Text

Forwards TS Section 3.6 Containing Several Proposed Improved TS Revs & Changes to Supporting Documentation Re Addressing NRC Comments,Per 970612 & 0714 Ltrs
	ML20198F430
Person / Time
Site:	Browns Ferry
Issue date:	12/29/1997
From:	Abney T; TENNESSEE VALLEY AUTHORITY
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A225	List: ML20198F430;
References
	TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9801120064
	Download: ML20198F430 (77)
	v • d • e

,.:5

(

Q:-

Tennessee Valley Authortty, Post Omco Box 2000, Ducatur, Alabama 35009-2000 j

December 29, 1997 10 CFR 50.90 U.S. Nuclear Regulatory Commiss!on

- ATTN: Document Control Desk Washington, DC'20555 Gentlemen:

In the-Matter of.

)

Docket Nds. 50-259 Tennessee Vall.ey Authority

)

50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE - 362 - IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUPPLEMENT 13 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI) - ITS SECTION 3.6 (TAC NOS.

,M96431, M96432, AND M96433) AND PROPOSED ITS LICENSE CONDITION

- BFN UNIT 1 (TAC NO. M96431).

.This-. letter.provides supplemental information in support of

-the TS-362 amendment request relating to Section 3.6, Containment Systems.

NRC comments on this section were

' included in an RAI dated June-12, 1997.

TS-362 is TVA's conversion package from Current Technical Specifications (CTS) to ITS and was originally submitted to NRC on September 6, j

1996.

Additionally, in response to NRC's Letter dated July

./

.14, 1997, a proposed License Condition is provided associated with the application of ITS for BFN Unit 1.

/

The Enclosure to this'1etter provides the response to the NRC LRAI on Section 3.6, and contains several proposed ITS 3~.

. revisions and-tchanges to supporting documentation related to o

d a'ddressing the'NRC comments.

In addition,

hanges and corrections associated with in-house TVA retiews are included.

'Also,' applicable-Owners Group Technical Specification Task 7

Vif

Force L (TSTF) items have been. incorporated.

Although a'large' number of revised ITS Bases pages are l included in the submittal, most are the result of s

9901120064 971229 POR ADOCK 05000259 1111115.51.li.llllll

+_

x

a o

U.S. Nuclear Regulatory Commission Page 2 December 29, 1997 header / footer and spacing or margin changes which caused some text to be shifted to adjacent pages.

Since these changes do not affect the technical content, they are not marked with revision bars.

The Enclosure is organized as following:

Responses to NRC questions Summary Description of ITS Changes ITS Revised Pages ITS Bases Revised Pages CTS Mark-up Revised Pages Justification for Chances to CTS (DOCS) Revised Pages e

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 e

No Significant Hazards Considerations Revised Pages Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433 Many of the NRC RAI questions request additional justification for Administrative, Less Restrictive, and Relocated changes in the conversion from CTS to ITS.

When possible, the additional justification will be provided in the RAI question response.

The associated DOCS will be revised only if the scope of the original DOC is significantly changed.

This same approach will also be applied to JDs.

Regarding TSTF items, as previously agreed, TVA has reviewed NRC approved TSTF items not previousl" incorporated to determine those applicable to this section.

TVA has established September 1, 1997, as the cut-off date for incorporation of TSTFs.

The Summary Description of ITS changes in the Erclosure lists the TSTF items incorporated in this submittal.

On a separate subject, Unit 1 is currently defueled and will require extensive analyses and modifications to be completed prior to restart.

TVA plans to perform the required analyses and modifications on Unit 1 such that on restart, the Unit 1 plant configuration and analysis basis will be the same or similar c Units 2 and 3.

Hence, in TS-362, the proposed f

LU.S. Nuclear _--Regulatory Commission

-Page'3' December 29, 1997-UnitEl ITS were the same as those proposed for Units 2 and 3 except for minor intrinsic unit differences.

In recognition of this approach, NRC in a letter dated July 14, 1997, requested-that TVA describe the controls and licensing requirements for ensuring that the required analyses and modifications have been completed prior to returning-Unit 1 to an operating configuration.

In response to the NRC letter, we propose the following License Condition be added to the Unit 1 License as follows:

"TVA shall review the Technical Specification (TS) changes made by TS-362 and subsequent TS changes for Unit 1, and-verify that required analyses and modifications needed to

-support the changes are complete prior to entering-the mode for which the TS applies."

This will ensure that the appropriate modifications and analyses are in place prior to entering modes of operation for which the TS apply.

The enclosed supplemental information does not alter the determination that there are no significant hazards considerations associated with the proposed changes and the determination that the changes qualify for a categorical exclusion from environmental review purs' tant to the provisions of 10 CFR 51.22 (c) (9).

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.

4 w

l U.S. Nuclear Regulatory Commission Page 4 1

December 29, 1997 There are no commitments contained in this letter.

If you have any questions, please contact me at (205) 729-2636.

Sqncerel 4

Manager of Li in and Indue ry Affai s Subscribed a d sworn to before me M ulg1997.

on this &94h aA43 b.

~

My Commission Expires anyc._;_1+_, g ga g cc (Enclosure):

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 61 Forsyth Street, S.W.

Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Dr. Donalo E. Wi' amson State Health Off Alabama State Department of Public Health 434 Monroe Street

Enclosure i

w ITS Section 3.6 Containment Systems' Enclosure Contents 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 Changer, 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 Changen to NUREG-1433 (JDs) e Revised Pages No Significant Hazards Considerations Revised Pages Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433 l

U 1

l

ITS SECTION 3.6.1.1 9

PRIMARY CONTAINMENT 3.6.1.1-1 CTS 3.7.A.2.a requires containment integrity be maintained.

ITS 3.6.1.

changes containment integrity be maintained to " PRIMARY CONTAINMENT shall be OPERABLE".

A2 states.that the definition of PRIMARY CONTAINMENT INTEGRITY has been deleted from the ITS.

This is incorrect.

The definition has hetually been relocated to the Bases BACKGROUND section for LCO 3.6.1.1, which is a less restrictive change.

TVA Response The existing BFN CTS definitior,of PRIMARY CONTAINMENT INTEGRITY is not in NUREG-1433 (STS) or being carried forth cxplicitly in the proposed BFN ITS.

Rather, as pointed out in the NRC comment, ITS LCO 3.6.1.1 provides a requirement that "the primary containtant shall be operable".

We also agree that the functional requirements for the maintenance or the primary O

containment boundary are relocated to the BASES BACKGROUND Section for LCO 3.6.1.1 and are very similar to CTS requirements for maintenance of primary containment integrity.

Since, however, the specific terminology " PRIMARY CONTAINMENT INTEGRITY" is not in ITS, the change has been appropriately categorized as an administrative deletion as further elaborated in DOC A2.

3.6.1.1-2 CTS 3.7.A.2.a requires containment integrity be maintained except while performing "open vessel" physics tests at power levels not to exceed 5 MW (t).

ITS 3.6.1.1 does not retain this requirement.

There is no discussion or justification for removing this detail.

TVA Response The objective of the existing CTS provisions for suspending the requirements of primary containment integrity for the conduct of open vessel physics tests at low powers was to allow flexibility for doing core physics testing during the original reactor start-up test programs.

BFN has no interest in retaining this 9

option and, due to the historical nature of the CTS provision, considers the change as an administrative change.

A new DOC (A7) has been added to better clarify the basis for this change.

1

l O

.6.1.1 3

~

CTS 3.7.A.2.b provides acceptance criteria for-integrated leak rate testing.

A4-states that the definition-of La is provided in ITS 1.1.

This is incorrect.

See: Item Number 3.'6.1.1-6.

TVA Response The definition of La is provided in ITS 5.5.12, " Primary Containment Leakage Rate Testing Program."

ITS 5.5.12 contains the acceptance criteria for primary containment leakage and is consiscent with NUREG-1433 for Appendix J Option B model TS and the provisions currently contained in CTS 6.8.4.3.

DOC A4 been i

corrected with regard to this point.

3.6.1.1-4 CTS 3.'7 A.2 c requirements for N2 makeup to un primary containment havo been moved to plant procedures.

CTS 4.7.A.2 Surveillance Requirements are moved to plant procedures and Bases.

There is inadequate discussion and justification for moving the details to' plant procedures and the change control process on the procedures.

-w g TVA Response CTS 3.7.A.2.c provides required actions to be taken if (when the containment is inerted) gross nitrogen consumption is equivalent to La per CTS 4.7.A.2.

.SR 4.7.A.2 is a conservative gross measurement technique since nitrogen is also. consumed by leakage from'the drywell control air system, the drywell/ suppression chamber differential pressurization system, and nitrogen supply piping external to the~ containment.

Other expedient indications of gross leakage can also be obtained from other sources such as containment oxygen concentration, AP compressor run times, and differential pressure decay rates.

Considerin7 that CTS 3.7 A.2.c/4.7.A.2 provides an auxiliary operational technique for monitoring containment integrity, it

.not necessary ' chat these provisions.be in ITS.

Rather, TVA has decided it is more appropriate that these provisions be relocated

.into the~ Technical Requirements Manual (TRM).

Changes to the TRM

.are reviewed in'accordance with 10 CFR 50.59.

DOC Lhl has been modified appropriately.

This change is consistent with STS.

2 j

~. -

. 6.1.1-51 a

1 LCTS 4.7.A.2.j> requires the. continuous leak rate monitor be OPERABLE.

This requirement -is not retained in: ITS 3. 6.'l-.1.--

This----

requirement is_ moved _to " licensee controlled documents." - The

~

.apecific: licensee controlled documents are not' identified.

TVA Response The requirements of CTS.4.7.A.2.jfwillfbe relocated to the TRM; Changes tofthe TRM are reviewed in-accordance with 10 CFR 50.59.

DOC LC1 has been.recategorized.as IJU2 and modified appropriately.

3.6;1.1-6 CTS 4.7.A.2.g requires leak' rate testing in accordance with the Primary 1 Containment Leakage Rate--. Testing-Program.

STS SR 3.6.1.1.1= requires the visual examination and leakage rate testing be_ performed in accordance with 10 CFR 50- Appendix J as-modified;by approved exemptions.

TS SR 3.6.1.1.1 modifies STS SR 3.6.1.1.11to conform to CTS 4.7.a.2.

The STS is--based on-Appendix J Option-A while the CTS /ITS are_ based on-Appendix.J Option B.c Changes to the STS with regards to Option A versus

(N Option B are covered by a letter ~from Mr.; Christopher-I. Grimes

(

to Mr.; David J.:Modeen,-NEI dated 11/2/95 and TSTF 52.

The ITS changes are not in conformance'with the letter of TSTF 52 as modifiediby-staff comments.

See Item Humber-3 6.1.1-3.

TVA-Response

-The' proposed ITS 3.6.1 BASES have been revised to remove statements whichLindicated-that Main Steam Isolation-Valve leakage _is(excluded from_ combined Appendix J Type B and C

-leakage.

Justification (JD) P18 has been-revised appropriately.

y N

3

[f a

gs 3.6.1.1 's The STS: Bases for SR 3.6.1.1.1 states that failure to meet MSIV leakage (STSLSR 3.6.1.3.13): does not necessarily result in a-failure-of STS SR 3.6.1.1.1.

ITS B 3.6.1.1 Bases for SR

?.6.1.1.1 changes this to "The main steam isolation valve leakage

-(SR-3.6.1.3.10) is not included-in the combined Type B and C leakage baaed onian exemption from Appendix'J and Appendix J Option B (Ref 7)."

The change is designated P54.

P54 provides no justification for this change.

In addition Reference.7 is still under review by the staff and completion is not expected

-prior to issuance of the ITS amendment.

This change is a beyond-scope of review item.

i TVA^ Response

.The proposed ITS 3.6.1.1 BASES have been revised to remove statements which indicated that Main Steam Isolation. Valve leakage is excluded from combined Appendix J Type B and C leakage.

ITS-BASES-3.6.1.1 Reference 7 has been deleted, and JD P54 is no longer required and has also been deleted.

The BFN proposed ITS should now be consistent with Appendix J

("'}

Option B model TS.

i

\\-,i

&V 4

t

)

a

-l 7'

ITS SECTION 3.6.1.2 PRIMARY CONTAINMENT l

' AIR LOCK 1

[

v

-_ 3. 6.1'. 2.

-CTS-3.7.A.2 a. specifies the conditions for which containment-(containment air lock) integrity must'be_ maintained.

Justification Al is-a-generalized'.ceformatting, renumbering and-editorializing justification, which does not apply in-this case.

.ITS 3.6.1.1? justifications A2 and M2 apply to the CTS ~ change,. as

-well-as_ITS 3.6.1.2 justification M4.

See Item Numbers 3.6.1.1-1 and 3.6.1.1-2.

l WA Response Refer torthe responses to Item Numbers 3.6.1.1-1 and 3.6.1.1 #

for an explanation for the categorization of DOC Al as administrative.

We believe the existing CTS mark-ups are satisfactory as augmented by the M-DOC explanations of changes in O

this ITS section.

3.6.1.2-2 CTS 4.7.A.2.g specifies the acceptable criteria for air lock leakage testing.

The markup show-this item being relocated to ITS 5.5.1.12.

No justification is provided-for the administrative change.

WA Response The relocation of the airlock--leakage. acceptance criteria.is consistent with Appendix J Option B model TS.

3.6.1.2-3 See-Item Number 3.6.1.1-6

- WA Response.

-Refer to the~ response to Item Number 3.6.1.1-6.

JD P18 has also

Q

'been revised to clarify;the treatment of. airlock leakage

i, g

. criteria.

1.

l..

. /'~]

ITS SECTION 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs) 3.6.1.3-1 CTS 3.7.D.1 states that when Primary Containment integrity is required, all PCIVs and reactor coolant system instrumentation EFCVs rk-ll be OPERABLE.

ITS LCO 3.6.1.3 requires all PCIVs and EFCVs except for the reactor building-to-suppression chamber Vacuum break 1rs to be OPERABLE.

This change is designated as A1.

This change-is justified as administrative based on the fact the vacuum breakers are governed by another LCO, in this case ITS LCO 3.6.1.5.

However,-since the CTS also has a TS on the vacuum breakers (CTS 3.7.A.3), this argument is not valid.

This change-is'not an administrative change.

TVA Response CTS 3.7.A.3.a requires that two pressure suppression chamber

(N (torus) vacuum breakers be operable whenever primary containment

\\

integrity is required.

CTS 3.7.A.3.b provides that, if one of the suppression chamber vacuum breakers la inoperable, then reactor operation can continue for 7 days provided that the repair procedure does not violate primary containment integrity.

Each of the; reactor building-to-suppression chamber vacuum breakers consists of an air operated inboard butterfly and a self acting outboard check valve as described in the BACKGROUND BASES for ITS 3.6.1.5.

The check valve will open if the torus pressure is more than.5 psid below that of the reactor building.

The air operated valve opens on a electronic signal if the pressure differential is.5 psid or greater.

The air operated valve receives no isolation signal and is designed to fail open on loss of air to maintain vacuum relief capability.

During normal operation, both-valves are closed.

Hence, these valves have a dual safety function; containment isolation under normal conditions and vacuum relief in-the accident mode.

While it is recognized that the valves provide a containment isolation function, the need for the concurrent vacuum relief function does not allow treatment as " standard" containment isolation valves in TS.

In STS,~this duality of function is explicitly addressed in 3.6.1.7 which prescribes Required Actions in terms of closed status of the valves and the ability of the valves to open.

7-ss

(

)

Under the existing CTS, this-distinction is not explicitly

\\s /

delineated.

1

[~$

The intent of administrative change (DOC A1) for ITS 3.6.1.3 is

' (--[:

to: indicate ~that-the exception for the reactor-building _ vacuum-breakers as-isolation valves in ITS LCO 3.6.1.311s-administrative since the vacuum breakers'will have a separate specification in 3

ITS~as ITS 3.6.1.5.

As noted above, this same distinction is-made in CTS 3.7.A.3.a and CTS 3.7.A 3.b although'less clearly.

1.

We consider-that the specific differences _between CTS and ITS are adequately justified in the mark-ups, DOCS, and JDs for cae subprovision.* of ITS 3.6.1.3 and 3.6.1.5.

Also,uns noted in '.he response to NRC comment 3.6.1.5-1, TVA has subsequently-decided to: modify ITS 3.6.1.5 to be consistent with the LCO and Required Actions of STS 3.6.1.7.

3.6.1.3-2 CTS 3.7.D.1 states that when Primary Containment integrity is required, all PCIVs and EFCVs shall be OPERABLE.

ITS LCO 3.6.1.3 requires all PCIVs and EFCVs except-for-the reactor building-to-suppression chamber vacuum breakers to be OPERABLE.

Justification Al states that ITS LCO 3.6.1.3 in addition to exempting _the vacuum breakers also exempts the scram discharge volume vent and drain valves.

CTS 3.7.D.1, the markup of CTS 3.7.D.1, and ITS-LCO 3.6.1.3 do not show an exemption for the scram discharge volume vent and drain valves.

This change, if

("')N incorporated, would not be an administrative change but a less

(

restrictive change, and has the potential for being a generic change but a less restrictive change, and has the potential for being a generic change, which would be beyond the scope of review for this conversion.

TVA Response The reference to the scram discharge volume vent and drain valves

'hes been removed from DOC A1.

These valves are not containment isolation valves and an exemption is not needed.

3.6.1.3. CTS 4.7.A.2.1 specifies-the MSIV leakage limits and remedial Lactions to take upon discovery of leakage rates exceeding specified limits.

CTS 3.7.D.1 and CTS 3.7.D.2 provide additional operability requirements,. remedial actions and associated times in which to complete the. repairs and retests-associated with CTS 4.7.A.2.1.

The repair time per CTS 3 7.D.2'is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ITS 3.6.1.3 Condition D changes STS 3.6.1.3 Condition D from 7-~3

" Secondary _ containment bypass leakage rate not within limit to "One of more penetration flow paths-with MSIV leakage not within i

1's !- : limits."

Based on STS B.3.6.1.3 Bases RA D.1 discussion, STS w

2

a 1

1 TV 3.6.1.3 Condition 1D includes both secondary containment and MSIV-L(

) ' leakage.

Therefore, the proposed change.to~ Condition.Dfis acceptable.

However, the change of the completion Time-associated.with RA D.1 and CTS 3.7.C.1 from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to an ITS

. time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is not adequately justified.

The justification-used is consistency with the Completion Time of STS/ITS 3.6.1.3 4

'RA-A.l.

The Completion Time associated with ITS 3.6.1.3 RA D.1 takes into-account the safety significance of containment leakage versus valve inoperability.

T1.us the STS completion Time for leakage-is less than the Completion Time for an inoperable _MSIV.

TVA Response' The Completion Time for ITS 3.6.1.3 Condition D has been revised to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months which is consistent with STS.

3.6.1.3-4 CTS-4.7.D.1.a requires the Primary Containment Isolation Valves (PCIVs) be tested in accordance with CTS 1.0' MM for closure times.

ITS SR 3.6.1.3.6 requires verifying MSIV isolation time 2 3' seconds and s 5 seconds.

There is no discussion or justification for these time limits.

IN,,)

TVA Response The basis for the MSIV closure times is as follows:

,5 second maximum time Prevent damage to the fuel barrier by limiting the loss of Reactor cooling water in case of a major leak from the steam line piping outside the Primary Containment, and Limit release of radioactive materials by closing the primary containment barrier in case of a major leak from the, nuclear system inside the primary containment.

3 second minimum time The minimum time ensures that' closure of all steam lines will not induce a more severe transient (pressure / power increase) on the nuclear system than the closure of the Main Steam Stop Valves while the turbine bypass valves remain closed.

These same times are also shown in FSAR Table 5.2-2 lL) 31

'x 3.6.1.3 y CTS 3.7.F.1, CTS 3.7.F.2 and' CTS 4.7.F requirements for the containment-purge system are relocated-to the Technical Requirements Manual-(TRM).

There is no discussion of how the TRM addresses'these requirements and how changes to The TRM are-controlled.

See Item Number 3.6.1.3-6.

TVA Response-

'The requirements of CTS 3.7.F.1, CTS 3.7.F.2, and CTS 4.7.F will be relocated in their entirety to the TRM.* Changes to the TRM l

are governed by the 10 CFR 50.59 proceos.

i

=3.6.1.3-6

-CTS 3.7.F.1, CTS 3.7.F.2_ and CTS 4.7.F requirements for the containment purge system are relocated to the TRM.

The justiiication for this relocation is inadequate.

There is no discussion either in R1 or in " Browns _ Ferry Nuclear Plant

Application Screening Criteria" which discusses why this system does not meet the criteria specified in 10 CFR 50.36(c) (2) (ii).

TVA-Response The primary containment purge system at BFN is not a safety related system (with the exception of the primary containment isolation valves which are covered by ITS 3.6.1.3) and is not relied upon to mitigate any transient or design basis event.

It does not contain installed instrumentation used to detect a significant abnormal degradation in the reactor coolant pressure boundary and is not modeled in the BFN Probabilistic Safety Assessment.

The system (with the exception of the primary containment isolation valves which are covered by ITS 3.6.1.3) does not meet any of the four criteria specified in 10 CFR

50. 36 (c)-(2) (ii) and, therefore, it is appropriate that the requirements of CTS 3.7.F.1, CTS 3.7.F.2, and CTS 4.7.F be relocated to the TRM.

DOC R1 has been revised to include the above discussion.

J

- U 4

g.,r'~' :- -0.6.1.3-i

'~' ' STS : SR 3.6.1.3.2 verifies each 18: inch primary containment purge STS SR 3.6.1.3.2 has a Note 1 which states that valve is closed.

the SR is_"only required to be met in MODES 1, 2 and 3.".

The Basis for-STS SR states that the basis:for the Note is that if a-LOCA inside containment occurs in these MODES, the purge valves may'not be capable of closing before.the pressure pulse _affects systems downstream of the purge valves or the release of radioactive material will exceed limits prior to the valve closing.

ITS SR 3.6.1.3.1 deletes this Note on the basie that no PCIV leakage tests are required in MODES other than'1, 2 and 3.

The Note and SR do not have anything to do with leakage.

TVA Response The Note has been deleted since it is not needed; purge valves are-not required to be Operable in Modes other than 1,-2,- and 3.

The Applicability of this LCO is only in Modes 1, 2, 3; Modes 4 and 5 are only_ applicable for Shutdown Cooling Isolation valves when the instrumentation-is required per ITS LCO 3.3.6.1.

Additionally, as discussed in FSAR section 5.3.3.6.3, the BFN containment purge valves have been analyzed and shown to be

/

adequate for closure against DBA forces consistent with NRC

(,)i Branch Technical Position CSB 6-4.

This also protects against overpressurization of the appurtenant ductwork.

JD P16 has been amended to include the above discussion.

3.6.1.3-8 See Item Number 3.6.1.1-6 and 3.6.1.3-7 TVA Response DFN proposed ITS are consistent with Appendix J Option B Model TS.

Also, with regard to JD P21, see the response to'3.6.1.3-9.

3.6.1.3-9 STS SR 3.6.1.3.14 and Associated Bases have been deleted from ITS.-

The justifications used are that the current licensing basis does not include this requirement and this type of leakage

~is part of the overall containment leakage.

These statements are contradictory: and the second justification would be considered

./~'}

_ generic which would be beyond the scope of review for this

(

j conversion.

If the-hydrostatic tests are part of the overall containment leakage test required by Appendix J, then it is part 5

of the current-licensing basis. 'Thus STS'SR13.6.1.3.14_must'be-

~

/']x included in the-ITS, unless an' exemption has been granted by.the -

!'J staff.

TVA Response BFN does not have any specific requirement in CTS that corresponds to STS SR' 3.6.1.3.14.-

BFN has-water tested primary containment isolation valves in seismic class I (SCI) lines and in systems that'are water sealed post' accident.

The treatment of'

' water tested valves is specified in the Conta!nment Leak Rate-Program, c BFN does not have any_ acceptance criteria based on a 1eak rate multiplied by the total number of PCIVs that are water tested.

BFN does have acceptance criteria specified-in the Containment Leak Rate Program for water sealed components.

This criteria is based on maintaining a water seal for 30 days at 1.1 9Pa.

This criteria allows those particular components to be water-tested in. lieu of air testing as allowed by_10 CFR_50, Appendix J.

SCI valves that are water tested are required to be tested and results reported to the Commission, but thase lines are considered to be extensions of primary containment and any leakage through these valves remains inside containment.

Additionally, some of these SCI valves are also Pressure Isolation Valves (PIVs) and have allowable leak rates based on a

/g percentage of downstream relief valve capacity as described in 1

j the ASME Section XI' Program.

These extensions of containment (RHR and Core Spray) are tested during the Type A test Containment Integrated Leak Rate Test (CILRT) by monitoring level drop (displacement) of the reactor vessel during the test.

Therefore, STS SR 3.6.1.14 is a new specification not currently contained in CTS or associated licensing bases.

For this case, BFN has. decided to continuo the current methodology of testing described above and chosen not to adopt STS-SR 3.6.1.14 which we would consider a more restrictive requirement.

'fD v )-

t

.s-6 r

T w

/ Djl.6.1.3-10 d# 2TS 3.6.1.3 : Action [:F removes the phrase " Operation with al potential'for draining the vessel (OPDRVs)".from Condition F and-places-it in:RA F.1-in place.of "OPDRVs" The justification ~

i states that OPDRVs!can onlyL0ccur in MODES 4 and 5,-thus it:is

not necessary to specify it in condition:F..

The staff has determined that thiu~is a generic change which is beyond the-scope offreview for.this conversion.

-TVA Response We consider this change administrative.

Moving-the statement regarding operations with a potential for draining the-reactor-vessel (OPDRVs) from the Condition statcment to the Required Action is more direct and simply eliminatc= redundant text.--This makes the ITS more useable for BFN, but,does not change-the objectives or requirements of the STS provisions.

3.6.1.3-11 The Bases for SR.3.6.1.3.10 refers to a Note 1 which ITS SR 3.6.1.3.10 does not show a note.

Therefore, the Bases discussion on the Note was deleted from the ITS.

This is an error.

The

(}

Note should be added to ITS SR-3.6.1.3.10'

(,f

~

and the discussion retained in the Bases.

This Note deals with leakage limit applicability and is associated with ITS 3.6.1.3 ACTIONS Note 4.

Also, BWR 16 C.5 corrected this error.

See Item Number ~3.6.1.1-6 with regards to changes to ti:is note.

/

TVA Response A review of previously approved BWR-4 ITS indicates the subject note has not typically incorporated.

Therefore, we believe the item should be approved as a generic change prior to requesting individual. licensees _ adopt'the change.

l-l p

o L

^

i-L 7-

-... ~.. -

.. - - ~..

l-C e

3. 6.1'. 3-12 '

i

\\

ITS B.3.6.1.3' Bases for the LCO'section 3 hows the statement

="These passive. isolation valves and devices are those listed in

' Reference 2."-

The deletion is-marked-P59.;- The' justifications state that.P59 is "not:used".

WA Response-BFN does not have a corresponding FSAR'referance which-lists all passive isolation-valves and devices.

JD'P59 has been corrected accordingly.

J r

i r

i 3.

1 1

1 d.

.f

-a b

4 P

4 8

i

..~r-.c,...w.

,cr.,

, - - ~ ~ - -. - - +, -.

,~i<

e

~.

i 3A l

ITS SECTION 3.6.1.4

. DRYWELL AIR TEMPERATURE.

8.3.6.1.4-1 STS 3'.L6.1.4, Drywell Pressure, is deleted for the ITS.- The ITS

is renumbered:such that ITS 3.6.1.4 is Drywell-Air Temperature.-

- i The discussion.and justification-for deleti.ng the Drywell -

-Pressure STS requirement does not address the current licensing

-basis,1 system design,.or_ operational constraints.

.The justification is based on a.recent GE evaluation on drywell pressure.

The justification used virtually the_same words as Brunswick and Duane Arnold for deleting this requirement from their-respective amendments.

The only difference between'the BFN

justification is the reference to a GE Report-NEDC-32466P Supplement 1.

This report has not been reviewed and approved by the staff._ Therefore the justification based on:this report would constitute a. generic. change to the: STS and wou3d be beyond -

the scope of.rev.few.for a conversion.

TVA Response-

\\- /

The document referred to in the NRC comment is s Brunswick

. specific report and is not discussed.or referenced in'the BFN ITS submi'tal.

BFN's-justification for eliminating the LCO is based ori a worst case plant-specific evaluation of peak containment pressure with an. initial drywell pressure of 17.05 psia- (2.75 psig), a drywell temperature of 150* F, and a drywell-to-wetwell pressure difference of.l.1 psid.

The ana' lysis is based on 100% reactor power and the_ core flow corresponding to the Maximum Extended

-Load Line Analysis (MELLLA) point.

The analysis showed the peak drywell pressure remains below the JFSAR value of 49.6 psig and is thus below the 56 psig design pressure.

This analysis confirms that limiting-the initial

drywell pressure to below 2.5 psig (ITS Table 3.3.1.1-1 High Drywell Pressure Scram-setpoint), will ensure that the peak drywell pressure-remains within the previously analyzed results.

Therefore, it is acceptable not to monitor drywell pressure.via &

separate LCO;and-SR since'the:RPS instrumentation will trip the

. reactor >for drywell pressures above 2.5 psig.-

V 1

_ _.. ~ _.. _.

4

...~_.__..m.

x

~. (_ j

- 3.'6.1.- 4 -1

~

The_ change.in numberingLfrom STS;3.6.1.5'(Drywell-' Air ~

J Temperature)"f:o_. ITS : 3. 6.1._4 will depend on! resolution -- of sItem -

1 Number S.3.6.1.4-1.

x

- WA - Respons

since it was deleted from the' Ttext of-SR 3.6.4.3.2." -This justification is wrong. BWR 16, C.22;has nothing to do with this!section.of.the STS; -BWR'16, C.26 however does. Also, SR 3.6.4.3.2 does not have anything_to do with this reference or section, i - WA Response' O Af ter 'further-review, we agree - that BWR16 C22-referenced in-JD PL2 should be BWR16 C26 and-the reference to'SR 3.6.4.3.2-should be STS 3.6.1.5, Applicabl'e Safety Analyses Bases. JD P52 has been revised accordingly. t 4 c-f y: ? a. 1 /7 ITS SECTION 3.6.1.5 REACTOR BUILDING-to-SUPPRESSION CHAMBER VACUUM BREAKERS l 3.6.1.5-1 In light of the discussion of issues with regards to the changes made in CTS 3.7.A.3, ITS 3.6.1.5 LCO, ITS 3.6.1.5 ACTIONS and associated ITS Beses particularly for Item Number 3.6.1.5-3, and 3.6.1.5 -4, licensee should consider either totally revising the ITS LCO and ACTIONS to conform totally to the ITS. ,TyA Response In response to the NRC comment, we have decided _to utilize the STS Completion Times in accordance with NUREG-1433. DOC L1 has been modified and a new DOC M3 added to address the shorter 72-hour completion time that is applicable for single vacuum breakers being inoperable. JD P15 has been deleted. O(,/ 3.6.1.5-2 CTS 3.7 A.3 is being modified to conform to ITS 3.6.1.5 (STS 3.6.1.7). ITS 3.6.1.5 adds a Note to the ACTIONS which states that " Separate Condition entry is allowed for each line." The justification states the change is consistent with NUREG 1433, and is classified as an administrative change. The CTS does not have this restriction and nothing in the justification clearly shows that the change is purely administrative. The change seems to be less restrictive. TVA Response CTS does not-have this restriction due to the fact that there is only one action prescribed under CTS 3.7.A.3.b. This change is -in accordance with NUREG-1433 and is administrative since multiple actions were adopted directly from the STS. V(3 l 1 ' ") 3.6.1.5-3 ~ j s CTS 4.7.A.3.b_ requires a " visual exaniination" and determination '~' that the force required to open the vacuum breakers does not exceed limits. This requirement is not retained in ITS 3.6.1.5 and is moved to plant procedures. There is inadequate justification of the plant procedure change control process. TVA Response The requirement for visual examination of the Reactor Building-to-Guppression Chamber vacuum breakers (check valves) is considered an operational detail for conducting the vacuum breaker SR 3.6.1.5.3. Specifically,'to test the outboard vacuum breaker (check valve), local testing is necessary using weights to apply an opening force. Applying the force involves a attaching a weight cradle to the check valve swing arm and verifying valve movement after the predetermined amount of weight is added to the cradle. During the test, a visual inspection of the vacuum breakers is also performed to verify for proper movement, cleanliness, and valve condition. It is not necessary to carry forth this level of operational detail for conducting the SR into the ITS. Rather, details for the mechanics of conducting the test and visual inspection will be included in the /T test instruction for SR 3.6.1.5.3. Changes to surveillance tests ( ) are controlled by site administrative procedures which includes a review for 10 CFR 50.59 applicability. DOC LA1 has been modified slightly to clarify the above position. 3.6.1.f-4 CTS 3.7 A.3.a requires only 2 cut of the 4 reactor building Building-to-Suppression chamber vacuum breakers to be OPERABLE. CTS 3.7.A.3 b specifies the remedial actions to be taken if one of the 2 required vacuum breakers is inoperable. Thus 3 vacuum breakers can be inoperable before one has to enter CTS 3.7.A.3.b. ITS 3.6.1.5 requires all four Reactor Building-to-Suppression chamber vacuum breakers to be OPdRABLE and proposes appropriate actions for the various combinations of inoperable vacuum breakers. This change is not less restrictive, but more restrictive. See Item Numbers 3.6.1.5-1 and 3.6.1.5-5. TVA Response ITS 3.6.

1.5 BACKGROUND

Bases provides a detailed description of the design of the vacuum breakers.

There are two pairs of vacuum 7-'y breakers in series which constitute two parallel flow paths.

)

With respect to CTS 3.7.A.3.b, the requirement that two reactor building vacuum breakers be operable applies to the path (paired)

N' 2

f'~'

valves.

TL;refore, the inoperability of three vacuum breakers

(

) would always result in the loss of two pathways.

Since CTS dees -

not provide an-LCO for the loss of two pathways, the actions

'~'

default to CTS definition 1.0.C.1 which requires that, in the event a LCO and/or associated requirements cannot be satisfied because of circumstances in excess of those addressed in the specification, the unit shall be placed in at least hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Failure of either of the valves for a particular paired pathway results in being in the CTS 7-day LCO.

The proposed ITS specifications, which are in accordance with the NUREG, are generally more flexible since vacuum breaker operability requirements are defined on an individual valve basis and also on a functional basis (open/close capability).

Hence, this change is appropriately categorized as less restrictive as discussed in DOC L1, 3.6.1.5-5 CTS 3.7.A.3.b specifies that with one of the required 2 Reactor Building-to-Suppression Chamber vacuum breakers inoperable, reactor operation may continue for up to 7 days provided that repair procedures do not violate primary containment integrity.

(N ITS ACTIONS A and C specify the Conditions and Required Actions

)

to take if one or two of the required 4 vacuum breakers are

('#

inoperable.

ITS Condition D reflects CTS 3.7.A.3.b.

The Completion Time associated with Conditions A and C reflect the AOT for CTS 3.7.A.3.b which is 7 days, rather than the STS Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

CTS 3.7.A.3 actually allows the AOT for Conditions A and C to be indefinite.

Condition D has a Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months versus the CTS AOT of 7 days.

The ITS and STS times are more restrictive t han the CTS.

The justification for P15 stLtes that Completion Times for ITS ACTIONS A and C are based on retaining the current licensing basis, which is wrong based on the above discussion.

See Item Numbers 3.6.1.5-1 and 3.6.1.5-4.

TVA Response As discussed in response to the NRC comment 3.6.1.5-1, we have decided to incorporate the STS Completion Times in accordance with NUREG-1433.

Associated Justifications have been revised.

We believe this revision should address the NRC comment.

x 3

1 i

/y 3.6.1.5,

\\_-)- CTS 4.7.A.3.a requires Reactor Building-to-Suppression. Chamber

^

vacuum break instrumentation.to be functionally tested per_ Table-4.7.A.

CTS Table 4.7.A requires Reactor Building-to-Suppression-Chamber vacuum breaker instrumentation-to have a functional test' once/ month.- ITS SR 3.6.1.5.2 requires s-functional test of each vacuum breaker every 92 days.

The Bases; states that this test involvcs cycling.the vacuum breaker from fully open to fully closed on a 92 day Frequency.

The cycling of the vacuum breaker on -a 92 day Frequency seems to meet the first part of CTS-4.7.A.3.a of exercising in accordance with CTS 1.0 MM.

However, cycling and/orJexercising the vacuum. breaker does not necessarily mean_that.it is.done using the system instrumentation; it could be done manually.

The ITS Bases-does not clarify this.

L2 does not provide sufficient discussion on this aspect to determine if this functional test of the instrumentation is being performed on

- a once/ month frequency (CTS 4.7.A.3.a) or a 92 day frequency gITS SR 3.6.1.5.2).

If the instrumentation functional test is being performed on a-once/ month frequency then a justification (7.'.)

for relocating this requirement was not provided.

If the instrumentation functional test is being performed on a 92 day Frequency, then a justification-(L) for changing the surveillance test 1 interval was not-provided.

See Item Number 3.6.1.5.7.

Q(

TVA Response After further review, we have decided to relocate the subject CTS 4.7.A.3.a instrumentation requirements to the TRM and corresponding implementing procedures for the TRM.

Changes to the TRM are controlled in accordance with 10 CFR 50.59.

Changes to TRM implementing procedures are controlled by site administrative processes.which include a review for 10 CFR 50.59 applicability.

DOC L2 has been deleted and the a new DOC LA2 added to1 justify the change.

i y"%

t k

4 n

r a.6.1.5 c "CTSf4.7.A.3.a requires Reactor Building-to-Suppression Chamber tvacuum breaker instrumentationito-be functionally-testediper

Table 4.7.A.

CTS 0able 4.7.A'requiresLReactor Building-to~-

Suppression Chamber. vacuum-breaker instrumentation to be calibrated everyyl8 months.

ITS SR 3'.6.1.5~.3 reqcires. verifying z

'the? opening _setpointJof:the vacur7 breakers.

L2 states"that vacuum brecker-instrumentation is requiredito be OPERABLE-to.

satisfy the setpoint. verification of ITS SR 3.6.1.5.3.

Verifying

-operability through actuation-of the' system doesinoticonstitutec

=j or meet the CTS requirement of~ calibrating the-system.- There is uno discussion or. justification for removing the instrumentation 4

- surveillance requirements for this'less-restrictive (LA) change.

TVA Response As indicated in the response to Item 3.6.1.5-6, a decision has-been make to relocate the subject CTS item ~to the TRM-and the procedures which implement the-TRM.

Changes to the TRM are controlled through the 10 CFR 50.59 process.

Changes'to TF0(

implementing procedures are controlled by site administrative processed which' include a review for 10 CFR 50.59 applicability.

3.6.1.5-8

(

=

'The LCO Bases for STS 3.6.1.7 requires the vacuum breakers to be closed except during testing or when performing their intended function.

ITS B 3.6.1.5 Bases LCO deletes.the exception for "During Testing."

ITS SR'3.6.1.5.1 verifies that the vacuum c

breakers are closed.

ITS=SR 3.6.1~.5.1 has two Notes associated With it.

Note 1 provides an exception-for testing and Note 2 prcvides an exception when tke valves'are performing'their intended function.

The deletionLof the phrase "during_ testing-or"Sfrom the--LCO Bases section negates Note 1.

See Item-Number-

~

3.6.1.6-6.

TVA Response The wording has been-reinstated in the in the ITS 3.6.1.5 LCO abases as= recommended'by1the NRC comment.

This change is

~~

iconsistent with'NUREG-1433.

7 i

I

.. /~NA-

~

5

+

.. _,. -, ~ _, - _.

.-;a-_

(;

3.6.1.5 !

STS B 3.6.1.7 Bases APPLICABILITi' justifies the operability of the Reactor Building-to-Suppression Evol vacuum breakers in MODES 1,

2 and 3.

Two conditions related to excessive negative pressure necessitate this MODE Applicability, an inadvertent actuation of the Suppression Pool Spray System and depressurization of the d::ywell.

ITS B 3.6.1.5 Bases APPLICABILITY states that, depressurization of the drywell could occur due to inadvertent a;tuation of the Drywell Spray System.

All mention of inadvertent actuation of the Suppression Pool Spray System inadvertent actuation has been deleted.

The justification does not adequately address this deletion, which could be a potential generic change.

TVA Response The ITE 3.6.1.5 Applicability Bases have been modified to be more similar to the NUREG-1433 Bases with regard to the effects of the containment spray systems as adapted for BFN-specific accider.c analyses results.

/~N (v) l r~'s i

I L,/

6

Ih ITS SECTION 3.6.1.6 I

Is_ /

SUPPRESSION CHAMBER-to DRYWELL VACUUM BREAKERS 3.6.1.6-1 STS B 3.6.1.8 Bases for RA B.1 and SR 3.6.1.8.1 describes an alternate method of verifying that the vacuum breakers are closed.

This method is to verify that a differential pressure of

'.5 PS!D between the suppression chamber and drywell is 0

maintained for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without :.a,;e up.

ITS 3 3.6.1.6.1 Bases for RA B.1 deletes this description and ITS B 3.6.1.6 Bases for SR 3.6.1.6.1 changes it to " monitoring'the decay rate of the Drywell-to-Suppression Chamber differential pressure."

Justification P63 states that this change is made since."There is no specific requirement to maintain a specified differential pressure for a specified time period without makeup.

The CTS markup adds Action B.

The justification (L2) for the addition of

?fTION B uses the exact same words as STS B 3.6.1.8 Bases RA B.1, which implies _that this alternate metnod was going to lue used for

/%

-both ITS 3.6.1.6 RA B.1 and SR 3.6.1.6.1.

-t TVA Response The acceptance criteria of SR 3.6.1.6.1 (see ITS Bases) and CTS 4.7.A.4.d provide for an citernate test method to demonstrate satisfactory vacuum breaker closure.

The method described in STS 3.6.1.8 is not feasible at BFN since all "make-up" cannot be isolated during plant operation.

Specifically, the Drywell Control Air System is a source of make-up that cannot be isolated when the unit is operating.

Hence, we have included, as the alternate test mechod for ITS SR 3.6.1.6.1, the test described in CTS 4.7.A.4.d.

This test can be performed without isolating make-up.

For clarification purposes and in response to the NRC comment, we have added a more explicit discussion of this alternate test method to the Bases for SR 3.6.1.6.1 and also to the Bases for ITS 3.6.1.6 Required Action B.1.

DOC L2 has also been revised to better addresa the alternate test method.

,DN t

\\.j 1

(s 3.6.1.6-2 l\\~,)

CTS 3.7.A.4.b states that a Suppression Chamber-to-Drywell vacuum breaker may be not fully closed so long as it is determined to_be not more than 3' open as indicated by position lights.

The markup indicates that this requirement will be Note 2 to ITS SR 3.6.1.6.1.

ITS SR 3.6.1.6.1 does not show a Not'e 2.

The ITS B 3.6.1.6.1 Bases for APPLICABLE SAFETY ANALYSIS, LCO, and SR 3.6.1.6.1 all have inserts which describe or discuss this requirement.

The discussion in SR 3.6.1.6.1 Bascs is not characterized as a Note 2.

These changes are all (esignated P55.

TVA Response A Note 2, which is a restatement of CTS 3.7.A.4.b criteria, has been added back into ITS SR 3.6.1.6.1 and into the STS mark-up.

The current licensing basis is that leakage equivalent to one drywell vacuun breaker opened to no more than a nominal 3* as confirmed by the position indicating lights is acceptable.

On this basis, an indefinite allowable repair time for a malfunction of the operator or disc (if nearly closed) of one vacuum breaker is justified.

The current JD P55 adequately describes this change.

q,)

3.6.1.6-3 See Item Number 3.6.1.5-9 TVA Response The ITS 3.6.1.6 Applicability Bases have been modified to be more similar to the NUREG-1433 Bases with regard to the effects of the containment spray systems as adapted for BF1-specific accident analyses results.

A similar change was made to ITS 3.6.1.5 as discussed in response to question 3.6.1.5-9.

3.6.1.6-4 STS SR 3.6.1.8 requires the vacuum breakers be verified t;osed every 14 days and after any discharge or steam or any operation causing a vacuum breaker to open.

ITS SR 3.6.1.6.1 deletes the second frequency (steam or operational opening).

The justification (P22) states that this frequency is not needed since ITS SR 3.0.1 would not be met and appropriate actions taken.

The justification also states that if conditions exist

/~'S for the vacuum breakers to be potentially opened, control room

(

)

operators would be alerted to the possibility and would ensure the vacuum breakers were closed at the completion of the 2

u

l

(~'T evolution.

The SR frequency assures that this is done.

Further

(,/

justification for these frequencies /justificationa is that they delay the entering into the appropriate actions based on statements made in the LCO Bases section (See Item Number

3. 6.1. 6-6).

The staff has determined based on the justification that this is a generic chat.ge which is beyond the scope of review of a conversion.

TVA Response CTS do not have SRs which require functional tests of the suppression chamber vacuum breakers after discharge of steam from the safety / relief valves or other operations that causes the vacuum breakers to open as discussed in JD P23.

The vacuum breakers are highly reliable and it is atypical to require additional testing for systems just because the system was exercised.

Furthermore, BFN CTS 3.7.A.6.a as carried forth as proposed ITS 3.6.2.6 requires the maintenance of a 1.1 psid drywell to torus pressure offferential which effectively prevents cycling d the vacuum breakers during normal operations or reactor 'c.ansients.

11ence, it would be highly unusual for the vacuum breakors to operate.,xcept during planned vacuum breaker surveillance testing.

Therefore, the addition of the second and third Frequencies of STS 3.6.1.8.2 to BFN ITS would be extraneous

(

due to the low likelihood of application.

i We consider that proposed ITS SRs 3.6.1.6.1, 3.6.1.6.2, and 3.6.1.6.3, which maintain consistency with the current licensing basis requirements, provide sufficient assurance of vacuum breaker operability.

Potential problems with the vacuum breakers would be readily detected by normal operational observations of the position indicators or by system performance problems such as if differential pressure could not be maintained.

In summary, in consideration of the above reasons and the justifications provided in P22 and P23, we have determined that BFN elects to adopt the ITS 3.6.1.6 SRs as currently proposed which are consistent with CTS requiroments.

Since addition of the subject STS Frequencies would be in excess of CTS requirements, the Staff's determination that the change is generic or beyond scope is inconsistent with the conversion guidelines of NEI 96-06.

O 3

/~~N 3.6.1.6-5 k

STS SR 3.6.1.2 requires a functional test of the vacuum breakers within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of any discharge of steam into the suppression chamber and following any operation that causes the vacuum breaker to open.

ITS SR 3.6.1.6.2 deletes those f requencies/ conditions.

The justification (P23) quotes a memorandum from C.E McCraken to C.I. Grimes, dated 9/8/92, providing the basis for the SR frequency.

The staff determined that this was sufficient justification to retain the frequencies / conditions in Revision 1 to NUREG 1433.

The licensee provides additional discussion for deleting these frequencies based on the NRC memorandum.

Further justifications is that they delay the entering into the appropriate actions *ased on statements made in the LCO Bases section (See Item Number

3. 6.1. 6-6).

The staff has determined that this is a generic change which is beyond the scope of review for a conversion.

TVA Response See the response to item 3.6.1.6-4 3.6.1.6-6 (s /

The LCO Bases for STS 3.6.1.8 requires the vacuum breakers to be closed except during testing or when performing their intended function.

ITS B 3.6.1.6 Dases LCO deletes the exception for "during testing."

ITS SR 3.6.1.6.1 has a Note associated with it that provides an exception during surveillance testing.

The deletion of phrase "during testing or" from the LCO Bases section negates the Note.

See Item Number 3.6.1.5-8.

TVA Response The words "during testing or" have been added to the IIS 3.6.1.6 LCO Bases in this revision package.

O 4

. - - _ _ =

a ITS SECTION 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE s

i 3.6.2.1-1 CTS 3.7.A.1.e requires, when the suppression pool temperature'is

> 110*F during the STARTUP CONDITION, HOT STANDBY CONDITION, or REACTOR POWER CPERATION, the reactor is scrammed.

The APPLICABILITY for ITS 3.6.2.1 is MODE 1, 2, or 3.

The discussion and justification for this change characterize this as a More Restrictive change.

STARTUP CONDITION and HOT STANDBY CONDITION

-are MODE 2 and reactor power of operation is MODE 1.

ITS 3.6.2.1 RA 3 requires the reactor be in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Thus, the ITS is less restrictive than the CTS.

TVA Response The C'ts 3.7.A.1.e applicability is when the suppression pool temperature is > 110' F during the STARTUP CONDITION, HOT STANDBY h

CONDITION, or REACTOR POWER OPERATION.

ITS Table 1.1-1 MODE

\\

definitions are slightly broader than the corresponding CTS (MODE) definitions.

In particular, MODE 3 in ITS would also envelop the HOT SHUTDOWN condition in CTS.

Therefore, we consider the ITS is slightly more restrictive since the applicability is broader.

This distinction is largely semantic since torus temperature limits are of primary concern when the reactor is operating at elevated powers.

CTS requires the reactor to be scrammed if suppression pool temperature exceeds 110'F; however, CTS does not require a cooldown to the equivalent conditions of MODE 4.

Therefore, ITS 3.6.2.1 RA D.3, which requires the unit to be in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months of exceeding 110

'F, is also more restrictive.

This is separately discussed in DOC M4.

3 6.2.1-2 2

CTS 3.7.A.1.d requires, when the suppression-pool water temperature is 2 105'F during testing of ECCS or relief valves, all testing is stopped and pool cooling is initiated.

The y

requirement to initiate pool cooling is moved to plant L

g procedures.

There is inadequate discussion and justification for moving the requirement to plant procedures; and the change-control process for the procedures is not described.

1

/'~'T TVA Response L)

CTS 3.7.A.1.d requires, when the suppression pool water temperature is > 105'F during testing of ECCS or rold.ef valves, all testing be stopped and pool cooling initiated.

The requirement to initiate pool cooling has been relocated to plant proceduros as discussed in DOC LA1.

As discussed in the BASES for ITS 3.6.2.1 Condition C, immediately suspending all testing will preserve the heat absorption capability of the suppression pool.

With the testing suspended, Condition A is applicable which requires the suppression pool temperature to be restored to 95' F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The CTS requirement to initiate pool cooling is considered an operational detail which would be performed via plant procedures in response to the requirements of ITS 3.6.2.1 Required Action A.2.

This level of detail need not be included as a specific TS requirement and is more appropriately prescribed in plant procedures.

The procedure for performing suppression pool cooling is the Operating Instruction (OI) for the RHR system which currently requires that suppression pool cooling be put in service anytime pool temperature exceeds 95* F.

Changes to OIs are performed in

/"'

accordance with plant administrative processes which include a

{TJ review for 10 CFR 50.59 applicability.

3.6.2.1-3 CTS 3.7.A.1.c requires, limits with the suppression pool water temperature > 95'F and CTS 3.7.A.1.d requires, limits with the suppression pool water temperature > 105'F.

ITS 3.6.2.1 Condition A and C also includes the criteria'any OPERABLE IRM channel 2 25/40 divisirns of full scale on Range 7.

The CTS markup documents "when any OPERABLE IRM channel is s 25/40 divisions of full scale on Range 7."

There is no justification for the difference between > 25/40 div.4sions in the ITS and

< 25/40 divisions in the CTS.

However, ITS seems that it was just an error and the CTS should be "; 25/40".

TVA Response TVA agrees with the NRC comment.

The CTS mark-up shows the equality symbol in the wrong direction.

The CTS mark-up has been corrected.

2

t

(}/

3.6.2.1-4

\\s-CTS 3.7.A.1 requires that any t;me there is irradiated fuel in 4

the reactor vessel, and the nuclear system is pressurized above atmosp'aeric pressure, the suppression pool temperature and water level are maintained within limits.

ITS 3.6.2,1 APPLICABILITY is MODES 1, 2, and 3.

The nuclear system can be pressurized above atmospheric pressure in MODE 4.

This change is a less restrictive change.

There is no discussion or justification for this less restrictive change.

TVA Response

-CTS 3.7.A.1 specifies suppression pool temperature limits for the unit when it is not in the cold shutdown condition.

Therefore, i

in CTS, when the unit is in condition equivalent to MODE 4 in ITS, there are no limits on suppression chamber temperature.

In MODE 4, the reactor can only be pressurized above atmospheric by mechanical moans such as during the reactor vessel hydrostatic leak test.

By definition, reactor coolant temperature must remain s 212*F to be in Mode 4.

Vessel hydrostatic tests are only conducted in association with refueling outages so Os suppression pool temperatures should always be normal.

In the event of a breach of the reactor coolant boundary while in a MODE 4 pressurized condition (mechanical pressurization), reactor pressure'would rapidly return to atmospheric since the coolant acts as an incompressible fluid.

Similarly, there is little heat inventory in the vessel available to transfer to the suppression pool due to the low temperature (Mode 4 limits temperature to s 212'F) of the bulk coolant particularly when considering that the torus heat absorption capability is sized for a reactor blowdown from a 100 percent operating state.

Hence, there is no basis for a suppression pool temperature requirement in MODE 4 in ITS.

A new DOC (L2)-has been added to address NRC's concern concerning the less restrictive aspect of the change.

_ v 3

e r'--'

r'~T-r v

t-t-

?--

s-e?-

y

.ss.

w 9-s w-i r a+ - eun'eme v

m--mi-.

+-'

w l

f?f,h) klisci"5 K'A 4

CTS 3.7.A.1 requires that when work is being done which-has the potential to drain the vessel, the suppression pool temperature and water level are maintained within limits.

This condition has been relocated to ITS 3.5.2.

There is no discussion or justification for this administrative change.

TVA Response The subject requirements of CTS 3.7.A.1 regarding suppression pool water level and temperature have been relocated to ITS 3.5.2 an justified in the DOCS for ITS 3.5.2.

Additionally, the Applicability statement for LCO 3.5.2 for MODE 5 has been revised-(Reference NRC comment 3.5.2-4) to explicitly include Operations with the Potential for Draining the Reactor Vessel (OPDRVs).

3.6.2.1-6 CTS 3.7.A.1 provides a requirement any time there is irradiated fuel in the reactor vessel, and the nuclear system is pressurized above atmospheric pressure, the " suppression pool temperature will be maintained within limits."

ITS 3.6.2.1 includes the O

CTS:

following less restrictive changes that are not included in the

a. ITS LCO 3.6.2.1.a requires the supprescion pool average temperature S 95'F when any OPERABLE in; rmediate range channel (IRM) is 25/40 divisions of full scale,

b. ITS LCO 3.6.2.1.b requires reducing THERMAL POWER until an OPERABLE IRM is 25/40 divisions of full scale on Range 7 when temperature 5 105'F.

c. ITS LCO 3.6.2.1.c requires suppression pool average temperature be <105'F when any OPERABLE IRM is 25/40 divisions of full scale on Range 7.

A justification for these additions is not provided.

TVA Response The justification for these additions is provided in the original submittal as Less Restrictive DOC L1 for ITS Section 3.6.2.1.

U l

l t

4 p-

['~)

3.6.2.1-7

\\

)

ITS 3.6.2.1 makes the following changes:

a.

ITS 3.6.2.1 Condition D deletes the STS words "but s 120'F".

b.

ITS 3.6.2.1 RA D.2 changes the STS wording from " Verify" to

" Monitor" and deletes "< 120*F".

ITS 3.6.2.1 Required Actions deletes the STS wording "AND E.2 c.

be in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ."

The justification for these changes states that STS 3.6.2.1 Action D could inadvertently be skipped if the average temperature was s 120*F but never discovered in the range oetween 110*F and 120*F.

If such an event occurred, Action D would no longer apply.

An unmonitored and sizeable temperature increase is not totally unlikely and has happened at BFN before.

Justification M4 justifies ITS 3.6.2.1 Actions D and E using the STS wording.

The staff finds justification P48 unacceptable.

Unmonitored and sizeable temperature increase should not occur.

The operators should be aware of what is going on in the plant.

In Addition, P48 contradicts M4.

The staff has also determined that this change is a generic change which is beyond the scope of

/~^

review for a conversion.

TVA Response TVA has revised the proposed ITS to use the subject STS provisions.

JD P48 has been deleted.

l l

1 l

1

{

j

\\m/

5

s 1

I i

BROWNS PERRY NUCLE AR PLANT. IMPROVED TECHNICAL SPECIFICATIONS i

SEC!10N 3.6 l

LISTOF REVISED PAGES UNIT 1 ITS SECDON (Revised pnpas anarked *RI)

Replaced 3.6 4 thea 3.64 with 3.6-4 thru 3.64 Revision i Replaced 3.611 thru 3.613 with 3.611 thru 3.613 Revidos I i

Replaced 3.616 with 3.616 hiske 1 Replaced 3.6 20 thru 3.6 23 with 3.6 20 thru 3.6 23 Raisk I'

Raplaced 3.6 37 with 3.6 37 Revision i Raplaced 3.641 with 3.641 Rev%e 1 Replaced 3.644 with 3.644 Raision 1

?

6 F

t U

L i

k h

i h

4 e

6 e

n,'-a w

--a,,

n--re-.-

em,

-,,w-.-

r.

-,.,w----,--y w--

e--

_,, - -,,e,ev-e,

,,w, w-s

-.. ~,,

w

,,, - -e,

,-we-

.n w er.,

oe,

l 1

O-ITS SECTION 3.6.2.2 a

SUPPRESSION POOL WATER LEVEL t

3.6.2.2-1 See Item Number 3.6.2.1-4 i

WA Response A new DOC L3 has been added to address the NRC comment.

The disposition is similar to that discussed in the response to Item 3.6.2.1-4 as applied to suppression pool water level.

3.6.2.2-2 See Item Number 3.6.2.1-5 WA Response The subject requirements of CTS 3.*l.A.1 regarding suppression pool water level and temperature have been relocated to ITS 3.5.2 as justified in the DOCS for ITS 3.5.2, Additionally, the Applicability statement for LCO 3.5.2 for MODE 5 has been revised (Reference NRC comment 3.5.2-4) to explicitly include Operations with the Potential.for Draining the Reactor Vessel (OPDRVs).

1

,, - ~..

.--y n

e--

r w

r--

- - Tr

.. _~

O ITS SECTION 3.6.2.3 k_-

RilR SUPPRESSION POOL COOLING i

3.6.2.3-1

[

ITS 3.6.2.3 adds an ACTION C which states that with three or more RHR suppression pool cooling subsystems inoperable restore required RHR Systems to OPERRBLE status in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

This change also modifies ITS 3.6.2.3 ACTION D (STS 3.6.2.3 ACTION C).

The CTS doas not have this requirement instead.he CTS under these conditions would require a shutdown in-accordance with 1.0.c.1, This change since it involves a total loss of function which-l requires a shutdown per STS 3.6.2.3 ACTION C is potentially a generic change which is beyond to review of a conversion.

The change is unacceptable, j

1596 Response The BFN design with respect to suppression pool cooling is different from the generic BWR-4 design as described in the

- i NUREG-1433 Bases.

The generic BWR-4 has two_ subsystems each containing two pumps and one heat exchanger contrasted with the O.

I

)

BFN design of four pumps with four heat exchangers.

For the

\\- /

generic BWR-4, if two subsystems were lost, there would be no suppression pool cooling capability.

At BFN, since each RHR pump has its own separate heat exchanger, there are four RHR subsystems instead of the generic BWR-4 two subsystems.

ACTION C corresponds to the case for which only one OPERABLE subsystem is remaining and some suppression pool cooling capability remains unlike the generic BWR-4 for which there would be no suppression pool cooling capability.

ITS ACTION D corresponds to the case for which-there is no suppression pool cooling capability.

Therefore, ACTION C allows for plant specific design differences at"BFN for which there remains some suppression pool cooling capability with three subsystems inoperable.

The eight hours allows a reasonable time to restore an additional-subsystem prior to entering ITS ACTION D.

This is consistent with proposed, Residual Heat Removal Service Water (RHRSW) requirementsJin ITS 3.7.1.

l i

E D

1-l 9

w s

g y-w w

, +-

n- - - -,.

('~N 3.6.2.3-2

)

CTS 3.5.B.1 requires the RHR System to be OPERABLE anytime there is irradiated fuel in the reac. tor vessel, the reactor vessel pressure is above atmospheric pressure, and prior to STARTUP from a COLD SHOTDOWN condition.

ITS 3.6.2.3 changes the APPLICABILITY to MODES 1, 2, and 3.

The reactor vessel pressure can be pressurized above atmospheric pressure in MODE 4.

This change is a less restrictivo change.

There is no discussion or justification for this less restrictive change.

TVA Response MODE 4 requires the reactor temperature to be < 212*F and, thus, the reactor coolant would be in an incompressi5le liquid state.

If the nuclear system is pressurized during MODE 4, it is by mechanical means since no steam is present.

In the event of a breach of the reactor coolant boundary while in a MODE 4 pressurized condition, the reactor pressure would rapidly return to atmospheric with a very small associated loss of reactor coolant.

The pressurized condition is not capable of causing large amounts of reactor coolant to be lost or causing large heat inputs to the suppression pool.

llence, the condition is essentially the equivalent of a MODE 4 unpressurized condition.

(T Thus, it is concluded that the MODE 4 pressurized condition does

(,)

not warrant any additional RHR requirements for the MODE 4 condition beyond those specified by ITS 3.4.8, 3.5.2, and 3.10.1.

To address NRC's concern regarding the Less Restrictive aspect of the change, a new DOC L3 has been added.

3.6.2.3-3 CTS 3.5.B.5 and 3.5.B.6 specify the remedial actions to be taken if one or two RHR pumps (containment cooling mode) or associated heat exchangers, respectively, are inoperable.

Operation may continue for 30 days provided that the associated diesel generator is OPERABLE.

This requirement has been relocated to ITS 3.8.1.

There is no discussion or justification for this administrative change.

TVA Response As noted in the mark-up for CTS 3.5.B.5 and 3.5 B.6, the requirement for the diesel generators to be OPERABLE has been relocated to ITS 3.8.1.

Refer to DOC L6 for ITS 3.8.1 for the 7-x justification.

(v) 2

h l

/^'s

~

ITS SECTION 3.6.2.4 t

t

)

\\s/

RIIR SUPPRESSION POOL SPRAY 3.6.2.4-1 i

CTS 4.5.B.2 requires an air test be performed on the drywell and torus headers and nozzles every 5 years.

CTS 4.5.B.2 allows substituting a water test for the air' test.. Even though the ITS retains the surveillance, the details of the methods of performing the surveillance test requirements (air test or water test) 'have been relocated to the Bases and procedures.

ITS B.3.6.2.4 Brases SR 3.6.2.4.2 do not specify which test can be used (air and water) for these SRs. _Thus, the details have not been relocated to the Bases.

See Item Number 3.6.2.4-2.

4 TVA Response ITS SR 3.6.2.4.2 verifies the suppressicn pool spray nozzles are unobstructed.

The detailed methods used to perform this SR (use f-~s of air or water) are immaterial to the completion of the SR as

('s) long as the methods can verify that the nozzles are unobstructed.

Therefore, it is appropriate that details of the test methods be provided in the plant procedure which implements SR 3.6.2.4.2.

This relocation is consistent with 10 CFR 50.36 criteria.

Changes to plant SRs are controlled in accordance with site administrative processes which include a review for 10 CFR 50.59 applicability.

3.6.2.4-2 CTS 4.5.B.2 requires an air test be performed on the drywell and torus headers nozzles every 5 years.

CTS 4.5.B.2 allows substituting a water test for the air test.

Even though the ITS retains the surveillance, the details of the air and water tests are moved to the ITS Bases and procedures which are controlled by licensee controlled programs.

There is inadequate discussion and justification for moving the details of the air and water tests

.to Bases and plant procedures, the procedure is not identified, and the change control process for the procedures is not described.

See Item Number 3.6.2.4-1.

(

1

g' ~'

TVA Response i

See the response for NRC comment'3.6.2.4-1.

The same reasoning is applicable.

t 3.d.2.4-3 See Item Number 3.6.2.3-2.

TVA Response MODE 4 requires the reactor temperature to be < 212'F and, thus, the reactor coolant would be in an incompressiBIe liquid state.

If the nuclear system is pressurized during MODE 4, it must be by mechanical means since no steam energy is available.

In the-event of a breach'of.the reactor coolant boundary while in a MODE 4 pressurized condition, the reactor pressure.would rapidly return to atmosphoric with a very small associated loss of reactor coolant.. The pressurized condition is not capable of causing large amounts of reactor coolant to be lost or causing large heat inputs to the suppression pool air space.

Therefore, the condition is essentially the equivalent of MODE 4 unpressurized condition.

Thus, it is concluded thte the MODE 4

(

pressurized condition does not warrant any additional RHR.

's,)) requirements for the MODE 4 condition beyond those specified by ITS 3.4.8, 3.3.2, and 3.10.1.

To address NRC's co'ncern regarding the Less Restrictive aspect of the change, a new DOC L3 has been added.

3 '. 6. 2. 4 -4 See Item Number 3.6.2.3-3 TVA Response, Jus noted in the mark-up for CTS 3.5.B.5 and 3.5.B.6, the requirement for the diesel generators to be OPERABLE has been relocated to ITS 3.8.'1.

Refer to DOC L6 for ITS 3.8.1 for the justification.

I

.- u).

l 2-

,. m

ITS SECTION 3.6.2.5 O

RESIDUAL IIEAT REMOVAL (RIIR) DRYWELL SPRAY 3.6.2.5-1 See Item Numbers 3.6.2.4-1 and 3.6.2.4-2 t

TVA Itosponse ITS SR 3.6.2.5.2 verifies the suppression pool spray nozzles are unobstructed.

The detailed methods used to verify this SR (air i

I or water) are immaterial to the completion of the SR as long as

- the methods can verify the fact that the nozzles are unobstructed.

Hence, it is appropriate that details of the test be provided in the plant procedure which implements SR 3.6.2.5.2.

This relocation is consistent with 10 CFR 50.36 criteria.

Changes to plant-.SRs are controlled in accordance with site administrative processes which include.a review for 10 CFR 50.59 applicability.

O

.6.2.5-2 3

See Item Numbers 3.6.2.4-1 and 3.6.2.4-2 TVA Response See the response for the previons item.

The same reasoning is applicable.

3.C.2.5-3 See Item Number 3.6.2.3-2 TVA Response MODE 4 requires the reactor temperature to be $_212*F and, thus, the reactor coolant would be in an incompressible liquid state.

If the nuclear system is pressurized during MODE 4, it must be by mechanical means since no steam energy is present.

In the event of a breach of the reactor coolant boundary while in a MODE 4 pressurized condition, the reactor pressure would rapidly return to atmospheric with a very small associated loss of reactor 4

\\

coolant.

Therefore, the pressurized condition is not capable of 1

i O,causinglargeamountsreactorcoolanttobelostorprovide significant: heat input to the_drywell air space._ Thus, there'is -

[

no need to relocate the_ subject MODE 4 CTS requirement for j

drywell" spray to-the.ITS.

j

.To address-NRC's concern regarding the Less Restrictive aspect of c !

-this' change,-a new DOC L3 has been added.

i 1

f 3.6.2.5-4 ITS B 3.6.2;5 Bases has two typographical errorst on page 609 of-939, a line should be between the end of the BACKGROUND Section-and the APPLICABLE-SAFETY ANALYSIS Section; and on;page 612 of-l

,939 " Surveillance Requirements _ -(Continued)" should be moved to.

- f top of page and "SR 3.6.2.5.2 L(continued)" should be deleted, and paragraphs made into 1 paragraph.

"TVA Mesponse'

'"% agrees. with the NRC review comment.

The typographical errors i

. ave been corrected.

i

~

i.

i b

j p

k r

a-I r

-I i

t

+

n-y E

-5 s '

i

.a -

.a -&--

..c-

.u

.a.

l..

ITS SECTION 3.6.2.6 DRYWELIrto-SUPPRESSION CIIAMBER DIFFERENTIAL, PRESSURE I

i 3.6.2.6-1 CTS 3.7. A. 6.a. (1) is Applicable when the drywell to suppressicn chamber differential pressure is established within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of achieving operating temperature and pressure, and the differential pressure may be reduced to less than 1.1 psid 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled shutdown.

ITS 3.6.2.6 APPLICABILITY is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15% RTP prior i

to the next scheduled reactor shutdown.

This change modified the APPLICABILITY.

The justification (L1) states that "As long as reactor power is below 15% RTP, the probability of an event within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a shutdown is low.

This statement is confusing, and does not address the change.

The less restrictive change is going from the CTS requirements of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from 15% RTP on r$

startup and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to decreasing to less than 1% RTP on

'( j startup and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to shutdown to the ITS requirement of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from 15% RTP on startup and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to decreasing to less than 15% on shutdown.

The justification is incomploto in that it does not address the time required to go from 1% RTP to 15% RTP plus the addition of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The same is true on the shutdown requirement.

TVA Response DOC L1 points out the probability of an event occurring (typically a design basis LOCA) during the time period of power transition between the CTS requirement (about 1% RTP) and the ITS requirement (15% RTP) is very small.

The time spent during reactor start-ups or shutdowns between 1% RTP and 15% RTP is minimal (typically less than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ).

Also, Drywell-to-Suppression chamber d/p control is typically relinquished only just prior to refueling outages and reestablished after each refueling outage (and possibly during 1nfrequent forced outages if a-containment entry is necessary).

Therefore, BFN would expect-to be in the relaxed ITS realm (between 1% RTP and 15%

RTP) for approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months every 18 months or 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months per

!v 1

-e nw--

w

f'^N year.

This change is, therefore, insignificant and will result

) in BFU consistency with NUREG-1433.

NOTESt The probability for a large LOCA at BFN is 5.93E-4/yr.

The probability for any LOCA resulting in core damage at BFN is 4.41E-7/yr The probability of being in the relaxed condition is 9.13E-4/yr.

3.6.2.6-2 CTS 3.7.A.6.b allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the drywell to suppression chamber differential pressure to within limits before requiring a shutdown, which requires the plant in Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS 3.6.2.6 ACTION A and B allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore differential pressure and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reduce thermal power to s 15% RTP respectively.

Since the ITS APPLICABILITY only applies above 15% RTP, there is no neod to perform a shutdown to COLD SHUTDOWN.

However, there is inadequate diacussion and justification for changing the CTS AOT from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to the ITS time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and no justification for the

-~s

(

)

more restrictive change of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reduce thermal power to 6

\\- /

15% RTP, TVA Response The difference between the CTS AOT of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the ITS AOT of 0 hours0 days 0 hours 0 weeks 0 months is not explicitly addressed in DOC L2 since the change is insignificant and was chosen to be consistent with NUREG-1433.

This minimal change in the time (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) will have no measurable effect on overall plant safety.

Additionally, there is a new ITS requirement to reduce power less than 15% RTP within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months versus the CTS requirement to be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the Required Action is not met.

While there is a more restrictive element concerning the ITS time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reduce power below 15% RTP, on the whole the CTS requirement to be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is more restrictive than the proposed ITS requirement as discussed in DOC L2.

The allowed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to be below 15% power is reasonable based on operating experience and can be achieved in an orderly A separate M DOC for this aspect is not deemed necessary manner.

since the overall change in going to the ITS is less restrictive.

1

'q, 2

1 p

ITS SECTION 3.6.3.1 V

CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM P

3.6.3.1-1 CTS 4.7.C l.a requires the solenoid operated air / nitrogen valves be cycled in accordance with the specification 1.0.MM (IST Program).

This requirement is being relocated to the IST Program.

The change control process for_the IST Program is not specified.

WA Response The IST program is described in ITS 5.5.6.

The details of the IST program are currently contained in Site Standard Practice (SSP)-8.6, "ASME Section XI Inservice Testing of Pumps and Valves", which implements ASME Section XI requirements to verify operational readiness of pumps and valves required for safety.

Changes to SSP-8.6 are controlled by site administrative processes which include a review for 10 CFR 50.58 applicability.

t 3.C.3.1-2 CTS 3.7.G.5 requires that primary containment pressure be limited to 30 psig during repressurization following a LOCA.

The requirement is moved to emergency operation procedures which are controlled by licensee controlled programs.

WA Response The Emergency Operating Instructions are required to be established, implemented, and maintained by ITS 5.4.1.b.

The LOIs are controlled by SSP-12.16, " Emergency Operating Instruction Control" and described in the EOI Program Manual (currently 8 volumes).

Changes to these procedures are controlled by site administrative processes which include a review for 10 CFR 50.59 applicability.

The subject limitation is also stated in FSAR Section 5.2.6.2.

Changes to the FSAR are reviewed in accordance with 10 CFR 50.59.

A 1

1 l

~ '

'3.6.3.1-3 i

ITS B 3.6.3.1 Bases BACKGROUND states that the CAD system is shared by Units 1, 2, and 3.

ITS 3.6.3.1 ACTIONS only reflect the remedial action to be taken for one unit, not all three.

There is no just3fication or discussion as to why the ITS only ITS only reflects the actions to be taken for only one unit rather than all three.

TVA Response The CAD system consists of two common nitrogen storage tanks (and associated equipment) which serve all1three units.- The cystem i

consists of a common distribution header, unit-specific branch-off lines to the respective units, and unit-specific equipment.

Since the CAD system is required in only Modes 1 and 2, if any unit was in a condition for which CAD operability was required (Modes 1 or 2), then all common CAD equipment needed to ensure the CAD system is OPERABLE for that unit _would be required-to be OPERABLE.

For example, if Units 2 and 3 were both in Mode 4

1, then the CAD systems specific to each unit would be required in addition to common equipment required by both Units 2 and 3.

If only Unit 2 was in Mode 1 (Units 1 and 3 in Mode 3 or lower),

then_the commor. CAD equipment (in addition to-the unit-specific i

(}

equipment) required for the Unit 2 CAD system to be OPERABLE _

g j would be_ required.

Therefore, it is unnecessary to specify in a particular units' TS, actions for another unit.

Hence, the ITS as currently written will er.sure the CAD equipment needed for each unit is' OPERABLE whenever required by ITS 3.6.3.1.

v 2

TrS SECrlGN 3.6.3.2 i

PRIMARY CONTAINMENT j

OXYGEN CONCENTRATION i

1 83.6.3.2 i

STS 3.6.3.2, Drywell Cooling System Fans is deleted from the ITS.

The ITS is renumbered such that ITS 3.6.3.2 in Primary 1

Conteinment Oxygen Concentration.

The discussion and i'

justification'(05) for deleting Drywell Cooling System fans states that the BFN specific analysis does not assume Drywell Coo'.ing System fans are available to assure adequate mixing.

HoWLvor, thp D&Les for STS 3.6.3.2 APPLICABLE SAFETY ANALYSIS states that tydrogen is released to the drywell within 2 minutes following a DM LOCA.

Natural circulation phenomena results in a gradient concentration difference-in thi drywell and suppression-chamber.

"Even,thm.gh this gradient is acceptably small.and no j

credit for mechanical mixings was assuned in the analysis, two drywell cooling aystem fans are required to be OPERABLE i

(typically four to six fans are required to keep the drywell cool during operation in HODE 1 or 2) by this LCo."

The staff has I

determined that this system meets Criterion 3 of 10 CFR 50.36 (c) (2) (ii) (C).

Thus.in light of the STS Bases discussion, PS is inaccur..te and incomplete.

TVA Response The Drywell Cooling System Fans are not credited in any transient er accident analysis, are not safety-related, and-are not considered an Engineered Safety Feature at BFN.

They are, i

therefore, not designed to function after a loss of coolant accident.

For those reasons the Drywell Cooling System Fans do l

- not meet Criterion 3 of 10 CFR 50.36(c) (2) (ii) (C) and it is not bppropriate to include the Drywell Cooling System Fans in the BFN ITS.

P f

..f 1

c.y+

e e.W;. mwe -

v.,-,-a.-

=t%--re---emswmr e's-9e F vr-g ' + w w

-e qe ?.g w -

+ey wwwwwvra---rsw+--=-9 M

r*9ev'm+*'t- - * ' = = - WM N w'

l r

3.6.3.2-1 i

N,)g CTS 3.7.A.S.a requires reducing the containment atmosphere to less than 4% oxygen with nitrogen gas.

This requirement is not retained in-ITS 3.6.3.2.

The requirement is moved to plant.

)

procedures which are controlled by licensee controlled programs.

In addition, the justification does not provide adequate discussion on why this requirement may be-relocated to plant procedures.

i l

TVA Response-ITS LCO 3.6.3.2 requires primary containment oxygen concentration 7

to be < 4.0 volume percent similar to CTS 3.7.3.5.a.

The method employed by BFH to control oxygen concentration is by inerting the drywell with nitrogen gas from the Containment Inerting i

System as described in Section 5.2 of the FSAR.

Review of changes to plant design features as described-in the FSAR are performed in accordance with 10 CFR 50.59.

Each respective unit has unit-specific system operating procedures for inerting the drywell.with' nitrogen (01-76, " Containment Inerting System").

The details of valve lineups and procedures for inerting are contained in this OI.

Changes to OIs are governed by the plant i

administrative procedures which include a review for 10 CFR 50.59 applicability.

The removal of this level of detail is consistent O

with NUREG-1433 and the NRC Final Policy Statement on Technical Specification Improvements of July 22, 1993, since the parameter of-concern is oxygen concentration.

3.6.3.2-2 CTS 4.7.A.5.a and 4.7.A.S.b requires that the methods to measure primary containment oxygen concentration account for instrument uncertainty and calibrating the instrument each refueling cycle.

These requirements are not retained in ITS 3.6.3.2.

These requirements are moved to plant procedures which are controlled by licensee' controlled programs.

In addition, the justification does not provide adequate discussion on why these requirements may be relocated to plant procedures.

TVA Response CTS 4.7.A.5.a and 4.7.A.S b will be relocated to the TIW and TRM impicmenting procedures. ~ Changes to the TRM are governed by the 10 CFR 50.59 process.

Changes to TRM implementing procedures are made.in accordance with site administrative processes which

'nclude a review for 10 CFR 50.59 applicability.

Either the j

-installed' instrumentation covered in the TRM or grab samples 2

~

)

\\

(~'s analyzed by lab?ratory instrumentation are satisfactory to comply

(

)

with the weekly SR 3.6.3.2.1 for measuring oxygen concentration.

K/

The removal of this level of detail is consistent with NUREG-1433 and the NRC Final Policy Statement on Technical Specification Improvements of July 22, 1993, since the parameter of concern is i

oxygen concentration, not the measurement technique.

DOC LA2 has been revised to reference the TRM.

3.6.3.2-3 CTS 3.7.A.S.c and CTS 4.7.A.5.c require that if plant control air is used to supply the pneumatic control system, the reactor is not started or if the reactor is operating the reactor is brought to COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This requirement is not retained in ITS 3.6.3.2.

The CTS requirement and associated Surveillance Requirements are moved to the TRM.

The change control process for the TRM is not discussed in the justification.

It also appears this is a change to the current licensing basis.

No justification was provided for relocating the CTS requirements to the TRM.

TVA Response

/

The drywell control air compressors are the normal supply for s'

pneumatic control within the drywell.

There are two drywell control air compressors which take suction from the drywell atmosphere.

These compressors are highly reliable and are powered from a diesel backed AC power supply.

There is also an additional backup supply from the CAD system which was not installed when the plant was originally licensed.

The only instance that plant control air would be used for drywell service during power operation is when both drywell air compressors are failed and the CAD system cross-tie is not available.

Therefore, if plant control air is used as a supply for pneumatic control for drywell service, this configuration would be a highly unusual, short-term line-up.

In this case, the concern would be for inadvertently increasing the oxygen concentration inside the drywell while it was inerted, since the plant control air system uses air as the pneumatic control medium.

Since SR 3.6.3.2.1 ensures the primary containment oxygen concentration is maintained within limits and there are no safety related functions performed by the drywell control air compressors (or plant control air, if so aligned), it is acceptable to relocate the CTS requirement to the TRM.

Changes to the TRM are governed by the 10 CFR 50.59 process.

p)

%_,)

3

l l

)

3.6.3.2-4 I

CTS 4.7.A.5.a requires primary containment oxygen concentration be measured and recorded daily.

Thu recording requirement is not retained in ITS 3.6.3.2.

The requirement to recorf the containment oxygen concentration is relocated to plant procedures i

which are controlled by licensee controlled programs.

In addition, the justification does not provide adequate discussion on why this requirement may be relocated to plant procedures.

1 TVA Response Logging of data required for the performance of surveillance tests is considered routine practice which is required by plant testing instructions and quality assurance requirements.

Therefore, it is not required to retain a specific requirement to record data in the equiv31ent ITS SR.

Recording of the oxygen concentration for the performance of ITS SR 3.6.3.2.1 will be located in the plant procedure which implements ITS SR 3.6.3.2.1.

Changes to SR procedures are controlled by plant administrative processes which include a review for 10 CFR 50.59 applicability.

l 3.6.3.2-5 ITS B3.6.3.3 Bases BACKGROUND section refers to the drywell cooling system fans (STS 3.6.3.2) as one means of inerting, maintaining oxygen concentration and mitigating the events that produce hydrogen in Primary Containment.

ITS B3.6.3.2 Bases BACKGROUND deletes this reference to the Drywell Cooling System Fans based on the deletion of STS 3.6.3.2 from the ITS.

Item

-Number S3.6.3.2-1 questions this STS. deletion.

This item will be pursued in conjunction with Item Number S3.6.3.2-1.

TVA Response See the response to Item S3.6.3.2-1.

i l

l i

O l

u i

L 4

~

k

'N ITS SECTION 3.6.4.1

,)

SECONDARY CONTAINMENT 3.6.4.1-1 CTS.3.7.C.1, 3.7.C.2 and 3.7.C.3-specify that secondary containment, reac tor zone secondary containment, and refue)ing zone se ondary containment integrity be maintained, respectively.

Secondary containment, reactor zone secondary con

wment, and refueling zone secondary containment integz is described and defined in CTS 1.0.P.3 respectively.

ITS 3.6.4.1 1.0.P.1,Hl.0.P.2, e 4 does not require reactor zone or refueling zone secondary containment integrity be maintained.

The justification states that a combined secondary containment integrity test will demonstrate TS OPERABILITY.

It also states that due to leakage between zones, zone integrity is difficult to maintain.

Since the current' licensing basis requires integrity in all areas, the justification about difficulty in maintaining zone integrity due to leakage is unacceptable.

The deletion of these requirements based on

[~ )\\

this justification is a beyond scope of review for this

(_-

conver.sion.

In addition, the deletion of these requirements would constitute a less restrictive change, not a more restrictive change.

The requirements and description / definition of secondary containment integrity (OPERABILITY) found in CTS 1.0.P should as a minimum be relocated to the Bases for ITS 3.6.4.1 and appropriate changes to ITS 3.6.4.1 ACTIONS and SRn be made to accommodate the an1 secondary containment design.

Thus the change now becomes an administrative change.

See Item Numbers 3.6.4.1-4, 3.6.4.1-6,'3.6.4.1-7 and 3.6.4.1-8.

TVA Response Zonal isolation within the secondary containment was part of the original reactor building design but, in practice, is not utilized.

Rather, for the purposes of maintaining secondary containment, the whole of the four zones (3 reactor zones and refuel zone) exterior boundaries is considered the secondary containment boundary.s_ Hence, the zonal-concept has been abandoned and the CTS provisions 3.7.C.3 and 3.7.C.4, and associated definitions (1.0.P.1, 1.0.P.2 and 1.0.P.3) have been deleted in the proposed ITS.

'y Since actual operating practice is to treat the secondary

/,

i containment.as a single collective volume, the zonal CTS

\\--

provisions are enveloped by the macroscopic CTS secondary 1

r

()

containment requirements and, hence, the CTS requirements for zonal isolation are not needed.

Additional detail is i

i

\\- '

provided below.

The secondary containment is one contiguous volume for the three BrN units with interconnecting flow paths.

The 1

reactor building is divided into four normal HVAC ventilation zones (3 reactor zones plus a refueling zone) with separate normal IIVAC systems.

A secondary containment isolation signal can be generated from within any of the four ventilation zones or manually from the control room.

An isolation signal from a reactor zone will cause the normal HVAC in tha. area and the refuel floor to isolate, that zone's secondary containment isolation valves to isolate, and the standby gas treatment (SGT) system to initiate.

The othar zones are not affected.

Similarly, an isolation signal from the refuel zone will cause the normal HVAC a. only that area to isolate, that zone's secondary containment isolation valves to isolate and the SGT system to initiate.

The other zones are not affected.

If in either scenario, a high level of radiation is detected in another zone (s), that zone (s) will also isolate until ultimately all four zones could isolate.

The SGT system is fully capable of performing its' required function for the whole of the four zones or any portion as described above, i

The discussion in 3.6.4.1 DOC M5 regarding the difficulty in maintaining zonal integrity was provided as the reason for why the zonal concept has been abandoned rather than as a justification for demonstrating the change is acceptable.

The justification for acceptability is based on the integrity of the overall secondary containment boundary as demonstrated by testing.

Under current practice, a secondary containment breach (to the environs) or a non-operable secondary containment for any zone is considered to be a non-operable secondary containment for the entire reactor building.

This is considered a more restrictive change since the CTS flexibility of being able to remove a zone from the secondary containment has been deloted.

liowever, as explained above, in actual practice there are no operating activities which credit the ability to establish zonal separation.

The overall requirement for secondary containment operability (CTS 3.7.C.1) is contained in ITS LCO 3.6.4.1 and the actions for when it is not operable (CTS 3.7.C.2) j have been retained in Required Actions A, B,

and C and will i

be applied uniformly to all zones.

The definitions for

(~'T zonal integrity (CTS 1.0.P) are already contained in ITS by

()

the proposed SRs and LCOs.

For example, CTS 1.0.P.1.a is l

2 i

_,1

O captured by ITS SR 3.6.4.1.1 and SR 3.6.4.1.2.

. CTS 1.0.P.1.b is captured by ITC SR 3.6.4.1.4 and LCO 3.6.4.3.

CTh 1.0.P.1.c is captured by ITS LCO 3.6.4.2.

Definitions CTil 1.0.P.2 and 1.0.P.3 are captured by the same ITS sectioni since secondary containment is now considered one vo,ume.

As discusst d above, the proposed ITS are a simplification of CTJ-and reflect actual plant practice by formally abandoning CTU provisions which would allow interzonal separation.

The 1T1' provisior.s treat secondary containment as a single integral building which is consistent with NUREG-1433.

Therefore, BFN does not consider this change beyond scope or less restrictive.

3.6.4.1-2 CTS 4.7.C.l.a requires performing the secondary containment surveillance requirement to verify maintaining 1/4 inch of water vacuum under calm wind conditions.

This requirement is moved to ITS B.3.6.4.3 Bases BACKGROUND Section and plant procedures which are controlled by licensee controlled

programs, o

As noted in the NRC comment, the requirement regarding calm wind conditions is relocated to ITS 3.6.4.3 Sackground Bases and renamed as " neutral" wind rwnditions.

Additionally, for clarification, the requirement.Or neutral wind conditions

(< 5 mph) has been added to the SR 3.6.4.1.3 and 3.6.4.1.4 Bases and will also be included in the procedures which implement these SRs.

Changes to SR implementing procedures are controlled by plant administrative processes which include a review for 10 CFR 50.59 applicability.

Changes to the Bases are controlled by ITS 5.5.10, " Technical Specifications (TS) Bases Control Program" which requires a 10 CFR 50.59 review.

3.6.4.1-3 CTS 4.7.C.1.a requires performing the secondary containment surveillance requirement to verify maintaining 1/4 inch of water vacuum under calm. wind conditions. (< 5 mph) with a system leakage rate of <12,000 cfm.

This requirement is retained in:ITS SR 3.6.4.1.4 with the exception of the " calm

/

Y wind condition."

This has been relocated to ITS B 3.6.4.3 L[

, Bases BACKGROUND Section and changed to " neutral wind 3

z

)

r)

conditions."

No justification has been provided of changes.

i made to'ITS SR 3.6.4.1.4 and ITS Associated Bases to require this current licensing basis requirements or show that the

{

ITS SR is equivalent to the CTS SR.

In addition, no l

justification has been provided to show that calm wind conditions (< 5 mph) is equivalent to neutral wind conditions which the staff considers O mph.

TVA Response In response to the NRC co.nment, neutral wind has been clarified in ITS 3.6.4.3 Background Bases to mean less than

i 5 mph as currently defined in CTS 4.7.C.l.a.-

Also, as discussed in comment 3.6.4.1-2, the requirement for neutral wind conditions has been added to the SR 3.6.4.1.3 and 3.6.4.1.4 Bases.

DOC LAl has been revised to clarify this poit. '.

3.6.4.1-4 CTS 4.7.C.2 requires operating the Standby Gas Treatment System after a secondary containment violation is identified and the affected zones are isolated from the remainder of

/~'

secondary containment to confirm the SGT's ability to

(,}/

maintain the proper vacuum.

This requirement is moved to plant procedures-which are controlled by licensee controlled programs.

It is unclear from the justification and discussion as to why this requirement is retained, but relocated to plant procedures.

Testing redundant systems was deleted from TS years ago In addition, relocating this requirement to plant procedures provides additional justification for the staff concern in-Item Number

?.6.4.1-1.

TVA Response As discussed.in item 3.6.4.1-1, the provisions for zonal' separation have been abandoned.

The CTS mark-up has been revised and DOC LA2 has been eliminated since it pertained to. implementing zonal separation.

Since the zonal concept is not used by BFN, the capability to isolate selected secondary containment zones no longer could be used to-continue operation in the non-affected zones by operating the SGT system.. The LCO for ITS 3.6.4.1 would not be met ~

and Required Actions would be taken which would require all zones to be placed in Conditions for which the LCO did not apply.

The-basis'for this change.is described in DOC M5 as s

-(

1-a more' restrictive change since-continued operation in the d

non-affected zones would not be allowed.

4

"'s 3.6.4.1-5

(\\')

CTS 4.7.C.1.a requires performing the secondary containment surveillance cach refueling outage prior to refueling.

ITS SR 3.6.4.1.3 and ITS SR 3.6.4.1.4 extends the frequency by changing to testing on a STAGGERED TEST BASIS, which means all three SGT subsystems are tented every 2 refueling cycles.

ITS SR 3.6.4.1.3 and ITS SR 3.6.4.1.4 reduces the STI based on Generic Letter 91-04.

Generic Letter 91-04 provides justification for changing the refueling outage and associate SR frequencies from 18 months to 24 months.

This generic letter does not apply in this case. Therefore, the justification for this less restrictive change is unacceptable.

TVA Responso The references to NRC Generic Letter 91-04 have been eliminated from DOC L1 for ITS 3.6.4.1 and additional justification added to DOC Ll.

Operating experience has shown an 18-month staggered test interval is acceptable from a reliability standpoint and extending the tesc interval reduces the chances for an unnecessary plant transients due to testing (as explained in revised DOC L1).

3.6.4.1-6 ITS 3.6.4.1 RA C.1 is modified by a Note stating that ITS LCO 3.0.3 is not applicable if moving fuel assemblies in MODES 4 and 5.

The S?!S was developed for a single unit not for a multi-unit plant with a shared secondary containment.

Thus this Note to ITS 3.6.4.1 may not be applicable for the BFN design and the CTS.

See Item Numbers 3.6.4.1-1, 3.6.4.1-7, and 3.6.4.1-8.

TVA Responso ITS LCO 3.0.3 is the motherhood clause and provides a time frame for shutting down the reactor when an LCO and the associated Actions are not met, or an associated Action is not provided.

LCO 3.0.3 states that it is only applicable during MODES 1, 2 and 3.

With regard to ITS 3.6.4.1 Required Action C.1, it is possible that secondary containment could become inoperable with the reactor in MODES 1, 2, or 3 while fuel movements are in process (for example, fuel transfers in progress in the spent fuel pool).

In this case, Conditions A and B would apply to the reactor 73

(

)

and Condition C would apply to the fuel movement.

\\_ /

Similarly, if other units are operating, that units' 5

.~

l

('~S Conditions A and B would apply.

The addi. tion of the note L' ')

serves to emphasize that LCO 3.0.3 would not apply to the fuel transfer activities.

3.6.4.1-7 STS 3.6.4.1 ACTIONS were developed based on a single unit, not for a multi-unit plant with a shared secondary containment.

CTS 3.7.C.2, 3.7.C.3, 3.7.C.4, and 4.7.C.2 opecify the remedial actions to be taken in the event that secondary containment, reactor zone secondary containment or refueling zone are inoperable, including the required shutdown or ALL units at BFN.

ITS 3.6.4.1 ACTIONS do not reflect the CTS requirements nor is there appropriate justification for changing the CTS requirements when converting to the ITS.

See Item Numbers 3.6.4.1-1, 3.6.4.1-4, 3.6.4.1-6 and 3.6.4.1-8.

TVA Response As discussed in item 3.6.4.1-1, the provisions for zonal separation have been abandoned and the secondary containment is treated as one contiguous system.

The associated

(}

requirements for' zonal violations from CTS 3.7 C.2, 3.7.C.3,

(

/

3.7,0. 4, and 4.7.C.2 have accordingly not been included in ITS.

The secondary containment requirements for the other

'~'

units are included explicitly in that unit's ITS.

In ITS, a loss of secondary containment on any unit or the refuel zone will be treated as a loss of secondary containment for all reactor units.

3.6.4.1-8 CTS 3.7.C.1 requires maintaining containment integrity in the reactor zone "at all times" except as noted.

ITS 3.6.4.1 APPLICABILITY is MODES 1, 2, and 3, During movement of irradiated fuel, During CORE ALTERATIONS, and During Operations with the Potential for Draining the Reactor Vessel (OPDRV).

The' ITS changes the APPLICABILITY and deletes the operability requirements for MODES 4 and 5, and the defueled condition.

There is no discussion or justification for this more restrictive change in the APPLICIBILITY.

See Item Numbers 3.6.4.1-1, 3.6.4.1-4, 3.6.4.1-6, and 3.6.4.1-7.

O l

6 l

l N

-TVA Response

}

TVA does not consider that there are any differences in the secondary containment Applicability requirements between CTS and ITS.

ITS (Conditions A and B) and CTS (3.7.C.2.b) both explicitly cover Modes 1, 2 and 3.

CTS covers fuel handling, CORE-ALTERATICNS and OPDRVs via 3.7.C.2.a while ITS covers the same evolutions in the LCO 3.6.4.1 Applicability statement and. Condition C.

CTS 3.7.C.2.b

-allows secondary containment to be inoperable in Modes 4 and 5 if no fuel handling, CORE ALTERATIONS, or OPDRVs are in process.

This is identical to ITS requirements.

3.6.4.1-9 STS SR 3.6.4.1.1 verifies the containment vacuum is < 0.25 inch of vacuum water gauge on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency.

This SR has been deleted from the ITS based on the justification that it is a bracketed, optional requirement.

CTS 4.7.C.l.a verifies that the-secondary containment's capability to maintain 0.25 inch of water vacuum under certain conditions each refueling outage.

ITS B.3.6.4.1 Bases BACKGROUND Section used the same words as the STS.

The implication of

('

CTS 4.7.C l.a and the ITS Bases wording is that the

\\

secondary containment is maintained at < 0.25. inch of vacuum water gauge at all times.

Therefore the justification for deleting STS SR 3.6.4.1.1 and-the Associated Bases is inadequate.

TVA Response CTS 4.7.C.l.a verifies the capability of the secondary containment to maintain 0.25 inch of water vacuum with the I

standby SGT operating.

CTS does not require the secondary containment to be maintained at 0.25 inch of water vacuum at all times with normal HVAC. Similarly, ITS and STS Background Bases do not specifically address / require the-secondary containment to be maintained at 0.25 inch of water vacuum at all times..Therefore, BFN does not consider that the proposed Bases 11mply a-requirement to maintain secondary containment at a 0.25 inch of water vacuum.

The normal HVAC system is, however, capable of maintaining the secondary containment 1at or near this value during normal operation.

In' order for a post-accident release to occur, the radiological contamination must first be transported from the. site of the accident (from inside primary containment or the fuel pool) to the secondary containment boundary.-

If

\\

the secondary containment pressure is less than atmospheric 7

.---l-___-----___...-

]

pressure, contamination will not be allowed to pass directly

,eNg through the secondary containment membrsne to the ty' 'j -

environment.

ITS SR 3.6.4.1.3 verifies that the SGT is capable of drawing the secondary containment down within a 120 second period to greater than or equal to 0.25 inch of water vacuum starting at atmospheric pressure.

This time period is-short enough to ensure that an insignificant amount of contamination is transported from the primary containment directly through the secondary containment membrane.

The post-accident pressure response of the H

secondary containment is considered in the plant radiological analyses.

3.6.4.1-10 As a result of the change made by Item Number 3.6.4.1-9, the numbering of the STS SRs were changed in the ITS.

Resolution of this item will depend on the resolution of Item Number 3.6.4.1-9.

TVA Response

(~'N Based on the disposition of Item 3.6.4.1-9, no changes to

!Q the SR numbering is required.

O 8

ITS SECTION 3.6.4.2 SECONDARY CONTAINMENT ISOLATION VALVES 3.6.4.2-1 The CTS does not contain any surveillance requirements for SCIVs.

Thus, ITS SR 3.6.4.2.1 (STS SR 3 6. 4.2.2), ITS SR 3.6.4.2.2 (STS SR 3. 6. 4.2. 3), and their Associated Bases were added.

STS SR 3.6.4.2.1, which verifies.the secondary containment manual isolation valves and blind flanges that are required to be closed during accident conditions are closed, was not included in the ITS.

.The associated Bases sections for STS-B3.6.4.2, LCO and SR 3.6.4.2.1 were also deleted.

The justification (P56) states _that BFN does not have this requirement,-and chooses not to adopt it, but will maintain the requirement under administrative controls.-

This justification directly contradicts justification A2 which states that the new LCO will require all SCIVs the be OPERABLE consistent with the secondary containment rN

-OPERABILITY requirements.

The-bases for secondary

( )

containment (B.3.6.4.1) requires leak tightness to assure that the required vacuum can be maintained.

Since this requirement is maintained by administrative controls, it can be considered part of the current licensing basis.

In addition, the CTS for Primary Containment did not have similar surveillances for manual valves and blind flanges but they were_added to ITS 3.6.1.3.

Therefore, STS SR 3.6.4.1.1 and associated Bases need to be added to ITS 3.6.4.2.

TVA Respense STS SR 3.6.4.2.1 requires that each secondary containment inalation manual valve and blind flange that is required to be closed during an accident be verified closed every 31 days.

CTS does not contain this requirement and BFN chooses to maintain CTS licensing requirements by not adopting the subject STS SR.

The piping systems which penetrate secondary containment maintain the~ secondary containment boundary via a combination of pipes and valves / isolation devices.

s Isolation devices include devices such as blind flanges,

_[~'}=

pipe caps and loop seals.

The pipes and isolation devices

(

,f are depicted on controlled BEN drawings.

a i

a

/\\n 1

(d y

Someolocations utilize a closed valve / isolation device and the piping as the-secondary containment boundary.

Other i

locations rely on the integrity of the closed loop piping.

BFN has adequate administrative controls on the. manual' valves and isolation devices such.that monthly checks are not required.

These controls are as follows:

1. Independent valve lineup verifications following outages when a system has-been taken out of its normal alignment.

2.-Independent licensed operator preparation and verification of tagouts and independent placement and verification of-these tagouts.

3.. Blind flanges and pipe caps are only positioned using' maintenance work control documents which are reviewed-by Operations for system impact.

The nature of systems with normally closed-valves / caps is such that'there is seldom a need to operate these davices and'so the potential for degrading secondary contai ment by n

misoperation or failure is minimized.

BFN opera *.ing experience indicates the above controls are very effective

,\\

in maintaining status control.

Additionally, problems with leaking blind flanges or manual valves would be identified during the performance of ITS SR 3.6.4.1.4.

DOC A2 is not in contradiction with this position since the SCIVs referred toLin A2 are_the dampers for the HVAC-systems that penetrate secondary containment.

These dampers must be operable per the requirements and their leak tightness checked' periodically.

3. 6. 4. 2-2 See-Item Number 3.6.4.1-8 TVA Responce

-See the response to NRC comment 3.6.4.1-8.

No changes are.

required.

A l

2

a 1

f?~<g -

3.6.4".2-31 Y

)'

SeeLItem Number 3.6.4.1-6:

TVA Response Refer to the response to NRC comment 3.6.4.1-6.

The same reasoning applies to this Item.

3.6.4.2-4 See Item-Number 3.6.4.1-7 TVA Response Refer to the response to NRC comment 3.6.4.1-7.

No changes are required.

3.6.4.2-5 See' Item Number 3.6.4.1-1 j

TVA Response Bases on the disposition of Item 3.6.4.1-1, no changes are required.

3.6.4.2-6 CTS 3.7.C.1, 3.7.C.2 and 3.7.C.3 specify secondary

-containment, reactor-zone secondary containment, and refueling zone secondary containment integrity be maintained, respectively.

Secondary containment, reactor zone secondary containment, and refueling zone secondary containment is described and defined with regards to SCIVs in L?S 1.0.P.1, '1.0.P.2 and 1.0.P.3, respectively.

The CTS markup does not include a markup of CTS 3.7.C.3 with regards to'SCIVs.

See Item Number 3.6.4.1-1.

TVA Response

As discussed in item 3.6.4.1-1, the provisions for zonal separation have been abandoned and theLsecondary-conta1nment-is-treated.as one contiguous system.

The associated-

~

' requirements for-zonal violations from CTS 3.7.C.3 have similarly not been included'in ITS. iThe requirements for-1s.

SCIVs are contained in ITS 3.6.4.2.

3-W.

~-,

.. 37. -.. _ _.

_.____._.._._.______..7._.._._

i t

J j

3.6.4.'2-7 i

l As a. result'of the-change made by Item Number 3.6.4.2-1, the-numbers-of the STS SRs.were changed in the ITS, Resolution'-

~

t of!this item will depend on_the resolution of-Item Number l

3.6.4.2-1.

TVA Response Based en the-disposition of Item-3.6.4.2-1, no changes to the:SR numbering is required.

i 1

a v

i 4

d y$.

1

-l

(

A i.

4

\\

1 s

i4 e,

,.3.-

g n

y

- - yy, w

y--.,

_r_

d

/'5 -

ITS SECTION 3.6,4.3 s

)-

STANDBY GAS TREATMENT (SGT) SYSTEM 3.6.4.3-1 CTS 3.7.B.4 specifies the-actions to be taken if one'SGT is inoperable. _ Based on the CTS APPLICABILITY this action applies at all times.

ITS 3.6.4.3 adds ACTIONS C & E which are applicable during movement of irradiated fuel assemblies in the-secondary containment, during CORE ALTERATION, or during OPDRVs for one and two SGT system (s) inoperable,'

respectively.

This change is characterized as administrative change Al - reformatting, renumbering and editorial rewording to make.the CTS. consistent with NUREG-1433.

The addition of ITS 3.6.4.3 ACTION C is a less restrictive change from CTS 3.7.B.4 while the addition of ITS 3'.6.4.3 ACTION E is less restrictive since the CTS does not have the equivalent to ACTION E, in CTS 3.7.B, but would require a shutdown in accordance with 1.0.C.

Adding these ACTIONS is a'less restrictive change and a justification is 7-~3 not provided. 'Sec. Item Numbers 3.6.4.1-6, 3.6.4.3-6,

(

j 3.6.4.3-8, and 3.6.4.3-9.

w/

TVA Response TVA agrees that the addition of ITS Required Action C.1 is a less restrictive change, but it is already addressed by DOC L2.

CTS 3.7.B.3. requires that if one train of SGT is found inoperable, REACTOR POWER OPERATION and fuel handing operations are permitted for only-7 days.

After the 7 days, CTS 3.7.B.4 requires an immediate cessation of reactor operation and fuel handling.

ITS Required Action C.1 allows unlimited duration of reactor operation and fuel handling provided that two OPERABLE-SGT subsystems are in operation.

'As stated in:the ITS 3.6.4.3 Required Actions Bases for gp C 1, this action will ensures that the remaining SGT S-

subsystems are operable,-that no failures related to automatic actuation could prevent operation, and any other failure would be readily detected.

The SGT systems are basically simple systems with a minimum number of active components.

It is,_therefore, highly unlikely.that an operating system would suddenly'and catastrophically fail.

With two systems in operation, the function of the SGT and,

/~ ~g

'hence, secondary containment would be assured in the event i )

of an accident requiring-secondary containment.

1 3

~

D a

\\

TyA' disagrees that the addition of Required Action E is-a

-less-restrictive change.

Required Action E is the same-requirement as CTS 3.7 B.4.a for fuel handling, _ core alterations,_and OPDRVs.

'A unit can be in Mode 1,L2, or 3

..and be moving fuel inside secondary containment (i.e.,

fuel movements within-the fuel pool). -If-two or three SGT subsystems became inoperable, Condition D would apply to the reactor and Condition E would apply to the fuel related activities.

Similarly, if other units are operating, that unit's Conditions A, B,

or D would applyr if required.

This is the same as CTS 3.7.B.4.a_and 3.7.B.4.b.

=See the responses to items 3.6.4.1-6 and 3.6.4.1-8 for additional discussion.

3.6.4.3-2 CTS 4.7.B.2.d requires each SGT train be operated a total of at.least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months each month.

ITS SR 3.6.4.3.1 requires each SGT train be' operated continuously for 2 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months with heaters operating.

While the Justification (M2) addresses

-(

the-more restrictive change of going from a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per month to continuously operating for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , no mention is made about the addition of "with heaters operating."

There is no discussion or justification for this more restrictive requirement to have the heaters operating.

TVA Response The SGT system L.aters automatically operate (if flow is adequate and temperatures are not abnormally high) when SGT is started.

To address the NRC comment, DOC M2 has been revised to provide additional justification on this change l

l l

g 2

(~')

3.6.4.3-3 CTS 4.7.B.2.e requires testing the seals of gaskets-for housing doors.- This requirement.is not retained in ITS 3.6.4.3.

These requirements are' moved to plant procedures and/or system operating instructions, which are controlled

-by licensee controlled programs.

TVA Response The CTS requirement has been explicitly added to the BASES of ITS SR 3.6.4.3.2.

This will insure the smoke test is performed whenever SBGT. filter testing is performed in accordance with the Ventilation Filter-Testing Program, and thereby preserve the present CTS requirement.

Changes to the BASES will be controlled by ITS 5,.5.10.

DOC LAl-has been-revised to cor:espond to the above discussion.

3.6.4.3-4 CTS 4.7.B.3.a requires that once per operating cycle automatic initiation of each branch of SGT is demonstrated from each control room.

b

\\/

ITS SR 3.6.4.3.3 requires verifying each SGT subsystem actuates on an actual or simulated initiation signal every 18 months.

The method used to perform the surveillance is moved to plant procedures which are controlled by licensee controlled programs.

TVA Response The change in the wording of CTS 4.7.B.3.a to the wording of ITS SR 3.6.4.3.3 is considered an administrative change that has not changed either the method of performing the test or deleted / changed the amount of information contained in TS.

The test of the " automatic initiation" stated in CTS has been clarified to state "on an actual or simulated initiation signal".

BFN considers these terms to be equivalent.

Details regarding methods for verifying proper operation of the SGT system will De included in the plant procedure which implements SR 3.6.4.3.3.

SR procedure revisions are performed in accordance with site

-administrative procedures which include a review for 10 CEE

, ~s 50.59 applicability.

See the response to Item 3.6.4.3-5 for-(

additional information.

x 3

(]

3.6.4.3-5 i '/

CTS 4.7.B.3.a requires demonstrating once per operating cycle automatic initiation of each branch of SGT "from each control room."

1TS SR 3.6.4.3.3 requires verifying each SGT subsystem actuates on an actual or simulated initiated signal every 18 months.

There is inadequate discussion and justification for deleting the requirement for initiating SGT from each control room and adding the requirement to actuate the system using a simulated or actual initiation signal.

This is a less restrictive change in that one is going from the CTS requirement or testing from each unit (control room) to the ITS requirement which could be done from only one unit all the time.

TVA Response The change in the wording of CTS 4.7.B.3.a to the wording of ITS SR 3.6.4.3.3 is considered an administrative change that has not changed either the method of performing the test or deleted / changed the amount of information contained in TS.

The test of the " automatic initiation" stated in CTS has been clarified to state "on an actual or simulated initiation signal".

BFN considers these terms to be

(]

equivalent.

N)

The three SGT trains can be started from the control bay either manually from handswitches or from test handswitches which provide a simulated Primary Containment Isolation Signal (PCIS) in order to initiate an auto-start signal for SGT.

The A and B trains of SGT can be manually started from hand switches in the Units 1 or 3 control rooms.

The C train can be manually started from handswitches in the Unit 2 or 3 control rooms.

There are two test handswitches in the Unit 1 control room which provide simulated PCIS signals to the A and B trains, respectively.

There is one test handswitch in the Unit 2 control room which provides a simulated PCIS signal to the C train.

There are no test handswitches in the Unit 3 control room and, hence, no automatic testing is done from this unit.

These three test handswitches are currently used to test the three trains by providing an "automntic initiation" and will be used under ITS to provide an " actual or simulated initiation signal" for performing SR 3.6.4.3.3.

The simulated signal for testing under SR 3.6.4.3.3 can only be performed with the above described test switches.

This surveillance test will be classified as a common

(h surveillance test which means a single test is conducted for

,/

all three units to satisfy the SR (simultaneously).

4

-4 3/~'g Accordingly, BFN does not consider 1this change to be-a less.

('j restrictive-change since the system design dictates the test--

methodologytwhich'willinotEchange under ITS.

i

=3.6.4.3-6 An alternative' action _is proposed to_ suspending operations if a SGT System cannot be returned.to OPERABLE status within-seven days and movement _of irradiated fuel assemblies, CORE ALTERATIONS,_or OPDRVs are being conducted.

The alternative.

(ITS:3.6.4.3 RA C.1) is to initiate operation of thegtwo remaining SGT systems.

The CTS does not have this requirement..

The addition of this less: restrictive requirement will depend on the resolution-of Item Numbers 3.6.4.1-6,-3.6.4.3-1,, and 3.6.4.3-9.

TVA Responso.

See the1 responses to NRC comments 3.6.4.1-6, 3.6.4,3-1, and:

3.6.4.3-9 for the disposition of this Item.

No. additional

= changes-are required.

'3.6.4.3-7 See Item Number 3.6.4.1-6, 3.6.4.3-1, 3.6.4.3-6, and 3.6.4.3-9.

TVA Response See the responses to NRC comments 3.6.4.1-6, 3.6.4.3-1, 3.6.4.3-6, and 3.6.4.3-9 for the disposition of this Item.

No additional changes _are required.

3.6.4.3-8 CTS 3.7.B.1-requires 3 trains of Standby Gas Treatment-(SGT)

System be OPERABLE "at all times" when secondary containment integrity is required.

See Item--Number:3.6.4.1-8 for concern about secondary containment integrity which also

-applies here.

ITS;3.6.4.3 APPLICABILITY is MODES 1,-2, and 3, During movement of irradiated fuel, During CORE

' ALTERATIONS. and During Operations with the Potential for D1aining the Reactor Vessel.

There is-no discussion or" justification-forithis more restrictive. change to the-CTS f-~

APPLICABILITY..See Item Number 3.6.4.3-6, 3.6.4.3-7,-and (3) 3.6.4.3-9.

5

+

t

.g(

l r%

1 W A R e s p o n s e -.

Seegthe: responses to NRC comments 3.6.4.1-8,;3.6.4.3-6, 43 3.6.4.1-7, and:--3.6.4.3-9'for the disposition'of this/ Item.

ENo; additional changes are required.

3.6.4.3-9 iSTS 3.6.4.3 ACTIONS were developed based-on a. single unit with two SGT Systems not for a--multi-unit plant with a shared ' secondary containment (See Item-Number 3.6.4.1-7) and three SGT Systems.

CTS 3.7.B.4 specifies the remedial actions to be taken in the event that.one SGT System is inoperable including-the required shutdown of ALL Units at BFN, and CTS 1.0.C specifies the shutdown of all units:if more than one SGT system is inoperable. -ITS 3.6.4.3 ACTIONS do,not reflect the CTS requirements nor is there appropriate

-justification _for changing the CTS requirements when converting to the ITS.

See Item. Numbers 3.6.4.3-1,

~3.6.4.3-6, 3.6.4;3-7, and 3.6.4.3-8.

A WA Response 4

As discussed-in the response to Item 3.6.4.3-1 and in DOC L2, ITS Required Action C.1 is a less restrictive change which is being adopted in the conversion to ITS.

Other than this addition, the CTS requirements for operating reactors (CTS 3.7.B.4.b) are equivalent to ITS 3.6.4.3 Required

. Actions B and D and the CTS 3.7.B.4.a requirements-for fuel handling operations are analogous to ITS Required Actions C.2 and E.

-Regarding the issue of single unit versus multi-unit, if'any SGT train (s) is found. inoperable, each unit's individual ITS will govern the Required Actions for that u.it.

6

(}

3.6.4.3-10

^,

\\u,)

CTS 4.7.B.3.b requires demonstrating manual operability at least once per year of the bypass valve for filter cooling.

The-CTS markup shows that CTS 4.7.B.3.b will be ITS SR 3.6.4.3.4 requires verifying that each decay heat removal damper can open.

The difference between the-CTS and ITS are the CTS words " bypass valve for filter cooling" and the ITS words " decay heat removal damper".

There is no discussion or' justification to show that these two valves are the same or to show why the CTS bypass valve requirement was deleted in favor of the STS decay heat removal damper, if they are not the same.

TVA Response The bypass valve (damper) described in CTS 4.7.B.3.b is no longer required to be OPERABLE for filter cooling to be placed in service.

A design change was made which installed three manually positioned dampers, two of which directly

" bypass" the bypass damper referred to in CTS 4.7.B.3.b, thereby rendering operation of this bypass damper for the establishment of filter cooling unnecessary.

These new dampers are locked in the proper position to obtain the

/N required bypass flow with no active operator action (e.g.

(,)

opening the bypass damper) required.

Since these new dampers do not require manual operation, manual cycling is unnecessary.

The three dampels are periodically checked (quarterly) to be in the proper position by plant procedures, 0-GOI-300-3, " General Valve Operations".

Revisions to 0-GOI-300-3 are controlled by site administrative processes which include a review for 10 CFR 50.59 applicability.

Since plant procedures ensure these valves are properly positioned quarterly and manual operation of the bypass damper is no longer required to implement filter cooling, it is acceptable to relocate this requirement to 0-GOI-300-3.

ITS SR 3.6.4.3.4 has been deleted in this submittal and a new DOC LA3 added to address the relocation of the val.ve position checks discussed above.

O 7

1

_f:

)

(\\;

3.6.4.3-11 i

-- Q")/

.STSLSR 3;6.4.3.4 requires _verifyingfeach-SGT1 filter cooler 1

(bypass' damper can open and the fan starts on an118 monthi l

frequency.

ITS SR 3.6.4.3.4 requires verifying thatieach' decay' heat remova1Ldamper'can open on a 12 month frequency.

There is no.; discussion or justification for deleting the-STS 1

requirement that1the-fan starts.

~TVA Response-As discussed in-the response to NRC comment-3.6.4.3-10,_due to-plant specific; design change, ITS SR.3.6.4.3.4 has been

deleted. -The STS, requirement-to_ start the fan is ciready g

contained in'SR 3.6.4.'3.1 at an increased; frequency-(SR:3.6.4.3.1 requirement of every 31-days versus the

-Lprevious SR 3.6.4.3.4~ requirement _of every 18 months).

-3.6.4.3"12 See Item Number'3.6.4.1-3.

TVA Response

'As_ discussed in the response to NRC comment 3.6.4.1-3, neutral wind has been clarified in ITS 3.6.4.3 Background Bases-to mean-less than 5 mph as currently defined in CTS 4.7.C.1.a.

Also, as discussed in comment 3.6.4.1-2, the requirement---for neutral wind conditions-has been added to the SR 3.6.4.1.3 and 3.6.4.1.4 Bases.

T P

i 1

. v.

g,

. 8

-i; _.

.,.,..,~..-,

,,_. a.

~. -. -. -. -. - _ -

.-- - -. -~-..__ - ~. -.

3.6.4.3-13 m.

-STS B3.6.4.3 Bases for SR 3.6.4.3.2: states that "The SGT, filter tests are in accordance#with Regulatory Guidef(RGF l'. 2-(Ref. 3). " ITS B3.6.4.3' Bases for SR 3.6.4.3.2. deletes-5

+

this-statement:and Reference 3_from ITS B.3.6.4.3: Bases REFERENCE Section.

The basis for this deletion is that the

~ filter tests are not done_in accordance with RG 1.52 Revision (2), but in accordance_with-the ventilation filtration testing program (ITS 5.5.7)..

ITS 5.5.7 states that the VF7P test shallibe-done in accordance with RG 1.52 Rev. 2.

Therefore, the justific: tion P41 is wrong, and the STS statement and Reference 3 s'ould be reinserted into ITS B3.6.4.3 Bases SR 3'.6.4.3.2 and ITS B.3.6.4.3 Bases-REFERENCES, respectively.

Furthermore,' the staff would

~

consider this change and that portion of the justification (P41) which-refers to,the.VFTP as a generic change s TVA Response Section 5.0 of ITS has previbusly been revised to remove references to ventilation testing in accordance8bith

. Regulatory Guide 1.52.

Specifically, the Ventilation Filter

-Test Program (VFTP) described in ITS 5.5.7 has been revised to more closely match' CTS requirements for ventilation system testing.

BFN is not committed to Regulatory Guide 1.52 and all references have been removed from ITS.

With these changes, P41 is accurate.

s i

s.

+

I E

x 9

f')

SUMMARY

DESCRIPTION of ITS/ BASES CHANGES

'v ITS SECTION 3.6 - CONTAINMENT SYSTEMS TVA is submitting a proposed supplement to TS-362 for Section 3.6, CONTAINMENT SYSTEMS.

This supplement makes several changes associated with NRC comments on Section 3.6

-(

Reference:

.NRC Request for Additional Information Regarding Improved Standard Technical Specifications, dated June 12, 1997, TAC NOS M96431, M96432, M96433), incorporates changes resulting from internal.TVA reviews, and incorporates Owner's. Group Technical Specification Task Force (TSTF) items approved by NRC subsequent to the original submittal of TS-362.

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

Surveillance Requirement (SR) 3.6.1.1.1 Bases In response to an NRC comment, removed statemento which indicated that Main Steam Isolation Valve leakage is excluded from combined Appendix J Type B and C leakage.

TVA has a pending TS amendment request on this issue which is not yet NRC approved.

ITS 3.6.1.1 Bases References In response to an NRC comment, deleted Reference 7.

The TS amendment request in Reference 7 is not yet approved.

ITS 3.6.1.2 - Actions A.1, A.2, A.3 BASES Editorial change to sentence order.

SR 3.6.1.2.1 and Associated BASES In response to an NRC comment, modified to match model Appendix J ITS provisions.

SR 3.6.1.2.2 and Associated BASES Incorporated TSTF-17 extending the frequency for performance of the primary containment air lock door interlock SR.

LCO 3.6.1.3 and Actions, SR 3.6.1.3.1, and Associated Bases In response to internal TVA reviews, clarified purge valve sizes to be consistent with actual plant design.

Also, i

/

other minor changes to better describe pisnt design.

I i

1

(-

N 3.6.1.3 Applicability Bases

h Ix In response to a TVA internal review, deleted " sealed" to be consistent with BFN purge valve operating requirements.

3.6.1.3 Action D and Associated Bases In response to an NRC comment, changed completion time from 8 to.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to be consistent with NUREG-1433.

SR 3.6.1.3.2 and Associated BASES In response to a TVA internal review, added a new note 3 which excludes small valves from the scope of the monthly position verification SR.

This SR is not required by current TS (CTS).

Additionally, included a Final Safety Analysis (FS AR) reference (7) for a listing of valves in the scope of the subject SR.

Also, to incorporate TSTF-45, added a provision that locked, sealed, or otherwise secured manual valves and blind flanges are not required to be in the scope of the SR.

In the last paragraph of the SR 3.6.1.3.2 Bases, deleted the statement regarding inerted containment since this SR

())

involves valves and flanges outside containment.

(_,

SR 3.6.1.3.3 and Associated BASES In response to a TVA internal review, added a new note 3 which excludes small valves from the scope of the position verification SR.

This SR is not required by current CTS.

Also, to incorporate TSTF-45, added a provision that locked, sealed, or otherwise secured manual valves and blind flanges are not required to be in the scope of the subject SR.

SR 3.6.1.3.5 and Associated Bases Incorporated TSTF-46 which clarifies that only automatic power operated valves are in the scope of the SR.

ITS 3.6,1.3 Bases References In response to a TVA internal review, corrected P.eference 2 and added Reference 7 which is the FSAR Table listing of containment isolation valves, q

)

-s 2

l 140 3.6.1.5 LCO Actions and Associated Bases

(

-J In response to an NRC comment, revised completion times to-

'~#

be consistent with NUREG-1433.

LCO 3.6.1.5 Bases In response to an NRC comment, added "during testing or" for consistency with NUREG-1433.

ITS 3.6.1.5 Applicability Bases In response to an MRC comment,-clarified Bases to better describe the effects of centainment spray systems during design basis accidents.

The changes result in a better correlation to the NUREG-1433 text as adapted to BFN specific design analyses.

Unit 2 Only - ITS 3.6.1.5 Action D.1 Bases Inserted missing text (word processing omission) for consistency with Unit 1 and 3 Bases.

LCO 3.6.1.6 Bases [

(__f)

In response to an NRC comment, added "during testing or" for consistency with NUREG-1433.

ITS 3.6.1.6 Applicabiljty Bases In response to an NRC comment, clarified Bases to better describe the effects of containment spray systems during i

design basis accidents.

The changes result in a better correlation to the NUREG-1433 text as adapted to BFN specific design analyses.

LCO 3.6.1.6 Action B.1 Bases In response to an NBC comment, added (explicitly) CTS provisions for alternate means for verifying vacuum breaker closure.

SR 3.6.1.6.1 and Assoef.ated Bases in response to an NRC comment, added a new Note 2 to the SR which incorporates the CTS criteria allowing a single vacuum breaker to be in a slightly open position.

In the Bases, added (explicitly) CTS provisions for alternate means for O

verifying vacuum breaker closure.

3

^

ITS 3.6.2.1 and Esses (Several Locations)

N

,J In response to a TVA internal review, changed the

~~'

Intermediate Range Monitor (IRM) ocale values On range 7 (point of nominal reactor heat input) from 25/40 to 70/125.

The IRM instruments have dual ranges (0-40 and 0-125),

however, readings per operating procedures are taken based only on the 0-125 scale.

Thus, this c.hange is not technical.

ITS 3. 6.2.1 Actions D_and E, and Associated Bases In response to an NRC comment, revised Actions D and E to be consistent with NUREG-1433 regarding torus water temperature monitoring requirements.

ITS 3.6.2.3 Background BASES In response to a TVA internal review, added the word *any" to clarify the RHR heat removal pump requirements in the BACKGROUND DASES section.

ITS SR 3.6.4.1.1 and SR 3.6.4.1.2 BASES

('^h In response to an NRC comment, added missing " SURVEILLANCE Lj' REQUIREMENTS" margin heading to corresponding BASES section.

This is an editorial change.

ITS SR 3.6.4.1.4 and SR 3.6.4.1.3/SR 3.6.4.1.4 BASES In response to a TVA internal review, the requirement to maintain test conditions for one hour in 3R 3.6.4.1.4 has been removed.

It is necessary to secure normal reactor building ventilation to perform the test and, with units in operation, a test duration of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months may result in temperature problems in some plant areas (for example, steam tunnels).

This change is consistert with the CTS requirements and maintains the current licensing basis.

Also in response to an NRC comment, clarified the term

" neutral" wind conditions to be less than 5 miles per hour.

ITS 3.6.4.2 LCO BASES Incorporated TSTF-46 which clarifies that only automatic i

power operated valves are in the scope of the SR.

4

l

?

}

ITS SR 3.6.4.2.1 and Associated BASES t,y/

In response to.a TVA internal 1 review, the test frequency in SR 3.6.4.3.1 is changed to 92 days from "in accordance with the Inservice Test (IST) Program" since these valves (dampers) are not currently included in the IST program.

Also, incorporated TSTF-46 which clarifies that only automatic power operated valves are in the scope of the SR.

ITS 3.6.

4.3 BACKGROUND

BASES In response to an NRC comment, clarified the term " neutral" wind conditions to be lesu than 5 miles per hour.

ITS SR 3.6.4.3.2 BASES In response to an NRC comment, added requirements to include a chemical smoke test to check the sealing of gaskets for filter housing doors to SR 3.6.4.3.2 BASES.

This is consistent with CTS requirements and maintains the current licensing basis.

ITS SR 3.6.4.3.4 and Associated BASES

)

In response to a TVA internal review, deleted SR 3.6.4.3.4 which required surveillance testing of the Standby Gas Treatment System bypass dampers.

A design change has been made which installed three manually positioned dampers which are locked in the correct position.

Therefore, a surveillance to demonstrate the capability to manually operate the valves is not necessary.

The position of the dampers is verified quarterly in accordance with general operating instructions.

4 5

v t e Letter Sequence Other
TAC:M96431, Administrative Controls Program Exceptions, Revise Reporting Requirements to Be Consistent with 10 CFR 20 (Approved, Closed) TAC:M96432, Administrative Controls Program Exceptions, Revise Reporting Requirements to Be Consistent with 10 CFR 20 (Approved, Closed) TAC:M96433, Administrative Controls Program Exceptions, Revise Reporting Requirements to Be Consistent with 10 CFR 20 (Approved, Closed)
Initiation Acceptance... Supplement, Supplement, Supplement, Supplement Administration Meeting, Meeting Questions 26 February 1998 Answers Results Approval Other: ML18038B898, ML18039A196, ML18039A205, ML18039A208, ML18039A262, ML18039A265, ML20149E737, ML20198F430, ML20198Q445, ML20199E118, ML20203B078, ML20211J898
MONTHYEAR1997-07-14 [Table View]

ML20198F430

Text

1.5 BACKGROUND

SUMMARY

Reference:

4.3 BACKGROUND

Navigation menu

Search