ML20217E268
| ML20217E268 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/17/1997 |
| From: | Williams J NRC (Affiliation Not Assigned) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9710060426 | |
| Download: ML20217E268 (58) | |
Text
- _ _ _ . .
Mr. Oliver D. Kingsley, Jr. September 17, 1997
' President. TVA Nuclear and Chief Nuclear Officer Tennessee Valley Authority l 6A Lookout Place l 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 N05. M96431.1196432. AND M96433)
Dear Mr. Kingsley:
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. On February 20. 1997, the NRC staff provided its initial comments on the BFN ITS submittal. Meetings were held on February 26.
March 20. April 30. and May 21. 1997 to review these comments and TVA's course of action.
This letter forwards the NRC staff's detailed comments on Sections 3.5. 3.9.
and 3.10 of the BFN ITS submittal. TVA is requested to provide additional information to address these comments to facilitate the staff's review.
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.
/S/
Joseph F. Williams. Project Manager Project Directorate 11 3 Division of Reactor Projects - !/11 Office of Nuclear Reactor Regulation Docket Nos. 50 259. 50 260. and 50 296
Enclosure:
NRC Coments cc w/ enclosure: See next page O Di st rib.it' on Docket 1' e PUBLIC \
BFN Rdg. Reading BBoger i OGC ACRS MWeston TSB/ADPR JJohnson. Ril DOCUMENT NAME: G:\BFN\M96431A.RAI To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" - Copy with attachment / enclosure "N" - No cooy OFFICE NAME PDll 3/PM JWilliams
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Mr. Oliver D. Kingsley, Jr. BROWNS FERRY NUCLEAR PLANT Tennessee Valley Authority cc:
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 i Engineering & Technical Services -Licensing and Industry Affairs Tennessee Valley Authority Browns Ferry Nuclear Plant 6A Lookout Place Tennessee Valley Author'.ty 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 11 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 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, At 35611 Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 4
BFN ITS 3.5.1 ECCS OPEPATING ITEM # DOC' CTS /STS Description of Issue C0FNENTS or LC0 JD#
3.5.1-1 LA2 CTS 3.5.H CTS 3.5.H provides requirements Add referenced CTS for ECCS discharge pressure requirements to ITS indicator readings. According Bases or revise to DOC LA2. this information is explanatien of location moved to the ITS Bases. Nothing of these moved details.
in the ITS 3.5.1 Bases was found that references these specific Provide a justification requirements. In addition. DOC as to why movement of LA2 does not provide any these details from the justification as to why the TS to the Bases and removal of these details from , procedures is the TS is acceptable. J:teptable.
3.5.1-2 LA3 CTS 4.5.H & CTS 4.5.H & 4.6.D contain Provide a justification 4.6.0 details of methods for as to why movement of performing surveillance and these details from the routine system status TS to the Bases and monitoring. DOC LA3 states that procedures is these details have been acceptable.
relocated to the Bases and procedures but does not provide any justification as to why the removal of these details from the TS is acceptable.
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BFN' ITS 3.5.1 ECCS OPERATING ITEM f DOC CTS /STS Description of Issue COMENTS or: LCO -
'JD#
3.5.1-3 LA5- CTS 3.5.B.14 The markup'for the CTS indicates Provide i justification that DOC LA5 provides'- for the renoval of the justification for the removal of requirements in CTS the requirements in CTS 3.5.B.14 3.5.B.14.
regarding operability of rrcirculation pump discharge valves. DOC LA5 does not discuss this change.
3.5.1-4 tA6 CTS 3.5.E CTS 3.5.E provides deteils of Provide'a justification methods of performing a HPCI as to why movement of surveillance test. DOC LA6 these details from the states that these details have TS to the Bases and been relocated to the Bases and procedures is procedures but does not provide acceptable.
any justification as to why the removal of these details from the TS'is acceptable.
3.5.1-5 LA7 CTS 4.5.H.1 CTS 4.5.H.1 provides Provide a justification requirements for venting the RHR as to why movement of discharge. piping. DOC LA7 these details from the states that the requirement to TS to procedures is vent prior to testing has been acceptable.
relocated to procedures but does not 3rovide any justification as to w1y the removal of these-details from the TS is acceptable.
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- BFN ITS 3.5.1 ECCS OPERATING
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ITEM f' DOC CTS /STS. Description of Issue C0t!ENTS or LCO JDi 3.5.1-6 L7 & CTS 3.5.B & CTS 3.5.B only allows one LPCI The only' concern with P24 STS'3.5.1. pump to be inoperable. ITS this chance is the Actions A & H 3.5.1. Action A. allows two LPCI wording of ITS pumps. one per loop or two in Condition H. The staff one loop. to be inoperable for believes it is seven days. This is a change to unnecessarily wordy and both the CTS and the STS. DOC proposes revising the L7 states that this change is first part of Condition justified based on the plant- H to read. "Two or more specific LOCA analysis for BFN. low pressure ECCS injection / spray
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subsystems inoperable for reasons other than Condition A.- This was the wording adopted in the Peach Bottom ITS for the same change.
3.5'.1 L8 CTS 4.6.D.2 The CTS markup references _ DOC L8 Please correct the CTS for changes to the requirements and ITS references in of CTS 4.6.D.2 which are DOC L8.
translated into a Note for ITS SR 3.5.1.11. DOC L8 incorrectly references CTS 4.6.D.4 and ITS SR 3.5.1.12 for this change.
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BFN ITF 3.5.1 ECCS OPERATI?G ITEM # 00C CTS /STS Description of Issue COMMENTS or LCO JD#
3.5.1-8 L9 & CTS 4.5.E.1.d CTS 4.5.E.1.d requires Please provide an L10 & 4.5.E.1.e verification that HPCI is explanation of the capabie of delivering at least basis for the new HPCI 5000 gpm at normal reactor test pressures. How vessel operating pressure ITS were the new numbers SR 3.5.1.7 requirems derived? What does the verification of HPCI flow rate accident analysis with reactor pressure > 920 psig assume with reaard to and 5 1010 psig. HPCI oeprating pressure? Include this CTS 4.5.E.1.e requires information as verification of HPCI flow at 150 additional psig reactor steam pressure. justification in DOCS ITS SR 3.5.1.9 requires L9 & L10.
verification of HPCI flow with reactor pressure 5 165 psig.
DOCS L9 & L20 state that the ability nf the HPCI pump to perform at the CTS required pressures has already been demonstrated and that a small change in the required test pressure will not affect the validity of the test to determine that the pump and turbine are still operating at the design specifications. The NSH considerations for these changes state that these changes do not affect the current accident analysis assumptions.
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BFN ITS 3.5.1 ECCS OPERATING t
ITEM # DOC CTS /STS Description of Issue COMMENTS or LCO JD#
3.5.1-9 L13 & CTS 4.5.8.1.g CTS 4.5.B.I.9 for Unit 3 This is a change that P29 for Unit 3 requires verification that the is beyond the. scope of only LPCI subsystem cross-tie valve the conversion to the is closed and power removed from STS: however. the the valve operator. ITS SR technical staff is 3.5.1.4 contains this same reviewing the requirement but offers an acceptability of the alternative of verifying the change based on the manual shutoff valve in the LPCI justification provided.
cross tie is closed. This is a If further information change to both the CTS and the is required it will be STS. forwarded in a separate request. ,
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ITEM # DOC CTS /STS Description of Issue COMMENTS or- LCO JD#
3.5.1 P21 STS.SR JFC P21 describes changes to 5i, The changes appear to 3.5.1.6 SR 3.5.1.6 (ITS SR 3.5.1.5). alter the STS Ine changes are made to be p esentation consistent with the current onnccessarily. The licensing basis (CLB). staff proposes retaining the STS Note as Note 2. adding another Note as Note I that reads. Only required to be performed when in MODE 4 > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.* and revising the STS Frequency to read.
~0nce prior to entering MODE 2 from MODE 3 or
In addition. the Bases additions for SR 3.5.1.5 are confusing.
What is meant by the phrase ' verification during or following entry into Mode 4 > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. . .~?
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BFN ITS 3.5.1 ECCS OPERATING ITEM # DOC CTS /STS Description of Issue COMMENTS or LCO JD#
3.5.1-11 B3 CTS 4.9.A.5 CTS 4.9.A.5 provides The only concern with requirements for testing the this change is the automatic transfer capability of wording of ITS SR the for the 480-V RMOV boards. 3.5.1.12. The staff ITS SR 3.5.1.12 provides the believes it is ;
same requirement in the ITS. unnecessarily wordy and proposes revising the '
SR to read. ~)erify automatic transfer of the power supply from the normal source to the alternate source for each LPCI subsystem i inboard injection valve and each recirculation pump discharge valve."
This was the wording adopted in the Peach Bottom ITS for the same change.
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ITEM # DOC CTS /STS Description of Issue <
COMMENTS or LCO JD#
3.5.1-12 Pil STS Bases for The STS discussion on limiting The staff dTs not 3.5.1 single failures has been deleted agree that infonnation Applicable in the ITS Bases. JFC Pil on the limiting single Safety states that it is unnecessary failures is unnecessary Analyses and that the information is not in the ITS Bases. It needed for operator should be noted that understanding of the many people besides the speci fication. operators will be using the ITS Bases as a reference and this information would be very helpful for a complete understanding of the requirements contained in the s nification. This is w1y the Applicable Safety Analyses section was included in the Bases. Please include a discussion of the limiting single failures. similar to that contained in the STS.
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BFN ITS 3.5.1 ECCS OPERATING ITEM i DOC CTS /STS Description of Issue COMMENTS or LCO.
JDf 3.5.1-13 P17 Bases The Reference Section in each Please revise the References LCO contains a reference to the reference to read as Final Policy Statement as follows. or provide follows: information as to where the original reference NRC No.93-102. " Final Policy came frort:
Statement on Technical Specification Improvements." " Final Policy Statement July 23. 1993. on Technical Specifications The staff does not believe this Improvements for is a correct reference. Nuclear Power Reactors.' 58 FR 39132.
July 22. 1993.
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BFN ITS 3.5.2 ECCS SHUTDLJnW i
ITEM # DOC CTS /STS Description of Issue COMMENTS or LCO JD#
3.5.2-1 N/A N/A It appears that all of the ITS Please correct CTS SRs referenced in the CTS markup markup to reference are incorrect (off by one correct SR numbers and t number). For example on page 3 provide a DOC for the of 7. DOC M3 is referenced to SR changes from CTS to 3.5.2.4 when it should be ITS SR 3.5.2.5. -
referenced to SR 3.5.2.3 and DOC M4 is referenced to SR 3.5.2.5 when it should be referenced to.
SR 3.5.2.4. In addition. there :
is no correct reference to ITS SR 3.5.2.5 for the simulated automatic initiation test and no associated DOC discussion.
3.5.2-2 LA1 CTS 4.5.H.1 CTS 4.5.H.1 provides Provide a requirements for venting the RHR justification as to 4 discharge piping. DOC LAI why movement of these states that the requirement to details from the TS to vent prior to testing has been procedures is ,
relocated to procedures but does acceptable.
not provide any justification as to why the removal of these details from the TS is l acceptable. '
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ITEM # DOC- CTS /STS Description of Issue C0rtfENTS or LCO JD#
3.5.2-3 LA3 CTS 4.5.H CTS 4.5.H contains details of Provide a methods for performing justification as to surveillance and routine system why movement of these status monitoring. DOC LA3 details from the TS to states that these details have the Bases and been relocated to the Bases and procedures is procedures but does not provide acceptable.
any justification as to why the removal of these details from the TS is acceptable 3.5.2-4 L1 CTS 3.5.A.5* The footnote ~*" to CTS 3.5'.A.5 Please provide requires manual initiation information as to how capability of either 1 CSS Loop this CTS requirement or 1 RHR pump. with the relates to your design capability of injecting water basis analysis. What into the reactor vessel when was the basis for this work is in progress which has requirement in the the potential to drain the CTS?
vessel. DOC L1 says that the deletion of this requirement is acceptable since the coolant inventory present when the fuel pool water level is maintained above the low level alarm setpoint is sufficient to allow operator action to terminate the inventory loss prior to fuel uncovery in case of an inadvertent draindown.
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BFN ITS 3.5.2 ECCS SRITDOWN ITEM # DOC' CTS /STS Description of issue COMMENTS :
or LCO JD# t 3.5.2-5 R1 CTS 3.5.is
- 4 DOC R1 discusses the relocation The staff could not i of a portion of CTS 3.5.A.5 that find a discussion of
] requires one RHR$W pump and this specific item in !
1 associated valves supplying the the document that standby coolant supply to be discusses application 4
OPERABLE when irradiated fuel is of the screening in the vessel and the vessel criteria. Also this i
! head is removed. DOC R1 states item did not appear in that additional information is the Summary ,
contained with regard to this Disposition Matrix. '
change in the application Please reconcile these document. discrepancies. :
3.5.2-6 Proposed changes to the Bases The staff believes P8 & STS Bases for [
, P19 3.5.2 Applicable Safety Analyses that a discussion of !
Applicable delf.e the discussion of the exactly what the i Safety number of ECCS subsystems design basis analysis i Analysis required in Modes 4 and 5 and requires for Modes 4 -
i replaces it with a general and 5 should be i i statement that says that ECCS retained in the Bases. ;
i recuirements are significantly The purpose of the j recuced during shutdown and that Applicable Safety
- "some' ECCS capability may be Analyses section is to required. provide any reader '
, with an understanding :
of why the TS !
requirements exist for !
that specification.
] The staff does not i agree that the ,
proposed changes make l
'j the Bases nrca- i understandable as !
stated in DOC P19. l
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-BFN ITS 3.5.2 ECCS SHUTDOWN ITEM #- DOC CTS /STS I Description of Issue COMMENTS or' LCO JD#
3.5.2-7 P8 STS Bases for. The Bases.have been changed to Is the information 3.5.2 LCO. add Insert B3.5-17C which states added to the Be .'s for that the necessary portions of LCO 3.5.2 also the Emergency Equipment Cooling applicable to LCO Water System are required to 3.5.1? If so. please provide adequate cooling-to each add this insert to the required ECCS subsystem.' This- Bases for LCO 3.5.1.
information does not appear'in. If not. explain why the Bases for LC0 3.5.1. not. _
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BFN ITS 3 5.3 RCIC SYSTEM ITEM # DOC CTS /STS Description of; Issue COMMENTS.
or- LC0 -
JD#
3.5.3-1 LA1 CTS.3 5.H CTS 3.5.H provides details Provide a justification relating to system design and as to why movement of purpose. DOC LA2 states that these details from the these details ~have been TS to t % Base.s and-relocated,to the Bases ~and procedures is procedures but'does not provide acceptable.
any justification as. to why the removal of these details from the TS is acceptable.-
3.5.3-2 LA2' CTS 4.5.H.3 CTS 4.5.H.3 & 4.6.0 contain Provide a justification details'of methods for- .
as to why movement of performing surveillance tests. these details from the DOC LA2 states that these TS to the Bases and details have-been relocated to procedures is the Bases and procedures but acceptable.
does not pro"ide any justification as to why the removal of these details.from the TS is acceptable.
3.5.3-3 LA3 CTS 3.5.F.1 CTS 3.5.F.1 provides-details of Provide a justification methods of performing a~ RCIC as to why movement of surveillance test. DCC LA3 these details from the states that these details have TS to the Bases and-been relocated to the Bases and procedures is procedures but does not' provide acceptable.
any justification as to why the removal' of these. details from-the TS is acceptable.
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BFN ITS 3.5.3 RCIC SYSTEM 1 " "'
ITEM # DOC CTS /STS. Description of Issue. COMENTS' or- 'LCO.
JD#-
3.5.3-4 L4 8, CTS 4.5.F.1.d' CTS 4.5.F.1.d requires Please provide an L5 & 4.5.F.1.e verification that RCIC is e- planation'of the capable of delivering at least basis for the new RCIC-600 gpm at normal reactor vessel test pressures'. How operating pressure. ITS SR were the new numbers 3.5.3.3 -requires verification of- deriveJ!' Include this RCIC flow rate with reactor information as pressure > 920 psig and 5 1010 additional psig. justification in DOCS L4 & L5.
CTS 4.5.F.1.e requires verification of RCIC flow at 150 psig reactor steam pressure.
ITS SR 3.5.3.4 requires.
verification af RCIC flow with reactor. pressure 5 165 psig.
00Cs L4 & L5 state'that the ability of the RCIC pump to perform at the CTS required pressures'has already been demonstrated and.that a small change in.the required test ,
pressure will not affect the validity of:the test to determine'that the pump and turbine are still operating at the' design ~ speci fications.
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.' 1 BFN' ITS 3.5.3 RCIC SYSTEM l ITEM # DOC CTS /STS- Description of' Issue COMMENTS-or LCO:
JD#
3.5.3-5 P27 STS Bases for A change has been made to the Both of these SRs SR 3.5.3.3-8 STS bases'to delete a contain notes stating SR 3.5.3.4 description of the steam flow that they are not rate'or' number of open bypass required to be valves that represent adequate. 3erformed until 12 steam flow to perform the 1 lours after reactor subject SRs. JFC P27 states steam pressure and flow that the availability of . are adequate to perform adequate steam flow is not as the test. Therefore.
critical for RCIC as it is for the staff, feels that it HPCI and SRV testing and that is important to state BFN does not consider it what is meant by necessary to specify a reactor- adequate steam flow in power or turbine bypass valve the Bases for these position which represents SRs. Please provide a adequate steam flow for RCIC- discussion of the pump flow testing. parameters that define adequate steam flow for the purpose of these SRs similar to that provided in the STS Bases.
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BFN ITS 3.9.1 REFUELING EQUIPMENT INTERLOCKS COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC CTS /STS Description of. Issue Date Date COMMENTS or LCO Opened Closed JFD 3.9.1-1 Al- CTS 3.10 CTS 3.10 requires core reactivity 1-23-97 Provide limitations in place to ensure that the discussion and core reactivity.is within the capability justification for y of the control rods. ITS 3.9.1 does not moving this CTS a retain the. core reactivity limitations requirement.
for control rod capability. There is no discussion or justification for moving this detail.
3.9.1-2 Al CTS 3.10 CTS 3.10 requires core reactivity 1-23-97 Provide limitations in place to prevent discussion and criticality during refueling. ITS 3.9.1 justification for does not retain the core reactivity moving this CTS limitations to present criticality during requirement refueling. There is no discussion or justification for moving this detail.
3.9.1-3 Al CTS 3.10 CTS 3.10 requires fuel handling 1-23-97 Provide requirements in place during CORE discussion and.
ALTERATIONS. ITS 3.9.1 requires the fuel justification for handling interlocks in place only during this less in-vessel fuel movement. This chance is restrictive a less restrictive change that is not change.
justified.
3.9.1-4 Al CTS 4.10 CTS Surveillance Requirement 4.10 1-23-97 Provide requires periodic testing of discussion and instrumentation required for refueling justification for interlocks during CORE ALTERATIONS. ITS moving this CTS SR 3.9.1 does not retain the requirement requirement.
to periodically test instrumentation of the refueling interlocks during CORE ALTERATIONS. There is no discussion or justification for moving this detail.
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BFN ITS 3.9.1 REFUELING EQUIPMENT INTERLOCKS COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC CTS /STS Description of Issue Date Pate COMMENTS or LCO Opened Closed JFD 3.9.1-5 A3 CTS CIS 3.10.A.1 requires that the refueling 1-23-97 Provide 3.10.A.1 equipment interlocks be OPERABLE except additional as specified in CTS 3.10. A.6 and discussion and 3.10.A.7. ITS 3.9.1 does not retain the justification for eXCEations of CTS 3.10. A.6 and 3.10. A.7. moving this CTS The justification provided for moving requirement.
this detail is inadequate.
3.9.1-6 A4 CTS CTS Surveillance Requirement 4.10.A.1 1-23-97 Provide 4.10.A.1 requires functional testing the required discussion and refueling equipment interlocks prior to justification for any fuel handling with the head off the this less vessel. ITS 3.9.1 does not retain the restrictive requirement to perform the functional requirement.
testing prior to any fuel handling with the head off the vessel. This is a less restrictive change that is not justified.
3.9.1-7 Al CTS CTS Surveillance Requirement 4.10.A.1 1-23-97 Provide 4.10.A.1 requires functionally testing the additional required refueling equipment interlocks. discussion and ITS SR 3.9.1.1 requires performing justification for CHANNEL FUNCTIONAL TESTS on the required the changed CTS refueling equipment interlock inputs. requirement.
There is no discussion or justification that indicates the CTS " functionally testing" equates to the ITS "OIANNEL FUNCT10NAL TEST."
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BFN ITS 3.9.1 REFUELING EQUIPMENT INTERLOC;iS COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS J
DOC CTS /STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.9.1-8 'Al CTS CTS Surveillance Requirement 4.10.A.1 1-23-97 Provide 4.10.A.1 requires functionally testing tha additional required refueling equipment interlocks. discussion and ITS SR 3.9.1.1 requires performing a justification for CHANNEL FUNCTIONAL TEST on each of the the changed CTS required refueling equipment interlock requirement.
inputs. There is no discussion or justification that indicates CTS
" refueling equipment interlocks" equates to the ITS'" refueling equipment interlock inputs."
3.9.1-9 LA1 CTS CTS 3.10.A.3 requires setting the fuel 1-23-97 Provide 3.10.A.3 grapple hoist load switch at s 1000 lbs. additional ITS 3.9.1 does not retain any of this discussion and requirement. The justificatior provided justification for for moving this detail is inadequate and moving this CTS the requirement is moved to an requirement.
unspecified utility controlled document. Specify the document (s) to which the requirement is moved and how it is controlled.
l BFN TTS 3.9.1 REFUELING EQUIPMENT INTERLOCKS l COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC CTS /STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.9.1-10 LAl CTS CTS 3.10. A.4 requires that if the frame- 1-23-97 Provide 3.10.A.4 mounted auxiliary hoist. the monorail- additional mounted auxiliary hoist. or the service discussion and platform hoist is to be used for handling justification for fuel with the head off the reactor moving this CTS vessel. the load limit switch on the requirement.
hoist to be used shall be set at < 400 Specify the lbs. ITS 3.9.1 does not retain any of document (d to this recuirement. The justification which the providec for moving this detail is requirement is inadequate and the requirement is moved moved and how is to an unspecified utility controlled to be controlled.
document.
3.9.1 11 LA2 CTS CTS Surveillance Requirement 4.10.A.1 1-23-97 Provide 4.10.A.1 requires testing following any re) air additional work associated with the interlocts. ITS discussion and 3.9.1 does,not retain the requirement to justification for test following repair work. The the moving the justification provided for moving this CTS requirement.
detail is inadequate 3.9.1-12 Al CTS CTS Surveillance Requirement 4.10.A.1 1-23-97 Provide 4.10.A.1 requires weekly testing of the additional interlocks. ITS SR 3.9.1.1 requires a 7 discussion and day testing frequency. Weckly can mean justification for performance anytime during a week. while this changed CIS 7 days means every 7 days. There is no requirement.
discussion or justification to indicate that the CTS " weekly" equates to the ITS "every 7 days."
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i BFN'ITS 3.9.1 REFUELING EQUIPMENT' INTERLOCKS COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC. CTS /STS' Description of-Issue Date . Date COMMENTS or LCO Opened Closed JFD-3.9.1-13 JDC. STS SR . STS SR 3.9.1.1.c requires performing a 1-23-97 Provide B1 3.9.1.1.c CIW4NEL FUNCTIONAL TEST on each of the discussion and required refueling equipment interlock justification for inputs: . Refuel platform [ fuel grapple]. the STS deviation fuel loaded. ITS SR 3.9.1.1.c requires based on current.
performing CHANNEL FUNCTIONAL TESTS on _ . licensing bas.s.
each of the required refueling. equipment system design. or interlock inputs: Refuel platform main operational hoist. fuel loaded.. There is no constraints.
discussion or. justification based on current licensing basis or system design for the deviation from the STS in changing the CTS [ fuel grapple] to the ITS-main hoist.
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BFN ITS 3.9.2 REFUEL P03ITION ONE-ROD-0UT INTERLOCK COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC CTS /STS Description of Issue COMMENTS or LCO JFD 3.9.2-1 Al CTS 3.10 CTS 3.10 requires core reactivity Provide l limitations in place to ensure that the discussion and '
core reactivity is within the capability justification for of the control rods. ITS 3.9.2 does not moving this CTS retain the core reactivity limitations requirement.
for control rod capability. There is no discussion or justification for moving this detail. j 3.9.2-2 Al CTS 3.10 CTS 3.10 requires core reactivity Provide limitations in place to prevent discussion and cr.ticality during refueling. ITS 3.9.2 justification for does not retain the core reactivity moving this CTS limitations to prevent criticality during requirement.
refueling. There is no discussion or justification for moving this detail.
3.9.2-3 Al CTS 3.10 CTS 3.10 requires fuel handling Provide requirements in place during CORE discussion and ALTERATIONS. ITS 3.9.2 requires the fuel justification for handling interlocks in place only during this less in-vessel fuel movement. This change is restrictive a less restrictive change that is not requirement.
justi fied.
3.9.2-4 Al CTS 4.10 CTS Surveillance Requirement 4.10 Provide requires periodic testing of discussion and instrumentation required for refueling justification for interlocks during CORE ALTERATIONS. ITS moving the CTS SR 3.9.2 does not retain the requirement requirement.
to periodically test instrumentation of the refueling interlocks during CORE ALTERATIONS. There is no discussion or justification for moving this detail.
BFN ITS 3.9.2 REFUEL POSITION ONE-R00-00T INTERLOCK COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC CTS /STS Description of Issue COMMENTS or LC0 JFD 3.9.2-5 A3 CTS CTS 3.10. A.1 requires the refueling Provide 3.10.A.1 equipment interlocks OPERABLE except as discussion and speci fied in CTS 3.10. A.6 and 3.10. A.7. justification for ITS 3.9.2 does not retain the exceptions moving this CTS of CTS 3.10. A.6 and 3.10. A.7. The requirement. !
justification provided for moving this i detail is inadequate.
3.9.2-6 L1 CTS CTS Surveillance Requirement 4.10.A.1 Provide 4.10.A.1 requires that. prior to any fuel handling additional with the head off the vessel. the discussion and required refueling equipment interlocks justification for be functionally tested. The ITS SR this less 3.9.2.2 NOTE allows I hour after any restrictive control rod withdrawal before requiring a change.
CHANNEL FUNCTIONAL TEST. There is no discussion or justification for this less restrictive change in the CTS.
3.9.2-7 L2 CTS CTS 3.10.A.1 is applicable during CORE Provide 3.10.A.1 ALTERATIONS. ITS 3.9.2 is applicable additional during MODE 5 with the reactor node discussion and switch in the REFUEL position and any justification for control rod withdrawn. There is this less inadequate discussion or justification restrictive for this less restrictive change in the change.
CTS.
3.9.2-8 LAl CTS CTS Surveillance Requirement 4.10.A.1 Provide 4.10.A.1 requires testing following any repair additional work associated with the interlocks. ITS discussion and 3.9.2 does not retain the requirement to justification for test fellowing repair work. The moving this CTS justification provided for moving this requirement.
detail is inadequate.
.m
~
BFN ITS 3.9.2 REFUEL POSITION ONE-ROD-0UT INTERLOCK- !
COPMENTS ON INPROVED TECHNICAL SPECIFICATIONS .
00C' CTS /STS- Descriptio'n of Issu'e. COMMENTS .
i ;i or LCO JFD 3.9.2-9 Al CTS. CTS Surveillance' Requirement 4.10.A.1 Provide.
4 10.A.1 requires functionally. testing the . .
additional required refueling equipment interlocks. discussion and ITS SR 3.9.2.1-requires performing. justification for CHANNEL FUNCTIONAL TESTS on the required ti.e changed CTS refueling equipment interlock inputs. requirement.
There is no discussion or justification that indicates the CTS " functionally-testing" equates to the ITS " CHANNEL-FUNCTIONAL. TEST."
3.9.2-10 Al CTS CTS Surveillance Requirement 4.10.A.1 Provide 4.10.A.1 requires functionally testing the additional required refueling. equipment interlocks. discussion and ITS SR 3.c 2.1 requires performing a justification for CHANNEL Fin 4CTIONAL TEST-on each of the the changed CTS-required refueling equipment interlock requirement.
inputs. 'There:is no discussion of justification that; indicates CTS
" refueling equipment interlocks" equates to the ITS " refueling equipment interlock inputs."
3.9.2-11 A1 CTS CTS Surveillance Requirement 4.10.A.1 Provide 4.10.A.1 requires weekly testing of the. additional interlocks. .ITS SR 3.9.2.1 requires a 7 discussion and day testing frequency. Weekly can mean justification for
= performance anytime during a week. while the changed CTS.
7 days means every 7 days. There is no.
requirement.
discussion or justification to indicate that the CTS " weekly" equates to the ITS ,
"every 7 days."
_..-.i____.z__.___
-BFN ITS 3.9.3 CONTROL-R00 POSITION
'COMENTS ON IMPROVED-TECHNICAL SPECIFICATIONS DOC CTS /STS- Description of Issue COMMENTS or LC0 JFD' "No Issues" I
1 1
i%
f . g
.BFN ITS 3.9.4 CONTROL R00 POSITION INDICATION COMENTS ON IMPROVED TECHNICAL SPECIFICATIONS.
DOC- CTS /STS Description.of Issue- COMMENTS or LCO JFD 3.9.4-1 JDC sis 3.9.4 STS 3.9.4 requires the control rod Provide P3 full-in position indication channel for discussion and each control rod OPERABLE. ITS 3 9.4 justification for recuires the control rod. full-in position the STS deviation incication for each control rod OPERABLE. based on current There is inadequate discussion or licensing basis.
justification based on system design for - system design.
the deviation from the STS for dropping and operational the word channel. constraints.
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.- . 4 BFN'ITS 3.9.6 REACTOR PRESSURE VESSEL (RPV) WATER LEVEL COMMENTS ON IMPROVED TECHNICAL SPECIFICATIONS DOC CTS /STS Description of Issue- COMMENTS s or LC0 JfD 3.9.6-1 JDC STS 3.9.6 STS 3.9.6 is titled Reactor Pressure Provide B1- Vessel Water Level - Irradiated Fuel. discussion and l ITS 3.9.6 is titled Reactor Pressure justification for Vessel Water Level. There is no the STS deviation discussion or justification based on based on current current licensing basis. system design. licensing basis, or operational constraints for this STS system design, deviction of changing the title of the and operational LCO. constraints.
3.9.6-2 JDC STS 3.9.6 STS SR 3.9.6.1 verifies the Reactor Provide.
B1 Pressure Vessel (RPV) water level is = 23 discussion and ft. above the top of the RPV flange. ITS justification for 3.9.6.1 verifies the Reactor Pressure the STS deviation Vessel (RPV) water level is 2 23 ft. based on current above the top of the irradiated fuel licensing basis.
assemblies seated within the RPV. There system design.
is no discussion or justification based and operational on current licensing basis, system constraints.
design. or operational constraints for this .STS deviation of changing the reference from which the water height is measured.
'BFN ITS 3.9.7 RESIDUAL HEAT REMOVAL (RHR) - HIGH WATER LEVEL COPMENTS ON INPROVED TECHNICAL SPECIFICATIONS.-
I
' DOC CTS /STS Description of-Issue - COMMENTS or LCO JFD 3.9.7-1 JDC ST:,- STS 3.9.8 Applicability is for MODE 5 Provide- .
B1 - 3.9.8- with irradiated fuel in the Reactor discussion and Pressure Vessel (RPV) and the water level: justification for 2' 23 ft. above the top of. the RPV flange. the STS deviation
-ITS 3.9.7 Applicability is for MODE 5 based on current' with irradiated fuel in the Reactor licensing basis.
Pressure Vessel-(RPV) and the water level system design.
2 22 ft. above the top of the RPV flange. and operational There is no discussion or justification design.
based on current licensing basis.. system design. or operational constraints for the deviation from the STS water level of 2 23 ft. to 2 22 ft.
1 BFN ITS 3.9.8' RESIDUAL HEAT REMOVAL'(RHR) - LOW WATER LEVEL i l
..COPMENTS ON IMPROVED TECHNICAL SPECIFICATIONS
- O DOC CTS /STS.- Description of Issue COMMENTS or LCO JFD 3.9.8-1 JDC- STS STS 3.9.9 Applicability is for MODE 5 Provide B1 3.9.9. with irradiated fuel in the Reactor discussion and Pressure Vessel (RPV) and the water level' justification for
< 23 ft. above the top of the RPV flange. the STS deviation ITS 3.9.8 Applicability is for MODE 5 based on current with irradiated fuel in the Reactor licensing basis.
Pressure Vessel (RPV) and the water level system design.
< 22 ft. above the top of the RPV flange. and operational There is no discussion or justification design.
based on current licensing basis system design. or operational constraints for the deviation from the STS water level of
< 23 ft. to < 22 ft.
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BFN ITS 3.10.2 REACTOR MODE SWITCH INTERLOCK TESTING .,-
ITEM # DOC # CTS /STS Description of Issue COMMENTS or LCO JFD#
3.10.2-1 M2 CTS 1.0.M CTS 1.0.M. Note (1), allows placing the mode switch in any Provide Note (1) position to perform required tests or maintenance justification for authorized by the shift operations supervisor. ITS 3.10.2 adding these allows changing the mode switch to a position other than restrictions, that specified in ITS Table 1.1-1 to perform testing of instrumentation associated with the mode switch interlock functions. The CTS allows changing the mode switch for any testing or maintenance while the ITS allows changing the mode switch for only testing of mode switch interlocks.
The discussion does not provide justification for this additional restriction.
3.10.2-2 Al' STS ITS 3.10.2 provides specific conditions in which ITS 3.10.2 Provide discussion 3.10.2 is applicable._ There is no discussion of how the CTS and and justification Applicabi ITS Applicabilities are the same. for applicability of, lity ITS 3.10.2.
3.10.2-3 L1 CTS 1.0.M CTS 1.0.M. Footnote 1. allows placing the reactor mode Provide Note (1) switch in any position to perform required tests or justification for maintenance authorized by the shift operations supervisor this more provided control rods are verified fully inserted. ITS restrictive change.
3.10.2 allows conducting mode switch interlock testing if all control rods remain fully inserted in core cells containing one or more fuel assemblies and no core alterations are in progress. The addition of the requirement that no core alterations are in progress is a more restrictive change.
o- - -- - - - - -
.; ^
BFN ITS 3.10.2 REACTOR MODE SWITCH INTERLOCK TESTING ,,
I' TEM #- DOC # CTS /STS. Description'of Issue- COMMENTS-or. LC0 JFD#'
3.10.2-4 M1 CTS 1.0.M ITS 3.10.2 adds ACTIONS to identify the Required Actions- Provide Note-(1) and Completion Times for noncompliance. The CTS contains. justification.for-no similar ACTIONS. ITS 3.10.2 also adds Surveillance adding.these Requirements to' verify all control rods are inserted in ACTIONS and cells containing fuel.and that no CORE ALTERATIONS are in Surveillance progress. The discussion does not provide justification Requirements.
for these additional restrictions.
3.10.2-5 LA1 CTS 1.0.M CTS-1.0.M. Footnote 1. allows the reactor mode switch Provide Note.(1) placed in any position to perform required tests or justification for maintenance authorized by the shift operations supervisor removing these provided the control rods are verified fully inserted by a details and the.
second licensed operator or other technically qualified. specific procedure staff member. . ITS 310.2 allows conducting mode switch these requirements interlock testing if all control rods remain fully inserted moved to.
in core cells containing one or more fuel assemblies and no CORE ALTERATIONS are in progress. ITS SRs 3.10.2.1 and 3.10.2.2 recuire verification that control rods are
~ inserted anc no CORE ALTERATIONS are'in progress. ITS 3.10.2 does not contain the details of how the surveillances are performed. The discussion does not provide justification for removing these details or discuss specifically the procedure these detaiis may have been moved to.
L.
m__ -
BFN!ITS 3.10.3 SINGLE CONTROL R0D WITHDRAWAL-- HOT. SHUTDOWN ..
ITEM # DOC # CTS /STS Description of-Issue COMMENTS-or LCO JFD#
3.10.3-1 M1 CTS 1.0.M CTS 1.0.M..Footnota 3 allows placing Provide discussion and Note'(3) the reactor mode switch in the refuel justification for the position while recoupling or additional
~
withdrawing a= single control rod. requirements of ITS provided the one-rod-out interlock is 3.19.3.
o>erable. ITS 3.10.3 allows changing t1e reactor mode switch position specified. in ITS Table'1.1-1 for MODE 3 to include the' refuel position.
allowing withdrawal of a single control rod. provided the following requirements are met: a) ITS 3.9.2.
refuel position one-rod-out
~
interlock; b) ITS 3.9.4. control rod position indication: c) all other control rods fully, inserted: and d)
ITS 3.3.1.1-for certain Reactor Protection Instrumentation including Intermediate Range Monitors. Scram Discharge Volume Water Level. Reactor' Mode Switch -Shutdown Position. and Manual Scram and'ITS'3.9.5. control rod OPERABILITY - refueling or all other control rods in a five by five array centered on the control rod being withdrawn are disarmed. The discussion does not adequately address all of:the requirements added in ITS 3.10.3.
BFN ITS 3.10.4 SINGLE CONTROL R0D WITHDRAWAL -. COLD SHUTDOWN :.....
ITEM #: 00C#_. CTS /STS- De'scription of Issue COMMENTSL or- LCO JFD#- >
3.10.4-1 A2 CTS 3.10.A.51 CTS 1.0.M. Note 2. allows placing ' Provide discussion and the reactor mode switch in the justification for refuel' position while a single- these less; restrictive _
control rod drive is being changes.
pro.ided coolant temperature s 212 *F. -CTS 3.10.A.5 allows maintenance performed on a single control: rod or' control rod drive without removing the fuel in the control cell. if the following conditions are met: a) refueling interlocks are OPERABLE. and b) all control rods diagonally and face adjacent to the maintenance rod are: fully inserted and disarmed. CTS 3.10.A.5 specifically addresses performing maintenance on a control rod or control rod drive without removing fuel. ITS 3.10.4 addresses withdrawing a single control rod. and= subsequent removal of the associated control rod drive, if desired. The CTS applies .to a very specific.
condition while the ITS is more general. These differences appear less restrictive and are not discussed:in the justification of the changes.
BFN ITS 3.10.'4 . SINGLE CONTROL' ROD WITHDRAWAL - COLD SHUTDOWN ,
_ ITEM #.. 00C#. CTS /STS Description of Issue- COMMENTS' or. LCO JFD#'
3.10.4-2 M1 CTS CTS 3.10.A.5 b requires all Provide additional 3.10.A.5.b control rods diagonall." and face justification for and' adjacent to the maintenance rod these more restrictive CTS be fully inserted and disarmed. changes.
Surveillance ITS 3.10.4.c.2 is more Requirement restrictive since it requires 4.10.A.5 disarming all other control rods in a'.five by five array centered on the control rod being withdrawn. 'The corresponding surveillance. ITS SR 3.10.4.2 is also more restrictive than CTS-Survei11ance Recuirement 4.10.A.5. ~The ciscussion does not adequately justify these more restrictive changes.
BFN ITS 3.10.4 SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN .
ITEM # DOC # CTS /STS Description of Issue COMMENTS or LCO-JFD#
3.10.4 Al CTS 4.10.A.5 CTS 4.10.A.5 requires performing Provide discussion and-the surveillance requirements of justification for CTS 4.10.A.1'(refueling these more restrictive-interlocks) prior to performing changes.
control rod or control rod drive maintenance without removing fuel assemblies. ITS SR 3.10.4.1 requires performing the applicable SRs for the required LCOs. The applicable LCOs may include ITS 3.9.2.'ITS 3.9.4. ITS 3.3.1.1. or ITS 3.9.5. The CTS markup shows these as equivalent.
for example. showing CTS 4.10.A.1 is the same as ITS 3.9.2. -The discussion and justification does not adequately address these more restrictive changes.
BFN ITS 3.10.4 ' SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN .
ITEM # DOC # CTS /STS Description of Issue COMMENTS or LCO JFD#
3,10.4-4 M3 CTS 4.10.A.5. CTS 4 10.A.5 does not~ require a Provide -justification perisdic verification that for these more control rods are disarmed. ITS' restrictive changes.
SR 3.10.4.2. rec uires veri fying -
all control ' roc s. Other than the rod withdrawn in the five by five array are disarmed on'a frequency of 24-_ hours.
Therefore. the periodic reverification is more restrictive. ITS SR 3.10.4.3 is also'added to verify all control' rods. Other than the control rod being withdrawn. are fully inserted every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No justification is provided for these more restrictive changes.
3.10.4-5 M4- CTS 3.10.A.5- ITS 3.10.4.b.1~ requires meeting- Provide justification ITS 3.9.4. " Control Rod Position for this more Indication." in addition to ITS restrictive change.
3.9.2 " Refuel. Position One-Rod-Dut-Interlock." CTS 3.10.A.S.a requires having'the one-rod-out interlock' OPERABLE. No justification is provided for' this more restrictive change.
I BFN ITS 3.10.4. SINGLE CONTROL R0D WITHDRAWAL -. COLD SHUTDOWN 4 ITEM #- DOC # CTS /STS" Description of Issue COMMENTS or1 LCO -
JFD#
3.10.4-6 LA1 CTS 3.10.A.5 CTS 3.10.A.5 and 4.10.A.5 require Provide s)ecifics to and electrically disarming the. support t1e CTS 4.10.A.5 directional control valve for justification for control rods adjacent'to a moving these details.
maintenance rod. ITS 3.10.4.c.2 .
recuires disarming the control rocs in a- five by five array
~
surrounding-the rod being withdrawn. The justification states the details of disarming-control rods moved to the BASES and procedures. ITS B.3.10.4 states'the control rods are disarmed electrically or hydraulically. The discussion does not provide justification for allowing hydraulically disarming the control rods. The justification does not give the specific procedure.
.BFN ITS 3.10.57 SINGLE CONTROL R00 DRIVE (CRD). REMOVAL - REFUELING ..
ITEM # . DOC #' CTS /STS Descript' ion of Issue COMMENTS.
or LCO JFD#
3.10.5-1 Al CTS . CTS 3.10.A.6 allows withdrawing two Provide discussion and 3.10.A.6 non-adjacent control rods justification for this simultaneously to perform control less restrictive rod and/or control rod. drive change.
maintenance without removing fuel from the' cells. provided certain conditions are met. ITS 3.10.5 permits the suspension of several
-ITS requirements to allow removal of a single' control rod drive, associated with a control rod withdrawn from a core cell containing one or more fuel assemblies. provided certain conditions are met. The ITS requirements suspended include Reactor Protection System (RPS) instrumentation. RPS power monitoring. refueling interlocks.
one-rod-out interlock. control rod g position' indication, and. control rod operability. This change is less-restrictive since it allows -
suspension of other requirements.
There is,no discussion or-justification for this change.
'BFN ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFbdini _
n- -
ITEM # DOC #. CTS /STS Description of issue ComENTS or LCO -
JFD#
3.10.5-2 A2 CTS' CTS 3.10.A.6.a requires all Provide discussion and 3.10.A.6.a refueling interlocks OPERABLE. justification for this except the Interlock which prevents less restrictive morc than one control rod being change.
withdrawn. when withdrawing control rods to perform control rod or.CPJ) maintenance. ITS 3.10.5 permits the suspension of ITS 3.9.1.
Refueling Equipment Interlocks. to allow removal of a single control rod drive associated with a control rod withdrawn from a' core cell containing one or more fuel assemblies. ITS 3.10.5 deletes the statement requiring all other refueling interlocks OPERABLE. The justification does not adgately justify this as an administrative change. No discussion is provided .
showing equivalency between the CTS and ITS.' ITS 3.10.5 allows suspension of ITS 3.9.1. Refueling Equipment Interlocks. however CTS 3.10.A.6.a requires the refueling interlocks.
c BFN ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUE.,NG .
7 ' ITEM # DOC # CTS /STS Description of, Issue COMMENTS.
or LCO-JFD#
3.10.5-3. A5 CTS ITS 3.10.5 adds Required Action A Provide discussion and 3.10.A.6 which requires suspending removal justification for this of the CRD and initiating action to more restrictive insert the affected rod back into change.
the core. or comply with the requirements of ITS 3.10.5. CTS 3.10.A.6 dTs not provide specific actions if the requiremer.t are not met. The change is more restrictive since the CTS does not provide specific actions.
3.10.5-4 M1 CTS CTS 3.10.A.6 allows withdrawing two Provide justification
< 3.10.A.6 control rods to perform centrol rod for this more or CRD maintenance. ITS 3.10.5 restrictive changc.
only allows one control rod to be withdrawn and removed from the core. The discussion does not provide justification for this more restrictive change.
3.10.5-5 M1 CTS The CTS 3.10.A.6.c requirement that Provide justification 3.10.A.6.c two maintenance cells be separated for this less by two rods in all directions. is restrictive change.
deleted from ITS 3.10.5. The deletion of this requirement is a less restrictive change.- The discussion does not provide justification for this change.
BFN ITS 3.10.5 SINGLE CONTROL ROD DR.'VE (CRD) REMOVAL - REFUELING ,
i ITEM # DOC # CTS /STS Description of Issue COMMENTS or LCO
.- JFDf 3.10.5-6 M1 ITS' ITS 3.10.5.a. c. and d add new Provide justification 3.10.5.a. requirements to ensure only one rod for these more
- c. and d is withdrawn. This includes restrictive changes.
requiring all other control rods fully inserted (ITS 3.10.5.a). SDM requirements modified (ITS 3.10.5.c). a control rod block is inserted (ITS 3:10.5.c). and no other CORE ALTERATIONS in progress (ITS 3.10.5.d)._ The discussion does not provide justification for these more restrictive changes.
3.10.5-7. M1 CTS- CTS 3.10.A.6.a allows bypassing the Provide justification 3.10.A.6.a refueling interlock which prevents for tnis more more than one rod from being restrictive change.
withdrawn. ITS 3.10.5 does not allow bypassing this interlock.
The discussion does not provide justification for this more restrictive change.
11 3.10.5-8 M2 CTS CTS Surveillance Requirement Provide justification 4.10.A.6 4.10.A.6 requires verification that for this more the requirements of CTS 3.10.A.6 restrictive change.
are satisfied prior to performing control rod or CRD maintenar.ce.
The ITS Surveillance Requirements require periodic verification that ITS 3.10.5 requirements are met.
The discussion does not provide justificataon for this more restrictive change.
BFN ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING ,'
ITEM #' DOC # CTS /STS Description of Issue COMMENTS or LCO JFD#
3.10.5-9 M3 ITS SR ITS 3.10.5 adds new Surveillance Provide justification 3.10.5.1. Requirements to verify all other for these changes.
3.10.5.3. control rods are fully inserted and (ITS SR 3.10.5.1). to verify a 3.10.5.5 control rod withdrawal block is inserted (ITS SR 3.10.5.3). and to verify that no other CORE ALTERATIONS are in progress (ITS SR 3.10.5.5). No justification is provided for these more restrictive
]' - changes.
3.10.5-10 LA1 CTS CTS 3.10.A.6.a requires the reactor Provide specifics to 3.10.A.6.a mode switch locked in the REFUEL support the position. ITS 3.10.5 does not justification for specify the position of the MODE moving the MODE switch. The justification states switch.
the movement of the MODE switch is controlled by procedure. The justification does not give the specific procedure.
BFN ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING ,"
ITEM #- DOC # CTS /STS Description of Issue CQttENTS or LCO JFD#
3.10.5-11 LA2 CTS- CTS Surveillance Requirement Provide specifics to 4.10.A.6- 4.10.A.6. requires two Senior support the Reactor Operators (SRO) verify the justification for requirements of CTS 3.10.A_6 are moving this met. ITS SR 3.10.5.2 and SR requirement to the 3.10.5.2.4 require verification of Bases or procedures.
the requirements. but do not specify two SR0s. The justification states these requirements moved to the Bases and procedures. The justification does not give the specific procedure and the Bases does not address this requirement.
a l
d 4
BFN ITS 3.10.5 SINGLE CONTROL R00 DRIVE (CRD) REMOVAL - REFUELING _
ITEM # 00C# CTS /STS Description of Issue COMMENTS or LCO JFD#
3.10.5-12 LA3 CTS CTS 3.10.A.6.b requires Provide specifics to 3.10.A.6.b electrically disarming directional support the control valves for control rods justification for when withdrawing a control rod for moving these details.
control rod or CRD maintenance.
ITS 3.10.5.b requires disarming control rods if removing a CRD.
The justification states the details of disarming control rods moved to the BASES and procedures.
ITS B.3.10.5 states the control rods are disarmed electrically or hydraulically. The discussion does not provide justification for allowing hydraulically disarming the control rods The justification does not give the specific procedure.
BFN ITS 3.10.6 MULTIPLE CONTROL R00 WITHDRAWAL - REFUELING- .
kITEM# DOC # CTS /STS Description of Issue COPMENTS or LC0 o JFD#
3.10.6-1 Al CTS CTS 3.10.A.7 allows any number of Provide discussion and 3.IO.A.7 control rods withdrawn or removed. justification for this provided certain conditions are more restrictive met. ITS 3.10.6 permits the change.
suspension of several ITS requirements to allow the withdrawal of multiple control rods. removal of associated control rod drives. or both, provided certain conditions are met. The
" ITS' requirements suspended include:
control rod position. control rod position indication. and control rod operability. There is no discussion or justification for this more restrictive change.
BFN ITS 3.10.6 MULTIFLE CONTROL ROD WITM) RAMAL - REPJELING ._
ITEM #. DOCf CTS /STS Description of Issue COMMENTS or LCO JFD#
3.10.6-2 A2 CTS ITS 3.10.6 adds Required Action A. Provide discussion and 3.10.A.7 which requires suspending removai justification for this of the control rods and CRD. more restrictive suspending loading fuel. and change.
inserting all controls rods in cells containing fuel or initiating action to satisfy the requirements-of ITS 3.10.6. CTS 3.10.A.7 does not provide specific actions if the requirements are not met. The change is more restrictive since the CTS does not provide specific l actions.
BFN ITS 3.10.6 MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING .
ITEM # DOCf CTS /STS Description of Issue COWINTS or LCO JFDf 3.10.6 A3 CTS CTS 3.10.A.7.a requires all Provide discussion and 3.10.A.7.a refueling interlocks OPERABLE justification for this except the interlock which prevents administrative change.
more than one control rod being withdrawn when withdrawing multiple control rods. ITS 3.10.6 permits the suspension of ITS requirements for control rod position. control
, rod position indication. control i rod operability. and bypassing the full-in position indication to allow removal of multiple control rods and/or CRDs. ITS 3.10.6 deletes the statement requiring all other refueling interlocks be OPERABLE. The justification does not adequately justify this as an administrative change. No discussion is provided showing equivalency between the CTS and ITS.
BFN ITS 3.10.6 MULTIPLE CONTROL R00 WITHDRAWAL - REFUELING .'
ITEM # DOC # CTS /STS Description of Issue COMMENTS or LCO JFD#
3.10.6-4 A4 CTS CTS 4.10.A.7 prohibits withdrawing Provide adequate 4.10.A.7 more than one control rod. with the justification for mode switch in REFUEL or SHUTDOWN. deleting this '
without first removing fuel from statement. '
the cell. The justification states this is repetitive to CTS 4.10.A.6.
CTS 4.10.A.6 requires satisfying CTS 3.10.A.6 prior to performing maintenance on control rod or control rod drive on two control l cells simultaneously without removing the fuel. The !
requirements of CTS 4.10.A.7 and '
4.10.A.6 are not equivalent. '
therefore the justification is not adequate.
3.10.6-5 M1 CTS CTS 3.10.A.7 establishes the Provide justification 3.10.A.7 conditions required for the for adding this I withdrawal or removal of multiple requirement.
control rods during refueling. ITS 3.10.6. Multiple Control Rod Withdrawal-Refueling. sets the requirements for the same activity i in the ITS. ITS 3.10.6.b adds a recuirement that all other control !
rocs in core cells containing one or more fuel assemblies must be fully inserted. The discussion does not provide justification for adding this requirement.
BFN ITS 3.10.6 MULTIPLE CONTROL ROD WITERAWAL - REFUELING [
ITEM # 00C# CTS /STS Description of Issue COMMENTS or LCO JFD#
i 3.11.6-6 M2 CTS. CTS-4.10.A.7 requires two licensed Provide justification 4.10.A.7- operators verify that fuel is for adding the removed from each_ cell before any requirement to number of control rods are periodically verify withdrawn. ITS SR 3.10.5.1 the fuel asserblies requires verifying the fuel are' removed.
assemblies are removed from the core cells associated with each control rod or CRD removed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The discussion does not provide justification for this more restrictive chance.
3.10.6-7 M2 ITS SRs ITS SRs 3.10.6.2 and 3.10.6.3 are Provide justification 3.10.6.2 added to verify that all control for adding these rods in core cells containing one surveiltance and 3.10.6.3 or more fuel assenblies are fully requirements.
inserted every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and fuel assemblies are loaded in compliance with an approved spiral reload sequence. The discussion does not provide justification for this more i restrictive chance.
l _
BFN~ITS 3.10.6 HULTIPLE CONTROL ROD WITHDRMAL - REFUELING .
ITEM #- 00C# CTS /STS Description of Issue COMMENTS or LCO.
JFD#
3.10.6-8 LA1 CTS CTS 4.10.A.7 requires two lit.ensed Provide specifics to 4.10.A.7 operators verify that fuel is. support the removed from each cell before any justification for number of control rods are moving this withdrawn. ITS SR 3.10.5.1 requirement.
requires verifying the fuel assemblies'are removed from the core cells associated with each control rod or CRD removed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> but does not specify two licensed operators. The justification states these requirements are moved to the BASES and procedures. The justification does not give the specific procedure and the BASES does not address this requirement.
. . . . . . ~ -_ . .. .
BFN ITS 3.10.6 MULTIPLE CONTROL ROD WIT}0RAWAL - REFUELING .[
ITEM # DOC #- CTS /STS Description of Issue COMMENTS or LCO JFD#
3.10.6-9 L1 CTS CTS 3.10. A.7 recuires. for the Provide justtfication 3.10.A.7 removal or withcrawal of multiple for deleting the control rods during refueling. that requirement to lock the reactor mode switch be locked the reactor mode in the refuel position and all switch in the REFUEL other refueling interlocks position.
uded IT Multiple Control Rod Withdrawal-Refueling. which recuires that the reactor be in Hoce 5 (mode switch in either shutdown or refuel) while the full-in position signal is defeated for multiple control rods that are withdrawn or removed. The discussion does not justify deleting the requirement to lock the reactor mode switch.
. -o BFN ITS 3.10.6 MULTIPLE CONTROL ROD WI!!ORAWAL - REFUELING .
ITEM # 00C# CTS /STS Description of Issue - ~
CortfENTS or LCO JFD#
3.10.6-10 L2 ITS ITS 3.10.6.c provides an exemption Provide justification 3.10.6.c frum ITS 3.9.3 allowing the loading for allowing exemption of fuel when multiple control rods to this requirement.
are withdrawn or removed as long as-the fuel assemblies are inserted' only into cells that have a control rod that is ~ fully inserted and fuel is being loaded in compliance with an approved spiral reload sequence.
CTS 3.10.A.7 does not provide an exemption from requiring all control rods inserted before loading fuel. No justification is given for exempting the requirement to have all control rods inserted.
. - ._m. _ . _ . _ _ _ _ _ _ .
BFN ITS 3.10.7 CONTROL ROD TESTING - OPERATING .
ITEM # 00C# CTS /STS Description of~ Issue COMMENTS or LCO JFD#
3.10.7-1 L1 STS ITS 3.10.7 permits.the suspension of Provide justification 3.10.7 ITS 3.1.6. Rod Pattern Control. for referring to the during control rod testing. Shutdown Startup Test Program Margin demonstrations. and the in ITS 3.10.7.
Startup Test Program. while in MODFS 1 and 2. The CTS does not have similar provisions. Other sections of the ITS do not reference the Startup Test Program since it is completed. Reference to the Startup Test Program is also removed from the BASES.
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