ML20112G381

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Application for Amends to Licenses DPR-33,DPR-52 & DPR-68, Revising Section 6, Administrative Controls, to Be More Closely Aligned W/Requirements of Improved Std TSs
ML20112G381
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 06/06/1996
From: Salas P
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20112G385 List:
References
NUDOCS 9606110389
Download: ML20112G381 (22)
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Tennessee Valley Authority, Post Office Box 2000. Decatur, Alabama 35609 June 6, 1996 TVA-BFN-TS-372 10 CFR 50.90 U.S. Nuclear Regulatory Commission I ATTN: Document Control Desk Washington, D.C. 20555 l

Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Autho.ity ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

TECHNICAL SPECIFICATION (TS) CHANGE TS-372 - SECTION 6, ADMINISTRATIVE CONTROLS In accordance with the provisions of 10 CFR 50.4 and 50.90, ,

TVA is submitting a request for an amendment (TS-372) to  !

licenses DPR-33, DPR-52, and DPR-68 to change the TSs for Units 1, 2, and 3. The proposed changes revise Section 6,

" Administrative Controls," to be more closely aligned with ,

requirements of the Improved Standard TSs. Additionally, these changes are consistent with NRC Administrative Letter i, ,

i 96-06, Relocation of TS Administrative Controls Related to Quality Assurance, in that applicable paragraphs will be )CO-relocated'to the TVA Nuclear Quality Assurance Plan.

TVA has determined that there are no significant hazards considerations associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9) .

9606110389 960606 PDR ADOCK 05000259 P PDR

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U.S. Nuclear Regulatory Commission Page 2 1 June 6, 1996 I

The BFN Plant Operations Review Committee and the BFN Nuclear-Safety Review Board have reviewed this proposed change and determined that operation of BFN Units 1, 2, and 3 in accordance with the proposed change will not endanger the health and safety of the public. Additionally, in accordance with 10 CFR 50.91(b) (1), TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public  !

Health, l l

Enclosure 1 to this letter provides the description and I evaluation of the proposed change and contains a retention and relocation summary. This enclosure also includes TVA's determination that the proposed change does not involve a significant hazards consideration, and is exempt from environmental review. Enclosure 2 contains copies of the appropriate TS pages from Units 1, 2, and 3 marked-up to show the proposed change. Enclosure 3 forwards the revised TS pages for Units 1, 2, and 3 which incorporate the proposed change. The Quality Assurance Plan pages which are revised as a result of this TS and a description are contained in l Enclosure 4.

, TVA requests that the revised TS be made effective within 45 days of NRC approval. If you have any questions about this ,

change, please contact me at (205) 729-2636. l Since p Pedro Salas Manager of Site Licensing Enclosures cc: See page 3 Subscrib 9d and sworn to before me on this wIh day of "d # E 1996..

Sodass A fatn Notary Public 4 Counhelon Expires 168 .

My Commission Expires I

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U.S. Nuclear Regulatory Commission Page 3 June 6, 1996 Enclosures cc (Enclosures):

Mr. W. D. Arndt General Electric Company 735 Broad Street Suite 804, James Building Chattanooga, Tennessee 37402 Mr. Johr.ny' Black, Chairman Limestone County Commission 310 Mest Washington Street Athens, Alabama 35611  :

Mr. Mark S. Lesser, Branch Chief  !

U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant  :

10833 Shaw Road Athens, Alabama 35611 Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 l l

Dr. Donald E. Williamson State Health officer Alabama State Department of Public IIealth 434 Monroe Street l Montgomery, Alabama 36130-3017

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-372 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I

I I. DESCPIPTION OF_THE_ PROPOSED CHANGE TVA proposes to revise the BFN Units 1, 2, and 3 TSs to eliminate portions of Section 6, Administrative Controls, relocating them to the TVA Nuclear Quality Assurance Plan (NQAP). When approved, the administrative section of the TS will be similar to the Improved Standard TSs.

Requirements for Plant Operations Review Committee (PORC),  !

Nuclear Safety Review Board (NSRB), Reporting and Audit Requirements, and Record Retention are being relocated into the TVA NQAP and will be subject to the requirements of 10 CFR 50.54(a). Other sections which have been deleted are based upon guidance provided by the staff to the Boiling Water Reactor Owners group (BWROG) in a letter dated October 25, 1993, which discussed the content of Standard TSs Administrative Controls. The staff concluded that a significant number of the sections can be relocated to other licensee documents for which those provisions are i adequately controlled by regulatory requirements. Further i details of the changes are as follows:

1. Units 1, 2, and 3, Section 6.5, Plant Review and I Audit, and Section 6.10, Station Operating Records and l Retention, will be relocated to the TVA NQAP. Section 6.11, Process Control Program, will be relocated to other licensee documents for which those provisions are adequately controlled by regulatory requirements.

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2. Units 1, 2, and 3, TS page 1.0-10, Section 1.0, l Definitions, Item Number BB, Offsite Dose Calculation Manual (ODCM), currently reads:

" . . . The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.4 and . . .

The revised specification will change the wording to read:

" . . . The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs and . . . "

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3. Units 1, 2, and 3, TS page 1.0-10, Section 1.0, Definitions, Item Number DD, Process Control Program, currently reads:

"DD. Process Control Proaram - Shall contain the ,

current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished'in such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste."

The revised specification will delete Item Number DD from the Definitions section. ,

4. Units 1, 2, and 3, TS page 6.0-1, Section 6.1.2, Responsibility, currently reads:

"A management directive to this effect, signed by the Site Director shall be reissued to all station '

personnel on an annual basis."

The revised specification will delete the requirement to issue a management directive.

5. Units 1, 2, and 3, TS page 6.0-1, Section 6.2.1.a.,

Offsite and Onsite Organizations, currently reads:

"These requirements shall be documented in the FSAR and will be updated in accordance with 10 CFR 50.71(e)."

The revised specification will change the wording to read:

"These requirements shall be documented in the Nuclear Power Organization Topical Report (TVA-NPOD89A)."

6. Units 1, 2, and 3, TS page 6.0-2, Section 6.2.1.b.,

Offsite and Onsite Organizations, currently reads:

" Senior Vice President, Nuclear Power."

The revised specification will change the title to read:

" President, TVA Nuclear and Chief Nuclear Officer."

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7. Units 1, 2, and 3, TS page 6.0-3, Section 6.2.2.f.,

Plant Staff, currently reads:

"Either a licensed SRO or licensed SRO limited to fuel handling who has no concurrent responsibilities during this operation shall be present during fuel handling and shall directly supervise all CORE ALTERATIONS."

The revised specification will delete section 6.2.2.f.

8. Units 1, 2, and'3, TS page 6.0-5, Section 6.3, Plant Staff Qualifications, currently reads:

" Qualifications of the Browns Ferry Nuclear Plant management and operating staff shall meet the minimum acceptable levels as described in ANSI-N18.1, Selection and Training of Nuclear Power Plant Personnel, dated March 8, 1971. The qualifications of the Radiological Control Manager will meet or exceed the minimum acceptable levels as described in Regulatory Guide 1.8, Revision 2, dated April 1987.

The Shift Technical Advisor shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and j transient and accident response and analysis."

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The revised specification will read:

"Each member of the unit's staff shall meet or exceed the minimum qualifications for comparable positions as specified in the TVA Nuclear Quality Assurance Plan (TVA-NQA-PLN89-A)."

9. Units 1, 2, and 3, TS page 6.0-5, Section 6.4, l Training, is being deleted from the TS. i
10. Units 1, 2, and 3, TS pages 6.0-5 through 6.0-18, Section 6.5, Plant Review and Audit, is being deleted from the TS and will be relocated to the TVA NQAP. i 1
11. Units 1, 2, and 3, TS page 6.0-19, Sections 6.7.1.a.

and 6.7.1.c., Safety Limit Violation, currently read:

" ... Senior Vice President, Nuclear Power..."

The revised specification will change the title to i read:

" ... Site Vice President..." l l

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12. Units 1, 2, end 3, TS page 6.0-20, Section 6.8.1.1, Procedures, currently reads in part:

" Written procedures shall be established, implemented and maintained covering the activities referenced below:

d. Security plan implementation.
e. Emergency plan implementation . . .
h. Process Control Program (PCP) . . .

The revised specification will delete Sections 6.8.1.1.d., 6.8.1.1.e., and 6.8.1.1.h. from the TS. t These sections will be relocated to their respective plans.

13. Units 1, 2, and 3, TS page 6.0-21, Sections 6.8.1.2 and 6.8.1.3, Procedures, will be de.leted from the TS and will be relocated to the TVA NaAP.
14. Unit 1, TS page 6.0.22, Section 6.8.3.1 currently reads:

" . . . Individuals qualified in radiation protection procedures (e.g., a radiological control technician),

or personnel escorted by such individuals, . . . "

The revised specification will read:

" . . . Individuals qualified in radiation protection procedures (e.g., a radiological control technician) or personnel escorted by such individuals, . . . "

15. Unit 3, TS page 6.0-23, Section 6.8.3.2 currently reads:

"In addition, areas that are accessible to personnel and that have radiation levels greater then 1 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> . . .

The revised specification will read:

"In addition, areas that are accessible to personnel and that have radiation levels greater than 1 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> . . . "

16. Unit 2, TS page 6.0-23b, Section 6.8.4.1.g.2 currently reads:

"For Iodine-131, Iodine-133, tritium, and for all radionuclides in particulate form with half lives greater than 8 days: less than or equal to a dose rate of 1500 mrem /yr to any organ."

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The revised specification will read:

"For Iodine-131, Iodine-133, tritium, and for all radionuclides in p.rticulate form with half-lives greater than 8 days: less than or equal to a dose rate of 1500 mram/yr to any organ."

17. Units 1, 2, and 3, TS page 6.0-23c, Section 6.8.4.2, Radiological Environmental Monitoring Program, will be deleted in its entirety.
18. Units 1, 2, and 3, TS pages 6.0-24 and 6.0-25, Section 6.9.1.1, Startup Report, will be deleted in its entiret)
19. Units 1, 2, and 3, TS page 6.0-26, Section 6.9.1.3, 1 Monthly Operating Report, first sentsnce currently l reads: l

" . . . Office of Inspection and Enforcement. . .

The revised specification will change the title to read:

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" ATTN: Document Control Desk,"

20. Units 1, 2, and 3, TS page 6.0-27, Section 6.9.2, Special Reports, currently reads:

" Reports on the following areas shall be submitted in l writing to the Director of Regional Office af Inspections and Enforcement:"

The revised specification will change the Region II submittal office from " Office of Inspections and Enforcecont:" to " Office, Division of Reactor Projects:"

21. Units 1, 2, and 3, TS page 6.0-27, Section 6.9.2.5, Special Reports, currently reads:

" Primary Containment Integrated Leak Rate Testing,"

"4.7.A.2," and "Within 90 days of completion of each test."

The revised specification will delete the current requirement to submit summary reports of Primary / Secondary Containment Integrated Leak Rate Tests.

22. Unit 2, TS page 6.0-28, Section 6.9.2.7 currently reads:

" . . . As a minimum, the reliability Improvement Program report for NRC audit shall include:. . . "

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The revised specification will read:

" . . . As a minimum, the Reliability Improvement Program report for NRC audit'shall include:. . . "

23. Units 1, 2, and 3, TS page 6.0-29, Section 6.9.2.8, Special Reports, currently reads:

" Secondary Containment Integrated Leak Rate Testing *,

"4.7.C," and "Within 90 days of completion of each test."

The asterisk refers to a paragraph that reads: "*Each integrated leak rate test of the secondary containment l shall be the subject of a summary technical report.

This report should include data on the wind speed, wind direction, outside and inside temperatures during j the test, concurrent reactor building pressure and i emergency ventilation' flow rate. The report shall j also include analyses and interpretations of those 1 data which demonstrate compliance with.the specified leak rate limits."

The revised specification will delete the current requirement in Specification 6.9.2.8, page 6.0-29 to submit suutary reports after performing Primary /Racondary Containment' Integrated Leak Rate Tests.

24. Units 1, 2, and 3, TS pages 6.0-29 through 6.0-31, Section 6.10, Station Operating Records and Retention, will be deleted'from the TS and will be relocated to the TVA NQAP.

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25. Units 1, 2, and 3, TS page 6.0-32, Section 6.11, Process Control Program, will be deleted in its entirety. I
26. Units 1, 2, and 3, TS page 6.0-32, Section 6.12.1, Offsite Dose Calculation Manual, currently reads:

" . . . Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.1.r . . .

The revised specification will read:

"Shall be kept in a manner convenient for review."

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27. Units 1, 2, and 3, TS page 6.0-33, Section 6.12.2, Offsite Dose Calculation Manual, currently reads:

"Shall become effective after review-and acceptance by the PORC and the approval of the Plant Manager."

The revised specification will read:

"Shall become effective after review and acceptance by tha process described in TVA-NQA-PLN89A."

2 iB . Unit 3, TS page 6.0-33, Section 6.12.3 currently >

reads:

"Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as part of or concurrent with the Annual P.adioactive Effluent Release Report . . . "

The revised specification will read:

"Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report . . . "

II. REASON FOR THE PROPOSED CHANGE In general, administrative controls are those requirements not covered by other technical specifications, but are necessary to assure operation of the facility in a safe manner. However, some of the Section 6 administrative requirements are broad descriptions.of regulatory requirements which are covered in more detail by regulatory controls which include the NQAP, Final Safety ,

Analysis Report (FSAR), 10 CFR 50.59 and 10 CFR 50.54.

These documents are used to ensure change control of the removed provisions. Thus the proposed technical specification change will reduce the need for future license amendments, allow for adequate NRC control through other regulatory channels, and provide for consistent administration of these requirements at the TVA nuclear sites.

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BROWNS FERRY SECTION 6 - TS RETENTION AND RELOCATION SUNNARY OLD NEW ,

6.1 Responsibility Same 6.1.1 Plant Manager Same 6.1.2 SOS Delete the annual management directive (See C.4) ,

6.2 Organization Same 6.2.1 Offsite Same (Clarification'to Section Organization 6.2.1.a and 6.2.1.b, see C.5 &

C.6) 6.2.2. Plant Staff Same 6.2.2.a Same

6.2.2.b Same 6.2.2.c Same 6.2.2.d Same 6.2.2.e Same 6.2.2.f Core Alterations Delete the requirement for SRO to directly supervise all Core Alterations (See C.7)

Table 6.2.A Same 6.3 Plant Staff Reference TVA-NQA-PLN89-A (See Qualification C.8) 6.4 Training Delete (See C.9) 6.5 Plant Review and Audit Relocate to TVA-NQA-PLN89-A (See C.10) 6.7 Safety Limit Violation Same'(Clarification to Section 6.7.1.a and 6.7.1.c, see C.11) 6.8 Procedures / Instructions Same and Programs 6.8.1 Procedures Same 6.8.1.1.a Same 6.8.1.1.b Same ,

6.8.1.1.c Same 6.8.1.1.d Security plan Relocate (See C.12) implementation El-8

OLD NEW 6.8.1.1.e Emergency plan Relocate (See C.12) implementation 6.8.1.1.f Same 1

6.8.1.1.h Process Control Delete (See C.12) l Program (PCP) l 6.8.1.1.1 Same 6.8.1.1.j Same 6.8.1.2 Delete (See C.13) 6.8.1.3 Delete (See C.13) 6.8.2 Drills Same 6.8.3 Radiation Control Same I Procedures 1 6.8.3.1 Same (Revised to correct ,

administrative error, Unit 1 l only, see C.14) 6.8.3.2 Same (Revised to correct administrative error, Unit 3 only, see C.15) 6.8.3.3 Same 6.8.4 Radioactive Effluent Same l Controls I 6.8.4.1 Same (Revised to correct administrative error, Unit 2 only, see C.16) 6.8.4.2 Delete (See C.17) l l

6.8.5 Programs Same 6.9 Reporting Same I Requirements 6.9.1 Routine Reports Same 6.9.1.1 Startup Report Delete (See C.18) 6.9.1.2 Same 6.9.1.3 Same (Clarification, change of mailing address, see C.19) 6.9.1.4 Same 6.9.1.5 Same 6.9.1.6 Same El-9

OLD NEW 6.9.1.7 Same 1

6.9.1.8 Same 6.9.2 Same (Clarification, change of mailing address, see C.20) 6.9.2.1 Same  ;

1 6.9.2.2 Same i 6.9.2.3 Same 1

6.9.2.4 Same l

l 6.9.2.5 Delete (See C.21) l 6.9.2.6 Same 6.9.2.7 Same (Revised to correct administrative error, Unit 2 only, see C.22) 6.9.2.8 Delete (See C.23) 6.9.2.9 Same 6.9.2.10 Same 6.10 Station Operating Relocate to TVA-NQA-PLN89-A Records and (See C.24)

Retention 6.11 Process Control Delete (See C.25)

Program 6.12 Same (Clarification of Sections 6.12.1 & 6.12.2, see C.26, C.27) 6.12.3 Same (Revised to correct administrative error, Unit 3 only, see C.28)

III. JUSTIFICATION FOR THE CHANGE A number of provisions in Section 6 have been identified which are adequately controlled by other regulatory requirements. The relocation of these provisions does not diminish the effectiveness of enforcement of the relocated provisions. The NQAP, FSAR, Generic letter 93-07, 10 CFR 50.59 and 10 CFR 50.54 are used to ensure change control of the removed provisions. Additionally, these changes are consistent with NRC Administrative Letter 95-06, Relocation of TSs Administrative Controls Related to Quality El-10

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I Assurance, in that applicable paragraphs will be relocated to the TVA NQAP. Further justification for the proposed

changes is provided below.  ;

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C.1 Sections 6.5 and 6.10 will be relocated to the NQAP i l and Section 6.11, Process Control Program, will be relocated to other licensee documents for which those l provisions are adequately controlled by regulatory requirements.

C.2 Section 1.0, Item BB, Offsite Dose calculation Manual (ODCM), is being revised to delete a reference which no longer exists in the TS.

C.3 Item DD, Process Control Program, is being deleted from the Definitions section. The Process Control Program (PCP) can be adequately described in the Process Control Program Manual where change control is maintained by 10 CFR 50.59. )

C.4 Section 6.1.2 of the TS should not require an administrative letter be issued to station personnel on an annual basis describing the responsibility of the Shift Operations Supervisor (SOS). The SOS responsibilities are adequately described in the Nuclear Power Organization Topical Report (TVA-NPOD89-A), Section 3.3.6.e. Repeating the organization responsibilities via an internal management directive only increases the administrative burden on the facility with no resulting benefit.

C.5 Section 6.2.1.a. is being revised to change a reference. The offsite and onsite organizational charts, functional descriptions of responsibilities, and job descriptions are documented in the Nuclear I Power Organization Topical Report (TVA-NPOD89-A).

C.6 Section 6.2.1.b is being revised by changing a title to correct an administrative error in the TS.

C.7 The requirement for a Senior Reactor Operator (SRO) to be present during fuel handling and to supervise all core alterations should not be retained in section 6.2.2.f. of the TS. This is a requirement of 10 CFR

50. 54 (m) (2 ) (iv) and is included in the plant's General Operating Instructions. Duplication of this regulation is not necessary to assure safe operation  !

of the facility. The current regulation states:

"Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior i

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BROWNS FERRY SECTION 6 - TS l RETENTION AND RELOCATION SUNNARY reactor operator license or a senior operator license-limited to fuel handling to directly supervise the activity and, during this time the licensee shall not assign other duties to this person."

C.8 Section 6.3 is being revised to reference the TVA NQAP which contains the minimum qualifications for the plant staff.

C.9 Section 6.4, Training, may be deleted from the TS on the basis that ANSI-N18.1 training requirements are adequately addressed in other Section 6 administrative controls. TS Section 6.3, Plant Staff Qualifications, provides adequate requirements to assure an acceptable, competent operating staff. As described in the Nuclear Power Organization Topical Report (TVA-NPOD89-A), the training program is maintained and under the direction of the Plant Manager.

In addition, 10 CFR 50.54 describes the minimum crew .

composition and delineates which positions require a l Reactor Operator or Senior Reactor Operator. Training and requalifications of those positions are as specified in 10 CFR 50.55. Based upon these considerations, duplicating the provisions relating to training in Section 6.4 of the TS is not necessary to assure safe operation of the facility.

c.10 Section 6.5, Plant' Review snd Audit, may be relocated from the TS on the basis that the review and audit functions can be adequately addressed elsewhere. The TS provisions are not necessary to assure safe operation of the facility, given the requirements in the TVA NQAP implementing 10 CFR 50.54 and 10 CFR 50, Appendix B to control the requirements for all review and audit functions. The following points summarize the reasons for removing the review and audit requirements from the TS.

A. The on-site review function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority and records are covered in equivalent detail in ANSI N18.7-1976.

These requirement will also be included in the TVA NQAP. Equivalent change control is provided by 10 CFR 50.54(a).

B. The off-site review group is also addressed in ANSI N18.7-1976. 'The TVA NQAP will include the requirements for the offsite review group. Their organization is not necessary to assure safe El-12

operation of the facility. Relocation of the requirements from the TS to the NQA Plan with equivalent change control is appropriate.

C. Audit requirements are specified in 10 CFR 50, Appendix B, Criterion XVIII and will be included in the TVA NQAP. Audits are also covered by ANSI N18.7, ANSI N45.2, 10 CFR 50.54(t), and 10 CFR 50.54(p). Duplication of the requirements contained in the above documents by the Administrative Controls Section of the TS does not enhance the level of nuclear safety for the plant. Therefore, the provisions relating to audits are not necessary to assure safe operation of the facility.

C.11 Sections 6.7.1.a. and 6.7.1.c. are being revised by changing a title to correct an administrative error in the TS.

C.12 Section 6.8.1.1.d., Security Plan implementation and Section 6.8.1.1.e., Emergency Plan' implementation program requirements are relocated to their respective plans in accordance with Generic Letter 93-07.

Further, changes in these review requirements must be made in accordance with 10 CFR 50.54(p) for the security plan and 10 CFR 50.54(q) for the emergency plan. The extensive requirements for emergency planning in 10 CFR 50.47 and 50.54 and for security in 10 CFR 50.54 and 73.55 for drills, exercises, testing, and maintenance of the program, provide adequate assurance that the objective of the previous TS for a periodic review of the program and changes to the program will be met. Therefore, duplication of the requirements contained in the regulations does not enhance-the level of nuclear safety. Such an approach results in an equivalent level of regulatory authority while providing for a more appropriate change control process. The net effect of the change is that the level of safety of plant operation is unaffected and NRC and facility resources associated with processing license amendments to this administrative control are optimized.

Section 6.8.1.1.h., Process Control Program (PCP), can be adequately described in the Process Control Manual where change control is maintained by 10 CFR 50.59.

The PCP Manual implements the applicable requirements  !

of 10 CFR Parts 20, 61, and 71 and, as such, relocation of the description of the PCP does not  ;

affect the safe operation of the facility.

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i C.13 Sections 6.8.1.2 and 6.8.1.3 are being deleted from the TS and relocated to the TVA NQAP. Relocation'of the requirements from the TS to the NQAP with equivalent change control is appropriate.

j C.14 Section 6.8.3.1, Unit 1, is being revised to correct an administrative error in the TS.

C.15 Section 6.8.3.2, Unit 3, is being revised to correct i an-administrative error in the TS.

C.16 Section 6.8.4.1.g.2, Unit 2, is being revised to correct an administrative error in the TS.

C.17 Section 6.8.4.2, Radiological Environmental Monitoring Program, requires that procedures be prepared for monitoring the radiation and radionuclides in the environs of the plant consistent with the guidance specified in 10 CFR Part 50, Appendix I. These procedures are developed to ensure that radioactive effluents are restricted to levels as low as reasonably achievable, and have no impact on plant nuclear safety. The details and description of the program are already contained in the Offsite Dose

[ Calculation Manual, as specified by existing TS 6.8.1.1.1. These regulatory requirements provide sufficient control of these provisions and removing them from the TS is acceptable. This proposal is consistent with the guidance provided in the NRC

letter to the BWROG dated October 25, 1993.

J C.18 Section 6.9.1.1, Startup Report, has been deleted from the Improved Standard TSs. The report was a summary 4 of plant startup and power escalation testing following receipt of the Operating License, and increase in licensed power level, the installation of nuclear fuel with a different design or manufacturer than the current fuel, and modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The report provided a mechanism for the staff to review the appropriateness of licensee activities after-the-fact, but contained no requirements for staff approval. The approved 10 CFR 50, Appendix B, NQA Plan and Startup i Testing Program (FSAR) provide assurance that the listed activities are adequately performed.

4 Since this report was required to be provided to staff within 90 days following completion of the respective milestone, it was clearly not necessary to assure

! operation of the facility in a safe manner for the interval between completion of the startup testing and j submittal of the report. Additionally, because there El-14

was no requirement.for the staff to approve the report, the Startup Report is not necessary to assure safe operation of the facility. Therefore, the removal of this requirement is considered acceptable.

C.19 Section 6.9.1.3 is being revised to update the NRC i _ mailing address for the Monthly Operating Report.

l" C.20 Section 6.9.2 is being revised to update the NRC regional office title.

C.21 Section 6.9.2.5 is being revised based on an NRC Code of Federal Regulations rule change and NRC changes to regulatory basis guidance documents. The submittal of 4

primary / secondary containment' integrated leak rate test reports was eliminated by NRC in 10 CFR Part 50, Appendix J, effective April 13, 1995.

C.22 Section 6.9.2.7, Unit 2, is being revised to correct an administrative error in the TS.

C.23 Section 6.9.2.8 is being revised based on an NRC Code of Federal Regulations rule change and NRC changes to regulatory basis guidance documents. The submittal of i primary / secondary containment integrated leak rate test reports was eliminated by NRC in 10 CFR Part 50, Appendix J, effective April 13, 1995.

C.24 Section 6.10, Station Operating Records and Retention, is being relocated from TS cn1 the basis that the requirements will be adequately addressed by the QA Program (10 CFR Part 50, Appendix B, Criterion XVII) and the related QA Plan.

Facility operations.are performed in accordance with approved written plant procedures. Areas include normal startup, operation and shutdown, abnormal conditions and emergencies, refueling, safety related maintenance, surveillance and testing, and radiation control. Facility records document appropriate station operation and activities. Retention of these records provides documentation and retrievability for review of compliance with requirements and regulations. Post-compliance review of records does not directly assure operation of the facility in a safe manner, as activities described in these documents have already been performed. In addition, numerous other regulations such as 10 CFR Part 20, Subpart L, and 10 CFR 50.71 require the retention of

, certain records related to operation of the nuclear plant. Therefore, it can be concluded that these regulatory requirements provide sufficient control of these record keeping provisions and removing them from TS is acceptable.

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'Cl.25 Section 6.11, Process Control Program (PCP) , can be adequately described in the Process Control Manual where change control is maintained by 10 CFR 50.59.

The PCP Manual implements the applicable requirements of 10 CFR Parts 20, 61, and 71 and, as such, relocation of the description of the PCP does not affect the safe operation of the facility.

C.26 Section 6.12.1 is being revised to delete the reference to section 6.10.1.r. and improve the clarity of the specification.

C.27 Section 6.12.2. is being revised to change the process for review and acceptance of the offsite Dose Calculation Manual to the process as described in the TVA NQAP.

C.28 Section 6.12.3, Unit 3, is being revised to correct an administrative error in the TS.

IV. NO SIGNIFICANT BAEARDS CONSIDERATION DETERMINATION TVA has concluded that operation of BFN Units 1, 2, and 3 in accordance with the proposed changes to the technical specifications does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a) (1) , of the three standards set forth in 10 CFR 50.92(c).

A. The nronosed amanAmant does not involVS a siGnifiORR$

increase in the nrobability or consecuences of an accident nreviousiv evaluated.

The proposed TS change to revise items 1 through 28 above (Section I,' Description of the Proposed Change) was evaluated and the proposed TS changes were determined to be administrative in nature. The changes involve administrative title changes of TVA management positions, the updating of an NRC mailing address and an NRC regional office title. In addition, certain sections are being relocated into other licensee documents for which those provisions are adequately controlled by regulatory requirements. These changes do not affect any of the design basis accidents. They do not involve an increase in the probability or consequences of an accident previously evaluated.

B. The proposed amendment does not create the nossibility of a new or different kind of accident from any accident previousiv evaluated.

( The proposed TS change to revise items 1 through 28 above (Section I, Description of the Proposed Change) 4 was evaluated and the proposed TS changes were determined to be administrative in nature. The changes El-16

involve administrative title changes of TVA management positions, the updating of an NRC mailing address and an NRC regional office title. In addition, certain sections are being relocated into other licensee documents for which those provisions are adequately controlled by regulatory requirements. These changes do not affect any of the design basis accidents. No modifications to any plant equipment are involved.

There are no effects on system interactions made by these changes. They do not create the possibility of a new or different kind of accident from an accident previously evaluated.

C. The DrODOsed Emendment does bot iBVOlVS a sianificant reductiOB in a marain Of safetV.

ine proposed TS change to revise items 1 through 28 above (Section I, Description of the Proposed Change) was evaluated and the proposed TS changes were determined to be administrative in nature. The changes involve administrative title changes of TVA management positions, the updating of an NRC mailing address and an NRC regional office title. In addition, certain sections are being relocated into other licensee documents for which-those provisions are adequately controlled by regulatory requirements. The margin of ~

safety as reported in the basis for the TSa is not reduced. The proposed change is administrative and I does not impact any technical information contained in I the bases of the TS.

V. ENVIRONMENTAL IMPACT CONSIDERATION The proposed change does not involve a significant hazards consideration, a significant change in the types of or i significant increase in the amounts of any effluents that may be released offsite, or a significant increase-in i individual or cumulative occupational radiation exposure. )

The proposed change meets the eligibility criteria for l categorical exclusion set forth in 10 CFR 51.22 (c) (9) . l Therefore, pursuant to 10 CFR 51.22 (b) , an environmental l assessment of the proposed ch nge is not required.

VI. 8AFETY ANALYSIS These administrative changes do not affect plant operation, design, or any safety-related activity or equipment.

Further, the changes provide revisions based on an NRC Code l of Federal Regulations rule change and NRC changes to regulatory basis guidance documents. These changes also correct errors and/or improve the clarity of the affected specifications, thereby increasing the probability that the specifications will be soterpreted correctly.

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ENCLOSURE 2 .

l TENNESSEE VALLEY AUTEORITY EROWNS FERRY NUCLEAR PLANT (EFN)

UNITS 1, 2, AND 3 PROPOSED TECNNICAL SPECIFICATION (TS) CNANGE TS-372 NARKED PAGES I. AFFECTED PAGE LIST Unit 1 Unit 2 Unit 3 v v v 1.0-10 1.0-10 1.0-10 6.0-1 6.0-1 6.0-1 6.0-2 6.0-2 6.0-2 6.0-3 6.0-3 6.0-3 6.~0-5 6.0-5 6.0-5 6.0-6 6.0-6 6.0-6 6.0-7 6.0-7 6.0-7 6.0-8 6.0-8 6.0-8 6.0-9 6.0-9 6.0-9 6.0-10 6.0-10 6.0-10 6.0-11 6.0-11 6.0-11. i 6.0-12 6.0-12 6.0-12 l 6.0-13 6.0-13 6.0-13 6.0-14 6.0-14 6.0-14  !

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'6.0-24 6.0-25 6.0-25 6.0-25 6.0-26 6.0-26 6.0-26 6.0-27 6.0-27 6.0-27 6.0-28 6.0-29 6 0-29 6.0-29 6.0-30 6.0-30 6.0-30 6.0-31 6.0-31 6.0-31 6.0-32 6.0-32 6.0-32 6.0-33 6.0-33 6.0-33 II. MARKED PAGES See attached.

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