ML20199E118

Forwards Suppl Info Supporting TS-362 Amend Request Relating to Section 3.4, Reactor Coolant Sys. Suppl Makes Several Improved Ts/Improved TS Bases Revs & Changes to Supporting Documentation Associated W/Addressing NRC Questions

ML20199E118
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
ML20199E122	List: ML20199E118 ML20199E136
References
TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9711210103
Download: ML20199E118 (30)

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,n F Tennessee VaHoy Althodty, Poet Cnfice Box 2000 Decatur, Alabama 3560+2000 November- 14,'1997 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:

In-the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296

-BROWNS FEFRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS)-362 - IMPROVED TECHNICAL SPECIFICATIONS (I'tS) SUPPLEMENT 5 - RESPONSE TO REQUEST FOR ADDITION 71 INFORMATION (RAI) - ITS SECTION 3.4 (TAC NOS, M96431, M96432, AND M96433)

The Enclosure to this' letter provides supplemental information in support of the TS-362 anendment request relating to Section 3.4, Reactor Cc- System. NRC questions on this cection were included in .. RAI dated June 12, 1997. TS-362 is TVA's conversion package from Current Technical Specifications (CTS) to ITS and was originally submitted to NRC on September 6, 1996.

This supplement makes several ITS/ITS BASES revisions and changes to supporting documentation associated with addressing the NRC questions. In addition, changes and corrections

' associated with in-house TVs reviews are included.

Also, applicable Owners Group Technica) Specification Task Force (TSTF) items have been incorporated.

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[U M N'uclear'RegulatoryjCommission TPagel21 November 14).1997  ;

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7TheLEnclosurefit: organized as f 11owing: -

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f eiLResponsesto[NRC\ questions e r SummaryLDescription of:ITS/ITS-: BASES Changes

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- les ITS" Revised Pages-

'e:JITS-BASES 1 Revised:Pages ,

efCTS; Mark-up Revised Pages g

• 1 JustificationLfor Changes-to CTS (DOCS). Revised Pages y to ;NUREG-1433-BWR/4 STS-Mark-up Revised Pages

- *!NUREG-1433-BWR/4'STSLBases Mark-up Revised Pages

• Justification.for. Changes to NUREG-1433L(JDs) Revised Pages e" No.Significant_ Hazards. Considerations' Revised Pages '

" *.-_ Cross-Reference Matrix Correlatiag Changes Between the CTS, ITS,:-:andiNUREG-1433 n

Many-of the NRC RAI-questions request additional justification ifor More-Restrictive, Less Restrictive, and Relocated changes

- in the conversion from CTS to ITS. When possible, the additionalEjustification will be provided in the=RAI question response.- _The associated DOCS will-be revised only if the t 1 scope of the originalJDOC is significantly changed. This same ,

approachiwill also be applied to JDs. ^

- Regarding TSTF items, as previously agreed, TVA has reviewed

NRC<1pproved-TSTF-items to determine those applicable to this

- 'section. TVA has established September 1, 1997, as the cut-offEdete forz incorporation of TSTFs. The Summary Description of:ITS changes in the enclosure lists the TSTF items

incorporated in this submittal.

-TVAfhas an outstanding TS amendment (TS-353S1) request which

affects--ITS,Section 3.4.l'and the associated ITS Bases

'section.' TS.353S1, submitted April 11, 1996, is the TS, change

request: package in:ITS; format for the Power Range Neutron ,

Monitorfsystem

installation, and implementation of-the Average W: Power; Range, Monitor.and Rod Block Monitor TS Improvement .

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DARTS) and Maximum Extended Load Line Limit (MELLL) Analysis.

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4These^ modifications'have been-implemented'on Unit 2.and the JTS-353S1;ITS. changes willineedLto be issued concurrently with

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-U.S. Nuclear Regulatory Commission

'Page 3 November 14, 1997 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 CFR 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.

Sincerely,

%Awd Manager of Lpnninc and Indu try Affai rs Subscribed d sworn to before me this j h day f November 199~.

DGA GM b- .GO W My commission expires N " "'" 4"" ""#"

Enclosure cc: see page 4 y

U.S. Nuclear Regulatory Conmission

Page '4-November- 14,!1997:

-cc (Enclosure):

Chairman Limestone County Commission 310 West Washington Street

-Athens, Alabama 35611-Mr. Mark S. Lesser, Branch Chief U.S. NuclearLRegulatory Commission Region II

_61 Forsyth Fcreet, ",. 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 7. Williamson

' State Health Officer Alabama State-Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017 m

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Enclosure ITS Section 3.4

-. Reactor Coolant System q Enclosure Contents Enclosed?  ;

e LResponse to-NRC questions . . . . . . -. . .- . .. . . -

. . Yes -

'o Summary. Description of ITS/ITS. BASES Changes. . . . -. Yes _,

- +- ITS: Revised'Pages . . . . . . . . . . . . . . . . . . Yes-

• ITS BASES Revised Pages . . . . - . . . . . . . . - . . . - - Yes ,

e CTS Mark-up Revised Pages. . . . . . . . . . . . . . . Yes

• -Justifications-for-Changes to CTS (DOCS)

Revised Pageso. . ..................Yes. .

e NUREG-1433 BWR/4 STS Mark-up Revised Pages. . . . . _ . Yes 4

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

-e Justification for Changes to NUREG-1433 (JDs) .

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

• No Significant Hazards Considerations Revised Pages-. Yes e Cross-Reference Matrix Correlatirg Changes Between the CTS, ITS, and NUREG ,*.433. . . . . . . . . Yes-i

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ITS Section 3.4 General-Item 3.4.G i

- CTS 3.6.H/4.6.H will;be included'in the Technical Requirements Manual l(TRM)~._ Therefore, we agree with NRC

- that this_ change can be reclassified'as a relocated item. ;l DOC LAl'"for CTS-3.6.H/4.6.H_has been-revised to'~ reflect--

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Item ~3.4.G-2 l CTS:3.6.B/4.6.B reactor coolant chemistry requirements will be included in the TRM. DOC R1xfor CTS 3.6.B/4.6.B'has been:

revised'to be mere specific on-this point, em 3.4.G-3 CTS 3.6.G/4.6'.G-structural integrity requirements will-be t

- included in the TRM. DOC R1 for CTS 3.6.G/4.6-G has been .

revised to be more specific on this point.

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. ITS Section 3.4.1

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Item'3.4.1-10 ,

ProposedfITS_ Surveillance-Requirement (SR) 3.4.1.1 addsDar

'moreDrestrictive SR that the! recirculation' pumps.be'verifiedL

-at; matched flows by_ comparing jet-pump _ loop flows.~ This, in,

-turn,nislused to satisfy ITS Limiting Conditionifor Operation. (LCO)- 3.4.1 for: demonstrationt of both--

. recirculation-loops lDeingfin service. _The Current Technical Specifications -(CTS): do not have an explicit SR that the-recirculation: loops be operated at matched flows for the--

purposes ofLdemonstrating_both-recircu!,ation pumps ir. ~

_e service,balthough to cerform CTS _SR 4.6.E.1.a regarding jet ipump operability, thk recirculation pump loop flows must be >

demonstrated to be within~15% of each other while_ operating at.the same speed. Since jet pump loop flow is'a function _

of recirculation pump. loop flow,LCTS hasta similar, though less explicit requirement that.the pumps-be_ operated at near ,

matched , fic es . The ITS are somewhat more~restrir'> e inx

terms of the reduced allowed _ percentage mismatch:is. the veiriousiflow conditions as. explained in DOC M2. The new ITS

, LSRE3.4.1.111s consistent with NUREG-1433 and considered an.

improvement-in TS.

Item 3 4.1 The1 existing header "B.1" has been revised to road "B.1 and B.2".

-Item 3.4.1-3 To, demonstrate jet pump operability, CTS 4.6.E.1.a includes

a SR to-compare recirculation pump loop flows while both recirculation pumps are operating at the same pump speed.

Proposed ITS SIU 3.4.1.1 adds an explicit SR that the recirculation pumps <beloperated at matched flows by  ;

comparing the jet _ pump loon flows as a percentageaof core-flow to demonstrate both recirculation loops are in service.

Since jet pump loop flow. varies as a. function of recirculation pump-loop-flow,.ITS SR 3.4.1.1 provides for a

-similar SR tb CTS SR.4.6.E'1.a,.although for the purposes of Ldemonstrating the-operability.of different components-(recirculationLloops:versus jet pumps). The ITS'SR is E somewhat more1 restrictive-requirement in terms of the absolute' allowed percentage mismatch for-the various flow Lconditions asJexplained in DOC M2.- Note that-the ITS requirements for- jet pump operability proper are _ addressed

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in 1TS Section 3.4.2. The proposed changes are consistent with NUREG-1433 and considered improvements in TS.

Item 3.4.1-4 Initiation of a reactor scram by using the manual push buttons (in CTS) or by placing the mode switch in shutdown (ITS) while at power are considered equivalent actions since either action results in a operator initiated scram.

Furthermore, plant operating procedures for e.ll operator initiated scrams direct that a manual scram be inserted and then the mode switch placed in shutdown. Considering the equivalency of the actions, the change from CTS to ITS requirements is appropriately considered administrative.

Item 3.4.1-5 Same response as item 3.4.1-4.

Item 3.4.1-6 The less restrictive time allowance to shutdown is justified based on operating experience to allow the plant to reach a l'ot Shutdown (MODE 3) condition in an o-derly manner and without challenging plant systems. The change is consistent with the STS. DOC L2 has been revised to be address this comment.

Item 3.4.1-7 After further review, TVA agrees with NRC's conclusion that the CTS and proposed ITS requirements for reactor operation with one or more recirculation pumps out of service are essentially the same. Hence, this change in no longer considered more restrictive. Accordingly, DOC M1 has been revised and recategorized to administrative (new DOC A4).

Item 3.4.1-8 Same response as item 3.4.1-4.

Item 3.4.1-9, DAs explained in the responses to NRC comments 3.4.1-1 and 3.4.1-3, jet pump loop flow and recirculation pump loop flow are functionally related. Similarly, these parameters are also related to pump speed since the recirculation pumps are variable speed pumps. Proposed ITS SR 3.4.1.1 adds an explicit SR that the recirculation pumps be operated at matched flows by comparing the jet pump loop flows as a

percentage of core flow to demonstrate both recirculation-loops are in service. Since_ jet pump loop flow varies as a function of recirculation pump loop flow and speed, ITS SR 3.4.1.1 provides a similar-SR to CTS SR 4.6.E.1.a, although for the purposes of demonstrating the operability of dif ferent components -(recirculation loops versus jet pumps) .

Note that'the-ITS requirements for jet pump operability proper are addressed in ITS Section 3.4.2. The proposed changes are. consistent with NUREG-1433 ano considered

-improvements in TS.

Item 3.4.1-10 CTS SR 4.6.F.1 requires a daily check of recirculation pump speeds to document that both pumps are in service. Proposed ITS SR 3.4.1.1 adds an explicit SR that the recirculation pumps be operated at matched flows by comparing the jet pump loop flows as a percentage of core flow to demor.. trate both recirculation loops are operable. Since jet pump loop flow varies as a function of recirculation pump loop flow and speed, ITS SR 3.4.1.1 provides for a similar SR to CTS SR 4.6.E.1.a, although for the purposes of demonstrating the operability of different components (recirculation loops versus jet pumps). The ITS are somewhat more restrictive in terms of the absolute allowed percentage mismatch for the various flow conditions as explained in DOC M2. Note that the ITS requirements for jet pump operability proper are addressed in ITS section 3.4.2. The proposed changes are consistent with NUREG-1433 and considered improvements in TS.

Item 3.4.1-11 CTS Definition LL provides the analogous means to extend surveillance intervals by 25% as does ITS SR 3.0.2.

Therefore, we see no change in going from CTS to ITS requirer ents and the administrative categorization applies.

Item 3.4.1-12 DOC LA2 has been revised to address the NRC comment.

Item 3.4.1-13 The system operating instruction (OI) for the recirculation system (OI-66) requires that the speed of the operating pump be less than 50% prior to starting the idle pump. As noted in DOC LA1, this restriction is considered an operational restriction which can be deleted from TS in accordance with the application of 10 CFR 50.36 criteria.

Iter 3.4.1-14 The TS' policy statement provides a comprehensive discussion of the background for conversion to ITS and basis for the content of the ITS. Hence, we believe a reference to the-policy statement is a more informative reference.

Therefore, TVA prefers to retain the existing references.

Item 3.4.1-15 Detailed criteria for monitoring core thermal-hydraulic instability and instructions for exiting instability regions are contained in the operating procedures for the recirculation system (OI-68). As noted in DOC LA3, details of the methods and criteria for stability monitoring are more appropriately maintained in operating procedures.

Similarly, detailed instructions for exiting instability regions are likewise bett addressed in operating instructions.

The instability criteria in OI-68 are similar to those contained in the ITS 3.4.1 ACTION B.1 BASES and are actually more conservative than the requirements in CTS 3.5.M.3.b. A similar but more conservative power / flow stability map corresponding to ITS Figure 3.4.1-1 is also in 01-68.

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ITS Section 3.4.2 -

iItem 13.4.2-1:

- CTS ? 3. 6'.E.lfis ~ anL original TS1 provision and;was. in : place i prior to;actualcindustry experience with --jet pump _ failures. 1 CTS 3,6.E.11 correlates the . failure of a jet pump -instrument-to'an actual jetLpump; failure.  : Clearly, the failure of j 11ndividual? jet' pump- flow instruments--is not_ specifically '

indica tive of - j et - pump 1 f ailures . - Hence, CTS 3.6.E.1 is '

considered extremely conservative.

4 Subsequently, based on operating. experiences and vendor analysis, -Ganeral Electric -(GE) Service Information Letter (SIL) #330, " Jet Pump Beam Cracks" (Reference 2 of BASES 3.4.2) was issued which provided more accurate methods of .

-monitoring for jet pump failures. NRC endorsed the SIL

' methodology in NUREG/CR-3052, " Closeout of IE Bulletin 80-07: :BWR Jet pump Assembly Failure"- (Reference 3 of BASES 3.'4,2).- These documents used the experience with. actual

'failute events to develop criteria to more accurately predict impending jet pump failure. This experience is reflected in the LCOs and the SRs of- NUREG-1433 Section 3.4.2 and the corresponding proposed BFN ITS 3.4.2 specifications. Therefore, the implementation of ITS ,

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specification 3.4.2 will improve the ability of BFN to predict impending jet pump failures over the CTS 3.6.E.1 requirements. The BFN proposed ITS 3.4.2 provisions and frequency requirements are the same as--those in NUREG-1433 with no deviations taken.

Item 13.4.2-2 Note-2 to ITS SR 3.4.2.1 provides that the jet pump p -surveillance be conducted wnen reactor power is greater than 25%.. As discussed in the SR 3.4.2.1-BASES, at low flows,

' jet pump noise approaches the threshold response of the associated instrumentation. Therefore, the colle~ction of

meaningful data at low powere is precluded. For this 1 reason, time considerations associated with Note 2 are

irrelevant ~.

Note l' to ITS; SR 3.4'.2.1 provides an acceptable time (4 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />); following the start of a- recirculation pump to est:blishLconditions appropriate for data collection and revaluatlon. Considering that both recirculation loops are -

placed--into service prior to power ascension during reactor A start-up, the four hour allowance in Note 1 would seldom V

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affect the timing requirements of the base 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequency specified in ITS SR 3.4.2.1 since reactor start-ups are very-infrequent. Therefore, the comparison of times presented in Ll' represents the typically expected maximum expected difference between CTS and the ITS requirements.

Item 3.4.2-3 The provisions for jet pump-operability _in NUREG-1433 are based on vendor analysis and plant experience as presented in GE SIL 330. NRC subsequently endorsed the methodology in NUREG/CR-3052, "Closecut of IE Bulletin 80-07: BWR Jet Pump Assembly Failure". Hence, we consider that the methods and provisions presented in the NUREG represent industry best practices which NRC has previously reviewed and accepted.

This change improves the ability of BFN to predict impending jet pump failure by adopting the provisions in NUREG-1433.

Item 3.4.2-4 CTS Definition LL provides the analogous means to extend surveillance intervals by 25 % as does ITS SR 3.0.2.

Therefore, we see no change in CTS and ITS requirements for this item and the administrative categorization applies.

Item 3.4.2-5 ITS 3.4.1 establishes LCOs and SRs for the operation of the recirculation pump loops. Specifically, ITS LCO 3.4.1 prescribes that both recirculation pumps be in service for continued reactor operation. ITS SR 3.4.1.1 also requires that the recirculation pumps be verified to be at matched flows. Conditions C/D provide an allowance for a short period of time for operation with single pump in service.

The change for DOC A4 is considered administrative since the change is merely a restatement of the SR conditions for applicability for recirculation pump operation which will now be established in proposed ITS LCO 3.4.1.

Note that actual jet pump operability requirements are addressed in ITS 3.4.2. SR 3.4.2.1 provides methods for demonstrating jet pump operability which are based on vendor analysis and plant experience as presented in GE SIL 330.

NRC subsequently endorsed this methodology in NUREG/CR-3052, *

"Closecut of IE Bulletin 80-07: BWR Jet Pump Assembly Failure". Hence, we consider that the methods and previsions presented in SR 3.4.2.1 represent industry best practices which NRC has previously reviewed and accepted.

Additional discussions of the comparisons of SRs between CTS

and ITS for jet pump operability are provided in DOCS A3 and H2 for ITS.3.4.2.

Item 3.4.2-6 ITS SR 3.4.2.1.a adds a SR that the recirculation pump flow to speed ratio be verified less than or equal to 5% from established patterns and the jet pump' loop flow to recirculation pump speed ratio be less than 5% from established patterns to_ determine jet pump operability.

This new SR is more restrictive than CTS 4.6 E.1.a which allows jet pump operability be demonstrated if the recirculation pump loop flows be compared within 15% of each other. Additionally, a similar SR to CTS SR 4.6.E.1.a has been separately established as proposed SR 3.4.1.1 for recirculation loop operation. IIence, SR 3.4.2.1.a is altogether considered an entirely new SR, and, hence, a more restrictive requirement.

ITS SR 3.4.2.1.c is a new requirement that stipulates that each individual jet pemp be no more than 10% different than the established baselane flow for itself. CTS 4.6.E.1.b requires that the indicated core flow rate derived from the loop flow measurements not vary by more than 10%.

Therefore, ITS SR 3.4.2.1.c is dissimilar to CTS 4.6.E.1.b.

Accordingly, for practical considerations, ITS SR 3.4.2.1.c is considered a new and more restrictive SR.

We consider that the methods and provisions presented in SR 3.4.2.1 for demonstrating jet pump operability, which are

- the same as those in NUREG-1433, represent industry best practices which NRC has previously reviewed and accepted.

In addition, the requirements can be readily implemented with no impact on system performance and represent improvements in TS.

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Weiagree"with.the NRC-commentLon DOC M1, although the change

= isustillsconsidered more! restrictive. DOC M1 has been  ;

- revised tofinclude afdiscussion on the~ comment' subject. .

matter.'

3.4.3-2 We agree with the NRC comment.. This change is'now- j adequately addressed by the revision to' DOC M1 in response -

to NRC comment 3.4.3-1. With this revision, DOC L2 no-longer applies and has been deleted.

. 3.4~.3-3

-In_ response to the NRC comment, ITS SR 3.4.3.1 has been .

revised toL"larify'that only 12-of the 13 S/RVs are required

- to meet the SR.- The SR BASES were likewise revised.

3.4.3-4 The S/RV testing for ITS SR 3.4.3.2 is performed following refuel: outages during the first reactor start-up. The

, . surveillance instruction requires that the reactor pressure be elevated for the test. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance is based onf plant. experience and provides a reasonable time, following establishment of test-conditions, to set-up for the surveillance test, conduct the test, and evaluate-results in an orderly manner.

3.4.3-5 Specification of S/RV setpoint tolerances in terms of percentages rather.than absolute-values maintains consistency with Inservice Test Program and ASME code requirementsEfor relief valve settings. Considering that -

-the conversion between percentages _-and numeric values is ,

. simple,fthe deviation from the1NUREG-1433 format.is minor.

Therefore, we prefer the.ITS format as-proposed by_TVA.

3.4.3-6 i CTS 54.6.D.4 will be relocated to the TRM. DOC LA2 has been-appropriately revised.

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ITS Section 3.4.4 3.4.4-1 The limit on total-reactor coolant leakage rate is established so that in the absence of normal AC power and normal feedwater flow, and without using Core Standby Cooling Systems, the leakage loss from the nuclear system can be replaced by other systems. The control rod drive system (CRD) and the Reactor Core Isolation Cooling (RCIC) system are independent of the feedwater system and normal AC power. RCIC is powered from DC power supplies and two of the five CRD pumps are powered from the Emergency Diesel Generators. The limit on total leakage was also established to allow a reasonable margin below the discharge capability of either the floor drain or equipment drain pumps. The CTS 3.6.C.1.a value of 25 gallon per minute (gpm) total leakage was arbitrarily chosen as meeting both of the above criteria. In the NUREG, the leakage is a bracketed value.

The 30 gpm value in proposed ITS 3.4.4.c is also well below the capacity of either the CRD or RCIC system for reactor vessel makeup, an9 either the floor drain or equipment drain system for discharge capability. The 30 gpm value will allow sufficient time for corrective action to be taken before either the nuclear system coolant make-up or the drywell sump removal capabilities are exceeded. Therefore, since 30 gpm was the value suggested in NUREG-1433, and there is no adverse consequence for BFN to adopt this value, it was chosen in order to be consistent with NUREG-1433 as justified in DOC Ll.

3.4.4-2 The only accurate means of quantifying total reactor coolant system leakage is through the use of the drywell floor drain and equipment drain sump monitoring system averaged over a finite period of time. CTS 4.6.C.1 requires the sumps be checked every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. To meet CTS SR 4.6.C.1, sump integrator readings are taken every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and total les.kage calculated and integrated over the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Since the integrator readings are dependent on sump levels (e.g., the sump pamps are automatically started and stopped based on sump levels), the sumps are manually pumped down at approximately 2400 each day to provide a consistent starting point for comparison each day.

r 3.4.4-3 We agree that the 4 additional hours in the Required Actions A .1, B.1, and B.2 is additive and results in a total of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to be in cold shutdown compared to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under CTS.

ITS does= require that the reactor be made subcritical in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Hot Shutdown) whereas CTS does not explicitly provide a time requirement for being in Hot Shutdown. Hence, the ITS require-the reactor be made subcritical sooner than would be required under CTS. To address the NRC comment, DOC L4 has been revised to explicitly discuss the change in timing requirements.

The BFN proposed ITS Completion Times are consistent with NUREG-1433. The additional time allowance (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />) to be in Cold-Shutdown compared to CTS is not large and is reasonable in terms of operating experience of shutting down in an orderly manner and without challenging plant systems following the decision to shutdown.

3.4.4-4 Generic Letter 88-01, Supplement 1 states; "On the basis of discussions with BWR operators, industry consultants and the BWR Owners' Group and a review of licensee's responses to GL 88-01, the staff determined that the following acceptable alternative staff positions and clarifications would facilitate the iraplementation of GL 88-01:

(1) The staff found that monitoring reactor coolant system (RCS) leakage every 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> creates an unnecessary administrative hardship for plant operators. Thus, RCS leakage casurements should be taken at least cnce per shift, not to exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Based on previous operating history related to monitoring and detection of coolant system leaks, BEN agrees with the alternate staff' position that a 12-hour surveillance frequency is satisfactory. Additionally,.the removal of unnecessary operator burdens will allow the operators to more fully concentrate on existing plant operations and conditions and, therefore, represents an improvement in TS.

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! 3.4.4 ITS LCO 3.4.4.d specifies that unidentified leakage within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> be limited to s a 2 GPM increase in unidentified leakage within the past-24 hours while in MODE

1. Since there is no previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period in MODE 1 until the plant has-operated in MODE 1 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the limit cannot be applied for the initial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Hence, CTS and ITS requirements in this regard are considered equivalent.

3_4,4. doc

F ITS Section 3.4.5 3.4,5-1 The subject instrumentation requirements as marked for DOC LA5 for the equipment drain monitoring system will be relocated to the TRM. DOC LA5 has been revised accordingly.

3.4.5-2 The subject instrumentation requirements as marked by LA4 for the equipment drain monitoring system will ba relocated to the TRM. DOC LA4 has been revised accordingly.

3.4.5-3 DOC M5 has been revised in response to the NRC concern to provide additional discussion of the more restrictive frequency requirement for performance of channel checks for the primary containment atmospheric monitoring system. 1 Performance of the channel check does not require removal of the system from service and does not require significant  ;

resources.

3.4.5-4 As noted in DOC LAl, a discussion of alternate leakage monitoring methods is included in the BASES for ITS 3.4.4.

Specifically, the BASES for ITS SR 3.4.4.1 discuss that a variety of alternate means are available to measure and quantify RCS LEAKAGE. The alternate method currently described in NOTE 2 of CTS 3.2 E (manual sump timing) will be carried forth in a surveillance test as an alternate means to satisfy SR 3.4.4.1. We do not, however, believe it is necessary to carry the level of procedural details for performing the surveillance actions currently in NOTE 2 into the ITS or BASES since these details are not required in TS to ensure system operability. DOC LA1 has been revised to be more specific on this point.

3.4.5-5 BFN is not committed to P.egulatory Guide 1,45. Therefore, the reference to Regulatory Guide 1.45, was intentionally omitted from ITS BASES section 3.4.5 to prevent

- misinterpretation of a specific BEN commitment to comply with Regulatory Guide 1.45. Regulatory Guide 1.45 was retained as a section reference in ITS BASES Section 3,4.4

+an-

I since it provides guidelines on additional approved methods to quantify leakage which BFN may wish to utilize in the future.- However, to be consistent with the deletion in ITS 3.4.5, we have deleted the reference to Regulatory Guide 1.45 in the ITS 3.4.4 BASES.

3.4.5-6 As noted in the responses to comments 3.4.5-1 and 3.4.5-2, the subject instrumentation requirements for the floor drain and equipment drain monitoring system are being relocated to the TRM. DOC LA2 has been revised accordingly.

3.4.5-7 The APPLICABLE SAFETY ANALYSES BASES for ITS 3.4.5 discusses the annunciator alarms for RCS leakage. We do not, however, believe it is necessary to carry the level of procedural detail regarding operator actions in event of an alarm now in NOTE 3 for CTS Table 3.2.E into the ITS or ITS BASES.

Standard BFN Alarm Response Procedures require operator acknowledgment of all alarms, and if confirmed, to take specified follow-up actions which includes entering TS ACTIONS as applicable.

3.4.5-8 As noted in the responses to comments 3.4.5-1 and 3.4.5-2, the subject instrumentation requirements for the floor drain and equipment drain monitoring system are being relocated to the TRM. DOC LA4 has been revised accordingly.

3.4.5-9 The drywell particulate and gaseous monitoring systems are grouped together in ITS LCO 3.4.5.b since they provide a similar function. Specifically, the instruments provide a means for an early warning of increased RCS leakage. At B FN, the particulate and gaseous monitoring instruments share common instrumentation features such as common suction and discharge lines and valvino to the drywell for sampling purpocas.

Plant experience has demonstrated that both of these instruments have high availability factors and are capable of indicating small magnitude (< 0.25 gpm) increases in RCS leakage prior to indication from the drywell floor drain sump monitoring system. The floor drain system is then used to confirni and quantify the leakage rate. Since either instrument provides a similar early warning of RCS leakage,

- -)

has historically demonstrated high availability, and is capable of detecting small increases in RCS leakage' prior to the drywell ficor drain sump monitoring system, it is appropriate that either be credited for the purposes of satisfying ITS 100 3. 4. 5.b. Overall, proposed ITS 3.4.5 requires suff30ient monitoring systems to ensure availabilit,.of diverse instrumentation which can detect and- ,

quantity unidentified leakage. Therefore, the proposed ITS are considered an improvement in TS requirements for detecting indications of increased leakage.

3.4.5-10 As noted in the responses to comments 3.4.5-1 and 3.4.5-2, the sub]ect instrumentation requirements for the floor drain and equipment drain monitoring system are being relocated to the TRM. DOC LA2 has been revised accordingly.

3.4.5-11 As discussed in Justification P25, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> COMPLETION TIME in ITS ACTION A is the same as CTS and represents current BFN design and licensing basis. This requirement was approved as part of a previous CTS license amendment (TS-222).

3.4.5-12 DOC L1 for ITS 3.4.5 provides the discussion of the less restrictive requirerart for CTS 3.6.C.3 compared to ITS regarding time to shutdown when leakage detection monitoring systems are inopecable. DOC L1 has also been revised to reflect the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> differential pointed out in the NRC comment.

3_4_5,doo 4

ITS Section 3.4.6 3.4.6-1 We agree that the proposed ITS 3.6.6 Applicability would allow the reactor to be critical and exceed reactor coolant chemistry provided all main steam lines were isolated. DOC M1 has been revised to provide more discussion with regard to this point. Due to the limited applicability, a separate "less restrictive" discussion is not deemed necessary.

3.4.6-2 Proposed ITS 3.4.6 retains the same reactor coolant system (RCS) activities as those in CTS. Actual reactor chemistry is maintained at levels considerably below the CTS / proposed ITS limits, but to preserve operating flexibility and margins, BFN desires to retain the existing licensing basis values.

Regarding power transients, ITS does not provide a specific allowance as to when the lower limit (3.2 Ci/gm) can be exceeded, but rather provides that the coolant activity be returned to within limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Since the number of power transients is typically very low and since significant margin exists between actual observed coolant activities and the proposed ITS, in practice, the retention of a " power transient" stipulation would have little impact.

Therefore, to maintain closer consistency with NUREG-1433, the CTS " power transient" provision is not carried into the proposed ITS. Additionally, as discussed in DOC L1, NRC has indicated in Generic Letter 85-19 that reporting of iodine spiking is no longer important due to improvements in fuel reliability and fuel integrity management practices.

3.4.6-3 Both CTS and ITS would require that the reactor be shutdown in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> as discussed in DOC A3. DOC L2 is also applicable to CTS 3.6.B 6 and to address the NRC comment, 4 has been revised to better address the less restrictive time l allowances to be in a HOT SHUTDOWN condition.

]

3 3.4.6-4 CTS 3.6.B.6 states "This limit may be exceeded followir.g power transients for a maximum of 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />." The limit referred to is the equilibrium value of 3.2 gCi/gm of dose a

I equivalent I-131. If.this condition existedEfor over 48

. hours (with Dose - Equivalent I-131 5 p26Ci/gm), then CTS 1.0.C.1 would apply since CTS do.not provide specific actions. This would require the plant'be_placed!in-Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in' Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (total of-36 hours to Cold Shutdown).

This is the point DOC A3 was attempting to make (that the 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />'to Cold Shutdown required by CTS is essentially the same as the ITS 3.4.6 B.2.2 requirement to be in Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />).

DOC L2 explains the less restrictive requirement in ITS

- 3.4.6 ACTION B to close Main Steam Irolation Valves (MSIVs) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and Mode 4 within'36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This char 3. allows adequate time to complete an orderly plant shutdown without immediately shutting MSIVs. Since the shutting of MSIVs removes the normal method of cool down via the secondary aide (balance of plant) systems, and forces decay heat removal via the S/RVs and the Residual Heat Removal (RHR)/ Re=idual Heat Removal Service Water (RHRSW) systems, the CTS requirement unnecessarily places the plant in an abnormal condition and unnecessarily challenges plant safety systems to mitigate against an extremely unlikely event (main steam line break (MSLB)) in this time period. Therefore, this ITS change increases overall plant safety, is an improvement in Technical Spc ifications, and is consistent with NUREG-1433, 3.4.6-5 DOC L2 explains the less restrictive requirement in ITS to close MSIVs within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change allows adequate time to complete an orderly plant shutdown without immediately shutting MSIVs. Immediate closure of the MSIVs is typically an undesirable action since the action removes the normal method of cool down via the secondary side (balance of plant) systems and forces decay heat removal via

, the S/RVs-and the RHR/RHRSW systems. Thus, the CTS requirement inappropriately places the plant in an abnormal condition and unnecessarily challenges plant safety systems to mitigate against an extremely unlikely event (MSLB) in this time period. Therefore, this ITS change increases overall plant safety, is an improvement in Technical Specifications, and is consistent with NUREG-1433.

3.4.6-6

. Typically, Dose-Equivalent I-131 RCS activities at BFJ are on the order of 1.0E-5 to 1.0E-3 gCi/gm-(Unit 2 currently is approximately 8.0E-5 pCi/gm). Unit 3 is currently operating with'6 fuel leakers and the Dose Equivalent _I-131 is_ higher at approximately 2.0 E-3 gCJ /gm. The higher number of leaking bundles on Unit 3 is attributed to use of an inventory of older fuel bundles which were affected by crud induced localized corrosion. These susceptible bundles will be discharged at the end of the current operating cycle (Fall-1998).

These I-131 values have considerable margin to the value (3.2E-2 gC1/gm) in CTS 4.6.B.6 for which the increased sampling would be required if under certain additional conditions (e.g., startup conditions). Considering that the deleted CTS requirements have a small probability of ever requiring increased sampling, and that the Dose Equivalent I-131 sampling frequency has decreased from the CTS monthly frequency to the more restrictive NUREG-1433 frequency of every 7 days (See DOC M3), these changes are justified and represent an improvement in TS which are consistent with NUREG-1433. For the same-reasons, several of the detailed CTS requirements (for instance, 3 consecutive samples) are no longer necessary to be maintained in TS and are being deleted as TS requirements. DOC LA1 has been revised to address these ci.snges.

3.4.6-7 BFN places the Mode switch in RUN (MODE 1) at approximately 8% power by plant procedures. During a typical startup the plant is brought to 100% power as rapidly as possible consistent with plant procedures. Thus, standard operations involves establishing " equilibrium" power conditions well above 8% RTP and typically at full power. -Therefore, the

" equilibrium" conditions referenced in CTS 4.6.B.5 would never be applied at low power since equilibrium states are entered at higher powers. Therefore, there is no real difference between CTS 4.6.3.5 and ITS SR 3.4.6.1 at less than 81 RTP.

Also, as stated in the ITS 3.4.6.1 Bases , "This SR is modified by a note that requires this surveillance to be performed only in MODE 1 because the level of fission products generated in other modes is much less." Therefore, any Dose Equivalent I-131 value at low power levels would be so small as to be essentially meaningless.

3.4.6 The frequency'for monitoring reactor coolant samples has been reduced from monthly to every 7 days in the conversion from CTS to ITS. Sampling every seven days is, however, consistent with actual coolant chemistry monitoring practices at BEM. Therefore, implementation of this change poses no undue hardship and promotes consistency with NUREG-1433.-

3,4 ,6. doc i

ITS Section 3.4.7 3.4.7-1 DOC M1 has been revised to provide additional discussion of new more restrictive aspects of ITS Section 3.4.7.  !

3_4,7. doc

ITS Section 3.4.8 3_. 4 . 8 -1 DOC M1 has been revised to provide additional discussion of more restrictive aspects of new ITS Section 3,1.8.

3 ,4,0. doc

• r

ITS Section 3.4.9 -

3.4.9-1, After further review, TVA has decided to incorporate the provisions of NUREG-1433 Section 3.4.11 on reactor pressure monitoring as ITS 3.4.10. Revised ITS and BASES are '

included in this submittal.

3.4.9-2 The notes on CTS Figure 3.6-1 provide useful reference information and will be retained on the corresponding ITS Figure 3.4.9-1.

3.4.9 3 The differentiation between nuclear and nonnuclear heatups contained in CTS is not provided in ITS SR 3.4.9.1.a, but is retained in Figure 3.4.9-1. To provide further clari fication, Note 1 will be modified to read:

" ...cooldown operations or RCS inservice leak ...",

versus" . . .cooldown operations and RCS inservice leak . . . " .

This change will prevent a potential misinterpretation of the Note 1 applicability.

BFN concurs that ITS could be interpreted as being more restrictive than CTS regarding conformance with Curve #2 when the reactor vessel head studs are detensioned and will add an additional clarification note to SR 3.4.9.1 as follows:

3. The limits of Figure 3.4.9-1 do not apply when the tension from the reactor head flange bolting studs is removed.

The addition of this note will maintain'the current licensing basis.

3.4.9-4 The surveillance test for CTS 3.6.A.7 uses a temperature element on the bottom head drain line which is the best available measurement of the reactor coolant temperature in the vicinity of the bottom head. In this regard, the terminology " bottom head drain" and " bottom head coolant" temperature are used interchangeably. The surveillance test for ITS SR 3.4'9.3 will utilize the same instrumentation.

l

3.4.9-5 Plant operating procedures. direct-that the recirculation pump be started as soon as possible following completion of the subject surveillance. Therefore, inclusion of a 15 minute requirement is consistent with normal operating practice, and the change ic-thus considered administrative.

3.4.9-6 The SR 3.4.9.3 BASES provide a discussion of the NOTE applicability for SR 3,4.9.3. In MODE 5, due to lower overall coolant temperatures and lower potential for significant-differences between the bottom head coolant temperature, overall stress on limiting components is low.

Also, recirculation pumps are seldom operated in MODE 5 due to equipment operational restrictions. Accordingly, monitoring of temperature differences is not required in MODE 5.

3.J.9-7 The_ current surveillance test for CTS 4.6.A.6 compares the recirculation pump loop temperatures just prior to starting the idle recirculation pump. Following the pump start, the temperatures in the two loops will quickly converge to the same temperature as the lower plenum water temperature.

Therefore, the differential between the two loops will be at a maximum just prior to the pump start and continually decrease following the start of the second pump. In this regard, the CTS terminology " prior to and during startup" is considered to refer to the activities associated with preparing and starting-the recirculation pump. Since, as noted above, the recirculation loop temperatures rapidly converge, the loop temperature comparison SR is most appropriately performed just prior to the pump start.

3.4.9-8 Logging of data required for the performance of surveillance tests is considered routine practice which is required by plant testing instructions and quality assurance requirements. Therefore, it is not required to retain a specific requirement to record data in the equivalent ITS SR.

3.4.9-9  !

The test methodology and temperature locations in CTS 4.6.A.1 are considered procedural details for performing '

surveillance tests. These details will be relocated to the SR which implements ITS SR 3.4.9.1.

3.4.,9-10 The test raethodology anc'. temperature locations in CTS

, 4.6.A.2 are considered proceder~_1 details for performing surveillance tests. These details will be relocated to the SR which Jmplements ITS SR 3.4.9.1.

3.4.9-11 .

The reason for the 15 minute requirement is provided in the bases for SR 3.4.9.2. 7his change is cons! stent with NUREG-1433.

3.4.9-12 Additional explanatioa for the new SRs is provided in the BASCS for the SRs.

3.4.9-13 The reasons for ACTIONS A, B, and C are provided in their respective BASES.

3.4.9-14 BEN agrees with the comment. Errors were made in the mark-ups of the prt osed ITS and the associated BASES. The current licensing basis was intended to be maintained, but the Unit 2 valut (82* F) was inadverttntly inserted for the Uni t 1 (80* ?) and 3 (70* F) values. Also, the Unit 2 Figure 3.4.9-1 was inadvertently inserted in Units 1 and 3 ITS.

The affected pages have been corrected in this submittal package.

3.4.9-15 BEN agrees that the Unit 3 CTS mark-up for nota 2 of SR 3.4.9.1 should be for SR 3.4.9.5. The CT3 mark-up has been '

revised accordingly.

As explained in DOC M2, the new ITS SR 3.4.9.6 and SR 3.4.9.7 frt,oencies represent additional requirements for B FN . The noted explaining the applicability of these

l ad-Jitional requiremants are necessary for consistent ,

implementation in accordance with NUREG-1433.

The new requirements of SR 3.4.9.6 and 3.4.9.7 are. -l implementable, do not require removing systems from service, or pose undue administrative burdens. These changes are also consistent with NUREG-1433. ,

In addition, the note for SR_3.4.9.6 has been modified in ,

this submittal to 85' F for all three units. This will provide adequate margin for monitoring for Unit 2 (limiting unit) while pro' tiding a common single temperature for all three units.

3,4,9. doc [

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