ML20199D520

Forwards Supplemental Info Which Supports TS-362 License Amend Request Re Improved TS Sections 3.0 & 4.0,in Response to RAI

ML20199D520
Person / Time
Site:	Browns Ferry
Issue date:	11/14/1997
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199D526	List: ML20199D520 ML20199D547
References
TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9711200354
Download: ML20199D520 (7)

Text

- - - - -

.maraw

• i 1

]  :!\

)

.t IPlhi I

~ ' ll November 14, 1997 1

h

< + ,

0 W .

3 .

2 10 CFR 50.90 $ ,

q n

L  !

l 1

i '

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk i Washingtcn, DC 20555 ,

- Gentlemen; .

l l i 2 In the Matter of ) Docket Nos. 50-259 h Tennessee Valley Authority ) 50-260 hj 2

50-296 / '

= I '

BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL .- i l #

SPECIFICATIONS (TS)-362 - IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUPPLEMENT 4 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI) - ITS SECTIONS 3.0 and 4.0 (TAC NOS. M96431, g 5

M96432, AND M96433) 1 -

l u

j The enclosures to this letter provide supplemental .nformation f.l in support of the TS-362 amendment request relating to .fL Section 3.v, Limiting Condition for Operation (LCO)

[

i Applicability, and Section 4.0, 've s i g n Features. NRC j questions on t: ese sections were included in an RAI dated ,  ;

-i September 29, 1997 TS-362 is TVA's conversion packaue from .

4 Current Techr.ical Specifications (CTS) to ITS and was "

originally submitted to NRC on September 6, 1996. [

.nq This supplement makes several ITS/ITS BASES revisions and changes to supporting documentation associated with addresslag . --

the NRC questions. In addition, changes and corrections

^

associated with in-house TVA reviews are included. Also, applicable owners Group Technical Specification Task Force

('I J T F ) items have been jncorporated.

- ( h,: 1

\

A separate enclosure is provided for each individual ITS

^

section. The standard format for enclosures includes tne

^

9711200354 971114 mtimisp '

alre ll!

E ADOCK 05000259 Ql;ldlirtu!Ill l ul1, nllulll211$11$u lllll PDR - * * ' ' ~

p PDR

t 1

U.S. Nuclear Regulatory Commission Page 2 November-14. 1997 information below. The enclosures will contain these subsections only if there are changes.

• Responses to NRC questions

• Summary Description of ITS/ITS BASES Changes

• ITS Revised Pages

• ITS BASES Revised Pages

• CTS Markup Revised Pages

• Justification for 'nanges to CTS (DOCS) Revised Pages

• NUREG-1433 BWR/4 STS Mark-up Revised Pages

• NUREG-1433 BWR/4 STS 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 Relocatec changes in *.he conversion from CTS to ITS. When possible, the additional justification will be provided in the RAI question 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.

Regarding TSTF items, ai previously agreed, TVA has reviewed and incorporated NRC approved TSTF items determined applicable to these sections. TVA has established September 1, 1997, as the cut-off date for incorporation of TSTFs. The Summary Description of ITS changes in the enclosures lists the TSTF items incorporated in this submittal.

The enclosed supplemental information does not alter the determination that there are no significant hszards 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 Sl .22 (c) (9) . Additionally, in accordance with 10 l' CFR 50. 91 (b) (1) , TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health.

N U.S. . Nuclear Regulatory Commission Page 3:

November 14, 1997 There are no commitments contained'in this letter. If you have any questions, please contact-me at (205)-729-2636, S ncerely E4 -

T. E. Abney Manager of icensi g i .and Ind stry-Affcirs Subscribed and sworn to before me n this pth day of November 1997, Ytso] h. Om$tm My commission expires: ".* "

Enclosures cc: see page 4

'U.S.-Nuclear-Regulatory Commission Page 4 November 14. 1997 Enclosure cc (Enclosures)i.

Chairman-Limestone. County Commission 3J0 West. Washington Street hthens,-Alabama 35611' Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street, S.W.

Suite 23T85

' Atlanta,. Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 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

Enclosure 1.0 ITS Section 3.0 LCO Applicability Enclosure Contents Enclosed?

• Response to NRC questions . . . . . . . . . . . . . . Yes

• Summary Description of ITS/ITS BASES Changes. . . . . Yes

• ITS Revised Pages . . . . . . . . . . . . . . . . . . Yes

• ITS BASES Revised Pages . . . . . . . . . . . . . . . Yes

• CTS Markup Revised Pages. . . . . . . . . . . . . . . N/A

• Justifications for Changes to CTS (DOCS)

Revised Pages . . . . . . . . . . . . . . . . . . . . Yes

• NUREG-1433 BWR/4 S"S Mark-up Revised Pages. . . . . . Yes

• NUREG-1433 BWR/4 STS Bases Mark-up Revised Pages. . . Yes

• Justification for Changes to NUREG-1433 (JDs)

Revised Pages . . . . . . . . . . . . . . . . . . . . Yes

• No Significant Ha:ards Considerations Revised Pages . N/A

• Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433. . . . . . . . . N/A

- - - - - -. - - - - _ _ ~ _ . - . -

r, .

Response to NRC Questions '

ITS Section 3.0 L

3.0-1 NRC Description ofissue: ITS 3.0.5 changes are proposed to make it apply to variables as well as equipment, NRC Comment: The changes proposed here were reviewed and rejected as TSTF 001. ' Provide markup deleting these changes.

( Response: ITS 3.0.5 changes associated with Technical Specifications Task l

Force (TSTF) item 001 have been deleted in the attached revised ITS and ITS Bases.

3.0-2 NRC Description ofIssue: None l NRC Comment: These changes are generic and must be handled accordingly.

Generic changes go to the Technical Specifications Task Force (TSTF) to be reviewed by the OGs and submitted as a TSTF. Provide new pages deleting the changes.

Response: We consider that the BFN proposed changes to ITS Section 3.0.6 Bases referenced in the Staff s question are be'ow the significance threshold for processing as generic changes for Bases as defined in NEl 96-06, " Improved Technical Specifications Conversion Guidance." Rather, the changes are editorial in nature and serve to simplify text and facilitate use of the Bases using language that is more familiar to BFN personnel. Accordingly, we consider the

! revisions within the prerogative of the Licensee's scope for changes for improved usability at BFN.

3.0-2 NRC Description ofissue: None NRC Comment: Thejustifications for change provide excellent explanations of -

what the LCOs do. They do r.ot, however, providejustification ofwhy they are acceptable for Biowns Ferry, whether they impose any operational constraints, ,

impact any system design or the current licensing basis. Provide simple statement of applicability to your plant.

Response: BFN CTS DOCS M1, M2, and M3 have been revised to provide additionaljustification on these more restrictive changes.

L <

L

- q1 dbem_idsutwnitda344&nD,0&:

['

o I

Summary Description of ITS/ITS Bases Changes ITS Section 3.0 LCO 3.0.5 and Associated BASES Deleted TSTF-001. The original TS-362 submittal incorporated text changes proposed in TSTF-001. This TSTF was subsequently not approved by the NRC. The ITS and corresponding bases show the deletion of the TSTF and a return to the standard NUREG-1433 provisions.

LCO 3.0.6 Incorporated TSTF-166 to explicitly require an evaluation in accordance with the Safety Function Determination Program to determine if a loss of safety function exists.

LCO 3.0.5 BASES Incorporated TSTF-165 to use the words " required testing" instead of "SR." This change provides consistency in nomenclature, i

i l

l