ML20247G088

Provides Rev 2 to Section 3.3, Instrumentation, in Support of TS-362 Amend Request.Position on Testing of Analog Trip Type Instruments W/Regard to Transition from CTS to ITS, Restated.Summary Description of Its/Bases Changes,Encl

ML20247G088
Person / Time
Site:	Browns Ferry, Oconee
Issue date:	05/14/1998
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A338	List: ML20247G088
References
NUDOCS 9805200134
Download: ML20247G088 (9)

Text

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l Tennessee Vaney Authority. Post Off:ce Box 2000. Decatur. Alabama 35609 May 14, 1998 10 CFR 50.90 U.S. Nuclear Regalatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) E0-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE - 362 - IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUPPLEMENT 19 - ITS SECTION 3.3 AND CLARIFICATION OF ITS PROVISIONS REGARDING ANALOG TRIP TESTING The Enclosure to this letter provides supplemental information in support of the TS-362 amendment request relating to Section 3.3, Instrumentation. TS-362 is TVA's conversion package from Current Technical Specifications (CTS) to ITS and was originally submitted to NRC on September 6, 1996. This supplement provides Revision 2 to Section 3.3. Revision 1 to Section 3.3 was submitted to the NRC on December 29, 1997.

This supplement makes several ITS/ITS Bases revisions and changes to supporting documentation in response to NRC comments provided in meetings on March 26, 1998, and April 14, 1998,.on Section 3.3 and in a follow-up teleconference on April 15, 1998. Several TVA initiated changes are also included as identified in the Enclosure.

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. U.S. Nucl' ear Regulatory Commission Page 2 Phy 14, 1998 The enclosed supplemental information does not alter the determination that the changes qualify ~for a categorical exclusion from environmental review pursuant to.the provisions of 10 CFR 51.22 (c) (9) . Additionally, in accordance with 10 CFR 50.91 (b) (1), TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health.

TVA wauld also like to'use this letter to restate our position on testing of analog trip type instruments with

. regard.to the transition from CTS to ITS. Specifically, in l

CTS there are several notes that apply to specification requirements for instrumentation for analog trip type devices that explicitly specify that a Channel Functional Test (CFT) consists of injection of a simulated signal into the electronic trip circuitry'or measurement channel in place of a system signal sensor to test the trip and alarm functions of the system. Examples of these are Note 7 to Table 4.1.A, Note 27 to Tables 4.2.A through 4.2.L, and footnote (1) to Table 4.7.A. These CTS notes are not being carried forth in

' the' proposed'BFN'ITS.

TVA's position is that the definition of CFT in Section 1.1 of the ITS' explicitly allows testing in the'same manner as CTS (use of a' simulated signal) and, hence, it is not necessary to incorporate the CTS notes in ITS. _

This issue was discussed with NRC staff to ensure that it was understood that'under ITS,~ testing.of analog trip type devices would continue in the same manner as currently employed under CTS and that ITS provisions were consistent with this approach.

NRC indicated that'it was accepted practice to perform analog trip-system testing in this manner and that the BFN ITS provisions supported this methodology.

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U.S. Nuclear Regulatory Commission Page 3 May 14, 1998 There are no commitments contained in this letter. If you have any questions, please contact me at (256) 729-2636.

Si/ cerely, j T. E. Abney Manager of Lice oing and Industry ffai s Subscribed and sw n o before me on is 14th day May iggg, C

Notary Public dd/d k t /4/ O My Commission expires -% CC'"'" W @ ** I E " {

l Enclosure cc: see page 4 l

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U.S. Nuclear Regulatory Commission Page 4 May 14, 1998 Enclosure cc (Enclosure) :

Chairman Limestone County Commission 310 West Washington Street Athens, Alabama 35611 Mr. A. W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Harold O. Christensen, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street, S.W.

Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Dr. Donald E. Williamson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017 I

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SUMMARY

DESCRIPTION of ITS/ BASES CHANGES ITS SECTION 3.3 - INSTRUMENTATION TVA is submitting a proposed supplement to TS-362 for ITS Section 3.3, INSTRUMENTATION. This supplement makes several changes associated with NRC comments on Section 3.3, and incorporates changes resulting from internal TVA reviews. A synopsis of the ITS and ITS BASES changes is provided below. i l

SECTION 3.3.1.1, RPS INSTRUMENTATION SURVEILLANCE REQUIREMENTS AND CORRESPONDING BASES In response to TVA reviews, changed frequency on SR j 3.3.1.1.7 from 1000 effective full power hours to 1000 MWD /T I average core exposure to be consistent with NUREG-1433.

TABLE 3.3.1.1-1 AND CORRESPONDING SAFETY ANALYSIS, LCO, AND APPLICABILITY BASES )

i In response to TVA reviews, deleted applicability of MODE l 5and associated SR FUNCTIONS 2.a, Average Power Range l Monitors Neutron Flux - High Setdown, and 2.e, Average Power  !

Range Monitors Neutron Inop. This change is made to be l

consistent with NUREG-1433. l BASES, BACKGROUND In response to TVA reviews, made editorial changes to agree with previously submitted NUREG mark-up.

BASES, ACTIONS In response to an NRC comment, clarified details for Function C.1 to better define when Functions lose trip capability due to multiple inoperable /untripped channels.

SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION TABLE 3.3.2.1-1 AND CORRESPONDING APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY BASES In response to TVA reviews, changed footnotes (a) and (b)

Minimum Critical Power Ratio (MCPR) values to agree with TS change 35351 and Amendment No. 249.

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SUMMARY

DESCRIPTION ofITS/ BASES CHANGES j l

l ITS SECTION 3.3 - INSTRUMENTATION l SECTION 3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP l l

INSTRUMENTATION SURVEILLANCE REQUIREMENTS In response to internal TVA reviews, changed Allowable Value for SR 3.3.2.2.3 from 588 inches above vessel zero to 586 I inches above vessel zero to agree with change previously made to the NUREG mark-up.

SECTION 3.3.3.1, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION SURVEILLANCE REQUIREMENTS In response to an NRC comment, made editorial changes to be  ;

consistent with NUREG format. '

SECTION 3.3.3.2, BACKUP CONTROL SYSTEM SURVEILLANCE REQUIREMENTS AND CORRESPONDING BASES In response to internal TVA reviews, modified SR 3.3.3.2.2 calibration frequency for Unit 3 to agree with engineering analysis.

BASES, TABLE B 3.3.3.2-1 In response to internal TVA reviews, modified Table 3.3.3.2-1 (Backup Control System Instrumentation and Controls) to delete extraneous note from Unit 1 and 2 tables, and deleted from the Unit 3 table the required number of components for parameter 9.

SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT)

INSTRUMENTATION SURVEILLANCE REQUIREMENTS In response to internal TVA reviews, changed 2 10% to s 10%

for turbine stcp valve closure allowable value to agree with plant design.

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SUMMARY

DESCRIPTION ofITS/ BASES CHANGES ITS SECTION 3.3 - INSTRUMENTATION  :

SECTION 3.3.4.2, ANTICIPATED TRANSIENT WITHOUT SCRAM

{ CIRCULATION PUMP TRIP (ATWS-RPT) INSTRUMENTATION l LCO In response to an NRC comment, changed water level nomenclature to be consistent other parts of the ITS.

l SURVEILLANCE REQUIREMENTS In response to an NRC comment, modified SR 3.3.4.2.1 water level nomenclature for consistency.

BASES, BACKGROUND, APPLICABLE SAFETY ANALYSES, LCO, AND APPLICABILITY In response to an NRC comment, changed water level nomenclature to be consistent with other parts of the ITS.

I SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM (ECCS)

INSTRUMENTATION ACTIONS AND CORRESPONDING BASES In response to an NRC comment, revised Completion Time descriptive information for Required Actions B.1, C .1, and  ;

E.1 to be more consistent with NUREG terminology. j BACKGROUND, APPLICABLE SAFETY ANALYSES, LCO, APPLICABILITY, j AND ACTIONS BASES In response to internal TVA reviews, made editorial changes to agree with changes made in the previously submitted 1."J.'1EG mark-up and added clarification regarding the effect of the minimum flow bypass valve on High Pressure Coolant Injection System operation.

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SUMMARY

DESCRIPTION ofITS/ BASES CHANGES l ITS SECTION 3.3 - INSTRUMENTATION SECTION 3.3.6.1, PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION ACTIONS AND CORRESPONDING BASES In response to an NRC comment, revised the Required Actions.

Note A.1 was revised to more clearly delineate the applicability (changed "15 of 16 Channels OPERABLE" to "two or more Channels inoperable"). Required Action D.1 was )

changed from " Isolate the affected penetration flow path (s)"

to original NUREG text, " Isolate associated Main Steam Line (MSL)". Deleted Required Action G.1 and associated Note  !

because Action was redundant to Actions in ITS Section 3.6.1.3, " Primary Containment Isolation Valves".

TABLE 3.3.6.1-1 In response to internal TVA reviews, corrected Functions 2.a and 2.b "Cenditions Referenced" from H to G in the NUREG mark-up to agree with changes previously made in identification of Required Actions.

In response to internal TVA reviews, changed Functions 3.a and 4.a " Allowable Value" from 150% rated steam flow for each function to 90 psi for Function 3.a and 450" H O for 2

Function 4.a to match corresponding CTS numeric values and supporting analysis.

In response to an NRC comment, revised footnote b to more closely match the NUREG text.

SECTION 3.3.6.2, SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION SURVEILLANCE REQUIREMENTS In response to an NRC comment, revised Note 3 to clarify that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Allowed Outage Time (AOT) is applicable only for channel calibration or maintenance.

SECTION 3.3.7.1,~ CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM INSTRUMENTATION ACTIONS In response to an NRC comment, revised the Required Actions and Completion Time description for D.1 and D.2 to be consistent with the NUREG.

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DESCRIPTION ofITS/ BASES CHANGES l ITS SECTION 3.3 - INSTRUMENTATION l SURVEILLANCE REQUIREMENTS AND CORRESPONDING BASES In response to an NRC comment, revised Note 3 to clarify that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT is applicable only for channel calibration or maintenance.

SECTION 3.3.8.1, LOSS OF POWER (LOP) INSTRUMENTATION ACTIONS AND CORRESPONDING BASES In response to NRC comments, changed the terminology from the relay logic being a channel to a relay being a channel.

Revised Required Actions A.1, A.2, B .1, B.2, C.1, C.2, D.1 and D.2 to accommodate the changing of relays to channels.

TABLE 3.3.8.1-1 In response to NRC comments, revised the number of required channels per board for the LOP Functions.

BACKGROUND, APDLICABLE SAFETY ANALYSES, LCO, AND l

APPLICABILITY BASES I l

1 In response to NRC comments, changed the terminology from  !

the relay logic being a channel to a relay being a channel.

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