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| number = ML18039A199
| number = ML18039A199
| issue date = 12/03/1997
| issue date = 12/03/1997
| title = Provides Supplemental Info in Support of TS Change 362 Amend Request Re Section 3.9, Refueling Operation & 3.10, Special Operations, Respectively. NRC Questions on Two Sections Included in RAI Dtd 970917
| title = Provides Supplemental Info in Support of TS Change 362 Amend Request Re Section 3.9, Refueling Operation & 3.10, Special Operations, Respectively. NRC Questions on Two Sections Included in RAI
| author name = Abney T
| author name = Abney T
| author affiliation = TENNESSEE VALLEY AUTHORITY
| author affiliation = TENNESSEE VALLEY AUTHORITY
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9712090173
| document report number = TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9712090173
| title reference date = 09-17-1997
| package number = ML18039A200
| package number = ML18039A200
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 32
| page count = 32
| project =  
| project = TAC:M96431, TAC:M96432, TAC:M96433
| stage = Supplement
| stage = Supplement
}}
}}


=Text=
=Text=
{{#Wiki_filter:Enclosure 1.0 ITS Section 3.9 REFUELING OPERATIONS Enclosure Contents                                       Enclosed'P
{{#Wiki_filter:Enclosure 1.0 ITS Section 3.9 REFUELING OPERATIONS Enclosure Contents Enclosed'P
  .Response to NRC questions                               Yes Summary Description of ITS/ITS BASES Changes.           Yes ITS Revised Pages                                         Yes ITS BASES Revised Pages                                   Yes CTS Mark-up Revised Pages.                             . N/A Justifications for Changes   to CTS (DOCs)
.Response to NRC questions Summary Description of ITS/ITS BASES Changes.
Revised Pages                                             Yes NUREG-1433 BWR/4 STS Mark-up Revised Pages.               Yes NUREG-1433 BWR/4 STS Bases Mark-up Revised Pages.         Yes Justification for Changes to NUREG-1433 (JDs)
ITS Revised Pages ITS BASES Revised Pages CTS Mark-up Revised Pages.
Revised Pages                                             Yes No Significant Hazards Considerations Revised Pages     N/A Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433.                     Yes
Justifications for Changes to CTS (DOCs)
Revised Pages NUREG-1433 BWR/4 STS Mark-up Revised Pages.
NUREG-1433 BWR/4 STS Bases Mark-up Revised Pages.
Justification for Changes to NUREG-1433 (JDs)
Revised Pages No Significant Hazards Considerations Revised Pages Cross-Reference Matrix Correlating Changes Between the
: CTS, ITS, and NUREG-1433.
Yes Yes Yes Yes
. N/A Yes Yes Yes Yes N/A Yes


Response to NRC Questions ITS SECTION 3.9.1 Refueling Equipment Interlocks ITEM 3.9.1-1 CTS 3.10 requires core reactivity limitations in place to ensure that the core reactivity is within the capability of the control rods. ITS 3.9.1 does not retain this limitation.
Response to NRC Questions ITS SECTION 3.9.1 Refueling Equipment Interlocks ITEM 3.9.1-1 CTS 3.10 requires core reactivity limitations in place to ensure that the core reactivity is within the capability of the control rods.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
ITS 3.9.1 does not retain this limitation.
There are no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC A1.
TVA RESPONSE ITEM The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
ITEM 3.9.1-2 CTS 3.10 requires core reactivity limitations in place to prevent criticality during refueling. ITS 3.9.1 does not retain the core reactivity limitations to prevent criticality during refueling.
There are no specific requirements in these introductory statements.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
There are no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC A1.
3.9.1-2 CTS 3.10 requires core reactivity limitations in place to prevent criticality during refueling.
ITS 3.9.1 does not retain the core reactivity limitations to prevent criticality during refueling.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no specific requirements in these introductory statements.
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the


corresponding ITS Bases. Therefore, this is an administrative   change as described by DOC A1.
corresponding ITS Bases.
ITEM 3.9.1-3 CTS   3.10 requires fuel handling requirements in place duri'ng core alterations. ITS 3.9.1 requires the fuel handling interlocks in place only during in-vessel fuel movement.
Therefore, this is an administrative change as described by DOC A1.
TVA RESPONSE The CTS 3.10   section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
ITEM 3.9.1-3 CTS 3.10 requires fuel handling requirements in place duri'ng core alterations.
There.'are .no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC A1.
ITS 3.9.1 requires the fuel handling interlocks in place only during in-vessel fuel movement.
ITEM 3.9.1-4 CTS Surveillance Requirement 4.10 requires periodic testing of instrumentation required for refueling interlocks during Core Alterations. ITS SR 3.9.1 does not retain this requirement.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
TVA RESPONSE The CTS 3.10   section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There.'are
There are no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC Al.
.no specific requirements in these introductory statements.
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC A1.
ITEM 3.9.1-4 CTS Surveillance Requirement 4.10 requires periodic testing of instrumentation required for refueling interlocks during Core Alterations.
ITS SR 3.9.1 does not retain this requirement.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no specific requirements in these introductory statements.
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC Al.


0 ITEM 3.9.1-5 CTS 3.10.A.1 requires that the refueling equipment interlocks be operable except as specified in CTS 3.10.A.6 and 3.10.A.7. ITS 3.9.1 does not retain these exceptions.
0
TVA RESPONSE The changes for CTS 3.10.A.6 and 3.10.A.7 are addressed 1n the justifications for ITS Section 3.10.5. There is no need to retain references to these exceptions in Section 3.9.1 since they are allowed, with changes,   in ITS Section 3.10..
 
ITEM 3.9.1-6 CTS Surveillance Requirement 4.10,A.1 requires functional testing the required refueling equipment interlocks prior to any fuel handling with the head off the vessel. ITS 3.9.1 does not retain this requirement.
ITEM 3.9.1-5 CTS 3.10.A.1 requires that the refueling equipment interlocks be operable except as specified in CTS 3.10.A.6 and 3.10.A.7.
ITS 3.9.1 does not retain these exceptions.
TVA RESPONSE The changes for CTS 3.10.A.6 and 3.10.A.7 are addressed 1n the justifications for ITS Section 3.10.5.
There is no need to retain references to these exceptions in Section 3.9.1 since they are allowed, with changes, in ITS Section 3.10..
ITEM 3.9.1-6 CTS Surveillance Requirement 4.10,A.1 requires functional testing the required refueling equipment interlocks prior to any fuel handling with the head off the vessel.
ITS 3.9.1 does not retain this requirement.
TVA RESPONSE Proposed ITS SR 3.0.1 requires all Surveillance Requirements (SRs) be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operations (LCOs),
TVA RESPONSE Proposed ITS SR 3.0.1 requires all Surveillance Requirements (SRs) be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operations (LCOs),
unless otherwise stated in the SR. This requires that the SR 3.9.1.1 be performed prior to entering the ITS LCO 3.9.1 Applicability. Therefore, since the subject CTS requirement is equivalently in effect under the ITS, the categorization of the change as administrative is appropriate.
unless otherwise stated in the SR.
ITEM 3.9.1-7 CTS Surveillance Requirement 4.10.A.1 requires functionally testing the required refueling equipment interlocks. ITS SR 3.9.1.1 requires performing Channel Functional Tests on the required refueling equipment interlock inputs. Provide discussion that indicates that Functionally Testing equates to Channel Functional Test.
This requires that the SR 3.9.1.1 be performed prior to entering the ITS LCO 3.9.1 Applicability.
TVA RESPONSE Channel Functional Test   in the ITS is defined as the injection of   a simulated or actual signal into the
Therefore, since the subject CTS requirement is equivalently in effect under the ITS, the categorization of the change as administrative is appropriate.
ITEM 3.9.1-7 CTS Surveillance Requirement 4.10.A.1 requires functionally testing the required refueling equipment interlocks.
ITS SR 3.9.1.1 requires performing Channel Functional Tests on the required refueling equipment interlock inputs.
Provide discussion that indicates that Functionally Testing equates to Channel Functional Test.
TVA RESPONSE Channel Functional Test in the ITS is defined as the injection of a simulated or actual signal into the


channel as close to the sensor as practicable to verify operability, including required alarms, interlock, display, trip functions, and channel failure trips. In CTS, a functional test is defined as the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances. We consider the subject ITS Channel Functional Test requirement for the refueling interlocks to envelop the CTS Functional Test for the same equipment and is a better characterization of the type of testing performed for the refueling equipment interlocks .
ITEM channel as close to the sensor as practicable to verify operability, including required alarms, interlock, display, trip functions, and channel failure trips.
J         J ITEM 3.9.1-8 CTS Surveillance Requirements 4.10.A.1 requires functionally testing the required refueling equipment interlocks. ITS SR 3.9.1.1 requires performing a Channel Functional Test on each of the required refueling equipment interlock inputs. Provide discussion that CTS refuel equipment interlocks equates to ITS refuel equipment interlock inputs.
In
TVA RESPONSE TVA considers "refueling equipment interlocks" and "refueling equipment interlocks inputs" as equivalent terms and that no changes in test methods or requirements will result from the change from CTS to ITS.
: CTS, a functional test is defined as the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances.
ITEM 3.9.1-9 CTS 3.10.A.3 requires setting the fuel grapple hoist load switch at < 1000 lbs. ITS 3.9.1 does not retain any of this requirement.
We consider the subject ITS Channel Functional Test requirement for the refueling interlocks to envelop the CTS Functional Test for the same equipment and is a better characterization of the type of testing performed for the refueling equipment interlocks.
TVA RESPONSE This requirement has been relocated to the Technical Requirements Manual (TRM). The TRH is controlled under the 10 CFR 50.59 process. DOC LA1 has been revised appropriately.
J J
ITEM 3.9.1-10 CTS 3.10.A.4 requires that if the frame-mounted auxiliary hoist, the monorail-mounted hoist, or the service platform hoist is to be used for handling fuel with the head off the reactor vessel, the load limit
3.9.1-8 CTS Surveillance Requirements 4.10.A.1 requires functionally testing the required refueling equipment interlocks.
ITS SR 3.9.1.1 requires performing a
Channel Functional Test on each of the required refueling equipment interlock inputs.
Provide discussion that CTS refuel equipment interlocks equates to ITS refuel equipment interlock inputs.
TVA RESPONSE TVA considers "refueling equipment interlocks" and "refueling equipment interlocks inputs" as equivalent terms and that no changes in test methods or requirements will result from the change from CTS to ITS.
ITEM 3.9.1-9 CTS 3.10.A.3 requires setting the fuel grapple hoist load switch at
< 1000 lbs.
ITS 3.9.1 does not retain any of this requirement.
TVA RESPONSE This requirement has been relocated to the Technical Requirements Manual (TRM).
The TRH is controlled under the 10 CFR 50.59 process.
DOC LA1 has been revised appropriately.
ITEM 3.9.1-10 CTS 3.10.A.4 requires that if the frame-mounted auxiliary hoist, the monorail-mounted hoist, or the service platform hoist is to be used for handling fuel with the head off the reactor vessel, the load limit


switch on the hoist to be used shall be set at     < 400 lbs. ITS 3.9.1 does not retain any of this requirement.
switch on the hoist to be used shall be set at
< 400 lbs.
ITS 3.9.1 does not retain any of this requirement.
TVA RESPONSE E.
TVA RESPONSE E.
This requirement has been relocated to the     TRM which is controlled under the 10 CFR 50.59 process.       DOC LA1 has been     appropriately revised.
This requirement has been relocated to the TRM which is controlled under the 10 CFR 50.59 process.
ITEM 3.9.1-11 CTS     Surveillance Requirement 4.10.A.1 required testing following any repair work associated with the interlocks. ITS 3.9.1 does not retain the requirement to test following work.
DOC LA1 has been appropriately revised.
TVA RESPONSE Anytime the     operability of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrat:e operability of the system or component.
ITEM 3.9.1-11 CTS Surveillance Requirement 4.10.A.1 required testing following any repair work associated with the interlocks.
ITS 3.9.1 does not retain the requirement to test following work.
TVA RESPONSE Anytime the operability of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrat:e operability of the system or component.
Per ITS SR 3.0.1, SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Per ITS SR 3.0.1, SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance shall be a failure to meet the LCO. ITS Bases for SR 3.0.1 states t:hat "upon completion of maintenance appropriate post maintenance testing is required to declare equipment operable."
Failure to meet a Surveillance shall be a failure to meet the LCO.
ITS Bases for SR 3.0.1 states t:hat "upon completion of maintenance appropriate post maintenance testing is required to declare equipment operable."
Therefore, this CTS provision need not be specifically included in the ITS.
Therefore, this CTS provision need not be specifically included in the ITS.
ITEM 3.9.1-12 CTS   Surveillance Requirement 4.10.A.1 requires weekly testing of the interlocks. ITS SR 3.9.1.1 requires a       7 day   testing frequency. Weekly can mean performance anytime during a week, while     7 days means every 7 days.
ITEM 3.9.1-12 CTS Surveillance Requirement 4.10.A.1 requires weekly testing of the interlocks.
TVA RESPONSE CTS   Table 1.1 specifies that the notation "Weekly" is equal t:o "At least once per 7 days". ITS SR 3.0.2 states that: "The specified Frequency for each SR is met if the Surveillance is performed within -1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
ITS SR 3.9.1.1 requires a
7 day testing frequency.
Weekly can mean performance anytime during a week, while 7 days means every 7 days.
TVA RESPONSE CTS Table 1.1 specifies that the notation "Weekly" is equal t:o "At least once per 7 days".
ITS SR 3.0.2 states that: "The specified Frequency for each SR is met if the Surveillance is performed within -1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a
specified condition of the Frequency is met.
Therefore, these CTS and ITS surveillance frequencies
Therefore, these CTS and ITS surveillance frequencies


are considered equivalent and the associated   change is administrative.
are considered equivalent and the associated change is administrative.
ITEM 3.9.1-13 STS SR 3.9.l.l.c requires performing a CHANNEL FUNCTIONAL TEST on each   of the required refueling equipment interlock inputs: Refuel platform [fuel grapple] fuel loaded. ITS SR 3.9.1.1.c requires performing CHANNEL FUNCTIONAL TESTS on each of the required refueling equipment interlock inputs:
ITEM 3.9.1-13 STS SR 3.9.l.l.c requires performing a
Refueling platform main hoist, fuel loaded. Provide discussion for the deviation from the STS in changing the CTS [fuel grapple] to the ITS main hoist.
CHANNEL FUNCTIONAL TEST on each of the required refueling equipment interlock inputs: Refuel platform [fuel grapple] fuel loaded.
TVA RESPONSE It was decided, in this instance, to retain the nomenclature specified in the CTS instead of adopting the suggested wording of NUREG-1433 for the subject ITS provision. This is a bracketed term in NUREG-1433.
ITS SR 3.9.1.1.c requires performing CHANNEL FUNCTIONAL TESTS on each of the required refueling equipment interlock inputs:
Refueling platform main hoist, fuel loaded.
Provide discussion for the deviation from the STS in changing the CTS [fuel grapple] to the ITS main hoist.
TVA RESPONSE It was decided, in this instance, to retain the nomenclature specified in the CTS instead of adopting the suggested wording of NUREG-1433 for the subject ITS provision.
This is a bracketed term in NUREG-1433.
Use of "main hoist" instead of [fuel grapple] retains the customary terminology presently in use at BFN and, thus, is an aid to plant personnel.
Use of "main hoist" instead of [fuel grapple] retains the customary terminology presently in use at BFN and, thus, is an aid to plant personnel.


Response to NRC Questions ITS SECTION 3.9.2 REFUEL POSITION ONE-ROD-OUT INTERLOCK ITEM 3.9.2-1 CTS   3.10 requires core reactivity limitations in place to .ensure that the core reactivity is within the capability of the control rods. ITS 3.9.2 does not retain the core reactivity limitations for control rod capability.
Response to NRC Questions ITS SECTION 3.9.2 REFUEL POSITION ONE-ROD-OUT INTERLOCK ITEM 3.9.2-1 CTS 3.10 requires core reactivity limitations in place to.ensure that the core reactivity is within the capability of the control rods.
TVA RESPONSE The CTS 3.10   section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
ITS 3.9.2 does not retain the core reactivity limitations for control rod capability.
There are no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC Al.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
ITEM 3.9.2-2 CTS   3.10 requires core reactivity limitations in place to prevent criticality during refueling. ITS 3.9.2 does not retain the core reactivity limitations to prevent criticality during refueling.
There are no specific requirements in these introductory statements.
TVA RESPONSE The CTS 3.10   section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
There are no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is,
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC Al.
ITEM 3.9.2-2 CTS 3.10 requires core reactivity limitations in place to prevent criticality during refueling.
ITS 3.9.2 does not retain the core reactivity limitations to prevent criticality during refueling.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no specific requirements in these introductory statements.
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC Al.
ITEM 3.9.2-3 CTS 3.10 requires fuel handling requirements in place during core alterations.
ITS 3.9.2 requires the fuel handling interlocks in place only during in-vessel fuel movement.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no specific requirements in these introductory statements.
The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC Al.
ITEM 3.9.2-4 CTS Surveillance Requirement 4.10 requires periodic testing of instrumentation required for refueling interlocks during Core Alterations.
ITS SR 3.9.2 does not retain this requirement.
TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no specific requirements in these introductory statements.
The LCOs and SRs are specified under the individual CTS.3.10/4.10 Specifications
: sections, which are addressed on an individual basis in the ITS submittal.
Similar wording to the "Applicability and Objectives" provisions is,
: however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.
Therefore, this is an administrative change as described by DOC Al.


however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC Al.
W
ITEM 3.9.2-3 CTS  3.10 requires fuel handling requirements in place during core alterations. ITS 3.9.2 requires the fuel handling interlocks in place only during in-vessel fuel movement.
TVA RESPONSE The CTS 3.10  section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no  specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC Al.
ITEM 3.9.2-4 CTS Surveillance Requirement 4.10 requires periodic testing of instrumentation required for refueling interlocks during Core Alterations. ITS SR 3.9.2 does not retain this requirement.
TVA RESPONSE The CTS 3.10  section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."
There are no specific requirements in these introductory statements. The LCOs and SRs are specified under the individual CTS .3.10/4.10 Specifications sections, which are addressed on an individual basis in the ITS submittal. Similar wording to the "Applicability and Objectives" provisions is, however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITY sections of the corresponding ITS Bases. Therefore, this is an administrative change as described by DOC Al.


W ITEM 3.9.2-5 CTS 3.10.A.l requires that the refueling equipment interlocks be operable except as specified in CTS 3.10.A.6 and 3.10.A.7. ITS 3.9.2 does not retain these exceptions.
ITEM 3.9.2-5 CTS 3.10.A.l requires that the refueling equipment interlocks be operable except as specified in CTS 3.10.A.6 and 3.10.A.7.
TVA RESPONSE The Justification for Changes for CTS 3.10.A.6 and 3.10.A.7 are provided in the DOCs for ITS 3.10.5 and 3.10.6. There is no need to retain references to these exceptions in Section 3.9.2 since they are allowed, with changes, in the referenced ITS sections.
ITS 3.9.2 does not retain these exceptions.
ITEM 3.9.2-6 CTS   Surveillance Requirement 4.10,A.1 requires functional testing the required refueling equipment interlocks prior to any fuel handling with the head off the vessel. ITS SR 3.9.2.2 NOTE allows 1 hour after any control rod withdrawal before requiring a channel functional test. Provide additional discussion and justification for this less restrictive   change.
TVA RESPONSE The Justification for Changes for CTS 3.10.A.6 and 3.10.A.7 are provided in the DOCs for ITS 3.10.5 and 3.10.6.
TVA RESPONSE To   perform a test of the one-rod-out interlock, a control rod must be withdrawn from its full-in position and a second rod attempted to be withdrawn. Since this requires entering the applicable condition to perform the test, ITS SR 3.9.2.2 is modified by the note which allows deferring the performance of the channel functional test until one hour after any rod is withdrawn. This change is acceptable because of the demonstrated reliability,of this interlock, procedural controls on control rod withdrawals, and visual indication in the control room of rod position. Refer to DOC Ll for added discussion.
There is no need to retain references to these exceptions in Section 3.9.2 since they are allowed, with changes, in the referenced ITS sections.
ITEM 3.9.2-6 CTS Surveillance Requirement 4.10,A.1 requires functional testing the required refueling equipment interlocks prior to any fuel handling with the head off the vessel.
ITS SR 3.9.2.2 NOTE allows 1 hour after any control rod withdrawal before requiring a channel functional test.
Provide additional discussion and justification for this less restrictive change.
TVA RESPONSE To perform a test of the one-rod-out interlock, a
control rod must be withdrawn from its full-in position and a second rod attempted to be withdrawn.
Since this requires entering the applicable condition to perform the test, ITS SR 3.9.2.2 is modified by the note which allows deferring the performance of the channel functional test until one hour after any rod is withdrawn.
This change is acceptable because of the demonstrated reliability,of this interlock, procedural controls on control rod withdrawals, and visual indication in the control room of rod position.
Refer to DOC Ll for added discussion.


ITEM 3.9.2-7 CTS   3.10.A.1 is applicable during Core Alterations.
ITEM 3.9.2-7 CTS 3.10.A.1 is applicable during Core Alterations.
ITS 3.9.2 is applicable during Mode 5 with the reactor mode switch in the refuel position and any control rod withdrawn. Provide discussion for this less restrictive   change.
ITS 3.9.2 is applicable during Mode 5 with the reactor mode switch in the refuel position and any control rod withdrawn.
TVA RESPONSE CTS   3.10.A.1 governs all of the refueling interlocks whereas   ITS 3.9.2 is only associated with the one-rod-withdrawn interlock. Since ITS 3.9.2 has a limited and well defined scope in accordance with NUREG-1433, a less stringent appl'icability can be applied. This new ITS applicability will result in the one-rod-out interlock being operable in all cases where required to prevent prompt reactivity it may be excursions. We have adopted the wording as specified in NUREG-1433.
Provide discussion for this less restrictive change.
TVA RESPONSE CTS 3.10.A.1 governs all of the refueling interlocks whereas ITS 3.9.2 is only associated with the one-rod-withdrawn interlock.
Since ITS 3.9.2 has a limited and well defined scope in accordance with NUREG-1433, a
less stringent appl'icability can be applied.
This new ITS applicability will result in the one-rod-out interlock being operable in all cases where it may be required to prevent prompt reactivity excursions.
We have adopted the wording as specified in NUREG-1433.
Refer to DOC L2 for added discussion.
Refer to DOC L2 for added discussion.
ITEM 3. 9. 2-8 CTS   Surveillance Requirement 4.10.A.1 requires testing following any repair work associated with the interlocks. ITS 3.9.2 does not retain the requirement to test following work.
ITEM 3. 9. 2-8 CTS Surveillance Requirement 4.10.A.1 requires testing following any repair work associated with the interlocks.
TVA RESPONSE Anytime the   operability of a system or component has been affected by repai'r, maintenance,   or replacement of a component, post maintenance testing   is required to demonstrate operability of the system or component.
ITS 3.9.2 does not retain the requirement to test following work.
TVA RESPONSE Anytime the operability of a system or component has been affected by repai'r, maintenance, or replacement of a component, post maintenance testing is required to demonstrate operability of the system or component.
Per ITS SR 3.0.1, SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Per ITS SR 3.0.1, SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance shall be failure to meet the LCO. ITS Bases for SR 3.0.1 states that "upon completion of maintenance, appropriate post maintenance testing is required to declare equipment operable."
Failure to meet a Surveillance shall be failure to meet the LCO.
ITS Bases for SR 3.0.1 states that "upon completion of maintenance, appropriate post maintenance testing is required to declare equipment operable."
Therefore, this CTS provision need not be specifically included in the ITS.
Therefore, this CTS provision need not be specifically included in the ITS.
10
10


ITEM 3. 9.2-9 CTS   Surveillance Requirement 4.10.A.1 requires functionally testing the required refueling equipment interlocks. ITS SR 3.9.2.1 requires performing Channel Functional Tests on the required refueling equipment interlock inputs. Provide discussion that indicates that Functionally Testing equates to Channel Functional Test.
ITEM 3. 9.2-9 CTS Surveillance Requirement 4.10.A.1 requires functionally testing the required refueling equipment interlocks.
TVA RESPONSE Channel Functional Test   in the ITS is defined as the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability, including required alarms, interlock, display, trip functions, and channel failure trips. In CTS, a functional test is defined as the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances. We consider the subject ITS Channel Functional Test requirement for the refueling interlocks to envelop the CTS Functional Test for the same   equipment.
ITS SR 3.9.2.1 requires performing Channel Functional Tests on the required refueling equipment interlock inputs.
ITEM 3.9.2-10 CTS   Surveillance Requirements 4.10.A.1 requires functionally testing the required refueling equipment interlocks. ITS SR 3.9.2.1 requires performing a Channel Functional Test on each of the required refueling equipment interlock inputs. Provide discussion that CTS refuel equipment interlocks equates to ITS refuel equipment interlock inputs.
Provide discussion that indicates that Functionally Testing equates to Channel Functional Test.
TVA RESPONSE TVA   considers "refueling equipment interlocks" and "refueling equipment interlocks inputs" equivalent terms and that no changes in test methods will result from the change from CTS to ITS.
TVA RESPONSE Channel Functional Test in the ITS is defined as the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability, including required alarms, interlock, display, trip functions, and channel failure trips.
ITEM 3.9.2-11 CTS   Surveillance Requirement 4.10.A.1 requires weekly testing of the interlocks. ITS SR 3.9.2.1 requires     a 7 day testing frequency. Weekly can mean performance anytime during     a week. While 7 days means every 7 days ~
In
: CTS, a functional test is defined as the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances.
We consider the subject ITS Channel Functional Test requirement for the refueling interlocks to envelop the CTS Functional Test for the same equipment.
ITEM 3.9.2-10 CTS Surveillance Requirements 4.10.A.1 requires functionally testing the required refueling equipment interlocks.
ITS SR 3.9.2.1 requires performing a
Channel Functional Test on each of the required refueling equipment interlock inputs.
Provide discussion that CTS refuel equipment interlocks equates to ITS refuel equipment interlock inputs.
TVA RESPONSE TVA considers "refueling equipment interlocks" and "refueling equipment interlocks inputs" equivalent terms and that no changes in test methods will result from the change from CTS to ITS.
ITEM 3.9.2-11 CTS Surveillance Requirement 4.10.A.1 requires weekly testing of the interlocks.
ITS SR 3.9.2.1 requires a
7 day testing frequency.
Weekly can mean performance anytime during a week.
While 7 days means every 7
days
~
11
11


0 TVA RESPONSE CTS Table 1.1 specifies that the notation "Weekly" is equal to "At least once per 7 days". ITS SR 3.0.2 states that "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in th'e Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met."
0
 
TVA RESPONSE CTS Table 1.1 specifies that the notation "Weekly" is equal to "At least once per 7 days".
ITS SR 3.0.2 states that "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in th'e Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met."
Therefore, these CTS and ITS surveillance frequencies are considered equivalent and the associated change is administrative.
Therefore, these CTS and ITS surveillance frequencies are considered equivalent and the associated change is administrative.
12
12


Response to NRC Questions ITS SECTION 3.9.4 CONTROL ROD POSITION INDICATION ITEM 3.9.4-1 STS 3.9.4 requires the control rod full-in position indication channel for each control rod shall be operable. ITS 3.9.4 requires the control rod full-in position indication for each control rod shall be operable. Provide additional discussion for dropping the word "channel".
Response to NRC Questions ITS SECTION 3.9.4 CONTROL ROD POSITION INDICATION ITEM 3.9.4-1 STS 3.9.4 requires the control rod full-in position indication channel for each control rod shall be operable.
TVA RESPONSE At BFN, the "channel" designation is normally associated with multiple circuits used to evaluate plant'ariables which produce discrete outputs used in logic. In the case of the control rod full-in position indication, there is only one circuit per individual control rod. Therefore, the use of the term "channel" is not appropriate. The use of "Position Indication" is more direct and better defines the ITS requirements.
ITS 3.9.4 requires the control rod full-in position indication for each control rod shall be operable.
Provide additional discussion for dropping the word "channel".
TVA RESPONSE At BFN, the "channel" designation is normally associated with multiple circuits used to evaluate plant'ariables which produce discrete outputs used in logic.
In the case of the control rod full-in position indication, there is only one circuit per individual control rod.
Therefore, the use of the term "channel" is not appropriate.
The use of "Position Indication" is more direct and better defines the ITS requirements.
13
13


Response to NRC Questions ITS SECTION 3.9.6 REACTOR PRESSURE VESSEL (RPV) WATER LEVEL ITEM   3.9.6-1 STS 3.9.6 is titled Reactor Pressure Vessel Water Level Irradiated Fuel. ITS 3.9.6 is Titled Reactor Pressure Vessel Water Level. Provide discussion for changing the title of the LCO.
Response to NRC Questions ITS SECTION 3.9.6 REACTOR PRESSURE VESSEL (RPV) WATER LEVEL ITEM 3.9.6-1 STS 3.9.6 is titled Reactor Pressure Vessel Water Level
TVA RESPONSE As discussed in Justification P14, BFN has chosen     not to adopt NUREG-1433 Specification 3.9.7 "Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods". This is a bracketed section.       In doing so, the requirements for maintaining water level during movement of control rods and new fuel were combined and will be   maintained exclusively in ITS 3.9.6.
. Irradiated Fuel.
ITS 3.9.6 is Titled Reactor Pressure Vessel Water Level.
Provide discussion for changing the title of the LCO.
TVA RESPONSE As discussed in Justification
: P14, BFN has chosen not to adopt NUREG-1433 Specification 3.9.7 "Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods".
This is a bracketed section.
In doing so, the requirements for maintaining water level during movement of control rods and new fuel were combined and will be maintained exclusively in ITS 3.9.6.
Therefore, the title was revised since ITS 3.9.6 provides requirements for maintaining reactor water level for other component (control rods) handling in addition to irradiated fuel.
Therefore, the title was revised since ITS 3.9.6 provides requirements for maintaining reactor water level for other component (control rods) handling in addition to irradiated fuel.
ITEM   3.9.6-2 STS SR 3.9.6.1   verifies the Reactor Pressure Vessel (RPV) water level   is > 23 ft. above the top of the RPV flange. ITS 3.9.6.1 verifies the Reactor Pressure Vessel (RPV) water level is > 23 ft. above the top of the irradiated fuel assemblies seated within the RPV.
ITEM 3.9.6-2 STS SR 3.9.6.1 verifies the Reactor Pressure Vessel (RPV) water level is
> 23 ft. above the top of the RPV flange.
ITS 3.9.6.1 verifies the Reactor Pressure Vessel (RPV) water level is
> 23 ft. above the top of the irradiated fuel assemblies seated within the RPV.
Provide discussion for the deviation of changing the reference from which the water height is measured.
Provide discussion for the deviation of changing the reference from which the water height is measured.
TVA RESPONSE The reference point, "above the top of the RPV flange",
TVA RESPONSE The reference point, "above the top of the RPV flange",
has been   incorporated to ITS 3.9.6 and its associated Bases in   this submittal. The reference level differential of   "> 23 feet" has been changed to "> 22 feet" to account for BFN physical'dimensions of the fuel pool and reactor well. The revised ITS, Bases, and Justifications are provided in this submittal.
has been incorporated to ITS 3.9.6 and its associated Bases in this submittal.
The reference level differential of "> 23 feet" has been changed to "> 22 feet" to account for BFN physical'dimensions of the fuel pool and reactor well.
The revised ITS, Bases, and Justifications are provided in this submittal.
14
14


Response to NRC Questions ITS SECTION 3.9.7 RESIDUAL HEAT REMOVAL (RHR) - HIGH WATER I EVEI ITEM 3. 9. 7-1
Response to NRC Questions ITS SECTION 3.9.7 RESIDUALHEATREMOVAL(RHR) - HIGHWATER I EVEI ITEM 3. 9. 7-1
    'STS   3.9.8 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water level > 23 ft. above the top of the RPV flange. ITS 3.9.7 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water level > 22 ft. above the top of the RPV flange.
'STS 3.9.8 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water level
Provide discussion for the deviation from the STS water level of > 23 ft. to > 22 ft.
> 23 ft. above the top of the RPV flange.
TVA RESPONSE The   water level Applicability was modified from > 23 feet to > 22 feet above the top of the RPV flange due to the physical dimensions of the fuel pool and reactor well. At BFN, the reactor vessel flange is at elevation 640 feet and the normal water level during refueling operations is maintained at elevation 663 feet. The low level alarm is set at 662.67 feet.
ITS 3.9.7 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water level
Therefore, the physical dimensions of the reactor well precludes the use of > 23 feet as the setpoint for this specification. A reduction in the water level is allowed in accordance with STS 3.9.6 Bases, Applicable Safety Analysis.
> 22 ft. above the top of the RPV flange.
Provide discussion for the deviation from the STS water level of > 23 ft. to
> 22 ft.
TVA RESPONSE The water level Applicability was modified from > 23 feet to
> 22 feet above the top of the RPV flange due to the physical dimensions of the fuel pool and reactor well.
At BFN, the reactor vessel flange is at elevation 640 feet and the normal water level during refueling operations is maintained at elevation 663 feet.
The low level alarm is set at 662.67 feet.
Therefore, the physical dimensions of the reactor well precludes the use of > 23 feet as the setpoint for this specification.
A reduction in the water level is allowed in accordance with STS 3.9.6 Bases, Applicable Safety Analysis.
15
15


Response to NRC Questions ITS SECTION 3.9.8 RESIDUAL HEAT REMOVAL(RHR) - LOW WATER LEVEL ITEM 3. 9. 8-1 STS 3.9.9 Applicability is for   MODE 5 with''rradiated fuel in   the Reactor .Pr'essure Vessel (RPV) and Che water level < 23 ft. above the top of the   RPV flange. ITS 3.9.8 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water
Response to NRC Questions ITS SECTION 3.9.8 RESIDUALHEATREMOVAL(RHR) - LOWWATER LEVEL ITEM 3. 9. 8-1 STS 3.9.9 Applicability is for MODE 5 with''rradiated fuel in the Reactor.Pr'essure Vessel (RPV) and Che water level
~ - -  level < 22 ft. above the top of...the RPV flange.
< 23 ft. above the top of the RPV flange.
ITS 3.9.8 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water
~
- level
< 22 ft. above the top of...the RPV flange.
Provide discussion for the~'deviation from the STS water
Provide discussion for the~'deviation from the STS water
      .level of < 23 ft. to < 22 ft.
.level of < 23 ft. to < 22 ft.
TVA RESPONSE The water level Applicability was changed from < 23 feet to < 22 feet above the top of the RPV flange due to the physical dimensions of the fuel pool and reactor well. At BFN,-the reactor vessel flange is at elevation 640 feet and the normal water level during refueling operations is maintained at elevation 663 feet. The low level alarm is set at 662.67 feet.
TVA RESPONSE The water level Applicability was changed from < 23 feet to < 22 feet above the top of the RPV flange due to the physical dimensions of the fuel pool and reactor well.
Therefore, the physical dimensions of the reactor well precludes the use of < 23 feet as the entry point for this specification. This change is also needed to provide consistency with the modified water level in ITS 3.9.7. A reduction in water level is allowed in accordance with STS 3.9.6 Bases, Applicable Safety Analysis.
At BFN,-the reactor vessel flange is at elevation 640 feet and the normal water level during refueling operations is maintained at elevation 663 feet.
The low level alarm is set at 662.67 feet.
Therefore, the physical dimensions of the reactor well precludes the use of < 23 feet as the entry point for this specification.
This change is also needed to provide consistency with the modified water level in ITS 3.9.7.
A reduction in water level is allowed in accordance with STS 3.9.6 Bases, Applicable Safety Analysis.
16
16


==SUMMARY==
==SUMMARY==
DESCRIPTION of ITS/BASES CHANGES ITS SECTION 3.9 TVA is submitting a proposed supplement to TS-362 for ITS
DESCRIPTION of ITS/BASES CHANGES ITS SECTION 3.9 TVA is submitting a proposed supplement to TS-362 for ITS
. Section 3.9,'REFUELING 'OPERATIONS. This supplement makes changes associated with NRC comments on Section 3.9
. Section 3.9,'REFUELING 'OPERATIONS.
This supplement makes changes associated with NRC comments on Section 3.9
(
(


==Reference:==
==Reference:==
NRC Request for Additional Information Regarding Improved Standard Technical Specifications, dated September 17, 1997, TAC NOS. M96431, M96432, M96433), incorporates minor changes resulting from an internal TVA review, and incorporates an Owner's Group Technical Specification Task Force (TSTF) item approved by NRC subsequent to the original submittal of TS-362. A synopsis of the,KTS and ITS BASES changes is provided below.
NRC Request for Additional Information Regarding Improved Standard Technical Specifications, dated September 17,
LCO   3.9.6.1   SR 3.9.6 And Associated BASES In response to     an NRC comment, changed referenced water level from 23 feet above the top of irradiated fuel assemblies seated within the Reactor Pressure Vessel (RPV) to 22 feet above the RPV flange. Also, revised APPLICABLE SAFETY ANALYSIS BASES to support the referenced level change. These changes are consistent with NUREG-1433.
: 1997, TAC NOS. M96431,
LCO   3.9.7   LCO   3.9.8 and Associated BASES NOTE 1   is modified to incorporate an approved Owner's Group Technical Specification Task Force item, TSTF-153. This change clarifies the text of the note to be consistent with the equivalent sections from the other reactor vendor ITS NUREGs. The associated BASES are likewise modified.
: M96432, M96433), incorporates minor changes resulting from an internal TVA review, and incorporates an Owner's Group Technical Specification Task Force (TSTF) item approved by NRC subsequent to the original submittal of TS-362.
SR 3.9.2   BASES In response to a TVA internal review, corrected typographical error in surveillance requirement (SR) BASES for SR 3.9.2.2.
A synopsis of the,KTS and ITS BASES changes is provided below.
ACTIONS 3.9.7 A.1 BASES and ACTIONS 3.9.8 A.l BASES In response to a TVA internal review, Action A1 Bases for the subject sections have been revised to delete the wording "operating with the regenerative heat exchanger bypassed",
LCO 3.9.6.1 SR 3.9.6 And Associated BASES In response to an NRC comment, changed referenced water level from 23 feet above the top of irradiated fuel assemblies seated within the Reactor Pressure Vessel (RPV) to 22 feet above the RPV flange.
Also, revised APPLICABLE SAFETY ANALYSIS BASES to support the referenced level change.
These changes are consistent with NUREG-1433.
LCO 3.9.7 LCO 3.9.8 and Associated BASES NOTE 1 is modified to incorporate an approved Owner's Group Technical Specification Task Force item, TSTF-153.
This change clarifies the text of the note to be consistent with the equivalent sections from the other reactor vendor ITS NUREGs.
The associated BASES are likewise modified.
SR 3.9.2 BASES In response to a TVA internal review, corrected typographical error in surveillance requirement (SR)
BASES for SR 3.9.2.2.
ACTIONS 3.9.7 A.1 BASES and ACTIONS 3.9.8 A.l BASES In response to a
TVA internal review, Action A1 Bases for the subject sections have been revised to delete the wording "operating with the regenerative heat exchanger bypassed",
due to physical design of the reactor water cleanup system.
due to physical design of the reactor water cleanup system.
The regenerative heat exchangers can not be bypassed.
The regenerative heat exchangers can not be bypassed.


ACTIONS     3.9.7 C.1 6 C.2 BASES and ACTIONS 3.9.8 C.1 E C.2 BASES In response to a TVA internal review, Action C1 and C2 Bases have been revised to include the wording "This alternative method may utilize forced or natural circulation". , This
ACTIONS 3.9.7 C.1 6 C.2 BASES and ACTIONS 3.9.8 C.1 E C.2 BASES In response to a TVA internal review, Action C1 and C2 Bases have been revised to include the wording "This alternative
, method may utilize forced or natural circulation".
, This
"'hange provides a clar'ification of methods for establishin'g an alternate means of coolant circulation.
"'hange provides a clar'ification of methods for establishin'g an alternate means of coolant circulation.
Execsu39.doc}}
Execsu39.doc}}

Latest revision as of 11:24, 6 January 2025

Provides Supplemental Info in Support of TS Change 362 Amend Request Re Section 3.9, Refueling Operation & 3.10, Special Operations, Respectively. NRC Questions on Two Sections Included in RAI
ML18039A199
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Issue date: 12/03/1997
From: Abney T
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ML18039A200 List:
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Text

Enclosure 1.0 ITS Section 3.9 REFUELING OPERATIONS Enclosure Contents Enclosed'P

.Response to NRC questions Summary Description of ITS/ITS BASES Changes.

ITS Revised Pages ITS BASES Revised Pages CTS Mark-up Revised Pages.

Justifications for Changes to CTS (DOCs)

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

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

Justification for Changes to NUREG-1433 (JDs)

Revised Pages No Significant Hazards Considerations Revised Pages Cross-Reference Matrix Correlating Changes Between the

CTS, ITS, and NUREG-1433.

Yes Yes Yes Yes

. N/A Yes Yes Yes Yes N/A Yes

Response to NRC Questions ITS SECTION 3.9.1 Refueling Equipment Interlocks ITEM 3.9.1-1 CTS 3.10 requires core reactivity limitations in place to ensure that the core reactivity is within the capability of the control rods.

ITS 3.9.1 does not retain this limitation.

TVA RESPONSE ITEM The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC A1.

3.9.1-2 CTS 3.10 requires core reactivity limitations in place to prevent criticality during refueling.

ITS 3.9.1 does not retain the core reactivity limitations to prevent criticality during refueling.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the

corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC A1.

ITEM 3.9.1-3 CTS 3.10 requires fuel handling requirements in place duri'ng core alterations.

ITS 3.9.1 requires the fuel handling interlocks in place only during in-vessel fuel movement.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There.'are

.no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC A1.

ITEM 3.9.1-4 CTS Surveillance Requirement 4.10 requires periodic testing of instrumentation required for refueling interlocks during Core Alterations.

ITS SR 3.9.1 does not retain this requirement.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC Al.

0

ITEM 3.9.1-5 CTS 3.10.A.1 requires that the refueling equipment interlocks be operable except as specified in CTS 3.10.A.6 and 3.10.A.7.

ITS 3.9.1 does not retain these exceptions.

TVA RESPONSE The changes for CTS 3.10.A.6 and 3.10.A.7 are addressed 1n the justifications for ITS Section 3.10.5.

There is no need to retain references to these exceptions in Section 3.9.1 since they are allowed, with changes, in ITS Section 3.10..

ITEM 3.9.1-6 CTS Surveillance Requirement 4.10,A.1 requires functional testing the required refueling equipment interlocks prior to any fuel handling with the head off the vessel.

ITS 3.9.1 does not retain this requirement.

TVA RESPONSE Proposed ITS SR 3.0.1 requires all Surveillance Requirements (SRs) be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operations (LCOs),

unless otherwise stated in the SR.

This requires that the SR 3.9.1.1 be performed prior to entering the ITS LCO 3.9.1 Applicability.

Therefore, since the subject CTS requirement is equivalently in effect under the ITS, the categorization of the change as administrative is appropriate.

ITEM 3.9.1-7 CTS Surveillance Requirement 4.10.A.1 requires functionally testing the required refueling equipment interlocks.

ITS SR 3.9.1.1 requires performing Channel Functional Tests on the required refueling equipment interlock inputs.

Provide discussion that indicates that Functionally Testing equates to Channel Functional Test.

TVA RESPONSE Channel Functional Test in the ITS is defined as the injection of a simulated or actual signal into the

ITEM channel as close to the sensor as practicable to verify operability, including required alarms, interlock, display, trip functions, and channel failure trips.

In

CTS, a functional test is defined as the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances.

We consider the subject ITS Channel Functional Test requirement for the refueling interlocks to envelop the CTS Functional Test for the same equipment and is a better characterization of the type of testing performed for the refueling equipment interlocks.

J J

3.9.1-8 CTS Surveillance Requirements 4.10.A.1 requires functionally testing the required refueling equipment interlocks.

ITS SR 3.9.1.1 requires performing a

Channel Functional Test on each of the required refueling equipment interlock inputs.

Provide discussion that CTS refuel equipment interlocks equates to ITS refuel equipment interlock inputs.

TVA RESPONSE TVA considers "refueling equipment interlocks" and "refueling equipment interlocks inputs" as equivalent terms and that no changes in test methods or requirements will result from the change from CTS to ITS.

ITEM 3.9.1-9 CTS 3.10.A.3 requires setting the fuel grapple hoist load switch at

< 1000 lbs.

ITS 3.9.1 does not retain any of this requirement.

TVA RESPONSE This requirement has been relocated to the Technical Requirements Manual (TRM).

The TRH is controlled under the 10 CFR 50.59 process.

DOC LA1 has been revised appropriately.

ITEM 3.9.1-10 CTS 3.10.A.4 requires that if the frame-mounted auxiliary hoist, the monorail-mounted hoist, or the service platform hoist is to be used for handling fuel with the head off the reactor vessel, the load limit

switch on the hoist to be used shall be set at

< 400 lbs.

ITS 3.9.1 does not retain any of this requirement.

TVA RESPONSE E.

This requirement has been relocated to the TRM which is controlled under the 10 CFR 50.59 process.

DOC LA1 has been appropriately revised.

ITEM 3.9.1-11 CTS Surveillance Requirement 4.10.A.1 required testing following any repair work associated with the interlocks.

ITS 3.9.1 does not retain the requirement to test following work.

TVA RESPONSE Anytime the operability of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrat:e operability of the system or component.

Per ITS SR 3.0.1, SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance shall be a failure to meet the LCO.

ITS Bases for SR 3.0.1 states t:hat "upon completion of maintenance appropriate post maintenance testing is required to declare equipment operable."

Therefore, this CTS provision need not be specifically included in the ITS.

ITEM 3.9.1-12 CTS Surveillance Requirement 4.10.A.1 requires weekly testing of the interlocks.

ITS SR 3.9.1.1 requires a

7 day testing frequency.

Weekly can mean performance anytime during a week, while 7 days means every 7 days.

TVA RESPONSE CTS Table 1.1 specifies that the notation "Weekly" is equal t:o "At least once per 7 days".

ITS SR 3.0.2 states that: "The specified Frequency for each SR is met if the Surveillance is performed within -1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a

specified condition of the Frequency is met.

Therefore, these CTS and ITS surveillance frequencies

are considered equivalent and the associated change is administrative.

ITEM 3.9.1-13 STS SR 3.9.l.l.c requires performing a

CHANNEL FUNCTIONAL TEST on each of the required refueling equipment interlock inputs: Refuel platform [fuel grapple] fuel loaded.

ITS SR 3.9.1.1.c requires performing CHANNEL FUNCTIONAL TESTS on each of the required refueling equipment interlock inputs:

Refueling platform main hoist, fuel loaded.

Provide discussion for the deviation from the STS in changing the CTS [fuel grapple] to the ITS main hoist.

TVA RESPONSE It was decided, in this instance, to retain the nomenclature specified in the CTS instead of adopting the suggested wording of NUREG-1433 for the subject ITS provision.

This is a bracketed term in NUREG-1433.

Use of "main hoist" instead of [fuel grapple] retains the customary terminology presently in use at BFN and, thus, is an aid to plant personnel.

Response to NRC Questions ITS SECTION 3.9.2 REFUEL POSITION ONE-ROD-OUT INTERLOCK ITEM 3.9.2-1 CTS 3.10 requires core reactivity limitations in place to.ensure that the core reactivity is within the capability of the control rods.

ITS 3.9.2 does not retain the core reactivity limitations for control rod capability.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC Al.

ITEM 3.9.2-2 CTS 3.10 requires core reactivity limitations in place to prevent criticality during refueling.

ITS 3.9.2 does not retain the core reactivity limitations to prevent criticality during refueling.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC Al.

ITEM 3.9.2-3 CTS 3.10 requires fuel handling requirements in place during core alterations.

ITS 3.9.2 requires the fuel handling interlocks in place only during in-vessel fuel movement.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS 3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC Al.

ITEM 3.9.2-4 CTS Surveillance Requirement 4.10 requires periodic testing of instrumentation required for refueling interlocks during Core Alterations.

ITS SR 3.9.2 does not retain this requirement.

TVA RESPONSE The CTS 3.10 section referred to in the NRC question is the general Applicability and Objective statement for the entire CTS Section 3.10/4.10 "Core Alterations."

There are no specific requirements in these introductory statements.

The LCOs and SRs are specified under the individual CTS.3.10/4.10 Specifications

sections, which are addressed on an individual basis in the ITS submittal.

Similar wording to the "Applicability and Objectives" provisions is,

however, being maintained in the BACKGROUND, APPLICABLE SAFETY ANALYSIS and APPLICABILITYsections of the corresponding ITS Bases.

Therefore, this is an administrative change as described by DOC Al.

W

ITEM 3.9.2-5 CTS 3.10.A.l requires that the refueling equipment interlocks be operable except as specified in CTS 3.10.A.6 and 3.10.A.7.

ITS 3.9.2 does not retain these exceptions.

TVA RESPONSE The Justification for Changes for CTS 3.10.A.6 and 3.10.A.7 are provided in the DOCs for ITS 3.10.5 and 3.10.6.

There is no need to retain references to these exceptions in Section 3.9.2 since they are allowed, with changes, in the referenced ITS sections.

ITEM 3.9.2-6 CTS Surveillance Requirement 4.10,A.1 requires functional testing the required refueling equipment interlocks prior to any fuel handling with the head off the vessel.

ITS SR 3.9.2.2 NOTE allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after any control rod withdrawal before requiring a channel functional test.

Provide additional discussion and justification for this less restrictive change.

TVA RESPONSE To perform a test of the one-rod-out interlock, a

control rod must be withdrawn from its full-in position and a second rod attempted to be withdrawn.

Since this requires entering the applicable condition to perform the test, ITS SR 3.9.2.2 is modified by the note which allows deferring the performance of the channel functional test until one hour after any rod is withdrawn.

This change is acceptable because of the demonstrated reliability,of this interlock, procedural controls on control rod withdrawals, and visual indication in the control room of rod position.

Refer to DOC Ll for added discussion.

ITEM 3.9.2-7 CTS 3.10.A.1 is applicable during Core Alterations.

ITS 3.9.2 is applicable during Mode 5 with the reactor mode switch in the refuel position and any control rod withdrawn.

Provide discussion for this less restrictive change.

TVA RESPONSE CTS 3.10.A.1 governs all of the refueling interlocks whereas ITS 3.9.2 is only associated with the one-rod-withdrawn interlock.

Since ITS 3.9.2 has a limited and well defined scope in accordance with NUREG-1433, a

less stringent appl'icability can be applied.

This new ITS applicability will result in the one-rod-out interlock being operable in all cases where it may be required to prevent prompt reactivity excursions.

We have adopted the wording as specified in NUREG-1433.

Refer to DOC L2 for added discussion.

ITEM 3. 9. 2-8 CTS Surveillance Requirement 4.10.A.1 requires testing following any repair work associated with the interlocks.

ITS 3.9.2 does not retain the requirement to test following work.

TVA RESPONSE Anytime the operability of a system or component has been affected by repai'r, maintenance, or replacement of a component, post maintenance testing is required to demonstrate operability of the system or component.

Per ITS SR 3.0.1, SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance shall be failure to meet the LCO.

ITS Bases for SR 3.0.1 states that "upon completion of maintenance, appropriate post maintenance testing is required to declare equipment operable."

Therefore, this CTS provision need not be specifically included in the ITS.

10

ITEM 3. 9.2-9 CTS Surveillance Requirement 4.10.A.1 requires functionally testing the required refueling equipment interlocks.

ITS SR 3.9.2.1 requires performing Channel Functional Tests on the required refueling equipment interlock inputs.

Provide discussion that indicates that Functionally Testing equates to Channel Functional Test.

TVA RESPONSE Channel Functional Test in the ITS is defined as the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability, including required alarms, interlock, display, trip functions, and channel failure trips.

In

CTS, a functional test is defined as the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances.

We consider the subject ITS Channel Functional Test requirement for the refueling interlocks to envelop the CTS Functional Test for the same equipment.

ITEM 3.9.2-10 CTS Surveillance Requirements 4.10.A.1 requires functionally testing the required refueling equipment interlocks.

ITS SR 3.9.2.1 requires performing a

Channel Functional Test on each of the required refueling equipment interlock inputs.

Provide discussion that CTS refuel equipment interlocks equates to ITS refuel equipment interlock inputs.

TVA RESPONSE TVA considers "refueling equipment interlocks" and "refueling equipment interlocks inputs" equivalent terms and that no changes in test methods will result from the change from CTS to ITS.

ITEM 3.9.2-11 CTS Surveillance Requirement 4.10.A.1 requires weekly testing of the interlocks.

ITS SR 3.9.2.1 requires a

7 day testing frequency.

Weekly can mean performance anytime during a week.

While 7 days means every 7

days

~

11

0

TVA RESPONSE CTS Table 1.1 specifies that the notation "Weekly" is equal to "At least once per 7 days".

ITS SR 3.0.2 states that "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in th'e Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met."

Therefore, these CTS and ITS surveillance frequencies are considered equivalent and the associated change is administrative.

12

Response to NRC Questions ITS SECTION 3.9.4 CONTROL ROD POSITION INDICATION ITEM 3.9.4-1 STS 3.9.4 requires the control rod full-in position indication channel for each control rod shall be operable.

ITS 3.9.4 requires the control rod full-in position indication for each control rod shall be operable.

Provide additional discussion for dropping the word "channel".

TVA RESPONSE At BFN, the "channel" designation is normally associated with multiple circuits used to evaluate plant'ariables which produce discrete outputs used in logic.

In the case of the control rod full-in position indication, there is only one circuit per individual control rod.

Therefore, the use of the term "channel" is not appropriate.

The use of "Position Indication" is more direct and better defines the ITS requirements.

13

Response to NRC Questions ITS SECTION 3.9.6 REACTOR PRESSURE VESSEL (RPV) WATER LEVEL ITEM 3.9.6-1 STS 3.9.6 is titled Reactor Pressure Vessel Water Level

. Irradiated Fuel.

ITS 3.9.6 is Titled Reactor Pressure Vessel Water Level.

Provide discussion for changing the title of the LCO.

TVA RESPONSE As discussed in Justification

P14, BFN has chosen not to adopt NUREG-1433 Specification 3.9.7 "Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods".

This is a bracketed section.

In doing so, the requirements for maintaining water level during movement of control rods and new fuel were combined and will be maintained exclusively in ITS 3.9.6.

Therefore, the title was revised since ITS 3.9.6 provides requirements for maintaining reactor water level for other component (control rods) handling in addition to irradiated fuel.

ITEM 3.9.6-2 STS SR 3.9.6.1 verifies the Reactor Pressure Vessel (RPV) water level is

> 23 ft. above the top of the RPV flange.

ITS 3.9.6.1 verifies the Reactor Pressure Vessel (RPV) water level is

> 23 ft. above the top of the irradiated fuel assemblies seated within the RPV.

Provide discussion for the deviation of changing the reference from which the water height is measured.

TVA RESPONSE The reference point, "above the top of the RPV flange",

has been incorporated to ITS 3.9.6 and its associated Bases in this submittal.

The reference level differential of "> 23 feet" has been changed to "> 22 feet" to account for BFN physical'dimensions of the fuel pool and reactor well.

The revised ITS, Bases, and Justifications are provided in this submittal.

14

Response to NRC Questions ITS SECTION 3.9.7 RESIDUALHEATREMOVAL(RHR) - HIGHWATER I EVEI ITEM 3. 9. 7-1

'STS 3.9.8 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water level

> 23 ft. above the top of the RPV flange.

ITS 3.9.7 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water level

> 22 ft. above the top of the RPV flange.

Provide discussion for the deviation from the STS water level of > 23 ft. to

> 22 ft.

TVA RESPONSE The water level Applicability was modified from > 23 feet to

> 22 feet above the top of the RPV flange due to the physical dimensions of the fuel pool and reactor well.

At BFN, the reactor vessel flange is at elevation 640 feet and the normal water level during refueling operations is maintained at elevation 663 feet.

The low level alarm is set at 662.67 feet.

Therefore, the physical dimensions of the reactor well precludes the use of > 23 feet as the setpoint for this specification.

A reduction in the water level is allowed in accordance with STS 3.9.6 Bases, Applicable Safety Analysis.

15

Response to NRC Questions ITS SECTION 3.9.8 RESIDUALHEATREMOVAL(RHR) - LOWWATER LEVEL ITEM 3. 9. 8-1 STS 3.9.9 Applicability is for MODE 5 withrradiated fuel in the Reactor.Pr'essure Vessel (RPV) and Che water level

< 23 ft. above the top of the RPV flange.

ITS 3.9.8 Applicability is for MODE 5 with irradiated fuel in the Reactor Pressure Vessel (RPV) and the water

~

- level

< 22 ft. above the top of...the RPV flange.

Provide discussion for the~'deviation from the STS water

.level of < 23 ft. to < 22 ft.

TVA RESPONSE The water level Applicability was changed from < 23 feet to < 22 feet above the top of the RPV flange due to the physical dimensions of the fuel pool and reactor well.

At BFN,-the reactor vessel flange is at elevation 640 feet and the normal water level during refueling operations is maintained at elevation 663 feet.

The low level alarm is set at 662.67 feet.

Therefore, the physical dimensions of the reactor well precludes the use of < 23 feet as the entry point for this specification.

This change is also needed to provide consistency with the modified water level in ITS 3.9.7.

A reduction in water level is allowed in accordance with STS 3.9.6 Bases, Applicable Safety Analysis.

16

SUMMARY

DESCRIPTION of ITS/BASES CHANGES ITS SECTION 3.9 TVA is submitting a proposed supplement to TS-362 for ITS

. Section 3.9,'REFUELING 'OPERATIONS.

This supplement makes changes associated with NRC comments on Section 3.9

(

Reference:

NRC Request for Additional Information Regarding Improved Standard Technical Specifications, dated September 17,

1997, TAC NOS. M96431,
M96432, M96433), incorporates minor changes resulting from an internal TVA review, and incorporates an Owner's Group Technical Specification Task Force (TSTF) item approved by NRC subsequent to the original submittal of TS-362.

A synopsis of the,KTS and ITS BASES changes is provided below.

LCO 3.9.6.1 SR 3.9.6 And Associated BASES In response to an NRC comment, changed referenced water level from 23 feet above the top of irradiated fuel assemblies seated within the Reactor Pressure Vessel (RPV) to 22 feet above the RPV flange.

Also, revised APPLICABLE SAFETY ANALYSIS BASES to support the referenced level change.

These changes are consistent with NUREG-1433.

LCO 3.9.7 LCO 3.9.8 and Associated BASES NOTE 1 is modified to incorporate an approved Owner's Group Technical Specification Task Force item, TSTF-153.

This change clarifies the text of the note to be consistent with the equivalent sections from the other reactor vendor ITS NUREGs.

The associated BASES are likewise modified.

SR 3.9.2 BASES In response to a TVA internal review, corrected typographical error in surveillance requirement (SR)

BASES for SR 3.9.2.2.

ACTIONS 3.9.7 A.1 BASES and ACTIONS 3.9.8 A.l BASES In response to a

TVA internal review, Action A1 Bases for the subject sections have been revised to delete the wording "operating with the regenerative heat exchanger bypassed",

due to physical design of the reactor water cleanup system.

The regenerative heat exchangers can not be bypassed.

ACTIONS 3.9.7 C.1 6 C.2 BASES and ACTIONS 3.9.8 C.1 E C.2 BASES In response to a TVA internal review, Action C1 and C2 Bases have been revised to include the wording "This alternative

, method may utilize forced or natural circulation".

, This

"'hange provides a clar'ification of methods for establishin'g an alternate means of coolant circulation.

Execsu39.doc

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