ML20203L426

Forwards Request for Addl Info Re Conversion of Custom TS to Improved Std TS

ML20203L426
Person / Time
Site:	Browns Ferry
Issue date:	02/26/1998
From:	De Agazio A NRC (Affiliation Not Assigned)
To:	Zeringue O TENNESSEE VALLEY AUTHORITY
References
TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9803060044
Download: ML20203L426 (28)

Text

__

Mr. O. J. Z:ringua Chief Nucle:r Officer and Executive Vice President Tennessee Valley Authority GA Lookout Place 1101 Market Street Chattanooga, Tennessee 37402 2801

SUBJECT:

BROWNS FERRY PLANT, UNIT NOS. I,2, AND 3 REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION OF CUSTOM TECHNICAL SPECIFICATIONS TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432, AND M96433)

Dear Mr. Zeringue:

By letter dated April 11,1997 Tennessee Valley Authority proposed revisions to technical specifications to convert the Browns Ferry Nuclear Plant Units 1,2, and 3 Custom Technical SpecJfnations to the improved Standard Technical Specification format. The Nuclear Regulatory Commission staff is reviewing your application and has determined that additional information is required to complete the review. The tables in Enclosures 1 and 2 provide staff concerns with the Standard Technical Specification and Custom Technical Specification markups respectively for Electrical Systems.

Your prompt response will assist us in completing a timely review.

Sincerely,

/s/

Albert W. De Agazio, Senior Project Manager Project Directorate 113 Division e' Reactor Frycts - 1/ll Office of Nuclear Remor Regulation Docket Nos. 50-259,50 200, and 50-296 Serial No. BFN-98-001

Enclosures:

1. Standard Technical Specification markup comments

2. Custom Technical Specification markup comments p' % l t

cc w/encis: See next page DISTRIBUTION-tby p p ~,O ', b a [_ [ [

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utS b Docket File F. Hebdon OGC PUBLIC B. Clayton ACRS PDll 3 R/F A. De Agazio L. Plisco, Region 11 J. Zwolinski (A)

W. Beckner DOCUMENT NAME: G:\\BFN\\96431EBT.RAI To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy 0FFICE PM PDil*3 M f[ #

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Official Record Copy 990306 P" ^0044 980;26't '

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February 26, 1998 Mr. O. J. Zoringue Chief Nuclear Officer i

= and Executive Vice President i

Tennessee Valley Authorny 6A Lookout Place 1101 Market Street I

Chattanooga, Tennessee 37402 2801 1

SUBJECT:

BROWNS FERRY PLANT, UNIT NOS. I,2, AND 3 REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION OF CUSTOM TECHNICAL 4

l SPECIFICATIONS TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432, AND M96433)

Dear Mr. Zoringue:

By letter dated April 11,1997, Tennessee Valley Authority proposed revisions to technical specifications to convert the Browns Ferry Nuclear Plant Units 1,2, and 3 Custom Technical Specifications to the improved Standard Technical Specification format. The Nuclear Regulatory Commission staff is reviewing your application and has determined that additional i

information is required to complete the review.~ The tatsles in Enclosures 1 and 2 provide staff concems with the Standard Technical Specification and Custom Technical Specification markups respectively for Electrical Systems.

Your prompt response will assist us in completing a timely review.

Sincerely,

/s/

Albert W. De Agazio, Senior Project Manager Project Directorate ll 3 Division of Reactor Projects.1/11 office of Nuclear Reactor Regulation Docket Nos. 50 259,50 260, and 50 296 Serial No. BFN 98-001

Enclosures:

1. - Standard Technical Specification markup comments

2. Custom Technical Specification markup comments oc w/oncis: See next page DISTRlRUTION:

Docket File F. Hebdon OGC PUBLIC B. Clayton ACRS PDil 3 R/F

- A. De Agazlo L Plisco, Ftegion ll J. Zwolinski(A)

W.' Beckner.-

DOCUMENT NAME: Gi\\BFN\\96431EST.RAI Ta receive a copy of this document, indicate in the box: "C" = Copy without :sttachment/ enclosure "E" = Copy with cttachment/ enclosure "N" = No copy 0FFICE-P88PDil*3 M fD44 La: Poll 3 I -I DIPDll*3, j l

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02/ w /9s 02/ t V98 02 E fres 02/ /9s Official Record Copy

a nao lt UNITED STATES y*

NLICLEAR REGULATORY COMMISSION WASHINGTON, o.C. soeuanoi k*..,..

February 26, 1998 Mr. O. J. Zeringue Chlef Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402 2801

SUBJECT:

BROWNS FERRY PLANT, UNIT NOS. I,2, AND 3 REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION OF CUSTOM TECHNICAL SPECIFICATIONS TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432, AND M96433)

Dear Mr. Zeringue:

By letter dated April 11,1997, Tennessee Valley Authority proposed revisions to technical specifications to convert the Browns Ferry Nuclear Plant Units 1,2, and 3 Custom Technical Specifications to the Improved Standard Technical Specification format. The Nuclear Regulatory Commission staff is reviewing your application and has determi" 4 that additional information is required to complete the review. The tables in Enclosures 1 ai,. J p* ovide staff concerns with the Standard Technical Specification and Custom Technical Specification markups respectively for Electrical Systems.

Your prompt response will assist us in completing a timely review, Sincerely, Albert W e Agazio, Senlo r ject Manager Project Directorate 113 Division of Reactor Projects. :/II Office of Nuclear Reactor Regulation Docket Nos. 50 259,50-260, and 50 296 Serial No. BFN 98-001

Enclosures:

1. Standard Technical Specification markup comments

2. Custom Technical Specification markup comments cc w/encls: See next page

o Mr. O. J. Zeringue BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority

)

3 cc:

Mr. J. A. Scalice, Senior Vice President Mr. Mark J. Burrynski, Managar Nuclear Operations Nuclear Licensing Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place 4J Blue Ridge 1101 Market Street 1101 Market Street Chattanooga, TN 37402 2801 Chattanooga, TN 37402 2801 Mr. Jack A. Bailey, Vice President Mr. Timothy E. Abney, Manager i

Engineering & Technical Services Licensing and Industry Affairs Tennessee Valley Authority Browns Ferry Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402 2801 Decatur, AL 37402 2801 Mr. C. M. Crane, Site Vice President Regional Administrator, Region il Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority 61 Forsyth Street, SW., Suite 23T85 P.O. Box 2000 Atlanta, GA 30303-3415 Decatur, AL 3560g Mr. Leonard D. Wert General Counsel Senior Resident inspector Tennessee Valley Authority U.S. Nuclear Regulatory Commission ET 10H Browns Ferry Nuclear Plant 400 West Summit Hill Drive 10833 Shaw Road Knoxville, TN 37902 Athens, AL 35611 Mr. Raul R. Baron, General Manager State Health Officer Nuclear Assurance Alabama Dept. of Public Health Tennessee Valley Authority 434 Monroe Street 4J Blue Ridge Montgomery, AL 351301701 1101 Market Street Chattanooga, TN 37402 2801 Chairman Limestone County Ccmmission Mr. Karl W. Singer, Plant Manager 310 West Washington Street Browns Ferry Nuclear Plant Athens, AL 35611 Tennessee Valley Authority P.O. Box 2000 Decatur, AL 3560g

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e ENCLOSURE 1 STANDARD TECHNICAL SPECIFICATION MARKUP COMMENTS

BFN STS MARKUP LCO 3,8.1 133ME DQGl REE DESCRIPT10N COMMENTS JED 1

P1 LCO 3.8.1 Insert 3.81A adds a requirement for The licensee should opposite Unit (s) DG OPERABILITY.

review Insert 3.81A with However, the requirement includes the a view towards deleting phrase "when (Unit 3)(Un:: 1 or 2)M the qualifying phrase.

NQI nn Modes 13. This is pntentially confusing because it begs the question, "what are the requirements when (Units 3)(Units 1 or 2) M in Modes 13. The i

opposite unit DGs are req'd. regardless of opposite unit (s) operating status.

2 P42 LCO 3.8.1 JFD P42 is confusing. The discussion The licensee should concentrates on Unit 1 and 2, but insert review the plant design, 3.81B appears to be applicable to all 3 Insert 3.81B and JFD units, is the common accident signal P42 for consistency, logic common to all 3 units? Or only Units 1 and 2.

3 P51 LCO 3.8.1 The JFD makes a case for a change in -

The licensee should Cond.A the language of NUREG SR 3.8.1.1, but consider including a SR does not adequately justify eliminating the 3.8.1.1 (ala NUREG) in SR entirely. This SR is necessary to tie -

the BFN ITS. albeit with together the LCO requirements for revised language.

OPERABILITY and the LCO Conditions / Req'd Actions for an inoperable offsite source.

4 P2 LCO 3.8.1 The ITS chsnges the NUREG Completion The licensee should Cond.A Time for this Condition from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and consider revising the 6 days to 7 days and 14 days. The -

second Completion Time change from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days is from 14 days to 10 days.

acceptable (retains CLB). However, the change from 8 days to 14 days is not acceptable. The NUREG Completion Time is based on adding 3 days to a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time, it was not and is not intended to be a blanket endorsement to double any Completion Time, including the BFN CLB of 7 days.

5 P51 LCO 3.8.1 See issue #3 (i.e., adding a SR As stated in issue #3.

Cond.B associated with offsite power OPERABILITY).

1

BFN STS MARKUP LCO 3.8.1 1810E DQCl 11EE DESCRIPTION COMMENTS K0 6

P2 LCO 3.8.1 See lasue #4, above re:7 day and 14 day As stated in issue #4.

Cond.B Completion Time.

7 P42 insert See issue #2, above. As noted, the JFD The li.mnsee should review 3.8 3A appears to be restricted to Units 1 and 2, JFD 42 to determine what but the proposed ITS (LCO 3.8.1, changes are required to Conditions C and D) appears to be resolve the possible applicable to all 3 units, inconsistency with the proposed ITS.

8 P42 LCO 3.8.1 See previous discussions re: JFD 42.

Licensee should review Cond.I The proposed ITS indicates the common JFD 42 for consistency accident signal and 480V load shed logic with proposed ITS.

requirements are applicable to all 3 units wheress JFD P42 seems to limit applicability to Units 1and 2.

9 P51 NUREG See previous comments re: including an As stated for issue #3.

SR 3.8.1.1 SR for offsite power.

10 P29 ITS The staff does not agree with the Licensee should consider SR 3.8.1.1 licensee's position as stated in JFD P2g.

retalning the Note. This is There is nothing in the NUREG or a permissive, not a Regulations that specifically states that requirement. (Note: the successful completion of one SR can staff does not disagree satisfy the requirements of another SR.

that any action can satisfy To avoid possible confusion, the NUREG the requirements of an SR Note should be retained, if the acceptance enteria are met-the staff disagrees that this is an

" understood permissive "

2

i BFN STS MARKUP LCO 3,8,1 R&QE QQGl ME DESCRIPTION COMMENIR 20 11 P30 ITS Deletion of NUREG Note 2 is acceptable.

The licensee should SR 3.8.1.1 However, the licensee should note that reconsider deletion of this this is a permissive, not a requirement. If permissive, deleted now, the permissive cannot be utilized unless the Note is again included by license amendment. This permissive cannot be implemented in the Bases.

Deletion of the werding 'Yrom standby The licensee should justify conditions" from the body of the SR it not deletion of this wording or acceptab.e. This wording has a spect'ic retain the NUREG.

purpose and the licensee has not justified deleting it.

12 P32 ITS The justification for the 31 day DG testing The li';9nsee should SR 3.8.1.1 is inadequate. The provisiens of prov!de a justification GL 94 01 expired in 7/96 and are no based on the Maintenance longer applicable.

Rule.

13 P31 ITS The proposed addition to Note 4 !s The licensee should SR 3.8,1.2 acceptable in concept; howevar, this is consider leaving the

. not the appropriate place for the addition, proposed addition tu Note 4 is a rerJirement; l.e., it must be Note 4 as part ofITS 3R done. The proposed addition is a 3.8.1.1, Note 2.

permissive; i.e., it may be utilized if desired. A permistive and a requirement should not be included in the same Note.

Suggest leaving this item as part of ITS SR 3.8.1.1 (per the NUREG).

14-B2 ITS The staff does not understand why the The licensee is requested SR 3.8.1.2 licensee has not taken advantage of the to provide a rationale for load range provide in the NUREG for DG this deviation from the testing. The load range is included as a NUREG.

means of eliminating DG overloading and attendant degradation.

3

BFN STS MARKUP LCO 3.8.1 ISSUE QQGl ME DESCRIPTION GOMMENTS JEQ 15 P22 NUREG ls the intent of this JFD to state that the The licensee should t

SR 3.8.1.5 NUREG SR is not req'd, by BFN CTS, answer the staffs question and the licensee does not choose to and provide a revised JFD, adopt the NUREG7 If so,it should be as applicable.

plainly state in the JFD, and all i

extraneous material deleted.

18 B2 ITS The staff has accepted a revision to this SR 3.8.1.4 SR that the licensee may want to consider. See the Watts Bar TS for details of the change to this SR, 17 P43 NUREG The staff does not fully understand this The licensee should SR 3.8.1.8 JFD. Per discussions with the licensee, provide clarification of the the staff is of the opinion that breakers at JFD per staff comments, the Unit Board level change position in response to a LOOP (or by manual action) to transfer power to the shutdown bussos and boards from the normal to the alternate source. This conflicts with this JFD. Clarification is required.

18 B2 ITS The staff has the following questions The licenses should B3 SR 3.8.1,5 regarding the plant specific values for this provide a response to the SR:

staffs questions.

1.) What is the basis for the 68.75 Hz value in part a (this is 11% increase over 60 Hz)?

2.) What is the basis for the 4800VAC value in part b (this is 15% increase over 4160VAC)?

3.) What is the justification for deleting the 3 second time in part b?

4.) What is the justification for deleting part c of the SR7 4

RFN STS MARKUP 1.CO 3.8.1 13 tug QQGl SEE DEBcRIPTION COMMENTE JED 19 P44 ITS -

Given the design of BFN, how is this SR The license, should P38 SR 3.8.1.6 conducted with the units at power without provide a response to the P34 creating a safety concem and still meet staffs question, the acceptance criteria.

The licensee should provide adequate Deletion of the voltage and frequency justification for deleting acceptance criteria for this SR is not most of the acceptance acceptable, as is JFD P44.

criteria for this SR.

The licensee should also Deletion of the acceptance criteria in provide a justification for parts d and e of the SR is not acceptable deleting 1 rom standby as is JFD P38.

conditions" from this LCO.

L 20 B2 ITS See comment #14 relating to load range As in comment #14.

l SR 3.8.1.7 for DG loading.

21

.P39 NUREG JFD 39 does not appear to be related to The licensee should SR the proposed deletion of NUREG SR provide an appropriate 3.8.1.15 3.8.1.15. The proposed change is, JFD, or retain the NUREG therefore, not acceptable.

SR (Hot Restart issue).

22

.P40 NUREG JFD 40 does not appear to be related to The licensee should SR.

the proposed deletion of NUREG SR-provide an appropriate 3.8.1.16 3.8.1.16. The proposed change is.

JFD, or retain the NUREG

.therefore, not acceptable.

SR (Transfer to offsite issue).

23 P41 NUREG The staff does not understand this JFD.

The licensee shou d

-SR If there is no test mode for the BFN DGs, expand the JFD to address 3.8.1.17 how is the monthly SR conducted? How the staffs concems, does the common accident signal factor into the lack of a " defined test mode".

+

Pending a receipt of a better explanation, this change is not acceptable.

24 B1 ITS The staff agrees that the SR wording The licensee should SR 3.8.1.8 needs to be changed to reflect the BFN consider revising the SR to design. However, the proposed wording more completely explain is somewhat confusing, particularly the what is meant by part about the " calibration tolerances" for

" calibration tolerances".

each individual timer.

5

BFN STS MARKUP LCO 3.8.1 lSSUE QQCl flee DESCRIPTION GDMMENTS Jf_Q 25 P32 NUREG GL 94-01 is not an adequate justification The licensee should Table for deleting this Table. The JFDs should provide a justification 3.8.1 1 be revised to justify the change based on based on the BFN DG the BFN implementation of the Maintenance Plan Maintenance Rule, developed in accordance with the Maintenance Rule, I

6

BFN STS MARKUP LCO 3,8,2 ISSUE DQCd REE DESCRIPTION COMMENTS I

1 P6 LCO 3.8.2 The staff does not understand the The licensee should Insert p,'oposed wording of the Insert if the consider revising the Insert 3.818A Unit 3 DGs are required to support Unit 1 to delete the reference to or 2, what difference does it make what the MODE Unit 3 is in.

MODE Unit 3 is in. Stated differently, (this is also applicable to how many Unit 3 DGs are req'd. to the Unit 1 and 2 DGs support Unit 2 (in MODE 4 or 5) when req'd to support Unit 3)

Unit 3 is in MODE 1,2 or 37 Is there any difference?

2 P27 LCO 3.8.2 This JFD appears to be in conflict with the The licensee should review Cond.A proposed change. The JFD discusses this change and the related

" inoperable" while the change says "no JFD with a view towards AC source to any req'd. 4.16 kV SD BD."

eliminating any Moreover, the staff does not understand inconsistency and the difference between "de-energized" confusion.

and "no AC source."

3 P6 LCO 3.8.2 The staff does not fully undwatand how The licensee should review Cond. A.1 the Completion Time for this condition is the staffs concems with a supposed to work, and the Bases does view towards identifying not provide much help. With only one what,if anything, the staff offsite circuit required, all required doet. not understand about features are supported by the one offsite the proposed LCO and source. If it becomes inoperable, all Bases, and propose required features must be declared appropriate revisions to inoperable, including the redundant make the submittal more required, features. This means that the

clearly, inoperability of the one offsite source means immediate entry into the LCOs for required features. In light of this, what is the purpose of having this condition?

4 P6 Insert consider Unit 2 and Unit 3 in MODE 4 or The licensee should review 3.8 20A

5. The SRs required for the DGs in these the staffs concem and MODES are not the same as the SRs propose changes as req'd. In MODES 1,2 or 3. Does the appropriate.

proposed insert take this into account?

Are the DG SRs required with a unit in MODES 4 or 5 adequate to establish OPERABILITY of the DGs required to support another unit?

7

BFN STS MARKUP LCO 3,8,3 ISSUE DQGl REE DEECdilEHQN COMMENTS JEQ 1

P48 NUREG The licensee proposes to substitute a The licensee should LCO 3.8.3 modified NUREG SR 3.8.3.3 for C TS consider adopting the Cond.D 4.9.A.1.e. This is acceptable to an NUREG Fuel Oil program extent;i.e., the staff acknowledges that since it is more effective the properties of fuel oilin ASTM Dg75 than CTS, but involves need not be verified periodically, approximately the same However, these properties do need to be level of effort, verified for new fuel, and critical parameters should be checked prior to adding any riew fuel to the stored fuel inventory. This can be accomplished by retalning Cond. D and the portions of NUREG SR 3,8.3.3 proposed for deletion.

2 P35 LCO 3.8.3 It appears that the licensee does not fully The licensee should review Cond.D understand the organization of NUREG the proposed changes to LCO 3.8.3. The intent of the NUREG is Cond. D and discuss them to allow some flexibility if the air receiver with the staff with a vbw pressure is less than that required for the towards retaining the maximum number of starts but is still NUREG version. Also, the adequate for one or more starts. Also, licensee should provide a what is the basis for the 165 psig value, response to the staffs and what is meant by "the required" and questions.

" unit " proposed for addition to Cond. D?

3 P16 LCO 3.8.3 The JFD does not provide a The licensee should revise Cond.D comprehensive discussion on why the the JFD.

change is proposed or why it is acceptable.

4 P48 SR 3.8.3.3 See staff comments regarding changes to P35 SR 3.8.3.4 NUREG Cond. D associated with these JFDs.

5 P22 SR 3.8.3.5 is it the intent of this JFD to state that The licensee should revise SR 3.8.3,6 these NUREG SRs are not currently the JFD as required, required at BFN, and that the licensee has opted to not adopt them as part of the BFN ITS? If so, the JFD should be revised to so state, and the JFD discussion regarding maintenance activities deleted.

8

i 4

I BFN STS MARKUP LCO 3.8.4 i

lSSUE DQCl REE DESCRIPTION COMMENTS

\\

JED 1

P6 LCO 3.8.4 Should the term "one" be added to insert Provide a response to the Cond.A 3.8 24B ahead of " Unit"?

staffs question.

2 P1 LCO 3.8.4 What is the purpose of adding the term Provide a response to the R$ A.1

" required" to this action? The addition staffs question, appears to add confusion.

3 N/A SR 3.8.4.3 The Bases discussion for these SRs SR 3.8.4.4 includes a reference to IEEE 279.

However, the proposed ITS and Bases incorporate the rnodified performance discharge test for station batteries. This test only appears in IEEE-450(1995).

Therefore, either the reference is wrong, or the proposed ITS is wrong. The submittal i hould be revised to include the

- appropriate SRs with the correct reference, j

-=

9

o BFN STS MARKUP LCO 3.8.6 JBBUE QQCd fi1E DESCRIPTION COMMENTS JEQ 1

N/A SR 3.8.5.1 Inciusion of the Note in proposed SR 3.8.5.1 appears to be inappropriate. As stated in JFD P34, the DC subsystems are totally shared, and SRs must be conducted at power to avoid a multiple unit shutdown. The reverse is also true, i.e., demonstration of the OPERABILITY of a DC subsystem in support of an operating unit cannot be deferred because one unit is in MODE 4 or 5. This issue requires further discussion with the staff.

10

8 BFN STS MARKUP LCO 3.8S ISSUE POct REE DESCRIPTION COMMENTS JED 1

P46 Table The staff understands what the licensee The licensee should review 3.8.6-1 would like to accomplish with proposed the proposed TS with a Note d Note d. However, the proposed wording view towards revising the is not specific enough; i.e., "used as TS to incorporate tre idea appropriate"is not adequately defined.

of Note d in more specific Also, the " alternate values" are applicable terms and to identify those only to specific batteries, but the existing batteries to which proposed Note, as part of the BFN TS, is the Note is applicable, generic and would apply to any battery The licensee should also (existing or future). Th!s is not provide a copy of the acceptable. The proposed TS need to be manufacturer,'s evaluation

revised, and/orjustification for staff

review, l

l 11

I BFN STS MARKUP 1CO 3.8.7 lSSUE DOCI REE DESCRIPTiQN COMMENTS JED 1

P12 LCO 3.8.7 Why are 480 VAC RMOV Boards 1 A,18 and 1C (Unit 1),2A,2B and 2C (Unit 2),

and 3A,3B and 3C (Unit 3) not included in the ITS.

2 P12 LCO 3.8.7 CTS 3.9.B.4 allows one shutdown board The licensee should Cond.A to bo inoperable for 5 days provided that provide the requested specific OPERABILITY requirements for guidance and consider other power equipment and safety appropriate Bases systems are met. These requirements revisions, are not carried over to the ITS, at least in the same form. The CTS markup indicates that these CTS requirements are captured in LCO 3.8.1, Conditions and Actions. However, the staffis unable to determine how each of the CTS t

requirements is captured in ITS LCO j

3.8.1 The licensee should provide specific guidance for the staff in this area and incorporate pertinent parts of the guidance in the Bases.

3 P12 LCO 3.8.7 What is the basis for the second The licensee should Cond.A Completion Time (12 days) for this provide a response to the Comp condition?

Staffs question.

Time This question is also applicable to the Completion Times for Conditions B and C.

4 N/A LCO 3.8.7 CTS 3.9.B.5 addresses an inoperable The licensee should Cond.A shutdown bus and allows inoperability for provide a response to the up to 7 days. This CTS requirement is staffs question.

proposed to be addressed in Action A.3 of ITS LCO 3.8.1, Cond. A. The staff does not understand how this is accomplished. The licensee should provide a detailed discussion of how the ITS captures the CTS requirement.

The licensee should also explain why it is acceptable to allow a shutdown bus to be inoperable for 7 days while a shutdown board is limited to 5 days.

12 J

m

BFN STS MARKUP LCO 3.8.7 ISSUE DQGl REE DESCRIPTION COMMENTS JED -

5 P12 LCO 3.8.7 The staff does r'ot understand why an The licensee should Cond.B inoperable 480V SD BD results in an provide information to Action with an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time address the staffs concem, while an inoperable 4KV SD BD results in an Action with a 7 day completion time.

The licensee should provide an explanation for this apparent inconsistency.

6 P15 LCO 3.8.7 The staff does not undert.t.end why it is The licensee should

'Cond.D acceptable for a DG AuxiliaryBoard provide the explanation (480V) to be inoperable (de-energized) requested by the staff, for 5 days, it is the staff understanding that the DG Auxiliary Boards are essential for DG OPERABILITY; i.e., inoperable auxiliary board equals inoperable DG, Since each auxiliary board supports 2 DGs, inoperability of an auxiliary board equals 2 inoperable DGs. ITS LCO 3.8.1, Cond. G addresses 2 DGs inoperable and allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore at least one DG to OPERABLE status. The licensee should explain the obvious inconsistency between 5 days in one case and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in the other.

13 7m

BFN STS MARKUP LCO 3.8.7 188ME DOC /

REE DESCRIPTION COMMENTS JED-7 P12 = LCO 3.8.7 There are 4 RMOV MG sets per unit at The licensee should insert BFN. CTS 3.9.B.1.d (Unit 1) requires the provide the justification r

3.8 38E plant to be shutdown in 24 if any two MG requested by the staff or sets are inoperable. The proposed ITC, revise the submittal to (LCO 3.8.7, Cond. C) requires declaring reflect CTS.

the associated RHR Subsystem inoperable if a 480V RMOV Board is The licensee should inoperable; i.e., both MG sets feeding the provide a response to the board are inoperable. The proposed ITS staffs question regarding is a substantialislaxation from the CTS 480V RMOV Boards A, B, that has not been justified, it is, and C (all units),

therefore, not acceptable. The tensee should provide a thorough justification for this substantial relaxation or revise the submittal to reflect the CTS requirements.

The licensee should also explain why only 480V RMOV Boards D and E (all units) are in TS while 480V RMOV Boards A, B, and C (all units) are not included. What Actions are appropriate when A, B or C

. boards are inoperable?

8 P12 LCO 3.8.7 Why is Cond. C not included in this The licensee should Cond.G default condition?

orovide a response to the staffs question.

9 N/A LCO 3.8.7 - It should be noted that the inoperability of No specific action is Cond.C 480 V RMOV Boards D and E in any unit re:;drei and H requires entry into LCO 3.0.3 for that unit, regardless of loss of function.

1 14

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e i

ENCLOSURE 2 CUSTOM TECHNICAL SPECIFICATION MARKUP COMMENTS 4

___J

BFN UNIT 1 CTS MARKUP LCO 3.8.1 lSSUE DDCl REE DERGRIPTION COMMENTS RD 1

L7 4.9.A.1.a The DOC references both RG 1.9(rev 3)

The licensee should review and RG1.108. This is not acceptable.

the associated changes Rev 3 to RG 1.9 incorporates RG 1.108, and revise the DOC such and the two RGs cannot coexist.

that only one RG is applicable.

2 N/A 4.9.A.5 Where is the CTS requirement captured in the ITS - 3.5.1 or 3.8.77 3

LA1 3.9.B.2 This does not appear to be appropriate The licensee should material for relocation of the Bases, reconsider this change, 4

LA7 3.9.B.9 This change is acceptable, but the DOC The licenseu should E

should be changed. The absence of a consider, with a view

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10CFR requirement does not preclude towards revision, the part the Commission from imposing additional of the DOC that states a TS.

TS cannot supersede regulations.

5 LA1 3.9.D.1 DOC LA1 does not adequately indicate The licensee should how the issue of an inoperable DG that is provide a response to the required for support of SGT or CREVs.

staff concerns.

This CTS requirement does not appear to be captured in the iTS and does not appear to be acceptable for relocation.

6 N/A N/A The CTS markup and the proposed ITS The licensee should appear to be flawed as indicated on the address the staff concerns, following page.

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e I

ITS LCO 3.8.1.C and CTS 3 9.D.1 I

The CTS and the proposed ITS appear to have the following problems:

• The ITS does not include any requirement for the DGs to support the SGT or CREV systems, it is not covered in ITS LCO 3.8.1, LCO 3.8, or LCO 3.7.

• There is no ACTION stated if the required DGs become INOPERABLE.

• The CTS does not include any action if the DGs required to support the SGT or CREV systems are INOPERABLE,

• The CTS only address INOPERABLE DGs on a unit that is in cold shutdown, refueling, or defueled.

The above deficiencies must be corrected, DOC LA1 and DOC A4 does not provide resolution.

The following DG operating requirements are not addressed:

SGT A SGT B SGT C CREV A CREV B 2A 2B 3D 2A 38 28 2D 2B 3C 2

l BFN UNIT 1 CTS MARKUP LCO 3.8.2 ISSUE DQGI REE DESCRIPTION GQMMENTS dEQ 1

N/A LCO The staff suggests the following wording 5.8.2.b change to avoid possible confusion:

change "Two Unit 1 and 2 DGs' to "Two of the four Unit 1 and 2 DGs" 2

LA1 3.9.D.1 Proposed LCO 3.8.2 does not include the The licensee should revise 3.9.D.2 CTS requirements for specific DGs to be the submittal to retain CTS OPERABLE to support SGT and CREVs.

with respect to SGT and LCO 3.8.8 does not require specific DGs CREVs or provide an to be aligned to specific systems /com.

adequatejustification for onents, and LCO 3.8.2 is worded such the change. DOC LA1 that offsite and a DG are not required, for does not appear to be all 4 kV busses. Placing this information m tequate.

In the Bases does not appear to be acceptable.

3 LA1 3.5.A.4 Proposed LCO 3.8.2 does not include the The licensee should retain CTS requirement for a specific DG to be CTS requirements, or OPERABLE to support a core spray loop provide an adequate and pump, and DOC LA1 does not justification for the change, provide an adequate justification for this change. DOC LA1 is adequate with respect to justifying relocating material to the Bases. The problem here is that the material selected for relocation should not have been selected.

4 1.A1 3.5.A*

This is the same issue as discussed in comments 2 and 3, above, except the components / systems involved ere CSS and RHR.

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e =,

BFN UNIT 1 CTS MARKUP LCO 3.8,4 181U1 DQGl 85E DESCRIPTION COMMENTS ED 1

L42 3.9.B.7 It is suggested that this DOC be revised.

The licensee should What is stated in the DOC is correct in consider revising the DOC.

general terms, but is not applicable here.

There are no requirements for reporting, Note: This comment is so the CTS do not supersede any applicable elsewhere in the regulations. However,in the absence of DOCS where the same any specific regulations, the ' Commission language is used.

may include such additional TS as the Commission finds appropriate." (See 10CFR50.36)

Except for the above concem with the DOC language, the changes associated with this DOC are acceptable.

)

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I BFN UNIT 1 CTS MARKUP LCO 3.8.6 ISSUE DQGl REE DESCRIPTION COMMENTS dEQ 1

M1 pg.

The last statement of the first paragraph 3.9/4.9-4 makes the reference to 1988 letter from IEEE regarding a 31 day AOT. How does this 1988 letter compare with the recommendations of IEEE 450,19957 Can IEEE-450,1995 be referenced here?

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O a p

1 BFN UNIT 1 CTS MARKUP LCO 3.8.7 ISSUE DQG1 REE DESCRIPTION COMMENTS 2D 1

N/A 3.9.B.6 This CTS is proposed as ITS LCO 3.8.7, Cond. D. Wdh one 480 VAC DG auxiliary board inoperable, two DGs are without auxiliary power and are, to all intents and purposes, inoperable. Given this, how can a 5 day AOT for an inoperable DG aux board be justifM?

2 L4 3.9.B 8 The proposed chcnge appears to be acceptable, However, a final decision is delayed pending a review of the BFN DC system design.

3 LA2 3.9.B.8 See comments regarding wording of DOC LA2 in comments to LCO 3.8.4.

4 L3 3.9.B.2 Allowing 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to resolve an inoperable 480V shutdown board is acceptable, but adding 12 days in place of the NUREG 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> is not acceptsble.

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