ML18039A196

Provides Suppl Info in Support of TS-362 Amend Request Re Section 5.0,Administrative Controls.Suppl Makes Several Improved TS Revs & Changes to Supporting Documentation Re NRC Questions.W/List of Revised Improved TS Pages

ML18039A196
Person / Time
Site:	Browns Ferry
Issue date:	12/03/1997
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A197	List: ML18039A196 ML18039A198
References
TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9712080169
Download: ML18039A196 (19)

Text

qy@nW~69 ITS SECTION 5.2 ORGANIZATION Description of Issue 5.2-1 NRC Comments TVA Response The term"health physics" in CTS 6.2.1d and 6.2.2e is changed to"radiological controls" in ITS 5.2.1d and 5.2.2d with no justification for the change from the CTS"health physics." The term"health physics" in STS 5.2.1d and 5.2.2d is changed to"radiological controls" in ITS 5.2.1d and 5.2.2d.JD P3 states that this is because it is the current licensing basis, but CTS 6.2.1d and 6.2.2e use the term"health h sics." The material is contradicto Provide further justification for using the term"radiological controls" instead of"health h sics." TVA has substituted the term radiological controls in Improved Technical Specifications ITS)for the term"health physics" used in the STS because the associated function and organization is known at Browns Ferry as radiological controls.This change is consistent with the Tennessee Valley Authority Topical Report, TVA-NPOD89-A, Nuclear Power Organization Description, referenced in UFSAR section 13.2.4 for the onsite or anization.

Description of Issue 5.2-2 NRC Comments TVA Response The bracketed STS 5.2.2a requirements for the number of non-licensed operators at a two-unit station when both units are shutdown is deleted in the conversion to ITS 5.2.2a with no discussion of its a licabilit to the Browns Fe's three-unit site.Provide a discussion of the applicability of the STS bracketed information for BFN.AAer further review, TVA has incorporated the bracketed requirements, modifying it slightly to reflect the fact that Browns Ferry has three units.The proposed change is less restrictive than CTS Table 6.2.A.A new DOC L1 has been added to address this chan e.Description of Issue 5.2-3 NRC Comments TVA Response CTS 6.2.2d requires two licensed reactor operators (RO)and a licensed senior reactor operator (SRO)in the control room when in MODE 1, 2, or 3.ITS 5.2.2b requires at least one RO and one SRO in the control room when in MODE 1, 2, or 3.Deleting the second re uired RO is not ustified and is a less restrictive chan e.Provide discussion and'ustification for this less restrictive chan e TVA agrees with the comment.A justification for this less restrictive re uirement OC L2 has been added.

ITS SECTION 5.2 ORGANIZATION Description of Issue 5.2-4 NRC Comments TVA Response I CTS Table 6.2.A Note b allows a shift crew composition of one less than specified for a time not to exceed two hours.ITS 5.2.2c does not limit the short complement to one, a less restrictive change.Though consistent with the STS, this less restrictive change has not been'ustified.

Provide discussion and'ustification for this less restrictive chan e.TVA agrees with this comment.A justification for this less restrictive re uirement OC L3 has been added.Description of Issue 5.2-5 NRC Comments TVA Response CTS Table 6.2.A Note b does not permit any shift crew position to be unmanned upon shiR change due to an oncoming shift crewman being late or absent.ITS 5.2 does not retain this requirement, a less restrictive removal of requirements that is not specifically discussed or'ustified in LAl.Provide discussion and justification.

for this less restrictive removal of re uirement.A specific less restrictive requirement (DOC L4)justification has been added to address this comment.

ITS SECTION 5.4 PROCEDURES Description of Issue 5.4-1 NRC Comments TVA Response CTS 6.8.2 requires annual drills for a)emergency conditions involving release of radioactivity and b)failures of safety-related systems or components.

The justification states these requirements are im lemented b the Radiolo ical Emer enc Plan.Does the Radiological Emergency Plan implement an annual drill for failures of safety-related systems or components?

Provide additional justification for this less restrictive removal of requirements, verifying where the requirement for an annual drill for failures of safety-related s stems or corn onents will beim lemented.DOC LA2 has been revised to provide additional justification to address the issues in this NRC comment.

ITS SECTION 5.5 PROGRAMS AND MANUALS Description of Issue 5.5-1 NRC Comments TVA Response CTS 6.8.4g.1 limits the noble gas dose rate to less than or equal to 3000 mrem/yr to the skin.ITS 5.5.4.g.1 includes the 3000 mrem/yr limit without the modifier'~.'his change appears to be an omission.Add the modifier'~'o the ITS 5.5.4.g.1 3000 mrem/yr limit The modifier K has been added to the 3000 mrem/yr limit in ITS 5.5.4..1.Description of Issue 5.5-2 NRC Comments TVA Response CTS 4.7.B.1 requires demonstrating acceptable pressure drop for the combined HEPA filters and charcoal adsorber banks of the standby gas treatment system and testing the inlet heaters"at least once per year." ITS 5.5.7 establishes the required testing"at least once per 18 months." This extension of the surveillance test interval is not'ustified as a less restrictive chan e.Provide ustification for this less restrictive chan e.A justification for this less restrictive change has been included (DOC L3.Description of Issue 5.5-3 NRC Comments TVA Response CTS 4.7.B.1c requires demonstrating the air distribution across the standby gas treatment system HEPA filters and charcoal adsorbers is uniform within 20%.This requirement is not transferred to ITS 5.5.7 but is moved to the Technical Requirements Manual.No justification was provided for this change in DOC LAl.DOC LA1 simply rovides a ve brief descri tion of some of the chan es it covers.Provide a justification specific to this less restrictive moving of a re uirement.The requirement contained in CTS 4.7.B.1c will be deleted.A'ustification for this deletion has been included DOC L2.Description of Issue 5.5-4 NRC Comments TVA Response CTS 3.8.A.6 requires suspending additions of radioactive waste if the specified limits are exceeded, reducing the activity in the tank to within limit, and reporting the occurrence in the next annual Radioactive Efnuents Release Report.These requirements are not transferred to ITS 5.5.8 but are moved to the Technical Requirements Manual.No justification was provided for this change in DOC LA1.DOC LA1 simply provides a very brief description of some of the chan es it covers.Provide a justification specific to this less restrictive moving of a re uirement.The previously submitted justification (DOC 5.5 LA1)has been revised to rovide additional detail.

ITS SECTION 5.5 PROGRAMS AND MANUALS Description of Issue 5.5-5 NRC Comments TVA Response CTS 4.8.A.6 requires analyzing samples of the contents of any outside liquid radwaste storage tanks at least once per 7 days when there are additions to the tank.These specific requirements are not transferred to ITS 5.5.8.Rather, ITS 5.5.8 contains general requirements for a surveillance program for verifying the quantity of radioactivity contained in outdoor liquid radwaste tanks.Deleting the s ecific re uirements in CTS 4.8.A.6 was not'ustified.

Provide a'ustification for deletin this re uirement The specific requirements contained in CTS 4.8.A.6 will be relocated to the Technical Requirements Manual (TRM).The previously submitted justification (DOC LA1)has been revised to reflect this relocation.

Description of Issue 5.5-6 NRC Comments TVA Response STS 5.5.10a requires testing new diesel fuel oil before adding it to storage tanks.ITS 5.5.9 does not contain this requirement although the justification in P 1 1 states that the fuel oil is tested before adding it to the 7 da tanks.For standardization and consistency, the staF would prefer to see the STS requirements retained in the Browns Ferry ITS.What is the impediment to including these requirements in the ITS, if the testing is alread bein done?Adoption of the STS provisions would result in a considerable increase in testing requirements for diesel fuel oil, which based on plant experience with existing TS requirements and testing, would not produce a significant increase in assurance of fuel oil quality.Further detail is provided below.CTS 4.9.A.l.e requires a quarterly test of the fuel oil for the emergency diesel generator 7-day tanks to verify compliance with ASTM-D-975-1989.

BFN has eight EDGs each of which has a 7-day tank.Each EDG directly draws fuel from a day tank which is integral with the EDG skid.When the oil level in any of the day tanks falls below a predetermined setpoint, oil is automatically transferred from the associated 7-day tank to the appropriate day tank.When the level in the 7-day tank falls below a predetermined limit, oil is manually transferred from Fuel Oil Storage Tank¹2 to the appropriate 7-day tank.As noted in Pl 1, the oil in Fuel Oil Storage Tank¹2 is verified to meet ASTM-D-975-1989 prior to storage in the tank.Hence, the make-up source for the 7-day tanks is tested for ualit.

ITS SECTION 5.5 PROGRAMS AND MAIAJALS TVA Response 5.5-6 continued STS 5.5.10 would require that a reduced scope test of the 7-day tank fuel oil be performed on a monthly basis.Therefore, STS provisions, if implemented, would significantly increase the oil testing requirements over the quarterly testing required by CTS.Operating experieace with the CTS quarterly sampling of each of the 7-day tanks as augmented by the testing of the 82 oil tank indicates that the current oil testing program maintains acceptable fuel quality for the EDGs.More fi'equent testing in accordance with STS provisions would require a considerable increase in resources with no obvious expected improvement in terms of increased assuraace of oil quality.Based on these consideratioas, BFN considers that retention of the CTS fuel oil testing requirements as proposed in the ITS is a ro riate.Description of Issue 5.5-7 NRC Comments TVA Response STS 5.5.4.b has been modified in ITS 5.5.4.b to adopt the CTS which includes changes to conform to the latest 10 CFR Part 20 revision.However, it appears that the transfer of the CTS language was not entirely accurate.CTS 6.8.4.b states,"Limitations oa the concentrations of radioactive material released in liquid efHuents to UNI&STRICTED AREAS conforming to 10 times the concentration values stated in 1D CFR 20.10001-20.2401, Appendix B, Table 2, Column 2." ITS 5.5.4.b states,"Limitations on the concentrations of radioactive material released in liquid eQluents to unrestricted areas, conforming to 10 times the concentration values stated in 10 CFR 20, A endix B Table 2, Column 2." Revise the ITS to retain the correct CTS reference for 10 CFR Part 20.The existing reference to 10 CFR 20 in CTS 6.8.4.b was based on a previous version of 10 CFR 20.The revised reference contained in the submittal is correct for the current version of 10 CFR 20.Therefore, the ITS should aot be changed Rom the original submittal.

DOC A10 has been added to cl this oint.

ITS SECTION 5.5 PROGRAMS AND MANUALS Description of Issue 5.5-8 NRC Comments TVA Response ITS 5.5.7 adds Insert 5.0-11A to the program description of STS 5.5.8 for the VFTP.Most of the additional information in the insert is based on CTS.However, the addition of the reference to Section Sa of Re lato Guide 1.52, Rev.2, is not discussed.

What is the reason for adding the reference to Section 5a, rather than leavin the eneral reference as in the STS?Current licensing basis does not commit Browns Ferry to meet the requirements of Regulatory Guide 1.52.Therefore, all references to Regulatory Guide 1.52 have been removed&om ITS and ITS has been revised to be more consistent with CTS requirements in this area.Refer to the revised ITS pages and accompanying justifications for more detail.Description of Issue 5.5-9 NRC Comments TVA Response ITS 5.5.7.c requires demonstrating that a laboratory test of a sample of charcoal adsorber shows the methyl iodide penetration less than the specified value, at a specified flow rate and relative humidity.The CTS do not appear to contain the restrictions on relative humidi, but no discussion of this chan e was rovided.Provide a justification of this change, stating how the value in the ITS was derived.ARer further review, Browns Ferry has decided to reinstate CTS requirements.

Therefore, ITS 5.5.7.c has been revised to delete the specification on relative humidity.It simply requires the sample to be tested in accordance with ASTM D3803-19&9.

Description of Issue 5.5-10 NRC Comments STS 5.5.2a and b requires a Primary Coolant Sources Outside Containment program with preventive maintenance and leak test requirements.

ITS 5.5.2 implements this program, however, ITS, 5.5.2a does not contain the preventive maintenance requirements and ITS 5.5.2b adds a restriction on the leak rate testing"to the extent permitted by system design and radiological conditions." The justi6cation states that these changes are consistent with BFN's current ro amsforminimizin leaka e.Provide additional justi6cation for this STS deviation based on system design and operational constraints.

What are your current commitments to the NRC regarding primary coolant sources outside containment?

ITS SECTION 5.5 PROGRAMS AND MANUALS TVA Response 5.5-10 continued Browns Ferry's current commitment for controlling leakage of systems which may contain highly radioactive fluids during a serious transient or accident is contained in UFSAR, Section 6.6, and states,"The CSCS (Core Standby Cooling Systems)piping and components in the Reactor Building are monitored by routine inspections, general housekeeping practices, and system operability testing which maintains system leakage to an as-low-as-possible level.Browns Ferry does not have a specific commitment to have a separate preventive maintenance program for leak reduction, but rather uses the normal program for the ECCS and the leak reduction strategy discussed above.Therefore, the ITS as proposed deviates from the STS to remain consistent with our current methods and commitments.

Additionally, section 5.5.2.b is modified to indicate that system leak rate tests are conducted to the extent permitted by system design and radiological conditions.

Since Browns Ferry CTS do not have equivalent provisions for a leak reduction program, we believe that the ITS should be made more specific in this regard to ensure effective im lementation.

ITS SECTION 5.6 REPORTING REQUIREMENTS Description of Issue 5.6-1 NRC Comments TVA Response CTS 6.9.1.2.b requires annual reporting to the NRC of any main steam relief valve that opens in response to reaching its setpoint or due to operator action to control reactor pressure.The justification neither details why this requirement is in the CTS, states whether this requirement is moved elsewhere (and the attendant controls on the requirement where moved), nor states that the requirement is being deleted entirel.Provide additional justification for this less restrictive removal of requirements, stating what will happen to the requirement when the ITS are im lemented.AAer further review, we have determined that the specific requirements of CTS 6.9.1.2.b can be deleted.A justification (DOC L2 has been added.Description of Issue 5.6-2 NRC Comments TVA Response LA3 states that the source test reporting requirements of CTS 6.9.1.6 are being moved to an unidentified licensee controlled document.No ustification is bein rovided for this chan e.Provide a justification for this less restrictive moving of requirements, identifying the document that will contain this requirement and the corres ondin control mechanism.

The requirements contained in CTS 6.9.1.6 will be relocated to the TRM.The previously submitted justification (DOC LA3)has been revised to reflect this relocation.

Changes to the TRM are controlled in accordance with 10 CFR 50.59.Description of Issue 5.6-3 NRC Comments TVA Response The criteria in the NRC Final Policy Statement and 10 CFR 50.36 do not apply to the Administrative Controls section of technical s ecifications.

The criteria onl a 1 to LCOs.Revise the justifications for these items to describe less restrictive

.changes (movement of requirements).

Identify, specifically, the documents to which these requirements will be moved and the associated control mechanisms.

Justifications (DOC R1-R4)have been revised to address the NRC comment.

ITS SECTION 5.7 HIGH RADIATION AREA Description of Issue 5.7-1 NRC Comments TVA Response CTS 6.8.3.2 provides requirements for"areas that are accessible to personnel and that have radiation levels greater than 1 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." ITS 5.7.2 references"areas that are accessible to personnel and that have radiation levels~1000 mrem/hr." Revise ITS 5.7.2 to change">1000 mrem/hr" to">1000 mrem/hr" to be consistent with CTS.TVA agrees with the NRC comment and has revised ITS 5.7.2 as described in NRC comment 5.7-1 to be consistent with CTS.10

SUMMARY

DESCRIPTION of ITS CHANGES ITS SECTION 5.0 TVA is submitting a proposed supplement to TS-362 for Section 5.0, ADMINISTRATIVE CONTROLS.This supplement makes several changes associated with NRC comments on Section 5.0 (

Reference:

NRC Request for Additional Information Regarding Improved Standard Technical Specifications, dated September 29, 1997, TAC NOS.M96431, M96432, M96433), incorporates changes resulting from internal TVA reviews, and incorporates Owner's Group Technical Specification Task Force (TSTF)items approved by NRC subsequent to the original submittal of TS-362.A synopsis of the ITS changes is provided below.ITS 5.2.1.c The position title for the Chief Nuclear Officer has been updated to incorporate a recent title change.ITS 5.2.2.a The following requirement has been added to incorporate a bracketed requirement from STS in response to an NRC comment,"When all three units are shutdown or defueled, a total of three non-licensed operators shall be assigned for all three units." ITS 5.5.4..1 inserted before the 3000 mrem/yr limit to the skin to bring the requirement into agreement with CTS.This change is also in response to an NRC comment.ITS 5.5.6 Deleted the words,"including applicable supports" based on program owner review.The Inservice Testing Program encompasses pumps and valves, but not supports.ITS 5.5.7 Specified frequencies for each of the Engineered Safety Features (ESF)filter ventilation systems tests and deleted references that do not apply to Browns Ferry licensing basis, based on program owner review.ITS 5.5.7.a Deleted the requirement to perform this test after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of syst: em operation based on program owner review.Justification is provided in DOC L5.'I ITS 5.5.7.b Deleted the requirement to perform this test after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation based on program owner review.Justification is provided in DOC L5.Page 1 e 0

SUMMARY

DESCRIPTION of ITS CHANGES ITS SECTION 5.0 ITS 5.5.7.c Revised the acceptance criteria for laboratory testing of charcoal adsorber for ESF ventilation systems to match CTS requirements based on program owner review and in response to an NRC comment.ITS 5.5.7.d Revised the acceptance criteria from 6 inches of water to 7 inches of water for delta p across the Standby Gas Treatment system combined HEFA filters, prefilters, and charcoal adsorbers based on program owner review.The CTS value (6 inches)did not include the prefilters.

ITS 5.5.9 Added"The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program testing frequencies" to incorporate TSTF-118.ITS 5.6.1 Revised to make reporting requirements consistent with 10 CFR 20 to incorporate TSTF-152.ITS 5.6.3 Revised to make reporting requirements consistent with 10 CFR 20 to incorporate TSTF-152.ITS 5.7.1 Revised to incorporate clarifications of dose rate measurements based on program owner review.This change is consistent with CTS and 10 CFR 20 measurement units.ITS 5.7.2 Changed"~" to">" for area radiation level in response to an NRC comment.Revised to incorporate clarifications of dose rate measurements based on program owner review.ITS 5.7.3 Revised to incorporate clarifications of dose rate measurements based on program owner review.This change is consistent with CTS and 10 CFR 20 measurement units.C: g~DecgmontsgImpraved Tech Specs~Suhcnittal~BXECSUHH.

DOC Page 2

BROWNS FERRY NUCLEAR PLANT-IMPROVED TECHNICAL SPECIFICATIONS SECTION 5.0 LIST OF REVISED PAGES UNIT 1 ITS (Revised pages marked*RI)NOTE: All pages are provided.Replaced 5.0-2 xvith 5.0-2 Revision 1 Replaced 5.0-3 with 5.0-3 Revision 1 Replaced.5.0-4 with 5.04 Revision 1 Replaced 5.0-9 with 5.0-9 Revision I Replaced 5.0-10 with 5.0-10 Revision I Replaced 5.0-11 with 5.0-11 Revision I Replaced 5.0-12 with 5.0-12 Revision I Replaced 5.0-13 with 5.0-13 Revision I Replaced 5.0-14 with 5.0-14 Revision 1 Replaced 5.0-15 with 5.0-15 Revision I Replaced 5.0-16 with 5.0-16 Revision I Replaced 5.0-17 with 5.0-17 Revision 1 Replaced 5.0-18 with 5.0-18 Revision I Replaced 5.0-19 with 5.0-19 Revision I Replaced 5.0-20 with 5.0-20 Revision 1 Replaced 5.0-21 xvith 5.0-21 Revision 1 Replaced 5.0-22 with 5.0-22 Revision I BROWNS FERRY NUCLEAR PLANT-IMPROVED TECHNICAL SPECIFICATIONS SECTION 5.0 LIST OF REVISED PAGES UNIT 2 ITS (Revised pages marked*Rl)NOTE: All pages are provided.Replaced 5.0-2 with 5.0-2 Revision 1 Replaced 5.0-3 with 5.0-3 Revision 1 Replaced 5.0<with 5.04 Revision 1 Replaced 5.0-9 with 5.0-9 Revision 1 Replaced 5.0-10 with 5.0-10 Revision 1 Replaced 5.0-11 with 5.0-11 Revision I Replaced 5.0-12 with 5.0-12 Revision 1 Replaced 5.0-13 with 5.0-13 Revision I Replaced 5.0-14 with 5.0-14 Revision 1 Replaced 5.0-15 with 5.0-15 Revision 1 Replaced 5.0-16 with 5.0-16 Revision I Replaced 5.0-17 with 5.0-17 Revision 1 Replaced 5.0-18 with 5.0-18 Revision 1 Replaced 5.0-19 with 5.0-19 Revision I Replaced 5.0-20 with 5.0-20 Revision I Replaced 5.0-21 with 5.0-21 Revision I Replaced 5.0-22 with 5.0-22 Revision 1

BROWNS FERRY NUCLEAR PLANT-IMPROVED TECHNICAL SPECIFICATIONS SECTION 5.0 LIST OF REVISED PAGES UNIT 3 ITS (Revised pages marked*Rl)NOTE: All pages are provided.Replaced 5.0-2 with 5.0-2 Revision I Replaced.5.0-3 with 5.0-3 Revision 1 Replaced 5.04 with 5.0-4 Revision I Replaced 5.0-9 with 5.0-9 Revision I Replaced 5.0-10 ivith 5.0-10 Revision I Replaced 5.0-11 ivith 5.0-11 Revision I Replaced 5.0-12 with 5.0-12 Revision 1 Replaced 5.0-13 with 5.0-13 Revision 1 Replaced 5.0-14 with 5.0-14 Revision I Replaced 5.0-15 with 5.0-15 Revision I Replaced 5.0-16 with 5.0-16 Revision I Replaced 5.0-17 with 5.0-17 Revision I Replaced 5.0-18 with 5.0-18 Revision 1 Replaced 5.0-19 with 5.0-19 Revision I Replaced 5.0-20 with 5.0-20 Revision I Replaced 5.0-21 with 5.0-21 Revision I Replaced 5.0-22 with 5.0-22 Revision I