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| issue date = 12/29/1997
| issue date = 12/29/1997
| title = Forwards Supplemental Info in Support of TS-362 Amend Request Re Section 3.3, Instrumentation. NRC Questions on Section Provided as Ref in RAI Dtd 970612
| title = Forwards Supplemental Info in Support of TS-362 Amend Request Re Section 3.3, Instrumentation. NRC Questions on Section Provided as Ref in RAI Dtd 970612
| author name = ABNEY T E
| author name = Abney T
| author affiliation = TENNESSEE VALLEY AUTHORITY
| author affiliation = TENNESSEE VALLEY AUTHORITY
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter:}}
{{#Wiki_filter:C Enclosure ITS Section 3.3 Instrumentation Enclosnre Contents                                          Enclosed?
~  Response    to NRC questions                                  Yes
~  Summary    Description of ITS/ITS    BASES Changes.          Yes
~  ITS Revised Pages                                            Yes
~  ITS BASES Revised Pages                                      Yes
~  CTS Hark-up Revised Pages.                                  . Yes
~  Justifications for Changes      to CTS (DOCs)
Revised Pages                                                Yes NUREG-1433 BWR/4 STS Mark-up Revised Pages.                  Yes
~  NUREG-1433 BWR/4 STS Bases Hark-up Revised Pages.            Yes Justification for Changes to NUREG-1433 {JDs)
Revised Pages                                                Yes
~  No  Significant  Hazards Considerations    Revised Pages    Yes
~  Cross-Reference    Matrix Correlating    Changes Between the CTS, ITS, and NUREG-1433.                        Yes
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT 8              DESCRIPTION OF ISSUE                              PROPOSED RESOLUTION                      INCORP COMPLETE Y/N    DATE 3.3.1.1-1  CTS TABLE 3.1.A, NOTE IA ALLOWS ONE HOUR BEFORE  THE REDUCTION FROM I HOUR TO IMMEDIATELYFOR                  8/28/97 INITIATIONOF CONTROL ROD INSERTION. ITS 3.3.1.1,  INSERTION OF ALLCONTROL RODS IF REQUIRED OPERABLE REQUIRED ACTION H.l DOES NOT ALLOWTHIS I HOUR    OR TRIPPED FUNCTIONS FOR REFUEL MODE ARE NOT PERIOD.                                          MAINTAINEDIS MADE TO BE CONSISTENT WITH NUREG-1433. SINCE SUFFICIENT TIME FOR ACTIONS ASSOCIATED WITH CONDITIONS A, B, AND C IS PROVIDED (AND EXTENDED FROM THE CTS ALLOWEDTIMES) IT IS CONCLUDED THATTHE REDUCTION OF THIS SPECIFIC TIME IS ACCEPTABLE FOR BFN.
3.3.1.1-2  THE UNIT I CALIBRATIONFREQUENCIES OF CTS TABLE    THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l.            8/28/97 4.1.B ARE CHANGED FROM 3 MONTHS TO 18 MONTHS TO  A GENERIC RESPONSE THAT STATES MAKINGUNIT I DUPLICATE THE UNIT2 & 3 LESS RESTRICTIVE          CONSISTENT WITH UNITS UNIT 2 & 3 IS DONE FOR FREQUENCIES OF CTS TABLE4.1.B AS AN              CONSISTENCY AND THAT THE UNIT I TECHNICAL ADMINISTRATIVECHANGE RESULTING IN ITS TABLE      SPECIFICATIONS WILLBE VERIFIED CORRECT PRIOR TG 3.1.1-1 FUNCTIONS 3,4,&6 RATHER THAN AS A LESS    UNIT ] STARTUP. THIS WILLBE A COMMENT TO RESTRICTIVE CHANGE.                              REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITI'ALSHOULD BE RE URED.
3.3.1.1-3  THE TSV AND TCV APPLICABILITYIS CHANGE TO 230%    SPECIFIC QUESTION ADDRESSED BY ADDINGADDITIONAL              8/29/97 RTP FROM 1ST STAGE PRESSURE (1 54 PSIG. A        INFO TO NOTE A6 PAGE I OF JFC 3.3.1.1. THE UFSAR STATEMENT IS MADETHAT THE TWO LIMITSARE          SECTION 14.5.1.5 ADDRESSES THE SETPOINT BEING 154 PSIG IDENTICALWITHOUTAPPROPRIATE REFERENCES OR        AND 30% RATED POWER BEING THE BYPASS POINT WHICH JUSTIFICATIONS TO CONCLUDE THE CHANGE IS          DEMONSTRATES THATTHE TWO VALUES ARE ADMINISTRATIVE                                    INTERCFIANGEABLEFOR THESE PERMISSIVE APPLICATIONS. THIS INFORMATIONWAS ADDED TO NOTE A6 BY ADDINGA SHEET la TO THE SECTION 3.3.1.1 JFC.
3.3.1.14    DOC A 12 DISCUSSES THAT HIGI.IREACTOR PRESSURE,  DOC A12 WILLBE REWIUTTEN TO MORE CLEARLYSHOW                  5/2/97-HIGH DRYWELLPRESSURE AND LOW WATER LEVEL          THAT THE EXISTING NOTE 7 WHICH STATES "WHEN THE.
FUNCTION ARE DELETED FOR MODE 5. NOTES 8 & 10 DO  REACTOR IS SUBCRITICALAND THE REACTOR WATER NOT APPLY TO LOW WATER LEVEL. THE NOTES STATE    TEMPERATURE IS LESS THAN 212'F, ONLY THE FOLLOWING THAT REFUEL MODE DOESN'T APPLY IF CONTAINMENTIS  TRIP FUNCTIONS NEED TO BE OPERABLE:
NOT REQUIRED (NOTE 8) OR IF THE HEAD IS UNBOLTED  A. MODE SWITCH IN SHUTDOWN (NOTE 10). DOC A12 DOES NOT ACCURATELYDISCUSS    B. MANUALSCRAM THE CHANGES THATARE BEING PROPOSED.              C. HIGH FLUX IRM C. SCRAM DISCHARGE VOLUMEHIGH LEVEL" NOTE 7 NEGATES THE NEED FOR THE DELETED REQUIREMENTS WHERE BECAUSE REFUEL MODE ASSURES THAT THE REACTOR IS SUBCRITICALAND THE REACTOR WATER TEMPERATURE IS LESS THAN 212'F.
PAGE
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT 8            DESCRIPTION OF ISSUE                                PROPOSED RESOLUTION                      INCORP COhf PLETE Y/N    DATE 3.3.1.1-5  THIS DOC DISCUSSES A MXTURE OF CHANGES TO          JUS11FICATION (A14) WAS CHANGED TO L6 AND                    5/2/97 ACTION STATEMENTS FOR RPS TRIPS. THE DOC STATES  JUSTIFICATION BASE D ON THE LESS RESTRICTIVE OPTIONS THATACTION 1.A HAS BEEN DELETED SINCE IT          BEING ACCEPTABLE AND THEREFORE THE REQUIREMENT CONTAINS AN OBVIOUS REQUIREMENT. ACTION I.A IS    TO INSERT RODS UNNECESSARY BUT STILL AVAILABLETO AN OPTIONAL ACTION FOR THE OPERATOR AND ITS      THE OPERATOR IF DESIRED.
DELETION RESULTS IN A LESS RESTRICTIVE SINCE OPTIONAL REQUIREMENTS ARE REMOVED. PROVIDE REVISED DISCUSSION THATADDRESS PROPOSED CHANGES.
3.3.1.14    THE IS NO DESIGN CHANGE FROM CTS TO ITS. BUT, THE A7 ADDRESSES THE NUMBER OF CKQBKLS REQUIRED..                  9/3/97 ITS PROPOSES 8 (REQUIIRED) CHANNELS PER TRIP      THIS NOTE NEEDS TO BE REVISED TO BETTER EXPLAIN SYSTEM WHILETHE CTS IS 4 (MINMUMOPERABLE)        THAT THE CTS USED 4 CHANNELS BASED ON RPS CHANNEL PER TRIP SYSTEM. EXPLAINWHYTHIS          CHANNELS Al, A2, Bl dc B2 WHEREAS IN THE ITS TO BETTER CHANGE IS CONSIDERED ADMMSTRATIVE.                MEET THE DEFMTION OF "CHANNELS PER TRIP SYSTEM" THE TOTAL NUMBER OF INPUTS FROM THE VALVELIMIT SWITCHES WILLBE USED.
M2 AND M3 ARE DESCRIPTIONS OF MORE RESTRIC11VE                  11/18/97 3.3.1.1-7  THE M-DOC DISCUSSIONS LACKA SAFETY IMPACT CHANGES. M2 ADDRESSES ADDINGA 4 HOUR TIME LIMT JUSTIFICATION FOR THE PROPOSED CHANGES.
ON TABLE 3.).A ACTION I.D WHICH PREVIOUSLY HAD NO TIME LIMIT. M2 ADDRESSES ADDINGA NEW SURVEILLANCETO VERIFY THAT SRM AND IRM CHANNELS OVERLAP PRIOR TO WITHDRAWINGTHE SRMs FROM THEIR FULLYINSERTED POSITION. JFC M2 AND JFC M3 WILLBE REVISED TO ADDRESS SAFETY MPACT.
THE NOTES ADDED WITH THE SURVEILLANCE                          9/3/97 3.3.1.1-8  THE IRM HIGH FLUX SR CALIBRATIONDISCUSSION DOES REQUIREMENT 3.3.1.1.9 ARE CONSISTENT WITH THE NOTES NOT INCLUDE DISCUSSION OF THE NOTES THATARE FOR SR 3.3.1.1.11 AND 3.3.1.1.13 WHICH IS FROM WHICH SR ALSO ADDED AS PART OF TI IE SR.
3.3.1.1.9 WERE TAKEN AS DOCUMENTED BY JFC P55. M4 WILLBE REVISED TO ADDRESS THE NOTES AS WELLAS THE SR.
VERIFICATIONOF IRM/APRM OVERLAP HAS BEEN                        9/3/97 3.3.1.1-9  VERIFICATIONOF THE IRM/APRMOVERLAP DURING CHANGED FROM STARTUP ( CTS) TO SHUTDOWN (ITS).
SHUTDOWN THAT IS NOT REQUIRED BY THE CTS IS AN THIS CHANGE IS ADDRESSED BY A REVISED JFC M5 AND A ADDITIONALRESTRICTION ON PLANT OPERATION.
NEW JFC L7 WHICH ADDRESSES BOTH THE MORE RESTRICTIVE ASPECTS OF THE NEW REQUIREMENT AND THE LESS RESTRICIVE ASPECTS OF DELETING THE OLD, RE UIREMENT.
PAGE  2
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT 8            DESCRIPTION OF ISSUE                                    PROPOSED RESOLUTION                      INCORP COMPLETE Y/N    DATE THIS IS TIED TO ISSUE 3.3.1.1-9 BECAUSE THE DELETION OF        9/5/97 3.3.1.1-10  DELETION OF VERIFICATIONOF OVERLAP DURING IRM/APRM OVERLAP DURING STARTUP WAS DELETED OOS        STARTUP IS LESS RESTRICTIVE ON PLANT OPERA11ON.
BASED ON THE ADDITIONOF IRM/APRM OVERLAP DURING SHUTDOWN. IT IS TRUE THATTHE DELETION IS LESS RESTRICTIVE AND THUS JFC M5 WILLBE REVISED AND L7 WILLBE ADDED.
3.3.1.1-1 I AN RPS CIIANNELTEST SWITCH FUNCTION IS ADDED TO        THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED                    9/5/97 TO THE NRC FOR APPROVAL. NO CHANGES THE CTS OR ITS THE LIST OF FUNCTIONS IN ITS TABLE 3.3.1.1-1, FUNCTION MARKUPS ARE REQUIRED.
12.
THE FREQUENCY OF CALIBRATIONFOR THE APRM FLOW                  9/9/97 3.3.1.1-12  INCORRECT DOC. THE APRM FLOW BIASED CFIANNEL BIAS INSTRUMENTATIONHAS BEEN CHANGED FROM ONCE CALIBRATIONFREQUENCY IS CHANGE TO QUARTERLY PER OPERATING CYCLE TO ONCE PER 92 DAYS. THIS WAS FROM ONCE PER OPERATING CYCLE.
AN ERROR IN THE CTS MARKUPS AS IS EVIDENCED BY THE REFERENCE TO JFC A4 WHICH INDICATES A NOMENCLATURE CHANGE FROM REFUELING CYCLE TO 18 MONTHS. ALSO, IN THE ITS BASES SR 3.3.1.1.11 ON PAGE B3.3-30 k 31 ADDRESS THE BASES FOR THE APRM FLOW BIASED FUNCTION STATES THE 18 MONTH FREQUENCY IS BASED ON SYSTEM DESIGN. CTS TABLE 4.1.B WILLBE REVISED TO CHANGE 92 DAYS TO 18 MONTHS AND CHANGE REFERENCED SR FROM 3.3.1.1.9 TO SR 3.3.1.1.11.
THIS TABLE (MATIRX)IS BEING PREPARED BY BILLY 3.3.1.1-13  PROVIDE A TABLE LISTING EACH ITEM THAT IS MOVED THIBADEAUX. THIS SHOULD NOT IMPACTTHE CTS OR ITS TO AN OWNER-CONTROLLED DOCUMENT. FOR EACH ITEM DESCRIBE TFIE NAME OF THE DOCUMENT THAT
                                                                  ~UPS      BUT WILLBE SUBMI1TED AS A RESPONSE TO THIS ISSUE.
THE ITEM IS MOVED TO AND THE REGULATORY CONTROL MECHANISMWFIICH WILLCONTROL FUTURE PROPOSED CHANGES.
CONCUR THATTHE CHANGE IS ADMINISTRAllVEBECAUSE                  9/8/97 3.3.1.1-14  NOTE 2 OF ITS SR 3.3.1.1 HAS TFIE REVISED WORDING "THE ASSOCIATED FUNCllONS MAINTAINSRPS TRIP            IT IS A CLARIFICATIONOF EXISTING NOTE. JFC LBI WILLBE CAPABILITY"THAT ASSURES TRIP FUNCTION CAPABILITY CHANGED TO JFC A15.
FOR ALLDESIGNS. THIS CHANGE APPEARS ADMINISTRATIVE,RATHER TING LESS RESTRICTIVE.
PAGE 3
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM INCORP COMPLETE COMMENT ¹              DESCRIPTION OF ISSUE                                    PROPOSED RESOLUTION                      Y/N    DATE THE REQUESTED DOCUMENTATIONWILLBE SUBMTTED                  9/5/97 3.3.1.1-15  THE CHANNEL FUNCTIONALTEST INTERVALOF RPS                TO THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR OOS        CHANNELS AND TRIP SYSTEMS (ITS TABLE 3.3.1.1-1,          ITS MARKUPS ARE REQUIRED.
FUNCTIONS 2, 3, 4, 5, 7, 8, 9, AND 11) ARE EXTENDED TO 92 DAYS FROM THE MONTHLYREQUIREMENT OF CTS TABLE4.1.A, BASED ON THE RELIABILITYANALYSIS OF "TECHNICALSPECIFICATION IMPROVEMENTANALYSES FOR BWR REACTOR PROTECTION SYSTEM," (NEDC-30851-P-A, MARCH 1988) AND AN UNREFERENCED BAN REPORT "TECHNICALSPECIFICATION MPROVEMENT ANALYSES FOR BROWNS FERRY NUCLEAR PLANT, UNIT 2," (MED            0286, OCTOBER 1995.)
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED                  9/8/97 3.3.1.1-16  THE ITS 3.3.1.1, CONDITION A, COMPLETION TIME IS          TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        EXTENDED FROM 1 HOUR IN CTS TABLE 3.1>, NOTES I          ITS MARKUPS ARE REQUIRED.
AND 23, TO 12 HOURS.
THE ITS 3.3.1.1, CONDITION B, COMPLETION TME IS EXTENDED FROM I HOUR IN CTS TABLE 3.1.A, NOTES I AND 23, TO 6 HOURS.
THE AOT FOR PLACING A CHANNEL IN TRIP FOR REQUIRED SURVEILLANCETESTING IS EXTENDED FROM THE 4 HOURS OF CTS TABLE 3.1.A, NOTE 23, TO 6 HOURS IN ITS TABLE 3.3.1.1-1.
THESE CHANGES ARE BASED ON THE RELIABILITY ANALYSIS OF "TECHNICALSPECIFICATION IMPROVEMENTANALYSES FOR BWR REACTOR PROTECTION SYSTEM," (NEDC-30851-P-A, MARCH 1988)
AND AN UNREFERENCED BAN REPORT "TECHNICAL SPECIFICATION IMPROVEMENTANALYSES FOR BROWNS FERRY NUCLEAR PLANT, UNIT 2," (MED-32-0286, OCTOBER 1995.)
JFCs Ll AND L2 WILLBE REVISED TO ADD ADDITIONAL              9/15/97 3.3.1.1-17  Ll DOES NOT DISCUSS      CHANGES PROPOSED TO CTS                                                      "
DETAILS ON THE PROPOSED CHANGES. MODE 5 WILLBE NOTE (7).                                                ADDED TO ITS TABLE 3.3.1.1-1 FUNCTIONS 2a AND 2e AS INDICATEDBY CTS TABLE 3.1.A NOTE 21 MARKUP ANDADD L2 DOES NOT DISCUSS MANUALSCRAM FUNCTION                JFC P92 TO JUSTIFY STS CHANGE.
CHANGES.
PAGE 4
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM INCORP COMPLETE COMMENT 4                DESCRIPTION OF ISSUE                                        PROPOSED RESOLUTION                    Y/N    DATE JFC L4 WILLBE REVISED TO ADD ADDITIONAL              Y  9/16/97 3.3.1.1-18  A NOTE IS ADDED TO THE HEAT BALANCECALIBRATION                JUSTIFICATION FOR ALLOWINGTHE 12 HOURS AFTER WHICH ALLOWS DELAYIN PERFORMING THE SR UNTILA                EXCEEDING 25% RTP TO PERFORM THE HEAT BALANCE PRESCRIBED POWER LEVEL IS REACHED. THE SAFETY CALIBRATION.
BASIS EVALUATIONSTATES ACCEPTANCE BASED ON OPERATING EXPERIENCE. BFNP HAS NEVER PERFORMED THE SURVEILLANCEWITH THE PROPOSED NOTE. WHAT IS THE BASIS FOR THE OPERATING EXPERIENCE JUSTIFICATION?
CTS TABLE 3.1.A NOTE I MARKUP WILLBE REVISED TO      Y    9/16/97 3.3.1.1-19  LB2 & L5 BOTH APPLY TO THE SAME BALLOONEDTEXT INTHE    ~UP      OF TABLE 3.1.A, NOTE (I). LS AS STATED DELETE LB2 JFC FOR SECTION THAT LISTS BOTH LB2 AND LS. FOR THE UNIT I MARKUP A SECTION BELOW THAT HAS DOES NOT PROVIDE APPROPRIATE JUSTIFICATION FOR NO JFC FLAG WILLHAVB LB2 FLAG ADDED. JFC LS WILL THE BALLOONEDTEXT.                                            BE REVISED TO BETfER REFLECT THE APPROPRIATE JUSTIFICATION FOR THE CHANGE.
JFC P58 WILLBE REVISED TO PROVIDE ADDITIONAL        Y    9/17/97 3.3.1.1-20  THE FUNCTION OF THE TIME CONSTANT CIRCUIT OF STS              JUSTIFICATION FOR DELETION OF CALIBRATIONOF THE SR 3.3.1.1.14 IS TO SIMULATEFLOW COAST DOWN FOR              APRM FLOW BIASED SIMULATEDTHERMALPOWER CIRCUIT THE APRM. ITS 3.3.1.1 DOES NOT IMPLEMENTTHIS                  TIME CONSTANT.
SURVEILLANCE. DELETING THE TIME CONSTANT TESTING IN STS SR 3.3.1.1.14 OF THE APRM FLOW BIASED SIMULATEDTHERMALPOWER CIRCUIT IS NOT SUFFICIENTLY SUPPORTED.
JFC P4 PROVIDES ADEQUATE JUSTIFICATION FOR NOT      N    9/17/97 3.3.1.1-21  STS SR 3.3.1.1.17 REQUIRES RPS 1lME RESPONSE TESTING.
INCLUDINGRESPONSE TIME TESTING AS A SURVEILLANCE ITS 3.3.1.1 DOES NOT IMPLEMENTTHIS SURVEILLANCE.              REQUIREMENT. BFN DOES NOT CURRENTLY PERFORM DELETING THE RPS TIME RESPONSE TESTING IN ITS                RESPONSE TIMETESTING AND THE BENEFITS OF ADDING 3.3.1.1 IS NOT SUFFICIENTLY SUPPORTED BY JFC OR THIS SR BASED ON THE UNLKELY POSSIBILITY OF THE BASES.                                                        RESPONSE TIMES SIGNIFICANTLYCHANGING THAT WOULD IMPACT THE ABILITYOF THE RPS TO PERFORM ITS SAFETY FUNCTION WITHOUT BEING IDENTIFIED DURING OTHER REQUIRED FUNCTIONALTESTS AND CALIBRATIONS DOES NOT JUSTIFY THE ADDITIONAL OUT OF SERVICE TIME FOR TI.IE RPS INSTRUMENTATIONOR ADDITIONAL BURDEN ON THE PLANT STAFF. (NOTE REQUESTED BERT MORRIS GUIDANCE ON THIS 9/17/97 3.3.1.1-22  TIK LOW SCRAM PILOT AIR HEADER PRESSURE SURVEILLANCE OF      ff$ SR 3 3 I I I 6 APPLIES TP UNITS 2 &  SC~    PROT ~ ~ER P~S~
JFC P60 WILLBE REVISED TO DOCUMENT THATTHE LOW NSW~MATION HAS NOT BEEN IMPLEMENTED ON UNIT I AND THEREFORE Y    9/18/97 3 BUT NOT UNrr1    No JUSTIFICATION OR EXPLANATION          THIS SURVEILLANCEWAS NOT APPLICABLE.
PAGE 5
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT P                DESCRIPTION OF ISSUE                                  PROPOSED RESOLUTION                    INCORP COMPLETE Y/N    DATE PREVIOUS JUSTIFICATION IN JFC P16 AND P79 ARE                9/18/97 3.3.1.1-23  THE DELETION OF THE STS BASES FOR THE SR 3.3.1.1.16 APPLICABLE. RETURNING THE SENSORS ONLINE WILL REQUIREMENT THAT THE MAINTURBINE BYPASS HAVE NO IMPACT UPON THE TURBINE VALVESAS THE VALVES MUST BE CLOSED WHEN CALIBRATIONIS ONLY LOGIC TIE IS IN THE REACTOR PROTECTION SYSTEM PERFORMED AT > 30% RTP SHOULD BE RECONSIDERED SUCH THAT TO RECEIVE A HALF SCRAM REQUIRES A IF ACTUALSTEAM PRESSURE IS USED TO VERIFY THE CLOSURE SIGNALFROM THE TURBINE STOP VALVES OR CALIBRATION. ITS BASES TURBINE CONTROL VALVESAND THE INDICATIONOF >30%
SR 3.3.1.1.15, FUNCTIONS 8 & 9, DO NOT HAVE THIS RTP FROM THE TURBINE FIRST STAGE PRESSURE REQUIREMENT. WHILETHE JUSTIFICATION THATAN SWITCHES. SINCE THE CALIBRATIONWILLNOT VERIFY ISOLATED SENSOR CAN BE TESTED WITH A GAGE CALIBRATORINDEPENDENT OF BYPASS VALVEPOSITION ANY FUNCTION OTHER THAN A POTENTIAL RPS HALF SCRAM AND THE PRESSURE SWITCHES ARE REMOVED IS TRUE, THE CALIBRATIONTHAT IS ADDRESSED BY ITS FROM THE PROCESS AND CALIBRATEDWITH A PRESSURE SR 3.3.1.1.15 IS NOT ONLY STEAM PRESSURE BYPASS TRIP SOURCE (NEGATING ANY IMPACT A BYPASS VALVEWOULD SETPOINT AND FUNCTION, BUT ALSO DEMONSTRATES HAVE ON THE CALIBRATION) THERE IS NO AFFECT FROM THATTHE FUNCTION IS VERIFIED BY PARTIAL THE BYPASS VALVES (AS STATED IN JFC P79) AND MOVEMENTOF THE TURBINE VALVES AFTER THE THEREFORE THE DELETION OF REQUIREMENT FOR THE SENSOR IS RI:"mRNED ON-LINE.
BYPASS VALVES TO BE CLOSED WHEN CALIBRATION OCCURS IS ACCEPTABLE THIS WAS PREVIOUSLY ADDRESSED IN RESPONSE TO ISSUE            9/18/97 3.3.1.1-24  CTS REQUIRE A CHANNEL CALIBRATIONONCE PER 3.3.1.1-12 AS FOLLOWS:
OPERATING CYCLE. THE CTS MARKUP SHOWS THIS THE FREQUENCY OF CALIBRATIONFOR Tl&APRM FLOW FREQUENCY IS CHANGED TO 92 DAYS AND IS RENAMED BIAS INSTRUMENTATIONHAS BEEN CHANGED FROM ONCE SR 3.3.1.1.9. IN THE ITS THE SAME SR IS 3.3.1.1.11 AND PER OPERATING CYCLE TO ONCE PER 92 DAYS. THIS WAS CARIUES A 184 DAY FREQUENCY. JFC P89 STATES THAT AN ERROR IN THE CTS MARKUPS AS IS EVIDENCED BY THE THE APRM DESIGN IS SUCH THAT THE FUNCTION CAN REFERENCE TO JFC A4 WHICH INDICATES A ONLY BE TESTED AT REFUELING WITHOUT CAUSING NOMENCLATURECHANGE FROM REFUELING CYCLE TO 18 MULTIPLEINOPERABLE APRMS AND A REACTOR TRIP.
MONTHS. ALSO, IN THE ITS BASES SR 3.3.1.1. I I ON PAGE RECONCILE THE APPARENT DISCREPANCIES BETWEEN B3.3-30 & 31 ADDRESS THE BASES FOR THE APRM FLOW THE CTS MARKUP, ITS MARKUP AND JFC 89.
BIASED FUNCTION STATES THE 18 MONTH FREQUENCY IS BASED ON SYSTEM DESIGN. CTS TABLE 4.1.B WILLBE REVISED TO CHANGE 92 DAYS TO 18 MONTHS AND CHANGE REFERENCED SR FROM 3.3.1.1.9 TO SR 3.3.1.1.11.
JFC P91 WILLBE REVISED TO ADDRESS THE DEVIATION                9/19/97 3.3.1.1-25  THIS SR APPLIES A 92 DAYCALIBRATIONFREQUENCY TO FROM THE STS.
RPS APRM TRIP FUNCTIONS WHICH OTHERWISE HAVE EITHER A 7 DAYOR REFUELING INTERVAL.
PAGE 6
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM DESCRIPTION OF ISSUE                                                                        INCORP COMPLETE COMMENT II                                                                    PROPOSED RESOLUTION Y/N    DATE SINCE THE ADDITIONOF CHANNEL CHECKS WOULD BE A              9/18/97 3.3.1.1-26  CHANNEL CHECKS ARE NOT ADOPTED AS PART OF THE NEW REQUIREMENT THAT BFN IS NOT PRESENTLY ITS FOR DRYWELLPRESSURE HIGH AND SDV TRIP REQUIRED TO MEET THE CHOICE NOT TO IMPLEMENT FUNCTIONS.
DOES NOT REQUIRE FURTHER JUSTIFICATION. THE CONVERSION FROM CTS TO ITS WAS NOT TO IMPOSE NEW RE UIREMENTS.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED                  9/19/97 3.3.1.1-27  ADDITIONOF CHANNELTEST SWITCHES WAS CREDITED IN TI-IE ANALYSIS OF NEDO-3851 FOR EXTENDING        TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS ITS MARKUPS ARE REQUIRED.
AUTOMATICSCRAM FUNCTION FREQUENCIES.
DISCUSSION OF MINMUMREQUIREMENTS FOR FUNCTIONS              9/9/97 3.3.1.1-28  A BLOCK OF TEXT IS MOVED FROM STS    BASES, TO MAINTAINTRIP CAPABILITYARE TYPICALLYINCLUDED REQUIRED ACTIONS C.I, TO AN UNIDENTIFIEDPL@K DOCUM'.NT. ITS BASES, REQUIRED ACTIONS C. I, DOES    IN THE BASES IN OTHER LCOs. THEREFORE, THE NOT  ~AIN      TMS INFORMATION.                    DISCUSSION OF MINIMUMREQUIREMENTS FOR THE RPS FUNCTIONS TO MAINTAINTRIP CAPABILITYHAS BEEN ADDED BACKTO THE BASES FOR ACTION C.l OF LCO 3.3.1.1.
REVISIONS HAVE BEEN MADETO THE NUREG WORDING TO REFLECT BFN DESIGN AND JFC P15 HAS BEEN REVISED TO ADDRESS THESE CHANGES.
THE APPLICABILITYOF JFC LA2 WILLBE DELETED FROM              5/19/97 3.3.1.1-29  NOTE 17 PROVIDES EXCEPTIONS TO CTS APRM NOTE 17 AND JFC M8 WILLBE ADDED TO ADDRESS THE OPOERABILITYREQUIREMENTS. LA2 PROPOSES TO REMOVALOF EXCEPTION TO OPERABILTY OF THE APRM RELOCATE THESE EXCEPTIONS.
FUNCTIONS, THATREFERTONOTE17, DURING "LOW POWER PHYSICS TESTS" .
NOTE  19 IS SPECIFIC TO THE TURBINE FIRST STAGE              5/19/97 3.3.1.1-30  NOTE 19 ESTABLISHES ALTERNATEREMEDIALACTIONS PERMSSIVE FUNCTION WHICH WAS RELOCATED BASED ON JFC LAS. SINCE NOTE 19 HAS NO PURPOSE OTHER THAN CLARIFICATIONOF ACTIONS FOR THE TURBINE FIRST STAGE PERMSSIVE THE JUSTIFICATION FOR THE RELOCATION OF THE REQUIREMENTS IN NOTE 19 WILLBE CHANGED TO LA5 WHICH BETTER DESCRIBES THE RATIONAL.
IN ESPONSE TO ISSUE 3.3.1.1-17 MODE 5(a) WAS ADDED TO        5/19/97 3.3.1.1-31  NOTE 21 IS SHOWED TO BECOME TABLE 3.3.1.1-1 NOTE (A)
ITS FUNCTIONS 2 a AND 2 e WHICH INCORPORATED THE AND APPLIES TO FUNCTIONS 2.A AND 2.E. IN TABLE I NOTE (A) DOES NPTAPPLY TP FUNCTIONS 2 A NOTE 21    EQ~~.          ALL EQUIRED CHANGES TO THE ITS TO CORRECT THIS OMISSION WERE MADE IN RESPONSE TO ISSUE 3.3.1.1-17.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT ¹            DESCRIPTION OF ISSUE                            PROPOSED RESOLUTION                    INCORP Y/N COMPLETE DATE NOTE I STATES "INI'IIALLY THE MINIMUMFREQUENCY FOR      N  5/19/97 3.3.1.1-32  NOTE I STATES THATTHE MINIMUMFREQUENCY FOR THE INDICATEDTESTS SHALL BE ONCE PER MONTH". THIS THE TEST SHALL BE AT LEAST ONCE PER MONTH.
NOTE REFERRED TO FIGURE 4. I-l WHICH PROVIDED A BASES FOR THE CALIBRATIONINTERVALSELECTION BASED ON FAILURE INTERVAL. THE BASES FOR THE TEST INTERVALS IS INCLUDED IN THE ITS BASES AND THUS JFC LA2 IS APPLICABLE BECAUSE THE DETAILS OF SELECTION OF TEST INTERVALS IS INCLUDED IN THE BASES. NO CORRECTIONS ARE RE UIRED DUE TO THIS ISSUE.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                      Y/N    DATE JFC Mg WILLBE REVISED TO CORRECT A                      Y  9/23/97 3.3.1.2-1  ITS 3.3.1.2, Conditions A, B and C, allow up to 16 hours (4 hours    MSINTERPRETATION THAT CTS 3.3.B.4 DEFAULTS TO CTS for Conditions A and B and 12 hours for Condition C) before the      1.0.C. I WHICH WOULD REQUIRE PLANT TO BE IN COLD reactor must be in Mode 3 when SRM OPERABILITY SHUTDOWN WITIK430 HOURS. CTS 1.0.C.1 IS NOT requirements are not satisfied versus the CTS 3.3.B.4 requirement    APPLICABLE IN THIS CASE BECAUSE THE ASSOCIATED of being in MODE 4 within the following 30 hours.                    REQUIREMENTS WOULD BE FULFILLEDBY NOT WITHDRAWINGANY CONTROL RODS IF TWO SRM The change of going to Mode 3 rather than MODE 4 is less              CHANNELS DO NOT HAVE AN OBSERVED COUNT RATE OF 3 restrictive, even ifmore time is allowed.                            CPS (THE REQUIRMENT IS TO NOT WITHDRAWCONTROL RODS). THUS THE INCLUSION OF TIME LIMITS ON ACTIONS The change of going to 16 hours rather than 30 hours is a more        FOR CONDITIONS A, B, AND C IS MORE RESTRICTIVE SINCE restrictive change.
A TIME LIMIT DID NOT EXIST PREVIOUSLY.
THE WORDS "THE SRM SHALL BE INSERTED TO THE            N  9/25/97 3.3.1.2-2  The requirement that "The SRM shall be inserted to the normal NORMALOPERATING LEVEL"ARE NOT SPECIFICALLY operating level'as not carried into the Bases as stated.
STATED IN THE ITS BASES BUT THE INTENT IS STATED IN THE ITS BASES BACKGROUND AS "THE SRMs ARE MAINTAINEDFULLYINSERTED UNTILTHE COUNT RATE IS GREATER THANA MNIMUMALLOWCOUNT RATE ...
AFTER SRM TO INTERMEDIATE RANGE MONITOR (IRM)
OVERLAP IS DEMONSTRATED ... THE SRMs ARE NORMALLY FULLYWITHDRAWNFROM THE CORE". IN ADDITION OTHER PARTS OF THE ITS BASES SPECIFY THE REQUIRED LOCATION OF THE SRM SENSOR. FOR EXAMPLETHE LCO BASES STATES "COVERAGE IS PROVIDED BY ONE SRM TO BE OPERABLE IN TIN QUADRANTOF THE REACTOR CORE WHERE CORE ALTERATIONSARE BEING PERFORMED, AND THE OTHER SRM TO BE OPERABLE IN AN ADJACENT QUADRANTCONTAININGFUEL". THUS IT IS CONCLUDED THAT THE BASES ADEQUATELYADDRESSES THE LOCATION OF THE SRM IN ORDER TO DECLARE IT OPERABLE AND NO CHANGES ARE NECESSARY.
A LEAD IN TO THE MORE RESTRICTIVE JFCs WILLBE ADDED    Y  11/19/97 3.3.1.2-3  Each discussion    of change should  be revised to discuss the TO PROVIDE JUSTIFICATION FOR THE CHANGES BEING AN justification or the basis for concluding the change are an          ENHANCEMENT.
appropriate enhancement to TS.
SEE ATfACHMENTI FOR PROPOSED RESOLUTION                N  11/1/97 3.3.1.24a  The proposed ITS make use of spiral oflload procedures and adopt OOS        a revision to SR 3.3.1.2.4 Note 2 for count rate verification during spiral loading. These are changes to the CTS allowances and the revision to the SR Note is a change to the STS.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR INCORP COMPLETE DESCRIPTION OF ISSUE                                            PROPOSED RESOLUTION Y/N    DATE CTS 4.10.B.2 WILLBE MARKED UP TO ADD THE 24 HR        9/26/97 3.3.1.2Mb CTS core monitoring surveillances require periodic verification of REQUIREMENT AND JFC M9 WILLBE ADDED TO DESCRIBE signal to noise ratio once per 12 hours during core alterations. The THE MORE RESTRICTIVE CHANGE.
ITS include this requirement and an additional verification of once per 24 hours during applicable modes. The required 24 hour testing is not dispositioned in either the DOCs or the JFC.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR ATTACHMENT1 3.3.1.2-4a PROPOSED RESPONSE There is no NRC staff acceptance review for operations allowing spiral loading/off-loading. The following is a technical justification for the practice of using a spiral off-loading/loading process A spiral off-loading involves off-loading the sub~ritical core (the reactor is shutdown) by removing fuel from the outer    edges of the core in a spiral sequence around the core. The core size is continuously reduced thus decreasing reactivity from the already subwritical configuration. By following a spiral off-loading pattern, reactivity is guaranteed to decrease as the core size gets smaller. No positive reactivity changes to the core willbe made during spiral off-loading. Therefore, the core monitoring surveillance is not required to be followed during a spiral off-load as it is not ncedcd to monitor the decreasing reactivity.
The safety analysis associated with all of the intermediate configurations of the core during a spiral off-load is bound by the safety analysis of the starting configuration including fuel loading errors and control rod withdrawal errors. Control rods remain inserted until adjacent fuel has been removed. Since shutdown margin calculations assume that the strongest worth rod is withdrawn from the core, leaving all control rods inserted provides substantial analytical margin to criticality.
A spiral loading involves loading the core by placing four fuel assemblics around a source range monitor and successively adding fuel assemblies around the fueled region building a larger core until the final, analyzed core loading pattern is achieved. The final, loaded core is more reactive than the intermediate configurations. The core is continuously monitored by the source range monitor in the center of the fueled region and by the other source range monitors as the fueled region includes these locations.
During the spiral, bridges to the other source range monitors can be built providing additional assurance that the core is appropriately monitored. A reduction in the number of required operable source range monitor channels is acceptable when using a spiral pattern because the use of a spiral pattern centered about an source range monitor provides assurance that the erable source range monitor is in the optimum position for monitoring changes in neutron flux levels resulting from the core eration.
The suety analysis associated with all of the intermediate configurations of the core during a spiral load is bound by the safety analysis of the final configuration.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION INCORP COMPLETE COMMENT 8                    DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                        Y/N    DATE JFC A3 WILLBE REVISED TO BETTER DESCRIBE THE                  9/30/97 3.3.2.1-1  The deletion of the CTS Table 3.2.C surveillance requirements for RATIONALFOR THE EXISTING ROD BLOCK LOGIC BEING A the Rod Block Logic has been justified by observing that other DUPLICATIONIN THE CTS THAT IS ADDRESSED IN THE ITS.
functional tests can test it. In order to be an Administrative change, it would be implemented in the ITS, essentially unchanged. The CTS requires a operating cycle test of the logic whereas the ITS requires a quarterly test. Provide a statement that all components tested by the CTS requirements are included in the ITS SRs, but at a more frequent interval.
A LEAD IN TO THE MORE RESTRICTIVE JFCs WILLBE ADDED            11/19/97 3.3.2.1-2  Each discussion    of change should  be revised to discuss the TO PROVIDE JUSTIFICATION FOR THE CHANGES BEING AN justification or the basis for concluding the change are an ENHANCEMENT.
appropriate enhancement to TS.
THE PORTION OF THE NOTE PERTAINING TO SRMs, IRMs,              10/I/97 3.3.2.1-3  Portions of the note limit the use of channel bypass for SRMs or AND APRMs ARE ADDRESSED BY JFC Rl AND THUS LA1 IS RBMs during repair or calibration are proposed to be placed in the NOT APPLICABLETO THOSE FUNCTIONS. THUS ONLYTHE Bases using a justification that they are operational details. Because RBM PART OF THE NOTE REMAINS ASSIGNED TO JFC LAI.
the statements establish allowed outage times for repair or test they SINCETHE REMAINING(LAI)PARTOF THE NOTE DOES are instead, operational limits.
ADDRESS THE SAME OPERATIONAL LIMITS, FORTHE RBM, AS NOTE 7.c & 7.d WHICH ARE ASSIGNED TO ACTIONS A & B OF THE ITS THE PART OF THE NOTE FLAGGED TO LA1 WILL INSTEAD BE ASSIGNED TO ACTIONS A&B.
NOTE 7 WILLBE MARKED UP TO REFER TO JFC M3 WHICH                10/2/97 3.3.2.14    LAI is applied to a change which cannot be distinguished from other    WILLBE REVISED TO BEITER DESCRIBE THE marks on the page. Provide clarifying documentation.
INCORPORATION OF THE NOTE AND CHANGES TO IT INTO THE ITS. IN ADDITONTHE PART OF NOTE 7.a WHICH STATES Note 7.a provides "operational restraints" to use of RBM bypasses.      "OR WHEN A PERIPHERAL CONTROL ROD IS SELECTED" IS The restraint stated as "or when a peripheral control rod is selected" SYSTEM DESIGN AND IS ADDRESSED IN THE ITS BASES THUS is not incorporated in the ITS applicability as noted in the CTS JFC LAI IS APPROPRITAT E FOR THAT SECTIONOF THE NOTE..
markup.
THE PARTOF TABLE 3.2.CNOTE7.c THAT STATES "...AND              10/6/97 3.3.2.1-5    Documentation of RBM operational constraints in Note 7.c related to ONLY ONE OF THESE MAYBE BYPASSED WITH THE the allowance for bypassing only one channel from the console" is CONSOLE SELECTOR" IS A DESIGN FEATURE OF THE SYSTEM not incorporated into ITS Actions A & B as stated.
AND WILLAPPROPRIATELY BE ASSIGNED TO JFC LA2. THE FSAR CURRENTLY STATES "ONE OF THE TWO RBMs CAN BE BYPASSED AT ANYTIME BY OPERATOR ACTION. EffHER RBM CAN INHIBITCONTROL ROD WITHDRAWAL."THE DESIGN PRECLUDES BYPASSING MORE THAN ONE CHANNEL ATATIME. NOTE7.cWILLBEREVISEDTOADDJFCLA2 FLAG TO THE SUBJECT PART.
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I      ~                                                                                              I
                                                                                                  ~ ~                                                        ~                                ~    I
                                                                                                                                                                        ~
                                                                            ~      ~    ~ ~
                                                                                      ~
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION COMMENT ¹                  DESCRIPTION OF ISSUE                                          PROPOSED RESOLUTION                    INCORP Y/N COMPLETE DATE NOTES 8 AND 13 ARE APPLICABLETO SRM, IRM, APRM, AND    Y  10/7/97, 3.3.2.1-8  Both DOCs are applied to this table note which discusml methods RBM FUNCTIONS. THE SRM IRM AND APRM FUNCTIONS for perforining functional tests.
WERE COMPLETELY RELOCATED TO PLANT DOCUMENTS.
THE RBM FUNCTIONS WERE RETAINED IN THE ITS. FOR NOTE 13 THE RELOCATION OF THE DETAILS OF THE FUNCTIONALTEST FOR SRM, IRM, AND APRM FUNCTIONS ARE ADDRESSED BY JFC Rl DUE TO THE TOTAL RELOCATION AND THE SAME IS ADDRESSED BY JFC LA2 FOR THE RBM FUNCTION WHICH JUSTIFKS THE RELOCATION OF THE DETAILS OF PERFORMING THOSE FUNCTIONALS. THUS THE APPLICATION OF BOTH OF THE JFCs TO NOTE 13 IS ACCEPTABLE.
SIMILARLY, JFC Rl ADDRESSES THE RELOCATION OF INSTRUMENT CHECKS FOR THE SRM, IRM, AND APRM FUNCTIONS THE DETAILS OF WHICH ARE DESCRIBED IN NOTE 8. THE DETAILRELOCATION FOR THE INSTRUMENT CHECKS FOR RBM FUNCTIONS ARE ADDRESSED IN JFC R2 RATHER THAN IN LA2 AS INDICTED BY THE FLAGS ON THE NOTE ITSELF (CORRECT IN THE TABLE). THUS THE LA2 FLAG TO NOTE 8 WILLBE CHANGED TO JFC R2.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITfEDTO          N    10/3/97 3.3.2.1-9  The CTS Table 3.2.C, Test interval of RBM CHANNEL THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS OOS          FUNCTIONALTEST (function I) is extended from I month to 92 MARKUPS ARE REQUIRED.
days in ITS SR 3.3.2.1.1, based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2" (MED-32-0286, October 1995).
THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED TO        N    10/3/97 3.3.2.1-10  Adoption of the 6 hour delay time limit for entry into associated THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS OOS        Conditions and Required Actions during perfonnance of required MARKUPS ARE REQUIRED.
SRs is based on the reliability analysis of GENE-770-06-1, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed-Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
PAGE 3
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                            PROPOSED RESOLUTION                      Y/N    DATE THE REQUESTED DOCUMENTATIONWILLBE SUBMITED TO        N  10/3/97 3.3.2.1-1 I The ITS SR 3.3.2.1.2 requirement for a CHANNEL FUNCTIONAL              THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS OOS        TEST is less restrictive because the Surveillance Test is not required MARKUPS ARE REQUIRED.
until I hour after the RWM is required OPERABLE while CTS 4.3.B.3.b. 1 required a test within 8 hours prior to withdrawal of control rods. This is based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement I, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2 (MED-3241286, October 1995).
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO        N  10/3/97 3.3.2.1-12  The ITS SR 3.3.2.1.3 requirement for a CHANNEL FUNCTIONAL              THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS OOS        TEST is less restrictive because the Surveillance Test is not required MARKUPS ARE REQUIRED.
until I hour after the THERMALPOWER is E 10% in MODE2 while CTS 4.3.B.3.b.2 required a test within 8 hours prior to the THERMALPOWER being E 10% in MODE 2. This is based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement I, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2" (MED-324286, October 1995).
JFC L3 WILLBE REVISED TO BETTER DESCMBE THE BASIS          10/10/97 3.3.2.1-13  This DOC discusses extending proposed completion times for            FOR THE CHANGES TO RBM LCO TIME LIMITS.
blocking control rod withdrawal ifone control rod is inoperable.
The proposed changes appear to result in more restrictive operations.
In addition, the justification does not adequately discuss why the proposed change will not result in a significant safety issue for operation  of the plant.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO      N    10/3/97 3.3.2.1-14  The proposed change eliminates CTS 4.3.B.S which requires a            THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS OOS        Functional Test of the Rod Block Monitor (RBM) "prior to              MARKUPS ARE REQUIRED.
withdrawal of the designated rod(s)" during operation with CMFCP or CMFLPD equal to or greater than 0.95 and at least once per 24 hours thereafter is eliminated. ITS Table 3.3.2.1-1 relies on the Functional Test, required every 92 days. This is based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1, October 1988) and an unreferenced BAN report "Technical Specification hnprovement Analyses for Browns Ferry Nuclear Plant, Unit 2," (MED-324286, October 1995.)
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                      Y/N    DATE THE APRM DOWNSCALE TRIP IS ADDRESSED IN TECHNICAL      N  10/10/97 3.3.2.1-15  The APRM, SRM, IRM and scram discharge volume control rod SPECIFICATIONS CHANGE 353S I THIS WAS A SUPPLEMENT blocks prevent a control rod withdrawal error at power transient.
TO TECHNICAL SPECIFICATION CHANGE 353 WHICH WAS TO The CTS Table 3.2.C and Notes 1-6, 8, 10, I I, and 12 and CTS MODIFY THE CTS FOR THE POWER RANGE NEUTRON Table 4.2.C and Notes 13, 15, and 20 requirements are moved to MONITOR UPGRADE AND PROVIDED MARKUPS OF THE plant documents. The justification includes the evaluation PROPOSED ITS FOR THE SAME SUBJECT. BFN IS CURRENTLY summarized in NEDO-31466 and the lack of credit taken for this IN THE PROCESS OF IMPLEMENTINGTHE POWER RANGE feature in design basis accident or tmnsient analysis. NUMAC NEUTRON MONITOR UPGRADE. THE APRM DOWNSCALE PRNM (ARTS) plant-specific changes in Enclosure I, Attachment 2; TRIP WILLBE DELETED AS PART OF THOSE CHANGES. IT deletes the RPS APRM downscale trip. This change is not reflected SHOULD BE NOTED THATA SER HAS ALREADYBEEN in ITS Table 3.3.1.1-1.
PREPARED FOR THE UNIT 2 CHANGES BASED ON THE CTS MARKUP (AMENDMENT249) FOR UNIT 2. CHANGES TO THE ITS SUBMHTAL353S I DUE TO NRC ISSUES BEING ADDRESSED WILLBE MADE AND THE PROPOSED CHANGES RESUBMITTED IN ITS ENTIRITY.
JFC R2 WILLBE REVISED TO PROVIDE ADDITIONAL            Y  10/14/97 3.3.2.1-16  The CTS requires daily instrument channel checks. The STS has no JUSTIFICATION FOR THE RELOCATION OF THE INSTRUMENT equivalent check for the RBM so performance of this test is relocated to plant procedures. Justification for these less restrictive CHANNEL CHECKS.
changes are that they were not already in the STS. The lack of equivalent surveillance in the STS is insufIicient justification for removing the requirement.
3.3.2.1-17  JFC P90 states the intent to implement APRM/RBM tech specs JFC P90 WILLBE EXPANDED TO BETTER EXPLAINTHE          Y  10/15/97 STATUS OF POWER RANGE NEUTRON MONITOR UPGRADE concurrent with installation of the power range neutron monitor IMPLEMENTATION.
upgrade for ARTS. RWE analysis associated with ARTS is credited where applicable and the associated RBM setpoints are flow-biased, rather than power dependent until ARTS hardware is installed. The ITS SRs retain power dependent setpoints. In addition, STS Table 3.3.2.1-1 functions for RBM on IRM upscale, high power range upscale and bypass time delays are deleted. These changes are not sufficiently discussed in P90. Staff approval of proposed ARTS implementation is not adequately documented and it is not obvious from the docketed discussions and markup of ITS that use of power dependent trip setpoints are proposed as stated in P90.
CURRENI'LY TIN RBM UPSCALE BLOCK VALUEIS SPECIFIED    N  10/7/97 3.3.2.1-18  The flow biased RBM upscale block Allowable Value is stated as "less than or equal to the value specified in the COLR." Provide        IN CTS TABLE 3.2.C NOTE 13 WHICH STATES "THE TRIP LEVEL SETTING AND CLIPPED VALUEFOR THIS SEITING documentation of staff approval of cycle dependent AVs for this rod SHALL BE AS SPECIFIED IN THE CORE OPERATING LIMITS block.
REPORT" WHICH DOCUMENTS THE STAFF APPROVAL OF THE CYCLE DEPENDENT Avs.
PAGE 5
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION COMMENT 8                        DESCRIPTION OF ISSUE                                PROPOSED RESOLUTION                  INCORP COhf PLETE Y/N    DATE ISTS-PROBLEM // 53 ITS SR 3.3.2.1.4 HAS A FREQUENCY OF 92 DAYS, WHILETHE BASED ON RMS // R70970605990 THE CALIBRATION          Y  10/16/97 BASES FOR SR 3.3.2.1.4 STATES THE FREQUENCY IS 184    FREQUENCY SUPPORTED BY THE SETPOINT CALCULATION DAYS.                                                IS 92 DAYS AND THUS THE BASES NEEDS TO BE MARKED UP TO SHOW 92 DAYS. NOTE THAT CALCULATIONED-22092-900118, RO, STATES IN SECTION 5.2.2 "ALLDRIFT ALLOWANCES FOR ALLCHANNEL COMPONENTS ARE BASED UPON TECHNICAL SPECIFICATION SURVEILLANCE VALUES...". THE VALUEIN THE CTS IS CURRENTLY 6 MONTHS BUT 3 MONTHS (92 DAYS) WILLBE UTILIZEDTO BE CONSISTENT WITHTHE APRM SURVEILLANCE REQUIREMENTS WHICH ARE THE SAME TYPE INSTRUMENTS.
JFC AS WILLBE DELETED AND JFC M4 ADDED TO ADDRESS THE MORE RESTRICTIVE CHANGE.
PAGE  6
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.2, FEEDWATER AND MAINTURBINE HIGH WATER LEVEL TRIP COMMENT 8                DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                                    INCORP COMPLETE Y/N    DATE THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED                                N  10/20/97 3.3.2.2-1  A new requirement is added to the CTS requiring two channels per TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR trip system of feedwater and main turbine high water level trip ITS MARKUPS ARE REQUIRED.
instrumentation OPERABLE when THERMALPOWER is '25%
RTP. The justification ofACTIONS and SRs is based on GENE-77046-1 (ITS 3.3.2.2, Reference 2).
BFN design for Feedwater and Main Turbine High Water Level Trip            N  10/20/97 3.3.2.2-2  STS Condition A is two or more trip channels inoperable. The Instrumentation is such that there are.two trip systems, each with two-proposed ITS replace this conditon with one or more trip channels out-of -two logic, and each capable of tripping the three feedwater.
inoperable in each trip system. These are equivalent statements.
pump turbines and the main turbine. The NUREG-1433 specification for Feedwater and Main Turbine High Water Level Trip Instrumentation is based on a tw~utwf-three logic trip system as described in the NUREG-1433 Bases. With the BFN design, iftwo feedwater and main turbine high level trip channels are inoperable in the same trip system but the remaining two channels in the other trip system are OPERABLE, Feedwater and Main Turbine High Water Level Trip capability is maintained. Thus, the wording in NUREG-1433, Specification 3.3.2.2, Condition B is inappropriate for BFN, since it would require Condition entry with trip capability maintained.
Proposed ISTS 3.3.2.2, Condition B states "one or more feedwater and main turbine high level trip channels inoperable in each trip system" since in this condition Feedwater and Main Turbine High Water Level Trip capability is lost until the required inoperable channels are restored to OPERABLE status or placed in trip. Similarly, to address the condition where two feedwater and main turbine high level trip channels are inoperable but Feedwater and Main Turbine High Water Level Trip capability is maintained, proposed ISTS 3.3.2.2, Condition A has been changed to require its entry for each inoperable channel (NUREG-1433, Condition A addresses one inoperable channel and proposed ISTS Condition A now addresses one or more inoperable channels).
PAGE 1
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3. 1, POST-ACCIDENT MONITORIN INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                            PROPOSED RESOLUTION                    Y/N    DATE A TSTF IS IN PROCESS. TRAVELLERBWROG-22 IS TRACKING    Y  10/16/97 3.3.3.1-1  Proposed Note 3 is added in conjunction  with table function 6, THE RECOMMENDED CHANGE TO LCO 3.3.3.1 NOTE 2 PCIV isolation position indication. The proposed note would allow  WHICH MODIFIES NOTE 2 "TO ALLOWSEPARATE separate condition entry for each containment penetmtion. The      CONDITION ENTRY FOR EACH PENETRATION" WHICH HAS note is generic change to the STS. Generic changes require a staff THE SAME INPACT AS PROPOSED NOTE 3. THE STATUS OF approved TSTF.                                                      THE TRAVELER IS "UNDER TSTF CONSIDERATION".
SHOULD THE CHANGE NOT BE APPROVED GENERICALLYIT IS BFN's INTENTIONTO JUSTIFY THE CHANGE FROM THE NUREG BASED ON PLANT SPECIFIC NEEDS. BFN CTS DO NOT CONTAIN THIS FUNCTION AND BELIEVES THAT ITS INCORPORATON AS WIUITENWOULD BE OVERLY RESTRICTIVE. JFC P80 WILLBE REVISED TO PROVIDE ADDITIONALJUSTIFICATION FOR THE CHANGE.
JFC A4 WILLBE REVISED TO ADDRESS CHANGING              Y  10/17/97 3.3.3.1-2  A4 does not dicuss the proposed surveillance requirement changes    ONCE/CYCLE TO 18 MONTHS.
from once per operating cycle to once per 18 months.
JFC LS ADDRESSES CHANGE FROM 7 DAYS TO 30 DAYS TO      N    10/17/97 3.3.3.1-3                                                        if CTS Table 3.2.F, Note 7, requires a Special Report one of the ALLOWFOR RESTORATION OF A SINGLE INOPERABLE two monitors is inoperable for more than 7 days. ITS 3.3.3.1      CHANNEL. JFC L6 ADDRESSES REQUIRED ACTIONS IF TWO requires a Special Report within 14 days of one channel being      CHANNELS ARE INOPERABLE. JFC L7 ADDRESSES THE inoperable for more than 30 days (Required ACTION B) or two        CHANGE IN THE SUBMfITALTIME FOR THE SPECIAL channels being inoperable for more than 7 days (Required ACTION REPORT FROM 7 DAYS TO 14 DAYS. TAKENTOGETHER G).                                                                THESE JFCs ADEQUATELYADDRESS THE LESS RESTRICTIVE ASPECTS OF THE INCORPORATION OF TABLE 3.2.F INCORPORATION INTO THE ITS.
THE VALUEOF 184 DAYS (6 MONTHS) IN THE ITS IS          Y    10/17/97 3.3.3.14    The Frequency for the CHANNELCALIBRATIONof CTS Table                CORRECT FOR THE CALIBRATIONFREQUENCY OF THE 4.2.F is 184 days in ITS SR 3.3.3.1.3 for the Reactor Pressure      REACTOR PRESSURE INDICATORS BASED ON PLANT indicators.                                                        SPECIFIC ANALYSIS. THE CTS MARKUP WILL BE REVISED TO CHANGE 18 MONTHS TO 184 DAYS. JFC A4 WILLBE REVISED TO ADDRESS THE EQUIVALENCEOF 184 DAYS TO 6 MONTHS. IN ADDITIONTHE ITS BASES WILLBE REVISED TO ADDRESS THE 184 DAY CALIBRATIONFREQUENCY FOR THE REACTOR PRESSURE INDICATIONINSTRUMENTATION WITH ASSOCIATED JFC P56 BEING REVISED TO JUSTIFY.
JFC L7 WILLBE REVISED TO PROVIDE FURTHER              Y  10/21/97 3.3.3.1-5  ITS 3.3.3.1, REQUIRED ACTION B. 1, increases the submittal        JUSTIFICATION FOR THE LESS RESTRICTIVE CHANGE.
time from within the CTS Table 3.2.F, Note 7, 7 days of exceeding the time limit for an inoperable Primary Containment Area Radiation channel, to within 14 days of exceeding the time limit.
PAGE I
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3.1, POST-ACCIDENT MONITORING INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                                  Y/N    DATE JFC Ml WILLBE REVISED TO PROVIDE REFERENCE TO THE                        Y  10/22/97 3.3.3.14    Additional PAM functions are added to the ITS table. Provide a SER REFERENCES.
revised DOC that includes a reference to the staff SER approving the plant speci fic PAM functions.
The following LA2 DOC is provided in place of the original LA2          Y  9/29/97 3.3.3.1-7  LA2 states the relocated alternate monitoring methods DOC:
requirements are in the Bases and plant procedures. The ITS uses The statement in Note (8) of CTS Table 3.2.F relative to the the PAM Report in Specification 5.6.6 to specifiy the reqirement to initiation of alternate monitoring methods when the Primary establish alternate monitoring methods with the details located in Containment Area Radiation monitors are inoperable has not been ownerwontrolled documentation.
included in proposed ACTIONS of ffS Section 3.3.3.1. However, the requirement for initiation of alternate monitoring is implied by proposed ITS 5.6.6, "PAM Report," which is required to be initiate by proposed ACTIONS B.l and G.l of LCO 3.3.3.1 when inoperable channels have not been returned to operable status within the allowed Completion Times. Proposed      ff8 5.6.6 requires a report to be submitted which outlines the alternate method of monitoring. The proposed 1TS Bases for ACTIONS B. I and G.l of LCO 3.3.3.1 provide additional discussion of proposed Specification 5.6.6 and the initiation of alternate monitoring methods.
THE PROPOSED CHANGE WAS AN ATTEMPT TO BETTER                            Y    10/22/97 3.3.3.1-8    Proposed changes are replace STS "installed control room CLARIFY THE TYPE OF VALVES REQUIRING INDICATIONIN indication channel" with "active PCIV." These are generic changes THE CONTROL ROOM. THE CHANGE WAS NOT TO CHANGE and require staff approval of an industry TSTF. A plant specific THE INTENT OF THE NOTE BUT RATHER TO ASSURE ONLY justification based on operational limitations or design difference THE INTENDED INDICATIONSARE REQUIRED. TI.IUS THE from the STS was not provided.                                      "active PCIV" WILLBE REMOVED FROM THE MARKUP AND "installed control room PAM Category I indication channel" shall replace it. THE PAM CATEGORY I IS TO CLARIFY THE INTENT OF THE NOTE AS IT PERTAINS TO BFN AND THUS JFC Pl I IS APPLICABLETO THE CHANGE.
PAGE 2
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3.2, BACKUP CONTROL SYSTEM INCORP COMPLETE COMMENT 8                DESCRIPTION OF ISSUE                                          PROPOSED RESOLUTION                        Y/N    DATE SINCE THERE ARE NO REQUIREMENTS IN THE CTS TO          Y  10/3 I /97 3.3.3.2-1  The ITS changes SR 3.3.3.2.1 to require channel checks of PERFORM CHANNEL CHECKS FOR BACKUP CONTROL functions that are normally energized and which provide indication INSTRUMENTS AND BFN DOES NOT BELIEVE THATTHIS during normal plant operation. The proposed change represents a ADDITIONBEYOND NORMALINDICATIONOBSERVATION generic change to the STS.
ADDS SIGNIFICANTBENEFIT TO PLANT SAFETY SR 3.3.3.2-1 REQUIRING CHANNEL CHECKS FOR INSTRUMENTATION WILLBE DELETED AND JUSTIFICATION PROVIDED IN A REVISED JFC P30.
PAGE I
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP COMMENT ¹ INCORP COh(PLETE DESCRIPTION OF ISSUE                                            PROPOSED RESOLUTION                    Y/N    DATE JFC  M I WILLBE REVISED TO PROVIDE ADDITIONAL              11/6/97 3.3.4.1-1  New Surveillance Requirements are added to CTS Table 4.2.B.
JUSTIFICATION FOR THE ADDITIONOF THE MORE ITS SR 3.3.4.1.3 requires a CHANNEL CALIBRATIONand a RESTRICTIVE REQUIREMENTS OF SR 3.3.4.1.2 AND SR verification that the Allowable Values are set properly. ITS SR 3.3.4.1.3.
3.3.4.1.2 verifies the bypass capability is properly functioning.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED            N  11/5/97 3.3.4.1-2  The CTS RPT Initiate LOGIC CFIANNEL FUNCTIONALTEST TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        Frequency is changed from I month to 92 days in the ITS. Browns ITS MARKUPS ARE REQUIRED.
Ferry has performed a plant specific evaluation (not referenced) and concluded that this instrumentation is consistent with the GE analysis performed in GENE-77046-1.
THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED            N  11/5/97 3.3.4.1-3  CTS Table 3.2.8, Note 17, allows testing for up to two hours prior TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS          to declaring that the channel INOPERABLE and REQUIRED ITS MARKUPS ARE REQUIRED.
ACTIONS taken. A ITS 3.3.4.1 Surveillance Requirements Note allows testing for up to 6 hours instead of 2 hours.
JFC L2 WILLBE REVISED TO PROVIDE ADDITIONAL                11/6/97 3.3.4.14    CTS Table 3.2.B, Note 17, only allows declaring the system DISCUSSION AND JUSTIFICATION OF THE NOTE TO ITS OOS                                      if inoperable within 72 hours one or more channels are 3.3.4.1 ACTION A.2.
INOPERABLE. This is reflected in ITS 3.3.4.1 REQUIRED ACTION A.l. An option is provided in ITS 3.3.4.1, REQUIRED ACTION A.2, for one or more INOPERABLE channel(s) to place all INOPERABLE channels in the tripped condition within 72 if hours. However, this action would result in system actuation, then declaring the system inoperable per ITS 3.3.4.1, REQUIRED ACTION A. 1, is the preferred action.
JFC L3 WILLBE REVISED TO PROVIDE FURTHER                    11/6/97 3.3.4.1-5  CTS Table 3.2.8, Note 17, requires an orderly power reduction to DISCUSSION OF THE CHANGE FROM IMMEDIATELYTO 2 OOS        be initiated immediately ifboth trip systems are INOPERABLE.
HOURS FOR BOTH TRIP SYSTEMS INOPERABLE.
ITS 3.3.4.1, REQUIRED ACTION B. I, allows 2 hours to restore one trip system to OPERABLE status    ifboth trip systems are INOPERABLE JFC L4 WILLBE REVISED TO ADDRESS APPLICATION OF THE        11/6/97 3.3.4.14    ITS 3.3.4.1.b and REQUIRED ACTION 8.2 add an option to CTS        COLR INCREASE IN MCPR IF EOC-RPT LCO IS NOT MET AS Table 3.2.B to allow increasing the MCPR limit by an appropriate AN ALTERNATEACTION.
amount (specified in the COLR) ifthe instrumentation is INOPERABLE.
PAGE I
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP INCORP COhtPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                          PROPOSED RESOLUTION                    Y/N    DATE JFC P16 WILLBE REVISED TO PROVIDE FURTHER                11/7/97 3.3.4.1-7  STS BASES SR 3.3.4.1.5 statement that bypass valves are to be      JUSTIFICATION FOR THE DEVIATIONFROM THE STS. THE closed during calibration has been deleted in ITS 3.3.4.1. The BASES WILLBE REVISED TO CLARIFY THE INTENT OF THE Bases is modified to state that opening the bypass valves may      DEVIATIONIS TO ONLY DECLARE THE FUNCTIONS affect operability of the Function ifthe valves are open above 30% INOPERABLE WHEN THE BYPASS VALVES ARE OPEN AND RTP. The statement to consider the Function inoperable under      BYPASS OF FUNCTIONS DUE TO RTP OCCURS.
these conditions is deleted in ITS 3.3.4.1.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.4.2, ANTICIPATEDTRANSIENTS WITHOUT SCRAM-RECIRCULATIONPUMP TRIP INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                    Y/N    DATE ITS SR 3.3.4.2.4 adds requirements for LOGIC SYSTEM                    JFC M2 WILLBE REVISED TO PROVIDE ADDITIONAL          Y  11/6/97 3.3.4.2-1                                                                          JUSTIFICATION FOR THE MORE RESTRICTIVE CHANGE.
FUNCTIONALTESTS. Since CTS Table 4.2.L does not specifically require this testing, the addition of this Surveillance is an additional restriction on plant operation.
THE REQUESTED DOCUMENTATIONWILLBE SUBMTTED            N  11/6/97 3.3.4.2-2  The CTS Table 4.2.L ATWS-RPT Initiate LOGIC CHAI4NEL                    TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        FUNCTIONALTEST Frequency is changed from I month to 92                  ITS MARKUPS ARE REQUIRED.
days in ITS SR 3.3.4.2.2. A plant specific evaluation (not referenced) concluded that this instrumentation is consistent with the GE analysis performed in GENE-77046-1.
JFC L2 WILLBE REVISED TO CLARIFYTHE TIME              Y  11/8/97 3.3.4.2-3    CTS Table 3.2.L, Note 2 requires the plant to be in HOT                REQUIREMENTS AND DIFFERENCE BETWEEN MODES.
OOS          SHUTDOWN within 6 hours for the condition of one trip system          REQURED ACTION D.l WAS DELETED BECAUSE BFN IS NOT inoperable for 72 hours or for the condition of both trip systems      LICENSED FOR I LOOP OPERATION AND THEREFORE THE inoperable. ITS 3.3.4.2, REQUIRED ACTION B requires a the              REFERECE IN JFC L2 WILLBE DELETED.
plant to be in STARTUP within 6 hours for the condition of one ATWS trip function inoperable for 72 hours. ITS 3.3.4.2 Action C allows I hour to restore the ATWS-RFI'rip capability for one function prior to initiating action to be in STARTUP. The CTS to ITS changes related to conditions of inoperability based on trip system vice trip function arc not discussed in DOC L.2. The additional hour to repair the condition of both trip systems inoperable is not discussed in DOC L.2. The different shutdown track, to Mode 2 in the ITS vice Mode 3 in the CTS is not discussed in L.2. Finally, DOC L.2 discusses the option to remove the associated recirculation pump from service, yet this option was not adopted in thc proposed ITS.
THE CTS MARKUP WILLBE REVISED TO SHOW JFC Ll TIED    Y    11/8/97 3.3.4.24    CTS Table 3.2.L, Note 2 provides a 6 hour AOT for channel repair TO THE PORTION A NOTE 2 DEALINGWITH CHANNEL before the channel must be declared inoperable or placed in trip.
OPERABILITYAND JFC LI WILLBE REVISED TO PROVIDE The DOC M.l is used to justify the change to this CTS                  SPECIFIC DETAILOF THE CHANGES.
requirement. The L.l DOC is the appropriate.
JFC P50 WILLBE REVISED TO PROVIDE JUSTIFICATION      Y  11/8/97 3.3.4.2-5    STS SR 3.3.4.2.1 is modified in ITS SR 3.3.4.2.1 to apply only to the Reactor Vessel Water Level-Low Function. This, in effect, deletes the CHANNEL CHECK of the Reactor Steam Dome Pressure. This change is not justified.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                            PROPOSED RESOLUTION                    Y/N    DATE THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l.        10/20/97 3.3.5.1-1  The Unit I CTS Table 4.2.B calibration frequencies of 3 months A GENERIC RESPONSE THAT STATES MAKINGUNIT I OOS        for Reactor Low Water Level, Reactor Low Pressure, and Reactor      CONSISTENT WITH UNITS UNIT2 8'c 3 IS DONE FOR High Water Level functions are not consistent with Units 2 and 3    CONSISTENCY AND THAT THE UNIT I TECHNICAL with a interval of 18 months for level and 6 months for pressure. SPECIFICATIONS WILLBE VERIFIED CORRECT PRIOR TO These frequencies are reflcctcd in ITS Table 3.3.5.1-1 for Unit I as UNIT I STARTUP. THIS WILLBE A COMMITMENTTO the same as those in the ITS for Units 2 and 3. The change to the REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO Unit I Surveillance test interval is justified as "willbe validated  REVISION OF THE SUBMITTALSHOULD BE REQUIRED.
prior to Unit I recovery."
THE REQUESTED DOCUMI:NTATIONWILLBE SUBMITTED          N    10/20/97 3.3.5.1-2  An allowed out of service time (AOT) for testing of 6 hours is      TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        added to CTS Table 3.2.B. ITS 3.3.5.1, SR Note 2, allows 6 hours ITS MARKUPS ARE REQUIRED.
for testing prior to entry into associated Conditions and Required Actions.
THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED          N    10/20/97 3.3.5.1-3  The CTS Table 3.2.B, Note I.A, AOT for repair, which allows TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        placing CS, LPCI, and HPCI channels in trip or restoring the        ITS MARKUPS ARE REQUIRED.
channel to OPERABLE status, remains at 24 hours for all Functions except the minimum flow Functions, and is extended to 7 days for the minimum flow Functions in ITS Table 3.3.5.1-1.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED          N    10/20/97 3.3.5.14    The AOT for placing ADS channels in trip, or to restore the TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        channel to OPERABLE status, is extended to 96 hours ifHPCI or ITS MARKUPS ARE REQUIRED.
RCIC is also INOPERABLE, or 8 days ifboth HPCI and RCIC are OPERABLE.
THE REQUESTED DOCUMENTATIONWILLBE SUBMBTED            N  10/20/97 3.3.5.1-5  The CHANNEL FUNCTIONALTEST frequency (STI) is extended              TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        to once per 92 days from monthly.                                    ITS MARKUPS ARE RE UIRED.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM INCORP COhtPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                                    Y/N    DATE JFC DOC    Ll has been revised to delete the reference to Required      Y  11/19/97 3.3.5.14    ITS 3.3.5.1, REQUIRED ACTIONS B.3, D.2.1, and F.2, are added        Action D.2.1. This action has been addressed in JFC P81 as not being to CTS Table 3.2.B, Note I, to allow placing an inoperable channel applicable at BFN. JFC LB1 provides the discussion of the changes in the tripped condition rather than declaring the associated      made to the CTS Action A and incorporated into O'S as Actions B, C, supported feature inoperable. This compensates for the inoperable D, F, and G. The action repair AOTs are based on NEDC-30936.
status of the channel, restores the single failure capability and provides the required initiation capability of the instrumentation.
Therefore, providing this option does not impact safety. However, ifthis action would result in system actuation, then declaring the system inoperable is preferred.
Required Action D.2.1 is deleted by JFC P81. DOC L.l is incomplete in that it does not identify and discuss the difference between the CTS requirements of Action A and the proposed replacement actions in the ITS, Actions B, C, D, F, and G. The Action repair AOT in the STS are based on NEDC-30936.
THE REQUESTED DOCUMENTATIONWILLBE SUBMTITED                            N    10/20/97 3.3.5.1-7    ITS Table 3.3.5.1-1, Functions I.c and 2.c required actions are    TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR changed from STS 3.3.5.1, Required Action C. I to Required          ITS MARKUPS ARE REQUIRED.
Actions B.l for Modes 1,2 and 3. ITS 3.3.5.1, RA C.l requires restoring channel to operable status within 24 hours. ITS 3.3.5.1, RA B. 1 requires placing channel in trip after 24 hours. The changes to the Required Action from restoring operabiltiy to placing the channel in trip is not justified and deviates from the CTS and from the STS. Bases insert B3.3-101A states that there are two reactor steam dome pressure (permissive) transmitters per system arranged in a one<ut-of-two logic. The required channels column in Table 3.3.5.1-1 is 4 The STS is based on the staff approved Topical Report NEDC-30936.
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t BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM INCORP COMPLETE COMMENT 8                    DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                                        Y/N      DATE As stated in JFC P35 manual initiation channel requirements have              N  11/20/97 3.3.5.1-8    The STS 3.3.5.1, REQUIRED ACTION G. I, Note that describes            been deleted for the ECCS syatems, ADS, RCIC, PCIVs, and SCIVs.
APPLICABILITYfor functions 4.c, 4.e, 4.f, 4.g, S.c, S.e, S.f, and    P35 provided clarification that appropriate STS Notes have been S.g is deleted. Justification for deleting the APPLICABILITYfor      revised to remove any reference to manual initiation channel ITS Table 3.3.5.1-1, functions 4.g, and S.g only is presented. No    requirements.
justification for deleting the APPLICABILITYfor functions 4.c,        Various BFN FSAR Sections describe manual isolation capability, 4.e, 4.f, S.c, S.e, and S.f is given.                                however, the design is such that a single switch in the logic cannot initiate the ECCS system or subsystem. As stated in the NUREG Manual initiation channel requirements are deleted because these    Bases for the Manual Initiation Function, there is no speci fic FSAR channels are not currently required at BF and because single switch safety analysis that takes credit for the Function. Based on the above logic design does not exist at BF. The staff requires the manual    and that the CTS does not include requirements for the manual initiation functions.                                                initiation functions, BFN maintains the exclusion of the manual functions from the ITS.
See response to Item 3.3.5.14. The CTS has been revised to add a              Y    11/19/97 3.3.5.1-9    CTS Action A is changed to ITS Action B, C, D, F, and G. In the JFC flag which justifies the Changed action.
ITS format CTS Action A is only equivalent to Action C.
As stated in JFC P59, CTS does not require a channel check for                N    11/20/97 3.3.5.1-10    Channel check requirements are not adopted from the STS because      these. Based on this, BFN maintains the exclusion of the channel they are not current licensing basis requirements.                    check r uirement for these functions from the ITS.
Footnote (e), ffS Table 3.3.5.1-1, has been revised to clarify that a        Y    11/20/97 3.3.5.1-1 I  Proposed footnote (e) clarifies the trip system channel assignments.
relay corresponds to a trip system.
The footnote discussed relays without providing a connection to the TS requirement for required channels per function.
ISTS Function 2.g was not included in ITS, as discussed in JFC P82,          N    11/19/97 3.3.5.1-12  The Rev.A submittal stated LPCI low flow bypass function is not      since TVA has an analysis that proves that the LPCI pumps have the included because the analysis assumptions willacheive rated capability to provide the required flow to the vessle with the injection with the bypass valve open.                                            flow valve in the open position . Since this analysis did not
                                                                                                                                                    'inimium cause any licensing documentation to change, it was not sent to the NRC for their review. This analysis can be made available for stafl review.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED                                  N  10/20/97 3.3.5.1-13    NEDC-30936 is incorporated by refeince TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE RE UIRED.
The CTS tables have been revised to depict the corresponding ITS            Y    I 1/19/97 3.3.5.1-14    The core spray low level (function l.a) and the HPCI level 8          Table 3.3.5.1-1 functions I.a and 3.c.
(function 3.c) are proposed iSTS functions that have no corresponding CTS table entry.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM COMMENT &#xb9; INCORP COMPLETE DESCRIPTION OF ISSUE                                          PROPOSED RESOLUTION                                  Y/N    DATE The LA1 DOC has been revised to clarify that the values in the CTS    Y  11/19/97 3.3.5.1-15  The LA.I DOC discusses relocating trip setpoints to owner heading "Trip Level Settings" are equivalent to allowable values.
documents and retaining the CTS Alloivable Values in the ITS. TVA's methodology for determination of setpoints utilizes the CTS For this CTS table the "trip level settings" column is simply "Trip Level Settings" as the allowable value in establishing the renamed "Allowable Value" in the ITS format. The Allowable nominal trip setpoint. The selection of nominal trip setpoints plus Values do not exist in the CTS.
associated inaccuracies ensures the "Trip Level Settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 which endorses ISA Std ISA467.04-1982 "Setpoint For Nuclear Safety Related Instrumentation Used in Nuclear Power Plants" and has been reviewed by the NRC in previous submittals, e.g. NRC Letter to Mr. Oliver D. Kingsley dated Jan 2, 1991, Issuance of Amendment TAC No. 77279            S 291 .
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                                    Y/N    DATE BFN agrees with the comment. The original DOC A. I I for proposed            9/30/97 3.3.6.1-1  CTS Table 3.2.A, Note 15, defines the Reactor Building              ISTS 3.3.6.1 has been designated as not used and the CTS markup of Ventilation Radiation (RBVR) trip functions for the refueling zone  CTS Table 3.2.A Note 15 (for Units I and 3) and Note 14 (for Unit 2) and the reactor zone as each being composed of two divisional trip  has been revised to reference markup for proposed ISTS 3.3.6.2 and systems with each trip system having one channel which contains    3.3.7.1.
two sensors, both of which must be OPERABLE. ITS Table 3.3.6.1-1 depicts each trip system as having two channels, meaning each sensor is considered a channel.
The justification for change documented a change to ITS Table 3.3.6.1-1, when the change was implemented in ITS Table 3.3.7.1-
: 1. The RBVR trip functions are located in ITS Table 3.3.7.1-1 not 3.3.6.1-1.
The CTS markup of Unit I Table 4.2.A for the Reactor Water                    10/20/97 3.3.6.1-2  The RWCU Temperature functions in CTS Table 4.2.A for Unit I        Cleanup System high temperature functions has been revised to are not consistent with those listed in CTS Table 4.2.A for Units 2  reference DOC A13 for the change in calibration frequency and 3. The Unit I CTS Table 4.2.A calibration frequency of these    requirements. The original CTS marhwp of Unit I Table 3.2A and functions is an operating cycle versus 4 months for Units 2 and 3. 4.2.A provided reference to DOC A12 for the difference between the However, ITS Table 3.3.6.1-1 for Unit I is consistent with Units 2  Unit I versus the Unit 2 and 3 Reactor Water Cleanup System high and 3.                                                              temperature functions. The following generic response is provided in reference to DOC A12 and A13:
The change modifies the Unit I action requirements without identifying what changed and without presenting a safety            THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l.
justification for proposed requirements.                            A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 4 3 IS DONE FOR CONSISTENCY AND THATTHE UNIT I TECHNICAL SPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMITMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION PROPOSED RESOLUTION                                INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                                                                      Y/N    DATE The CTS marhwp of Unit I Table 4.2.A for the Reactor Water                  10/20/97 3.3.6.1-3  The Unit I CTS Table 4.2.B calibration frequencies for the RCIC Cleanup System high temperature functions has been revised to OOS        and HPCI Turbine Steam Line Low Pressure functions are 3 reference DOC A13 for the change in calibration frequency months. This is not consistent with the 18 month interval of Units 2 requirements. The original CTS marhwp of Unit I Table 3.2.A and and 3. These frequencies are included in ITS SR 3.3.6.1.5 a 18 4.2A. provided reference to DOC A12 for the difference between the month intervals for all units.
Unit I versus the Unit 2 and 3 Reactor Water Cleanup System high temperature functions. The following generic response is provided in The change is presented as a administrative change rather than a reference to DOC A12 and A13:
less restrictive change of the surveillance testing of Unit I.
THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l.
A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY AND THAT THE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT 1 STARTUP. THIS WILLBE A COMMITMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART.
The comment is believed to be addressing the Unit I RCIC and HPCI      N  10/20/97 3.3.6.14    The Unit I CTS Table 4.2.B CHANNEL CHECK requirements for Turbine Steam Supply Low Pressure and Turbine Exhaust Diaphragm the RCIC and HPCI Turbine Steam Line High Flow and Exhaust High Pressure functions rather than the RCIC and HPCI Steam Line Diaphragm High Pressure functions are daily. These Unit I High Flow and Turbine Exhaust Diaphragm High Pressure functions CHANNEL CHECKS are deleted from ITS Table 3.3.6.1-1.
(Unit I CTS Table 4.2.B requires a channel check of the RCIC and HPCI Steam Supply Low Pressure functions but not the RCIC and The change is presented as a administrative change rather than a HPCI Turbine Steam Line High Flow functions). The following less restrictive change of the surveillance testing of Unit l.
generic response is provided:
THIS IS A GENERIC QUESTION ON HOW TO HANDLE UNIT I.
A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY AND THATTHE UNIT I TECHNICAL SPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMfIM1NTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMfITAL SHOULD BE RE UIRED.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENT ISOLATION COMMENT &#xb9;                  DESCRIPTION OF ISSUE                                          PROPOSED RESOLUTION                    INCORP Y/N COMPLETE DATE SEE A1TACHMENT I FOR RESPONSE .                      N  9/29/97 3.3.6.1-5  The CTS Table 3.2.A, Note I, Action for ITS Table 3.3.6.1-1, Functions 2.a (Reactor Low Water Level) and 2.b (High Drywell Pressure) and the corresponding Group 2 initiating logic requires Table 3.2.A, Note 1.A actions (initiate an orderly shutdown...) or Note I.B actions (to initiate an orderly load reduction and have the MSLs isolated) along with Note I.E actions (to initiate primary containment isolation within 24 hours).
The ITS Table 3.3.6.1-1, REQUIRED ACTIONS A. I (Place channel in trip within 12 hours), B. I (Restore isolation capability within I hour), and G.l (Be in MODE 3 in 12 hours), for these Functions are consistent with the STS. CTS Table 3.2.A, Note I, does not include the ITS 3.3.6.1, REQUIRED ACTION G.l.
This change deletes the CTS Table 3.2.A, Note I.E Action and adds the third option of ITS 3.3.6.1 REQUIRED ACTION G.l.
This is a less restrictive change that was addressed as a more restrictive change.
THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED          N  9/30/97 3.3.6.1-6  The allowed out of service time (AOT) for placing a channel in trip TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        when one trip system has inoperable, untrippcd channels, as ITS MARKUPS ARE REQUIRED.
defined in CTS Table 3.2.A, Note I, is extended from immediate to 12 hours in ITS 3.3.6.1, REQUIRED ACTIONA. I, for those channels common to RPS, and 24 hours in ITS 3.3.6.1, REQUIRED ACTION A.2, for all other channels. A justification for this AOT extension was not provided.
The AOTs for placing a channel in trip for required surveillance testing is defined in CTS Table 3.2.A, Note 11, and is extended from 4 hours to 6 hours in ITS 3.3.6.1, Surveillance Requirements Note 2. A justification for this AOT extension was not provided.
The monthly CHANNEL FUNCTIONALTEST Surveillance Test Interval (STI) in CTS Table 3.2.A is extended in ITS SR 3.3.6.1.2, to once per 92 days. Ajustification for this STI extension was not provided.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCORP COhIPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                                  Y/N    DATE The CTS markup, CTS page 3.2/4.2-22 (Unit 3) and page 3.2/4.2-23        Y  10/20/97 3.3.6.1-7  ITS 3.3.6.1, REQUIRED ACTION F. I allows I hour to isolate the (Units I &2), has been corrected to show that the CTS Table 3.2.B, affected Reactor Water Cleanup (RWCU) penetration flow path(s),
Note I.E action is equivalent to proposed ISTS Required Action A.l.
whereas CTS Table 3.2.A, Note I.C, requires immediately isolating the RWCU valves and CTS Table 3.2.B, Note I.B requires immediately declaring the HPCI/RCIC inoperable.
Note E markup for Table 3.2.B deletes the allowance to place the channel in trip. Note E marhwp should show that the option to repair the channel or place it in trip is equivalent to ffS Action A.l.
The CTS markup for Unit I and DOC A12 indicate that the Unit I          N  10/20/97 3.3.6.1-8  The RWCU Temperature functions in CTS Table 4.2.A for Unit I CTS RWCU Space Temperature High functions are different than the are not consistent with those listed in CTS Table 4.2A for Units 2 Unit 2 and 3 CTS RWCU Space Temperature High functions. DOC and 3. The Unit 1 functions temperature functions use the RWCU A12 also indicates that the proposed ISTS for Unit I is made floor drain temperature and RWCU space temperature. Units 2 and  consistent with the proposed ISTS for Units 2 and 3 and that the 3 uses 6 area space temperatures.
differences willbe resolved prior to Unit I recovery. The NUREG-1433 markup addresses the six area space temperatures for BFN (with The STS assumes six space temperatures. This deviation from the Unit I considered the same as Units 2 and 3 as addressed in DOC STS was not addressed. However some discussion was provided in A12) and provides JFC PI I for changes between the proposed ISTS the justification for an administrative change. The justification and NUREG-1433:Based on the above, the following generic indicated that the diflerences would bc addressed before Unit I response is provided:
recovery.
THIS IS A GENERIC QUESTION ON HOW TO HANDLE UNIT l.
A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY AND THAT THE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMTMENTTO REVIEW UNIT 1 TECH SPECS PRIOR TO RESTART. NO REVISION OF TI.IE SUBMITTAL SHOULD BE RE URED.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCOR P COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                    PROPOSED RESOLUTION                                      Y/N      DATE The LAI DOC willbe revised to clarify that the values in the CTS            N    11/8/97 3.3.6.1-9    System design and opemtional details found in CTS Tables 3.2.A,        heading "trip level settings" are equivalent to Allowable Values.
OOS          3.2.B, and 4.2.a, are moved to the ITS Bases and plant procedures      The CTS "trip level settings" are equivalent to ISTS "Allowable Trip setpoints are an operational detail not directly related to the  Values". TVA's methodology for determination of setpoints utilizes operability of the instrumentation. The Allowable Value is the        the CTS "trip level settings" as the allowable value in establishing the required limitation of the parameter and this value is retained in    nominal trip setpoint. The selection of nominal trip setpoints plus ITS Table 3.3.6.1-1.                                                  associated inaccuracies ensures the CTS "trip level settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 The LA.I DOC discusses relocating trip setpoints to owner              which endorses ISA Standard ISA467.04-1982 "Setpoints for Nuclear documents and retaining the CTS Allowable Values in the ITS.
Safety Related Instrumentation Used in Nuclear Power Plants" and For this CTS table the "trip level settings" column is simply          has been reviewed by the NRC in previous submittals, e.g. NRC letter renamed "Allowable Value" in the ITS format. The Allowable            to Mr. Oliver D. Kingsley dated January 2, 1991, Issuance of Values do not exist in the CTS.                                        Amendment TAC No. 77279              S291 .
The CTS markup for Unit I, on CTS page 3.2/4.243, has been                      10/20/97 3.3.6.1-10  Details of the methods for performing surveillances found in CTS      revised to replace the LA.2 DOC reference with a LB. I DOC Table 4.2.A, are moved to the ITS 3.3.6.1 Bases and plant              reference for the change in functional test frequency for the RWCU procedures.                                                            floor drain and space temperature high functions.
CTS markup on page 3.2/4.243 RWCU floor drain and Space Temperature high should be LB.1 NOT la.2 The BFN design is such that manual isolation capability is provided        N    10/20/97 3.3.6.1-1 1  Proposed change delete manual initiation functions and                as indicated in FSAR 7.3.3 Safety Design Bases 10 and discussed in "automatic" from loss of isolation capability action because the FSAR 7.3.4.5 (discussion of the fulfillmentof Safety Design Bases functions are not current requirements and single switch isolation is 10). However, the BFN design docs not include handswitches in the not consistent with the BFN design. The staff position is that        logic for generation of primary containment isolation signals. Manual manual actuation capability was a licensing basis of the design and    isolation of the PCIVs is typically accomplished by means of without which the design would not be meet regulatory design          handswitches for the individual PCIVs. In addition to these normal criteria. The absence of CTS manual requirements is an oversight      means of manual isolation, typically other means are available to which should be corrected. Further, current TS logic testing          initiate the required isolations (i.e., removal of power for normally requirements require a complete test of the circuitry including the    energized logic, etc.). As stated in the NUREG Bases for the Manual manual actuation functions.                                            Initiation Functions, their is no specific FSAR safety analysis that takes credit for the Functions. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion of the manual functions from the ISTS.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                  PROPOSED RESOLUTION                                    Y/N    DATE The NUREG-1433 marhwp for the RWCU Isolation Temperature                  Y  10/20/97 3.3.6.1-12  RWCU isolation functions are added to the current TS functions.
Functions (NUREG-1433, 3.3.6.1, Functions S.b and S.c) has been The SRs proposed include the same SRs as the CTS RWCU leve 3 revised to address the proposed changes in SRs. As indicated in the isolation except a 122 day channel calibration is proposed and no marhwp, the change to 122 day channel calibration is addressed in JD channel check is included.
P42 and the absence of the channel check requirement is addressed in JD P59. Also, as indicated in response to Question 3.3.6.1-2, the CTS marhwp of Unit I Table 4.2.A for the Reactor Water Cleanup System high temperature functions has been revised to reference DOC A13 for the change in calibration frequency requirements. The original CTS markup of Unit I Table 3.2.A and 4.2.A provided reference to DOC A12 for the difference between the Unit I versus the Unit 2 and 3 Reactor Water Cleanu S tcm hi tern erature functions.
SEE ATTACHMENT3 FOR RESPONSE                                              N  10/20/97 3.3.6.1-13  Proposed ITS markup is not identical to the CTS bypass allowance.
CTS provide the bypass for conditions of normal steam tunnel ventilation becoming inoperable. The proposed ITS provides an allowance to bypass the trip of Function I.d (Main Steam Tunnel Temperature High) for conditions of loss of trip capability.
The Reactor Vessel Water Level - Low, Level 3 Function has been            Y  10/26/97 3.3.6.1-14  Deleted TS for RHR shutdown cooling isolation in Modes 4 and 5.
added as Function 6.b to the proposed ISTS 3.3.6.1. The proposed Licensee agreed to revise the ITS to include the isolation functions applicability for this Function is Modes 3, 4, and 5. Necessary changes to the CTS Markups, DOCs, NUREG-1433 markup, and JDs have been made to su      rt this chan e.
The intent of the referenced statement in DOC A.7 is to indicate that    N    10/20/97 3.3.6.1-15  The CTS note requires the affected system to be declared it is unnecessary to create a Required Action F.2 (logically connected inoperable a(ter closing the RHR shutdown cooling isolation by AND to the proposed Required Action F. I) which would state that valves. The justification states "an action requiring the affected the aIfected system must be declared inoperable. The addition of such system to be declared inoperable is an unnecessary reminder that an action would be a deviation from the format of NUREG-1433 for other TS may be affected.
this Condition and would be an unnecessary reminder of proposed LCO 3.0.1. Proposed LCO 3.0.1 requires LCOs to be met during the MODES or other specified conditions in the Applicability. For example, proposed ISTS 3.0.1 would require proposed LCO 3.4.7, RHR Shutdown Cooling System - Hot Shutdown, to be met during its Applicability. Thus, ifduring the Applicability of proposed LCO 3.4.7 the RHR Shutdown Cooling Isolation Valves were isolated to comply with proposed ISTS 3.3.6.1 Required Action F. 1, proposed LCO 3.0.2 would r uire the Re uired Actions of ro sed LCO 3.4.7 to be met.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                                  INCORP COMPLETE Y/&#xc3;    DATE SEE ATTACHMENT2 FOR RESPONSE.                                          Y  10/20/97 3.3.6.1-16  Proposed Action F. I requires the licensee to isolate the affected penetration flow path for specific HPCI and RCIC functions rather than declare the system or component inoperable. ITS Action A. 1 requires the channel to be tripped in 24 hours vice the CTS requirement to repair the channel in 24 hours.
The difference between the trip versus repair actions is not discussed.
3.3.6.1-19  Evaluate the marhwp for revision. Deleted text is retained in ITS.
The text which was marked as deleted addressed the option to place      Y  10/20/97 the inoperable channel(s) in trip. This option is equiva! ent to the DOC discussion is missing for deleted text.
actions in proposed ISTS Required Action A.l. Therefore, the CTS marhwp, CTS page 3.2/4.2-22 (Unit 3) and page 3.2/4.2-23 (Units I k2), has been corrected to add back the previously deleted text in CTS Table 3.2.B, Note I.E.
THIS MORE RESTRICTIVE CHANGE IS CONSIDERED TO BE                        N  9/29/97 3.3.6.1-20  CTS 3.2.A requires primary containment isolation instrumentation ACCEPTABLE SINCE THE ANTICIPATEDDURATION AND OPERABLE when primary containment integrity is required. CTS FREQUENCY OF BEING IN MODE 2, NOT CRITICALAND <212 3.7.A.2.a, primary containment integrity is required OPERABLE at all times when the reactor is critical or when the reactor water
                                                                                'F, IS VERY SHORT AND INFREQUENCT AND WILLAHVE NO ADVERSE IMPACT ON THE OPERATION OF THE UNIT. THIS temperature is above 212'F and fuel is in the vessel. The ITS 3.3.6.1 Applicability for most functions is MODES I, 2, and 3.
CHANGE IS CONSISTENT WITH NUREG-1433.
This is more restrictive since CTS 3.7.A.2.a, does not require the primary containment integrity when in MODE 2, not critical and    (
212'F. This change is consistent with the STS.
The justiiflication did not justify adding the Applicability for (
212F.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION ATTACHMENT          1 RESPONSE TO ISSUE 3.3.6.1-5
 
===RESPONSE===
CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions specifies when the rcquircd channels are not met for one trip system and the function is not tripped or when the required channels cannot bc met for all trip systems that one of thc following actions must bc taken: 1) the reactor .
placed in the COLD SHUTDOWN CONDITION in 24 hours; OR 2) the operator initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours.
Proposed ISTS LCO 3.3.6.1 Required Actions for Reactor Vessel Water Level - Low, Level 3 and Diywell Pressure-High Functions require these channels when inoperable to be placed in trip in 12 hours (proposed LCO 3.3.6.1 Required Action A. I) and ifnot tripped within 12 hours or ifinitiation capability is lost and not restored in I hour (proposed LCO 3.3.6.1 Required Action B.l) the reactor to be in Mode 3 in 12 hours and Mode 4 in 36 hours (proposed LCO 3.3.6.1, Condition G).
The less restrictive 12 hour allowance for tripping channels is addressed in DOC LB I for proposed ISTS LCO 3.3.6.1.
The replacement of the CTS requirement to initiate required actions when the required channels are not met for all trip systems with the less restrictive proposed ISTS requirement to initiate required actions within 1 hour when initiation capability is lost is addressed in DOC Ll for proposed ISTS LCO 3.3.6.1. The less restrictive change from the CTS allowed 24 hours to 36 hours before being required to be in Cold Shutdown is addressed in DOC L2 for proposed ISTS LCO 3.3.6.1. The additional requirement to be in Mode 3 in 12 hours is addressed in DOC Ml for proposed ISTS LCO 3.3.6.1. The deletion of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours is addressed in DOC M3 for proposed ISTS LCO 3.3.6.1. BFN maintains that the additional requirement to be in Mode 3 in 12 hours and the deletion of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours e and primary containment isolation initiated within 24 hours are morc restrictive changes as further discussed in the folloiving.
When inoperable channels arc not tripped in thc allowed out of service time, proposed LCO 3.3.6.1, Required Action G. I will require a reactor shutdown in 12 hours where the CTS would allow power operation to continue past 12 hours provided the reactor could be placed in Mode 4 in 24 hours. Under the proposed ISTS iftwo channels of Reactor Vessel Water Level - Low, Level 3 or two channels of Drywell Pressure - High in the same trip system were inoperable and not tripped (automatic isolation capability lost) the reactor would be required to be shutdown in 13 hours (I hour for Completion time of proposed ISTS Required Action B. I plus 12 hours for Completion time of proposed ISTS Required Action G. 1). Under the same conditions the CTS would allow power operation to continue past 13 hours provided the reactor could be placed in Mode 4 in 24 hours. Ifa single channel of Reactor Vessel Water Level - Low, Level 3 or Drywell Pressure - High werc inoperable and not tripped both the CTS (first option) and proposed ISTS would require the reactor to bc shutdown to the specified Mode in 24 hours (for the CTS, 24 hours to be in Mode 4 per Table 3.2.A Note 1.A; for the ISTS, 12 hours for allowed out of service time (proposed ISTS Required Action A.l) plus 12 hours to be in Mode 3 (proposed Required Action G.l)). Under these conditions the extended allowed out of service time results in the proposed ISTS being slightly less restrictive since under thc CTS the reactor would have to be shutdown at some point prior to expiration of the 24 hour completion time in order to cool down to Cold Shutdown conditions. As indicated above, the less restrictive 12 hour allowance for tripping channels is addressed in DOC LBI for proposed ISTS LCO 3.3.6.1, and overall, the additional requirement to be in Mode 3 in 12 hours (proposed LCO 3.3.6.1, Required Action G. I) is morc restrictive.
The CTS option requiring the operator initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours (Option 2) does not require a shutdown of the reactor. The CTS option requiring the reactor be placed in the COLD SHUTDOWN CONDITION in 24 hours (Option
: 1) as well as the proposed ISTS shutdown requirements would allow power generation longer than CTS Option 2 (Main Stcam Lines could be maintained open longer than 8 hours). Thus, comparing the options to one another there are more restrictive and less restrictive aspects associated with both options. However, since the shutdown requirement is maintained (and the addition of proposed LCO 3.3".6.1, Required Action G. I is overall more restrictive as discussed above) the deletion of Option 2 reduces operation flexibilityand is thus more restrictive.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION ATTACHMENT2 RESPONSE TO ISSUE 3.3.6.1-16
 
===RESPONSE===
CTS Table 3.2.B, Note 1.A requires the specific HPCI and RCIC Function channels to be repaired in 24 hours. Ifthe channels are not repaired in 24 hours, CTS Table 3.2.B, Note 1.B is entered which requires the system or component to be declared inoperable. Proposed ISTS LCO 3.3.6.1 Required Action A. I requires these channels when inoperable to be restored to OPERABLE status or tripped in 24 hours. IfRequired Action A. 1 and its associated Completion Time is not met, proposed ISTS LCO 3.3.6.1 Required Action F.1 is entered for the functions as directed by proposed ISTS Table 3.3.6.1-1. Proposed ISTS LCO 3.3.6.1 Required Action F. 1 requires the affected penetration flow path(s) to be isolated in one hour. The change in the subsequent actions required when thc initial allowed out of service time is not met (i.e., change from the CTS action of declaring the system or component inoperable to the proposed ISTS action of isolating the aflected penetration flow path) is addressed in DOC M8. Relative to the initial required actions, the addition of the option to trip the inoperablc channels in lieu of repairing them is a less restrictive change and is addressed in DOC L7.
Based on the above, the difference between the trip versus repair actions is discussed in the appropriate DOC (i.e.,
DOC L7) and no revision to the M8 DOC is required. The original DOC L7 indicated that proposed ISTS Required Action A. I allows an inoperable channel to be placed in the tripped condition rather than declaring the associated supported feature inoperable. Since the CTS action of declaring the associated supported feature inoperable has been replaced with proposed ISTS Required Action F. I, DOC L7 has been revised to indicate that proposed ISTS Required Action A. I allows an inoperable channel to be placed in the tripped condition rather than restored to OPERABLE status.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION ATTACHMENT3 RESPONSE TO ISSUE 3.3.6.1-13 SPONSE:
The inclusion of Function l.d (Main Steam Line Space Temperature - High) in the list of "other than Functions" in the second Completion Time for proposed ISTS 3.3.6.1 Required Action A.1 was in error and has been deleted. With Function 1.d included in the list of "other than Functions" in the second Completion Time for proposed ISTS 3.3.6.1 Required Action A.1, no requirement existed to place inoperable Function l.d channels in trip when 14 or less Function I.d channels were OPERABLE. Relative to the CTS allowance for bypass of the Main Steam Tunnel Temperature High Function for conditions of normal stcam tunnel ventilation becoming inoperable, BFN maintains the proposed ISTS incorporates this allowance without additional relaxations. CTS Table 3.2.A, Note 12, states that in the event that normal ventilation is unavailable in the main steam line tunnel, the high temperature channels may be bypassed for a period of not to exceed four hours. In the proposed ISTS 3.3.6.1, when multiple Function I.d channels are inoperable such that isolation capability for Function I.d is not maintained, proposed Required Action B. I is entered. The proposed ISTS 3.3.6.1 Required Action B. I Completion Time, is 1 hour OR 4 hours for Function l.d when normal ventilation is not available. The proposed Bases for this Required Action clarifies this second completion time by stating it is provided to allow the plant to avoid an MSL isolation transient when recovering from a temporary loss of ventilation in the MSL tunnel area (e.g., during performance of the secondary containment leak rate tests). Thus, when proposed Required Action B. 1 is cntercd for Function 1.d, four hours are allowed to restore isolation capability ifthe Function 1.d channels were made inoperable to avoid an MSL isolation transient due to a temporary loss of ventilation in the MSL tunnel area. Ifthe Function I.d channels were inoperable with normal ventilation to the MSL tunnel area available, the second completion time of proposed ISTS 3.3.6.1 Required Action B. 1 would not apply and only I hour would be allowed to restore isolation capability. As indicated in DOC LA3, the compensatory actions associated with CTS Table 3.2.A, Note 12 have been incorporated into thc proposed Bases for ISTS 3.3.6.1 Required Action B.l.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COh(PLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                                      Y/N    DATE CTS 3.2.A combined with CTS 3.7.A.2.a, Primary Containment,          THIS MORE RESTRICTIVE CHANGE IS CONSIDERED TO BE                            N  9/27/07 3.3.6.2-1 requires primary containment integrity at all times when the reactor ACCEPTABLE SINCE THE ANTICIPATEDDURATIONAND is critical or when the reactor water temperature is above 212F      FREQUENCY OF BEING IN MODE 2, NOT CRITICALAND and fuel is in the vessel. ITS Table 3.3.6.2-1 requires the          <212'F, IS VERY SHORT AND INFREQUENT AND WILLHAVE secondary containment isolation instrumentation OPERABLE in          NO ADVERSE IMPACT ON THE OPERATION OF THE UNIT.
MODES 1, 2, and 3. Since the CTS does not require primary            THIS CHANGE IS CONSISTENT WITH NUREG-1433.
containment integrity when in ITS 3.3.6.2 MODE 2 conditions of not critical and < 212'F, this is a more restrictive change . No ustification is rovided for this more restrictive chan e.
3.3.6.2-2  CTS 3.7.A.2.a does not require primly containment integrity          The AS DOC was incorrect and the proposed change is a more                      CHECK "while performing 'open vessel'hysics tests at power levels not to  restrictive change. The AS DOC has been deleted and replaced with              WITH exceed 5 MW(t)." ITS 3.3.6.2 does not contain this exception.        the following M3 DOC:                                                          OPS  &
The justification is based on the provisions of ITS 3.0.8, which                                                                                    MECH indicates Special Operations in ITS 3.10 allow changing specified  CTS 3.7.A.2.a allows "Open Vessel" physics testing at power levels TS requirements. However ITS 3.10 does not address "open            not to exceed S MW(t). The proposed ISTS does not include Vessel" physics tests.                                              provisions for this activity, therefore this change is more restrictive.
BFN is past the point in plant life where this type of testing would be performed. This change is consistent with the BWR Standard Technical S ecifications, NUREG 1433.
3.3.6.2-3  ITS 3.3.6.2, SR Note 2, deletes "secondary containment" from STS    The words "secondary containment" have been added back to                  Y    10/20/97 SR Note 2.                                                          proposed ISTS 3.3.6.2, Condition B, Required Action B.l, and SR Note 2.
ITS 3.3.6.2, ACTION B modifies STS 3.3.6.2 ACTION B by removing the words "secondary containment".
The changes werc made based on being unnecessary since they are a art of the title for ITS 3.3.6.2.
PAGE I
 
e BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT 8                  DESCRIPTION OF ISSUE                                          PROPOSED RESOLUTION INCORP COMPLETE Y/N    DATE CTS Table 3.2.A, for Reactor Low Water Level and High Dryweil        SEE ATI'ACHMENTI FOR RESPONSE        5/29/97 3.3.6.24 Pressure, for less than the minimum required OPERABLE channels, provides the options when ACTION Note I are met.
These option are: I) place the reactor in cold shutdown in 24 hours (ACTION Note I.A) or 2) initiate a load reduction and isolate the Main Steam Lines within 8 hours (ACTION Note I.B) and initiate primary containment isolation within 24 hours (ACTION Note I.E). For the same Functions ITS 3.3.6.2, Required Actions C.l. I, C.1.2, C.2.1 and C.2.2, do not require entering cold shutdown or isolating the Main Steam Lines but, provide options, when Required Actions A. I and B. I arc not met, allowing isolation of the affected lines (zones) and starting the affected SGT subsystems (ITS 3.3.6.2 Required Actions C.l. 1 and C.2.1). Ifthis option is not chosen, then the affected components must be declared inoperable (ITS 3.3.6.2, Required Actions C.1.2 and C.2.2).
No justification, based upon safety analyses, is provided for deleting the CTS requirement to shutdown or isolate the Main Steam Lines.
CTS Table 3.2.A and Table 4.2.A provide separate ACTIONS and          SEE ATTACHMENT3 FOR RESPONSE.        10/20/97 3.3.6.2-5 SRs for Secondary Containment Isolation Instrumentation initiating and isolation logic (Reactor Building Isolation Logic, SGTS Trains A, B, and C Logic and Group 6 Logic). ITS 3.3.6.2 deletes the Reactor Building Isolation and SGTS Logic functions (including ACTIONS) and incorporates the SRs required by the CTS for these functions into required SRs of ITS Table 3.3.6.2-1. The discussion and justification does not demonstrate that 1TS Required Actions and SRs encompass the CTS Required Actions and SR for the logic functions.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                      Y/N    DATE 3.3.6.2-6  ITS 3.3.6.2 SR 3.3.6.2.2, CHANNEL FUNCTIONALTEST,                    THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED            N  9/30/97 extends the Surveillance Test Interval for the CTS Table 4.2.A      TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR Channel Functional Tests from monthly to once per 92 days.          ITS MARKUPS ARE REQUIRED.
ITS 3.3.6.2, Required Action A, extends the time in CTS Table 3.2.A, ACTION I, for tripping an inoperable channel from immediately to 12 hours for those channels common to RPS and 24 hours for all other channels.
ITS 3.3.6.2, SR Note 2, extends the Allowed Outage Time for performing surveillances in CTS Table 3.2A, Note 11, from 4 to 6 hours.
These changes are based on maintaining an acceptable risk in accordance with previously conducted reliability analysis (NEDC 30851-P-A, Supplement 2, March 1989 and NEDC-31677-P-A, Jul 1990 . This is an extension of Allowed Outa e Time.
3.3.6.2-7    ITS 3.3.6.2, Required Actions C.1.2 and C.2.2, add ACTIONS to        SEE ATTACHMENT2 FOR RESPONSE                              9/29/97 CTS Table 3.2A that require declaring the associated systems if inoperable within I hour secondary containment isolation or starting the SGT System is not possible or desired. The addition of more restrictive requirements is not administrative. Additionally, no ustification is rovided for the I hour corn letion time.
ITS 3.3.6.2, SR Note 3, extends the Allowed Outage Time for          THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED            N    9/30/97 3.3.6.2-8                                                                        TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR performing surveillances in CTS Table 3.2.A, Note 11, from 4 to 6 hours for a CHANNEL FUNCTIONALTEST. These changes are                ITS MARKUPS ARE REQUIRED.
stated to be based on maintaining an acceptable risk in accordance with previously conducted reliability analysis (NEDC 30851-P-A, Supplement 2, March 1989 and NEDC-31677-P-A, July 1990).
This is an extension of Allowed Outa e Time.
ITS Table 3.3.6.2-1, Functions I and 2, Reactor Vessel Water        THIS IS A GENERIC QUESTION ON HOW TO HANDLE UNIT l. N    9/29/97 3.3.6.2-9                                                                        A GENERIC RESPONSE THAT STATES MAKINGUNIT 1 Level - Low and Dr@veil Pressure - High, respectively, increase the CTS Table 4.2.A Unit I CHANNEL CALIBRATIONSurveillance              CONSISTENT WITH UNITS 2 4 3 IS DONE FOR CONSISTENCY Test Interval, for the same functions, from 3 montlis to 18 months. AND THATTHE UNIT I TECHNICAL SPECIFICATIONS WILL This change is implemented to make the Unit I ITS be consistent      BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS with Units 2 and 3 ITS. This is an extension of Surveillance Test  WILLBE A COMMffMENT TO REVIEW UNIT I TECH SPECS Interval for Unit I is not justified.                              PRIOR TO RESTART. NO REVISION OF THE SUBMITTAL SHOULD BE RE UIRED.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                  PROPOSED RESOLUTION                                        Y/N    DATE 3.3.6.2-10  CTS Table 4.2.A does not require an Instrument Check for the          Since a channel check is not currently required by the CTS for the          N  10/20/97 High Dryweil Pressure Function. ITS Table 3.3.6.2-1, Function 2,      High Drywell Pressure function, the proposed SR 3.3.6.2.1 channel Drywell Pressure - High, requires SR 3.3.6.2.1, CIIANNEL              check requirement has been deleted for proposed ISTS 3.3.6.2, CHECK every 24 hours. No justification is provided for adding        Function 2, Dryweil Pressure - High. The proposed ISTS Tables this surveillance test or deviating from the ISTS test frequency. 3.3.6.2-1, NUREG markup, and JD P59 have been revised to address this chan e.
3.3.6.2-1 1 The Completion Time for STS 3.3.6.3, Required Action A.l, is 12      THE REQUESTED DOCUMENTATIONWILLBE SUBMI1TED                                  N  9/30/97 hours for Function 2 and 24 hours for the other Functions. ITS        TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR 3.3.6.2, Required Action A. I, modifies the Completion time to 12    ITS MARKUPS ARE REQUIRED.
hours for Functions I and 2 and 24 hours for the other Functions.
This change is based on NEDC-30851-P-A, Supplement 2, March 1989, NEDC-31677-P-A, July 1990 and GENE-77046-1, February 1991.
ITS 3.3.6.2 adds SR Note 3 to STS 3.3.6.2 Surveillance Notes. ITS    THE REQUESTED DOCUMENTATIONWILLBE SUBMfITED                                  N  9/30/97 3.3.6.2-12 3.3.6.2, SR Note 3, allows one inoperable channel of the Reactor    TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR Zone and Refueling Zone Exhaust Radiation System for up to 6          ITS MARKUPS ARE REQUIRED.
hours for CHANNEL FUNCTIONALTESTING and for up to 24 hours for CHANNEL CALIBRATIONand maintenance as long as the downscale trip of the inoperable channel is placed in the tripped condition. The CTS provides the same allowance except only 4 hours is allowed for the CHANNEL FUNCTIONALTEST.
Extending 4 hours to 6 hours is based on reliability analyses in NEDC-30851-P-A NEDC-31677-P-A and GENE-77046-1.
CTS 3.2 and 4.2 System design and operational details are moved      The LA1 DOC willbe revised to clarify that the values in the CTS            N    11/8/97 3.3.6.2-13 to the ffS 3.3.6.2 Bases and plant procedures.                        heading "trip level settings" are equivalent to Allowable Values.
The CTS "trip level settings" are equivalent to ISTS "Allowable Trip setpoints are an operational detail not directly related to the  Values". TVA's methodology for determination of setpoints utilizes operability of the instrumentation. The Allowable Value is the        the CTS "trip level settings" as the allowable value in establishing the required limitation of the parameter and this value is retained in    nominal trip setpoint. The selection of nominal trip setpoints plus ITS Table 3.3.6.2-1.                                                associated inaccuracies ensures the CTS "trip level settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 The LA.I DOC discusses relocating trip setpoints to owner            which endorses ISA Standard ISA-S67.04-1 982 "Setpoints for Nuclear documents and retaining the CTS Allowable Values in the ITS.        Safety Related Instrumentation Used in Nuclear Power Plants" and For this CTS table the "trip level settings" column is simply        has been reviewed by the NRC in previous submittals, e.g. NRC letter renamed "Allowable Value" in the ITS forinat. The Allowable          to Mr. Oliver D. Kingsley dated January 2, 1991, Issuance of Values do not exist in the CTS.                                      Amendment TAC No. 77279 TS291 .
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8                DESCRIPTION OF ISSUE                                                    PROPOSED RESOLUTION                                      Y/N    DATE 3.3.6.2-14  Proposed change delete manual initiation functions and                The BFN design is such that manual isolation capability is provided          N  10/20/97 "automatic" from loss of isolation capability action because the      as discussed in FSAR 5.3.3.1, 5.3.3.2, 7.3.3 Safety Design Bases 10, functions are not current requirements and single switch isolation is and 7.3.4.5. However, the BFN design is such that a single switch in not consistent with the BFN design. The staff position is that        the logic can not initiate the secondary containment features in even manual actuation capability was a licensing basis of the design and  one division. Sepamte handswitches are provided for the inboard without which the design would not be meet regulatory design          refueling zone isolation logic systems, outboard refueling zone criteria. The absence of CTS manual requirements is an oversight      isolation logic systems, each inboard reactor zone isolation logic which should be corrected. Further, current TS logic testing          system, each outboard reactor zone isolation logic system, and each of requirements require a complete test of the circuitry including the  the three SGT Train Logic Systems. In addition to these normal means manual actuation functions.                                          of manual isolation, typically various other means are available to initiate the required features (i.e., removal of logic power, utilization of handswitches for individual dampers, etc.). As stated in the NUREG Bases for the Manual Initiation Function, their is no specific FSAR safety analysis that takes credit for the Function. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion of the manual functions from the ISTS.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION ATTACHMENT I FOR ISSUE 3.3.6.2-4
 
===RESPONSE===
The same Reactor Vessel Water Level - Low, Level 3 and D~vell Pressure - High channels and initiation portions of logic arc used in Primary Containment Isolation, Secondary Containmcnt Isolation, and CREV System Initiation. Based on the commonality of the instruments, the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) provides the required actions for this instrumentation. However, the required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation. In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the affects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure - High Functions require the reactor to be in the COLD SHUTDOWN CONDITION in 24 hours OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. The compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure - High Functions require these channels when inoperable to be placed in trip in 12 hours (proposed LCO 3.3.6. 1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 12 hours or ifinitiation capability is lost and not restored in 1 hour: 1) thc reactor to be in Mode 3 in 12 hours and Mode 4 in 36 hours (proposed LCO 3.3.6.1, Condition G);
: 2) in I hour isolate the associated SC zone or declare associated SCIVs inoperablc AND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3) in I hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E).
As evident from the above compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell ressurc - High Functions, the requirement to shutdown the reactor has not been deleted and is maintained in proposed ISTS CO 3.3.6.1 since this is the appropriate required action for loss of primary containment isolation capability from these unctions. Dclction of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours, the change from the CTS allowed 24 hours to 36 hours before being required to be in Cold Shutdown, and the additional requirement to bc in Mode 3 in 12 hours arc addressed in DOCs for proposed ISTS LCO 3.3.6.1. Other changes from thc CTS requirements (such as the 12 hour allowance for tripping channels, etc.) are addressed in DOCs for proposed ISTS LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1.
Based on the above and comment resolution for Comments 3.3.6.2-7, 3.3.7.1-1, 3.3.7.1-2, and 3.3.7.1-5, BFN proposes that deletion of the CTS requirements for Reactor Vessel Water Level - Low, Lcvcl 3 and Drywell Pressure - High Functions arc best described as an administrative change in the CTS markup and DOCs for proposed ISTS 3.3.6.2. Therefore, DOC L2 has been deleted, DOC A11 has been created to address the deletion of the CTS requirements for Reactor Vessel Water Level-Low, Level 3 and Drywell Pressure - High Functions, and DOC M2 has been created to address the addition of proposed ISTS LCO 3.3.6.2, Condition C requirements for Reactor Vessel Water Level - Low, Level 3, Drywell Prcssure - High, and Refueling Floor Exhaust Radiation - High Functions.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION ATTACHMENT2 FOR ISSUE 3.3.6.2-7
 
===RESPONSE===
Since CTS Table 3.2.A Note 1.G is not applicable to Reactor Vessel Water Level - Low, Level 3, Drywell Prcssure - High, and Refueling Floor Exhaust Radiation - High Functions, proposed ISTS 3.3.6.2, Required Actions C.1.2 and C.2.2 as well as Required Actions C.l. I and C.2.1 are new requirements for proposed ISTS 3.3.6.2 Functions I, 2, and 4. Proposed DOC M2 has been created to address this more restrictive change.
Since CTS Table 3.2.A Note 1.G is applicablc to Reactor Zone Exhaust Radiation - High Function, proposed DOC A6 is still applicable to proposed ISTS 3.3.6.2 Functions 3. However, the original DOC A6 was incorrect. Currently, reactor shutdown per CTS I.C.1 would be required ifthe required action to isolate the reactor building and start the standby gas treatment system (CTS Table 3.2.A Note 1.G) could not be performed. Under the proposed ISTS with the SCIVs and standby gas treatment system declared inoperable both proposed ISTS LCO 3.6.4.2 Condition C and LCO 3.6.4.3 Condition D would require the reactor to be shutdown. Specifically, proposed ISTS LCO 3.6.4.3 Required Action D. 1 would require proposed ISTS LCO 3.0.3 to be entered immediately. Changes in the generic shutdown LCO (CTS I.C. I changes relative to the proposed ISTS LCO 3.0.3) arc addressed in DOCs for proposed ISTS Section 3.0. Since both the CTS and proposed ISTS would require reactor shutdown, the addition of the actions of proposed ISTS 3.3.6.2, Required Actions C.1.2 and C.2.2 are considered administrative for proposed ISTS 3.3.6.2 Functions 3. However, the added 1 hour completion time for declaring the equipment inoperable is less restrictive. DOC A6 and Ll have been revised to reflect the above.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION ATTACHMENT3 FOR ISSUE 3.3.6.2-5
 
===RESPONSE===
The CTS markup for the logic systems have been revised to indicate the changes from the CTS actions. Justification for these changes are provided as indicated in DOC L2, L3, L4, and M2. DOC A8 has been revised to provide additional discussion and justification for the bases of considering the ISTS Required Actions and SRs for the channels and Functions encompass required actions and surveillances for the logic systems. The revised DOC A8 provides the following discussion:
When a logic system is discovered to be inoperable, the proposed LOGIC SYSTEM FUNCTIONALTEST Surveillance Requirement is not met, and thus, the proposed ISTS LCO is not met per proposed SR 3.0.1.
The proposed Bases for the LOGIC SYSTEM FUNCTIONALTEST Surveillance Requirements state that these tests demonstrate the OPERABILITYof the required isolation logic for a specific channel. Thus, each channel which can not perform the required initiation function through the logic system is declared inoperable for the associated feature and the proposed ISTS Conditions and Required Actions for the inoperable channels are entered. For example, when one of the three SGT Train Logic Systems is inoperable, all of the channels for proposed ISTS 3.3.6.2 Functions 1, 2, 3, and 4 would be declared inoperable for the associated SGT subsystem since all of the channels input through logic to the inoperable SGT Train Logic System. Under these conditions proposed ISTS Required Action A. I would require the logic system to be restored to OPERABLE status in 12 hours based on the 12 hour Completion Time for Functions 1 and 2 and that in affect the channels can not be placed in trip. Under these conditions proposed ISTS Condition B would not be entered since the Functions would still be maintaining initiation capability for two SGT subsystems. Ifthe inoperable SGT Train Logic System was not restored to OPERABLE status in 12 hours, proposed ISTS Condition C would be entered which would require in one hour the associated SGT subsystem to be placed in operation or declared inoperable. Ifin the above example two of the three SGT Train Logic Systems were inoperable, the required actions would be the same except that proposed ISTS Condition B would be entered which would require in one hour at least one of the inoperable SGT Train Logic Systems to be restored to OPERABLE status or Condition C entered.
Since the action for an inoperable logic system will require all channels affected by the inoperability to be declared inoperable and the Required Actions for the inoperable channels taken, and since the impact on safety from a logic system being inoperable due to a logic system failure is no more severe than a logic system being inoperable due to failure of its input channels, the potential 12 hour allowed out of service times for the logic systems is address in DOCs LB1.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM                                .
PROPOSED RESOLUTION            INCORP COMPLETE COMhKNT 8                  DESCRIPTION OF ISSUE                                                                            Y/N    DATE SEE ATfACHMENTI TO THIS LIST FOR PROPOSED      Y  9/30/97 3.3.7.1-1  The CTS Actions for ITS Functions I and 2 require the operator to RES OLUITION.
initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours or initiate primary containment isolation within 24 hours ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. The O'S requirements for these functions is to trip inoperable channels in 12 hours or declare the associated CREV subsystem inoperable I hour from discovery of loss of trip capability in both trip systems.
DOC A.2 does not address all of the proposed changes to CTS requirements. Administrative justifications cannot not be proposed for less restrictive changes.
SEE ATTACHMENTI TO THIS LIST FOR PROPOSED      Y  9/30/97 3.3.7.1-2  The CTS Actions for ITS Function 3 require the operator to isolate RES OLUITION.
the reactor building and start the SGTS immediately ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.
The CTS Actions for ITS Function 4 prohibit fuel handling and all operations over spent fuel and open reactor wells ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.
The ITS requirements for these functions is to trip inoperable channels in 12 hours or declare the associated CREV subsystem inoperable I hour from discovery of loss of trip capability in the trip system.
DOC A.2 does not address all of the proposed changes to CTS requirements. Administrative justifications cannot not be proposed for less restrictive changes.
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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                    INCORP COMPLETE Y/N    DATE SEE ATTACHMENT3 TO THIS LIST FOR PROPOSED              N  9/30/97 3.3.7.1-3  For two inoperable channels CTS require a functional test of the RESOLUTION particulate and radiation monitors once per shift. In addition, CTS actions provide a description of the use of these alarms for high radiation conditions. The required actions for failure to repair at least one channel in 30 day is ITS Action E. 1(place the CREV in operation). The CTS requires taking the actions specified in section 3.1.E.
Changes to the CTS Action 3.1.E are not identified and not evaluated.
The Unit I CTS Table 4.2.A calibration frequency for the High        THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT I. N  9/30/97 3.3.7.14 OOS        Dwell Pressure function is changed from 3 months to 18 months        A GENERIC RESPONSE THAT STATES MAKINGUNIT I in ITS Table 3.3.1.1-1 Functions 3, 4 & 6 to duplicate the less      CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY restrictive frequencies of Units 2 & 3 CTS Table 4.2A. The            AND THATTHE UNIT I TECHNICALSPECIFICATIONS WILL change is printed as an administrative change resulting in ITS        BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS Table 3.3.7.1-1, Function 2, rather than as a less restrictive change WILLBE A COMMIMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITAL SHOULD BE RE UIRED.
SEE ATTACHMENT2 TO THIS LIST FOR PROPOSED                  9/30/97 3.3.7.1-5  ITS 3.3.7.1, REQUIRED ACTION E. 1 allows the option of placing RESOLUTION.
CREVS in the pressurization mode of operation. CTS Table 3.2.A, Note I, does not allow this option. Required Action E. I is more restrictive on CTS page 3.2/4.2-12 and Requirol Action E is less restrictive on page 3.2/4.2-34.
The addition  of a less restrictive change is not more restrictive.
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e BFN ITS NRC COMMENT PROPOSED RESOLUTIONS 0
SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM INCORP COMPLETE COMMENT 4                  DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                                  Y/N    DATE THE REQUESTED DOCUMENTATION%ILLBE SUBMITTED                                  9/30/97 3.3.7.14    The allowed out of service time (AOT) for placing a channel in trip TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS        when one trip system has inoperable, untripped channels, is ITS MARKUPS ARE REQUIRED.
defined in CTS Table 3.2.A, Note I, is extended from immediate to 12 hours in ITS 3.3.7.1, REQUIRED ACTION B.2, for those channels common to RPS, and 24 hours in ITS 3.3.7.1, REQUIRED ACTION C.2; for all other channels.
The AOTs for placing a channel in trip for required surveillance testing is defined in CTS Table 3.2.A, Note 11, and is extended from 4 hours to 6 hours in ITS 3.3.7.1, Surveillance Requirements Note 2.
The CHANNEL FUNCTIONALTEST Surveillance Test Interval (STI) in CTS Table 3.2.A, is extended in ITS SR 3.3.7.1.2, to once per 92 days from monthly.
The DOC annotation for the Functional Test interval change from              9/30/97 3.3.7.1-7  CTS Table 4.2.G, Note I, calls for a Control Room Air Supply        monthly to 92 days for the Control Room Air Supply Duct Radiation Duct Radiation Monitor FUNCTIONALTEST once per month.                Monitors was not provided in the CTS markup of the Unit 3 CTS ITS Table 3.3.7.1-1 only requires a 92 day test interval. This    Table 4.2.G and uus incorrectly indicated as DOC A3 in the CTS change is not justified.                                            markup of the Unit I and 2 CTS Table 4.2.G. This change is based on the analyses of GENE-77046-1. Thus, the appropriate DOC for this change is DOC LB I. The CTS marhwp of the Unit I, 2, and 3 NOTES FOR TABLES 4.2.A THROUGH 4.2.L EXCEPT 4.2.D AND 4.2.K (includes the notes for CTS Table 4.2.G) correctly provided the DOC LBI annotation to the change in Note 1. Based on the above, the CTS markup of Table 4.2.G for Units I, 2, and 3 have been revised to rovide reference to DOC LBI for the chan e in Functional Test STI.
SEE ATTACHMENT4 FOR RESPONSE 3.3.7.1-8  ITS Functions 3 and 4 are shown to have one trip system with two channels. CTS Table 3.2.A Note (15) to Action G states these functions are comprised of two divisional trip systems with one channel in each zone and 2 sensors in each channel.
Explain the apparent discrepancy between the CTS and ITS required number of trip systems. Less restrictive changes proposed for the ITS are not administrative.
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BFN ITS NRC COMMENT'ROPOSED RESOLUTIONS SECTION 3.3.7. 1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM 0                                                    ATTACHMENT 1 ISSUE 3.3.7.1-1 & 3.3.7.1-2 RESPONSE
 
===RESPONSE===
The following DOC A.2 revision is provided to address all the proposed changes to CTS requirements for the Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions.
The same Reactor Vessel Water Level - Low, Level 3, Drpvell Pressure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High channels and initiation portions of logic are used in Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation (proposed ISTS 3.3.7.1 Functions 1, 2, 3, and 4 for CREVS). Based on the commonality of the instruments, the CTS Table for Control Room Isolation Instrumentation (CTS Table 3.2.G, Note 3) refers to the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) for required actions associated with this instrumentation. The required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation, In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the afFects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions require thc reactor to be in the COLD SHUTDOWN CONDITION in 24 hours OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours if and primary containment isolation initiated within 24 hours the required channels are not met for one trip if system and the function is not tripped or the required channels cannot be met for all trip systems. The compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure-High Functions require these channels when inoperable to be placed in trip in 12 hours (proposed LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 12 hours or ifinitiation capability is lost and not restored in 1 hour: 1) the reactor to be in Mode 3 in 12 hours and Mode 4 in 36 hours (proposed LCO 3.3.6.1, Condition G)<
: 2) in 1 hour isolate the associated SC zone or declare associated SCIVs inoperable AND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3) in 1 hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E). The less restrictive 12 hour allowance for tripping channels is addressed in DOC LB1 for proposed ISTS LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1. The replacement of the CTS requirement to initiate required actions when the required channels are not met for all trip systems with the less restrictive proposed ISTS requirement to initiate required actions within 1 hour when initiation capability is lost is addressed in DOCs for proposed ISTS LCO 3.3.6.1 and 3.3.6.2; however, since CTS Table 3.2.A does not require the CREV system to be declared inoperable or placed in operation the requirement to take these actions when initiation capability is loss is more restrictive and is addressed in DOC Ml of this section. Deletion of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours, the change from the CTS allowed 24 hours to 36 hours before being required to bc in Cold Shutdown, and the additional requirement to be in Mode 3 in 12 hours are addressed in DOCs for proposed ISTS LCO 3.3.6.1. The changes associated with LCO 3.3.6.2, Condition C are addressed in DOCs for proposed ISTS LCO 3.3.6.2. The added requirements associated with the CREV System are addressed in DOC Ml of this section...
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                                  ~
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT2 ISSUE 3.3.7.1-5 RESP.ONSE
 
===RESPONSE===
The same Reactor Vessel Water Level - Low, Level 3, Drywell Pressure - High, Reactor Zone Exhaust Radiation High, and Refueling Floor Exhaust Radiation - High channels and initiation portions of logic are used in Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation (proposed ISTS 3.3.7.1 Functions 1, 2, 3, and 4 for CREVS).
Based on the commonality of the instruments, the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) provides thc required actions for this instrumentation. However, the required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation. In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the affects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Dtywell Pressure - High Functions require the reactor to be in the COLD SHUTDOWN CONDITION in 24 hours OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours and primary containment isolation initiated within 24 hours ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. CTS Table 3.2.A actions for Reactor Zone Exhaust Radiation - High Function require the operator to isolate the reactor building and start the SGT immediately ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. CTS Table 3.2.A actions for Refueling Floor Exhaust Radiation High Function prohibit fuel handling and all operations            over  spent    fuel and  open  reactor  wells  if the  required    channels  are not met for one trip system and the function        is  not tripped  or if  the required    channels    cannot  bc  met  for  all trip  systems. Thc compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and D~vcll Pressure High Functions require these channels when inoperablc      to be  placed    in trip in  12  hours  (proposed    LCO    3.3.6.1,  3.3.6.2,  and  3.3.7.1)  and ifnot tripped within 2 hours or  if initiation capability    is lost and  not  restored  in  1  hour:  1)  the reactor  to bc in  Mode    3  in 12  hours and Mode 4 in 36 urs (proposed    LCO  3.3.6.1,  Condition      G); 2) in  1  hour  isolate  the  associated    SC  zone  or declare    associated  SCIVs inoperable ND place  SGT  in operation    or  declare    SGT  inoperable    (proposed    LCO    3.3.6.2,  Condition    C);  and  3)'in  1 hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E). The compiled proposed ISTS requirement for Reactor Zone Exhaust Radiation - High and Refueling Floor Exhaust Radiation High Functions require these channels when inoperable to be placed in trip in 24 hours (proposed LCO 3.3.6.2 and 3.3.7.1) and ifnot tripped within 24 hours or ifinitiation capability is lost and not restored in 1 hour: I) in 1 hour isolate the associated SC zone or declare associated SCIVs inoperable AND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C) and 2) in I hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E).
As evident from the above, for Reactor Vessel Water Level - Low, Level 3, D~vcll Prcssure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High Functions the proposed ISTS adds requirements that the CREV system be declared inoperable or placed in operation as well as maintains requirements relative to reactor shutdown (for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High) and isolation of the associated SC zones and placement of the SGT in service (for Reactor Zone Exhaust Radiation - High). The replacement of the CTS requirement to prohibit fuel handling and all operations over spent fuel and open reactor wells with the proposed LCO 3.3.6.2, Condition C requirements for the Refueling Floor Exhaust Radiation - High Function is addressed in DOCs for proposed ISTS LCO 3.3.6.2 and is unrelated to thc addition of the requirements for the CREV system (Other changes to CTS requirements are addressed in DOCs for proposed ISTS LCO 3.3.6. 1, 3.3.6.2, and 3.3.7.1). Based on the above, the added requirements to place the associated CREV subsystem in service or declare the associated CREV subsystem inoperable are more restrictive changes for proposed ISTS 3.3.7.1 Functions I, 2, 3, and 4 and these changes are appropriately addressed in DOC Ml and markup of CTS pages for CTS Table 3.2.A.
As indicated in DOC Ml, for proposed ISTS 3.3.7.1 Function 5 the requirement to declare the associated CREV subsystem inoperable when at least one Function 5 channel is not returned to OPERABLE status in the allowed out of service time currently exists in Note (2) of CTS Table 3.2.G. This discussion in DOC Ml is intended to exclude Ml applicability to proposed ISTS 3.7.1 Function 5. Since the CTS currently requires the associated CREV subsystem to be declared inoperable when at least one unction 5 channel is not returned to OPERABLE status in the allowed out of service time, the option of placing the associated CREV subsystem in operation is less restrictive for proposed ISTS 3.3.7.1 Function 5 and is addressed in DOC Ll and markup of page 3.2/4.2-34 (Units 1 and 2) and page 3.2/4.2-33 (Unit 3). DOC Ll has been revised to indicate that it is only less
                                                                                                                                                              'TS restrictive for proposed ISTS 3.3.7.1 Function 5.
PAGE 5
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT3 ISSUE 3.3.7.1-3 RESPONSE
 
===RESPONSE===
The CTS Table 3.2.G, Note 2 requirement for functional test of the particulate and radiation monitors once per shift when two channels of Control Room Air Supply Duct Radiation Monitors are inoperable and the description of the use of these alarms for high radiation conditions is captured by proposed ISTS LCO 3.3.7.1, Required Action D.2 and its associated Bases. The proposed ISTS Bases for Required Actions D.2 state: "... an allowed outage time of 30 days is provided to restore at least one channel to OPERABLE status provided that the alternate monitoring capability is verified functional once per 12 hours. The alternate monitoring capability is provided by the control room particulate monitor (RM-90-53) and radiation monitor (RE-90-8). These monitors alarm in the control room on high activity. Upon receipt of these alarms, the operator is required to manually isolate the control room and manually initiate the emergency pressurization system". The use of a 12 hour frequency for proposed ISTS LCO 3.3.7.1, Required Action D.2 is equivalent to the CTS requirement since CTS Table 1.1 defines the surveillance frequency of shift as at least once per 12 hours.
The CTS required actions for failure to repair at least one channel in 30 days is to declare the system initiated by these monitors inoperable and take action as specified in CTS section 3.7.E. The proposed ISTS required actions for failure to repair at least one channel in 30 days is to place the associated CREV subsystem(s) in the pressurization mode of operation (proposed ISTS LCO 3.3.7.1, Required Action E. 1) OR Declare associated CREV subsystem inoperable (proposed ISTS LCO 3.3.7.1, Required Action E.2). The addition of the ISTS proposed option to place the associated CREV subsystem(s) in the pressurization mode of operation (proposed ISTS LCO 3.3.7.1, Required Action E. 1) is less estrictive for Function 5 and is addressed by DOC Ll. Ifthe ISTS proposed option to place the associated CREV bsystem(s) in the pressurization mode of operation is not performed, both the CTS and proposed ISTS would require both CREV subsystems to be declared inoperable under these conditions. With both CREV subsystems declared inoperable under the current Technical Specifications, CTS LCO 3.7.E, Control Room Emergency Ventilation, would be entered (with a CREV subsystem declared inoperable entry into CTS LCO 3.7.E would be required even without the CTS Table 3.2.G Note 2 direction to enter CTS LCO 3.7.E). With both CREV subsystems declared inoperable, CTS LCO 3.7.E.I (requirement for two CREV subsystems to be OPERABLE) would not be met, and thus, CTS LCO 3.7.E.4 would require reactor shutdowns to be initiated and all reactors to be in COLD SHUTDOWN within 24 hours for REACTOR POWER OPERATIONS and refueling operations to be terminated within 2 hours (the other two CTS LCO actions in CTS 3.7.E, CTS LCO 3.7.E.2 and 3.7.E.3, address required results from surveillance tests and AOT for one CREV subsystem inoperable). With both CREV subsystems declared inoperable under the proposed ISTS, proposed ISTS LCO 3.7.3, CREV System, would be entered as applicable on each Unit. Proposed LCO 3.7.3, Required Action D. I for each Unit in MODE 1, 2, or 3 would require immediate entry into proposed ISTS LCO 3.0.3 (generic LCO for reactor shutdown), and proposed LCO 3.7.3, Condition E for each unit in process of movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, or OPDRVs would require suspension of these in process activities. Since CTS Table 3.2.6, Note 2 and proposed ISTS 3.3.7.1 both provide for declaring the CREV subsystems inoperable under these conditions and rely on the CREV System LCOs to address further actions, the changes between CTS LCO 3.7.E and ISTS LCO 3.7.3 when both CREV subsystems are declared inoperable are not addressed in the markups for proposed ISTS section 3.3.7.1. However, as evident from the above, the CTS and proposed ISTS required actions for both CREV subsystem inoperable are similar, and the changes between CTS LCO 3.7.E and ISTS LCO 3.7.3 when both CREV subsystems are declared inoperable are addressed in the markups for proposed ISTS section 3.7.3.
PAGE 6
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT4 ISSUE 3.3.7.1-8 RESPONSE The original JFC P67 and added wording to the Bases indicating that there is only one trip system for proposed ISTS LCO 3.3.7.1 Functions 3 and 4 were incorrect since there are two trip systems for these Functions as stated in CTS Table 3.2.A Note 15 (for Units 1 and 3) and Note 14 (for Unit 2). Based on DOC A4 for proposed ISTS section 3.3.7.1, the intent of the originally proposed ISTS Table 3.3.7.1-1 was to indicate that there are two trip systems for these Functions with each Function containing two channels (sensors) per trip system. However, based on the lack of clarity of the original proposed change and that the Test AOT of CTS Table 3.2.A Note 11 (proposed to be maintained as ISTS 3.3.7.1 Surveillance Requirements Note 3) is based on the channel definition in CTS Table 3.2.A Note 15 (for Units 1 and 3) and Note 14 (for Unit 2), the proposed ISTS has been revised to maintain the original CTS channel designation (i.e., two divisional trip systems with both trip systems contain one channel of each Function and each channel containing two sensors).
Based on the above the following changes have been made. The original JFC P67 has been deleted and replaced with a new JFC P67 which provides justification for the deletion of the words "...in both trip systems." Proposed ISTS Tables 3.3.7.1-1 have been revised to indicate 1 channel of Functions 3 and 4 are required per trip system. The original DOC A4 has been deleted and marked as not used and appropriate CTS markup revisions made. Appropriate changes to the proposed bases for ISTS 3.3.7.1 have been made. Similar changes were also made for proposed ISTS 3.3.6.2 since these channels are common for both CREV System and Secondary Containment Isolation initiation.
(Note the principal description ofthe channels is provided in the proposed Bases for ISTS 3.3.6.2, APPLICABLE SAFET Y ANALYSES, LCO, and APPLICABILITYfor Functions 3 and 4; the proposed Bases for ISTS 3.3.7.1 efers to the Bases for 3.3.6.2 for additional information on channel arrangements.)
PAGE 7
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.8.1, LOSS OF POWER COMMENT 0                  DESCRIPTION OF ISSUE                                                PROPOSED RESOLUTION                    INCORP COMPLETE Y/N    DATE 3.3.8.1-1  CTS 3.9.B. I I.a provides a 10 day AOT for inoperable Joss of TIN ITS, ITS BASES, CTS MARKUP, JFC, ISTS NUREG              10/30/97 MARKUP, AND ISTS NUREG BASES MARKUP SECTIONS voltage channels provided the degraded voltage relay channel on HAVE BEEN REVISED TO REQUIRE THE CTS VERIFICATION the same board is OPERABLE. ITS 3.3.8.1, REQUIRED Action OF OPERABILITYOF THE LOP INSTRUMENTATIONNOT B. I docs not require verification that the other undervoltage relay channel on the same board is OPERABLE. In addition, ITS allows TAKEN OUT OF SERVICE.
multiple condition entry which means any of the specified condtions can exist at the same time with their own completion time clocks. As such channels can be inoperable simultaneously for both loss of voltage and degraded voltage functions without entering a shutdown conditon. This is a less restrictive change to the CTS which othenvise would require entry into 3.0.3. Similar changes arc made to the CTS 3.9.B. I I.b and 3.9.B.I I.c.
Less restrictive requirements, such as deletion of CTS 3.9.B. I I.a, b and c verification requirements are not administrative changes.
Specific CTS changes must be identified and discussed.
THE ITS, ITS BASES, ISTS NUREG MARKUP, AND ISTS NUREG        10/30/97 3.3.8.1-2  ITS 3.3.8.1 SR Note 2 proposed a 2 hour delay from entering into BASES MARKUP HAVE BEEN REVISED TO DELETE SR NOTE the associated Conditions and Required Actions for a channel 2.
placed in an inoperable status solely for performance of Required Surveillances provided the associated Function maintains initiation capability for 3 out of 4 diesel generators.
This relaxation of requirements is added to the requirements of CTS 3.9.A.3 without a technical justification. The proposed change does not conform to the STS allowance which provides an allowance not to enter TS Actions because individual DG trip capability is maintained. The impact of this proposed note is to add two hours to the channel repair time when testing.
DOC A2 HAS BEEN ADDED TO PROVIDE ADDITIONAL                  10/30/97 3.3.8.1-3  The A.l justification is used for addition of the "separate condtion JUSTIFICATION FOR THE "SEPARATE CONDITION ENTRY" entry" note to the Actions. A.l is a discussion of editorial changes NOTE. THE A2 NOTE CLARIFIES THATTHE ITS NOTE IS which is not acceptable for technical changes to the CTS.
CONSISTENT WITH THE NUREG-1433 REQUIREMENTS AND PROVIDES CLARIFICATIONON THE CURRENT INTERPRETATION OF EXISTING SPECIFICATION.
CTS TABLE4.9A.4.C HAS BEEN REVISED TO CORRECTLY              10/30/97 3.3.8.14    LA.I allowable value items are incorrectly marked.
DEPICT THE LA.I APPLICABILffY.
PAGE I
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.8.1, LOSS OF POWER COMMENT 8                  DESCRIPTION OF ISSUE                                              PROPOSED RESOLUTION                        INCORP COht PLETE Y/N    DATE THE TIME DELAYFUNCTIONS I.b AND 2.b IN ITS TABLE            N  10/30/97 3.3.8.1-5  The licensee is not currently required to perform Loss of offsite 3.3.8.1-1 ARE NOT NEW REQUIREMENTS. CTS TABLE power instrumentation channel checks or channel functional test.
4.9.A.4.C LISTS THESE FUNCTIONS UNDER ITEM 1. TRIP The licensee proposed to maintain their current TS in the ITS.
RANGE, AND ITEM 3. TIMER 2-211-IA. THESE INSTRUMENTS This applies to functions I.a and 2.a of Table 3.3.8.1-1. The time DO NOT CUMKNTLYREQUIRE A CHANNEL CHECK OR delay functions in the same table, functions I.b and 2.b are new CHANNEL FUNCTIONALTEST. BFN PROPOSED requirements. Provide supporting justification, based on SURVEILLANCEREQUIREMENTS, WHICH DO NOT INCLUDE operational experience, to confirm the reliability of the time delay NUREG-1433 SRs 3.3.8.1.1 AND 3.3.8.1.2, ARE BASED ON BFNs functions to perform their intended safety function without periodic CURRENT LICENSING BASIS.
channel check and channel functional test requirements.
THE LA.1 DOC HAS BEEN REVISED TO CLARIFYTHATTHE                  10/30/97 3.3.8.1-6  System design and operational details are moved to the ITS 3.3.8.1 VALUES IN THE CTS HEADING "TRIP LEVEL SETTINGS ARE Bases and plant procedures.
EQUIVALENTTO ALLOWABLE,VALUES.
TVA'S METHODOLOGY FOR DETERMINATIONOF SETPOINTS Trip setpoints are an operational detail not directly related to the UTILIZES THE CTS "TRIP LEVEL SETIlNGS" AS THE operability of the instrumentation. The Allowable Value is the ALLOWABLEVALUEIN ESTABLISHING THE NOMNALTRIP required limitation of the parameter and this value is retained in SETPOINT. THE SELECTION OF NOMINALTRIP SETPOINTS ITS Table 3.3.8.1-1.
PLUS ASSOCIATED INACCURACIES ENSURES THE "TRIP LEVEL SETIINGS" ARE NOT EXCEEDED. TVA'S SETPOINT The LA.I DOC discusses relocating timer trip setpoints to owner METHODOLOGYIS CONSISTENT WlTH RG 1.105 WHICH documents and retaining the CTS Allowable Values in the ITS.
ENDORSES ISA STD ISA- S67.04-1 982 "SETPOINT FOR For this CTS table the "trip level settings" column is simply NUCLEAR SAFETY RELATED INSTRUMENTATIONUSED IN renamed "Allowable Value" in the ITS format. The Allowable NUCLEAR POWER PLANTS" AND HAS BEEN REVIEWED BY Values do not exist in the CTS and the proposed ITS allowable THE NRC IN PREVIOUS SUBMITTALS, e.g. NRC LEITER TO values (CTS setpoints) are changed without justification.
MR. OLIVER D. KINGSLEYDATED JAN 2, 1991, ISSUANCE OF AMENDMENT TAC NO. 77279            291 .
PAGE 2
 
BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3.2, REACTOR PROTECTION SYSTEM ELECTRIC POWER MONITORING PROPOSED RESOLUTION                                        INCORP COMPLETE COMMENT 8                  DESCRIPTION OF ISSUE                                                                                                              Y/N    DATE The time delay relays delay the RPS power monitoring                            N  11/05/97 3.3.8.2-1  CTS 4.1.B does not specify a Channel Calibration, but ITS SR                                                                    assemblies'ignal providing a time delay to ensure minor bus fluctuations, caused 3.3.8.2.2 adds CHANNEL CALIBRATIONrequirements with an surveillance frequency of 184 days. Time delay setting              by activities such as switching loads, do not cause an unnecessary trip of the RPS power supply. The time delay is an integral part of the requirements are added to ITS SR 3.3.8.2.2 for the undervoltage, RPS power monitoring channel and therefore its setpoint is required overvoltage, and underfrequency protective devices of the RPS MG to be confirmed to be properly set to ensure operability of the power set. These time delay settings are not required by the CTS. Time monitoring channel. DOC M2 provides adequate justification for this delay settings and surveillance interval are based on previous plant more restrictive change.
practice. These additional restrictions on plant operation are not justified as a more restrictive change.
The following A4 DOC is provided:                                              Y  9/29/97 3.3.8.2-2  CTS applicability requires operability of two RPS-EPM channels for each inservice MG Set or alternate source. ITS applicability CTS 3.1.B requires two RPS power monitoring channels for each requires operability of two RPS EPM assemblies for each inservice inservice RPS MG set or alternate source to be OPERABLE and CTS MG Set or alternate power supply. DOC do not justify the 3.1.B.I and 3.1.B.2 address LCO actions for inoperable RPS electric changing LCO terms from channels to assemblies.
power monitoring channels. The LCO and ACTIONS of proposed ISTS Section 3.3.8.2 are presented in terms of RPS electric power monitoring assemblies. The change from the use of the term channels to the term assemblies is considered administrative since in both, specifications the intent of the terms are the same. Specifically, in the CTS the contactor and associated sensing logic is intended to be considered as one RPS power monitoring channel. Referring to the contactor and associated sensing logic as an assembly, as in the proposed ISTS, is more appropriate since the overvoltage, undervoltage, and underfrequency instruments are each considered as channels within each assembl .
CTS 4.1.B.2 does not specify a channel calibration, however it does            Y  11/05/97 3.3.8.2-3    CTS 4.1.B does not specify a Channel Calibration, but ITS SR require the trip level settings of the circuit protectors be verified. ITS 3.3.8.2.2 adds CHANNEL CALIBRATIONrequirements with an has included this requirement under the CHANNEL CALIBRATION surveillance frequency of 184 days. This requirement is added heading consistent with NUREG 1433.
with a 184 day interval since this test is performed during the CFT The SR 3.3.8.2.1 Note has been deleted.
(SR 3.3.8.2.1).
Explain the absense of the SR 3.3.8.2.1 Note on SR 3.3.8.2.2 to allow a delay in required testing based on the Mode of operation.
PAGE I
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION      3. 3
'-0 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 as referenced in NRC letter to Oliver D. Kingsley dated June 12, 1997, with the subject      "BROWNS  FERRY  NUCLEAR PLANT UNITS  1,2,AND  3  REQUEST  FOR ADDITIONAL INFORMATION REGARDING IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432, M96433)", and incorporates changes resulting from internal TVA reviews. A synopsis of the ITS and ITS BASES changes is provided below.
SECTION      3.3.1.1, RPS  INSTRUMENTATION Table 3.3.1.1-1 Modified by adding applicability of MODE 5" and associated Surveillance Requirements (SRs) to FUNCTIONS 2.a, Average Range Monitors Neutron Flux  High Setdown, and 2.e, Average Range Monitors Neutron Inop. This change is to make the ITS consistent with the requirements of CTS Table 3.1.A. This is in response to NRC comment 3.3.1.1-17.
BASES g BACKGROUND Corrected typographical errors on page      B  3.3-1 to  make consistent with  NUREG-1433 Markup.
BASES, APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Added discussion of MODE 5 applicability in "2.a. Average Power Range Monitor Neutron Flux  High, Setdown".        This incorporates CTS Table 3.1.A note 21 discussion of use of SRM noncoincidence High Flux Scram by removing the shorting links.
Added Instrument UNIDs, as additional      information, to "3. Reactor Vessel Steam Dome Pressure      High".
Added Instrument UNIDs, as    additional information, to "4. Reactor Vessel Water Level    Low,  Level 3".
Added Instrument UNIDs, as    additional information, to "6. Drywell Pressure    High".
Added Instrument UNIDs, as additional information, to "7.a, 7.b. Scram Discharge Volume Water Level  High".
Page 1 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION      3. 3 Added Instrument UNIDs, as      additional information, to "9. Turbine Control Valve Fast Closure, Trip Oil Pressure-Low" and changed description from "transmitter" to "switch" because BFN uses discrete switches not transmitters for this function.
Added Instrument UNIDs, as additional information, to "13. Low Scram Pilot Air Header Pressure".      Note that  this function does not exist for Unit 1.
I BASES ~ ACT ONS Provided specific additional details by Function in C.1 to better define when Functions lose trip capability due to multiple inoperable/untripped channels.
BASEST  SURVEILLANCE REQUIREMENTS Corrected typographical omission by adding "and APRM" to third paragraph of SR 3.3.1.1.3 to match the original NUREG-1433 mark-up.
Corrected  SR 3.3.1.1.9, SR 3.3.1.1.10,and SR 3.3.1.1.13 by deleting "For the APRM Simulated Thermal Power-High Function, SR 3.3.1.1.9 also includes calibrating the associated recirculation loop flow channel" and "also" because the calibration of the recirculation flow loop is addressed in SR 3.3.1.1.11 instead of SR 3.3.1.1.9.
Corrected typographical omission by adding "calibrated flow signal and, therefore, the APRM Function accurately reflects the required setpoint as a function of flow" in first paragraph of SR 3.3.1.1.11 to match the original NUREG-1433 markup.
Added instrument UNIDs to identify instrumentation addressed by calibration of bypass channels in SR 3.3.1.1.15.
SECTION      3.3.1.2,    SOURCE RANGE MONITOR (SRM)  INSTRUMENTATION SURVEILLANCE REQUIREMENTS Deleted Note      2 to SR 3.3.1.2.4 and made associated  revisions (change NOTES to NOTE and deleted number 1 for the remaining note) because Note 2 conflicts with Note b to Table 3.3.1.2-1.      The  effect of this deletion is that the required SRM OPERABLE    channels will still require verification of a count rate    R  3.0 cps and a signal-to-noise ratio of ~ 3:1.
Page 2 of 24
 
e EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS)      -362 IMPROVED STANDARD TS      (ITS). SUPPLEMENT TO  ITS SECTION 3.3 BASES,  SURVEILLANCE REQUIREMENTS Deleted reference and associated'text      to Note 2 for SR  3.3.1.2.4.
Replaced "only" with "mainly" in second paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 to clarify that reactivity changes in MODES 3 and 4 are not due "only to control rod movement", but control rod movement is the main cause of reactivity  changes.
Replaced "the Surveillance"      in fourth paragraph of SR  3.3.1.2.5  and  3.3.1.2.6 with "SR 3.3.1.2.6" to clarify which of the  SRs the note pertains to.
Replaced "Frequency" with "Allowance" in fourth paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 because the 12 hours allotted after IRMs are on Range 2 or below to perform the SR is better described as an allowance rather than a Frequency which implies a time frame between performances.
Corrected "18 month" to "92 day" in second paragraph of SR 3.3.1.2.7. The 18 month value was not changed to 92 day value for applicability at the same time (Rev 0 markup) as the SR and other references to it.
Replaced "Frequency" with "Allowance" in second paragraph of SR 3.3.1.2.7 because the 12 hours allotted after IRMs are on Range 2 or below to perform the SR is better described as an allowance rather than a Frequency which implies a time frame between performances.
SECTION    3.3.2.1,  CONTROL ROD BLOCK INSTRUMENTATION BASES, BACKGROUND Inserted "on" between based and position in third paragraph of sentence which read "The RWM determines the actual sequence based position indication for each control rod."
The insertion of "on" clarifies the intent of the sentence.
BASES, APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Changed < 10% RTP    to ~ 10% RTP in fourth paragraph of "2. Rod Worth Minimizer" to agree with several other locations, including Note c to Function 2 (RWM) in ITS Table Page3 of24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS      (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO      ITS SECTION 3. 3 0          3.3.2.1-1, that the  Rod Worth use the ~    10% RTP Minimizer is required.
for when OPERABILITY  of BASES,  SURVEILLANCE REQUIREMENTS Changed the Frequency in third paragraph of "SR 3.3.2.1.4" from "184 day" to "92 day" to agree with the Frequency of the Channel Calibration specified in the Surveillance Requirement. This value is based on a site specific setpoint analysis that supports the 92 day Frequency.
SECTION 3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION ACTIONS Changed CONDITION A. from one CHANNEL inoperable to one or more in the same    trip  system inoperable because the other trip  system maintains the    ability to perform the required action (trip feedwater    and main  turbines).
REQUIRED ACTION A.l to CHANNEL(S)
Changed CHANNEL indicate that  itincould  be more than one channel.
to SURVEILLANCE REQUIREMENTS Changed Allowable Value for SR 3:3.2.2.3 from 588 inches above vessel zero to 586 inches above vessel zero.        This change made to agree with Analytical Limit and Scaling and Setpoint Analysis Calculations.
BASES,  BACKGROUND Added Instrument UNIDs      in the third paragraph to better identify the trip units    which actuate the trip logic.
BASES, ACTIONS Revised the description of ACTION A.l to address acceptability of having more than one CHANNEL in the same trip system inoperable based on the plant specific trip logic.
Page 4 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION        3.3 SECTION 3 3 3 1 i POST ACCIDENT MONITORING (PAM) 1NSTRUMENTATION SURVEILLANCE REQUIREMENTS Corrected  SR 3.3.3.1.4 from "Reactor Pressure,    Drywell, and Torus  H~ Analyzer  Functions"  to "Reactor  Pressure, and the Drywell and Torus H~ Analyzer    Functions"  which more clearly shows that the Drywell and Torus H~ Analyzer is one Function.
TABLE  3.3.3.1-1 Revised "Active    PC1V" in Note b to "installed Control Room PAM Category  1  indication CHANNEL" to more clearly define when  only one  position indication for a penetration flow path is required.
BASES,  LCO Added Instrument UNIDs, as additional      information, to "1. Reactor Steam Dome Pressure".
0        Added Instrument UNIDs, as      additional information, to "2. Reactor Vessel Water Level".
Added Instrument UNIDs, as      additional information, to "3. Suppression Pool Water Level".
Added Instrument UNIDs, as      additional information, to "4. Drywell Pressure".
Added Instrument UNIDs, as      additional information, to "5. Primary Containment Area Radiation (High Range)      .
Added "The PCIV    position PAM indication instrumentation consists of the Category 1 PCIV position indications identified in Reference 4" to the beginning of the second paragraph of "6. Primary Containment Isolation Valve (PCIV)
Position". This provides a reference for the identification of the PAM PCIV position indications.
Added Instrument UNIDs, as additional information,      to "7. Drywell and Torus Hydrogen Analyzers".
Deleted "or oxygen" from "7. Drywell and Torus Hydrogen Analyzers" because hydrogen is the only parameter of concern. This is consistent with the deletion of oxygen analyzer function from other parts of the ITS.
Pago 5 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS      (TS) -362 ITS SECTION 3.3 0        IMPROVED STANDARD TS (ITS) SUPPLEMENT TO Added Instrument UNIDs, as    additional information, .to "8. Suppression Pool Water Temperature".
Added "For a channel to be OPERABLE, at least 7 of its 8 sensors must be OPERABLE" to "8. Suppression Pool Water Temperature". This incorporates Note  6 from    CTS  Table 3.2.F into the ITS  BASES.
Added Instrument UNIDs, as    additional information, to "9. Drywell Atmosphere Temperature".
Changed "transmitters" to "sensors" in "9. Drywell Atmosphere Temperature" because the instruments which generate the signal (RTDs) are more appropriately described as sensors.
BASES ~ ACT IONS Added "does"    to ACTION F.1 for clarity which makes the statement  read  "the plant must be brought to a MODE in which the LCO does not apply".
BASEST  SURVEILLANCE REQUIREMENTS Addressed  SR  3.3.3.1-4 with  SR 3.3.3.1-2    and SR  3.3.3.1-3.
These  SRs  all  address CHANNEL CALIBRATION. In the original NUREG-1433 mark-up two additional SRs for CHANNEL CALIBRATIONs were added to address having 3 different calibration frequencies but only one of the additional SRs was added to the NUREG BASES markup.      Adding SR 3.3.3.1-4 and inserting "The 184 day frequency for CHANNEL CALIBRATION of the REACTOR Pressure Indication is based on plant specific analysis" will correct the omission from the Revision 0 markup. This change addresses NRC question 3.3.3.1-4.
Page 6 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362
: 3. 3 0 SECTION IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3.3.2,  BACKUP CONTROL SYSTEM SURVEILLANCE REQUIREMENTS Deleted  SR 3.3.3.2.1 and renumbered the remaining SRs. SR 3.3.3.2.1 was to "Perform a CHANNEL CHECK for each required instrumentation channel that is normally energized and provides indication during normal plant operation".
NUREG-1433 did not include the part of the SR that states "and provides indication during normal plant operation".
The addition of the clarification was rejected by the NRC as a Generic Change to The STS.      Without the clarification CHANNEL CHECKS would be required for all of the transfer/control functions in addition to the indication functions. There are no CTS requirements to perform CHANNEL CHECKS for the Backup Control Instrumentation. The requirement was therefore deleted from the ITS because the benefits of performing the CHANNEL CHECKS is not sufficient to justify the additional manpower required.
BASES,  SURVEILLANCE REQUIREMENTS Deleted  BASES  for SR  3.3.3.2.1 because the  SR was  deleted as stated above. Renumbered  the remaining SRs due  to the deletion.
BASES,  TABLE  B3.3.3.2-1 Replaced  existing Table 3.3.3.2-1 (Backup Control System Instrumentation and Controls) with a new one which better defined the required functions and contained notes to better explain the number of functions required.
SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT)
INSTRUMENTATION BASES ~ BACKGROUND Revised  third paragraph of the BACKGROUND to delete discussion of "electronic equipment (e.g., trip relays) because the instrumentation used for EOC-RPT utilizes discrete switches not analog transmitters. Also added "channel's pre-established" to "When the channel's re-established setpoint is exceeded,..." as clarification.
Page7 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)= SUPPLEMENT TO ITS SECTION    3.3 BASES  APPLICABLE SAFETY ANALYSES ~ LCO~ AND APPLICABILITY For the "Turbine Stop Valve    Closure" second paragraph change "switches" to "signals" in the sentence "There are two separate position switches associated with each stop valve..." because in actuality there is only one switch housing that provides the separate contacts for the signals.
Also added "Therefore, to consider this function operable bypass of the function must not occur when bypass valves are open". This change will allow testing of the bypass valves without making the Turbine Stop Valve (TSV)  Closure function inoperable unless bypassing the TSV  Closure function actually occurs due to decreasing the turbine first stage pressure below the bypass setpoint.
For the "Turbine Control Valve Fast Closure, Trip Oil Pressure  Low" function, added UNIDs for additional information. In the second paragraph changed "transmitter" to "s~itch" because pressure switches are utilized, not transmitters. Also in the second paragraph added "Therefore, to consider this function operable bypass of the function must not occur when bypass valves are open". This change will allow testing of the bypass valves without making the Turbine Control Valve (TCV) Fast Closure Trip Oil Pressure  Low function inoperable unless bypassing the function actually occurs due to decreasing the turbine first stage pressure below the bypass setpoint.
SECTION 3.3.4.2, ANTICIPATED TRANSIENT WITHOUT SCRAM RECIRCULATION PUMP TRIP (ATWS-RPT) INSTRUMENTATION BASES, BACKGROUND In the third paragraph, added "vessel" to "... either two Reactor Vessel Water Level..." for clarification.
In the fourth paragraph, replaced "both recirculation      pump breakers" with "one of the two breakers for each recirculation    pump" as clarification.
Added Instrument UNIDs, as    additional information, to "a. Reactor Vessel Water Level      Low".
Added Instrument UNIDs, as additional information,    to "b. Reactor Steam Dome Pressure  High".
Page 8 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION      3.3 SECTION 3 3 5 1 ~ EMERGENCY CORE COOLING SYSTEM (ECCS)
INSTRUMENTATION ACTIONS Removed    Functions 1.c and 2.c from REQUIRED ACTION B.1 and added them into REQUIRED ACTION C.1. REQUIRED ACTION C.1 is more appropriate for these Functions for Core Spray and LPCI because they are permissives for which      it is better to restore OPERABILITY than to place in trip which is non-conservative. Also clarified REQUIRED ACTIONS and COMPLETION TIMES FOR B.1 and C.1 by adding "ECCS" modifier to "feature(s) inoperable", changed "loss of feature" to "loss of function(s)", changed "loss of subsystem" to "loss of function(s)", and changed "both subsystems" to "both trip systems". These changes were all made to provide more accurate descriptions.
For REQUIRED ACTION H.1 added "ECCS" to "feature(s) inoperable" to clarify features of concern are the ECCS features.
TABLE 3.3.5.1-1 For Function 1.c, added reference to note b which was revised to state "Channels affect Common Accident Signal Logic. Refer to LCO 3.8.1, 'AC Sources        Operating'",.
changed the Conditions Referenced      from B to  C, and clarified that 4 Required Channels are    "2 per trip  system". The change to note b was to identify the actual logic that initiates the Diesel Generators and EECW to which the note previously referred. The change from Conditions Referenced is to agree with the change made to the REQUIRED ACTIONS.
For Functions 2.a and 2.b, deleted note b reference and also note b on this page because is addressed under Functions l.a, 1.b, and 1.c, "Core Spray System" where the Common Accident Signal is generated.
For Function 2.c, changed the Conditions Referenced from B to  C to agree with the change made to the REQUIRED ACTIONS.
For Function 2.e, added    clarification that  Required Channels are "1 per Subsystem".
For Function 2.f, Pumps C and D, added clarification that Required Channels are "1 per trip system" and modified note e with same information.
Page 9 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 0        IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION For Function  3.f, changed SR  3.3.5.1.3 to SR
: 3. 3 3.3.5.1.5 which effectively changes the calibration frequency from 92 days to 18 months. This is acceptable based on the setpoint analysis.
Corrected the Required Channels per Function for Function 4.e to 4, Function 4.f to 8, Function 4.g to 2, Function S.e to 4, Function 5.f to 8, and Function 5.g to 8. This was done because previously these had erroneously been listed on a per trip system basis.
BASES,  BACKGROUND In the third paragraph, clarified that the Common Accident Signal is the logic generated by the ECCS instrumentation that initiates the Diesel Generators and EECW System.
For the "Core Spray System", added clarification that Reactor Vessel Water Level and Drywell Pressure are "each" monitored by four transmitters. Changed Subsystem to trip system. Also clarified that the "low reactor water level" signal is sealed in.
For the "Automatic Depressurization System", clarified that the Level 3 signal is. used as a confirmatory signal to the Level 2 signal. Revised the description of the Core Spray and LPCI discharge pressure switches to correctly identify the appliable number. Revised the description of the ADS logic for clarity.
For the "Diesel Generators" and "Emergency Equipment Cooling Water (EECW) System", deleted these sections because they are not applicable to the    ECCS  section.
BASES  ~ APPL ICABLE SAFETY ANALYSES g  LCD'ND APPLI CABILITY In the third paragraph, deleted text on response time since BFN  is not committed to do response time testing and clarified text on note b to refer to the Common Accident Signal Logic.
In the fourth paragraph, deleted references to Diesel Generators based on note b revision.
For  "la, 2a Reactor Vessel Water Level  Low Low Low, Level 1", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal and deleted associated text. pertaining to the EECW and Diesel Generator Initiation si,gnals.
l Page 10 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS      (TS) -362 IMPROVED STANDARD TS,(ITS), SUPPLEMENT TO      ITS SECTION 3.3 For "1.b, 2.b Drywell Pressure      High", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal and deleted associated text pertaining to the EECW and Diesel Generator Initiation signals.
For "1.c, 2.c Reactor    Dome  Pressure    Low  (Injection Permissive and  ECCS  Initiation)",    added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal.
For "1.d Core Spray Pump Discharge Flow  Low (Bypass)",
added instrument UNIDs as additional information.
For "1.e, 2.f Core Spray and Low Pressure Coolant Injection Pump Start,  Time Delay Relay", clarified the number of relays per pump start logic.
For "2.d Reactor Steam Dome Pressure  Low (Recirculation Discharge Valve Permissive)", added instrument UNIDs as additional information.
For "2.e Reactor Vessel Water Level        Level 0", added instrument  UNIDs as  additional information.
For "3.a Reactor Vessel Water Level        Low Low,  Level 2",
added instrument UNIDs as    additional information.
For "3.b Drywell Pressure      ,High",  added instrument UNIDs as additional information.
For "3.c Reactor Vessel Water Level  High, Level 8", added instrument UNIDs as additional information.
For "3.d Condensate Header Level  Low", added instrument UNIDs as additional information.
For "3.e Suppression    Pool Water Level    High", added instrument  UNIDs as  additional information.
For  "3.f High Pressure Coolant Injection Pump Discharge Flow Low  (Bypass)", added instrument UNIDs as additional information and corrected "transmitter" to "switch" to agree with plant configuration.
For "4.a, S.a Reactor Vessel Water Level  Low Low Low, Level 1", added instrument UNIDs as additional information.
Page ll of24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS), SUPPLEMENT TO ITS SECTION              3.3 For "4.b, S.b Drywell Pressure              High", added instrument UNIDs as    additional information.
For "4.d, 5.d Reactor Vessel Water Level              Low,  Level 3",
added instrument UNIDs as            additional information.
For "4.e,      4.f, 5.e, 5.f,      Core Spray and Low Pressure Coolant Injection Pump        Discharge    Pressure  High", added instrument UNIDs as additional information and replaced "transmitters" with "switches" to match plant configuration. Also replaced "two for" with "one from" to clarify the signals from the Core Spray Pumps.
For "4.g, 5.g Automatic Depressurization System High Drywell Pressure Bypass Timer", clarified that there are. four bypass timers (two per trip system).
BASES g ACT ONSI For "B.1, B.2, and B.3", deleted text pertaining to Functions 1.c and 2.c which were relocated to "C.1 and C.2".
Deleted statement about DG and EECW inoperability because the logic for Common Accident Signal, which initiates these, is located in another section. Deleted "redundant" because it    is not applicable improve readability.
to  HPCI. Corrected other text to For    "C.l  and C.2" added      information pertaining to Functions 1.c    and 2.c which were        relocated from "B.1, B.2, and B.3".
For    "D.l" deleted      second and third sentences of second paragraph.      This change    is based on Operations review comment and    deletes    unnecessary    detail.
For "E.1 and E.2"          revised the discussion of inoperability due to multiple inoperable channels for the Core Spray Pump Discharge Flow  Low Bypass Function to clarify equipment affected (potentially all four CS Pumps). Also identified the Function of concern as 1.d.
BASES SURVEILLANCE REQUIREMENTS Revised    SR  3.'3.5.1.6 to delete      LCO 3.8.2 as  overlapping this Surveillance.
Page 12  of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS)    -362 IMPROVED STANDARD TS      (ITS) SUPPLEMENT TO  ITS SECTION 3.3 SECTION 3 3 5 2 g REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION APPLICABLE SAFETY ANALYSES ~ LCOg AND APPLICABILITY Added Instrument UNIDs, as      additional information, to "1. Reactor Vessel Water Level        Low Low, Level 2".
Added Instrument UNIDs, as      additional information, to "2. Reactor Vessel Water Level        High, Level 8".
SECTION        3.3.6.1,  PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION ACTIONS Revised "COMPLETION TIME" to add functions 6.b and 6.c (new functions in table) for "CONDITION A" to the functions that have 12 hours after being declare inoperable to be placed in trip.
For "REQUIRED ACTION D.1" changed "Isolate associated main steam line (MSL)" to "Isolate the affected penetration flow path(s)". This change is necessary because other penetration flow paths besides the Main Steam Lines are isolated by the functions which reference ACTION D from table 3.3.6.1-1.
Added REQUIRED ACTION G.1 and renumbered existing REQUIRED ACTION G.1 and G.2 to G.2.1 and G.2.2 respectively.          Also added note that specifies REQUIRED ACTION G.l, is only applicable for functions 2.a and 2.b which are inoperable as a result of inoperable actuation logic. The added action allows isolating the affected penetration flow path(s) in 1 hour instead of being in MODE 3 in 12 hours and in MODE 4 in 36 hours.      This change accomplishes the required safety action (isolation of primary containment for affected penetrations) and allows more flexibility than shutting down if    non-critical penetrations are inoperable.
Added a CONDITION      I which has the REQUIRED ACTION of "I.1, Initiate action to restore channel to OPERABLE status" or "I.2, Initiate action to isolate the Residual Heat Removal    (RHS) Shutdown Cooling  System". Both actions COMPLETION TIME    is  Immediately. This addition addresses the actions while in Shutdown Cooling and the Reactor Vessel Water Level  Low Function is isolation capability is not maintained.
Page 13  of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION    3. 3 TABLE  3.3.6.1-1 Added FUNCTIONS    3.f and 3.g and modified description of FUNCTION    3.e to identify the three separate areas (Exit, Midway, and Entry) for the HPCI Steam line Space Torus Area Temperature  High.
Added FUNCTIONS    4.f and 4.g and modified description of FUNCTION    4.e to identify the three separate areas(Exit, Midway, and Entry) for the RCIC Steam line Space Torus Area Temperature  High.
Added    "-High" to FUNCTIONS 5.a, 5.b, 5.c, S.d, 5.e and 5.f to better describe that the parameter of concern is high temperature.
Added FUNCTIONS 6.b (with associated note b), Reactor Vessel Water Level  Low, and 6.c, Drywell Pressure  High, for Shutdown Cooling System Isolation. This adds back requirements deleted from CTS in=original mark-up and responds    to  NRC comment  3.3.6.1-14.
BASES,    BACKGROUND Revised "1. Main Steam Line      Isolation" to provide more plant specific description    and  details.
Revised "2. Primary Containment Isolation" to provide more plant specific description and details.
Revised "3,4. High Pressure Coolant Injection Isolation and Reactor Core Isolation Cooling System Isolation" to provide moxe plant specific description and details.
Revised "5. Reactor Watex Cleanup System Isolation" to provide more plant specific description and details.
Revised "6. Shutdown Cooling System Isolation" to provide more plant specific description and details.
Each of the above sections was substantially revised based on    input from Operations Review.
Page 14 of 24
 
EXE CUT IVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION      3.3 BASES~  APPLICABLE SAFETY ANALYSES~ LCO AND APPLICABILITY Deleted "Each channel must also respond within its assumed response time, where appropriate".      This was deleted because BFN is not committed to do Response Time Testing and references to the ITS.
it  have been removed from other locations in Added a paragraph break      for  fifth paragraph for clarity.
Added Instrument UNIDs, as      additional information, to "1.a. Reactor Vessel Water Level  Low Low Low, Level 1".
In "1.b. Main Steam Line Pressure  Low", added Instrument UNIDs, as additional information. Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.
In "1.c. Main Steam Line Flow  High", added Instrument UNIDs, as additional information. Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.
In "1.d. Main  Steam Line Space Temperature  High", added Instrument UNIDs, as additional information. Changed "Line Space" to "Tunnel" in several locations to better reflect BFN terminology. Also added "excluding the Recirculation Loop Sample  Valves"  to last paragraph to clarify applicability.
In "2.a. Reactor Vessel Water Level  Low, Level 3", added Instrument UNIDs, as additional information. Also clarified applicability by revising last paragraph tc "This Function is required for the isolation of the Group 2 (excluding RHR valves for SDC), 6, and 8 valves. Portions of this instrumentation are also required for Functions 5.h and 6.b".
In "2.b. Drywell Pressure  High", added Instrument UNIDs, as additional information. Also clarified applicability by revising last paragraph to "This Function is required for the isolation of the Group 2 (excluding RHR valves for SDC),
6, and 8 valves. Portions of this instrumentation are also required for Function 6.c".
In "3.a., 4.a. HPCI and RCIC Steam    Line Flow  High", added Instrument UNIDs, as additional information.
Page 15 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS  (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO    ITS SECTION 3. 3 In "3.b., 4.b. HPCI and RCIC Steam  Line Pressure    Low",
added Instrument UNIDs, as additional information. Also deleted "Each Function is considered to have only one trip system since the output from the logic trips a common relay that initiates the isolations" because this information was added to the BACKGROUND.
In "3.c., 4.c. HPCI and RCIC Turbine Exhaust Diaphram Pressure  High", added Instrument UNIDs, as additional information. Also deleted "Each Function is considered to have only one trip system since the output from the logic trips a common relay that initiates the isolations" because this information was added to the BACKGROUND.
In "3.d., 3.e., 4.d., 4.e. Area Temperature  High", added functions 3.f., 3.g., 4.f., and 4.g. to address the torus area having three distinct area trip functions for each system. Added Instrument UNIDs, as additional information.
Also modified description of to clarify the number of channels and delete reference to Differential Temperature which is not utilized at BFN.
In "5.a., 5.b., 5.c., S.d., S.e.,5.f. Area Temperature High", added Instrument UNIDs, as additional information.
Also indicated that areas as opposed to rooms are being monitored and deleted text on the logic which has been included in the BACKGROUND.
In "5.h Reactor Vessel Water Level  Low, Level 3", added Instrument UNIDs, as additional information. Added paragraph that states the Allowable Value for the Function is the same as RPS Level 3 scram Allowable Value. Also revised applicability to state "This Function is required for the isolation of the Group 3 valves. Portions of this instrumentation are also required for Functions 2.a and 6.b." which in effect deletes Groups 2, 6, and 8.
In "6.a. Reactor  Steam Dome Pressure  High", added Instrument UNIDs, as additional information. Also clarified that the valves to be isolated are the Shutdown Cooling Supply  Isolation Valves.
Added  6.b., Reactor Vessel Water Level  Low, Level 3 and 6.c., Drywell Pressure  High BASES to address the new Functions added for the isolation of Shutdown Cooling valves.
Page 16 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION      3.3 BASES, ACTIONS New  Functions 6.b and 6.c were added to "A.1 and A.2" and minor changes were made for clarification.
The first paragraph of "B.1" was substantially revised in response to Operations comments.      This revision clarifies the number of required channels per function required to maintain isolation capability.
        "D.1, D.2.1, and D.2.2" was revised to change "MSL" to "penetration flow path(s) because lines (for example Main Steam Drain Lines) other than the Main Steam Lines could be affected which may not necessitate the isolation of a Main Steam Line.
For "G.l and G.2", a new ACTION G.l was added and the existing ACTIONS were renumbered to G.2.1 and G.2.2.
Additional details were provided to address the actions of isolating the affected penetration flow path(s) for Functions 2.a and 2.b being inoperable due to inoperable actuation logic.
Added BASES for new ACTIONS I.1 and I.2 which address the added Functions for RHR Shutdown Cooling System Isolation.
SURVEILLANCE REQUIREMENTS Added "The LOGIC SYSTEM FUNCTIONAL TEST shall include a calibration of time delay relays and timers necessary for proper functioning of the logic" to SR 3.3.6.1.6.        This change addresses CTS requirement for timer testing/calibration.
SECT ION 3 3 6 2 g      SECONDARY CONTAINMENT  ISOLAT ION INSTRUMENTATION ACTIONS Added "secondary containment" in front of "isolation capability" for CONDITION B and REQUIRED ACTION B.l for clarification. NRC  comment 3.3.6.2-3 noted that "secondary containment" had been deleted from NUREG-1433.
Replace "zone(s)" with "secondary containment isolation valves" for REQUIRED ACTION C.l.l because zonal isolation is no longer required by ITS section 3.6.4.1, Secondary Containment, but the affected secondary containment Page 17  of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS), SUPPLEMENT TO ITS SECTION        3.3 isolation valve    must  still maintain  isolation capability or be isolated.
Revised    REQUIRED ACTION  C.2.1 to add "associated" in front of "standby gas treatment" and replaced "system" with "subsystem(s)". This restores the original NUREG-1433 text.
Revised    REQUIRED ACTION  C.2.2 to add "associated" in front of  "SGT" and  replaced "system" with "subsystem(s)". This restores the original      NUREG-1433  text.
SURVEILLANCE REQUIREMENTS Added "secondary containment"      in front of "isolation capability" for    Note 2. NRC comment  3.3.6.2-3 noted that "secondary containment" had been deleted from NUREG-1433.
Deleted    SR 3.3.6.2.3 for performing a LOGIC SYSTEM FUNCTIONAL TEST every 184 days and renumbered the remaining SRs. It  was determined that the Functions (Reactor Zone Exhaust Radiation      High and Refueling Floor Exhaust Radiation  High)    that  had specified a 184-day LOGIC  SYSTEM FUNCTIONAL TEST could have      their  LOGIC SYSTEM FUNCTIONAL TEST extended to 18 months and,      therefore, the 184-day test was no    longer required.
TABLE  3.3.6.2-1 Renumbered    SRs due  to the deletion of    SR 3.3.6.2.3 and renumbering of the remaining SRs.        Deleted SR 3.3.6.2.1 (Channel Check) requirement for Function 2. Drywell Pressure  High. The Channel Check requirement was not included in the CTS and thus deletion is acceptable.
Revised the number of required channels per trip system for "3. Reactor Zone Exhaust Radiation  High" and "4. Refueling Floor Exhaust Radiation  High" from 2 to 1. This change is based on one channel of each function being required per trip system.
BASES,  BACKGROUND Deleted "In addition, manual initiation of the logic is provided" from the second paragraph because BFN is not committed to have manual initiation capability.
Page 18 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS    (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3. 3 BASES I APPLICABLE SAFETY ANALYSES I LCO/ AND    APPLICABILITY Deleted "Each channel must also respond within its assumed response time, where appropriate" from the fourth paragraph because BFN is not committed to perform response t:ime testing.
For "1. Reactor Vessel Water Level      Low,  Level 3", added Instrument UNIDs, as additional information. Also added "These signals are the same that isolate the primary containment (additional information on the arrangement of these channels in the PCIS trip systems can be found in the BASES for LCO 3.3.6.1, "Primary Containment Isolation Instrumentation", Function 2)" to provide a cross reference for other Funct'.ions performed by the same instrumentation.
Corrected title for second page to Level 3 (not Level 2).
For "2. Drywell Pressure    High", added Instrument UNIDs, as additional information. Also added "These signals are the same that isolate the primary containment (additional information on the arrangement of these channels in the PCIS trip systems can be found in the BASES for LCO 3.3.6.1, "Primary Containment Isolation Instrumentation", Function 2)" to provide a cross reference for other Functions performed by the same instrumentation.
For "3.4. Reactor Zone and Refueling Floor Exhaust Radiation High", added Instrument UNIDs, as additional information.
The second paragraph was rewritten to bett:er describe the logic of operation.
I BASES I ACT ONS Revised "B.1" to clarify minimum number of channels OPERABLE t:o assure penetration flow path isolation on a valid signal.
Added paragraph    to "C.1.1, C.1.2, C.2.1,    and  C.2.2" to explain that    REQUIRED ACTIONS  C.2.1 and C.2.2 can be performed independently on each    SGT  subsystem.
Page 19 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION          3.3 SURVEILLANCE REQUIREMENTS Corrected Functions to which Note 3 is applicable from Functions 2.c and 2.d to Functions 3 and 4 to which the Note actually refers. Functions 2.c and 2.d do not exist.
Added "This      Surveillance for Functions  3  and  4  shall consist of verifying the High Voltage Power Supply (HVPS) voltage at the Sensor and Convertors (detectors) is within its design limits. A CHANNEL FUNCTIONAL TEST as defined in Section 1.1, "Definitions" shall be performed once per 18 months as part of the CHANNEL CALIBRATION for Functions 3 and 4" to SR 3.3.6.2.2. This note incorporates CTS Table 4.2.A, Note 32.
For the LOGIC    SYSTEM FUNCTIONAL TEST SRs,    combined  SR 3.3.6.2.3    and SR 3.3.6.2.5 and renumbered to SR 3.3.6.2.4.
This change was necessary because the 184 day Frequency for Functions 3 and 4 were changed to 18 months and thus only one SR for LOGIC SYSTEM FUNCTIONAL TEST is required.
Renumbered    SR 3.3.6.2.4 to SR 3.3.6.2.3    and  relocated to proper sequential location.
INSTRUMENTATION ACTIONS Deleted    "in both trip  systems" from the COMPLETION TIME for CONDITION B. This      is because each trip system initiates its own CREV subsystem.
TABLE    3.3.7.1-1 Corrected the required number of channels per trip system for Functions 3, 4, and 5 from 2 to 1 to match system logic.
Added "above background"        for the Function  5,  Control  Room Air Supply      Duct Radiation    High, Allowable Value. This is consistent with    CTS  value.
BAS E S g BACKGROUND Significantly revised the third paragraph to provide additional description of the CREV System instrumentation.
This included a cross reference to the PCIS Function that utilize the same initiation instrumentation.
Page 20 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS)    -362 IMPROVED STANDARD TS  (ITS),. SUPPLEMENT TO ITS SECTION    3.3 BASES, APPLICABLE SAFETY ANALYSES, LCO, AND APPLICABILITY In "1. Reactor Vessel Water Level  Low, Level 3", added Instrument UNIDs as additional information. Added sentence that states the Allowable Value for the Function is the same as RPS Level 3 scram Allowable Value. Also deleted reference to PCIS logic which was included in Background.
In "2. Drywell Pressure  High", added Instrument UNIDs, as additional information.
In "3., 4. Reactor  Zone and Refueling Floor Exhaust Radiation  High", added Instrument UNIDs as additional information. Deleted statement on isolation of primary containment: which is not applicable to CREVs initiation.
Made several replacements and or additions to better describe the init;iation logic.
In "5. Control Room Air Supply Duct Radiation  High" added Instrument UNIDs, as additional information. Also deleted "There is only one trip system for this Function" which was not included in the NUREG-1433 original mark-up.
BASES, ACTIONS For ACTIONS B.1 and B.2, revised first paragraph to better describe requirements to maintain CREV System initiation capability.
For ACTIONS C.1 and C.2, revised      first paragraph  to better describe requirements to maintain      CREV System  initiation capability.
For ACTIONS D.l, D.2, and D.3, corrected RE-90-8 to RM-90-8 since the discussion is for the radiation monitor, not the radiation element.
ACTIONS  E.1 and E.2 were revised t:o provide additional information in the  first paragraph detailing that only one CREV subsystem must be operating to meet action E.l other subsystem will st:art automatically upon loss of the if  the operating unit, and to state that t: he required      actions can be taken independently on each subsystem.
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EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION      3.3 BASES,    SURVEILLANCE REQUIREMENTS Added "This    Surveillance for Functions 3 and 4 shall consist of verifying the High Voltage Power Supply (HVPS) voltage at the Sensor and Convertors (detectors) is within its design limits. A CHANNEL FUNCTIONAL TEST as defined in Section 1.1, "Definitions" shall be performed once per 18 months as part of the CHANNEL CALIBRATION for Functions 3 and 4" to SR 3.3.7.1.2. This note incorporates CTS Table 4.2.A Note 32.
SECTION        3.3.8.2,  LOSS OF POWER  (LOP) INSTRUMENTATION ACTIONS Added a new REQUIRED ACTION A.1 to "Verify by administrative means that the other two phase-to-phase degraded voltage relays and the loss of voltage relay channel on that shutdown board are OPERABLE" and renumbered the existing REQUIRED ACTION    A.1 to A.2. The COMPLETION TIME for the new REQUIRED ACTION    is Immediately. This change incorporates CTS    requirements that were not previously incorporated into the ITS and responds to      NRC comment 3.3.8.1-1.
Added a new REQUIRED ACTION B.1      to "Verify by administrative means    that the degraded voltage relay channel on that shutdown board is OPERABLE" and renumbered the existing REQUIRED ACTION B.l to B.2.      The COMPLETION TIME for the new REQUIRED ACTION is Immediately.      This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.
Added a new REQUIRED ACTION C.1 to "Verify by administrative means that the loss of voltage relay channel on that shutdown board is OPERABLE" and renumbered the existing REQUIRED ACTION C.1 to C.2.      The COMPLETION TIME for  the new REQUIRED ACTION, is Immediately.      This change incorporates CTS    requirements that were not previously incorporated into the ITS and responds to      NRC comment  3.3.8.1-1.
Page 22  of 24
 
e EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS    {TS) -362 IMPROVED STANDARD TS {ITS) SUPPLEMENT TO      ITS SECTION 3. 3 SURVEILLANCE REQUIREMENTS Deleted Note 2 to the SURVEILLANCE REQUIREMENTS which would have allowed a 2 hour delay for entry into associated Conditions and Required Actions when a channel was made inoperable solely to perform required Surveillances. NRC comment  3.3.8.1-2 indicated that use of the Note was a less restrictive change than CTS. After discussion with the system engineer regarding the usefulness of the Note in the performance of associated Surveillance instructions    it determined that the Note was of little benefit and should be was deleted.
BASES,  BACKGROUND Added a sentence to the last paragraph stating "The channel devices for each shutdown board are listed in Table B 3.3.8.1-1". The new table added to the end of the BASES lists  UNIDs by board  for the instrumentation of concern.
BASES, ACTIONS Incorporated the addition of new REQUIRED ACTION A.1 and renumbering of existing REQUIRED ACTION A.1 to A.2 into the BASES. This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine    if it  is out-of-service for maintenance or other reasons, and does not necessitate the perfcrmance of Surveillances which demonstrate its OPERABILITY.
Incorporated the addition of    new REQUIRED ACTION B.1 and renumbering of existing REQUIRED ACTION B.l to B.2 into the BASES. This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine    if it  is out of service for maintenance or other reasons, and does not necessitate the performance of Surveillances which demonstrate its OPERABILITY.
Incorporated the addition of new REQUIRED ACTION C.l and renumbering of existing REQUIRED ACTION C.1 to C.2 into the BASES. This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine    if it  is out of service for maintenance or other reasons, and does not necessitate the performance of Surveillances which demonstrate its OPERABILITY.
Page 23 of 24
 
EXECUTIVE
 
==SUMMARY==
 
PROPOSED TECHNICAL SPECIFICATIONS (TS) -3S2 IMPROVED STANDARD TS (ITS)- SUPPLEMENT TO ITS SECTION          3.3 BASES,    SURVEILLANCE REQUIREMENTS Deleted description and BASES of Note          2 which was deleted from the Surveillance Requirements.
SECTION 3 3 8 2 ~ REACTOR PROTECT ION SYSTEM (RPS          ) ELECTRI C POWER MONITORING SURVEILLANCE REQUIREMENTS Deleted Note to    SR 3.3.8.2.1 which stated "Only required to be performed    prior to entering MODE 2 or 3 from MODE 4, when in  MODE 4  for R 24 hours". This was deleted because the CHANNEL FUNCTIONAL TEST (SR 3.3.8.2.1) and the CHANNEL CALIBRATION (SR 3.3.8.2.2) are both performed at the same 184-day frequency (and thus performed together)          and, hence, the note    was not applicable to the CHANNEL CALIBRATION.
Based on the above, the note has no effect on when the CHANNEL FUNCTIONAL TEST is performed and should be deleted.
This is in response to NRC comment 3.3.8.2-3.
SURVE ILLANCE REQUIREMENTS U'ASES
                ~
Deleted reference to Note to        SR  3.3.8.2.1 which  was  deleted, and added "The 184-day Frequency is based on operating experience and the need to calibrate the instrument loop and sensor".
REFERENCES Deleted Reference 2,        "NRC Generic Letter 91-09,
        'Modification of Surveillance Interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System." This reference was deleted because the suggested relaxation of the Frequency of the CHANNEL FUNCTIONAL TEST is negated by the requirement to perform the CHANNEL CALIBRATION at the same Frequency based on Setpoint Analysis.
Page 24 of 24
 
0}}

Latest revision as of 15:39, 3 February 2020

Forwards Supplemental Info in Support of TS-362 Amend Request Re Section 3.3, Instrumentation. NRC Questions on Section Provided as Ref in RAI Dtd 970612
ML18039A226
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 12/29/1997
From: Abney T
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A227 List:
References
TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9801150071
Download: ML18039A226 (118)
v • d • e


Text

C Enclosure ITS Section 3.3 Instrumentation Enclosnre Contents Enclosed?

~ Response to NRC questions Yes

~ Summary Description of ITS/ITS BASES Changes. Yes

~ ITS Revised Pages Yes

~ ITS BASES Revised Pages Yes

~ CTS Hark-up Revised Pages. . Yes

~ Justifications for Changes to CTS (DOCs)

Revised Pages Yes NUREG-1433 BWR/4 STS Mark-up Revised Pages. Yes

~ NUREG-1433 BWR/4 STS Bases Hark-up Revised Pages. Yes Justification for Changes to NUREG-1433 {JDs)

Revised Pages Yes

~ No Significant Hazards Considerations Revised Pages Yes

~ Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433. Yes

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE 3.3.1.1-1 CTS TABLE 3.1.A, NOTE IA ALLOWS ONE HOUR BEFORE THE REDUCTION FROM I HOUR TO IMMEDIATELYFOR 8/28/97 INITIATIONOF CONTROL ROD INSERTION. ITS 3.3.1.1, INSERTION OF ALLCONTROL RODS IF REQUIRED OPERABLE REQUIRED ACTION H.l DOES NOT ALLOWTHIS I HOUR OR TRIPPED FUNCTIONS FOR REFUEL MODE ARE NOT PERIOD. MAINTAINEDIS MADE TO BE CONSISTENT WITH NUREG-1433. SINCE SUFFICIENT TIME FOR ACTIONS ASSOCIATED WITH CONDITIONS A, B, AND C IS PROVIDED (AND EXTENDED FROM THE CTS ALLOWEDTIMES) IT IS CONCLUDED THATTHE REDUCTION OF THIS SPECIFIC TIME IS ACCEPTABLE FOR BFN.

3.3.1.1-2 THE UNIT I CALIBRATIONFREQUENCIES OF CTS TABLE THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l. 8/28/97 4.1.B ARE CHANGED FROM 3 MONTHS TO 18 MONTHS TO A GENERIC RESPONSE THAT STATES MAKINGUNIT I DUPLICATE THE UNIT2 & 3 LESS RESTRICTIVE CONSISTENT WITH UNITS UNIT 2 & 3 IS DONE FOR FREQUENCIES OF CTS TABLE4.1.B AS AN CONSISTENCY AND THAT THE UNIT I TECHNICAL ADMINISTRATIVECHANGE RESULTING IN ITS TABLE SPECIFICATIONS WILLBE VERIFIED CORRECT PRIOR TG 3.1.1-1 FUNCTIONS 3,4,&6 RATHER THAN AS A LESS UNIT ] STARTUP. THIS WILLBE A COMMENT TO RESTRICTIVE CHANGE. REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITI'ALSHOULD BE RE URED.

3.3.1.1-3 THE TSV AND TCV APPLICABILITYIS CHANGE TO 230% SPECIFIC QUESTION ADDRESSED BY ADDINGADDITIONAL 8/29/97 RTP FROM 1ST STAGE PRESSURE (1 54 PSIG. A INFO TO NOTE A6 PAGE I OF JFC 3.3.1.1. THE UFSAR STATEMENT IS MADETHAT THE TWO LIMITSARE SECTION 14.5.1.5 ADDRESSES THE SETPOINT BEING 154 PSIG IDENTICALWITHOUTAPPROPRIATE REFERENCES OR AND 30% RATED POWER BEING THE BYPASS POINT WHICH JUSTIFICATIONS TO CONCLUDE THE CHANGE IS DEMONSTRATES THATTHE TWO VALUES ARE ADMINISTRATIVE INTERCFIANGEABLEFOR THESE PERMISSIVE APPLICATIONS. THIS INFORMATIONWAS ADDED TO NOTE A6 BY ADDINGA SHEET la TO THE SECTION 3.3.1.1 JFC.

3.3.1.14 DOC A 12 DISCUSSES THAT HIGI.IREACTOR PRESSURE, DOC A12 WILLBE REWIUTTEN TO MORE CLEARLYSHOW 5/2/97-HIGH DRYWELLPRESSURE AND LOW WATER LEVEL THAT THE EXISTING NOTE 7 WHICH STATES "WHEN THE.

FUNCTION ARE DELETED FOR MODE 5. NOTES 8 & 10 DO REACTOR IS SUBCRITICALAND THE REACTOR WATER NOT APPLY TO LOW WATER LEVEL. THE NOTES STATE TEMPERATURE IS LESS THAN 212'F, ONLY THE FOLLOWING THAT REFUEL MODE DOESN'T APPLY IF CONTAINMENTIS TRIP FUNCTIONS NEED TO BE OPERABLE:

NOT REQUIRED (NOTE 8) OR IF THE HEAD IS UNBOLTED A. MODE SWITCH IN SHUTDOWN (NOTE 10). DOC A12 DOES NOT ACCURATELYDISCUSS B. MANUALSCRAM THE CHANGES THATARE BEING PROPOSED. C. HIGH FLUX IRM C. SCRAM DISCHARGE VOLUMEHIGH LEVEL" NOTE 7 NEGATES THE NEED FOR THE DELETED REQUIREMENTS WHERE BECAUSE REFUEL MODE ASSURES THAT THE REACTOR IS SUBCRITICALAND THE REACTOR WATER TEMPERATURE IS LESS THAN 212'F.

PAGE

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COhf PLETE Y/N DATE 3.3.1.1-5 THIS DOC DISCUSSES A MXTURE OF CHANGES TO JUS11FICATION (A14) WAS CHANGED TO L6 AND 5/2/97 ACTION STATEMENTS FOR RPS TRIPS. THE DOC STATES JUSTIFICATION BASE D ON THE LESS RESTRICTIVE OPTIONS THATACTION 1.A HAS BEEN DELETED SINCE IT BEING ACCEPTABLE AND THEREFORE THE REQUIREMENT CONTAINS AN OBVIOUS REQUIREMENT. ACTION I.A IS TO INSERT RODS UNNECESSARY BUT STILL AVAILABLETO AN OPTIONAL ACTION FOR THE OPERATOR AND ITS THE OPERATOR IF DESIRED.

DELETION RESULTS IN A LESS RESTRICTIVE SINCE OPTIONAL REQUIREMENTS ARE REMOVED. PROVIDE REVISED DISCUSSION THATADDRESS PROPOSED CHANGES.

3.3.1.14 THE IS NO DESIGN CHANGE FROM CTS TO ITS. BUT, THE A7 ADDRESSES THE NUMBER OF CKQBKLS REQUIRED.. 9/3/97 ITS PROPOSES 8 (REQUIIRED) CHANNELS PER TRIP THIS NOTE NEEDS TO BE REVISED TO BETTER EXPLAIN SYSTEM WHILETHE CTS IS 4 (MINMUMOPERABLE) THAT THE CTS USED 4 CHANNELS BASED ON RPS CHANNEL PER TRIP SYSTEM. EXPLAINWHYTHIS CHANNELS Al, A2, Bl dc B2 WHEREAS IN THE ITS TO BETTER CHANGE IS CONSIDERED ADMMSTRATIVE. MEET THE DEFMTION OF "CHANNELS PER TRIP SYSTEM" THE TOTAL NUMBER OF INPUTS FROM THE VALVELIMIT SWITCHES WILLBE USED.

M2 AND M3 ARE DESCRIPTIONS OF MORE RESTRIC11VE 11/18/97 3.3.1.1-7 THE M-DOC DISCUSSIONS LACKA SAFETY IMPACT CHANGES. M2 ADDRESSES ADDINGA 4 HOUR TIME LIMT JUSTIFICATION FOR THE PROPOSED CHANGES.

ON TABLE 3.).A ACTION I.D WHICH PREVIOUSLY HAD NO TIME LIMIT. M2 ADDRESSES ADDINGA NEW SURVEILLANCETO VERIFY THAT SRM AND IRM CHANNELS OVERLAP PRIOR TO WITHDRAWINGTHE SRMs FROM THEIR FULLYINSERTED POSITION. JFC M2 AND JFC M3 WILLBE REVISED TO ADDRESS SAFETY MPACT.

THE NOTES ADDED WITH THE SURVEILLANCE 9/3/97 3.3.1.1-8 THE IRM HIGH FLUX SR CALIBRATIONDISCUSSION DOES REQUIREMENT 3.3.1.1.9 ARE CONSISTENT WITH THE NOTES NOT INCLUDE DISCUSSION OF THE NOTES THATARE FOR SR 3.3.1.1.11 AND 3.3.1.1.13 WHICH IS FROM WHICH SR ALSO ADDED AS PART OF TI IE SR.

3.3.1.1.9 WERE TAKEN AS DOCUMENTED BY JFC P55. M4 WILLBE REVISED TO ADDRESS THE NOTES AS WELLAS THE SR.

VERIFICATIONOF IRM/APRM OVERLAP HAS BEEN 9/3/97 3.3.1.1-9 VERIFICATIONOF THE IRM/APRMOVERLAP DURING CHANGED FROM STARTUP ( CTS) TO SHUTDOWN (ITS).

SHUTDOWN THAT IS NOT REQUIRED BY THE CTS IS AN THIS CHANGE IS ADDRESSED BY A REVISED JFC M5 AND A ADDITIONALRESTRICTION ON PLANT OPERATION.

NEW JFC L7 WHICH ADDRESSES BOTH THE MORE RESTRICTIVE ASPECTS OF THE NEW REQUIREMENT AND THE LESS RESTRICIVE ASPECTS OF DELETING THE OLD, RE UIREMENT.

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE THIS IS TIED TO ISSUE 3.3.1.1-9 BECAUSE THE DELETION OF 9/5/97 3.3.1.1-10 DELETION OF VERIFICATIONOF OVERLAP DURING IRM/APRM OVERLAP DURING STARTUP WAS DELETED OOS STARTUP IS LESS RESTRICTIVE ON PLANT OPERA11ON.

BASED ON THE ADDITIONOF IRM/APRM OVERLAP DURING SHUTDOWN. IT IS TRUE THATTHE DELETION IS LESS RESTRICTIVE AND THUS JFC M5 WILLBE REVISED AND L7 WILLBE ADDED.

3.3.1.1-1 I AN RPS CIIANNELTEST SWITCH FUNCTION IS ADDED TO THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED 9/5/97 TO THE NRC FOR APPROVAL. NO CHANGES THE CTS OR ITS THE LIST OF FUNCTIONS IN ITS TABLE 3.3.1.1-1, FUNCTION MARKUPS ARE REQUIRED.

12.

THE FREQUENCY OF CALIBRATIONFOR THE APRM FLOW 9/9/97 3.3.1.1-12 INCORRECT DOC. THE APRM FLOW BIASED CFIANNEL BIAS INSTRUMENTATIONHAS BEEN CHANGED FROM ONCE CALIBRATIONFREQUENCY IS CHANGE TO QUARTERLY PER OPERATING CYCLE TO ONCE PER 92 DAYS. THIS WAS FROM ONCE PER OPERATING CYCLE.

AN ERROR IN THE CTS MARKUPS AS IS EVIDENCED BY THE REFERENCE TO JFC A4 WHICH INDICATES A NOMENCLATURE CHANGE FROM REFUELING CYCLE TO 18 MONTHS. ALSO, IN THE ITS BASES SR 3.3.1.1.11 ON PAGE B3.3-30 k 31 ADDRESS THE BASES FOR THE APRM FLOW BIASED FUNCTION STATES THE 18 MONTH FREQUENCY IS BASED ON SYSTEM DESIGN. CTS TABLE 4.1.B WILLBE REVISED TO CHANGE 92 DAYS TO 18 MONTHS AND CHANGE REFERENCED SR FROM 3.3.1.1.9 TO SR 3.3.1.1.11.

THIS TABLE (MATIRX)IS BEING PREPARED BY BILLY 3.3.1.1-13 PROVIDE A TABLE LISTING EACH ITEM THAT IS MOVED THIBADEAUX. THIS SHOULD NOT IMPACTTHE CTS OR ITS TO AN OWNER-CONTROLLED DOCUMENT. FOR EACH ITEM DESCRIBE TFIE NAME OF THE DOCUMENT THAT

~UPS BUT WILLBE SUBMI1TED AS A RESPONSE TO THIS ISSUE.

THE ITEM IS MOVED TO AND THE REGULATORY CONTROL MECHANISMWFIICH WILLCONTROL FUTURE PROPOSED CHANGES.

CONCUR THATTHE CHANGE IS ADMINISTRAllVEBECAUSE 9/8/97 3.3.1.1-14 NOTE 2 OF ITS SR 3.3.1.1 HAS TFIE REVISED WORDING "THE ASSOCIATED FUNCllONS MAINTAINSRPS TRIP IT IS A CLARIFICATIONOF EXISTING NOTE. JFC LBI WILLBE CAPABILITY"THAT ASSURES TRIP FUNCTION CAPABILITY CHANGED TO JFC A15.

FOR ALLDESIGNS. THIS CHANGE APPEARS ADMINISTRATIVE,RATHER TING LESS RESTRICTIVE.

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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM INCORP COMPLETE COMMENT ¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE THE REQUESTED DOCUMENTATIONWILLBE SUBMTTED 9/5/97 3.3.1.1-15 THE CHANNEL FUNCTIONALTEST INTERVALOF RPS TO THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR OOS CHANNELS AND TRIP SYSTEMS (ITS TABLE 3.3.1.1-1, ITS MARKUPS ARE REQUIRED.

FUNCTIONS 2, 3, 4, 5, 7, 8, 9, AND 11) ARE EXTENDED TO 92 DAYS FROM THE MONTHLYREQUIREMENT OF CTS TABLE4.1.A, BASED ON THE RELIABILITYANALYSIS OF "TECHNICALSPECIFICATION IMPROVEMENTANALYSES FOR BWR REACTOR PROTECTION SYSTEM," (NEDC-30851-P-A, MARCH 1988) AND AN UNREFERENCED BAN REPORT "TECHNICALSPECIFICATION MPROVEMENT ANALYSES FOR BROWNS FERRY NUCLEAR PLANT, UNIT 2," (MED 0286, OCTOBER 1995.)

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED 9/8/97 3.3.1.1-16 THE ITS 3.3.1.1, CONDITION A, COMPLETION TIME IS TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS EXTENDED FROM 1 HOUR IN CTS TABLE 3.1>, NOTES I ITS MARKUPS ARE REQUIRED.

AND 23, TO 12 HOURS.

THE ITS 3.3.1.1, CONDITION B, COMPLETION TME IS EXTENDED FROM I HOUR IN CTS TABLE 3.1.A, NOTES I AND 23, TO 6 HOURS.

THE AOT FOR PLACING A CHANNEL IN TRIP FOR REQUIRED SURVEILLANCETESTING IS EXTENDED FROM THE 4 HOURS OF CTS TABLE 3.1.A, NOTE 23, TO 6 HOURS IN ITS TABLE 3.3.1.1-1.

THESE CHANGES ARE BASED ON THE RELIABILITY ANALYSIS OF "TECHNICALSPECIFICATION IMPROVEMENTANALYSES FOR BWR REACTOR PROTECTION SYSTEM," (NEDC-30851-P-A, MARCH 1988)

AND AN UNREFERENCED BAN REPORT "TECHNICAL SPECIFICATION IMPROVEMENTANALYSES FOR BROWNS FERRY NUCLEAR PLANT, UNIT 2," (MED-32-0286, OCTOBER 1995.)

JFCs Ll AND L2 WILLBE REVISED TO ADD ADDITIONAL 9/15/97 3.3.1.1-17 Ll DOES NOT DISCUSS CHANGES PROPOSED TO CTS "

DETAILS ON THE PROPOSED CHANGES. MODE 5 WILLBE NOTE (7). ADDED TO ITS TABLE 3.3.1.1-1 FUNCTIONS 2a AND 2e AS INDICATEDBY CTS TABLE 3.1.A NOTE 21 MARKUP ANDADD L2 DOES NOT DISCUSS MANUALSCRAM FUNCTION JFC P92 TO JUSTIFY STS CHANGE.

CHANGES.

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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM INCORP COMPLETE COMMENT 4 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC L4 WILLBE REVISED TO ADD ADDITIONAL Y 9/16/97 3.3.1.1-18 A NOTE IS ADDED TO THE HEAT BALANCECALIBRATION JUSTIFICATION FOR ALLOWINGTHE 12 HOURS AFTER WHICH ALLOWS DELAYIN PERFORMING THE SR UNTILA EXCEEDING 25% RTP TO PERFORM THE HEAT BALANCE PRESCRIBED POWER LEVEL IS REACHED. THE SAFETY CALIBRATION.

BASIS EVALUATIONSTATES ACCEPTANCE BASED ON OPERATING EXPERIENCE. BFNP HAS NEVER PERFORMED THE SURVEILLANCEWITH THE PROPOSED NOTE. WHAT IS THE BASIS FOR THE OPERATING EXPERIENCE JUSTIFICATION?

CTS TABLE 3.1.A NOTE I MARKUP WILLBE REVISED TO Y 9/16/97 3.3.1.1-19 LB2 & L5 BOTH APPLY TO THE SAME BALLOONEDTEXT INTHE ~UP OF TABLE 3.1.A, NOTE (I). LS AS STATED DELETE LB2 JFC FOR SECTION THAT LISTS BOTH LB2 AND LS. FOR THE UNIT I MARKUP A SECTION BELOW THAT HAS DOES NOT PROVIDE APPROPRIATE JUSTIFICATION FOR NO JFC FLAG WILLHAVB LB2 FLAG ADDED. JFC LS WILL THE BALLOONEDTEXT. BE REVISED TO BETfER REFLECT THE APPROPRIATE JUSTIFICATION FOR THE CHANGE.

JFC P58 WILLBE REVISED TO PROVIDE ADDITIONAL Y 9/17/97 3.3.1.1-20 THE FUNCTION OF THE TIME CONSTANT CIRCUIT OF STS JUSTIFICATION FOR DELETION OF CALIBRATIONOF THE SR 3.3.1.1.14 IS TO SIMULATEFLOW COAST DOWN FOR APRM FLOW BIASED SIMULATEDTHERMALPOWER CIRCUIT THE APRM. ITS 3.3.1.1 DOES NOT IMPLEMENTTHIS TIME CONSTANT.

SURVEILLANCE. DELETING THE TIME CONSTANT TESTING IN STS SR 3.3.1.1.14 OF THE APRM FLOW BIASED SIMULATEDTHERMALPOWER CIRCUIT IS NOT SUFFICIENTLY SUPPORTED.

JFC P4 PROVIDES ADEQUATE JUSTIFICATION FOR NOT N 9/17/97 3.3.1.1-21 STS SR 3.3.1.1.17 REQUIRES RPS 1lME RESPONSE TESTING.

INCLUDINGRESPONSE TIME TESTING AS A SURVEILLANCE ITS 3.3.1.1 DOES NOT IMPLEMENTTHIS SURVEILLANCE. REQUIREMENT. BFN DOES NOT CURRENTLY PERFORM DELETING THE RPS TIME RESPONSE TESTING IN ITS RESPONSE TIMETESTING AND THE BENEFITS OF ADDING 3.3.1.1 IS NOT SUFFICIENTLY SUPPORTED BY JFC OR THIS SR BASED ON THE UNLKELY POSSIBILITY OF THE BASES. RESPONSE TIMES SIGNIFICANTLYCHANGING THAT WOULD IMPACT THE ABILITYOF THE RPS TO PERFORM ITS SAFETY FUNCTION WITHOUT BEING IDENTIFIED DURING OTHER REQUIRED FUNCTIONALTESTS AND CALIBRATIONS DOES NOT JUSTIFY THE ADDITIONAL OUT OF SERVICE TIME FOR TI.IE RPS INSTRUMENTATIONOR ADDITIONAL BURDEN ON THE PLANT STAFF. (NOTE REQUESTED BERT MORRIS GUIDANCE ON THIS 9/17/97 3.3.1.1-22 TIK LOW SCRAM PILOT AIR HEADER PRESSURE SURVEILLANCE OF ff$ SR 3 3 I I I 6 APPLIES TP UNITS 2 & SC~ PROT ~ ~ER P~S~

JFC P60 WILLBE REVISED TO DOCUMENT THATTHE LOW NSW~MATION HAS NOT BEEN IMPLEMENTED ON UNIT I AND THEREFORE Y 9/18/97 3 BUT NOT UNrr1 No JUSTIFICATION OR EXPLANATION THIS SURVEILLANCEWAS NOT APPLICABLE.

PAGE 5

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT P DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE PREVIOUS JUSTIFICATION IN JFC P16 AND P79 ARE 9/18/97 3.3.1.1-23 THE DELETION OF THE STS BASES FOR THE SR 3.3.1.1.16 APPLICABLE. RETURNING THE SENSORS ONLINE WILL REQUIREMENT THAT THE MAINTURBINE BYPASS HAVE NO IMPACT UPON THE TURBINE VALVESAS THE VALVES MUST BE CLOSED WHEN CALIBRATIONIS ONLY LOGIC TIE IS IN THE REACTOR PROTECTION SYSTEM PERFORMED AT > 30% RTP SHOULD BE RECONSIDERED SUCH THAT TO RECEIVE A HALF SCRAM REQUIRES A IF ACTUALSTEAM PRESSURE IS USED TO VERIFY THE CLOSURE SIGNALFROM THE TURBINE STOP VALVES OR CALIBRATION. ITS BASES TURBINE CONTROL VALVESAND THE INDICATIONOF >30%

SR 3.3.1.1.15, FUNCTIONS 8 & 9, DO NOT HAVE THIS RTP FROM THE TURBINE FIRST STAGE PRESSURE REQUIREMENT. WHILETHE JUSTIFICATION THATAN SWITCHES. SINCE THE CALIBRATIONWILLNOT VERIFY ISOLATED SENSOR CAN BE TESTED WITH A GAGE CALIBRATORINDEPENDENT OF BYPASS VALVEPOSITION ANY FUNCTION OTHER THAN A POTENTIAL RPS HALF SCRAM AND THE PRESSURE SWITCHES ARE REMOVED IS TRUE, THE CALIBRATIONTHAT IS ADDRESSED BY ITS FROM THE PROCESS AND CALIBRATEDWITH A PRESSURE SR 3.3.1.1.15 IS NOT ONLY STEAM PRESSURE BYPASS TRIP SOURCE (NEGATING ANY IMPACT A BYPASS VALVEWOULD SETPOINT AND FUNCTION, BUT ALSO DEMONSTRATES HAVE ON THE CALIBRATION) THERE IS NO AFFECT FROM THATTHE FUNCTION IS VERIFIED BY PARTIAL THE BYPASS VALVES (AS STATED IN JFC P79) AND MOVEMENTOF THE TURBINE VALVES AFTER THE THEREFORE THE DELETION OF REQUIREMENT FOR THE SENSOR IS RI:"mRNED ON-LINE.

BYPASS VALVES TO BE CLOSED WHEN CALIBRATION OCCURS IS ACCEPTABLE THIS WAS PREVIOUSLY ADDRESSED IN RESPONSE TO ISSUE 9/18/97 3.3.1.1-24 CTS REQUIRE A CHANNEL CALIBRATIONONCE PER 3.3.1.1-12 AS FOLLOWS:

OPERATING CYCLE. THE CTS MARKUP SHOWS THIS THE FREQUENCY OF CALIBRATIONFOR Tl&APRM FLOW FREQUENCY IS CHANGED TO 92 DAYS AND IS RENAMED BIAS INSTRUMENTATIONHAS BEEN CHANGED FROM ONCE SR 3.3.1.1.9. IN THE ITS THE SAME SR IS 3.3.1.1.11 AND PER OPERATING CYCLE TO ONCE PER 92 DAYS. THIS WAS CARIUES A 184 DAY FREQUENCY. JFC P89 STATES THAT AN ERROR IN THE CTS MARKUPS AS IS EVIDENCED BY THE THE APRM DESIGN IS SUCH THAT THE FUNCTION CAN REFERENCE TO JFC A4 WHICH INDICATES A ONLY BE TESTED AT REFUELING WITHOUT CAUSING NOMENCLATURECHANGE FROM REFUELING CYCLE TO 18 MULTIPLEINOPERABLE APRMS AND A REACTOR TRIP.

MONTHS. ALSO, IN THE ITS BASES SR 3.3.1.1. I I ON PAGE RECONCILE THE APPARENT DISCREPANCIES BETWEEN B3.3-30 & 31 ADDRESS THE BASES FOR THE APRM FLOW THE CTS MARKUP, ITS MARKUP AND JFC 89.

BIASED FUNCTION STATES THE 18 MONTH FREQUENCY IS BASED ON SYSTEM DESIGN. CTS TABLE 4.1.B WILLBE REVISED TO CHANGE 92 DAYS TO 18 MONTHS AND CHANGE REFERENCED SR FROM 3.3.1.1.9 TO SR 3.3.1.1.11.

JFC P91 WILLBE REVISED TO ADDRESS THE DEVIATION 9/19/97 3.3.1.1-25 THIS SR APPLIES A 92 DAYCALIBRATIONFREQUENCY TO FROM THE STS.

RPS APRM TRIP FUNCTIONS WHICH OTHERWISE HAVE EITHER A 7 DAYOR REFUELING INTERVAL.

PAGE 6

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM DESCRIPTION OF ISSUE INCORP COMPLETE COMMENT II PROPOSED RESOLUTION Y/N DATE SINCE THE ADDITIONOF CHANNEL CHECKS WOULD BE A 9/18/97 3.3.1.1-26 CHANNEL CHECKS ARE NOT ADOPTED AS PART OF THE NEW REQUIREMENT THAT BFN IS NOT PRESENTLY ITS FOR DRYWELLPRESSURE HIGH AND SDV TRIP REQUIRED TO MEET THE CHOICE NOT TO IMPLEMENT FUNCTIONS.

DOES NOT REQUIRE FURTHER JUSTIFICATION. THE CONVERSION FROM CTS TO ITS WAS NOT TO IMPOSE NEW RE UIREMENTS.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED 9/19/97 3.3.1.1-27 ADDITIONOF CHANNELTEST SWITCHES WAS CREDITED IN TI-IE ANALYSIS OF NEDO-3851 FOR EXTENDING TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS ITS MARKUPS ARE REQUIRED.

AUTOMATICSCRAM FUNCTION FREQUENCIES.

DISCUSSION OF MINMUMREQUIREMENTS FOR FUNCTIONS 9/9/97 3.3.1.1-28 A BLOCK OF TEXT IS MOVED FROM STS BASES, TO MAINTAINTRIP CAPABILITYARE TYPICALLYINCLUDED REQUIRED ACTIONS C.I, TO AN UNIDENTIFIEDPL@K DOCUM'.NT. ITS BASES, REQUIRED ACTIONS C. I, DOES IN THE BASES IN OTHER LCOs. THEREFORE, THE NOT ~AIN TMS INFORMATION. DISCUSSION OF MINIMUMREQUIREMENTS FOR THE RPS FUNCTIONS TO MAINTAINTRIP CAPABILITYHAS BEEN ADDED BACKTO THE BASES FOR ACTION C.l OF LCO 3.3.1.1.

REVISIONS HAVE BEEN MADETO THE NUREG WORDING TO REFLECT BFN DESIGN AND JFC P15 HAS BEEN REVISED TO ADDRESS THESE CHANGES.

THE APPLICABILITYOF JFC LA2 WILLBE DELETED FROM 5/19/97 3.3.1.1-29 NOTE 17 PROVIDES EXCEPTIONS TO CTS APRM NOTE 17 AND JFC M8 WILLBE ADDED TO ADDRESS THE OPOERABILITYREQUIREMENTS. LA2 PROPOSES TO REMOVALOF EXCEPTION TO OPERABILTY OF THE APRM RELOCATE THESE EXCEPTIONS.

FUNCTIONS, THATREFERTONOTE17, DURING "LOW POWER PHYSICS TESTS" .

NOTE 19 IS SPECIFIC TO THE TURBINE FIRST STAGE 5/19/97 3.3.1.1-30 NOTE 19 ESTABLISHES ALTERNATEREMEDIALACTIONS PERMSSIVE FUNCTION WHICH WAS RELOCATED BASED ON JFC LAS. SINCE NOTE 19 HAS NO PURPOSE OTHER THAN CLARIFICATIONOF ACTIONS FOR THE TURBINE FIRST STAGE PERMSSIVE THE JUSTIFICATION FOR THE RELOCATION OF THE REQUIREMENTS IN NOTE 19 WILLBE CHANGED TO LA5 WHICH BETTER DESCRIBES THE RATIONAL.

IN ESPONSE TO ISSUE 3.3.1.1-17 MODE 5(a) WAS ADDED TO 5/19/97 3.3.1.1-31 NOTE 21 IS SHOWED TO BECOME TABLE 3.3.1.1-1 NOTE (A)

ITS FUNCTIONS 2 a AND 2 e WHICH INCORPORATED THE AND APPLIES TO FUNCTIONS 2.A AND 2.E. IN TABLE I NOTE (A) DOES NPTAPPLY TP FUNCTIONS 2 A NOTE 21 EQ~~. ALL EQUIRED CHANGES TO THE ITS TO CORRECT THIS OMISSION WERE MADE IN RESPONSE TO ISSUE 3.3.1.1-17.

PAGE 7

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.1, REACTOR PROTECTION SYSTEM COMMENT ¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE NOTE I STATES "INI'IIALLY THE MINIMUMFREQUENCY FOR N 5/19/97 3.3.1.1-32 NOTE I STATES THATTHE MINIMUMFREQUENCY FOR THE INDICATEDTESTS SHALL BE ONCE PER MONTH". THIS THE TEST SHALL BE AT LEAST ONCE PER MONTH.

NOTE REFERRED TO FIGURE 4. I-l WHICH PROVIDED A BASES FOR THE CALIBRATIONINTERVALSELECTION BASED ON FAILURE INTERVAL. THE BASES FOR THE TEST INTERVALS IS INCLUDED IN THE ITS BASES AND THUS JFC LA2 IS APPLICABLE BECAUSE THE DETAILS OF SELECTION OF TEST INTERVALS IS INCLUDED IN THE BASES. NO CORRECTIONS ARE RE UIRED DUE TO THIS ISSUE.

PAGE 8

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC Mg WILLBE REVISED TO CORRECT A Y 9/23/97 3.3.1.2-1 ITS 3.3.1.2, Conditions A, B and C, allow up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> MSINTERPRETATION THAT CTS 3.3.B.4 DEFAULTS TO CTS for Conditions A and B and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Condition C) before the 1.0.C. I WHICH WOULD REQUIRE PLANT TO BE IN COLD reactor must be in Mode 3 when SRM OPERABILITY SHUTDOWN WITIK430 HOURS. CTS 1.0.C.1 IS NOT requirements are not satisfied versus the CTS 3.3.B.4 requirement APPLICABLE IN THIS CASE BECAUSE THE ASSOCIATED of being in MODE 4 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. REQUIREMENTS WOULD BE FULFILLEDBY NOT WITHDRAWINGANY CONTROL RODS IF TWO SRM The change of going to Mode 3 rather than MODE 4 is less CHANNELS DO NOT HAVE AN OBSERVED COUNT RATE OF 3 restrictive, even ifmore time is allowed. CPS (THE REQUIRMENT IS TO NOT WITHDRAWCONTROL RODS). THUS THE INCLUSION OF TIME LIMITS ON ACTIONS The change of going to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> rather than 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> is a more FOR CONDITIONS A, B, AND C IS MORE RESTRICTIVE SINCE restrictive change.

A TIME LIMIT DID NOT EXIST PREVIOUSLY.

THE WORDS "THE SRM SHALL BE INSERTED TO THE N 9/25/97 3.3.1.2-2 The requirement that "The SRM shall be inserted to the normal NORMALOPERATING LEVEL"ARE NOT SPECIFICALLY operating level'as not carried into the Bases as stated.

STATED IN THE ITS BASES BUT THE INTENT IS STATED IN THE ITS BASES BACKGROUND AS "THE SRMs ARE MAINTAINEDFULLYINSERTED UNTILTHE COUNT RATE IS GREATER THANA MNIMUMALLOWCOUNT RATE ...

AFTER SRM TO INTERMEDIATE RANGE MONITOR (IRM)

OVERLAP IS DEMONSTRATED ... THE SRMs ARE NORMALLY FULLYWITHDRAWNFROM THE CORE". IN ADDITION OTHER PARTS OF THE ITS BASES SPECIFY THE REQUIRED LOCATION OF THE SRM SENSOR. FOR EXAMPLETHE LCO BASES STATES "COVERAGE IS PROVIDED BY ONE SRM TO BE OPERABLE IN TIN QUADRANTOF THE REACTOR CORE WHERE CORE ALTERATIONSARE BEING PERFORMED, AND THE OTHER SRM TO BE OPERABLE IN AN ADJACENT QUADRANTCONTAININGFUEL". THUS IT IS CONCLUDED THAT THE BASES ADEQUATELYADDRESSES THE LOCATION OF THE SRM IN ORDER TO DECLARE IT OPERABLE AND NO CHANGES ARE NECESSARY.

A LEAD IN TO THE MORE RESTRICTIVE JFCs WILLBE ADDED Y 11/19/97 3.3.1.2-3 Each discussion of change should be revised to discuss the TO PROVIDE JUSTIFICATION FOR THE CHANGES BEING AN justification or the basis for concluding the change are an ENHANCEMENT.

appropriate enhancement to TS.

SEE ATfACHMENTI FOR PROPOSED RESOLUTION N 11/1/97 3.3.1.24a The proposed ITS make use of spiral oflload procedures and adopt OOS a revision to SR 3.3.1.2.4 Note 2 for count rate verification during spiral loading. These are changes to the CTS allowances and the revision to the SR Note is a change to the STS.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR INCORP COMPLETE DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE CTS 4.10.B.2 WILLBE MARKED UP TO ADD THE 24 HR 9/26/97 3.3.1.2Mb CTS core monitoring surveillances require periodic verification of REQUIREMENT AND JFC M9 WILLBE ADDED TO DESCRIBE signal to noise ratio once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during core alterations. The THE MORE RESTRICTIVE CHANGE.

ITS include this requirement and an additional verification of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during applicable modes. The required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing is not dispositioned in either the DOCs or the JFC.

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.1.2, SOURCE RANGE MONITOR ATTACHMENT1 3.3.1.2-4a PROPOSED RESPONSE There is no NRC staff acceptance review for operations allowing spiral loading/off-loading. The following is a technical justification for the practice of using a spiral off-loading/loading process A spiral off-loading involves off-loading the sub~ritical core (the reactor is shutdown) by removing fuel from the outer edges of the core in a spiral sequence around the core. The core size is continuously reduced thus decreasing reactivity from the already subwritical configuration. By following a spiral off-loading pattern, reactivity is guaranteed to decrease as the core size gets smaller. No positive reactivity changes to the core willbe made during spiral off-loading. Therefore, the core monitoring surveillance is not required to be followed during a spiral off-load as it is not ncedcd to monitor the decreasing reactivity.

The safety analysis associated with all of the intermediate configurations of the core during a spiral off-load is bound by the safety analysis of the starting configuration including fuel loading errors and control rod withdrawal errors. Control rods remain inserted until adjacent fuel has been removed. Since shutdown margin calculations assume that the strongest worth rod is withdrawn from the core, leaving all control rods inserted provides substantial analytical margin to criticality.

A spiral loading involves loading the core by placing four fuel assemblics around a source range monitor and successively adding fuel assemblies around the fueled region building a larger core until the final, analyzed core loading pattern is achieved. The final, loaded core is more reactive than the intermediate configurations. The core is continuously monitored by the source range monitor in the center of the fueled region and by the other source range monitors as the fueled region includes these locations.

During the spiral, bridges to the other source range monitors can be built providing additional assurance that the core is appropriately monitored. A reduction in the number of required operable source range monitor channels is acceptable when using a spiral pattern because the use of a spiral pattern centered about an source range monitor provides assurance that the erable source range monitor is in the optimum position for monitoring changes in neutron flux levels resulting from the core eration.

The suety analysis associated with all of the intermediate configurations of the core during a spiral load is bound by the safety analysis of the final configuration.

PAGE 3

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC A3 WILLBE REVISED TO BETTER DESCRIBE THE 9/30/97 3.3.2.1-1 The deletion of the CTS Table 3.2.C surveillance requirements for RATIONALFOR THE EXISTING ROD BLOCK LOGIC BEING A the Rod Block Logic has been justified by observing that other DUPLICATIONIN THE CTS THAT IS ADDRESSED IN THE ITS.

functional tests can test it. In order to be an Administrative change, it would be implemented in the ITS, essentially unchanged. The CTS requires a operating cycle test of the logic whereas the ITS requires a quarterly test. Provide a statement that all components tested by the CTS requirements are included in the ITS SRs, but at a more frequent interval.

A LEAD IN TO THE MORE RESTRICTIVE JFCs WILLBE ADDED 11/19/97 3.3.2.1-2 Each discussion of change should be revised to discuss the TO PROVIDE JUSTIFICATION FOR THE CHANGES BEING AN justification or the basis for concluding the change are an ENHANCEMENT.

appropriate enhancement to TS.

THE PORTION OF THE NOTE PERTAINING TO SRMs, IRMs, 10/I/97 3.3.2.1-3 Portions of the note limit the use of channel bypass for SRMs or AND APRMs ARE ADDRESSED BY JFC Rl AND THUS LA1 IS RBMs during repair or calibration are proposed to be placed in the NOT APPLICABLETO THOSE FUNCTIONS. THUS ONLYTHE Bases using a justification that they are operational details. Because RBM PART OF THE NOTE REMAINS ASSIGNED TO JFC LAI.

the statements establish allowed outage times for repair or test they SINCETHE REMAINING(LAI)PARTOF THE NOTE DOES are instead, operational limits.

ADDRESS THE SAME OPERATIONAL LIMITS, FORTHE RBM, AS NOTE 7.c & 7.d WHICH ARE ASSIGNED TO ACTIONS A & B OF THE ITS THE PART OF THE NOTE FLAGGED TO LA1 WILL INSTEAD BE ASSIGNED TO ACTIONS A&B.

NOTE 7 WILLBE MARKED UP TO REFER TO JFC M3 WHICH 10/2/97 3.3.2.14 LAI is applied to a change which cannot be distinguished from other WILLBE REVISED TO BEITER DESCRIBE THE marks on the page. Provide clarifying documentation.

INCORPORATION OF THE NOTE AND CHANGES TO IT INTO THE ITS. IN ADDITONTHE PART OF NOTE 7.a WHICH STATES Note 7.a provides "operational restraints" to use of RBM bypasses. "OR WHEN A PERIPHERAL CONTROL ROD IS SELECTED" IS The restraint stated as "or when a peripheral control rod is selected" SYSTEM DESIGN AND IS ADDRESSED IN THE ITS BASES THUS is not incorporated in the ITS applicability as noted in the CTS JFC LAI IS APPROPRITAT E FOR THAT SECTIONOF THE NOTE..

markup.

THE PARTOF TABLE 3.2.CNOTE7.c THAT STATES "...AND 10/6/97 3.3.2.1-5 Documentation of RBM operational constraints in Note 7.c related to ONLY ONE OF THESE MAYBE BYPASSED WITH THE the allowance for bypassing only one channel from the console" is CONSOLE SELECTOR" IS A DESIGN FEATURE OF THE SYSTEM not incorporated into ITS Actions A & B as stated.

AND WILLAPPROPRIATELY BE ASSIGNED TO JFC LA2. THE FSAR CURRENTLY STATES "ONE OF THE TWO RBMs CAN BE BYPASSED AT ANYTIME BY OPERATOR ACTION. EffHER RBM CAN INHIBITCONTROL ROD WITHDRAWAL."THE DESIGN PRECLUDES BYPASSING MORE THAN ONE CHANNEL ATATIME. NOTE7.cWILLBEREVISEDTOADDJFCLA2 FLAG TO THE SUBJECT PART.

PAGE I

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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION COMMENT ¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE NOTES 8 AND 13 ARE APPLICABLETO SRM, IRM, APRM, AND Y 10/7/97, 3.3.2.1-8 Both DOCs are applied to this table note which discusml methods RBM FUNCTIONS. THE SRM IRM AND APRM FUNCTIONS for perforining functional tests.

WERE COMPLETELY RELOCATED TO PLANT DOCUMENTS.

THE RBM FUNCTIONS WERE RETAINED IN THE ITS. FOR NOTE 13 THE RELOCATION OF THE DETAILS OF THE FUNCTIONALTEST FOR SRM, IRM, AND APRM FUNCTIONS ARE ADDRESSED BY JFC Rl DUE TO THE TOTAL RELOCATION AND THE SAME IS ADDRESSED BY JFC LA2 FOR THE RBM FUNCTION WHICH JUSTIFKS THE RELOCATION OF THE DETAILS OF PERFORMING THOSE FUNCTIONALS. THUS THE APPLICATION OF BOTH OF THE JFCs TO NOTE 13 IS ACCEPTABLE.

SIMILARLY, JFC Rl ADDRESSES THE RELOCATION OF INSTRUMENT CHECKS FOR THE SRM, IRM, AND APRM FUNCTIONS THE DETAILS OF WHICH ARE DESCRIBED IN NOTE 8. THE DETAILRELOCATION FOR THE INSTRUMENT CHECKS FOR RBM FUNCTIONS ARE ADDRESSED IN JFC R2 RATHER THAN IN LA2 AS INDICTED BY THE FLAGS ON THE NOTE ITSELF (CORRECT IN THE TABLE). THUS THE LA2 FLAG TO NOTE 8 WILLBE CHANGED TO JFC R2.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITfEDTO N 10/3/97 3.3.2.1-9 The CTS Table 3.2.C, Test interval of RBM CHANNEL THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS OOS FUNCTIONALTEST (function I) is extended from I month to 92 MARKUPS ARE REQUIRED.

days in ITS SR 3.3.2.1.1, based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2" (MED-32-0286, October 1995).

THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED TO N 10/3/97 3.3.2.1-10 Adoption of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> delay time limit for entry into associated THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS OOS Conditions and Required Actions during perfonnance of required MARKUPS ARE REQUIRED.

SRs is based on the reliability analysis of GENE-770-06-1, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed-Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.

PAGE 3

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE THE REQUESTED DOCUMENTATIONWILLBE SUBMITED TO N 10/3/97 3.3.2.1-1 I The ITS SR 3.3.2.1.2 requirement for a CHANNEL FUNCTIONAL THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS OOS TEST is less restrictive because the Surveillance Test is not required MARKUPS ARE REQUIRED.

until I hour after the RWM is required OPERABLE while CTS 4.3.B.3.b. 1 required a test within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to withdrawal of control rods. This is based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement I, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2 (MED-3241286, October 1995).

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO N 10/3/97 3.3.2.1-12 The ITS SR 3.3.2.1.3 requirement for a CHANNEL FUNCTIONAL THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS OOS TEST is less restrictive because the Surveillance Test is not required MARKUPS ARE REQUIRED.

until I hour after the THERMALPOWER is E 10% in MODE2 while CTS 4.3.B.3.b.2 required a test within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the THERMALPOWER being E 10% in MODE 2. This is based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement I, October 1988) and an unreferenced BAN report "Technical Specification Improvement Analyses for Browns Ferry Nuclear Plant, Unit 2" (MED-324286, October 1995).

JFC L3 WILLBE REVISED TO BETTER DESCMBE THE BASIS 10/10/97 3.3.2.1-13 This DOC discusses extending proposed completion times for FOR THE CHANGES TO RBM LCO TIME LIMITS.

blocking control rod withdrawal ifone control rod is inoperable.

The proposed changes appear to result in more restrictive operations.

In addition, the justification does not adequately discuss why the proposed change will not result in a significant safety issue for operation of the plant.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED TO N 10/3/97 3.3.2.1-14 The proposed change eliminates CTS 4.3.B.S which requires a THE NRC FOR APPROVAL NO CHANGES TO THE CTS OR ITS OOS Functional Test of the Rod Block Monitor (RBM) "prior to MARKUPS ARE REQUIRED.

withdrawal of the designated rod(s)" during operation with CMFCP or CMFLPD equal to or greater than 0.95 and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter is eliminated. ITS Table 3.3.2.1-1 relies on the Functional Test, required every 92 days. This is based on the reliability analysis of "Technical Specification Improvement Analyses for BWR Control Rod Block Instrumentation," (NEDC-30851-P-A, Supplement 1, October 1988) and an unreferenced BAN report "Technical Specification hnprovement Analyses for Browns Ferry Nuclear Plant, Unit 2," (MED-324286, October 1995.)

PAGE 4

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE THE APRM DOWNSCALE TRIP IS ADDRESSED IN TECHNICAL N 10/10/97 3.3.2.1-15 The APRM, SRM, IRM and scram discharge volume control rod SPECIFICATIONS CHANGE 353S I THIS WAS A SUPPLEMENT blocks prevent a control rod withdrawal error at power transient.

TO TECHNICAL SPECIFICATION CHANGE 353 WHICH WAS TO The CTS Table 3.2.C and Notes 1-6, 8, 10, I I, and 12 and CTS MODIFY THE CTS FOR THE POWER RANGE NEUTRON Table 4.2.C and Notes 13, 15, and 20 requirements are moved to MONITOR UPGRADE AND PROVIDED MARKUPS OF THE plant documents. The justification includes the evaluation PROPOSED ITS FOR THE SAME SUBJECT. BFN IS CURRENTLY summarized in NEDO-31466 and the lack of credit taken for this IN THE PROCESS OF IMPLEMENTINGTHE POWER RANGE feature in design basis accident or tmnsient analysis. NUMAC NEUTRON MONITOR UPGRADE. THE APRM DOWNSCALE PRNM (ARTS) plant-specific changes in Enclosure I, Attachment 2; TRIP WILLBE DELETED AS PART OF THOSE CHANGES. IT deletes the RPS APRM downscale trip. This change is not reflected SHOULD BE NOTED THATA SER HAS ALREADYBEEN in ITS Table 3.3.1.1-1.

PREPARED FOR THE UNIT 2 CHANGES BASED ON THE CTS MARKUP (AMENDMENT249) FOR UNIT 2. CHANGES TO THE ITS SUBMHTAL353S I DUE TO NRC ISSUES BEING ADDRESSED WILLBE MADE AND THE PROPOSED CHANGES RESUBMITTED IN ITS ENTIRITY.

JFC R2 WILLBE REVISED TO PROVIDE ADDITIONAL Y 10/14/97 3.3.2.1-16 The CTS requires daily instrument channel checks. The STS has no JUSTIFICATION FOR THE RELOCATION OF THE INSTRUMENT equivalent check for the RBM so performance of this test is relocated to plant procedures. Justification for these less restrictive CHANNEL CHECKS.

changes are that they were not already in the STS. The lack of equivalent surveillance in the STS is insufIicient justification for removing the requirement.

3.3.2.1-17 JFC P90 states the intent to implement APRM/RBM tech specs JFC P90 WILLBE EXPANDED TO BETTER EXPLAINTHE Y 10/15/97 STATUS OF POWER RANGE NEUTRON MONITOR UPGRADE concurrent with installation of the power range neutron monitor IMPLEMENTATION.

upgrade for ARTS. RWE analysis associated with ARTS is credited where applicable and the associated RBM setpoints are flow-biased, rather than power dependent until ARTS hardware is installed. The ITS SRs retain power dependent setpoints. In addition, STS Table 3.3.2.1-1 functions for RBM on IRM upscale, high power range upscale and bypass time delays are deleted. These changes are not sufficiently discussed in P90. Staff approval of proposed ARTS implementation is not adequately documented and it is not obvious from the docketed discussions and markup of ITS that use of power dependent trip setpoints are proposed as stated in P90.

CURRENI'LY TIN RBM UPSCALE BLOCK VALUEIS SPECIFIED N 10/7/97 3.3.2.1-18 The flow biased RBM upscale block Allowable Value is stated as "less than or equal to the value specified in the COLR." Provide IN CTS TABLE 3.2.C NOTE 13 WHICH STATES "THE TRIP LEVEL SETTING AND CLIPPED VALUEFOR THIS SEITING documentation of staff approval of cycle dependent AVs for this rod SHALL BE AS SPECIFIED IN THE CORE OPERATING LIMITS block.

REPORT" WHICH DOCUMENTS THE STAFF APPROVAL OF THE CYCLE DEPENDENT Avs.

PAGE 5

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COhf PLETE Y/N DATE ISTS-PROBLEM // 53 ITS SR 3.3.2.1.4 HAS A FREQUENCY OF 92 DAYS, WHILETHE BASED ON RMS // R70970605990 THE CALIBRATION Y 10/16/97 BASES FOR SR 3.3.2.1.4 STATES THE FREQUENCY IS 184 FREQUENCY SUPPORTED BY THE SETPOINT CALCULATION DAYS. IS 92 DAYS AND THUS THE BASES NEEDS TO BE MARKED UP TO SHOW 92 DAYS. NOTE THAT CALCULATIONED-22092-900118, RO, STATES IN SECTION 5.2.2 "ALLDRIFT ALLOWANCES FOR ALLCHANNEL COMPONENTS ARE BASED UPON TECHNICAL SPECIFICATION SURVEILLANCE VALUES...". THE VALUEIN THE CTS IS CURRENTLY 6 MONTHS BUT 3 MONTHS (92 DAYS) WILLBE UTILIZEDTO BE CONSISTENT WITHTHE APRM SURVEILLANCE REQUIREMENTS WHICH ARE THE SAME TYPE INSTRUMENTS.

JFC AS WILLBE DELETED AND JFC M4 ADDED TO ADDRESS THE MORE RESTRICTIVE CHANGE.

PAGE 6

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.2.2, FEEDWATER AND MAINTURBINE HIGH WATER LEVEL TRIP COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED N 10/20/97 3.3.2.2-1 A new requirement is added to the CTS requiring two channels per TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR trip system of feedwater and main turbine high water level trip ITS MARKUPS ARE REQUIRED.

instrumentation OPERABLE when THERMALPOWER is '25%

RTP. The justification ofACTIONS and SRs is based on GENE-77046-1 (ITS 3.3.2.2, Reference 2).

BFN design for Feedwater and Main Turbine High Water Level Trip N 10/20/97 3.3.2.2-2 STS Condition A is two or more trip channels inoperable. The Instrumentation is such that there are.two trip systems, each with two-proposed ITS replace this conditon with one or more trip channels out-of -two logic, and each capable of tripping the three feedwater.

inoperable in each trip system. These are equivalent statements.

pump turbines and the main turbine. The NUREG-1433 specification for Feedwater and Main Turbine High Water Level Trip Instrumentation is based on a tw~utwf-three logic trip system as described in the NUREG-1433 Bases. With the BFN design, iftwo feedwater and main turbine high level trip channels are inoperable in the same trip system but the remaining two channels in the other trip system are OPERABLE, Feedwater and Main Turbine High Water Level Trip capability is maintained. Thus, the wording in NUREG-1433, Specification 3.3.2.2, Condition B is inappropriate for BFN, since it would require Condition entry with trip capability maintained.

Proposed ISTS 3.3.2.2, Condition B states "one or more feedwater and main turbine high level trip channels inoperable in each trip system" since in this condition Feedwater and Main Turbine High Water Level Trip capability is lost until the required inoperable channels are restored to OPERABLE status or placed in trip. Similarly, to address the condition where two feedwater and main turbine high level trip channels are inoperable but Feedwater and Main Turbine High Water Level Trip capability is maintained, proposed ISTS 3.3.2.2, Condition A has been changed to require its entry for each inoperable channel (NUREG-1433, Condition A addresses one inoperable channel and proposed ISTS Condition A now addresses one or more inoperable channels).

PAGE 1

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3. 1, POST-ACCIDENT MONITORIN INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE A TSTF IS IN PROCESS. TRAVELLERBWROG-22 IS TRACKING Y 10/16/97 3.3.3.1-1 Proposed Note 3 is added in conjunction with table function 6, THE RECOMMENDED CHANGE TO LCO 3.3.3.1 NOTE 2 PCIV isolation position indication. The proposed note would allow WHICH MODIFIES NOTE 2 "TO ALLOWSEPARATE separate condition entry for each containment penetmtion. The CONDITION ENTRY FOR EACH PENETRATION" WHICH HAS note is generic change to the STS. Generic changes require a staff THE SAME INPACT AS PROPOSED NOTE 3. THE STATUS OF approved TSTF. THE TRAVELER IS "UNDER TSTF CONSIDERATION".

SHOULD THE CHANGE NOT BE APPROVED GENERICALLYIT IS BFN's INTENTIONTO JUSTIFY THE CHANGE FROM THE NUREG BASED ON PLANT SPECIFIC NEEDS. BFN CTS DO NOT CONTAIN THIS FUNCTION AND BELIEVES THAT ITS INCORPORATON AS WIUITENWOULD BE OVERLY RESTRICTIVE. JFC P80 WILLBE REVISED TO PROVIDE ADDITIONALJUSTIFICATION FOR THE CHANGE.

JFC A4 WILLBE REVISED TO ADDRESS CHANGING Y 10/17/97 3.3.3.1-2 A4 does not dicuss the proposed surveillance requirement changes ONCE/CYCLE TO 18 MONTHS.

from once per operating cycle to once per 18 months.

JFC LS ADDRESSES CHANGE FROM 7 DAYS TO 30 DAYS TO N 10/17/97 3.3.3.1-3 if CTS Table 3.2.F, Note 7, requires a Special Report one of the ALLOWFOR RESTORATION OF A SINGLE INOPERABLE two monitors is inoperable for more than 7 days. ITS 3.3.3.1 CHANNEL. JFC L6 ADDRESSES REQUIRED ACTIONS IF TWO requires a Special Report within 14 days of one channel being CHANNELS ARE INOPERABLE. JFC L7 ADDRESSES THE inoperable for more than 30 days (Required ACTION B) or two CHANGE IN THE SUBMfITALTIME FOR THE SPECIAL channels being inoperable for more than 7 days (Required ACTION REPORT FROM 7 DAYS TO 14 DAYS. TAKENTOGETHER G). THESE JFCs ADEQUATELYADDRESS THE LESS RESTRICTIVE ASPECTS OF THE INCORPORATION OF TABLE 3.2.F INCORPORATION INTO THE ITS.

THE VALUEOF 184 DAYS (6 MONTHS) IN THE ITS IS Y 10/17/97 3.3.3.14 The Frequency for the CHANNELCALIBRATIONof CTS Table CORRECT FOR THE CALIBRATIONFREQUENCY OF THE 4.2.F is 184 days in ITS SR 3.3.3.1.3 for the Reactor Pressure REACTOR PRESSURE INDICATORS BASED ON PLANT indicators. SPECIFIC ANALYSIS. THE CTS MARKUP WILL BE REVISED TO CHANGE 18 MONTHS TO 184 DAYS. JFC A4 WILLBE REVISED TO ADDRESS THE EQUIVALENCEOF 184 DAYS TO 6 MONTHS. IN ADDITIONTHE ITS BASES WILLBE REVISED TO ADDRESS THE 184 DAY CALIBRATIONFREQUENCY FOR THE REACTOR PRESSURE INDICATIONINSTRUMENTATION WITH ASSOCIATED JFC P56 BEING REVISED TO JUSTIFY.

JFC L7 WILLBE REVISED TO PROVIDE FURTHER Y 10/21/97 3.3.3.1-5 ITS 3.3.3.1, REQUIRED ACTION B. 1, increases the submittal JUSTIFICATION FOR THE LESS RESTRICTIVE CHANGE.

time from within the CTS Table 3.2.F, Note 7, 7 days of exceeding the time limit for an inoperable Primary Containment Area Radiation channel, to within 14 days of exceeding the time limit.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3.1, POST-ACCIDENT MONITORING INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC Ml WILLBE REVISED TO PROVIDE REFERENCE TO THE Y 10/22/97 3.3.3.14 Additional PAM functions are added to the ITS table. Provide a SER REFERENCES.

revised DOC that includes a reference to the staff SER approving the plant speci fic PAM functions.

The following LA2 DOC is provided in place of the original LA2 Y 9/29/97 3.3.3.1-7 LA2 states the relocated alternate monitoring methods DOC:

requirements are in the Bases and plant procedures. The ITS uses The statement in Note (8) of CTS Table 3.2.F relative to the the PAM Report in Specification 5.6.6 to specifiy the reqirement to initiation of alternate monitoring methods when the Primary establish alternate monitoring methods with the details located in Containment Area Radiation monitors are inoperable has not been ownerwontrolled documentation.

included in proposed ACTIONS of ffS Section 3.3.3.1. However, the requirement for initiation of alternate monitoring is implied by proposed ITS 5.6.6, "PAM Report," which is required to be initiate by proposed ACTIONS B.l and G.l of LCO 3.3.3.1 when inoperable channels have not been returned to operable status within the allowed Completion Times. Proposed ff8 5.6.6 requires a report to be submitted which outlines the alternate method of monitoring. The proposed 1TS Bases for ACTIONS B. I and G.l of LCO 3.3.3.1 provide additional discussion of proposed Specification 5.6.6 and the initiation of alternate monitoring methods.

THE PROPOSED CHANGE WAS AN ATTEMPT TO BETTER Y 10/22/97 3.3.3.1-8 Proposed changes are replace STS "installed control room CLARIFY THE TYPE OF VALVES REQUIRING INDICATIONIN indication channel" with "active PCIV." These are generic changes THE CONTROL ROOM. THE CHANGE WAS NOT TO CHANGE and require staff approval of an industry TSTF. A plant specific THE INTENT OF THE NOTE BUT RATHER TO ASSURE ONLY justification based on operational limitations or design difference THE INTENDED INDICATIONSARE REQUIRED. TI.IUS THE from the STS was not provided. "active PCIV" WILLBE REMOVED FROM THE MARKUP AND "installed control room PAM Category I indication channel" shall replace it. THE PAM CATEGORY I IS TO CLARIFY THE INTENT OF THE NOTE AS IT PERTAINS TO BFN AND THUS JFC Pl I IS APPLICABLETO THE CHANGE.

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3.2, BACKUP CONTROL SYSTEM INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE SINCE THERE ARE NO REQUIREMENTS IN THE CTS TO Y 10/3 I /97 3.3.3.2-1 The ITS changes SR 3.3.3.2.1 to require channel checks of PERFORM CHANNEL CHECKS FOR BACKUP CONTROL functions that are normally energized and which provide indication INSTRUMENTS AND BFN DOES NOT BELIEVE THATTHIS during normal plant operation. The proposed change represents a ADDITIONBEYOND NORMALINDICATIONOBSERVATION generic change to the STS.

ADDS SIGNIFICANTBENEFIT TO PLANT SAFETY SR 3.3.3.2-1 REQUIRING CHANNEL CHECKS FOR INSTRUMENTATION WILLBE DELETED AND JUSTIFICATION PROVIDED IN A REVISED JFC P30.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP COMMENT ¹ INCORP COh(PLETE DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC M I WILLBE REVISED TO PROVIDE ADDITIONAL 11/6/97 3.3.4.1-1 New Surveillance Requirements are added to CTS Table 4.2.B.

JUSTIFICATION FOR THE ADDITIONOF THE MORE ITS SR 3.3.4.1.3 requires a CHANNEL CALIBRATIONand a RESTRICTIVE REQUIREMENTS OF SR 3.3.4.1.2 AND SR verification that the Allowable Values are set properly. ITS SR 3.3.4.1.3.

3.3.4.1.2 verifies the bypass capability is properly functioning.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED N 11/5/97 3.3.4.1-2 The CTS RPT Initiate LOGIC CFIANNEL FUNCTIONALTEST TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS Frequency is changed from I month to 92 days in the ITS. Browns ITS MARKUPS ARE REQUIRED.

Ferry has performed a plant specific evaluation (not referenced) and concluded that this instrumentation is consistent with the GE analysis performed in GENE-77046-1.

THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED N 11/5/97 3.3.4.1-3 CTS Table 3.2.8, Note 17, allows testing for up to two hours prior TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS to declaring that the channel INOPERABLE and REQUIRED ITS MARKUPS ARE REQUIRED.

ACTIONS taken. A ITS 3.3.4.1 Surveillance Requirements Note allows testing for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> instead of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

JFC L2 WILLBE REVISED TO PROVIDE ADDITIONAL 11/6/97 3.3.4.14 CTS Table 3.2.B, Note 17, only allows declaring the system DISCUSSION AND JUSTIFICATION OF THE NOTE TO ITS OOS if inoperable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> one or more channels are 3.3.4.1 ACTION A.2.

INOPERABLE. This is reflected in ITS 3.3.4.1 REQUIRED ACTION A.l. An option is provided in ITS 3.3.4.1, REQUIRED ACTION A.2, for one or more INOPERABLE channel(s) to place all INOPERABLE channels in the tripped condition within 72 if hours. However, this action would result in system actuation, then declaring the system inoperable per ITS 3.3.4.1, REQUIRED ACTION A. 1, is the preferred action.

JFC L3 WILLBE REVISED TO PROVIDE FURTHER 11/6/97 3.3.4.1-5 CTS Table 3.2.8, Note 17, requires an orderly power reduction to DISCUSSION OF THE CHANGE FROM IMMEDIATELYTO 2 OOS be initiated immediately ifboth trip systems are INOPERABLE.

HOURS FOR BOTH TRIP SYSTEMS INOPERABLE.

ITS 3.3.4.1, REQUIRED ACTION B. I, allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore one trip system to OPERABLE status ifboth trip systems are INOPERABLE JFC L4 WILLBE REVISED TO ADDRESS APPLICATION OF THE 11/6/97 3.3.4.14 ITS 3.3.4.1.b and REQUIRED ACTION 8.2 add an option to CTS COLR INCREASE IN MCPR IF EOC-RPT LCO IS NOT MET AS Table 3.2.B to allow increasing the MCPR limit by an appropriate AN ALTERNATEACTION.

amount (specified in the COLR) ifthe instrumentation is INOPERABLE.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.4.1, END OF CYCLE RECIRCULATION PUMP TRIP INCORP COhtPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC P16 WILLBE REVISED TO PROVIDE FURTHER 11/7/97 3.3.4.1-7 STS BASES SR 3.3.4.1.5 statement that bypass valves are to be JUSTIFICATION FOR THE DEVIATIONFROM THE STS. THE closed during calibration has been deleted in ITS 3.3.4.1. The BASES WILLBE REVISED TO CLARIFY THE INTENT OF THE Bases is modified to state that opening the bypass valves may DEVIATIONIS TO ONLY DECLARE THE FUNCTIONS affect operability of the Function ifthe valves are open above 30% INOPERABLE WHEN THE BYPASS VALVES ARE OPEN AND RTP. The statement to consider the Function inoperable under BYPASS OF FUNCTIONS DUE TO RTP OCCURS.

these conditions is deleted in ITS 3.3.4.1.

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.4.2, ANTICIPATEDTRANSIENTS WITHOUT SCRAM-RECIRCULATIONPUMP TRIP INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE ITS SR 3.3.4.2.4 adds requirements for LOGIC SYSTEM JFC M2 WILLBE REVISED TO PROVIDE ADDITIONAL Y 11/6/97 3.3.4.2-1 JUSTIFICATION FOR THE MORE RESTRICTIVE CHANGE.

FUNCTIONALTESTS. Since CTS Table 4.2.L does not specifically require this testing, the addition of this Surveillance is an additional restriction on plant operation.

THE REQUESTED DOCUMENTATIONWILLBE SUBMTTED N 11/6/97 3.3.4.2-2 The CTS Table 4.2.L ATWS-RPT Initiate LOGIC CHAI4NEL TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS FUNCTIONALTEST Frequency is changed from I month to 92 ITS MARKUPS ARE REQUIRED.

days in ITS SR 3.3.4.2.2. A plant specific evaluation (not referenced) concluded that this instrumentation is consistent with the GE analysis performed in GENE-77046-1.

JFC L2 WILLBE REVISED TO CLARIFYTHE TIME Y 11/8/97 3.3.4.2-3 CTS Table 3.2.L, Note 2 requires the plant to be in HOT REQUIREMENTS AND DIFFERENCE BETWEEN MODES.

OOS SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the condition of one trip system REQURED ACTION D.l WAS DELETED BECAUSE BFN IS NOT inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or for the condition of both trip systems LICENSED FOR I LOOP OPERATION AND THEREFORE THE inoperable. ITS 3.3.4.2, REQUIRED ACTION B requires a the REFERECE IN JFC L2 WILLBE DELETED.

plant to be in STARTUP within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the condition of one ATWS trip function inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ITS 3.3.4.2 Action C allows I hour to restore the ATWS-RFI'rip capability for one function prior to initiating action to be in STARTUP. The CTS to ITS changes related to conditions of inoperability based on trip system vice trip function arc not discussed in DOC L.2. The additional hour to repair the condition of both trip systems inoperable is not discussed in DOC L.2. The different shutdown track, to Mode 2 in the ITS vice Mode 3 in the CTS is not discussed in L.2. Finally, DOC L.2 discusses the option to remove the associated recirculation pump from service, yet this option was not adopted in thc proposed ITS.

THE CTS MARKUP WILLBE REVISED TO SHOW JFC Ll TIED Y 11/8/97 3.3.4.24 CTS Table 3.2.L, Note 2 provides a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AOT for channel repair TO THE PORTION A NOTE 2 DEALINGWITH CHANNEL before the channel must be declared inoperable or placed in trip.

OPERABILITYAND JFC LI WILLBE REVISED TO PROVIDE The DOC M.l is used to justify the change to this CTS SPECIFIC DETAILOF THE CHANGES.

requirement. The L.l DOC is the appropriate.

JFC P50 WILLBE REVISED TO PROVIDE JUSTIFICATION Y 11/8/97 3.3.4.2-5 STS SR 3.3.4.2.1 is modified in ITS SR 3.3.4.2.1 to apply only to the Reactor Vessel Water Level-Low Function. This, in effect, deletes the CHANNEL CHECK of the Reactor Steam Dome Pressure. This change is not justified.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l. 10/20/97 3.3.5.1-1 The Unit I CTS Table 4.2.B calibration frequencies of 3 months A GENERIC RESPONSE THAT STATES MAKINGUNIT I OOS for Reactor Low Water Level, Reactor Low Pressure, and Reactor CONSISTENT WITH UNITS UNIT2 8'c 3 IS DONE FOR High Water Level functions are not consistent with Units 2 and 3 CONSISTENCY AND THAT THE UNIT I TECHNICAL with a interval of 18 months for level and 6 months for pressure. SPECIFICATIONS WILLBE VERIFIED CORRECT PRIOR TO These frequencies are reflcctcd in ITS Table 3.3.5.1-1 for Unit I as UNIT I STARTUP. THIS WILLBE A COMMITMENTTO the same as those in the ITS for Units 2 and 3. The change to the REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO Unit I Surveillance test interval is justified as "willbe validated REVISION OF THE SUBMITTALSHOULD BE REQUIRED.

prior to Unit I recovery."

THE REQUESTED DOCUMI:NTATIONWILLBE SUBMITTED N 10/20/97 3.3.5.1-2 An allowed out of service time (AOT) for testing of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS added to CTS Table 3.2.B. ITS 3.3.5.1, SR Note 2, allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ITS MARKUPS ARE REQUIRED.

for testing prior to entry into associated Conditions and Required Actions.

THE REQUESTED DOCUMENTATIONWILLBE SUBMIITED N 10/20/97 3.3.5.1-3 The CTS Table 3.2.B, Note I.A, AOT for repair, which allows TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS placing CS, LPCI, and HPCI channels in trip or restoring the ITS MARKUPS ARE REQUIRED.

channel to OPERABLE status, remains at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for all Functions except the minimum flow Functions, and is extended to 7 days for the minimum flow Functions in ITS Table 3.3.5.1-1.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED N 10/20/97 3.3.5.14 The AOT for placing ADS channels in trip, or to restore the TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS channel to OPERABLE status, is extended to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> ifHPCI or ITS MARKUPS ARE REQUIRED.

RCIC is also INOPERABLE, or 8 days ifboth HPCI and RCIC are OPERABLE.

THE REQUESTED DOCUMENTATIONWILLBE SUBMBTED N 10/20/97 3.3.5.1-5 The CHANNEL FUNCTIONALTEST frequency (STI) is extended TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS to once per 92 days from monthly. ITS MARKUPS ARE RE UIRED.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM INCORP COhtPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE JFC DOC Ll has been revised to delete the reference to Required Y 11/19/97 3.3.5.14 ITS 3.3.5.1, REQUIRED ACTIONS B.3, D.2.1, and F.2, are added Action D.2.1. This action has been addressed in JFC P81 as not being to CTS Table 3.2.B, Note I, to allow placing an inoperable channel applicable at BFN. JFC LB1 provides the discussion of the changes in the tripped condition rather than declaring the associated made to the CTS Action A and incorporated into O'S as Actions B, C, supported feature inoperable. This compensates for the inoperable D, F, and G. The action repair AOTs are based on NEDC-30936.

status of the channel, restores the single failure capability and provides the required initiation capability of the instrumentation.

Therefore, providing this option does not impact safety. However, ifthis action would result in system actuation, then declaring the system inoperable is preferred.

Required Action D.2.1 is deleted by JFC P81. DOC L.l is incomplete in that it does not identify and discuss the difference between the CTS requirements of Action A and the proposed replacement actions in the ITS, Actions B, C, D, F, and G. The Action repair AOT in the STS are based on NEDC-30936.

THE REQUESTED DOCUMENTATIONWILLBE SUBMTITED N 10/20/97 3.3.5.1-7 ITS Table 3.3.5.1-1, Functions I.c and 2.c required actions are TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR changed from STS 3.3.5.1, Required Action C. I to Required ITS MARKUPS ARE REQUIRED.

Actions B.l for Modes 1,2 and 3. ITS 3.3.5.1, RA C.l requires restoring channel to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.3.5.1, RA B. 1 requires placing channel in trip after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The changes to the Required Action from restoring operabiltiy to placing the channel in trip is not justified and deviates from the CTS and from the STS. Bases insert B3.3-101A states that there are two reactor steam dome pressure (permissive) transmitters per system arranged in a one<ut-of-two logic. The required channels column in Table 3.3.5.1-1 is 4 The STS is based on the staff approved Topical Report NEDC-30936.

PAGE 2

t BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE As stated in JFC P35 manual initiation channel requirements have N 11/20/97 3.3.5.1-8 The STS 3.3.5.1, REQUIRED ACTION G. I, Note that describes been deleted for the ECCS syatems, ADS, RCIC, PCIVs, and SCIVs.

APPLICABILITYfor functions 4.c, 4.e, 4.f, 4.g, S.c, S.e, S.f, and P35 provided clarification that appropriate STS Notes have been S.g is deleted. Justification for deleting the APPLICABILITYfor revised to remove any reference to manual initiation channel ITS Table 3.3.5.1-1, functions 4.g, and S.g only is presented. No requirements.

justification for deleting the APPLICABILITYfor functions 4.c, Various BFN FSAR Sections describe manual isolation capability, 4.e, 4.f, S.c, S.e, and S.f is given. however, the design is such that a single switch in the logic cannot initiate the ECCS system or subsystem. As stated in the NUREG Manual initiation channel requirements are deleted because these Bases for the Manual Initiation Function, there is no speci fic FSAR channels are not currently required at BF and because single switch safety analysis that takes credit for the Function. Based on the above logic design does not exist at BF. The staff requires the manual and that the CTS does not include requirements for the manual initiation functions. initiation functions, BFN maintains the exclusion of the manual functions from the ITS.

See response to Item 3.3.5.14. The CTS has been revised to add a Y 11/19/97 3.3.5.1-9 CTS Action A is changed to ITS Action B, C, D, F, and G. In the JFC flag which justifies the Changed action.

ITS format CTS Action A is only equivalent to Action C.

As stated in JFC P59, CTS does not require a channel check for N 11/20/97 3.3.5.1-10 Channel check requirements are not adopted from the STS because these. Based on this, BFN maintains the exclusion of the channel they are not current licensing basis requirements. check r uirement for these functions from the ITS.

Footnote (e), ffS Table 3.3.5.1-1, has been revised to clarify that a Y 11/20/97 3.3.5.1-1 I Proposed footnote (e) clarifies the trip system channel assignments.

relay corresponds to a trip system.

The footnote discussed relays without providing a connection to the TS requirement for required channels per function.

ISTS Function 2.g was not included in ITS, as discussed in JFC P82, N 11/19/97 3.3.5.1-12 The Rev.A submittal stated LPCI low flow bypass function is not since TVA has an analysis that proves that the LPCI pumps have the included because the analysis assumptions willacheive rated capability to provide the required flow to the vessle with the injection with the bypass valve open. flow valve in the open position . Since this analysis did not

'inimium cause any licensing documentation to change, it was not sent to the NRC for their review. This analysis can be made available for stafl review.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED N 10/20/97 3.3.5.1-13 NEDC-30936 is incorporated by refeince TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR ITS MARKUPS ARE RE UIRED.

The CTS tables have been revised to depict the corresponding ITS Y I 1/19/97 3.3.5.1-14 The core spray low level (function l.a) and the HPCI level 8 Table 3.3.5.1-1 functions I.a and 3.c.

(function 3.c) are proposed iSTS functions that have no corresponding CTS table entry.

PAGE 3

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.5.1, EMERGENCY CORE COOLING SYSTEM COMMENT ¹ INCORP COMPLETE DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE The LA1 DOC has been revised to clarify that the values in the CTS Y 11/19/97 3.3.5.1-15 The LA.I DOC discusses relocating trip setpoints to owner heading "Trip Level Settings" are equivalent to allowable values.

documents and retaining the CTS Alloivable Values in the ITS. TVA's methodology for determination of setpoints utilizes the CTS For this CTS table the "trip level settings" column is simply "Trip Level Settings" as the allowable value in establishing the renamed "Allowable Value" in the ITS format. The Allowable nominal trip setpoint. The selection of nominal trip setpoints plus Values do not exist in the CTS.

associated inaccuracies ensures the "Trip Level Settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 which endorses ISA Std ISA467.04-1982 "Setpoint For Nuclear Safety Related Instrumentation Used in Nuclear Power Plants" and has been reviewed by the NRC in previous submittals, e.g. NRC Letter to Mr. Oliver D. Kingsley dated Jan 2, 1991, Issuance of Amendment TAC No. 77279 S 291 .

PAGE 4

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE BFN agrees with the comment. The original DOC A. I I for proposed 9/30/97 3.3.6.1-1 CTS Table 3.2.A, Note 15, defines the Reactor Building ISTS 3.3.6.1 has been designated as not used and the CTS markup of Ventilation Radiation (RBVR) trip functions for the refueling zone CTS Table 3.2.A Note 15 (for Units I and 3) and Note 14 (for Unit 2) and the reactor zone as each being composed of two divisional trip has been revised to reference markup for proposed ISTS 3.3.6.2 and systems with each trip system having one channel which contains 3.3.7.1.

two sensors, both of which must be OPERABLE. ITS Table 3.3.6.1-1 depicts each trip system as having two channels, meaning each sensor is considered a channel.

The justification for change documented a change to ITS Table 3.3.6.1-1, when the change was implemented in ITS Table 3.3.7.1-

1. The RBVR trip functions are located in ITS Table 3.3.7.1-1 not 3.3.6.1-1.

The CTS markup of Unit I Table 4.2.A for the Reactor Water 10/20/97 3.3.6.1-2 The RWCU Temperature functions in CTS Table 4.2.A for Unit I Cleanup System high temperature functions has been revised to are not consistent with those listed in CTS Table 4.2.A for Units 2 reference DOC A13 for the change in calibration frequency and 3. The Unit I CTS Table 4.2.A calibration frequency of these requirements. The original CTS marhwp of Unit I Table 3.2A and functions is an operating cycle versus 4 months for Units 2 and 3. 4.2.A provided reference to DOC A12 for the difference between the However, ITS Table 3.3.6.1-1 for Unit I is consistent with Units 2 Unit I versus the Unit 2 and 3 Reactor Water Cleanup System high and 3. temperature functions. The following generic response is provided in reference to DOC A12 and A13:

The change modifies the Unit I action requirements without identifying what changed and without presenting a safety THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l.

justification for proposed requirements. A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 4 3 IS DONE FOR CONSISTENCY AND THATTHE UNIT I TECHNICAL SPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMITMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION PROPOSED RESOLUTION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE Y/N DATE The CTS marhwp of Unit I Table 4.2.A for the Reactor Water 10/20/97 3.3.6.1-3 The Unit I CTS Table 4.2.B calibration frequencies for the RCIC Cleanup System high temperature functions has been revised to OOS and HPCI Turbine Steam Line Low Pressure functions are 3 reference DOC A13 for the change in calibration frequency months. This is not consistent with the 18 month interval of Units 2 requirements. The original CTS marhwp of Unit I Table 3.2.A and and 3. These frequencies are included in ITS SR 3.3.6.1.5 a 18 4.2A. provided reference to DOC A12 for the difference between the month intervals for all units.

Unit I versus the Unit 2 and 3 Reactor Water Cleanup System high temperature functions. The following generic response is provided in The change is presented as a administrative change rather than a reference to DOC A12 and A13:

less restrictive change of the surveillance testing of Unit I.

THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT l.

A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY AND THAT THE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT 1 STARTUP. THIS WILLBE A COMMITMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART.

The comment is believed to be addressing the Unit I RCIC and HPCI N 10/20/97 3.3.6.14 The Unit I CTS Table 4.2.B CHANNEL CHECK requirements for Turbine Steam Supply Low Pressure and Turbine Exhaust Diaphragm the RCIC and HPCI Turbine Steam Line High Flow and Exhaust High Pressure functions rather than the RCIC and HPCI Steam Line Diaphragm High Pressure functions are daily. These Unit I High Flow and Turbine Exhaust Diaphragm High Pressure functions CHANNEL CHECKS are deleted from ITS Table 3.3.6.1-1.

(Unit I CTS Table 4.2.B requires a channel check of the RCIC and HPCI Steam Supply Low Pressure functions but not the RCIC and The change is presented as a administrative change rather than a HPCI Turbine Steam Line High Flow functions). The following less restrictive change of the surveillance testing of Unit l.

generic response is provided:

THIS IS A GENERIC QUESTION ON HOW TO HANDLE UNIT I.

A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY AND THATTHE UNIT I TECHNICAL SPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMfIM1NTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMfITAL SHOULD BE RE UIRED.

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENT ISOLATION COMMENT ¹ DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP Y/N COMPLETE DATE SEE A1TACHMENT I FOR RESPONSE . N 9/29/97 3.3.6.1-5 The CTS Table 3.2.A, Note I, Action for ITS Table 3.3.6.1-1, Functions 2.a (Reactor Low Water Level) and 2.b (High Drywell Pressure) and the corresponding Group 2 initiating logic requires Table 3.2.A, Note 1.A actions (initiate an orderly shutdown...) or Note I.B actions (to initiate an orderly load reduction and have the MSLs isolated) along with Note I.E actions (to initiate primary containment isolation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

The ITS Table 3.3.6.1-1, REQUIRED ACTIONS A. I (Place channel in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), B. I (Restore isolation capability within I hour), and G.l (Be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), for these Functions are consistent with the STS. CTS Table 3.2.A, Note I, does not include the ITS 3.3.6.1, REQUIRED ACTION G.l.

This change deletes the CTS Table 3.2.A, Note I.E Action and adds the third option of ITS 3.3.6.1 REQUIRED ACTION G.l.

This is a less restrictive change that was addressed as a more restrictive change.

THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED N 9/30/97 3.3.6.1-6 The allowed out of service time (AOT) for placing a channel in trip TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS when one trip system has inoperable, untrippcd channels, as ITS MARKUPS ARE REQUIRED.

defined in CTS Table 3.2.A, Note I, is extended from immediate to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in ITS 3.3.6.1, REQUIRED ACTIONA. I, for those channels common to RPS, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in ITS 3.3.6.1, REQUIRED ACTION A.2, for all other channels. A justification for this AOT extension was not provided.

The AOTs for placing a channel in trip for required surveillance testing is defined in CTS Table 3.2.A, Note 11, and is extended from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in ITS 3.3.6.1, Surveillance Requirements Note 2. A justification for this AOT extension was not provided.

The monthly CHANNEL FUNCTIONALTEST Surveillance Test Interval (STI) in CTS Table 3.2.A is extended in ITS SR 3.3.6.1.2, to once per 92 days. Ajustification for this STI extension was not provided.

PAGE 3

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCORP COhIPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE The CTS markup, CTS page 3.2/4.2-22 (Unit 3) and page 3.2/4.2-23 Y 10/20/97 3.3.6.1-7 ITS 3.3.6.1, REQUIRED ACTION F. I allows I hour to isolate the (Units I &2), has been corrected to show that the CTS Table 3.2.B, affected Reactor Water Cleanup (RWCU) penetration flow path(s),

Note I.E action is equivalent to proposed ISTS Required Action A.l.

whereas CTS Table 3.2.A, Note I.C, requires immediately isolating the RWCU valves and CTS Table 3.2.B, Note I.B requires immediately declaring the HPCI/RCIC inoperable.

Note E markup for Table 3.2.B deletes the allowance to place the channel in trip. Note E marhwp should show that the option to repair the channel or place it in trip is equivalent to ffS Action A.l.

The CTS markup for Unit I and DOC A12 indicate that the Unit I N 10/20/97 3.3.6.1-8 The RWCU Temperature functions in CTS Table 4.2.A for Unit I CTS RWCU Space Temperature High functions are different than the are not consistent with those listed in CTS Table 4.2A for Units 2 Unit 2 and 3 CTS RWCU Space Temperature High functions. DOC and 3. The Unit 1 functions temperature functions use the RWCU A12 also indicates that the proposed ISTS for Unit I is made floor drain temperature and RWCU space temperature. Units 2 and consistent with the proposed ISTS for Units 2 and 3 and that the 3 uses 6 area space temperatures.

differences willbe resolved prior to Unit I recovery. The NUREG-1433 markup addresses the six area space temperatures for BFN (with The STS assumes six space temperatures. This deviation from the Unit I considered the same as Units 2 and 3 as addressed in DOC STS was not addressed. However some discussion was provided in A12) and provides JFC PI I for changes between the proposed ISTS the justification for an administrative change. The justification and NUREG-1433:Based on the above, the following generic indicated that the diflerences would bc addressed before Unit I response is provided:

recovery.

THIS IS A GENERIC QUESTION ON HOW TO HANDLE UNIT l.

A GENERIC RESPONSE THAT STATES MAKINGUNIT I CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY AND THAT THE UNIT I TECHNICALSPECIFICATIONS WILL BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS WILLBE A COMMTMENTTO REVIEW UNIT 1 TECH SPECS PRIOR TO RESTART. NO REVISION OF TI.IE SUBMITTAL SHOULD BE RE URED.

PAGE 4

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCOR P COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE The LAI DOC willbe revised to clarify that the values in the CTS N 11/8/97 3.3.6.1-9 System design and opemtional details found in CTS Tables 3.2.A, heading "trip level settings" are equivalent to Allowable Values.

OOS 3.2.B, and 4.2.a, are moved to the ITS Bases and plant procedures The CTS "trip level settings" are equivalent to ISTS "Allowable Trip setpoints are an operational detail not directly related to the Values". TVA's methodology for determination of setpoints utilizes operability of the instrumentation. The Allowable Value is the the CTS "trip level settings" as the allowable value in establishing the required limitation of the parameter and this value is retained in nominal trip setpoint. The selection of nominal trip setpoints plus ITS Table 3.3.6.1-1. associated inaccuracies ensures the CTS "trip level settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 The LA.I DOC discusses relocating trip setpoints to owner which endorses ISA Standard ISA467.04-1982 "Setpoints for Nuclear documents and retaining the CTS Allowable Values in the ITS.

Safety Related Instrumentation Used in Nuclear Power Plants" and For this CTS table the "trip level settings" column is simply has been reviewed by the NRC in previous submittals, e.g. NRC letter renamed "Allowable Value" in the ITS format. The Allowable to Mr. Oliver D. Kingsley dated January 2, 1991, Issuance of Values do not exist in the CTS. Amendment TAC No. 77279 S291 .

The CTS markup for Unit I, on CTS page 3.2/4.243, has been 10/20/97 3.3.6.1-10 Details of the methods for performing surveillances found in CTS revised to replace the LA.2 DOC reference with a LB. I DOC Table 4.2.A, are moved to the ITS 3.3.6.1 Bases and plant reference for the change in functional test frequency for the RWCU procedures. floor drain and space temperature high functions.

CTS markup on page 3.2/4.243 RWCU floor drain and Space Temperature high should be LB.1 NOT la.2 The BFN design is such that manual isolation capability is provided N 10/20/97 3.3.6.1-1 1 Proposed change delete manual initiation functions and as indicated in FSAR 7.3.3 Safety Design Bases 10 and discussed in "automatic" from loss of isolation capability action because the FSAR 7.3.4.5 (discussion of the fulfillmentof Safety Design Bases functions are not current requirements and single switch isolation is 10). However, the BFN design docs not include handswitches in the not consistent with the BFN design. The staff position is that logic for generation of primary containment isolation signals. Manual manual actuation capability was a licensing basis of the design and isolation of the PCIVs is typically accomplished by means of without which the design would not be meet regulatory design handswitches for the individual PCIVs. In addition to these normal criteria. The absence of CTS manual requirements is an oversight means of manual isolation, typically other means are available to which should be corrected. Further, current TS logic testing initiate the required isolations (i.e., removal of power for normally requirements require a complete test of the circuitry including the energized logic, etc.). As stated in the NUREG Bases for the Manual manual actuation functions. Initiation Functions, their is no specific FSAR safety analysis that takes credit for the Functions. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion of the manual functions from the ISTS.

PAGE 5

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE The NUREG-1433 marhwp for the RWCU Isolation Temperature Y 10/20/97 3.3.6.1-12 RWCU isolation functions are added to the current TS functions.

Functions (NUREG-1433, 3.3.6.1, Functions S.b and S.c) has been The SRs proposed include the same SRs as the CTS RWCU leve 3 revised to address the proposed changes in SRs. As indicated in the isolation except a 122 day channel calibration is proposed and no marhwp, the change to 122 day channel calibration is addressed in JD channel check is included.

P42 and the absence of the channel check requirement is addressed in JD P59. Also, as indicated in response to Question 3.3.6.1-2, the CTS marhwp of Unit I Table 4.2.A for the Reactor Water Cleanup System high temperature functions has been revised to reference DOC A13 for the change in calibration frequency requirements. The original CTS markup of Unit I Table 3.2.A and 4.2.A provided reference to DOC A12 for the difference between the Unit I versus the Unit 2 and 3 Reactor Water Cleanu S tcm hi tern erature functions.

SEE ATTACHMENT3 FOR RESPONSE N 10/20/97 3.3.6.1-13 Proposed ITS markup is not identical to the CTS bypass allowance.

CTS provide the bypass for conditions of normal steam tunnel ventilation becoming inoperable. The proposed ITS provides an allowance to bypass the trip of Function I.d (Main Steam Tunnel Temperature High) for conditions of loss of trip capability.

The Reactor Vessel Water Level - Low, Level 3 Function has been Y 10/26/97 3.3.6.1-14 Deleted TS for RHR shutdown cooling isolation in Modes 4 and 5.

added as Function 6.b to the proposed ISTS 3.3.6.1. The proposed Licensee agreed to revise the ITS to include the isolation functions applicability for this Function is Modes 3, 4, and 5. Necessary changes to the CTS Markups, DOCs, NUREG-1433 markup, and JDs have been made to su rt this chan e.

The intent of the referenced statement in DOC A.7 is to indicate that N 10/20/97 3.3.6.1-15 The CTS note requires the affected system to be declared it is unnecessary to create a Required Action F.2 (logically connected inoperable a(ter closing the RHR shutdown cooling isolation by AND to the proposed Required Action F. I) which would state that valves. The justification states "an action requiring the affected the aIfected system must be declared inoperable. The addition of such system to be declared inoperable is an unnecessary reminder that an action would be a deviation from the format of NUREG-1433 for other TS may be affected.

this Condition and would be an unnecessary reminder of proposed LCO 3.0.1. Proposed LCO 3.0.1 requires LCOs to be met during the MODES or other specified conditions in the Applicability. For example, proposed ISTS 3.0.1 would require proposed LCO 3.4.7, RHR Shutdown Cooling System - Hot Shutdown, to be met during its Applicability. Thus, ifduring the Applicability of proposed LCO 3.4.7 the RHR Shutdown Cooling Isolation Valves were isolated to comply with proposed ISTS 3.3.6.1 Required Action F. 1, proposed LCO 3.0.2 would r uire the Re uired Actions of ro sed LCO 3.4.7 to be met.

PAGE 6

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/Ã DATE SEE ATTACHMENT2 FOR RESPONSE. Y 10/20/97 3.3.6.1-16 Proposed Action F. I requires the licensee to isolate the affected penetration flow path for specific HPCI and RCIC functions rather than declare the system or component inoperable. ITS Action A. 1 requires the channel to be tripped in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> vice the CTS requirement to repair the channel in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The difference between the trip versus repair actions is not discussed.

3.3.6.1-19 Evaluate the marhwp for revision. Deleted text is retained in ITS.

The text which was marked as deleted addressed the option to place Y 10/20/97 the inoperable channel(s) in trip. This option is equiva! ent to the DOC discussion is missing for deleted text.

actions in proposed ISTS Required Action A.l. Therefore, the CTS marhwp, CTS page 3.2/4.2-22 (Unit 3) and page 3.2/4.2-23 (Units I k2), has been corrected to add back the previously deleted text in CTS Table 3.2.B, Note I.E.

THIS MORE RESTRICTIVE CHANGE IS CONSIDERED TO BE N 9/29/97 3.3.6.1-20 CTS 3.2.A requires primary containment isolation instrumentation ACCEPTABLE SINCE THE ANTICIPATEDDURATION AND OPERABLE when primary containment integrity is required. CTS FREQUENCY OF BEING IN MODE 2, NOT CRITICALAND <212 3.7.A.2.a, primary containment integrity is required OPERABLE at all times when the reactor is critical or when the reactor water

'F, IS VERY SHORT AND INFREQUENCT AND WILLAHVE NO ADVERSE IMPACT ON THE OPERATION OF THE UNIT. THIS temperature is above 212'F and fuel is in the vessel. The ITS 3.3.6.1 Applicability for most functions is MODES I, 2, and 3.

CHANGE IS CONSISTENT WITH NUREG-1433.

This is more restrictive since CTS 3.7.A.2.a, does not require the primary containment integrity when in MODE 2, not critical and (

212'F. This change is consistent with the STS.

The justiiflication did not justify adding the Applicability for (

212F.

PAGE 7

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION ATTACHMENT 1 RESPONSE TO ISSUE 3.3.6.1-5

RESPONSE

CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions specifies when the rcquircd channels are not met for one trip system and the function is not tripped or when the required channels cannot bc met for all trip systems that one of thc following actions must bc taken: 1) the reactor .

placed in the COLD SHUTDOWN CONDITION in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; OR 2) the operator initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Proposed ISTS LCO 3.3.6.1 Required Actions for Reactor Vessel Water Level - Low, Level 3 and Diywell Pressure-High Functions require these channels when inoperable to be placed in trip in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (proposed LCO 3.3.6.1 Required Action A. I) and ifnot tripped within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or ifinitiation capability is lost and not restored in I hour (proposed LCO 3.3.6.1 Required Action B.l) the reactor to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (proposed LCO 3.3.6.1, Condition G).

The less restrictive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance for tripping channels is addressed in DOC LB I for proposed ISTS LCO 3.3.6.1.

The replacement of the CTS requirement to initiate required actions when the required channels are not met for all trip systems with the less restrictive proposed ISTS requirement to initiate required actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when initiation capability is lost is addressed in DOC Ll for proposed ISTS LCO 3.3.6.1. The less restrictive change from the CTS allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> before being required to be in Cold Shutdown is addressed in DOC L2 for proposed ISTS LCO 3.3.6.1. The additional requirement to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is addressed in DOC Ml for proposed ISTS LCO 3.3.6.1. The deletion of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is addressed in DOC M3 for proposed ISTS LCO 3.3.6.1. BFN maintains that the additional requirement to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the deletion of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> e and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are morc restrictive changes as further discussed in the folloiving.

When inoperable channels arc not tripped in thc allowed out of service time, proposed LCO 3.3.6.1, Required Action G. I will require a reactor shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> where the CTS would allow power operation to continue past 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provided the reactor could be placed in Mode 4 in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Under the proposed ISTS iftwo channels of Reactor Vessel Water Level - Low, Level 3 or two channels of Drywell Pressure - High in the same trip system were inoperable and not tripped (automatic isolation capability lost) the reactor would be required to be shutdown in 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> (I hour for Completion time of proposed ISTS Required Action B. I plus 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Completion time of proposed ISTS Required Action G. 1). Under the same conditions the CTS would allow power operation to continue past 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> provided the reactor could be placed in Mode 4 in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Ifa single channel of Reactor Vessel Water Level - Low, Level 3 or Drywell Pressure - High werc inoperable and not tripped both the CTS (first option) and proposed ISTS would require the reactor to bc shutdown to the specified Mode in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (for the CTS, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be in Mode 4 per Table 3.2.A Note 1.A; for the ISTS, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for allowed out of service time (proposed ISTS Required Action A.l) plus 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to be in Mode 3 (proposed Required Action G.l)). Under these conditions the extended allowed out of service time results in the proposed ISTS being slightly less restrictive since under thc CTS the reactor would have to be shutdown at some point prior to expiration of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time in order to cool down to Cold Shutdown conditions. As indicated above, the less restrictive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance for tripping channels is addressed in DOC LBI for proposed ISTS LCO 3.3.6.1, and overall, the additional requirement to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (proposed LCO 3.3.6.1, Required Action G. I) is morc restrictive.

The CTS option requiring the operator initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Option 2) does not require a shutdown of the reactor. The CTS option requiring the reactor be placed in the COLD SHUTDOWN CONDITION in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Option

1) as well as the proposed ISTS shutdown requirements would allow power generation longer than CTS Option 2 (Main Stcam Lines could be maintained open longer than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). Thus, comparing the options to one another there are more restrictive and less restrictive aspects associated with both options. However, since the shutdown requirement is maintained (and the addition of proposed LCO 3.3".6.1, Required Action G. I is overall more restrictive as discussed above) the deletion of Option 2 reduces operation flexibilityand is thus more restrictive.

PAGE 8

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION ATTACHMENT2 RESPONSE TO ISSUE 3.3.6.1-16

RESPONSE

CTS Table 3.2.B, Note 1.A requires the specific HPCI and RCIC Function channels to be repaired in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Ifthe channels are not repaired in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, CTS Table 3.2.B, Note 1.B is entered which requires the system or component to be declared inoperable. Proposed ISTS LCO 3.3.6.1 Required Action A. I requires these channels when inoperable to be restored to OPERABLE status or tripped in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. IfRequired Action A. 1 and its associated Completion Time is not met, proposed ISTS LCO 3.3.6.1 Required Action F.1 is entered for the functions as directed by proposed ISTS Table 3.3.6.1-1. Proposed ISTS LCO 3.3.6.1 Required Action F. 1 requires the affected penetration flow path(s) to be isolated in one hour. The change in the subsequent actions required when thc initial allowed out of service time is not met (i.e., change from the CTS action of declaring the system or component inoperable to the proposed ISTS action of isolating the aflected penetration flow path) is addressed in DOC M8. Relative to the initial required actions, the addition of the option to trip the inoperablc channels in lieu of repairing them is a less restrictive change and is addressed in DOC L7.

Based on the above, the difference between the trip versus repair actions is discussed in the appropriate DOC (i.e.,

DOC L7) and no revision to the M8 DOC is required. The original DOC L7 indicated that proposed ISTS Required Action A. I allows an inoperable channel to be placed in the tripped condition rather than declaring the associated supported feature inoperable. Since the CTS action of declaring the associated supported feature inoperable has been replaced with proposed ISTS Required Action F. I, DOC L7 has been revised to indicate that proposed ISTS Required Action A. I allows an inoperable channel to be placed in the tripped condition rather than restored to OPERABLE status.

PAGE 9

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.1, PRIMARY CONTAINMENTISOLATION ATTACHMENT3 RESPONSE TO ISSUE 3.3.6.1-13 SPONSE:

The inclusion of Function l.d (Main Steam Line Space Temperature - High) in the list of "other than Functions" in the second Completion Time for proposed ISTS 3.3.6.1 Required Action A.1 was in error and has been deleted. With Function 1.d included in the list of "other than Functions" in the second Completion Time for proposed ISTS 3.3.6.1 Required Action A.1, no requirement existed to place inoperable Function l.d channels in trip when 14 or less Function I.d channels were OPERABLE. Relative to the CTS allowance for bypass of the Main Steam Tunnel Temperature High Function for conditions of normal stcam tunnel ventilation becoming inoperable, BFN maintains the proposed ISTS incorporates this allowance without additional relaxations. CTS Table 3.2.A, Note 12, states that in the event that normal ventilation is unavailable in the main steam line tunnel, the high temperature channels may be bypassed for a period of not to exceed four hours. In the proposed ISTS 3.3.6.1, when multiple Function I.d channels are inoperable such that isolation capability for Function I.d is not maintained, proposed Required Action B. I is entered. The proposed ISTS 3.3.6.1 Required Action B. I Completion Time, is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OR 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Function l.d when normal ventilation is not available. The proposed Bases for this Required Action clarifies this second completion time by stating it is provided to allow the plant to avoid an MSL isolation transient when recovering from a temporary loss of ventilation in the MSL tunnel area (e.g., during performance of the secondary containment leak rate tests). Thus, when proposed Required Action B. 1 is cntercd for Function 1.d, four hours are allowed to restore isolation capability ifthe Function 1.d channels were made inoperable to avoid an MSL isolation transient due to a temporary loss of ventilation in the MSL tunnel area. Ifthe Function I.d channels were inoperable with normal ventilation to the MSL tunnel area available, the second completion time of proposed ISTS 3.3.6.1 Required Action B. 1 would not apply and only I hour would be allowed to restore isolation capability. As indicated in DOC LA3, the compensatory actions associated with CTS Table 3.2.A, Note 12 have been incorporated into thc proposed Bases for ISTS 3.3.6.1 Required Action B.l.

PAGE 10

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COh(PLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE CTS 3.2.A combined with CTS 3.7.A.2.a, Primary Containment, THIS MORE RESTRICTIVE CHANGE IS CONSIDERED TO BE N 9/27/07 3.3.6.2-1 requires primary containment integrity at all times when the reactor ACCEPTABLE SINCE THE ANTICIPATEDDURATIONAND is critical or when the reactor water temperature is above 212F FREQUENCY OF BEING IN MODE 2, NOT CRITICALAND and fuel is in the vessel. ITS Table 3.3.6.2-1 requires the <212'F, IS VERY SHORT AND INFREQUENT AND WILLHAVE secondary containment isolation instrumentation OPERABLE in NO ADVERSE IMPACT ON THE OPERATION OF THE UNIT.

MODES 1, 2, and 3. Since the CTS does not require primary THIS CHANGE IS CONSISTENT WITH NUREG-1433.

containment integrity when in ITS 3.3.6.2 MODE 2 conditions of not critical and < 212'F, this is a more restrictive change . No ustification is rovided for this more restrictive chan e.

3.3.6.2-2 CTS 3.7.A.2.a does not require primly containment integrity The AS DOC was incorrect and the proposed change is a more CHECK "while performing 'open vessel'hysics tests at power levels not to restrictive change. The AS DOC has been deleted and replaced with WITH exceed 5 MW(t)." ITS 3.3.6.2 does not contain this exception. the following M3 DOC: OPS &

The justification is based on the provisions of ITS 3.0.8, which MECH indicates Special Operations in ITS 3.10 allow changing specified CTS 3.7.A.2.a allows "Open Vessel" physics testing at power levels TS requirements. However ITS 3.10 does not address "open not to exceed S MW(t). The proposed ISTS does not include Vessel" physics tests. provisions for this activity, therefore this change is more restrictive.

BFN is past the point in plant life where this type of testing would be performed. This change is consistent with the BWR Standard Technical S ecifications, NUREG 1433.

3.3.6.2-3 ITS 3.3.6.2, SR Note 2, deletes "secondary containment" from STS The words "secondary containment" have been added back to Y 10/20/97 SR Note 2. proposed ISTS 3.3.6.2, Condition B, Required Action B.l, and SR Note 2.

ITS 3.3.6.2, ACTION B modifies STS 3.3.6.2 ACTION B by removing the words "secondary containment".

The changes werc made based on being unnecessary since they are a art of the title for ITS 3.3.6.2.

PAGE I

e BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE CTS Table 3.2.A, for Reactor Low Water Level and High Dryweil SEE ATI'ACHMENTI FOR RESPONSE 5/29/97 3.3.6.24 Pressure, for less than the minimum required OPERABLE channels, provides the options when ACTION Note I are met.

These option are: I) place the reactor in cold shutdown in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (ACTION Note I.A) or 2) initiate a load reduction and isolate the Main Steam Lines within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (ACTION Note I.B) and initiate primary containment isolation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (ACTION Note I.E). For the same Functions ITS 3.3.6.2, Required Actions C.l. I, C.1.2, C.2.1 and C.2.2, do not require entering cold shutdown or isolating the Main Steam Lines but, provide options, when Required Actions A. I and B. I arc not met, allowing isolation of the affected lines (zones) and starting the affected SGT subsystems (ITS 3.3.6.2 Required Actions C.l. 1 and C.2.1). Ifthis option is not chosen, then the affected components must be declared inoperable (ITS 3.3.6.2, Required Actions C.1.2 and C.2.2).

No justification, based upon safety analyses, is provided for deleting the CTS requirement to shutdown or isolate the Main Steam Lines.

CTS Table 3.2.A and Table 4.2.A provide separate ACTIONS and SEE ATTACHMENT3 FOR RESPONSE. 10/20/97 3.3.6.2-5 SRs for Secondary Containment Isolation Instrumentation initiating and isolation logic (Reactor Building Isolation Logic, SGTS Trains A, B, and C Logic and Group 6 Logic). ITS 3.3.6.2 deletes the Reactor Building Isolation and SGTS Logic functions (including ACTIONS) and incorporates the SRs required by the CTS for these functions into required SRs of ITS Table 3.3.6.2-1. The discussion and justification does not demonstrate that 1TS Required Actions and SRs encompass the CTS Required Actions and SR for the logic functions.

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE 3.3.6.2-6 ITS 3.3.6.2 SR 3.3.6.2.2, CHANNEL FUNCTIONALTEST, THE REQUESTED DOCUMENTATIONWILLBE SUBM11TED N 9/30/97 extends the Surveillance Test Interval for the CTS Table 4.2.A TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR Channel Functional Tests from monthly to once per 92 days. ITS MARKUPS ARE REQUIRED.

ITS 3.3.6.2, Required Action A, extends the time in CTS Table 3.2.A, ACTION I, for tripping an inoperable channel from immediately to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for those channels common to RPS and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for all other channels.

ITS 3.3.6.2, SR Note 2, extends the Allowed Outage Time for performing surveillances in CTS Table 3.2A, Note 11, from 4 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

These changes are based on maintaining an acceptable risk in accordance with previously conducted reliability analysis (NEDC 30851-P-A, Supplement 2, March 1989 and NEDC-31677-P-A, Jul 1990 . This is an extension of Allowed Outa e Time.

3.3.6.2-7 ITS 3.3.6.2, Required Actions C.1.2 and C.2.2, add ACTIONS to SEE ATTACHMENT2 FOR RESPONSE 9/29/97 CTS Table 3.2A that require declaring the associated systems if inoperable within I hour secondary containment isolation or starting the SGT System is not possible or desired. The addition of more restrictive requirements is not administrative. Additionally, no ustification is rovided for the I hour corn letion time.

ITS 3.3.6.2, SR Note 3, extends the Allowed Outage Time for THE REQUESTED DOCUMENTATIONWILLBE SUBMITTED N 9/30/97 3.3.6.2-8 TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR performing surveillances in CTS Table 3.2.A, Note 11, from 4 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for a CHANNEL FUNCTIONALTEST. These changes are ITS MARKUPS ARE REQUIRED.

stated to be based on maintaining an acceptable risk in accordance with previously conducted reliability analysis (NEDC 30851-P-A, Supplement 2, March 1989 and NEDC-31677-P-A, July 1990).

This is an extension of Allowed Outa e Time.

ITS Table 3.3.6.2-1, Functions I and 2, Reactor Vessel Water THIS IS A GENERIC QUESTION ON HOW TO HANDLE UNIT l. N 9/29/97 3.3.6.2-9 A GENERIC RESPONSE THAT STATES MAKINGUNIT 1 Level - Low and Dr@veil Pressure - High, respectively, increase the CTS Table 4.2.A Unit I CHANNEL CALIBRATIONSurveillance CONSISTENT WITH UNITS 2 4 3 IS DONE FOR CONSISTENCY Test Interval, for the same functions, from 3 montlis to 18 months. AND THATTHE UNIT I TECHNICAL SPECIFICATIONS WILL This change is implemented to make the Unit I ITS be consistent BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS with Units 2 and 3 ITS. This is an extension of Surveillance Test WILLBE A COMMffMENT TO REVIEW UNIT I TECH SPECS Interval for Unit I is not justified. PRIOR TO RESTART. NO REVISION OF THE SUBMITTAL SHOULD BE RE UIRED.

PAGE 3

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE 3.3.6.2-10 CTS Table 4.2.A does not require an Instrument Check for the Since a channel check is not currently required by the CTS for the N 10/20/97 High Dryweil Pressure Function. ITS Table 3.3.6.2-1, Function 2, High Drywell Pressure function, the proposed SR 3.3.6.2.1 channel Drywell Pressure - High, requires SR 3.3.6.2.1, CIIANNEL check requirement has been deleted for proposed ISTS 3.3.6.2, CHECK every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No justification is provided for adding Function 2, Dryweil Pressure - High. The proposed ISTS Tables this surveillance test or deviating from the ISTS test frequency. 3.3.6.2-1, NUREG markup, and JD P59 have been revised to address this chan e.

3.3.6.2-1 1 The Completion Time for STS 3.3.6.3, Required Action A.l, is 12 THE REQUESTED DOCUMENTATIONWILLBE SUBMI1TED N 9/30/97 hours for Function 2 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the other Functions. ITS TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR 3.3.6.2, Required Action A. I, modifies the Completion time to 12 ITS MARKUPS ARE REQUIRED.

hours for Functions I and 2 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the other Functions.

This change is based on NEDC-30851-P-A, Supplement 2, March 1989, NEDC-31677-P-A, July 1990 and GENE-77046-1, February 1991.

ITS 3.3.6.2 adds SR Note 3 to STS 3.3.6.2 Surveillance Notes. ITS THE REQUESTED DOCUMENTATIONWILLBE SUBMfITED N 9/30/97 3.3.6.2-12 3.3.6.2, SR Note 3, allows one inoperable channel of the Reactor TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR Zone and Refueling Zone Exhaust Radiation System for up to 6 ITS MARKUPS ARE REQUIRED.

hours for CHANNEL FUNCTIONALTESTING and for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for CHANNEL CALIBRATIONand maintenance as long as the downscale trip of the inoperable channel is placed in the tripped condition. The CTS provides the same allowance except only 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is allowed for the CHANNEL FUNCTIONALTEST.

Extending 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is based on reliability analyses in NEDC-30851-P-A NEDC-31677-P-A and GENE-77046-1.

CTS 3.2 and 4.2 System design and operational details are moved The LA1 DOC willbe revised to clarify that the values in the CTS N 11/8/97 3.3.6.2-13 to the ffS 3.3.6.2 Bases and plant procedures. heading "trip level settings" are equivalent to Allowable Values.

The CTS "trip level settings" are equivalent to ISTS "Allowable Trip setpoints are an operational detail not directly related to the Values". TVA's methodology for determination of setpoints utilizes operability of the instrumentation. The Allowable Value is the the CTS "trip level settings" as the allowable value in establishing the required limitation of the parameter and this value is retained in nominal trip setpoint. The selection of nominal trip setpoints plus ITS Table 3.3.6.2-1. associated inaccuracies ensures the CTS "trip level settings" are not exceeded. TVA's setpoint methodology is consistent with RG 1.105 The LA.I DOC discusses relocating trip setpoints to owner which endorses ISA Standard ISA-S67.04-1 982 "Setpoints for Nuclear documents and retaining the CTS Allowable Values in the ITS. Safety Related Instrumentation Used in Nuclear Power Plants" and For this CTS table the "trip level settings" column is simply has been reviewed by the NRC in previous submittals, e.g. NRC letter renamed "Allowable Value" in the ITS forinat. The Allowable to Mr. Oliver D. Kingsley dated January 2, 1991, Issuance of Values do not exist in the CTS. Amendment TAC No. 77279 TS291 .

PAGE 4

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE 3.3.6.2-14 Proposed change delete manual initiation functions and The BFN design is such that manual isolation capability is provided N 10/20/97 "automatic" from loss of isolation capability action because the as discussed in FSAR 5.3.3.1, 5.3.3.2, 7.3.3 Safety Design Bases 10, functions are not current requirements and single switch isolation is and 7.3.4.5. However, the BFN design is such that a single switch in not consistent with the BFN design. The staff position is that the logic can not initiate the secondary containment features in even manual actuation capability was a licensing basis of the design and one division. Sepamte handswitches are provided for the inboard without which the design would not be meet regulatory design refueling zone isolation logic systems, outboard refueling zone criteria. The absence of CTS manual requirements is an oversight isolation logic systems, each inboard reactor zone isolation logic which should be corrected. Further, current TS logic testing system, each outboard reactor zone isolation logic system, and each of requirements require a complete test of the circuitry including the the three SGT Train Logic Systems. In addition to these normal means manual actuation functions. of manual isolation, typically various other means are available to initiate the required features (i.e., removal of logic power, utilization of handswitches for individual dampers, etc.). As stated in the NUREG Bases for the Manual Initiation Function, their is no specific FSAR safety analysis that takes credit for the Function. Based on the above and that the CTS does not include requirements for the manual initiation functions, BFN maintains the exclusion of the manual functions from the ISTS.

PAGE 5

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION ATTACHMENT I FOR ISSUE 3.3.6.2-4

RESPONSE

The same Reactor Vessel Water Level - Low, Level 3 and D~vell Pressure - High channels and initiation portions of logic arc used in Primary Containment Isolation, Secondary Containmcnt Isolation, and CREV System Initiation. Based on the commonality of the instruments, the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) provides the required actions for this instrumentation. However, the required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation. In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the affects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure - High Functions require the reactor to be in the COLD SHUTDOWN CONDITION in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. The compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure - High Functions require these channels when inoperable to be placed in trip in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (proposed LCO 3.3.6. 1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or ifinitiation capability is lost and not restored in 1 hour: 1) thc reactor to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (proposed LCO 3.3.6.1, Condition G);

2) in I hour isolate the associated SC zone or declare associated SCIVs inoperablc AND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3) in I hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E).

As evident from the above compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell ressurc - High Functions, the requirement to shutdown the reactor has not been deleted and is maintained in proposed ISTS CO 3.3.6.1 since this is the appropriate required action for loss of primary containment isolation capability from these unctions. Dclction of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the change from the CTS allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> before being required to be in Cold Shutdown, and the additional requirement to bc in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> arc addressed in DOCs for proposed ISTS LCO 3.3.6.1. Other changes from thc CTS requirements (such as the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance for tripping channels, etc.) are addressed in DOCs for proposed ISTS LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1.

Based on the above and comment resolution for Comments 3.3.6.2-7, 3.3.7.1-1, 3.3.7.1-2, and 3.3.7.1-5, BFN proposes that deletion of the CTS requirements for Reactor Vessel Water Level - Low, Lcvcl 3 and Drywell Pressure - High Functions arc best described as an administrative change in the CTS markup and DOCs for proposed ISTS 3.3.6.2. Therefore, DOC L2 has been deleted, DOC A11 has been created to address the deletion of the CTS requirements for Reactor Vessel Water Level-Low, Level 3 and Drywell Pressure - High Functions, and DOC M2 has been created to address the addition of proposed ISTS LCO 3.3.6.2, Condition C requirements for Reactor Vessel Water Level - Low, Level 3, Drywell Prcssure - High, and Refueling Floor Exhaust Radiation - High Functions.

PAGE 6

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION ATTACHMENT2 FOR ISSUE 3.3.6.2-7

RESPONSE

Since CTS Table 3.2.A Note 1.G is not applicable to Reactor Vessel Water Level - Low, Level 3, Drywell Prcssure - High, and Refueling Floor Exhaust Radiation - High Functions, proposed ISTS 3.3.6.2, Required Actions C.1.2 and C.2.2 as well as Required Actions C.l. I and C.2.1 are new requirements for proposed ISTS 3.3.6.2 Functions I, 2, and 4. Proposed DOC M2 has been created to address this more restrictive change.

Since CTS Table 3.2.A Note 1.G is applicablc to Reactor Zone Exhaust Radiation - High Function, proposed DOC A6 is still applicable to proposed ISTS 3.3.6.2 Functions 3. However, the original DOC A6 was incorrect. Currently, reactor shutdown per CTS I.C.1 would be required ifthe required action to isolate the reactor building and start the standby gas treatment system (CTS Table 3.2.A Note 1.G) could not be performed. Under the proposed ISTS with the SCIVs and standby gas treatment system declared inoperable both proposed ISTS LCO 3.6.4.2 Condition C and LCO 3.6.4.3 Condition D would require the reactor to be shutdown. Specifically, proposed ISTS LCO 3.6.4.3 Required Action D. 1 would require proposed ISTS LCO 3.0.3 to be entered immediately. Changes in the generic shutdown LCO (CTS I.C. I changes relative to the proposed ISTS LCO 3.0.3) arc addressed in DOCs for proposed ISTS Section 3.0. Since both the CTS and proposed ISTS would require reactor shutdown, the addition of the actions of proposed ISTS 3.3.6.2, Required Actions C.1.2 and C.2.2 are considered administrative for proposed ISTS 3.3.6.2 Functions 3. However, the added 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> completion time for declaring the equipment inoperable is less restrictive. DOC A6 and Ll have been revised to reflect the above.

PAGE 7

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.6.2, SECONDARY CONTAINMENTISOLATION ATTACHMENT3 FOR ISSUE 3.3.6.2-5

RESPONSE

The CTS markup for the logic systems have been revised to indicate the changes from the CTS actions. Justification for these changes are provided as indicated in DOC L2, L3, L4, and M2. DOC A8 has been revised to provide additional discussion and justification for the bases of considering the ISTS Required Actions and SRs for the channels and Functions encompass required actions and surveillances for the logic systems. The revised DOC A8 provides the following discussion:

When a logic system is discovered to be inoperable, the proposed LOGIC SYSTEM FUNCTIONALTEST Surveillance Requirement is not met, and thus, the proposed ISTS LCO is not met per proposed SR 3.0.1.

The proposed Bases for the LOGIC SYSTEM FUNCTIONALTEST Surveillance Requirements state that these tests demonstrate the OPERABILITYof the required isolation logic for a specific channel. Thus, each channel which can not perform the required initiation function through the logic system is declared inoperable for the associated feature and the proposed ISTS Conditions and Required Actions for the inoperable channels are entered. For example, when one of the three SGT Train Logic Systems is inoperable, all of the channels for proposed ISTS 3.3.6.2 Functions 1, 2, 3, and 4 would be declared inoperable for the associated SGT subsystem since all of the channels input through logic to the inoperable SGT Train Logic System. Under these conditions proposed ISTS Required Action A. I would require the logic system to be restored to OPERABLE status in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> based on the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time for Functions 1 and 2 and that in affect the channels can not be placed in trip. Under these conditions proposed ISTS Condition B would not be entered since the Functions would still be maintaining initiation capability for two SGT subsystems. Ifthe inoperable SGT Train Logic System was not restored to OPERABLE status in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, proposed ISTS Condition C would be entered which would require in one hour the associated SGT subsystem to be placed in operation or declared inoperable. Ifin the above example two of the three SGT Train Logic Systems were inoperable, the required actions would be the same except that proposed ISTS Condition B would be entered which would require in one hour at least one of the inoperable SGT Train Logic Systems to be restored to OPERABLE status or Condition C entered.

Since the action for an inoperable logic system will require all channels affected by the inoperability to be declared inoperable and the Required Actions for the inoperable channels taken, and since the impact on safety from a logic system being inoperable due to a logic system failure is no more severe than a logic system being inoperable due to failure of its input channels, the potential 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed out of service times for the logic systems is address in DOCs LB1.

PAGE 8

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM .

PROPOSED RESOLUTION INCORP COMPLETE COMhKNT 8 DESCRIPTION OF ISSUE Y/N DATE SEE ATfACHMENTI TO THIS LIST FOR PROPOSED Y 9/30/97 3.3.7.1-1 The CTS Actions for ITS Functions I and 2 require the operator to RES OLUITION.

initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or initiate primary containment isolation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. The O'S requirements for these functions is to trip inoperable channels in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or declare the associated CREV subsystem inoperable I hour from discovery of loss of trip capability in both trip systems.

DOC A.2 does not address all of the proposed changes to CTS requirements. Administrative justifications cannot not be proposed for less restrictive changes.

SEE ATTACHMENTI TO THIS LIST FOR PROPOSED Y 9/30/97 3.3.7.1-2 The CTS Actions for ITS Function 3 require the operator to isolate RES OLUITION.

the reactor building and start the SGTS immediately ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.

The CTS Actions for ITS Function 4 prohibit fuel handling and all operations over spent fuel and open reactor wells ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems.

The ITS requirements for these functions is to trip inoperable channels in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or declare the associated CREV subsystem inoperable I hour from discovery of loss of trip capability in the trip system.

DOC A.2 does not address all of the proposed changes to CTS requirements. Administrative justifications cannot not be proposed for less restrictive changes.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE SEE ATTACHMENT3 TO THIS LIST FOR PROPOSED N 9/30/97 3.3.7.1-3 For two inoperable channels CTS require a functional test of the RESOLUTION particulate and radiation monitors once per shift. In addition, CTS actions provide a description of the use of these alarms for high radiation conditions. The required actions for failure to repair at least one channel in 30 day is ITS Action E. 1(place the CREV in operation). The CTS requires taking the actions specified in section 3.1.E.

Changes to the CTS Action 3.1.E are not identified and not evaluated.

The Unit I CTS Table 4.2.A calibration frequency for the High THIS IS A GENERIC QUESTION ON HOW TO HANDLEUNIT I. N 9/30/97 3.3.7.14 OOS Dwell Pressure function is changed from 3 months to 18 months A GENERIC RESPONSE THAT STATES MAKINGUNIT I in ITS Table 3.3.1.1-1 Functions 3, 4 & 6 to duplicate the less CONSISTENT WITH UNITS 2 & 3 IS DONE FOR CONSISTENCY restrictive frequencies of Units 2 & 3 CTS Table 4.2A. The AND THATTHE UNIT I TECHNICALSPECIFICATIONS WILL change is printed as an administrative change resulting in ITS BE VERIFIED CORRECT PRIOR TO UNIT I STARTUP. THIS Table 3.3.7.1-1, Function 2, rather than as a less restrictive change WILLBE A COMMIMENTTO REVIEW UNIT I TECH SPECS PRIOR TO RESTART. NO REVISION OF THE SUBMITAL SHOULD BE RE UIRED.

SEE ATTACHMENT2 TO THIS LIST FOR PROPOSED 9/30/97 3.3.7.1-5 ITS 3.3.7.1, REQUIRED ACTION E. 1 allows the option of placing RESOLUTION.

CREVS in the pressurization mode of operation. CTS Table 3.2.A, Note I, does not allow this option. Required Action E. I is more restrictive on CTS page 3.2/4.2-12 and Requirol Action E is less restrictive on page 3.2/4.2-34.

The addition of a less restrictive change is not more restrictive.

PAGE 2

e BFN ITS NRC COMMENT PROPOSED RESOLUTIONS 0

SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM INCORP COMPLETE COMMENT 4 DESCRIPTION OF ISSUE PROPOSED RESOLUTION Y/N DATE THE REQUESTED DOCUMENTATION%ILLBE SUBMITTED 9/30/97 3.3.7.14 The allowed out of service time (AOT) for placing a channel in trip TO THE NRC FOR APPROVAL. NO CHANGES TO THE CTS OR OOS when one trip system has inoperable, untripped channels, is ITS MARKUPS ARE REQUIRED.

defined in CTS Table 3.2.A, Note I, is extended from immediate to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in ITS 3.3.7.1, REQUIRED ACTION B.2, for those channels common to RPS, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in ITS 3.3.7.1, REQUIRED ACTION C.2; for all other channels.

The AOTs for placing a channel in trip for required surveillance testing is defined in CTS Table 3.2.A, Note 11, and is extended from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in ITS 3.3.7.1, Surveillance Requirements Note 2.

The CHANNEL FUNCTIONALTEST Surveillance Test Interval (STI) in CTS Table 3.2.A, is extended in ITS SR 3.3.7.1.2, to once per 92 days from monthly.

The DOC annotation for the Functional Test interval change from 9/30/97 3.3.7.1-7 CTS Table 4.2.G, Note I, calls for a Control Room Air Supply monthly to 92 days for the Control Room Air Supply Duct Radiation Duct Radiation Monitor FUNCTIONALTEST once per month. Monitors was not provided in the CTS markup of the Unit 3 CTS ITS Table 3.3.7.1-1 only requires a 92 day test interval. This Table 4.2.G and uus incorrectly indicated as DOC A3 in the CTS change is not justified. markup of the Unit I and 2 CTS Table 4.2.G. This change is based on the analyses of GENE-77046-1. Thus, the appropriate DOC for this change is DOC LB I. The CTS marhwp of the Unit I, 2, and 3 NOTES FOR TABLES 4.2.A THROUGH 4.2.L EXCEPT 4.2.D AND 4.2.K (includes the notes for CTS Table 4.2.G) correctly provided the DOC LBI annotation to the change in Note 1. Based on the above, the CTS markup of Table 4.2.G for Units I, 2, and 3 have been revised to rovide reference to DOC LBI for the chan e in Functional Test STI.

SEE ATTACHMENT4 FOR RESPONSE 3.3.7.1-8 ITS Functions 3 and 4 are shown to have one trip system with two channels. CTS Table 3.2.A Note (15) to Action G states these functions are comprised of two divisional trip systems with one channel in each zone and 2 sensors in each channel.

Explain the apparent discrepancy between the CTS and ITS required number of trip systems. Less restrictive changes proposed for the ITS are not administrative.

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BFN ITS NRC COMMENT'ROPOSED RESOLUTIONS SECTION 3.3.7. 1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM 0 ATTACHMENT 1 ISSUE 3.3.7.1-1 & 3.3.7.1-2 RESPONSE

RESPONSE

The following DOC A.2 revision is provided to address all the proposed changes to CTS requirements for the Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions.

The same Reactor Vessel Water Level - Low, Level 3, Drpvell Pressure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High channels and initiation portions of logic are used in Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation (proposed ISTS 3.3.7.1 Functions 1, 2, 3, and 4 for CREVS). Based on the commonality of the instruments, the CTS Table for Control Room Isolation Instrumentation (CTS Table 3.2.G, Note 3) refers to the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) for required actions associated with this instrumentation. The required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation, In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the afFects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High Functions require thc reactor to be in the COLD SHUTDOWN CONDITION in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the required channels are not met for one trip if system and the function is not tripped or the required channels cannot be met for all trip systems. The compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and Dwell Pressure-High Functions require these channels when inoperable to be placed in trip in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (proposed LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or ifinitiation capability is lost and not restored in 1 hour: 1) the reactor to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (proposed LCO 3.3.6.1, Condition G)<

2) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the associated SC zone or declare associated SCIVs inoperable AND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E). The less restrictive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance for tripping channels is addressed in DOC LB1 for proposed ISTS LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1. The replacement of the CTS requirement to initiate required actions when the required channels are not met for all trip systems with the less restrictive proposed ISTS requirement to initiate required actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when initiation capability is lost is addressed in DOCs for proposed ISTS LCO 3.3.6.1 and 3.3.6.2; however, since CTS Table 3.2.A does not require the CREV system to be declared inoperable or placed in operation the requirement to take these actions when initiation capability is loss is more restrictive and is addressed in DOC Ml of this section. Deletion of the CTS option to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the change from the CTS allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> before being required to bc in Cold Shutdown, and the additional requirement to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> are addressed in DOCs for proposed ISTS LCO 3.3.6.1. The changes associated with LCO 3.3.6.2, Condition C are addressed in DOCs for proposed ISTS LCO 3.3.6.2. The added requirements associated with the CREV System are addressed in DOC Ml of this section...

PAGE 4

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BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT2 ISSUE 3.3.7.1-5 RESP.ONSE

RESPONSE

The same Reactor Vessel Water Level - Low, Level 3, Drywell Pressure - High, Reactor Zone Exhaust Radiation High, and Refueling Floor Exhaust Radiation - High channels and initiation portions of logic are used in Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation (proposed ISTS 3.3.7.1 Functions 1, 2, 3, and 4 for CREVS).

Based on the commonality of the instruments, the CTS Table for Primary Containment and Reactor Building Isolation Instrumentation (CTS Table 3.2.A) provides thc required actions for this instrumentation. However, the required actions for this instrumentation in CTS Table 3.2.A are based on combined affects on Primary Containment Isolation, Secondary Containment Isolation, and CREV System Initiation. In proposed ISTS LCO 3.3.6.1 (Primary Containment Isolation Instrumentation), LCO 3.3.6.2 (Secondary Containment Isolation Instrumentation), and LCO 3.3.7.1 (CREV System Instrumentation) each LCO includes the required actions for the required instrumentation but bases the actions on the affects to the feature addressed by the LCO. CTS Table 3.2.A actions for Reactor Vessel Water Level - Low, Level 3 and Dtywell Pressure - High Functions require the reactor to be in the COLD SHUTDOWN CONDITION in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OR the operator to initiate an orderly load reduction and have Main Steam Lines isolated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and primary containment isolation initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. CTS Table 3.2.A actions for Reactor Zone Exhaust Radiation - High Function require the operator to isolate the reactor building and start the SGT immediately ifthe required channels are not met for one trip system and the function is not tripped or ifthe required channels cannot be met for all trip systems. CTS Table 3.2.A actions for Refueling Floor Exhaust Radiation High Function prohibit fuel handling and all operations over spent fuel and open reactor wells if the required channels are not met for one trip system and the function is not tripped or if the required channels cannot bc met for all trip systems. Thc compiled proposed ISTS requirement for Reactor Vessel Water Level - Low, Level 3 and D~vcll Pressure High Functions require these channels when inoperablc to be placed in trip in 12 hours (proposed LCO 3.3.6.1, 3.3.6.2, and 3.3.7.1) and ifnot tripped within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or if initiation capability is lost and not restored in 1 hour: 1) the reactor to bc in Mode 3 in 12 hours and Mode 4 in 36 urs (proposed LCO 3.3.6.1, Condition G); 2) in 1 hour isolate the associated SC zone or declare associated SCIVs inoperable ND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C); and 3)'in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E). The compiled proposed ISTS requirement for Reactor Zone Exhaust Radiation - High and Refueling Floor Exhaust Radiation High Functions require these channels when inoperable to be placed in trip in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (proposed LCO 3.3.6.2 and 3.3.7.1) and ifnot tripped within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or ifinitiation capability is lost and not restored in 1 hour: I) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the associated SC zone or declare associated SCIVs inoperable AND place SGT in operation or declare SGT inoperable (proposed LCO 3.3.6.2, Condition C) and 2) in I hour place associated CREV subsystem in operation or declare associated CREV subsystem inoperable (proposed LCO 3.3.7.1, Condition E).

As evident from the above, for Reactor Vessel Water Level - Low, Level 3, D~vcll Prcssure - High, Reactor Zone Exhaust Radiation - High, and Refueling Floor Exhaust Radiation - High Functions the proposed ISTS adds requirements that the CREV system be declared inoperable or placed in operation as well as maintains requirements relative to reactor shutdown (for Reactor Vessel Water Level - Low, Level 3 and Drywell Pressure - High) and isolation of the associated SC zones and placement of the SGT in service (for Reactor Zone Exhaust Radiation - High). The replacement of the CTS requirement to prohibit fuel handling and all operations over spent fuel and open reactor wells with the proposed LCO 3.3.6.2, Condition C requirements for the Refueling Floor Exhaust Radiation - High Function is addressed in DOCs for proposed ISTS LCO 3.3.6.2 and is unrelated to thc addition of the requirements for the CREV system (Other changes to CTS requirements are addressed in DOCs for proposed ISTS LCO 3.3.6. 1, 3.3.6.2, and 3.3.7.1). Based on the above, the added requirements to place the associated CREV subsystem in service or declare the associated CREV subsystem inoperable are more restrictive changes for proposed ISTS 3.3.7.1 Functions I, 2, 3, and 4 and these changes are appropriately addressed in DOC Ml and markup of CTS pages for CTS Table 3.2.A.

As indicated in DOC Ml, for proposed ISTS 3.3.7.1 Function 5 the requirement to declare the associated CREV subsystem inoperable when at least one Function 5 channel is not returned to OPERABLE status in the allowed out of service time currently exists in Note (2) of CTS Table 3.2.G. This discussion in DOC Ml is intended to exclude Ml applicability to proposed ISTS 3.7.1 Function 5. Since the CTS currently requires the associated CREV subsystem to be declared inoperable when at least one unction 5 channel is not returned to OPERABLE status in the allowed out of service time, the option of placing the associated CREV subsystem in operation is less restrictive for proposed ISTS 3.3.7.1 Function 5 and is addressed in DOC Ll and markup of page 3.2/4.2-34 (Units 1 and 2) and page 3.2/4.2-33 (Unit 3). DOC Ll has been revised to indicate that it is only less

'TS restrictive for proposed ISTS 3.3.7.1 Function 5.

PAGE 5

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT3 ISSUE 3.3.7.1-3 RESPONSE

RESPONSE

The CTS Table 3.2.G, Note 2 requirement for functional test of the particulate and radiation monitors once per shift when two channels of Control Room Air Supply Duct Radiation Monitors are inoperable and the description of the use of these alarms for high radiation conditions is captured by proposed ISTS LCO 3.3.7.1, Required Action D.2 and its associated Bases. The proposed ISTS Bases for Required Actions D.2 state: "... an allowed outage time of 30 days is provided to restore at least one channel to OPERABLE status provided that the alternate monitoring capability is verified functional once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The alternate monitoring capability is provided by the control room particulate monitor (RM-90-53) and radiation monitor (RE-90-8). These monitors alarm in the control room on high activity. Upon receipt of these alarms, the operator is required to manually isolate the control room and manually initiate the emergency pressurization system". The use of a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency for proposed ISTS LCO 3.3.7.1, Required Action D.2 is equivalent to the CTS requirement since CTS Table 1.1 defines the surveillance frequency of shift as at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The CTS required actions for failure to repair at least one channel in 30 days is to declare the system initiated by these monitors inoperable and take action as specified in CTS section 3.7.E. The proposed ISTS required actions for failure to repair at least one channel in 30 days is to place the associated CREV subsystem(s) in the pressurization mode of operation (proposed ISTS LCO 3.3.7.1, Required Action E. 1) OR Declare associated CREV subsystem inoperable (proposed ISTS LCO 3.3.7.1, Required Action E.2). The addition of the ISTS proposed option to place the associated CREV subsystem(s) in the pressurization mode of operation (proposed ISTS LCO 3.3.7.1, Required Action E. 1) is less estrictive for Function 5 and is addressed by DOC Ll. Ifthe ISTS proposed option to place the associated CREV bsystem(s) in the pressurization mode of operation is not performed, both the CTS and proposed ISTS would require both CREV subsystems to be declared inoperable under these conditions. With both CREV subsystems declared inoperable under the current Technical Specifications, CTS LCO 3.7.E, Control Room Emergency Ventilation, would be entered (with a CREV subsystem declared inoperable entry into CTS LCO 3.7.E would be required even without the CTS Table 3.2.G Note 2 direction to enter CTS LCO 3.7.E). With both CREV subsystems declared inoperable, CTS LCO 3.7.E.I (requirement for two CREV subsystems to be OPERABLE) would not be met, and thus, CTS LCO 3.7.E.4 would require reactor shutdowns to be initiated and all reactors to be in COLD SHUTDOWN within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for REACTOR POWER OPERATIONS and refueling operations to be terminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (the other two CTS LCO actions in CTS 3.7.E, CTS LCO 3.7.E.2 and 3.7.E.3, address required results from surveillance tests and AOT for one CREV subsystem inoperable). With both CREV subsystems declared inoperable under the proposed ISTS, proposed ISTS LCO 3.7.3, CREV System, would be entered as applicable on each Unit. Proposed LCO 3.7.3, Required Action D. I for each Unit in MODE 1, 2, or 3 would require immediate entry into proposed ISTS LCO 3.0.3 (generic LCO for reactor shutdown), and proposed LCO 3.7.3, Condition E for each unit in process of movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, or OPDRVs would require suspension of these in process activities. Since CTS Table 3.2.6, Note 2 and proposed ISTS 3.3.7.1 both provide for declaring the CREV subsystems inoperable under these conditions and rely on the CREV System LCOs to address further actions, the changes between CTS LCO 3.7.E and ISTS LCO 3.7.3 when both CREV subsystems are declared inoperable are not addressed in the markups for proposed ISTS section 3.3.7.1. However, as evident from the above, the CTS and proposed ISTS required actions for both CREV subsystem inoperable are similar, and the changes between CTS LCO 3.7.E and ISTS LCO 3.7.3 when both CREV subsystems are declared inoperable are addressed in the markups for proposed ISTS section 3.7.3.

PAGE 6

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.7.1, CONTROL ROOM EMERGENCY VENTILATIONSYSTEM ATTACHMENT4 ISSUE 3.3.7.1-8 RESPONSE The original JFC P67 and added wording to the Bases indicating that there is only one trip system for proposed ISTS LCO 3.3.7.1 Functions 3 and 4 were incorrect since there are two trip systems for these Functions as stated in CTS Table 3.2.A Note 15 (for Units 1 and 3) and Note 14 (for Unit 2). Based on DOC A4 for proposed ISTS section 3.3.7.1, the intent of the originally proposed ISTS Table 3.3.7.1-1 was to indicate that there are two trip systems for these Functions with each Function containing two channels (sensors) per trip system. However, based on the lack of clarity of the original proposed change and that the Test AOT of CTS Table 3.2.A Note 11 (proposed to be maintained as ISTS 3.3.7.1 Surveillance Requirements Note 3) is based on the channel definition in CTS Table 3.2.A Note 15 (for Units 1 and 3) and Note 14 (for Unit 2), the proposed ISTS has been revised to maintain the original CTS channel designation (i.e., two divisional trip systems with both trip systems contain one channel of each Function and each channel containing two sensors).

Based on the above the following changes have been made. The original JFC P67 has been deleted and replaced with a new JFC P67 which provides justification for the deletion of the words "...in both trip systems." Proposed ISTS Tables 3.3.7.1-1 have been revised to indicate 1 channel of Functions 3 and 4 are required per trip system. The original DOC A4 has been deleted and marked as not used and appropriate CTS markup revisions made. Appropriate changes to the proposed bases for ISTS 3.3.7.1 have been made. Similar changes were also made for proposed ISTS 3.3.6.2 since these channels are common for both CREV System and Secondary Containment Isolation initiation.

(Note the principal description ofthe channels is provided in the proposed Bases for ISTS 3.3.6.2, APPLICABLE SAFET Y ANALYSES, LCO, and APPLICABILITYfor Functions 3 and 4; the proposed Bases for ISTS 3.3.7.1 efers to the Bases for 3.3.6.2 for additional information on channel arrangements.)

PAGE 7

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.8.1, LOSS OF POWER COMMENT 0 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COMPLETE Y/N DATE 3.3.8.1-1 CTS 3.9.B. I I.a provides a 10 day AOT for inoperable Joss of TIN ITS, ITS BASES, CTS MARKUP, JFC, ISTS NUREG 10/30/97 MARKUP, AND ISTS NUREG BASES MARKUP SECTIONS voltage channels provided the degraded voltage relay channel on HAVE BEEN REVISED TO REQUIRE THE CTS VERIFICATION the same board is OPERABLE. ITS 3.3.8.1, REQUIRED Action OF OPERABILITYOF THE LOP INSTRUMENTATIONNOT B. I docs not require verification that the other undervoltage relay channel on the same board is OPERABLE. In addition, ITS allows TAKEN OUT OF SERVICE.

multiple condition entry which means any of the specified condtions can exist at the same time with their own completion time clocks. As such channels can be inoperable simultaneously for both loss of voltage and degraded voltage functions without entering a shutdown conditon. This is a less restrictive change to the CTS which othenvise would require entry into 3.0.3. Similar changes arc made to the CTS 3.9.B. I I.b and 3.9.B.I I.c.

Less restrictive requirements, such as deletion of CTS 3.9.B. I I.a, b and c verification requirements are not administrative changes.

Specific CTS changes must be identified and discussed.

THE ITS, ITS BASES, ISTS NUREG MARKUP, AND ISTS NUREG 10/30/97 3.3.8.1-2 ITS 3.3.8.1 SR Note 2 proposed a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> delay from entering into BASES MARKUP HAVE BEEN REVISED TO DELETE SR NOTE the associated Conditions and Required Actions for a channel 2.

placed in an inoperable status solely for performance of Required Surveillances provided the associated Function maintains initiation capability for 3 out of 4 diesel generators.

This relaxation of requirements is added to the requirements of CTS 3.9.A.3 without a technical justification. The proposed change does not conform to the STS allowance which provides an allowance not to enter TS Actions because individual DG trip capability is maintained. The impact of this proposed note is to add two hours to the channel repair time when testing.

DOC A2 HAS BEEN ADDED TO PROVIDE ADDITIONAL 10/30/97 3.3.8.1-3 The A.l justification is used for addition of the "separate condtion JUSTIFICATION FOR THE "SEPARATE CONDITION ENTRY" entry" note to the Actions. A.l is a discussion of editorial changes NOTE. THE A2 NOTE CLARIFIES THATTHE ITS NOTE IS which is not acceptable for technical changes to the CTS.

CONSISTENT WITH THE NUREG-1433 REQUIREMENTS AND PROVIDES CLARIFICATIONON THE CURRENT INTERPRETATION OF EXISTING SPECIFICATION.

CTS TABLE4.9A.4.C HAS BEEN REVISED TO CORRECTLY 10/30/97 3.3.8.14 LA.I allowable value items are incorrectly marked.

DEPICT THE LA.I APPLICABILffY.

PAGE I

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.8.1, LOSS OF POWER COMMENT 8 DESCRIPTION OF ISSUE PROPOSED RESOLUTION INCORP COht PLETE Y/N DATE THE TIME DELAYFUNCTIONS I.b AND 2.b IN ITS TABLE N 10/30/97 3.3.8.1-5 The licensee is not currently required to perform Loss of offsite 3.3.8.1-1 ARE NOT NEW REQUIREMENTS. CTS TABLE power instrumentation channel checks or channel functional test.

4.9.A.4.C LISTS THESE FUNCTIONS UNDER ITEM 1. TRIP The licensee proposed to maintain their current TS in the ITS.

RANGE, AND ITEM 3. TIMER 2-211-IA. THESE INSTRUMENTS This applies to functions I.a and 2.a of Table 3.3.8.1-1. The time DO NOT CUMKNTLYREQUIRE A CHANNEL CHECK OR delay functions in the same table, functions I.b and 2.b are new CHANNEL FUNCTIONALTEST. BFN PROPOSED requirements. Provide supporting justification, based on SURVEILLANCEREQUIREMENTS, WHICH DO NOT INCLUDE operational experience, to confirm the reliability of the time delay NUREG-1433 SRs 3.3.8.1.1 AND 3.3.8.1.2, ARE BASED ON BFNs functions to perform their intended safety function without periodic CURRENT LICENSING BASIS.

channel check and channel functional test requirements.

THE LA.1 DOC HAS BEEN REVISED TO CLARIFYTHATTHE 10/30/97 3.3.8.1-6 System design and operational details are moved to the ITS 3.3.8.1 VALUES IN THE CTS HEADING "TRIP LEVEL SETTINGS ARE Bases and plant procedures.

EQUIVALENTTO ALLOWABLE,VALUES.

TVA'S METHODOLOGY FOR DETERMINATIONOF SETPOINTS Trip setpoints are an operational detail not directly related to the UTILIZES THE CTS "TRIP LEVEL SETIlNGS" AS THE operability of the instrumentation. The Allowable Value is the ALLOWABLEVALUEIN ESTABLISHING THE NOMNALTRIP required limitation of the parameter and this value is retained in SETPOINT. THE SELECTION OF NOMINALTRIP SETPOINTS ITS Table 3.3.8.1-1.

PLUS ASSOCIATED INACCURACIES ENSURES THE "TRIP LEVEL SETIINGS" ARE NOT EXCEEDED. TVA'S SETPOINT The LA.I DOC discusses relocating timer trip setpoints to owner METHODOLOGYIS CONSISTENT WlTH RG 1.105 WHICH documents and retaining the CTS Allowable Values in the ITS.

ENDORSES ISA STD ISA- S67.04-1 982 "SETPOINT FOR For this CTS table the "trip level settings" column is simply NUCLEAR SAFETY RELATED INSTRUMENTATIONUSED IN renamed "Allowable Value" in the ITS format. The Allowable NUCLEAR POWER PLANTS" AND HAS BEEN REVIEWED BY Values do not exist in the CTS and the proposed ITS allowable THE NRC IN PREVIOUS SUBMITTALS, e.g. NRC LEITER TO values (CTS setpoints) are changed without justification.

MR. OLIVER D. KINGSLEYDATED JAN 2, 1991, ISSUANCE OF AMENDMENT TAC NO. 77279 291 .

PAGE 2

BFN ITS NRC COMMENT PROPOSED RESOLUTIONS SECTION 3.3.3.2, REACTOR PROTECTION SYSTEM ELECTRIC POWER MONITORING PROPOSED RESOLUTION INCORP COMPLETE COMMENT 8 DESCRIPTION OF ISSUE Y/N DATE The time delay relays delay the RPS power monitoring N 11/05/97 3.3.8.2-1 CTS 4.1.B does not specify a Channel Calibration, but ITS SR assemblies'ignal providing a time delay to ensure minor bus fluctuations, caused 3.3.8.2.2 adds CHANNEL CALIBRATIONrequirements with an surveillance frequency of 184 days. Time delay setting by activities such as switching loads, do not cause an unnecessary trip of the RPS power supply. The time delay is an integral part of the requirements are added to ITS SR 3.3.8.2.2 for the undervoltage, RPS power monitoring channel and therefore its setpoint is required overvoltage, and underfrequency protective devices of the RPS MG to be confirmed to be properly set to ensure operability of the power set. These time delay settings are not required by the CTS. Time monitoring channel. DOC M2 provides adequate justification for this delay settings and surveillance interval are based on previous plant more restrictive change.

practice. These additional restrictions on plant operation are not justified as a more restrictive change.

The following A4 DOC is provided: Y 9/29/97 3.3.8.2-2 CTS applicability requires operability of two RPS-EPM channels for each inservice MG Set or alternate source. ITS applicability CTS 3.1.B requires two RPS power monitoring channels for each requires operability of two RPS EPM assemblies for each inservice inservice RPS MG set or alternate source to be OPERABLE and CTS MG Set or alternate power supply. DOC do not justify the 3.1.B.I and 3.1.B.2 address LCO actions for inoperable RPS electric changing LCO terms from channels to assemblies.

power monitoring channels. The LCO and ACTIONS of proposed ISTS Section 3.3.8.2 are presented in terms of RPS electric power monitoring assemblies. The change from the use of the term channels to the term assemblies is considered administrative since in both, specifications the intent of the terms are the same. Specifically, in the CTS the contactor and associated sensing logic is intended to be considered as one RPS power monitoring channel. Referring to the contactor and associated sensing logic as an assembly, as in the proposed ISTS, is more appropriate since the overvoltage, undervoltage, and underfrequency instruments are each considered as channels within each assembl .

CTS 4.1.B.2 does not specify a channel calibration, however it does Y 11/05/97 3.3.8.2-3 CTS 4.1.B does not specify a Channel Calibration, but ITS SR require the trip level settings of the circuit protectors be verified. ITS 3.3.8.2.2 adds CHANNEL CALIBRATIONrequirements with an has included this requirement under the CHANNEL CALIBRATION surveillance frequency of 184 days. This requirement is added heading consistent with NUREG 1433.

with a 184 day interval since this test is performed during the CFT The SR 3.3.8.2.1 Note has been deleted.

(SR 3.3.8.2.1).

Explain the absense of the SR 3.3.8.2.1 Note on SR 3.3.8.2.2 to allow a delay in required testing based on the Mode of operation.

PAGE I

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3. 3

'-0 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 as referenced in NRC letter to Oliver D. Kingsley dated June 12, 1997, with the subject "BROWNS FERRY NUCLEAR PLANT UNITS 1,2,AND 3 REQUEST FOR ADDITIONAL INFORMATION REGARDING IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M96431, M96432, M96433)", and incorporates changes resulting from internal TVA reviews. A synopsis of the ITS and ITS BASES changes is provided below.

SECTION 3.3.1.1, RPS INSTRUMENTATION Table 3.3.1.1-1 Modified by adding applicability of MODE 5" and associated Surveillance Requirements (SRs) to FUNCTIONS 2.a, Average Range Monitors Neutron Flux High Setdown, and 2.e, Average Range Monitors Neutron Inop. This change is to make the ITS consistent with the requirements of CTS Table 3.1.A. This is in response to NRC comment 3.3.1.1-17.

BASES g BACKGROUND Corrected typographical errors on page B 3.3-1 to make consistent with NUREG-1433 Markup.

BASES, APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Added discussion of MODE 5 applicability in "2.a. Average Power Range Monitor Neutron Flux High, Setdown". This incorporates CTS Table 3.1.A note 21 discussion of use of SRM noncoincidence High Flux Scram by removing the shorting links.

Added Instrument UNIDs, as additional information, to "3. Reactor Vessel Steam Dome Pressure High".

Added Instrument UNIDs, as additional information, to "4. Reactor Vessel Water Level Low, Level 3".

Added Instrument UNIDs, as additional information, to "6. Drywell Pressure High".

Added Instrument UNIDs, as additional information, to "7.a, 7.b. Scram Discharge Volume Water Level High".

Page 1 of 24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3. 3 Added Instrument UNIDs, as additional information, to "9. Turbine Control Valve Fast Closure, Trip Oil Pressure-Low" and changed description from "transmitter" to "switch" because BFN uses discrete switches not transmitters for this function.

Added Instrument UNIDs, as additional information, to "13. Low Scram Pilot Air Header Pressure". Note that this function does not exist for Unit 1.

I BASES ~ ACT ONS Provided specific additional details by Function in C.1 to better define when Functions lose trip capability due to multiple inoperable/untripped channels.

BASEST SURVEILLANCE REQUIREMENTS Corrected typographical omission by adding "and APRM" to third paragraph of SR 3.3.1.1.3 to match the original NUREG-1433 mark-up.

Corrected SR 3.3.1.1.9, SR 3.3.1.1.10,and SR 3.3.1.1.13 by deleting "For the APRM Simulated Thermal Power-High Function, SR 3.3.1.1.9 also includes calibrating the associated recirculation loop flow channel" and "also" because the calibration of the recirculation flow loop is addressed in SR 3.3.1.1.11 instead of SR 3.3.1.1.9.

Corrected typographical omission by adding "calibrated flow signal and, therefore, the APRM Function accurately reflects the required setpoint as a function of flow" in first paragraph of SR 3.3.1.1.11 to match the original NUREG-1433 markup.

Added instrument UNIDs to identify instrumentation addressed by calibration of bypass channels in SR 3.3.1.1.15.

SECTION 3.3.1.2, SOURCE RANGE MONITOR (SRM) INSTRUMENTATION SURVEILLANCE REQUIREMENTS Deleted Note 2 to SR 3.3.1.2.4 and made associated revisions (change NOTES to NOTE and deleted number 1 for the remaining note) because Note 2 conflicts with Note b to Table 3.3.1.2-1. The effect of this deletion is that the required SRM OPERABLE channels will still require verification of a count rate R 3.0 cps and a signal-to-noise ratio of ~ 3:1.

Page 2 of 24

e EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3 BASES, SURVEILLANCE REQUIREMENTS Deleted reference and associated'text to Note 2 for SR 3.3.1.2.4.

Replaced "only" with "mainly" in second paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 to clarify that reactivity changes in MODES 3 and 4 are not due "only to control rod movement", but control rod movement is the main cause of reactivity changes.

Replaced "the Surveillance" in fourth paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 with "SR 3.3.1.2.6" to clarify which of the SRs the note pertains to.

Replaced "Frequency" with "Allowance" in fourth paragraph of SR 3.3.1.2.5 and 3.3.1.2.6 because the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allotted after IRMs are on Range 2 or below to perform the SR is better described as an allowance rather than a Frequency which implies a time frame between performances.

Corrected "18 month" to "92 day" in second paragraph of SR 3.3.1.2.7. The 18 month value was not changed to 92 day value for applicability at the same time (Rev 0 markup) as the SR and other references to it.

Replaced "Frequency" with "Allowance" in second paragraph of SR 3.3.1.2.7 because the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allotted after IRMs are on Range 2 or below to perform the SR is better described as an allowance rather than a Frequency which implies a time frame between performances.

SECTION 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION BASES, BACKGROUND Inserted "on" between based and position in third paragraph of sentence which read "The RWM determines the actual sequence based position indication for each control rod."

The insertion of "on" clarifies the intent of the sentence.

BASES, APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Changed < 10% RTP to ~ 10% RTP in fourth paragraph of "2. Rod Worth Minimizer" to agree with several other locations, including Note c to Function 2 (RWM) in ITS Table Page3 of24

EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3. 3 0 3.3.2.1-1, that the Rod Worth use the ~ 10% RTP Minimizer is required.

for when OPERABILITY of BASES, SURVEILLANCE REQUIREMENTS Changed the Frequency in third paragraph of "SR 3.3.2.1.4" from "184 day" to "92 day" to agree with the Frequency of the Channel Calibration specified in the Surveillance Requirement. This value is based on a site specific setpoint analysis that supports the 92 day Frequency.

SECTION 3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION ACTIONS Changed CONDITION A. from one CHANNEL inoperable to one or more in the same trip system inoperable because the other trip system maintains the ability to perform the required action (trip feedwater and main turbines).

REQUIRED ACTION A.l to CHANNEL(S)

Changed CHANNEL indicate that itincould be more than one channel.

to SURVEILLANCE REQUIREMENTS Changed Allowable Value for SR 3:3.2.2.3 from 588 inches above vessel zero to 586 inches above vessel zero. This change made to agree with Analytical Limit and Scaling and Setpoint Analysis Calculations.

BASES, BACKGROUND Added Instrument UNIDs in the third paragraph to better identify the trip units which actuate the trip logic.

BASES, ACTIONS Revised the description of ACTION A.l to address acceptability of having more than one CHANNEL in the same trip system inoperable based on the plant specific trip logic.

Page 4 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3.3 SECTION 3 3 3 1 i POST ACCIDENT MONITORING (PAM) 1NSTRUMENTATION SURVEILLANCE REQUIREMENTS Corrected SR 3.3.3.1.4 from "Reactor Pressure, Drywell, and Torus H~ Analyzer Functions" to "Reactor Pressure, and the Drywell and Torus H~ Analyzer Functions" which more clearly shows that the Drywell and Torus H~ Analyzer is one Function.

TABLE 3.3.3.1-1 Revised "Active PC1V" in Note b to "installed Control Room PAM Category 1 indication CHANNEL" to more clearly define when only one position indication for a penetration flow path is required.

BASES, LCO Added Instrument UNIDs, as additional information, to "1. Reactor Steam Dome Pressure".

0 Added Instrument UNIDs, as additional information, to "2. Reactor Vessel Water Level".

Added Instrument UNIDs, as additional information, to "3. Suppression Pool Water Level".

Added Instrument UNIDs, as additional information, to "4. Drywell Pressure".

Added Instrument UNIDs, as additional information, to "5. Primary Containment Area Radiation (High Range) .

Added "The PCIV position PAM indication instrumentation consists of the Category 1 PCIV position indications identified in Reference 4" to the beginning of the second paragraph of "6. Primary Containment Isolation Valve (PCIV)

Position". This provides a reference for the identification of the PAM PCIV position indications.

Added Instrument UNIDs, as additional information, to "7. Drywell and Torus Hydrogen Analyzers".

Deleted "or oxygen" from "7. Drywell and Torus Hydrogen Analyzers" because hydrogen is the only parameter of concern. This is consistent with the deletion of oxygen analyzer function from other parts of the ITS.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 ITS SECTION 3.3 0 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO Added Instrument UNIDs, as additional information, .to "8. Suppression Pool Water Temperature".

Added "For a channel to be OPERABLE, at least 7 of its 8 sensors must be OPERABLE" to "8. Suppression Pool Water Temperature". This incorporates Note 6 from CTS Table 3.2.F into the ITS BASES.

Added Instrument UNIDs, as additional information, to "9. Drywell Atmosphere Temperature".

Changed "transmitters" to "sensors" in "9. Drywell Atmosphere Temperature" because the instruments which generate the signal (RTDs) are more appropriately described as sensors.

BASES ~ ACT IONS Added "does" to ACTION F.1 for clarity which makes the statement read "the plant must be brought to a MODE in which the LCO does not apply".

BASEST SURVEILLANCE REQUIREMENTS Addressed SR 3.3.3.1-4 with SR 3.3.3.1-2 and SR 3.3.3.1-3.

These SRs all address CHANNEL CALIBRATION. In the original NUREG-1433 mark-up two additional SRs for CHANNEL CALIBRATIONs were added to address having 3 different calibration frequencies but only one of the additional SRs was added to the NUREG BASES markup. Adding SR 3.3.3.1-4 and inserting "The 184 day frequency for CHANNEL CALIBRATION of the REACTOR Pressure Indication is based on plant specific analysis" will correct the omission from the Revision 0 markup. This change addresses NRC question 3.3.3.1-4.

Page 6 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362

3. 3 0 SECTION IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3.3.2, BACKUP CONTROL SYSTEM SURVEILLANCE REQUIREMENTS Deleted SR 3.3.3.2.1 and renumbered the remaining SRs. SR 3.3.3.2.1 was to "Perform a CHANNEL CHECK for each required instrumentation channel that is normally energized and provides indication during normal plant operation".

NUREG-1433 did not include the part of the SR that states "and provides indication during normal plant operation".

The addition of the clarification was rejected by the NRC as a Generic Change to The STS. Without the clarification CHANNEL CHECKS would be required for all of the transfer/control functions in addition to the indication functions. There are no CTS requirements to perform CHANNEL CHECKS for the Backup Control Instrumentation. The requirement was therefore deleted from the ITS because the benefits of performing the CHANNEL CHECKS is not sufficient to justify the additional manpower required.

BASES, SURVEILLANCE REQUIREMENTS Deleted BASES for SR 3.3.3.2.1 because the SR was deleted as stated above. Renumbered the remaining SRs due to the deletion.

BASES, TABLE B3.3.3.2-1 Replaced existing Table 3.3.3.2-1 (Backup Control System Instrumentation and Controls) with a new one which better defined the required functions and contained notes to better explain the number of functions required.

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

INSTRUMENTATION BASES ~ BACKGROUND Revised third paragraph of the BACKGROUND to delete discussion of "electronic equipment (e.g., trip relays) because the instrumentation used for EOC-RPT utilizes discrete switches not analog transmitters. Also added "channel's pre-established" to "When the channel's re-established setpoint is exceeded,..." as clarification.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS)= SUPPLEMENT TO ITS SECTION 3.3 BASES APPLICABLE SAFETY ANALYSES ~ LCO~ AND APPLICABILITY For the "Turbine Stop Valve Closure" second paragraph change "switches" to "signals" in the sentence "There are two separate position switches associated with each stop valve..." because in actuality there is only one switch housing that provides the separate contacts for the signals.

Also added "Therefore, to consider this function operable bypass of the function must not occur when bypass valves are open". This change will allow testing of the bypass valves without making the Turbine Stop Valve (TSV) Closure function inoperable unless bypassing the TSV Closure function actually occurs due to decreasing the turbine first stage pressure below the bypass setpoint.

For the "Turbine Control Valve Fast Closure, Trip Oil Pressure Low" function, added UNIDs for additional information. In the second paragraph changed "transmitter" to "s~itch" because pressure switches are utilized, not transmitters. Also in the second paragraph added "Therefore, to consider this function operable bypass of the function must not occur when bypass valves are open". This change will allow testing of the bypass valves without making the Turbine Control Valve (TCV) Fast Closure Trip Oil Pressure Low function inoperable unless bypassing the function actually occurs due to decreasing the turbine first stage pressure below the bypass setpoint.

SECTION 3.3.4.2, ANTICIPATED TRANSIENT WITHOUT SCRAM RECIRCULATION PUMP TRIP (ATWS-RPT) INSTRUMENTATION BASES, BACKGROUND In the third paragraph, added "vessel" to "... either two Reactor Vessel Water Level..." for clarification.

In the fourth paragraph, replaced "both recirculation pump breakers" with "one of the two breakers for each recirculation pump" as clarification.

Added Instrument UNIDs, as additional information, to "a. Reactor Vessel Water Level Low".

Added Instrument UNIDs, as additional information, to "b. Reactor Steam Dome Pressure High".

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3 SECTION 3 3 5 1 ~ EMERGENCY CORE COOLING SYSTEM (ECCS)

INSTRUMENTATION ACTIONS Removed Functions 1.c and 2.c from REQUIRED ACTION B.1 and added them into REQUIRED ACTION C.1. REQUIRED ACTION C.1 is more appropriate for these Functions for Core Spray and LPCI because they are permissives for which it is better to restore OPERABILITY than to place in trip which is non-conservative. Also clarified REQUIRED ACTIONS and COMPLETION TIMES FOR B.1 and C.1 by adding "ECCS" modifier to "feature(s) inoperable", changed "loss of feature" to "loss of function(s)", changed "loss of subsystem" to "loss of function(s)", and changed "both subsystems" to "both trip systems". These changes were all made to provide more accurate descriptions.

For REQUIRED ACTION H.1 added "ECCS" to "feature(s) inoperable" to clarify features of concern are the ECCS features.

TABLE 3.3.5.1-1 For Function 1.c, added reference to note b which was revised to state "Channels affect Common Accident Signal Logic. Refer to LCO 3.8.1, 'AC Sources Operating'",.

changed the Conditions Referenced from B to C, and clarified that 4 Required Channels are "2 per trip system". The change to note b was to identify the actual logic that initiates the Diesel Generators and EECW to which the note previously referred. The change from Conditions Referenced is to agree with the change made to the REQUIRED ACTIONS.

For Functions 2.a and 2.b, deleted note b reference and also note b on this page because is addressed under Functions l.a, 1.b, and 1.c, "Core Spray System" where the Common Accident Signal is generated.

For Function 2.c, changed the Conditions Referenced from B to C to agree with the change made to the REQUIRED ACTIONS.

For Function 2.e, added clarification that Required Channels are "1 per Subsystem".

For Function 2.f, Pumps C and D, added clarification that Required Channels are "1 per trip system" and modified note e with same information.

Page 9 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 0 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION For Function 3.f, changed SR 3.3.5.1.3 to SR

3. 3 3.3.5.1.5 which effectively changes the calibration frequency from 92 days to 18 months. This is acceptable based on the setpoint analysis.

Corrected the Required Channels per Function for Function 4.e to 4, Function 4.f to 8, Function 4.g to 2, Function S.e to 4, Function 5.f to 8, and Function 5.g to 8. This was done because previously these had erroneously been listed on a per trip system basis.

BASES, BACKGROUND In the third paragraph, clarified that the Common Accident Signal is the logic generated by the ECCS instrumentation that initiates the Diesel Generators and EECW System.

For the "Core Spray System", added clarification that Reactor Vessel Water Level and Drywell Pressure are "each" monitored by four transmitters. Changed Subsystem to trip system. Also clarified that the "low reactor water level" signal is sealed in.

For the "Automatic Depressurization System", clarified that the Level 3 signal is. used as a confirmatory signal to the Level 2 signal. Revised the description of the Core Spray and LPCI discharge pressure switches to correctly identify the appliable number. Revised the description of the ADS logic for clarity.

For the "Diesel Generators" and "Emergency Equipment Cooling Water (EECW) System", deleted these sections because they are not applicable to the ECCS section.

BASES ~ APPL ICABLE SAFETY ANALYSES g LCD'ND APPLI CABILITY In the third paragraph, deleted text on response time since BFN is not committed to do response time testing and clarified text on note b to refer to the Common Accident Signal Logic.

In the fourth paragraph, deleted references to Diesel Generators based on note b revision.

For "la, 2a Reactor Vessel Water Level Low Low Low, Level 1", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal and deleted associated text. pertaining to the EECW and Diesel Generator Initiation si,gnals.

l Page 10 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS,(ITS), SUPPLEMENT TO ITS SECTION 3.3 For "1.b, 2.b Drywell Pressure High", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal and deleted associated text pertaining to the EECW and Diesel Generator Initiation signals.

For "1.c, 2.c Reactor Dome Pressure Low (Injection Permissive and ECCS Initiation)", added instrument UNIDs as additional information, and provided text to explain the generation of the Common Accident Signal.

For "1.d Core Spray Pump Discharge Flow Low (Bypass)",

added instrument UNIDs as additional information.

For "1.e, 2.f Core Spray and Low Pressure Coolant Injection Pump Start, Time Delay Relay", clarified the number of relays per pump start logic.

For "2.d Reactor Steam Dome Pressure Low (Recirculation Discharge Valve Permissive)", added instrument UNIDs as additional information.

For "2.e Reactor Vessel Water Level Level 0", added instrument UNIDs as additional information.

For "3.a Reactor Vessel Water Level Low Low, Level 2",

added instrument UNIDs as additional information.

For "3.b Drywell Pressure ,High", added instrument UNIDs as additional information.

For "3.c Reactor Vessel Water Level High, Level 8", added instrument UNIDs as additional information.

For "3.d Condensate Header Level Low", added instrument UNIDs as additional information.

For "3.e Suppression Pool Water Level High", added instrument UNIDs as additional information.

For "3.f High Pressure Coolant Injection Pump Discharge Flow Low (Bypass)", added instrument UNIDs as additional information and corrected "transmitter" to "switch" to agree with plant configuration.

For "4.a, S.a Reactor Vessel Water Level Low Low Low, Level 1", added instrument UNIDs as additional information.

Page ll of24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS), SUPPLEMENT TO ITS SECTION 3.3 For "4.b, S.b Drywell Pressure High", added instrument UNIDs as additional information.

For "4.d, 5.d Reactor Vessel Water Level Low, Level 3",

added instrument UNIDs as additional information.

For "4.e, 4.f, 5.e, 5.f, Core Spray and Low Pressure Coolant Injection Pump Discharge Pressure High", added instrument UNIDs as additional information and replaced "transmitters" with "switches" to match plant configuration. Also replaced "two for" with "one from" to clarify the signals from the Core Spray Pumps.

For "4.g, 5.g Automatic Depressurization System High Drywell Pressure Bypass Timer", clarified that there are. four bypass timers (two per trip system).

BASES g ACT ONSI For "B.1, B.2, and B.3", deleted text pertaining to Functions 1.c and 2.c which were relocated to "C.1 and C.2".

Deleted statement about DG and EECW inoperability because the logic for Common Accident Signal, which initiates these, is located in another section. Deleted "redundant" because it is not applicable improve readability.

to HPCI. Corrected other text to For "C.l and C.2" added information pertaining to Functions 1.c and 2.c which were relocated from "B.1, B.2, and B.3".

For "D.l" deleted second and third sentences of second paragraph. This change is based on Operations review comment and deletes unnecessary detail.

For "E.1 and E.2" revised the discussion of inoperability due to multiple inoperable channels for the Core Spray Pump Discharge Flow Low Bypass Function to clarify equipment affected (potentially all four CS Pumps). Also identified the Function of concern as 1.d.

BASES SURVEILLANCE REQUIREMENTS Revised SR 3.'3.5.1.6 to delete LCO 3.8.2 as overlapping this Surveillance.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3.3 SECTION 3 3 5 2 g REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION APPLICABLE SAFETY ANALYSES ~ LCOg AND APPLICABILITY Added Instrument UNIDs, as additional information, to "1. Reactor Vessel Water Level Low Low, Level 2".

Added Instrument UNIDs, as additional information, to "2. Reactor Vessel Water Level High, Level 8".

SECTION 3.3.6.1, PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION ACTIONS Revised "COMPLETION TIME" to add functions 6.b and 6.c (new functions in table) for "CONDITION A" to the functions that have 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after being declare inoperable to be placed in trip.

For "REQUIRED ACTION D.1" changed "Isolate associated main steam line (MSL)" to "Isolate the affected penetration flow path(s)". This change is necessary because other penetration flow paths besides the Main Steam Lines are isolated by the functions which reference ACTION D from table 3.3.6.1-1.

Added REQUIRED ACTION G.1 and renumbered existing REQUIRED ACTION G.1 and G.2 to G.2.1 and G.2.2 respectively. Also added note that specifies REQUIRED ACTION G.l, is only applicable for functions 2.a and 2.b which are inoperable as a result of inoperable actuation logic. The added action allows isolating the affected penetration flow path(s) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> instead of being in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This change accomplishes the required safety action (isolation of primary containment for affected penetrations) and allows more flexibility than shutting down if non-critical penetrations are inoperable.

Added a CONDITION I which has the REQUIRED ACTION of "I.1, Initiate action to restore channel to OPERABLE status" or "I.2, Initiate action to isolate the Residual Heat Removal (RHS) Shutdown Cooling System". Both actions COMPLETION TIME is Immediately. This addition addresses the actions while in Shutdown Cooling and the Reactor Vessel Water Level Low Function is isolation capability is not maintained.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3. 3 TABLE 3.3.6.1-1 Added FUNCTIONS 3.f and 3.g and modified description of FUNCTION 3.e to identify the three separate areas (Exit, Midway, and Entry) for the HPCI Steam line Space Torus Area Temperature High.

Added FUNCTIONS 4.f and 4.g and modified description of FUNCTION 4.e to identify the three separate areas(Exit, Midway, and Entry) for the RCIC Steam line Space Torus Area Temperature High.

Added "-High" to FUNCTIONS 5.a, 5.b, 5.c, S.d, 5.e and 5.f to better describe that the parameter of concern is high temperature.

Added FUNCTIONS 6.b (with associated note b), Reactor Vessel Water Level Low, and 6.c, Drywell Pressure High, for Shutdown Cooling System Isolation. This adds back requirements deleted from CTS in=original mark-up and responds to NRC comment 3.3.6.1-14.

BASES, BACKGROUND Revised "1. Main Steam Line Isolation" to provide more plant specific description and details.

Revised "2. Primary Containment Isolation" to provide more plant specific description and details.

Revised "3,4. High Pressure Coolant Injection Isolation and Reactor Core Isolation Cooling System Isolation" to provide moxe plant specific description and details.

Revised "5. Reactor Watex Cleanup System Isolation" to provide more plant specific description and details.

Revised "6. Shutdown Cooling System Isolation" to provide more plant specific description and details.

Each of the above sections was substantially revised based on input from Operations Review.

Page 14 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3.3 BASES~ APPLICABLE SAFETY ANALYSES~ LCO AND APPLICABILITY Deleted "Each channel must also respond within its assumed response time, where appropriate". This was deleted because BFN is not committed to do Response Time Testing and references to the ITS.

it have been removed from other locations in Added a paragraph break for fifth paragraph for clarity.

Added Instrument UNIDs, as additional information, to "1.a. Reactor Vessel Water Level Low Low Low, Level 1".

In "1.b. Main Steam Line Pressure Low", added Instrument UNIDs, as additional information. Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.

In "1.c. Main Steam Line Flow High", added Instrument UNIDs, as additional information. Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.

In "1.d. Main Steam Line Space Temperature High", added Instrument UNIDs, as additional information. Changed "Line Space" to "Tunnel" in several locations to better reflect BFN terminology. Also added "excluding the Recirculation Loop Sample Valves" to last paragraph to clarify applicability.

In "2.a. Reactor Vessel Water Level Low, Level 3", added Instrument UNIDs, as additional information. Also clarified applicability by revising last paragraph tc "This Function is required for the isolation of the Group 2 (excluding RHR valves for SDC), 6, and 8 valves. Portions of this instrumentation are also required for Functions 5.h and 6.b".

In "2.b. Drywell Pressure High", added Instrument UNIDs, as additional information. Also clarified applicability by revising last paragraph to "This Function is required for the isolation of the Group 2 (excluding RHR valves for SDC),

6, and 8 valves. Portions of this instrumentation are also required for Function 6.c".

In "3.a., 4.a. HPCI and RCIC Steam Line Flow High", added Instrument UNIDs, as additional information.

Page 15 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3. 3 In "3.b., 4.b. HPCI and RCIC Steam Line Pressure Low",

added Instrument UNIDs, as additional information. Also deleted "Each Function is considered to have only one trip system since the output from the logic trips a common relay that initiates the isolations" because this information was added to the BACKGROUND.

In "3.c., 4.c. HPCI and RCIC Turbine Exhaust Diaphram Pressure High", added Instrument UNIDs, as additional information. Also deleted "Each Function is considered to have only one trip system since the output from the logic trips a common relay that initiates the isolations" because this information was added to the BACKGROUND.

In "3.d., 3.e., 4.d., 4.e. Area Temperature High", added functions 3.f., 3.g., 4.f., and 4.g. to address the torus area having three distinct area trip functions for each system. Added Instrument UNIDs, as additional information.

Also modified description of to clarify the number of channels and delete reference to Differential Temperature which is not utilized at BFN.

In "5.a., 5.b., 5.c., S.d., S.e.,5.f. Area Temperature High", added Instrument UNIDs, as additional information.

Also indicated that areas as opposed to rooms are being monitored and deleted text on the logic which has been included in the BACKGROUND.

In "5.h Reactor Vessel Water Level Low, Level 3", added Instrument UNIDs, as additional information. Added paragraph that states the Allowable Value for the Function is the same as RPS Level 3 scram Allowable Value. Also revised applicability to state "This Function is required for the isolation of the Group 3 valves. Portions of this instrumentation are also required for Functions 2.a and 6.b." which in effect deletes Groups 2, 6, and 8.

In "6.a. Reactor Steam Dome Pressure High", added Instrument UNIDs, as additional information. Also clarified that the valves to be isolated are the Shutdown Cooling Supply Isolation Valves.

Added 6.b., Reactor Vessel Water Level Low, Level 3 and 6.c., Drywell Pressure High BASES to address the new Functions added for the isolation of Shutdown Cooling valves.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3 BASES, ACTIONS New Functions 6.b and 6.c were added to "A.1 and A.2" and minor changes were made for clarification.

The first paragraph of "B.1" was substantially revised in response to Operations comments. This revision clarifies the number of required channels per function required to maintain isolation capability.

"D.1, D.2.1, and D.2.2" was revised to change "MSL" to "penetration flow path(s) because lines (for example Main Steam Drain Lines) other than the Main Steam Lines could be affected which may not necessitate the isolation of a Main Steam Line.

For "G.l and G.2", a new ACTION G.l was added and the existing ACTIONS were renumbered to G.2.1 and G.2.2.

Additional details were provided to address the actions of isolating the affected penetration flow path(s) for Functions 2.a and 2.b being inoperable due to inoperable actuation logic.

Added BASES for new ACTIONS I.1 and I.2 which address the added Functions for RHR Shutdown Cooling System Isolation.

SURVEILLANCE REQUIREMENTS Added "The LOGIC SYSTEM FUNCTIONAL TEST shall include a calibration of time delay relays and timers necessary for proper functioning of the logic" to SR 3.3.6.1.6. This change addresses CTS requirement for timer testing/calibration.

SECT ION 3 3 6 2 g SECONDARY CONTAINMENT ISOLAT ION INSTRUMENTATION ACTIONS Added "secondary containment" in front of "isolation capability" for CONDITION B and REQUIRED ACTION B.l for clarification. NRC comment 3.3.6.2-3 noted that "secondary containment" had been deleted from NUREG-1433.

Replace "zone(s)" with "secondary containment isolation valves" for REQUIRED ACTION C.l.l because zonal isolation is no longer required by ITS section 3.6.4.1, Secondary Containment, but the affected secondary containment Page 17 of 24

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS), SUPPLEMENT TO ITS SECTION 3.3 isolation valve must still maintain isolation capability or be isolated.

Revised REQUIRED ACTION C.2.1 to add "associated" in front of "standby gas treatment" and replaced "system" with "subsystem(s)". This restores the original NUREG-1433 text.

Revised REQUIRED ACTION C.2.2 to add "associated" in front of "SGT" and replaced "system" with "subsystem(s)". This restores the original NUREG-1433 text.

SURVEILLANCE REQUIREMENTS Added "secondary containment" in front of "isolation capability" for Note 2. NRC comment 3.3.6.2-3 noted that "secondary containment" had been deleted from NUREG-1433.

Deleted SR 3.3.6.2.3 for performing a LOGIC SYSTEM FUNCTIONAL TEST every 184 days and renumbered the remaining SRs. It was determined that the Functions (Reactor Zone Exhaust Radiation High and Refueling Floor Exhaust Radiation High) that had specified a 184-day LOGIC SYSTEM FUNCTIONAL TEST could have their LOGIC SYSTEM FUNCTIONAL TEST extended to 18 months and, therefore, the 184-day test was no longer required.

TABLE 3.3.6.2-1 Renumbered SRs due to the deletion of SR 3.3.6.2.3 and renumbering of the remaining SRs. Deleted SR 3.3.6.2.1 (Channel Check) requirement for Function 2. Drywell Pressure High. The Channel Check requirement was not included in the CTS and thus deletion is acceptable.

Revised the number of required channels per trip system for "3. Reactor Zone Exhaust Radiation High" and "4. Refueling Floor Exhaust Radiation High" from 2 to 1. This change is based on one channel of each function being required per trip system.

BASES, BACKGROUND Deleted "In addition, manual initiation of the logic is provided" from the second paragraph because BFN is not committed to have manual initiation capability.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3. 3 BASES I APPLICABLE SAFETY ANALYSES I LCO/ AND APPLICABILITY Deleted "Each channel must also respond within its assumed response time, where appropriate" from the fourth paragraph because BFN is not committed to perform response t:ime testing.

For "1. Reactor Vessel Water Level Low, Level 3", added Instrument UNIDs, as additional information. Also added "These signals are the same that isolate the primary containment (additional information on the arrangement of these channels in the PCIS trip systems can be found in the BASES for LCO 3.3.6.1, "Primary Containment Isolation Instrumentation", Function 2)" to provide a cross reference for other Funct'.ions performed by the same instrumentation.

Corrected title for second page to Level 3 (not Level 2).

For "2. Drywell Pressure High", added Instrument UNIDs, as additional information. Also added "These signals are the same that isolate the primary containment (additional information on the arrangement of these channels in the PCIS trip systems can be found in the BASES for LCO 3.3.6.1, "Primary Containment Isolation Instrumentation", Function 2)" to provide a cross reference for other Functions performed by the same instrumentation.

For "3.4. Reactor Zone and Refueling Floor Exhaust Radiation High", added Instrument UNIDs, as additional information.

The second paragraph was rewritten to bett:er describe the logic of operation.

I BASES I ACT ONS Revised "B.1" to clarify minimum number of channels OPERABLE t:o assure penetration flow path isolation on a valid signal.

Added paragraph to "C.1.1, C.1.2, C.2.1, and C.2.2" to explain that REQUIRED ACTIONS C.2.1 and C.2.2 can be performed independently on each SGT subsystem.

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PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS) SUPPLEMENT TO ITS SECTION 3.3 SURVEILLANCE REQUIREMENTS Corrected Functions to which Note 3 is applicable from Functions 2.c and 2.d to Functions 3 and 4 to which the Note actually refers. Functions 2.c and 2.d do not exist.

Added "This Surveillance for Functions 3 and 4 shall consist of verifying the High Voltage Power Supply (HVPS) voltage at the Sensor and Convertors (detectors) is within its design limits. A CHANNEL FUNCTIONAL TEST as defined in Section 1.1, "Definitions" shall be performed once per 18 months as part of the CHANNEL CALIBRATION for Functions 3 and 4" to SR 3.3.6.2.2. This note incorporates CTS Table 4.2.A, Note 32.

For the LOGIC SYSTEM FUNCTIONAL TEST SRs, combined SR 3.3.6.2.3 and SR 3.3.6.2.5 and renumbered to SR 3.3.6.2.4.

This change was necessary because the 184 day Frequency for Functions 3 and 4 were changed to 18 months and thus only one SR for LOGIC SYSTEM FUNCTIONAL TEST is required.

Renumbered SR 3.3.6.2.4 to SR 3.3.6.2.3 and relocated to proper sequential location.

INSTRUMENTATION ACTIONS Deleted "in both trip systems" from the COMPLETION TIME for CONDITION B. This is because each trip system initiates its own CREV subsystem.

TABLE 3.3.7.1-1 Corrected the required number of channels per trip system for Functions 3, 4, and 5 from 2 to 1 to match system logic.

Added "above background" for the Function 5, Control Room Air Supply Duct Radiation High, Allowable Value. This is consistent with CTS value.

BAS E S g BACKGROUND Significantly revised the third paragraph to provide additional description of the CREV System instrumentation.

This included a cross reference to the PCIS Function that utilize the same initiation instrumentation.

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EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS),. SUPPLEMENT TO ITS SECTION 3.3 BASES, APPLICABLE SAFETY ANALYSES, LCO, AND APPLICABILITY In "1. Reactor Vessel Water Level Low, Level 3", added Instrument UNIDs as additional information. Added sentence that states the Allowable Value for the Function is the same as RPS Level 3 scram Allowable Value. Also deleted reference to PCIS logic which was included in Background.

In "2. Drywell Pressure High", added Instrument UNIDs, as additional information.

In "3., 4. Reactor Zone and Refueling Floor Exhaust Radiation High", added Instrument UNIDs as additional information. Deleted statement on isolation of primary containment: which is not applicable to CREVs initiation.

Made several replacements and or additions to better describe the init;iation logic.

In "5. Control Room Air Supply Duct Radiation High" added Instrument UNIDs, as additional information. Also deleted "There is only one trip system for this Function" which was not included in the NUREG-1433 original mark-up.

BASES, ACTIONS For ACTIONS B.1 and B.2, revised first paragraph to better describe requirements to maintain CREV System initiation capability.

For ACTIONS C.1 and C.2, revised first paragraph to better describe requirements to maintain CREV System initiation capability.

For ACTIONS D.l, D.2, and D.3, corrected RE-90-8 to RM-90-8 since the discussion is for the radiation monitor, not the radiation element.

ACTIONS E.1 and E.2 were revised t:o provide additional information in the first paragraph detailing that only one CREV subsystem must be operating to meet action E.l other subsystem will st:art automatically upon loss of the if the operating unit, and to state that t: he required actions can be taken independently on each subsystem.

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EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -362 IMPROVED STANDARD TS (ITS). SUPPLEMENT TO ITS SECTION 3.3 BASES, SURVEILLANCE REQUIREMENTS Added "This Surveillance for Functions 3 and 4 shall consist of verifying the High Voltage Power Supply (HVPS) voltage at the Sensor and Convertors (detectors) is within its design limits. A CHANNEL FUNCTIONAL TEST as defined in Section 1.1, "Definitions" shall be performed once per 18 months as part of the CHANNEL CALIBRATION for Functions 3 and 4" to SR 3.3.7.1.2. This note incorporates CTS Table 4.2.A Note 32.

SECTION 3.3.8.2, LOSS OF POWER (LOP) INSTRUMENTATION ACTIONS Added a new REQUIRED ACTION A.1 to "Verify by administrative means that the other two phase-to-phase degraded voltage relays and the loss of voltage relay channel on that shutdown board are OPERABLE" and renumbered the existing REQUIRED ACTION A.1 to A.2. The COMPLETION TIME for the new REQUIRED ACTION is Immediately. This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.

Added a new REQUIRED ACTION B.1 to "Verify by administrative means that the degraded voltage relay channel on that shutdown board is OPERABLE" and renumbered the existing REQUIRED ACTION B.l to B.2. The COMPLETION TIME for the new REQUIRED ACTION is Immediately. This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.

Added a new REQUIRED ACTION C.1 to "Verify by administrative means that the loss of voltage relay channel on that shutdown board is OPERABLE" and renumbered the existing REQUIRED ACTION C.1 to C.2. The COMPLETION TIME for the new REQUIRED ACTION, is Immediately. This change incorporates CTS requirements that were not previously incorporated into the ITS and responds to NRC comment 3.3.8.1-1.

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e EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS {TS) -362 IMPROVED STANDARD TS {ITS) SUPPLEMENT TO ITS SECTION 3. 3 SURVEILLANCE REQUIREMENTS Deleted Note 2 to the SURVEILLANCE REQUIREMENTS which would have allowed a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> delay for entry into associated Conditions and Required Actions when a channel was made inoperable solely to perform required Surveillances. NRC comment 3.3.8.1-2 indicated that use of the Note was a less restrictive change than CTS. After discussion with the system engineer regarding the usefulness of the Note in the performance of associated Surveillance instructions it determined that the Note was of little benefit and should be was deleted.

BASES, BACKGROUND Added a sentence to the last paragraph stating "The channel devices for each shutdown board are listed in Table B 3.3.8.1-1". The new table added to the end of the BASES lists UNIDs by board for the instrumentation of concern.

BASES, ACTIONS Incorporated the addition of new REQUIRED ACTION A.1 and renumbering of existing REQUIRED ACTION A.1 to A.2 into the BASES. This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine if it is out-of-service for maintenance or other reasons, and does not necessitate the perfcrmance of Surveillances which demonstrate its OPERABILITY.

Incorporated the addition of new REQUIRED ACTION B.1 and renumbering of existing REQUIRED ACTION B.l to B.2 into the BASES. This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine if it is out of service for maintenance or other reasons, and does not necessitate the performance of Surveillances which demonstrate its OPERABILITY.

Incorporated the addition of new REQUIRED ACTION C.l and renumbering of existing REQUIRED ACTION C.1 to C.2 into the BASES. This includes describing the administrative means of determining operability of the remaining Loss of Power instrumentation by examining logs or other documentation to determine if it is out of service for maintenance or other reasons, and does not necessitate the performance of Surveillances which demonstrate its OPERABILITY.

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EXECUTIVE

SUMMARY

PROPOSED TECHNICAL SPECIFICATIONS (TS) -3S2 IMPROVED STANDARD TS (ITS)- SUPPLEMENT TO ITS SECTION 3.3 BASES, SURVEILLANCE REQUIREMENTS Deleted description and BASES of Note 2 which was deleted from the Surveillance Requirements.

SECTION 3 3 8 2 ~ REACTOR PROTECT ION SYSTEM (RPS ) ELECTRI C POWER MONITORING SURVEILLANCE REQUIREMENTS Deleted Note to SR 3.3.8.2.1 which stated "Only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for R 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />". This was deleted because the CHANNEL FUNCTIONAL TEST (SR 3.3.8.2.1) and the CHANNEL CALIBRATION (SR 3.3.8.2.2) are both performed at the same 184-day frequency (and thus performed together) and, hence, the note was not applicable to the CHANNEL CALIBRATION.

Based on the above, the note has no effect on when the CHANNEL FUNCTIONAL TEST is performed and should be deleted.

This is in response to NRC comment 3.3.8.2-3.

SURVE ILLANCE REQUIREMENTS U'ASES

~

Deleted reference to Note to SR 3.3.8.2.1 which was deleted, and added "The 184-day Frequency is based on operating experience and the need to calibrate the instrument loop and sensor".

REFERENCES Deleted Reference 2, "NRC Generic Letter 91-09,

'Modification of Surveillance Interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System." This reference was deleted because the suggested relaxation of the Frequency of the CHANNEL FUNCTIONAL TEST is negated by the requirement to perform the CHANNEL CALIBRATION at the same Frequency based on Setpoint Analysis.

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