ML20211J898

Forwards Staff Detailed Comments Re Sections 1,2,3.0,3.1, 3.2,4 & 5 of BFN ITS Submittal.Requests Addl Info to Address Comments to Facilitate Review

ML20211J898
Person / Time
Site:	Browns Ferry
Issue date:	09/29/1997
From:	Williams J NRC (Affiliation Not Assigned)
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9710090013
Download: ML20211J898 (39)

Text

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _

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Mr. Oliver D. Kingsley, Jr. September 29, 1997 President. TVA Nuclear and Chief Nuclear Officer Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT UNITS 1. 2. AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431. M96432. AND M96433)

Dear Mr. Kingsley:

l On September 6. 1996, the Tennessee Valley Authority (TVA) requested amendments of the operating licenses for the Browns Ferry Nuclear Plant (BFN)

Units 1. 2. and 3. The proposed amendments convert the existing custom technical specifications (TS) to improved TS (ITS) using the improved standard TS (ISTS) format.

I This letter forwards the NRC staff's detailed comments on Sections 1. 2. 3.0.

3.1. 3.2. 4 and 5 of the BFN ITS submittal. TVA is requested to provide additional informatior to address these comments to facilitate the staff's review.

Note that the staff F is identified changes to section 3.1.7 (standby liquid control) as beyond-scopi. whch will require technical staff review. Any cuestions that arise in toe review of this s?ction will be provided at a later cate.

Please provide as soon as practical your schedule for responding to these comments. Contact me at (301)416-1470 if you have any questions on this topic.

Sincerely.

/S/

Joseph F. Williams. Project Manager Project Directorate 11-3 Division of Reactor Projects - I/11 Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosure:

NRC Comments cc w/ enclosure: See next page

)istribution m)ocketlile~ PUBLIC BFN Rdg. Reading BBoger _9(%;\

OGC ACR9 MWeston JJohnson, RIl DOCUMENT NAME: G:\BFN\M964318.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 PDil 3/PM l d. PDil*3/LA JWilliams p_ / ,, l l 158 wb6 l -l PDil 3/D ,) lC NAME fW BClayton A A W F Hetdon M i DATE 09/Rf/97 W/ 09/3 f>/91 09/1Q /97 09/3 4/97 1 0FFICIAL RECORD COPY 59 e eon h. . h.h.h. . . mm3 ma n.tyu [u. p"[mGKo. fij[)y

p ,. 0.,k UNITED STATES g

] NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 40M

%.,y** September 29, 1997 Mr. Oliver D. Kingsley, Jr. "

President, TVA Nuclear and Chief Nuclear Officer Tennessee Valley Authority 6A Lookout Place -

1101 Market Street l Chattanooga, TN 37402 2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - RE0 VEST FOR ADDITIONAL INFORMATION REGARDING IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS, M96431 M96432, AND M96433)

Dear Mr. Kingsley:

On September 6, 1996, the Tennessee Valley Authority (TVA) requested amendments of the o Units 1, 2, and 3. perating licenses for the Browns Ferry Nuclear Plant (BFN)

The proposed amendments convert the existing custom technical specifications (TS) to improved TS (ITS) using the improved standard TS (ISTS) format.

This letter forwards the NRC staff's detailed comments on Sections 1, 2, 3.0, 3.1, 3.2, 4, and 5 of the BFN ITS submittal. TVA is requested to provide additional review. information to address these comments to facilitate the staff's Note that the staff has identified changes to section 3.1.7 (standby liquid control) as beyond scope, which will require technical staff review. Any questions that arise in the review of this section will be provided at a later date.

Please provide as soon as practical your schedule for responding to these coments. Contact me at (301)415 1470 if you have any questions on this topic.

Sincerely.

l $h

f //  %

/

Joseph F. Williams, Project Manager Project Directorate 11-3 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50 296

Enclosure:

NRC Comments cc w/ enclosure: See next page j

i g

Mr. Olive J. Kiiigsley, Jr. BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority l-CCt <

Mr. O. J. Zeringue, Sr. Vice President Mr. Mark J. Burzynski, 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 Engineering & Technical Services Licensing and Industry Affairs Tennessee Valley Authority Browns Ferry Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Marht Street P.O. Bnx 2000 Chattanooga, TN 37402-2801 Decatur AL 37402-2801 Mr. C. M. Crane, Site Vice President Re Browns Ferry Nuclear Plant U.gional Administrator, S. Nuclear Region 11 Regulatory Commission Tennessee Valley Authority 61 Forsyth Street, SW., Suite 23T85 P.O. Box 2000 Atlanta, GA 30303-3415 Decatur, AL 35609 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 35130-1701 1101 Market Street Chattanooga, TN 37402-2801 Chairman Limestone County Commission 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 35609

BFN ITS 1.0 USE A E APPLICATIONS A:UAsuo.ent -

1.0 DOC JFD CHANGE / DIFFERENCE COMMENTS STATUS 1.0-1 A.8 The DOC for CTS 1.0. definition of CORE Revise the CTS and the L.3 ALTERATION. states "...The provision added less restrictive change to that allows control rod movement with no include the insertion of L.3 fuel assenblies in the core cell to not be to the definition of Core considered a Core Alteration is less Alteration.

restrictive and is discussed in Conenent L.3 below. However. the CTS for Core Alteration is not indicated as L.3 for this less restrictive change.

BFN Response:

1.0-2 A.9 P.3 The ITS 1.1. CHANNEL CALIBRATION. deletes Provide justification and P.5 the allowance for "...an inplace additional description for qualitative assessment for sensor behavior the STS deviation based on and normal calibration of the remaining system design and operational adjustable devices in the channel..." The constraints.

justification does not discuss system design and operational constraints that preclude using these definitions in the ITS.

BFN Response:

1.0-3 P.1 The STS definitions for EMERGENCY CORE Provide justification and COOLING SYSTEM RESPONSE TIME. END OF CYCLE additional description for RECIRCULATION PUMP TRIP RESPONSE TIME. the STS deviation based on ISOLATION SYSTEM RESPONSE TIME RESPONSE system design and operational TIME. and REACTOR PROTECTION SYSTEM constraints.

RESPONSE TIME. are deleted because they are not required by the CTS. The justification does not discuss system i design and operational constraints that would preclude using these definitions in the ITS.

BFN ITS 1.0 USE Ape APPLICATIONS A:uAsuo.BrN _

1.0 00C JFD OMNGE/ DIFFERENCE C0f90lTS STATUS BFN Response:

1.0-4 P.4 The ITS does not adopt the STS 1.1 Provide justification and definition for PRESSURE AND TEMPERATURE additional description for 1.IMITS REPORT because the methodology is the STS deviation based on not approved. ITS 3.4 contains those system design and operational limits. The justification does not constraints. ,

discuss system design and operational constraints that would preclude PRESSURE ,

i AND TEMPERATURE LIMITS REPORTS.

BFN Response:

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I BFN ITS 1.3. COMPLETION TIMES A:UA803.BFN -

1.3 DOC JFD CHANGE / DIFFERENCE COPMENTS STATUS 1.3-1 P.7 STS 1.3 (Page 1.3-6). Example Provide justification and 1.3-3. Completion Time. Item C. additional description for Completion tine of STS revised the STS deviation based on from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to system design or operational restore Function X subsystem to constraints.

OPERABLE status.

Revise this change to a less Example 1.3-3 is "... proposed to restrictive change.

be revised to more adequately reflect BWR specific TS ACTIONS rather than PWR specific TS ACTIONS."

BFN Response:

I 1.3-E P.7 STS 1.3 (Page 1.3-10). Example Provide justification and 1.3-5. Required Action. Item A. additional description for Required Action A.2 is revised the STS deviation based on from "... Reduce THERMAL POWER to system design or operational 5 50% RTP." This was revised to constraints.

... Place channel in trip.

Revise this change to a less Example 1.3-5 is "... proposed to restrictive change.

be revised to more adequately reflect BWR specific TS ACTION rather than PWR specific TS ACTIONS.

BFN Response:

4 l

BFN ITS 2.0 SAFETY LIMITS A4TAst20.srx .

2.0 DOC- JFD CHANGE / DIFFERENCE COP 9 TENTS STATUS 2.0-1 A.3 CTS 1.2.A states. 'The pressure at the Provide discussion and lowest point of the reactor vessel justification for this more shall not exceed 1.375 )sig whenever restrictive change.

irradiated fuel is in tie reactor vessel." This limit is reworded in ITS 2.1.2 to be ' Reactor steam dome preu~en shall be 5 1325 psig." This ir e restrictive change because (as , quick calculation shows that 1325 psig in the steam dome equals approximately 1355 psig at the lowest point and (b) the limit is now enforced without regard to whett.er irradiated fuel is in the vessel.

BFN Response:

2.0-2 L.2 The CTS 1.1.C Safety Limit for the Provide additional reactor vessel water level is that justification for this less level shall be maintained not less than restrictive change. Note:

372.5 inches above vessel zero. The Consistent with the STS.

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 Tess restrictive change to an allowable value.

BFN Response:

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

i BFN ITS 3.0 LIMITING COICITION FG/ M TION (LCO) APPLICABILITY . .,

ITEM f DOC or CTS /STS Description of Issue = COPMENTS JFD# LCO 3.0-1 P4 3.0.5 ITS 3.0.5 changes are proposed to make it apply to variables as well as equipment.

The changes proposed here were reviewed and rejected as j

TSTF 001. Provide markup 1 deleting these changes.

a 3.0-2 PS. P6 3.0.6 Bases 'hese

. changes are generic and P8 must be handled accordingly.

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

3.0-3 M1. 4.0 The justifications . for- change M2. M3 provide excellent' explanations of what the LCOs l do.' They do not. however.

provide justification of why they are acceptable for Browns Ferry. whether they inpose any operational constraints. impact any.

system design or the current licensing basis. Provide simple statement of

, applicability to your plant.

f BFN 'ITS 3.1.1 SHUTD0lm MARGIN (SDM) --

ITEM # DOC CTS /STS; Description of Issue:. CGMENTS, or- LCO- >

JFDf' 3.1.1-1 P2 ITS 3.1'.1'- Required. Action modified to insert This change is generic "with isolation Valve (s)" 'and must be changed accordingly'(through TSTF). If there are no isolation valves-in '

the flow path, then it a pears that the-clange is a non sequitur.

3.1.1-2 LA.1 CTS 4.3.A.1 CTS 4.3.A.1 details part of..the Identify what-method to perform the SOM procedure the details ITS 3.1.1 Surveillance and this information of the SOM is moved to "the procedures". As' Surveillance are moved. -

STS 3.1.1 stated " procedures are controlled to and how changes to by the licensee controlled this procedure are programs."~ controlled. i

BFN ITS 3.1.2 REACTIVITY ANOMALIES -

_ e ITEM # DOC CTS /STS- Description of Issue COPf1ENTS or LCO JFDf 3.1.2-1 LA.1 CTS 4.3.0 CTS 4.3.D provides details of What is going where?

methods to perform the Reactivity khat is in the Bases?

ITS 3.1.2 Anomaly Surveillance that are not Indicate procedures to contained in'ITS 3.I.2. These whP ti information will STS 3.1.2 details are moved to the ITS Bases 90.

and procedures.

3.1.2-2 P46 CTS 4.3.0 CTS 4.3.0 requires that a Either convert the CTS reactivity Anomaly comparison will units to those in the ITS SR be made at least every full power ITS or use the CTS 3.1.2.1 month. ITS SR 3.1.2.1 requires units. Is P46 the that this comparison be made each appro)riate reference STS SR 1000 EFPH during operations in for tie ITS markup. .

3.1.2.1 MODE 1. The STS SR 3.1.2.1 recuires that this comparison be mace each 1000 MWD /T during operations in MODE 1.

. _ . _ _ _ . . . _ . _ . . _ _ . _ _ _ _ _ ~ _ _ ._

.: - ;P BFN ITS 3.1.3 CONTROL ROD' OPERABILITY' -

ITEM f: 00C.or. ' CTS /STS. Description of Issue C0ffiENTS V -

i- JFDF: LCO -t I ..

3.1.3-1 M1. M3 - Provide justification MS. M6. relative your plant.

M9. operational M10, constraints.Lsystem  :

l Mll- design.

3 L 3.1.3-2. A.7 CTS 3.3.B.1- The' discussion for A.7 states'"This Provide discussion and CTS 3.10.A.6 recuirement duplicates an identical justification 'for- i anc more appropriately placed deleting the portion  !

requirement in existing of CTS 3.3.B.1 speci fication 3.10.A.6. Therefore, identifled as A.7. .

deletion of. this requirement is -

considered administrative." This statement is inaccurate because CTS  ;

3.3.B.1 and CTS 3.10.A.6 are not' ,

~

identical. CTS 3.3.B.1 states "This requirement does not apply in the SHUTDOWN CONDITION when the  !

. reactor is vented. Two control rod 3

[ drives may be removed as long as 4

3.3.B.1.. shutdown margin (SDM) is CTS 3.10.A.6 refers to met."  !

withdrawing control radi during  !

refuelina but makes no mention of  ;

SDM requirements. It is physically  ;

correct that a control rod must be '

withdrawn in order to remove .the drive mechanism- but the SDM requirement is not contained in CTS i 3.10.A.6 and CTS 3.10 does not apply to the plant ~ condition  !

described in CTS 3.3.B.1 but only i refueling.

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BFN ITS 3.1.3 CONTROL ROD OPERABILITY -

ITEM f DOC or CTS /STS. Description of Issue COPMENTS JFDf- LCO 3.1.3-3 R.I. CTS 3.3.B.2 The requirements of CTS 3.3.B.2 and For R1 provide LA1. CTS 4.3.B.2 4.3.B.2 concerning the CRD housing discussion and LA2 support requirements are moved to justification for a plant procedures and not relocated Less Restrictive as stated. This change to CIS Administrative change requirements .is a Less restrictive rather than a Administrative change and not a Relocation. 4 Relocation. For all. are they '

being moved to the

'.! bases. FSAR or plant

' procedures. Sepcify and indicate how changes to these procedures are controlled.

g t_____- - --

BFN ITS 3.1.4 CONTROL ROD SCRAM TIES - '!

ITEM f- DOC or--. CTS /STS Description of Issue COPMENTS JFD# LCO F .

3.1.4-1 P14. ITS SR SR 3.1.4.1 has a note added that Both 'of these changes P44 3.1.4.1. and makes exceptions not allowed by are Beyond the Sco m j SR 3.1.4.3 STS or CTS. SR 3.1.4.'3 also makes of this review. Tiey '

and exce) tion not contained in the are also generic "

CTS or t1e STS issues that do not

' only apply to BFN and i therefore require TSTF review. approval and submittal 3.1.4-2 H2. M3. Each of these needs to M4. M6 justified relative to BFN and any added -

i operational

• constraints and any impact on system design or licensing i basis. ,

3.1.4-3 A.2 CTS 3.3.C.1 CTS 3.3.C.1 and 3.3.C.2 specify Provide information

• control rod position in terms of % that clearly shows the from Fully Withdrawn for scram. equivalency of'the time testing limits. ITS Table percentages shown in 3.1.4-1 specifies rod position in the CTS compared with terms of " Notch Position" for time the notch position i testing limits. The discussion shown in the ITS.

states that these positions are- Comment 82 does not  ;

I equivalent to the next nearest- appear to apply here.  !

measured notch position. exce)t as it applies --

to t1e brackets.  ;

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'BFN ITS 3.1.4 CONTROL ROD SCRAM TIES -

ITEM # DOC or CTS /STS Description of. Issue C0tt!ENTS' JFD# LCO 3.1.4-4 LA1. Where are these LA2. details going? To the LA3 FSAR or Bases. Some of this detail needs to be in one of the-above. Identify what will go to plcnt procedures and what goes to FSAR cr Bases.

Indicate control mechanism.

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BFN ITS 3.1.5 CONTROL ROD SCRAM ACCtMILATORS

_ .c ITEM # DOC CTS /STS Description of-Issue COMMENTS or 'LCO JFD#

3.1.5-1 LA.1 CTS 4.3.A.2.d CTS 4.3.A.2.d requires that Should some of this control rod accumulators be information should go determined OPERABLE by verifying to the Bases or FSAR.

that the pressure and level detectors are not in the alarmed condition each 7 days.

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. BFN ITS 3.1.6 ROD PATTERN ColGROL ITEM # DOC- CTS /STS Description of Issue COMMENTS' or LCO t JFD#- .

None None ,

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BFN ITS 3.1.7 STM OBY LIQUID CONTROL (SLC) SYSTEM 4 ITEM f DOC CTS /STS. Description of Issue COPtfENTS or LCO JFD#

3.1.7 All All There are so many changes that differ from the STS and all of the other BWRs that have been reviewed that this complete specification is being considered as Beyond '

Scope and technical staff review is requested.

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BFN 'ITS 3.2.1 AVERAGE PLANAR LINEAR' HEAT GENERATION' RATE 1

ITEM # DOC CTS /STS Description of Issue COP 91ENTS 1

or LCO - '

JDi 3.2.1-1 M1. Provide justification '

M2 for your plant .

relative to i gact on t licensing basis.

l system design. and j i . operational '

constraints 3.2.1 M-2 CTS 3.5.I In the event'that the APLHGR Provide discussion and cannot be restored within limits '

justification for this

within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. CTS 3.5.I lessrestrictive

requires placing the plant in change. .

COLD SHUTDOWN CONDITION within 36' hours. With the same The licensee' submittal l conditions present. ITS 3.2.1- indicated that because i REQUIRED ACTION B.1 requires CTS 1.0.C.1 states '

reducing thermal. xwer to <25% that action '

of RATED' THERMAL' NWER within requirements are four hours. The final condition applicable during the

(< 25% RTP in the ITS vs. COLD operational conditions ,

l SHUTDOWN CONDITION in the CTS). of each specification.  :

is a higher power level / MODE and the requirement to '

that'is a less restrictive place the plant in  !

change chich has not been cold shutdown is not discussed. aplicable after l

twrmal xwer is -

reduced mlow 25% RTP. .

i However, the "-

requirements of CTS '

1.0.C.1 and CTS 3.5.I-conflict in this case  !

and the most ..

restrictive would be used.

BFN ITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE '.

4

BFN 4ITS 3;2.2. MINIMUM CRITICAL POWER RATIO' -

__ a ITEM # DOCL CTS /STS' ' Description of. Issue- C0fMENTS or LCO-JDi '

3.2.2-1 M1. Provide justification M2 for your plant.

relative to impact on licensing basis.1 system design. and operatier.a1 constraints 3.2.2-2 A-2 CTS 3.5.K CTS 3.5.K requires observing the Provide discussion and Minimum Critical Power Ratio justification-for this (MCPR) limits during steady less restrictive--

state power' operation. ITS change.

3.2.2. A plicability requires that MCPR limits be observed .

with THERMAL. POWER = 25% RTP.

Since the ITS does not enforce MCPR' limits below 25% RATED THERMAL POWER. even if the plant is in steady state conditions, this is a less restrictive change.

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,BFN~ ITS 3.2.2 MINIMUM CRITICAL POWER RATIO -

ITEM.# DOC. CTS /STS Description of-Issue: COPMENTS -

or-' LCO:

JDI 3.2.2-3 M-2 CTS 3.5.K In the event that the MCPR . Provide' discussion and-cannot-be restored within limits justification for this within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. CTS 3.5.K less restrictive requires placing the plant in change.

COLD SHilTDOWN CONDITION within l 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. With the same The licenseelsubmittal conditions present. ITS 3.2.2. indicated that because RE0llIRED ACTION B.I.: requires CTS 1.0.C.1 states reducing thermal power to <25% that action of RATED THERMAL POWER within requirements are four hours. The final condition applicable during the

(< 25% RTP in-the ITS:vs. COLD operational conditions

, SHUTDOWN CONDITION in the CTS). of-each specification.

is a higher power. level / MODE and the requirement to that is a less restrictive place tie plant in change which has not been cold shutdown is not -

discussed. a plicable after tiermal xwer is reduced M1ow-25% RTP.

However, the requirements' of CTS .

1.0.C.1 and CTS 3.5.K conflict in this case and the most restrictive'should be-used.

t BFN ITS 3.2.3 LINEAR HEAT GENERATION RATE - --

ITEM f. DOC- CTS /STS- Description of Issue COMENTS-or LCO 1' JD#~

3.2.3-1 M1; Same as 3.2.2-1 M2

~~

3.2.3 A-2 CTS 3.5.J CTS 3.5.J reouires LHGR limits: Provide discussion and be observed during steady state- lustification for this power o mration. ITS 3.2.3. lessrestrictive Applica)ility, reqtiires that. change.

LHGR limits be observed den -

THERMAL POWER = 25% RTP. Since the ITS does not enforce LHGR '

! I limits below 25% RATED-THERMAL .

POWER. even if the plant is in 'I steady state conditions. this is a less restrictive change. .

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BFN- ITS 3.2.3 LINEAR HEAT GENERATION RATE -

ITEM # DOC CTS /STS. Description of Issue C0tMENTS or . LCO '

JD# ~

3.2.3-3 H-2 CTS 3.5.J In the event that the LHGR Provide discussion and .

cannot be restored within limits justification for this within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. CTS 3.5.J 1ess restrictive requires placing the plant in change.  ;

COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. With the same The licensee submittal conditions. ITS 3.2.3. REQUIRED indicated that because ACTION B.1 requires reducing CTS 1.0.C.1 states THERMAL POWER to <25% of RATED that action THERMAL POWER within four hours. requirements are ,

The final condition (< 25% RTP applicable during the in the ITS vs. COLD SHUTDOWN operational conditions CONDITION in the CTS). is a of each specification, higher power level / MODE and that the requirement to  :

is a less restrictive change place the plant in which has not been discussed. cold shutdown is not .

a plicable after t1ermal mwer is reduced mlow 25% RTP.

However. the requirements of CTS 1.0.C.1 and CTS 3.5.J conflict in this case and the most restrictive should be '

used.

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.BFN .ITS 3.2.4 AVERAGE POWER RANGE MONITOR-(APRM) GAIN relD SETPOINTS ITEM f DOC' CTS /STS Description of Issue.- COP 91ENTS or ~ . LCO-JD# :

3.2.4-1 M1. Same as previous M2 3.2.4-2 A-2~ CTS In the event that' the ratio of' The justification is 3.5.L.1 FRACTION RATED POWER (FRP) to acceptable. however.

CORE MAXIMUM FRACTION LIMITING it is a less POWER DENSITY (MFLPD)is < 1.0. restrictive change.

CTS 3.5.L.1 requires that the APRM Scram and Rod Block setpoint be reduced by the fraction FRP/MFLPD. ITS 3.2.4 requires that either MFLPD be less than or equal to FRP (implying that FRP/MFLPD is .

> 1.0). OR APRM Scram and Rod Block setpoints be reduced. OR APRM gains be adjusted such that APRM readings are > 100% times MFLPD. CTS 3.5.L.1 adds the ITS 3.2.4 option to allow increasing the APRM gains'to cause the APRM to read > 100% times MFLPD.

Allowing APRM gain adjustment to '

compensate for MFLPD > FRP is a less restrictive change that is not justified.

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BFN ITS 4.0 DESIGN FEATURES A:UABL40.BFN -

'4.0 DOC :JFD CHANGE / DIFFERENCE COP 9ENTS '  : STATUS-4.0-1 H.1 CTS 5.1 lists the minimum distance Provide justification.for from the.outside of secondary making changes.

containment to the exclusion area boundary as 4000 feet. ITS 4.1 states. "... The distance from the plant stack to the site and i exclusion area boundaries as 1465 meters. There is no justification for changing the minimum distance from feet to a' distance in meters or

! changing the endpoint from the outside of secondary containment to the plant stack.

BFN Response:

4.0-2 H.3 B.2 ITS 4.3.3 states. "...the spent fuel Provide discussion and storage pool is designed and shall justification for the more be maintained with a storage restrictive change.

I capacity limited to no more than 3476 fuel asseertilies. . ." The STS has beca indicated. "...a storage cepacity limited to no more than 3471-fuel assemblies." Which number

' of fuel assemblies-is correct for BFN? What is the technical basis for the limit'of fuel assemblies?

j; BFN Response:

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BFN ITS 4.0 DESIGN FEATURES A:UABL40.BFN *' '

4.0~ , DOC' JFD~ CHANGE / DIFFERENCE COPMENTS ' STATUS i

4.0-3 LA.2 CTS 5.5.C prohibii.s "... loads Provide. discussion and greater than 1000 pounds shall not i justif! cation for moving this-be carried over spent fuel requirement.

assemblies stored in the spent fuel  !

pool." This requirement is moved to plant procedures. The )rocedures and the controls over t1e changes to .!

this requirement cre not: identified. 1 '

BFN Response:  !'

4.0-4 P.2 STS 4.3.1.la and 4.3.1.2a require Provide ~ discussion and fuel storage racks be designed with

" justification for the STS  !

... fuel assemblies having a maximum deviation based on system  !

[k-infinity of [1.31] in the normal design and operational  !

reactor core configuration at cold constraints.

conditions][ average U-235 enrichment  !

i

! of [4.5] weight percent]:..." The

justification states. "...The i proposed new limitation is a fuel  !

i design feature and not a design feature of the rack..." The  :

justification.does not discuss system design and operational  ;

constraints that preclude adopting these STS requirements. i"

-E BFN Response:

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BFN ITS 5.2 ORGANIZATION Comments on Improved Technical Specifications ITEN # JFC# CTS /STS Description of Issue Date Date COMMENTS LCO Opened Closed 5.2-1 A2 CTS 6.2.1d The term'" health physics" in CTS 9/23/97 Provide further and 6.2.2e 6.2.1d and 6.2.2e is changed to justification for

" radiological controls" in ITS 5.2.1d using the term '

P3 STS 5.2.1d and 5.2.2d with no justification for " radiological and 5.2.2d the change from the CTS " health controls" instead physics." The term " health physics" of " health in STS 5.2.1d and 5.2.2d is changed physics."

to " radiological controls" in ITS 5.2.1d and 5.2.2d. JFC P3 states that this is because it is the current licensing basis, but CTS 6.2.1d and 6.2.2e use the ;erm " health physics"). The material is .

contradictory.

5.2-2 JDC STS 5.2.2a The bracketed STS 5.2.2a requirements 9/23/97 Provide a B2 for the number of non-licensed discussion of the operators at a two-unit station when a)plicability of both units are shutdown is deleted in t1e STS bracketed the conversion to ITS 5.2.2a with no information for discussion of its ap)licability to BFN.

the Browns Ferry's t1ree unit site.

5.2-3 N/A CTS 6.2.2d CTS 6.2.2d requires two licensed 9/23/97 Provide discussion reactor operators (RO) and a licensed and justification senior reactor operator (SRO) in the for this less control room when in MODE 1. 2. or 3. restr.tctive change.

ITS 5.2.2b requires at least one R0 -

and one SRO in the control room when in MODE 1. 2. or 3. Deleting the second required R0 is not justified and is a less restrictive change.

BFN ITS 5.2 ORGANIZATION Conuments on Improved Technical Specifications ITEM # JFC# CTS /STS Description of Issue Date Date- C0tWENTS LCD- Opened Closed .

5.2-4 Al CTS Table CTS Table 6.2.A. Note b. allows a 9/23/97 Provide discussion 6.2.A. shif t crew composition of one less and justification -

Note b than specified. for a time not to for this less exceed two hours. ITS 5.2.2c does restrictive change.

not limit the short compliment to 1.

a less re*:trictive change. Though consistent with the STS. this less restrictive change has not been justified.

5.2-5 LAl CTS Table CTS .able 6.2.A. Note b. does not 9/23/97 Provide discussion 6.2.A. perr.it any shift crew position to be and justification Note b unmanned u)on shift change due to an for this less oncoming slift crewman beina late or restrictive removal absent. ITS 5.2 does not retain this of requirement.

requirement. a less restrictive removal of requirements that is not specifically discussed or justified in JFC LAl. ' ,

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L BFN ITS 5.4 PROCEDURES

! Comments on Improved Technical Specifications ITEM # DOC CTS /STS Description of Issue Date Date COMMENTS-

! or 1.C0 Grened. Closed i JDC#.

5.4-1 LA2 CTS 6.8.2 CTS 6.8.2 requires annual drills for 9/23/97 Does the a) emergency cor.ditions involving Radiological release of radioactivity and b) Emergency Plan failures of safety-related systems or implement an annual '

components. The justification states drill for failures these requirements are implemented by of safety-related the Radiological Emergency Plan. systems or  !

components?

Provide additional justification for this less

, restrictive removal of requirements.

verifying where the requirement for an annual drill for faiidres of safety-related systems or components will be implemented.

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BFN ITS 5.5 PROGRAMS AND MANUALS Comments on Improved Technical Specifications-ITEM # JFCf. CTS /STS Description of Issue Date Date COPMENTS LCO Opened Closed 5.5-1 Al CTS CTS 6.8.4 9 .1 limits the noble gas 9/23/97 Add the modifier 6.8.4g.1 dose rate to less than or equal to 's' to the ITS 3000 mrem /yr to the skin. ITS 5.5.4.g.1 3000 5.5.4.g.1 includes the 3000 mrem /yr mrem /yr limit.

limit without the modifier "s." This change appears to be an omission.

5.5-2 Al CTS CTS 4.7.B.1 requires demonstrating 9/23/97 Provide 4.7.B.1 acceptable pressure drop for the justification for combined HEPA filters and charcoal this less adsorber banks of the standby gas restrictive change. 1 treatment system and testing the  ;

inlet heaters "at least once per  !

year." ITS 5.5.7 establishes the I required testing "at least once w r 18 months." This extension of tie surveillance test interval is not justified as a less restrictive change.

5.5-3 LA1 CTE CTS 4.7.B.1c requires demonstrating 9/23/97 Provide a 4.7.B.lc the air distribution across the justification standby gas treatment system HEPA specific to this filters and charcoal adsorbers is less restrictive.

uniform within 20%. This re.quirement moving of a is not transferred to ITS 5.5.7 but requirement.

is moved to the Technical _

Requirements Manual. No -

justification was provided for this change in DOC LA1. DOC LA1 simply provides a very brief description of some of the changes it covers. ,

a BFN ITS 5.5 PROGRAMS N O MANUALS ~ -

A Comments on Improved Technical Specifications ITEM # JFCf CTS /STS Description of Issue Date Date COPtENTS LCO Opened Closed .l 5.5-4 LA1 CTS CTS 3.8.A.6 requires suspending 9/23/97 Provide a 3.8.A.6 additions of radioactive waste if the justification I

specified limits are exceeded, specific to this reducing the activity in the tank to less restrictive within limit, and reporting the moving of a occurrence in the next annual requirement.

Radioactive Effluent Release Report.

These requirements are not transferred to ITS'5.5.8 but are moved to the Technical Requirements Manual. No justification was provided for this change in DOC LA1.

XE LA1 simply provides a very brief description of scme of the changes it _

covers.

5.5-5 N/A CTS CTS 4.8.A.6 requires analyzing 9/23/97 Provide a-4.8.A.6 samples of the contents of any justification for outside' liquid radwaste storage tanks deleting this at least once per 7 days when there requirement.

are additions to the tank. These specific requirements are not transferred to ITS 5.5.8. Rather.

ITS 5.5.8 contains general requirements for a surveillance program for verifying the quantity of radioactivity contained in outdoor .

liquid radwaste tanks. Deleting the -

specific requirements in CTS 4.8.A.6 was not justified.

BFN ITS 5.5 PROGRAMS AND MANUALS Comments on Improved Technical Specifications ITEM # JFC# CTS /STS Description of Issue Date Date COPMENTS LCD Opened Closed 5.5-6 P11 STS STS 5.5.10a requires testing new 9/23/97 For standardization 5.5.10a diesel fuel oil before adding it to and consistency.

storage tanks. ITS 5 5.9 does not the staff would contain this requirement although the prefer to see the justification in JDC P11 states that STS requirements the fuel oil is tested before adding retained in the it to the 7 day tanks. Browns Ferry ITS.

What is the impediment to including these requirement 5 in the ITS. if the testing is already being done?

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. l BFN ITS 5.5 PROGRAMS AfD MANUALS Comments on Improved Technical Specifications ITEM f JFC# CTS /STS Description of Issue Date Date . COPMENTS LCO Opened Closed 5.5-7 P7 STS STS 5.5.4.b has been modified in ITS 9/23/97 Revise the ITS to 5.5.4.b 5.5.4.b to adopt the CTS which retain the correct includes changes to conform to the CTS reference for, latest 10 CFR Part 20 revision. 10 CFR Part 20.

However. it appears that the transfer of the CTS language was not entirely accurate. CTS 6.8.4.b states.

" Limitations on the concentrations of radioactive material released in li id effluents to UNRESTRICTED AR conforming to 10 times the concentration values stated in 10 CFR 20.10001-20.2401. Appendix B.

Table 2. Column 2." ITS 5.5.4.b states. " Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas. conforming to 10 times the concentration values stated in 10 CFR 20. Appendix B.

Table 2. Column 2."

5.5-8 B4 STS 5.5.8 ITS 5.5.7 adds Insert 5.0-11A to the 9/23/97 What is the reason-program description of STS 5.5.8 for for adding the the VFTP.- Most of the additional reference to information in the insert is based on Section Sa. rather the CTS. However, the addition of than leaving the the reference to Section 5a of general reference Regulatory Guide 1.52. Rev. 2. is not as in the STS?

discussed.

1 BFN ITS 5.5 PROGMMS MO MANUN.S I Comments on Impr6ved Technical Sper.1fications 1

ITEM f JFCf CTS /STS Description of Issue Date Date CDPMLE, l LCO Opened , Cit, sed 5.5-9 B3 STS ITS 5.5.7.c requires demonstrating 9/23/97 Provide a 5.5.8.c that a laboratory test of a samale of justification of charcoal adsorber shows the metlyl this change.

iodide penetration less thar the stating how the specified value. c'. a specified flow value in the US rate and relative humidity. The CTS vas derived.

do not appear to contain the restrictions on relative humidity, but no discussion of this change was provided.

5.5-10 P6 STS 5.5.2 STS 5.5.2a and b requires a Primary 9/23/97 Provide additional M1 a and b Coolant Sources Outside Containment justification for program with preventive maintenance this STS deviation and leak test requirements. ITS based cn system 1 5.5.2 implements this program. design and however. ITS 5.5.2a does not contain operational the preventive maintenance constraints. What requirements and ITS 5.5.2b adds a are your current restriction on the leak rate testing commitments to the "to the extent permitted by system NRC regarding design and radiological conditions.- primary coolant The justification states that these sources outside changes are consistent with BfN's containment?

current programs for minimizing leakage.

BFN ITS 5.6 REPORTING REQUIREENTS Comments on Improved Technical Specifications ITEM f JFCf CTS /STS Description of Issue Date Date CDPMENTS LCD Opened Closed i 5.6-i LAI CTS CTS 6.9.1.2.b requires annual 9/23/97 Provide additional 6.9.1.2.b reporting to the NRC of any eain justification for steam relief valve that opens in this less response to scaching its setpoint or restrictive removal due to operator action to control of requirements.

reactor pressure. The justification stating what will neither details why this requirement happen to the is in the CTS. states whether this requirement when reouirement is moved elsewhere (and the ITS are the attendant controls on the implemented.

requirement where moved). nor states that the requirements is being deleted entirely.

5.6-2 LA3 CTS JFC LA3 states that the source test 9/23/97 Provide a 6.9.1.6 reporting requirements of CTS 6.9.1.6 justification for are being moved to an unidentified this less licens w controlled document. No restrictive moving justification is provided for this of requirements.

change. 1dentifying the document that will contain this requirement and t!e corresponding control mechanism.

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BFN ITS 5.6 REPORTING REQUIREENTS Comments on Improved Technical Specifications ITEM f JFCf CTS /STS Description of Issue Date Date CDPMENTS LCO Opened Closed 5.6-3 RI-R4 CTS 6.9.2 The criteria in the NRC Final Policy 9/23/97 Revise the Statement and 10 CFR 50.36 do not justifications for apply to the Administrative Controls these items to section of technical specifications. describe less The criteria only apply to LCOs. restrictive changes (movement of requirements). l Ideitify. l specifically. the doctments to which these requirements will be moved and the associated control mechanisms.

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BFN ITS 5.7 HIGI RADIATION AREA -

• Comments on Improed Technical Specifications ITEM f JFC# CTS /STS Description of Issue Date Date CDPetENTS LCO Opened Closed l 5.7-1 N/A CTS CTS 6.8.3.2 provides requirements for 9/23/97 6.8.3.2 Revise ITS 5.7.2 to

" areas that are accessible to change t 1000 personoci and that have radiation arem/hr" to > 1000 levels greater than 1 rem in I hour." arem/hr* to be l

ITS 5.7.2 references ' areas tnat are consistent with the accessible to personnel and that have CTS.

, radiation levels 2 1000 mrem /hr."

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