ML20247H930
| ML20247H930 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/25/1989 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907310182 | |
| Download: ML20247H930 (4) | |
Text
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 SN 1578 Lookout Place l
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JUL 251989 I
TVA-BFN-TS-271 10 CFR 50.90-U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 l
Gentlemen:
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In the Matter.of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - TVA BFN TECHNICAL SPECIFICATION NO. 271 -
SUPPLEMENT 1 - CORE ALTERATIONS / SOURCE RANGE MONITORS This letter is to submit a revised Enclosure 3, No Significant Hazards Consideration, for BFN-TS-271 which was submitted to NRC on June 20, 1989.
The " Description of Proposed TS Amendment" along with Section 3 of the "No Significant Hazards Consideration" is being revised to~ provide-additional clarification.
The information contained in this letter does not change or alter the proposed Technical Specifications as initially. submitted.
If'you have any questions, please telephone Patrick P.' Carter at (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY
% GL M.J. pay, Manager-Licensing Project Management
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Subscrib d d sworn to hefore me on' his day fOuffA1989
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Notary Public '
My Commission Expires h l
Enclosures cc:
See'page 2 q
j 9 0Y 8907310182 89072S P
PNV
,k PDR ADOCK.05000259 4
An Equal O'pportunity Employer -
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' ~ U.S.NucidarRegulatoryCommission JUL 251989 cc (Enclosures):
Ms. S. C. Black, Assistant Director for Projects.
TVA Projects Division.
U.S. Nuclear Regulatory Commission -
One White Flint, North 11555 F.o-'"ille Pike Rockville, Maryland 20852 Mr. Charles R. Christopher, Chairman Limestone County Commission P.O. Box 188 Athens, Alabama 35611 Dr. C. E. Fox State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36194 Mr. J. E. Jone, General Electric Company No. 1 Union Square 808 Krystal Building Chattanooga, Tennessee' 37402 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 1
American Nuclear Insurers Attention:
Librarian The Exchange, Suite 245 270 Farmington Avenue l
Farmington, Connecticut 06032
,k ENCLOSURE 3 l
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION j
BROWNS r'ERP,Y NUCLEAR PLANT (BFN) l UNITS 1, 2, AND 3 DESCRIPTION OF PROPOSED TS AMENDMENT BFN units 1, 2, and 3 technical specifications (TS), 1.0.S. 3.10.B.,
I and 3.10.C are being revised.
The main purpose of this change is to delete TS 3.10.B.l.b.2 and 3.10.B.1.b 3 which currently allows I
reactivity additions to be made without continuous core monitoring and to clarify requirements for full core offloads.
These are interim changes resulting from agreements between NRC and TVA during an Enforcement Conference earlier this year.
There is currently no industry standard practice for neutron monitoring during core alterations. GE and EPRI are working on a program to evaluate reactivity controls during refueling.
Recommendations made from this evaluation are expected to be available for industry review in early 1990. TVA will evaluate these generic recommendations when they become available. Core loading is not anticipated with these proposed interim TS changes, however, the proposed TSs will support a core loading if needed.
BASIS FOR PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION NRC has prrvided standards for determining whether a significant hazards considerations exists as stated in 10CFR50.92(c). A proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from an accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
l 1.
This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The design basis accident during core alterations is the dropping of a fuel assembly.
Since these changes increase the monitoring requirements for core alterations and there is no new fuel handling activity introduced that was not previously allowed by the current technical specifications, there is no increase in the probability or consequence of the dropped assembly accident.
These changes do not increase the probability or consequences of a control rod removal error or a fuel assembly insertion error.
There is no increased probability or consequence of an accidental reactivity insertion or an inadvertent criticality.
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2.
This proposed change does not create the possibility of a new or i
different kind of accident from any previously evaluated.
1 These TS changes result in improved monitoring requirements during l
core alterations that would add reactivity. There are no new activities required during core alterations due to these proposed changes which could introduce any new or different accident.
The deletion of the two options of loading fuel without continuous SRM monitoring will require the use of fuel loading chambers (FLCs) during part of the fuel loading.
FLCs have been used during 13
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previous fuel loadings at BFN.
The proposed clarifications.of the TS allowing the SRM count rate to decrease below 3 cps during the special conditions specified for complete core unloading do not change the intent of the current TS. The Control Rods are fully 1
inserted in the core and are electrically disarmed and cannot be j
moved. Therefore, no reactivity can be added by control rod movement.
In addition, any fuel movements would be to remove a fuel assembly from the reactor core.
In either case, no core altere ons will be made that would increase core reactivity. All other chs les are more conservative than the current TS requirements on cor.e alterations, including normal control rod movement.
Therefore, t possibility of a new kind of accident is not created.
3.
This change does not involve a significant reduction in the margin c.
safety.
The only margin of safety applicable to fuel loading is the requirement for having a 0.38 percent AK shutdown margin. 'The proposed changes are conservative by requiring continuous SRM monitoring during core alterations which could add reactivity.
In addition, the requirements for control rod withdrawal with the vessel head removed will be considered as a core alteration which is also more con:ervative than the current TS.
The use of SRMs for core i
monitoring during core alterations is not taken credit for in any margin of safety as defined in the TS base:. Since these proposed TS changes are more restrictive, they will not result in the reduction l
of any margin of safety as defined in the TS bases.
j DETERMINATION OF BASIS FOR PROPOSED NO SIGNIFICANT HAZARDS Since the application for amendment involves a proposed change that is encompassed by the criteria for which no significant hazards consideration exists, TVA has made a proposed determination that the application involves no significant hazards consideration.
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