ML061040397

Units 1, 2, & 3 - Technical Specifications (TS) Change TS-447 - Follow-up to Second Request for Additional Information (RAI) - Extension of Channel Calibration Surveillance Requirement Performance Frequency & Allowable Value Revision

ML061040397
Person / Time
Site:	Browns Ferry
Issue date:	04/14/2006
From:	Crouch W Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC4070, TAC MC4071, TAC MC4072, TVA-TS-447
Download: ML061040397 (11)

Text

April 14, 2006

TVA-TS-447 10 CFR 50.90 U.S. Nuclear Regulatory Commission

Mail Stop: OFWN P1-35

ATTN: Document Control Desk

Washington, D.C. 20555-0001

Gentlemen:

In the Matter of

) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

TECHNICAL SPECIFICATIONS (TS) CHANGE TS-447 - FOLLOW-UP TO SECOND REQUEST FOR ADDITIONAL INFORMATION (RAI) - EXTENSION OF CHANNEL CALIBRATION SURVEILLANCE REQUIREMENT PERFORMANCE FREQUENCY AND ALLOWABLE VALUE REVISION (TAC NOS. MC4070, MC4071, and MC4072)

On August 16, 2004, TVA submitted a license amendment request (TS-447, ADAMS Accession No. ML04237061) to ext end the calibration surveillance frequency for the high pressure coolant injection (HPCI) system, reactor core

isolation cooling (RCIC) system, and reactor wate r clean-up (RWCU) system high area temperature isolati on instrument channels on BFN Units 1, 2, and 3. On January 10, 2005, NRC informed TVA via letter (ADAMS Accession No.

ML043640556) that additional informati on was required in support of the requested amendments. On March 11, 2005, TVA provided a response (ADAMS Accession Nos. ML050770370 and ML050770379) to this RAI. TVA's response addressed the specific NRC RAI questions, and additionally provided

U.S. Nuclear Regulatory Commission Page 2 April 14, 2006

excerpts from relevant instrument scali ng and setpoint engin eering calculations and a copy of the TVA nuclear program instrument setpoint methodology document.

On August 15, 2005, NRC informed TVA via letter (ADAMS Accession No.

ML052130135) of two additional RAI questions. These questions were answered in TVA's response of November 4, 2005 (ADAMS Accession No. ML053110343).

Subsequently, in a December 5, 2005 telecon, NRC made an additional, verbal request for information. The enclosure to this letter provides the information as requested in the telecon.

This letter provides additional informati on only, and no information in the original submittal nor the previous RAI responses is being revised. The proposed finding of no significant hazards considerati ons and environmental impact consideration as submitted in TVA's August 16, 2004 letter remain valid.

With regard to the instrumentation methodology issues discussed in the March 31, 2005, NRC letter to NEI, whic h provided NRC's position related to resolving Method 3 instrument setpoint methodology issues, as stated in our November 4, 2005, response letter, the instruments affected by TS-447 do not provide a limiting safety system settings (LSSS) function in accordance with 10 CFR 50.36(c)(1)(ii)(A). Therefore, no additional changes are needed to address the March 31, 2005, letter.

Each of the three previous TVA submittals has noted that the current calibration intervals are contrary to good ALARA and industrial safety practices for plant personnel. Therefore, TVA requests NRC approval of TS-447 as soon as possible. TVA also requests that the im plementation of the revised TS be within 60 days of NRC approval.

There are no regulatory commitments associat ed with this submittal. If you have any questions about this change, please contact me at (256)729-2636 or Paul

Heck at (256)729-3624.

Sincerely,

Original signed by:

William D. Crouch Manager, Site Licensing

and Industry Affairs

Enclosures:

1. TS-447 RAI response - December 5, 2005 telecon RAI

2. Instrumentation setpoi nt scaling information table

U.S. Nuclear Regulatory Commission Page 3 April 14, 2006

Enclosures cc (Enclosures):

State Health Officer

Alabama Dept. of Public Health

RSA Tower - Administration

Suite 1552

P. O. Box 303017

Montgomery, AL 36130-3017 (Via NRC Electronic Distribution)

U.S. Nuclear Regulatory Commission Region II

Sam Nunn Atlanta Federal Center

61 Forsyth Street, SW, Suite 23T85

Atlanta, Georgia 30303-3415

Mr. Malcolm T. Widmann, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415

NRC Senior Resident Inspector Browns Ferry Nuclear Plant

10833 Shaw Road

Athens, AL 35611-6970

Margaret Chernoff, Senior Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739

Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739

U.S. Nuclear Regulatory Commission

Page 4 April 14, 2006

DTL:PSH:BAB Enclosures

cc (Enclosures): B. M. Aukland, POB 2C-BFN

M. Bajestani, NAB 1A-BFN A. S. Bhatnagar, LP 6A-C J. C. Fornicola, LP 6A-C

R. G. Jones, POB 2C-BFN

R. F. Marks, PAB 1C-BFN G. W. Morris, BR 4X-C

B. J. O'Grady, PAB 1E-BFN

K. W. Singer, LP 6A-C

E. J. Vigluicci, ET 11A-K NSRB Support, LP 5M-C EDMS WT CA - K

s:lic/submit/Techspcs/TS 447 RAI E1-1 ENCLOSURE 1 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI

1.0 BACKGROUND

INFORMATION AND RAI

SUMMARY

TVA's August 16, 2004, letter (Reference

1) requested amendmen ts to Operating Licenses DPR-33, DPR-52, and DPR-68 for BF N Units 1, 2, and 3, respectively. The proposed changes are to revise t he operating licenses to extend the performance frequency of required calibration surveillance testing on instrumentation channels a ssociated with high area tem perature system isolation of the high pressure coolant injection (HPCI), reactor core isolation cooling (RCIC), and reactor water clean-up (RWCU) systems. Allowable values for the trip setpoints for some of these channels would also be revised. The Technical Specifications (TS) currently require perfo rmance of these calibration activities on a more frequent interval than is technically necessary, and the continued performance of these calibrations on the current frequency is contrary to both ALARA principles and good indu strial safety practices.

NRC's January 10, 2005 letter to TVA (R eference 2) communicated an RAI to TVA, and in a March 11, 2005 letter (Refer ence 3), TVA responded to the RAI.

NRC then, on August 15, 2005, notified TVA vi a letter (Reference 4) that further additional information was required.

TVA's November 4, 2005 letter (Reference 5) provided this information. Subsequently, in a December 5, 2005 telecon, NRC verbally requested that the additional information described below be provided:

1. Identify the controls used at BFN which ensure the instrumentation setting is returned to the acceptable as-left value during calibration.

2. For the affected instrum entation, provide the setpoints, acceptable as-left values, and the acceptable as-fou nd values. Describe the band between the acceptable as-found value a nd the TS allowable value.

3. What is the action that BFN would take should this instrumentation be found outside of the acceptable as-found values?

4. Provide a discussion regarding the backup equipment available in case of loss of function of the affected instruments.

5. What impact does this instrum entation have on core damage frequency (CDF) and Large Early Release Frequency (LERF)?

Each of these areas are addressed below.

ENCLOSURE 1 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI E1-2 2.0 TVA RAI RESPONSE

1. Identify the controls used at BFN which ensure the instrumentation setting is returned to the acceptable as-left value during calibration.

TVA response:

These administrative controls are contained within the associated TS surveillance requirement (SR) calibration procedures. Calibrat ion of the HPCI and RCIC area high temperature switches is accomplished by physically replacing the switches in the field at each calibration interval with like switches which have been bench calibrated in the maintenance shop. The bench

calibration verifies and documents the as-lef t setpoint value of the switches being installed to be within the acceptable range. The as-f ound trip setpoints of the switches removed from the field are then determined by bench-testing in the maintenance shop, and the as-found trip setpoints are documented within the calibration procedure. For the RWCU area high temperature loops, following

determination of the as-found setpoint valu es and documentation of these values within the procedure, the rack-mounted analog trip unit (ATU) modules are recalibrated, if necessary, to meet t he loop as-left scaling requirements. For each of these instruments, the as-left va lue is documented within the calibration procedure to be within the s pecified value range before the instrument/loop is returned to service.

In no case is an instrument returned to se rvice with an as-left setpoint outside the acceptable range.

2. For the affected instrum entation, provide the setpoints, acceptable as-left values, and the acceptable as-fou nd values. Describe the band between the acceptable as-found value and the TS allowable value.

TVA response:

provides the requested informa tion in a tabular format. The values listed would be put in place upon approval and implementation of TS-447.

3. What is the action that BFN would ta ke should this instrumentation be found outside of the acceptable as-found values?

TVA response:

Each of the associated SR calibration pr ocedures includes reference(s) to TVA procedure SPP-8.1, "Conduct of Testing."

Steps 3.6.A and 3.

6.B of SPP-8.1 are excerpted below:

ENCLOSURE 1 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI E1-3 3.6 Problems During Testing The individual(s) performing the test shall be responsible for actions in this subsection as noted. The responsible supervisor is to be consulted if additional guidance is required. A. Operations must be immediately notified if a problem is encountered that affects the operabili ty of TS equipment or it is determined that a component or system operation is degraded. If the individual performing the test is uncertain, Operations should be notified. B. Problems identified during the te st shall be annotated on the CTL [chronological test log] including a description of the problem, the procedure step when/where the problem was identified, corrective action steps taken to resolve the problem, and the number of the corrective action document, if one was required.

Additionally, TVA procedure SPP-6.7, "Instrumentation Setpoint, Scaling, and Calibration Program," s pecifies a Maintenance M anagement System (MMS) database where required recalibrations of safety-related, TS, post-accident monitoring, and TS compliance instrumentation are documented for trending purposes.

These documentation methods for instrume nt out-of-tolerance instances (within testing data packages, the BFN corrective action program, and the MMS, as appropriate), provide a high confidence that any negative trend in instrumentation performance will be ident ified and addressed.

4. Provide a discussion regarding the backup equipment available in case of loss of function of the af fected instruments.

TVA response:

The subject TS change does not impact the functional testing intervals of the associated area temperat ure instruments. Functional testing which demonstrates the isolation capability of the associated instrumentation will continue at the current frequency, theref ore any functional issues which might arise with the isolation logic will be read ily identified in the same way as under the current TS. The BFN licensing basis assumes only the loss of a single redundant instrument or logi c channel, and the TS change requested in TS-447 does not impact the validity of this basis.

There is no identified mechanistic way t hat the changes being requested by this TS submittal could effect simultaneous fa ilures of this high area temperature instrumentation such that the one-out-of-two-twice isolation logic becomes non-functional. However, if such simultaneous failures are postulated, as in the RAI question being addressed, t he following plant respons e would be expected.

ENCLOSURE 1 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI E1-4 Postulated Event (coincident with multiple isolation instrument failures) Backup equipment available Anticipated plant response HPCI steam line break outside primary containment high steam flow detection instrumentation and

plant indication of

temperature and area

radiation automatic isolation on high flow for larger breaks or manual isolation of the

system by plant staff using

existing abnormal and

emergency procedures RCIC steam line break

outside primary

containment high steam flow detection

instrumentation and

plant indication of

temperature and area

radiation automatic isolation on high flow for larger breaks or

manual isolation of the

system by plant staff using

existing abnormal and

emergency procedures RWCU loop piping

break outside primary

containment plant indication of temperature and area

radiation manual isolation of the system by plant staff using

existing abnormal and

emergency procedures For each of the pipe break events listed in the preceding table, multiple safety and non-safety related systems remain av ailable which are fully capable of supplying makeup water to the reactor. Achieving and maintaining a hot shutdown condition as described in the BFN licensing basis is in no way

impacted by implementation of TS-447.

5. What impact does this instrum entation have on core damage frequency (CDF) and Large Early Release Frequency (LERF)?

TVA response:

The BFN probabilistic risk assessment (P RA) model includes initiating events associated with rupture of the Main Steam, HPCI, RCIC, or RWCU lines outside of primary containment. Collectively, th is set of initiators is called "breaks outside containment" (BOC). The model re sults are insensitive to calibration issues involving the isolation instrum ents, though the results are affected if isolation of a hypothetical break is considered unsuccessful.

As stated above in the response to question 4, there is no identified mechanistic way that the changes being requested by this TS submittal could effect simultaneous failures of this high area tem perature instrumentation such that the one-out-of-two-twice isolation logic becom es non-functional. The probability of successful isolation remains unchanged. Since the PRA model is only sensitive to the success/failure of the break isolat ion, and it is insensitive to the precise point at which the isolation is accomp lished, there will be no impact to either CDF or LERF from the approval of TS-447.

ENCLOSURE 1 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI E1-5

3.0 REFERENCES

1. August 16, 2004, Letter from TVA to NRC transmitting Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Technical Specifications (TS) Change TS-447

- Extension of Channel Calibration Surv eillance Requirement Performance Frequency And Allowable Value Revision (ADAMS accession number ML04237061) 2. January 10, 2005, Letter from NRC to TVA transmitting Results Of Acceptance Review Regarding Request To Extend Technical Specification Channel Calibration Frequencies (MC4070, MC4071, and MC4072) (TS-447) (ADAMS accession number ML043640556)

3. March 11, 2005, Letter from TVA to NRC transmitting Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - Technical Specifications (TS) Change TS-447 Request For Additional Information (RAI) - Extension Of Channel Calibration Surveillance Requirement Perform ance Frequency And Allowable Value Revision (ADAMS accession numbers ML050770370 and ML050770379)

4. August 15, 2005, Letter from NRC to TVA transmitting Browns Ferry Units 1, 2, and 3 - Request for Additional Informati on Regarding Channel Calibration Test Interval (TAC NOS. MC4070, MC4071, AND MC4072) (TS-447) (ADAMS accession number ML052130135)

5. November 4, 2005 Letter from TVA to NRC transmitting Browns Ferry Nuclear Plant (BFN) - Units 1, 2, And 3 - Technical Specific ations (TS) Change TS-447 Second Request For Additional Informa tion (RAI) - Extension Of Channel Calibration Surveillance Requirement Performance Frequency And Allowable Value Revision (TAC NOS. MC 4070, MC4071, and MC4072) (ADAMS accession number ML053110343)

ENCLOSURE 2 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI E2-1 The following page contains a tabl e which, for each instrument affected by this TS amendment, details the setpoints, acceptable as-left val ues, acceptable as-found values, and the associated TS allowable value. Each of these instruments is listed below by it s TVA unique identifier (UNID) tag. The plant area monitored by the instrument is also listed.

UNID (Units 1, 2, and 3) Monitored Area in U1/U2/U3 Reactor Building TS-073-02A, B, C, D HPCI pump room area TS-073-02E, F, G, H HPCI st eamline - torus area (exit) TS-073-02J, K, L, M HPCI steamline - torus area (midway) TS-073-02N, P, R, S HPIC steamline - torus area (entry)

TS-071-02A, B, C, D RCIC pump room area TS-071-02E, F, G, H RCIC st eamline - torus area (exit) TS-071-02J, K, L,M RCIC st eamline - torus area (midway) TS-071-02N, P, R, S RCIC st eamline - torus area (entry) TIS-069-835A, B, C, D RWCU pipe trench area TIS-069-836A, B, C, D RWCU pump room A TIS-069-837A, B, C, D RWCU pump room B TIS-069-838A, B, C, D TIS-069-839A, B, C, D RWCU Heat Exchanger room (east and west walls)

ENCLOSURE 2 BROWNS FERRY (BFN) TS-447 REQUEST FOR ADDITIONAL INFORMATION (RAI)

RESPONSE TO THE DECEMBER 5, 2005 TELECON RAI E2-2 UNID's (U1/U2/U3)

Monitored Plant Area Minimum as-found value Setpoint Maximum as-found value Minimum as-left value Maximum as-left value TS allowable

value TS-073-02A, B, C, D HPCI pump room area 174.8 185.0 195.2 182.4 187.6 200.0 TS-073-02E, F, G, H HP CI steamline - torus area (exit) 155.9 165.0 174.1 162.7 167.3 180.0 TS-073-02J, K, L, M HPCI steamline - torus area (midway) 155.9 165.0 174.1 162.7 167.3 180.0 TS-073-02N, P, R, S HPIC steamline - torus area (entry) 155.9 165.0 174.1 162.7 167.3 180.0 TS-071-02A, B, C, D RCIC pump room area 155.9 165.0 174.1 162.7 167.3 180.0 TS-071-02E, F, G, H RCIC steamline - torus area (exit) 155.9 165.0 174.1 162.7 167.3 180.0 TS-071-02J, K, L, M RCIC steamline - torus area (midway) 155.9 165.0 174.1 162.7 167.3 180.0 TS-071-02N, P, R, S RCIC steamline - torus area (entry) 155.9 165.0 174.1 162.7 167.3 180.0 T -069-835A, B, C, D RWCU pipe trench area 128.7 131.0 133.3 129.8 132.2 135.0 T -069-836A, B, C, D RWCU pump room A 145.7 148.0 150.3 146.8 149.2 152.0 T -069-837A, B, C, D RWCU pump room B 145.7 148.0 150.3 146.8 149.2 152.0 T -069-838A, B, C, D RWCU Heat Exchanger room, East Wall 136.7 139.0 141.3 137.8 140.2 143.0 T -069-839A, B, C, D RWCU Heat Exchanger room, West Wall 163.7 166.0 168.3 164.8 167.2 170.0