change is considered to be editorial in nature since it does not impact the l discussior of the associated example. Hence, we consider the categorization of. c the change as administrative as appropriate. 4 U Page 3 .-._.,_,.._._.._._,.~.._.______.-....m. . _ _ _. _.. _ ~ _... ~, _...,., _
BROWNS FERRY NUCLEAR PLANT IMPROVED TECilNICAL SPECIFICATIONS SECTION 1.0 LIST OF REVISED PAGES JUSTIFICATION FOR CHANGES TO NUREG 1433 Replaced pages il of 2 through 2 of 2 Revision 1) with pages [1 of 2 through 2 of 2 Revision 2) 6
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JUSTIFICATIONS FOR CHANGE 5 TO NUREG-1433 i SECTION 1.0 - USE AND APPLICAT!DN BRACKETED PLANT SPECIFIC INFORMATION 4 B1 The brackets were removed within the definition of ' DOSE EQUIVALENT I-131' and the optional wording for the 1962 AEC document was used. The remaining words were deleted since the conversion facto s from the 1962 document are used at BFN versus the ones from the 1971 document. B2 Brackets removed and optional wording deleted. 83 The brackets were removed and optional wording in brackets was replaced by the plant specific information as appropriate or due to plant preference. B4 The brackets were removed from around LHGRs and all other bracketed ir. formation was deleted from the definition of AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR). 85 The brackets were removed and optional wording in brackets was used. NON-BRACKETED PLANT SPECIFIC CHANGES P1 Response Time testing is not required by current BFN TS. Generic studies are in progress / review and show that response time changes (times getting longer), that could impact safety, do not normally vary such that they would e,c be detected during other required surveillances (e.g., Channel Calibrations). Since the addition of these tests are a major burden to BFN, with little gain in safety, the SRs associated with these tests have not been added for any test associated with instrumentation. Therefore, the definitions have also not been added. P2 Grammatical error corrected. P3 Changed to use proper terminology. P4 Since an NRC approved methodology does not exist for BFN, BFN chooses to maintain the existing RCS pressure and temperature limits in the ITS until an acceptable methodology for BWRs has been developed. Due to delay in generating the " approved methods" report that could be referenced in Section 5.0, BFN has decided not to pursue a PTLR at this time. BFN has maintained its current licensing basis pressure and temperature limits as addressed by 1 and 2 of SR 3.4.9.1, SR 3.4.9.4, and SR 3.4.9.5. BFN UNITS 1, 2, & 3 1 of 2 REVISION 2
0 JUSTIFICATIONS FOR CetANGE5 TO NUREG-1433 SECTIOM 1.0 - USE Als APPLICATION NON-BRACKETED PLANT SPECirIC CHANGES (continued) P5 ' Calibration of instrument channels with resistance temperature detector j (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel" was deleted from the definition of CHANNEL CALIBRATION. This sentence was replaced with "Non-calibratable devices are excluded from this requirement, but will be included in CHANNEL FUNCTIONAL TESTS and source checks." The replacement sentence is used in the CTS and BFN chose to retain it because this better i describes the channel calibration methodology. This replacement sentence encompasses both RTD and themocou)1e sensors and acknowledges that other non-calibratable sensors exist witch cannot be calibrated but must have their functionality confimed. P6 BFN implemented 10 CFR 50, Appendix J, Option B requirements for primary containment leakage rate testing for Units 1, 2, and 3 by Amendment No. 228, 243 and 203, respectively date february 22, 1996. The definition of L, and P, is provided in the description of that program. Therefore, L, has not been included in the proposed BFN ISTS. This is consistent i I with the BWR/4, Option 8 Nodel dated 10/31/95. l P7 Example 1.3-3 and Example 1.3-6 are proposed to be revised to more adequately reflect BWR specific Technical Specifications ACTIONS rather than PWR specific Technical Specification ACTIONS. In example 1.3-3, the Completion Times for Condition C are proposed to be revised from '72 hours' to "12 hours." In Example 1.3-6, Required Action A.2 is proposed to be revised from " Reduce THERMAL POWER to s 505 RTP" to " Place channel in trip." These changes are considered to be editorial in nature since they do not impact the discussions of the associated examples. BFN-UNITS 1, 2, & 3 2 of 2 REVISION 2
ITS Section 2.0 Safety Limits Enclosure Contents Enclosed? Response to NRC questions Yes Summary Description of ITS/ITS BASES Changes. N/A ITS Revised Pages. ...............N/A ITS BASES Revised Pages. N/A CTS Markup Revised Pages Yes a Custifications for Changes to CTS (DOCS) Revised Pages. Yes NUREG-1433 BWR/4 STS Mark-up Revised Pages. N/A NUREG-1433 BWR/4 STS Bases Markup Revised Pages. N/A Justification for Changes to NUREG-1433 (JDs) Revised Pages N/A No Significant Hazards Considerations Revised Pages N/A Cross-Reference Matrix Correlati.ng Changes Between the CTS, ITS, and NUREG-1433. N/A
0 . Response to NRC Questions ITS Section 2.0L t 2.0-1 NRC Change / Difference sta/cment: CTS 1.2.A states, "The pressure at the - lowest point of the reactor vessel shall not exceed 1,375 psig whenever 1 irradiated fuel is in the reactor vessel." This limit is reworded in ITS 2.1.2 to be " Reactor steam dome pressure shall be s:1325 psig." This is a more restrictive change because (a) a quick calculation shows that 1:25 psig in the steam dome equals approximately 1355 psig at the lowest point and (bW limit is now enforced without regard to whether irradiated fuel is in t e u 'el. NRC Comment: Provide discussion and justification for this more restrictive change. Response: We agree that 1325 psig is a conservative value. This change has been recategorized as a more restrictive item as discussed in (new) Justification for Changes to Currerit Technical Specifications (DOC) M2, DOC A3 has also been modified to correspond to this change. 2.0-2 - NRC Change / Difference statement The CTS 1.1.C Safe:J Limit for the reactor vessel water level is that level shall be maintained not less than 372.5 inches above vessel zero. The ITS 2.1.1.3 Safety Limit is that level should be greater than the top of the active irradiated fuel (approximately 366 inches above vessel zero). This is a less restrictive change to an allowable value NRC Comment: Provide additionaljustification for this less restrictive change. Note: Consistent with the STS. Response: DOC L2 was previously modified in Revision 1 (submitted to NRC in ITS Supplement 2, dated August 14,1997) to provide additionaljustification. DOC L2 is also included in this submittal for reference. .}}