ML20247P215
| ML20247P215 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/19/1998 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18039A358 | List: |
| References | |
| NUDOCS 9805270352 | |
| Download: ML20247P215 (4) | |
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l-Tennessee Valley Authority. Post office Box 2000. Decatur. A!abama 35609 10 CFR 50.90 May 19, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 i
BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE - 362 - IMPROVED TECHNICAL
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SPECIFICATIONS (ITS) SUPPLEMENT 20 - ITS SECTIONS 3.4, 3.5, 3.6, AND 5.0 AND APPLICABILITY OF STANDARD TECHNICAL SPECIFICATIONS (STS) BASES RELATED TO PERFORMANCE OF CONTAINMENT ATMOSPH2RIC MONITORING (CAM) CHANNEL FUNCTIONAL TESTS (CFT)
J This letter provides supplemental information in support of the TS-362 amendment request relatirq to the four subject ITS l
sections.
TS-362 is TVA's conversion package from Current Technical Specifications (CTS) to ITS and was originally submitted to NRC on September 6, 1996.
The change to the Figure in Section 3.4 originated from internal TVA reviews.
The change to Section 3.5.2 is based on comments provided by the NRC ITS Section 3.5 reviewer in a teleconference on April 30, 1998.
In Section 3.6, a Bases change to Section 3.6.1.3 was made and one Justification for Change (DOC) in Section 3.6.4.3 was recategorized based on NRC reviewer comments.
Also, one TVA clarification change to a DOC in 3.6.4.3 is included.
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'The change to Section 5.3.1 was prompted by NRC comments on TS-372 which1is e parallel change to the Administrative Controls Section of CTS which was originally submitted on P
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9" 2-1-( LU.S..(Ndelear Regulatory, Commission Page 27 May 19, 1998: y Junei6, 1996. The change.to Section:5.6.4 is based on comments provided bysthe~NRC ITS Section 5.0 reviewer in a teleconference on May-7,-1998. The remaining change.is in Section-5.5;7 and originates from~TVA internal review comments. A separate Enclosure is provided'for each affected ITS Section with the revised Bas"s,. detailed DOCS, and mark-ups as' applicable. The enclosed' supplemental information does not alter the determination that there are no significant hazards considerations associated with the proposed changes and the ' determination that the: changes. qualify for a categorical exclusion from' environmental review pursuant to the provisions of '10 CER 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. 'This' letter also serves to document BFN's position related to of the application of the Bases for BFN ITS Surveillance -Requirement -(SR) 3.4.5.2, which is the monthly CFT for the ,Drywell. CAM system instrumentation. Specifically, the Bases for'this SR state, "The test'also verifies the alarm setpoint Jand~ relative accuracy _of the instrument string." This wording 'is the same as the corresponding STS Bases. During internal TVA reviews'of the ITS, it was noted that the " relative accuracy" language in-this SR Bases could be read as requiring a calibration of the instrumentation rather than simply _a CFT. After reviewing this issue, the TVA position is as follows. The subject SR is a CFT which ITS Section 1.0 defines as "A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor.as practicable to verify OPERABILITY, including , required' alarm, interlock, display, trip functions, and channelifailure trips." Clearly, this ITS definition does not-infer calibration requirements. Additionally, the existing Surveillance Instruction for the drywell CAMS' Functional Test in CTS states; "This l instruction simulates high radiation signal by injecting a . signal using calibrated Measuring and Test Equipment." g-The injection of a signal of known value into the channel F will! verify.that alarms occur between two known values and,.thus, the alarm setpoints are verified. Also, since ~ the input signal'is known.and the alarms occur between b. g
I U.S. Nuclear Regulatory Commission l Page 3 l May 19, 1998 1 known values, this verifies the relative accuracy of the excluding the detector). The effects instrument string s of not including the detector in the ITS CFf on the relative accuracy of the instrument string should be minimal since radiation detectors do not change efficiency rapidly, but rather show a gradual loss of output based on input. If there is a failure of the detector, it would be indicated by a downscale alarm. i TVA discussed this matter with the NRC which concurred that the BEN ITS SR Bases provisions as proposed (which retain STS verbiage) do not imply that a calibration type test is required to satisfy ITS SR 3.4.5.2. Therefore, TVA does not plan to propose changes to these Bases and the drywell CAM CFT will continue to be performed in the manner described above. There are no commitments contained in this letter. If you have any questions, please contact me at (205) 729-2636. S peerel i. s V T. E, ney Manager of Lic'isit g and Industr Afftirs Subscribed and kliy efore me on this \\ 9th day of g4 1998. G>ua W Notary Public My Commission Expires N *** "' W h *d Enclosure cc: see page 4 1 m__.______
l -U.S. Nuclear Regulatory Commission Page 4 May 19, 1998 Enclosure-cc (Enclosure): Chairman Limestone County Commission 310 West Washington Street-Athens, Alabama 35611 i Mr. A. W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 H. 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}}