ML20199D172
| ML20199D172 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/11/1997 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18039A242 | List: |
| References | |
| TS-BFN-TS-362, NUDOCS 9801300149 | |
| Download: ML20199D172 (5) | |
Text
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk f 7
Washington, D.C. 20555 Gentlemen:
f In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296
' BROWNS FERRY NUCLEAR PIANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE 362 - IMPROVED TECHNICAL SPECIFICATIONS (ITS) - SUPPLEMENTAL INFORMATION - CHANGES TC INSTRUMENTATION SURVEILLANCE TEST INTERVALS (STIs) AND ALLOWED OUT-OF-SERVICE TIMES (AOTs)
This letter provides supplemental information for the review of TS-362 regarding the basis for changes made in the ITS from Current Technical Specifications (CTS) related to extensions of instrumentation system STIs and AOTs. TS-362 is TVA's conversion package from CTS format to Improved Standard Technical Specifications format (NUREG-1433, Revision 1) and was originally submitted to NRC on September 6, 1996.
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In TS-362, the STIs and AOTs for a number of instrumentation systems were extended from those required in CTS. These )
changes are less restrictive than CTS, and a justification for each of these extensions is provided in the ITS submittal with p a reference to an approved Boiling Water Reactor Owners' Group E (BWROG) Licensing Topical Report which established the generic basis for supporting the plant-specific TS change. TVA has not, however, previously provided NRC with the results of the plant-speci_fic, assessments which demons': rate the acceptability 9001300149 971211 PDR P
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4 U.S. Nuclear Regulatory Commission Page 2 December 11, 1997 of these generic analyses for BFN. These BFN-specific analyses are provided in Enclosure 1 to this letter.
In the TS-362 submittal, TVA referred to several BWROG Licensing Topical Reports used in justifying the STIs and AOTs for particular instrument systems. These were:
- 1. NEDC-30851P-A, Technical Specification Improvement Analysis for Reactor Protection System; NEDC-30851P-A Supplement 1, Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation; and NEDC-30851P-A Supplement 2.
Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation.
- 2. GENE-770-06-1, Bases for Changes to Surveillance test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specificatior.s
- 3. GENE-770-06-2, Addendum to Bases for Changes to Surveillance test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications
- 4. NEDC-31677P-A, Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation
- 5. NEDC-30936P-A, Technical Specification Improvement Methodology, Parts 1 and 2 (With Demonstration for BWR ECCS Actuation Instrumentation).
TVA contracted General Electric (GE) to perform an assessment of the analyses referenced above for the instrumentation configuration on Unit 2. The results of these GE assessments are included in Enclosure 1 as five separate assessments. Note that in the assessments, GENE-770-06-2, regarding Reactor Core Isolation Cooling instrumentation, is not directly referenced.
It is, however, indirectly referenced in Enclosure 1 assessment number 5 by the *i-tence to NEDC-30936P-A which was the predecessor basit : :ument for GENE-770-06-2.- The -
instrumentation contiguration on Unit 2 for the instrumentation systems in the proposed ITS has not significantly changed since the completion of these assessments except for the recent installation of the Power Range Neutron Monicoring (PRNM) System a r
U.S. Nuclear Regulatory Commission Page 3 December 11, 1997 on Unit 2. A separate submittal and justification was provided for the PRNM system as TS-353S1, submitted April 11, 1997 (in ITS format).
These assessments concluded that the referenced generic analyses were applicable to BFN. Additionally, TVA'S setpoint methodology is consistent with Regulatory Guide 1.105 which endorses ISA STD ISA-S67.04-1982 "Setpoints for Nuclear Safety Related Instrumentation used in Nuclear Power Plants".
The setpoint methodology accounts for drift inaccuracies associated with the duration between calibrations. NRC has previously reviewed TVA's setpoint methodology in association with various CTS amendments and during the Unit 2 Nuclear
, Performance Plan inspections.
l l For Unit 3, TVA performed a similarity analysis between Unit 2 and Unit 3 instrumentation systems which concluded that the GE evaluations were likewise applicable to Unit 3. This evaluation is provided as Enclosure 2. Note that the PRNM system is not yet installed on Unit 3 (scheduled for Fall 1998). Also, the setpoint methodology used for Unit 3 is the same as that used for Unit 2. .
Therefore, TVA has concluded that the BWROG generic analyses are applicable to BFN and the STI and ACT extensions as proposed and justified in TS-362 are acceptable. This satisfies the respective :T.tC Safety Evaluation Report requirements for the determination of plant specific acceptability for use of the generic analyses.
This submittal also provides supporting information in response to NRC's request for additional information (RAI) dated June 12, 1997 (TAC NOS. M96431, M96432, and M96433) which provided comments on ITS Section 3.3, Instrumentation. In that RAI, NRC indicated that the approval of STIs and A0Ts proposed in ITS 3.3 was contingent on staff approval of the application of the subject generic documents.
Enclosure 1 Item 4 (MDE-32-0286, Revision 2, Technical Specification Improvement Analysis for the Reactor Protection System for Browns Ferry Nuclear Plant, Unit 2) contains j information proprietary to GE, and GE requests that this
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- U.S. Nuclear-Regulatory Commission Page 4 December 11, 1997 document be withheld from public disclosure in accordance with 10 CFR 2.790 la) (4) . An aff'. davit supporting this request is provided -in Enclosure 1 in accordance with 10 CFR 2.790(b) (1) .
If you-have further questions on this submittal, please contact me at (205) 729-2636.
Sijicerely
-Mknager . Licensi g and Indust Affairs
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Enclosures cc: See page 5 .
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l U.S. huelear Regulatory Commission Page 5 December 11, 1997 Enclosures cc (Enclosures):
Chairman Limestone County Commission 310 West Washington Street Athens, Alabama 35611 Mr. A. W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North-11555 Rockville Pike Rockville, Maryland 20852 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 601 Forsyth St., Suite 23785 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Dr.-Donald E. Willianson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017
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