NUREG-1433, Discusses 960906 TVA Submittal Application to Amend Operating Licenses for Plants.Amend Proposes to Convert BFN Current TS to Improve TS Based Upon ISTS Format Given in NUREG-1433.NRC Staff Concluded Submittal Inadequate

Discusses 960906 TVA Submittal Application to Amend Operating Licenses for Plants.Amend Proposes to Convert BFN Current TS to Improve TS Based Upon ISTS Format Given in NUREG-1433.NRC Staff Concluded Submittal Inadequate

ML20138L763
Person / Time
Site:	Browns Ferry
Issue date:	02/20/1997
From:	Williams J NRC (Affiliation Not Assigned)
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
RTR-NUREG-1433 TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9702250063
Download: ML20138L763 (6)

Text

.

u O

[p+Mo k UNITED STATES g j 2

NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20565-0001

\..m/ February 20, 1997 Mr. Oliver D. Kingsley, Jr.

President, TVA Nuclear and Chief Nuclear Officer Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - STAFF COMMENTS ON APPLICATION FOR CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432 AND M96433) (TS 362)

Dear Mr. Kingsley:

On September 6,1996, the Tennessee Valley Authority (TVA) submitted an application to amend the operating licenses for the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3. This amendment request proposes to convert the BFN current technical specifications (CTS) to improved technical specifications (ITS) based upon the improved standard technical specification (ISTS) format, given in NUREG-1433. Based on initial review of TVA's submittal, the NRC staff has concluded the submittal is inadequate, and that TVA will need to submit revised information so that the staff can complete its review. The deficiencies are discussed below, with more details provided in the enclosure.

Please note that the deficiencies identified in this letter are not the result of a complete staff review of your submittal, and may not represent a comprchensive description of problems. Therefore, merely addressing the examples noted will not resolve our fundamental concerns. It is very important that TVA conduct a thorough review of its submittal to identify any other areas which may require revision to support timely staff review.

The NRC staff, with the assistance of its contractor, the Idaho National Engineering and Environmental Laboratory, has determined that the Discussions of Changes (DOCS) given in TVA's ISTS conversion submittal are generally inadequate. The information provided in the submittal does not meet the standards established by NEI 96-06, " Improved Technical Specifications Conversior. Guidance," issued in August 1996. In Administrative Letter (AL) 96-04, " Efficient Adoption of Improved Standard Technical Specifications,"

October 9, 1996, the staff noted that NEI 96-06 provides useful information which may improve the efficiency of the ITS conversion process. Additional guidance on ITS conversion applications was provided by the staff in a letter dated December 13, 1996 from Christopher Grimes, Chief of the Technical Specifications Branch, to James Davis of the Nuclear Energy Institute. These documents reflect lessons learned in the course of staff review of the initial ITS conversion submittals, and provide a framework to permit timely and thorough staff review of submittals without the extensive interaction between the staff and licensees which was characteristic of the pilot conversions. 4} 0 2sooo3NRC FH CENTER COPY 9702250063 970220 PDR ADOCK 05000259

}i P PDR

.t Mr. O. D. Kingsley The staff also notes that, frequently, your DOCS rely upon the similarity between the proposed ITS and NUREG-1433 as justification for changes. Such a i justification is not acceptable, because it does not address why the NUREG-1433 content is appropriate for your facility. Therefore, TVA should review the DOCS in its September 6,1996 submittal, and determine what changes should be made to ensure adequate justificati5n is provided.

The staff.has also been working with the various reactor owners groups to review Technical Specification Task Force (TSTF) items, which represent proposed changes to the ISTS content. The staff is also aware that TVA has identified additional changes which it believes are desirable for incorporation in the ITS conversion. Therefore, the staff requests that TVA provide information describing which TSTF items it has incorporated into the ITS conversion submittal and any other items it believes should be revised.

This discussion should include adequate justification for any changes from the  !

CTS.

l I have previously discussed many of these topics with members of your staff.

Based on those discussions, preparations are underway to conduct a meeting to review the staff concerns and TVA's proposed response. Based on the results l of that meeting, it is our expectation that TVA will revise or supplement the  !

BFN ITS conversion submittal prior to the staff continuing review of your application.

Please call me at (301)415-1470 if you have any questions regarding this topic.

l Sincerely, Original sicrM by Joseph F. Williams, Project Manager Project Directorate II-3 1 Division of Reactor Projects - I/II j Office of Nuclear. Reactor Regulation j l

Docket No. 50-259, 50-260 and 50-296 .

Enclosure:

Comments of Application .

cc w/ enclosure: See next page i Distribution Docket File PUBLIC . BFN Rdg. CSchulten SVarga JZwq)inski OGC, "NGilles- ,

ACRS JJohnson, RII MWeston ETomlinson DOCUMENT NAME: G:\BFN\M96431.JFW *see prior concurrence-T: seceive a copy of this document. Insheete in the bes: *C" = Copy without attachment / enclosure ' *E' = Copy with attachn ent/ enclosure "N" = No copy OFFICE DRPE M- PD!l*3/LA _a . lR [ TCSB lE PDil-2/PM //1_ l g. PDil*3/D lE NAME RClark* 8Clayton /fM CGrimes* JWilliams /F FHebdon*

i DATE C2/19/97 02/nt)/97 02/20/97- 02/ 2et /97 02/20/97 0FFICIAL RECORD COPY 4

Mr. Oliver D. Kingsley, Jr. BROWNS FERRY NUCLEAR PLANT

? Tennessee Valley Authority cc:

Mr. O. J. Zeringue, Sr. Vice President Regional Administrator Nuclear Operations U.S. Nuclear Regulatory Commission Tennessee Valley Authority Region II 6A Lookout Place 101 Marietta Street, NW., Suite 2900 1101 Market Street Atlanta, GA 30323 Chattanooga, TN 37402-2801 Mr. Michael J. Morgan Hr. Mark 0. Medford, Vice President Senior Resident Inspector Engineering & Technical Services Browns Ferry Nuclear Plant Tennessee Valley Authority U.S. Nuclear Regulatory Commission 6A Lookout Place 10833 Shaw Road 1101 Market Street Athens, AL 35611 Chattanooga, TN' 37402-2801 Chairman Mr. R. D. Machon, Site Vice President Limestone County Commission Browns Ferry Nuclear Plant 310 West Washington Street Tennessee Valley Authority Athens, AL 35611 P.O. Box 2000 Decatur, AL 35609 State Health Officer Alabama Department of Public Health General Counsel 434 Monroe Street Tennessee '/ alley Authority Montgomery, AL 36130-1701 ET 10H 400 West Summit Hill Drive Knoxville, TN 37902 Mr. Raul R. Baron, General Manager Nuclear Assurance and Licensing Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Eugene Preston, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority l P.O. Box 2000 i Decatur, AL 35609 l Mr. Pedro Salas, Manager Licensing and Industry Affairs Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 NRC STAFF COMENTS ON IMPROVED STANDARD TECHNICAL SPECIFICATIONS SUBMITTAL OF SEPTEMBER 6, 1996 ,

l The NRC staff and its contractor, the Idaho National Engineering Laboratory (INEL), have identified substantial deficiencies with the proposed conversion of the Browns Ferry Nuclear Plant (BFN) technical specifications to the i improved standard technical specifications format. The comments below summarize the categories of problems identified in the initial NRC and INEL review, but do not represent a comprehensive discussion of problems.

I. Many discussion of changes (DOCS) do not address one or more of the five elements for the staff's evaluation of the proposed changes. The five fl elements are:

- CTS reference ,

- Succinct statement of the CTS requirement I

- ITS reference

- Succinct statement of change

- Justification for the change-This content is consistent with the guidance provided in NEI 96-06,

-" Improved Technical Specifications Conversion Guidance." ,

s. 1 L Differences between the current technical specifications (CTS) and improved technical specifications (ITS) are not always reconciled.

Often, the changes are justified merely on the basis of consistency with NUREG-1433 without a discussion of why the change is appropriate for BFN. ' Consistency with NUREG-1433 may be desirable, but does not, in itself, provide an adequate justification for a change. Further, many new requirements, added consistent with NUREG-1433, are not consistently identified and justified.

3. Some DOCS refer to explanations provided for other changes instead of being discussed on their own merit. For example, many changes in ITS Section'3.3 refer to justifications for other changes.

4. Justifications do not always coincide with the specifications which refer to them. For example, extensive problems wt te identified in Section 3.8, where some justifications refer to specifications which do not exist,-or are not relevant to the topic of the justification.

2

5. Changes are often addressed by a generic justification which does not adequately address all the changes.

6. Changes which are classified as administrative include more or less restrictive components which are not addressed by the D0C. In Section 3.8, proposed ITS Condition I appears to be a less restrictive change rather than an administrative change. The classification and justification should be changed, accordingly.

7. DOC discussions do not usually identify which CTS or ITS requirement is being addressed. As a result, it is difficult to determine whether a CTS or ITS requirement is being addressed.

8. It is not clear where portions of the CTS are addressed in the ITS.

Sometimes, items are not included in the ITS, but no justification is provided for the deletion. This problem is demonstrated by requirements that are marked as incorporated in another limiting condition for operation (LCO), yet the conversion process in that LC0 deletes the requirement. For example, CTS 3.9.C.4 requires one 480-V RMOV board motor-generator (MG) set for each required RMOV board. Neither ITS 3.8.8 nor ITS 3.5.2 keep this requirement. Justification presented with ITS 3.5.2 does not provide enough technical details nor discuss how an inoperable MG set results in declaring the low pressure coolant injection subsystem inoperable. These LCOs cannot be reviewed independently and must be consistent.

9. DOCS occasionally reference documents as part of a justification, without any indication of whether the documents have been reviewed by the NRC for use at Browns Ferry.

10. DOCS sometimes justify new ITS requirements as being consistent with .

existing plant practice. Such a justification alone does not provide a i sufficient basis for the new license requirements.

11. Insufficient justification is provided for some more restrictive and many less restrictive changes. Examples include:

Almost all of the CTS relative to offsite power are being moved to the ITS Bases. DOC LA.1 of section 3.8 does not provide an adequate justification for why this change is acceptable. In particular, the DOC does not address why the material was initially included in the CTS, nor why such things as the constraints associated with specific offsite circuits can be removed to the Bases. In addition, the proposed ITS Bases do not provide any insight regarding these concerns.

The CTS appear to require demonstrating that the appropriate diesel generators (DGs) will start on an accident signal in any unit. This requirement is not captured in the proposed ITS, and the DOC does not adequately address why this CTS requirement is not carried over to the ITS.

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

4 i .

3 More restrictive requirements for a flow rate test of the core spray

system (ITS 3.5.2), and for fuel oil particulate testing

(ITS 5.5.9.b)

No justification is provided for relocation of requirements into

! procedures.

Justifification for proposed functions 3 and 4 of ITS 3.3.7.1-1 i states that these functions have only one trip system. This statement seems inconsistent with CTS Table 3.2-A, Note 15, which

states each function is composed of two divisional trip systems.

ITS 3.6.1.6 provides less restrictive vacuum breaker requirements without justification.

ITS 3.7.2.3 provides new emergency equipment cooling water (EECW) pump surveillance requirements without justification.

i Surveillance frequency changes are proposed without justification.

t >

Differences in CTS and ITS requirements for diesel generator testing

! are not addressed.

! 12. DOCS are not always consistent with one another. For example, CTS 3.5.C.1. and 3.5.C.2 specify Actions based on RHRSW pump operability.

STS 3.7.1 and 3.7.2 specify separate Actions for the RHRSW (or EECW) i pumps and RHRSW (or EECW) subsystems. The ITS deletes the separate

! Actions for the pumps and references pumps with the Actions for the RHRSW (or EECW) pumps and RHRSW (or EECW) subsystems. The ITS deletes the separate' Actions for the pumps and references pumps with the Actions for the RHRSW subsystems in Action A and then defaults to only reference the RHRSW subsystems in the other Action statements. The facility justified the change because of loop redundancy. The wording.is inconsistent whether pumps or loops are referenced.

An additional example is given by ITS 3.8.4.1, which adds acceptance criteria of battery terminal voltage greater than 248 Y for Unit and Shutdown Board battery and greater than 124 V for each DG battery on float charge. The 248 V and greater than 124 V limits are not justified. Additionally, ITS 3.8.4.5 verifies the required battery chargers, the Shutdown Board battery chargers and greater than 105 V for the DG battery chargers. The voltage specified in ITS 3.8.4.5 will not successfully charge a battery to the voltage requirements of ITS 3.8.4.1 (greater than 248 V.for each Unit and Shutdown Board Battery and greater than 124 V for each DG battery on float charge). Therefore, ITS 3.8.4.5 does not successfully demonstrate the capacity of the battery chargers at the battery design voltage.