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DEC 2 31993

TVA-BFN-TS-346 10 CFR 50.90

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555

Gentlemen:

In the Matter of ) Docket Nos. 50-259Tennessee Valley Authority ) 50-260

50-296

BROWNB FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

TECHNICAL SPECIFICATION (TS).NO. 346 - ALTERNATIVEREQUIREMENTS FOR SNUBBER VISUAL INSPECTION INTERVALS ANDCORRECTIVE ACTIONS - REQUEST FOR REVIEW AND APPROVAL OF COSTBENEFICIAL LICENSING ACTION RLA-04

In accordance with the provisions of 10 CFR.50.4 and 50.90,TVA is submitting a request for an amendment (TS-346) tolicenses DPR-33, DPR-52, and DPR-68 to change the TSs forUnits 1, 2, and 3. The proposed change incorporates therecommendations for snubber visual inspection intervalscontained in Generic Letter 90-09, " Alternative. Requirementsfor Snubber Visual Inspection Intervals and CorrectiveActions." TVA proposes that the TS requirements.for visualinspection of safety-related snubbers be revised to. increasethe allowable interval between visual inspections _providedthe snubbers are operating at or above a prescribed-level _ofdependability. This change to the visual inspection schedule

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U.S. Nuclear Regulatory CommissionPage 2

DEC 2 31993

will_ provide the same confidence level of snubber operabilityas the existing schedule with the potential for reducingresource demands and unnecessary occupational radiologicalexposure.

TVA has determined that there are no significant hazardsconsiderations associated with the proposed change and thatthe change is exempt from environmental review pursuant to10 CFR 51.22 (c) (9) . The Browns Ferry Plant Operations ReviewCommittee and the Browns Ferry Nuclear Safety Review Boardhave reviewed this proposed change and determined.thatoperation of BFN Units 1, 2, and 3 in accordance with theproposed change will not endanger the health.and safety ofthe public. Additionally, in accordance with 10 CFR50. 91(b) (1) , TVA is sending a copy of this letter andenclosures to the Alabama State Department of Public Health.

Enclosure 1 to this letter provides the description andevaluation of the proposed change. Enclosure 2 containscopies of the appropriate TS pages from Units 1, 2, and 3marked-up to show the proposed change. Enclosure 3 forwardsthe revised TS pages for Units 1, 2, and 3 which incorporatethe proposed change.

TVA requests NRC review and approval of TS-346 as a costbeneficial licensing action. Enclosure 4 (RLA-04) provides adescription of the proposed change which includes therequested NRC licensing action, the basis for the request,and justification for higher priority NRC review.

Additionally, TVA requests NRC review and approval of this TSamendment by May 1, 1994. This date is necessary in order-to support resource planning and allocation-for the Unit 2-Cycle.7 refueling outage which is scheduled to begin on-October 1, 1994. TVA feels that the requested _ review andapproval time is consistent with_similar Generic Letter 90-09TS change requests performed by the staff for otherutilities. If NRC is unable to support the above date,.TVArequests early notification so that an alternate date can benegotiated with the staff that will provide forimplementation of the proposed TS change prior to the outage.This is similar to a previous request, negotiated with thestaff, for review and approval of BFN TS-332, Frequency ofEmergency Diesel Generator Inspections. TVA also requeststhat the revised TS be made effective within 30 days of NRCcpproval.

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U.S. Nuclear Regulatory CommissionPage 3

DEC 2 31993

If you have any questions about this change, please telephoneme at (205) 729-2636.

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Sincerely,)

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Pe a asManager of Site Licensing

Enclosurescc: See page 3

Subscribed and sworn to before meon this 'A ] day of h la1993.

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Notary Public

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U.S. Nuclear Regulatory CommissionPage 4

DEC 2 31993 - :

cc (Enclosures): '

American Nuclear InsurersTown Center, Suite 300S29 South Main Street :'West Hartford, Connecticut 06107-2445

Mr. W. D. ArndtGeneral Electric Company735 Broad Street >

Suite 804, James BuildingChattanooga, Tennessee 37402

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Mr. Johnny Black, Chairman !

Limestone County Commission 3

310 Washington Street.Athens, Alabama 35611 ,

Mr. R. V. Crlenjak, Project ChiefU.S. Nuclear Regulatory CommissionRegion II

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101 Marietta Street, NW, Suite 2900Atlanta, Georgia. 30323 .

NRC Resident InspectorBrowns Ferry Nuclear Plant i

Route 12, Box 637Athens, Alabama 35611

Mr. Joseph F. Williams, Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint, North11555 Rockville PikeRockville, Maryland 20852

Dr. Donald E. WilliamsonState Health OfficerState Department of Public Health ~ t

State Office BuildingMontgomery, Alabama 36194

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-|ENCLOSURE 1 .

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L TENNESSEE VALLEY AUTHORITY. 'b

BROWNS FERRY-NUCLEAR. PLANT'(BFN) j

UNITS 1, 2, AND 3PROPOSED TECHNICAL SPECIFICATION (TS) CRANGE'TS-346 i

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DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE- ~|

I. DESCRIPTION OF~THE PROPOSED CHANGE,

The proposed change would revise the BFN. Units 1, 2, and 3,

TS by providing an alternate visual inspection schedule jfor safety-related snubbers following the recommendations 1

of NRC Generic Letter _(GL) 90-09, " Alternative.

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Requirements for Snubber Visual Inspection Intervals.and-Corrective Actions," dated = December 11, 1990. The

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alternate visual inspection schedule is based on'thenumber of unacceptable snubbers.found during the previous .

inspection, and.the size of the snubber population or !

categories.and provides the same' operability confidence '!level.as the existing schedule. The1 alternate inspection '

interval is based on a fuel cycle of up.to 24 months andmay be as long as two fuel cycles, or 48 months depending ,

on the number of unacceptable snubbers found during theprevious visual inspection. -Additionally, the proposed-

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change will~ reduce occupational radiological exposure-to.plant personnel and generally allow'BFN to perform visualinspections and corrective actions during plant outages. R

In addition to the changes described above, certaineditorial and terminology changes have-been madethroughout TS 3.6.H/4.6.H and the' associated bases to ;

'provide consistency between affected: sectionsincorporating the changes recommended by GL 90-09'andthose sections not directly affected. The specific' .:changes are provided below: )

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1. For Units 1, 2, and 3, TS Section 3.6.H, delete ;

specific reference to Browns Ferry (BF) Surveillance: |'

Instructions (SI) BF SI 4.6.H-l'and BF?SI-4.6.H-2 andrefer only to " Plant Surveillance Instructions.".

The revised TS Section 3.6.H reads:,

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'lDuring all modes of-operation, all:snubbers shall be. OPERABLE except as 1

noted in 3.6.H.1. 'All safety-related -jsnubbers'are listed'in Plant ]

Surveillance Instructions ~.

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2. For Units 1,.2, and 3, TS Section 4.6.H, deletespecific reference to BF SI 4.6.H-l'and BF SI 4.6.H-2and refer only to " Plant Surveillance Instructions."

The revised TS Section 4.6.H reads:

Each safety-related snubber shall bedemonstrated OPERABLE by performance ofthe following augmented inserviceinspection program and the requirements ofSpecification 3.6.H/4.6.H. These snubbers arelisted in Plant Surveillance Instructions.

3. For Units 1, 2, and 3, TS Section 4.6.H.1, deleteentire secticn regarding " Inspection Groups" andreplace with GL 90-09 recommendations.

The revised TS Section 4.6.H.1 reads:

Inspection Types

As used in this specification, " type ofsnubber" shall mean snubbers of the samedesign and manufacturer, irrespective ofcapacity.

4. For Units 1, 2, and 3, TS Section 4.6.H.2, deleteentire section regarding " Visual Inspection, Schedule.and Lot Size" and replace with GL 90-09recommendations.

The revised TS Section 4.6.H.2 reads:

Visual Inspections

Snubbers are categorized as inaccessible oraccessible during-reactor operation. Each ofthese categories (inaccessible and accessible) maybe inspected independently according to theschedule determined by Table 4.6.H-1. The. visualinspection interval'for each typelof snubber shall '

be determined based upon the criteria provided inTable 4.6.H-1 and the first. inspection interval

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determined using this criteria.shall be based upon '

the previous inspection interval as established bythe requirements in effect before amendment (*) .

*NRC will include the number of the license amendment that -

implements this change. j1

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5. For Units 1, 2, and 3 add Table 4.6.H-1, " Snubber s

Visual Inspection Interval," which incorporates therecommendations in GL 90-09.

TABLE 4.6.H-1

SNUBBER VISUAL INSPECTION INTERVAL

NUMBER OF UNACCEPTABLE SNUBBERS |

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Population Column A Column B Column C- ;

or Category Extend Interval Repeat Interval Reduce Interval ,

(Notes 1 and 2) (Notes 3 and 6) (Notes 4 and 6) (Notes 5 and 6)

1 0 0 1

80 0 0 2,

100 0 1 4

150 0 3 8=

200 2 5 13

300 5 12 25

400 8 18 36

500 12 24 48,

750 20 40 78

1000 or rnore 29 56 109.

Note 1: The next visualinspection interval for a snubber population or category size shall bedetermined based upon the previous inspection interval and the number.of unacceptablesnubbers found during that interval. Snubbers may be categorized, based upon theiraccessibility during power operation, as accessible or inaccessible. .These categories maybe examined separately or jointly. However, the licensee must make and document thatdecision before any inspection and shall use that decision as the basis upon which todetermine the next inspection interval for that category.

Note 2: Interpolation between population or category sizes and the number of unacceptable -snubbers is permissible. Use next lower integer for the value of the limit for Columns A,B, or C if that integer includes a fractional value of unacceptable snubbers as determinedby interpolation.

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Note 3: if the number of unacceptable snubbers is equal to or less than the number in Column A,the next inspection interval may be twice the previous interval but not greater than 48months.

Note 4: If the number of unacceptable snubbers is equal to or less than the number in column Bbut greater than the number in Column A, the next inspection interval shall be the same asthe previous interval.

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Note 5: If the number of unacceptable snubbers is equal to or greater than the number in Column jC, the next inspection interval shall be two-thirds of the previous interval. However, if the -

number of unacceptable snubbers is less than the number in Column C but greater thanthe number in Column B, the next interval shall be reduced proportionally by interpolation,that is, the previous interval shall be reduced by a factor that is one-third of the ratio of |

the difference between the number of unacceptable snubbers found during the previous- |interval and the number in Column B to the differences in the numbers in Columns B and |C. .|

Note 6: The provisions of Specification 1.0.LL are applicable for all inspection intervals up to andincluding 48 months.

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6. For Units 1, 2, and 3, TS Section 4.6.H.3,. delete |section regarding " Visual Inspection Performance and i

Evaluation" and replace with GL 90-09recommendations. It should be noted that the -l

criteria regarding transient event inspections was jnot deleted from 4.5.H.3 and is shown in paragraph .)two of the revised 4.6.H.3.

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The revised TS Section 4.6.H.3 reads:

Visual Inspection Acceptance Criteria

Visual inspections shall verify that'(1) ,

the snubber has no visible indications of- :

damage or impaired OPERABILITY, (2)attachments to the foundation or i

supporting structure are functional, and !

(3) fasteners for the attachment of the jsnubber to the component and to the i

snubber anchorage are functional'.Snubbers which. appear inoperable'as aresult of visual inspections shall be ;

classified unacceptable and may be |reclassified acceptable for the purpose ofestablishing the next visual inspectioninterval, provided that -(1)' the cause ofthe rejection is clearly established andremedied for that particular snubber and

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for other snubbers irrespective of typethat may be generically susceptible; and(2) the affected snubber is functionally ;

tested in the as-found condition anddetermined OPERABLE per Specification4.6.H.S. A review and evaluation shall beperformed and documented to justifycontinued operation with an unacceptable ;

snubber. If continued operation cannot bejustified, the snubber shall be declaredinoperable and the LIMITING CONDITIONS FOROPERATION shall be met.

Additionally, snubbers attached to sections of ,

safety-related systems that have experiencedunexpected potentially damaging transients sincethe last inspection period shall be evaluated for 'lthe possibility of concealed damage andfunctionally tested, if applicable, to confirm |

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OPERABILITY. Snubbers that have been made '

inoperable as the result of unexpectedtransients, isolated damage, or other randomevents, when the provisions of 4.6.H.7.and4.6.H.8 have been met and any other appropriatecorrective action implemented, shall not becounted in determining the next visual inspectioninterval.

7. For Units 1, 2, and 3, TS Section 4.6.H.4, firstparagraph, replace the word " group" with the word" type". Also, in the second paragraph, firstsentence, replace the word " groups" with the word" types."

The revised TS Section 4.6.H.4 (first paragraph andsecond paragraph first sentence) reads:

During each refueling cutage, a representativesample of 10% of the total of each type ofsafety-related snubber in use in the plant shallbe functionally tested either in place or in abench test.

The representative sample selected for functionaltesting shall include the various configurations,operating environments, and the range of size and.capacity of snubbers within the types.

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8. For Units 1, 2, and 3, TS Section 4.6.H.6, in the -

fourth sentence replace the word " group" with theword " type". Also in the fifth sentence replace thewords " inspection group" with the words " functional '

test type."

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The revised TS Section 4.6.H.6 (fourth and fifthsentences) reads: ,

For'each snubber that does not meet theFUNCTIONAL TEST acceptance criteria, an :

additional lot equal to 10 percent of theremainder of that type of snubbers shall ;

be functionally tested. Testing shall'

continue until no additional inoperablesnuobers are found within subsequent lots !or all snubbers of the original functional !test type have been tested or all suspectsnubbers identified by the failureanalysis have been tested, as applicable.

9. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H, !

" Snubbers," fourth paragraph, fifth sentence, add ,

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the word " visual" between the words " thorough" and" inspection."

The revised sentence reads: ;

A thorough' visual inspection of thesnubber threaded attachments to the pipeor components and the anchorage will bemade in conjunction with all requiredFUNCTIONAL TESTS.

10. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H," Snubbers," sixth paragraph, delete the secondsentence in its entirety.

The deleted sentence reads:

Thus, the required inspection interval varies ;

inversely with the observed snubber failures.;

11. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H," Snubbers," seventh paragraph, first sentence, delete ;

the words " exempted from being counted" and replace '

with " reclassified." Also, in the same sentence,change the word " inoperable" to " operable."

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The revised TS bases sentence reads:

When the cause of the rejection of asnubber in a visual inspection is clearlyestablished and remedied-for that snubber. i

and for any other snubbers that may begenerically susceptible and operabilityverified by inservice functional testing,if applicable, that snubber may bereclassified as operable.

12. For Units 1, 2, and 3, TS Bases 3.6.H/4.6.H," Snubbers," seventh paragraph, third, fourth and

'fifth sentences, replace the words " groups," " group,"and " groupings" with the words " types" and " type" asappropriate.

The revised TS bases sentences read:

Inspection types may be established based ondesign features, and installed conditionswhich may be expected to be generic. Each ofthese inspection types is inspected and testedseparately-unless an engineering analysisindicates _the inspection type is improperlyconstituted. All suspect. snubbers are aubjectto inspection and testing regardless cfinspection type.

II. REASON FOR THE PROPOSED CHANGE,

The proposed amendment requests changes to the Browns i

Ferry Technical Specifications in response to GL 90-09, ,

" Alternative Requirements for Snubber Visual InspectionIntervals and Corrective Actions." The generic letter'

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describes line-item Technical Specification improvementsdeveloped by the NRC Staff to allevi. ate problems being |encountered with the current Standard TechnicalSpecifications snubber visual inspection requirements.

Improvements described in GL 90-09 provide an alternateschedule for visual inspection of snubbers that maintainsthe same confidence level for identifying defectivesnubbers'as the existing schedule.

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Implementing the proposed changes will reduce futureoccupational radiological exposure and will generallyallow the snubber visual inspection and corrective actionsto be performed during plant outages. ' Additionally, the .

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implementation of the proposed alternative snubber visualinspection schedule'will allow for less frequent' snubberinspections provided the results of ongoing inspections. ,

are favorable.

Also, certain editorial changes have been made in theproposed amendment to provide consistency between affectedsections incorporating the changes recommended by GL 90-09and those sections not directly affected. !

TVA is also proposing to remove reference to the specificPlant sis that list the BFN safety-related snubbers andrefer only to " Plant Surveillance Instructions."

III. SAFETY ANALYSIS t

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The proposed alternate snubber visual inspection schedulewould allow BFN to extend snubber visual inspection

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intervals (in accordance with GL 90-09) without reducingthe confidence level provided.by the existing visualinspection schedule. As previously discussed,verification that a snubber can operate within specified-performance limits is provided by functional testing.This testing provides a 95 percent' confidence level thatat least 90 percent to 100 percent of the snubbers operate ,

within.specified. performance limits. The-performance ofvisual inspections is a separate process that complementsthe functional testing program and provides additionalconfidence in snubber operability. Therefore, revisingthe schedule for snubber visual inspections, using theguidance'provided in GL 90-09, does not reduce theconfidence level associated with snubber operability. Asa result, a significant amount of resources could be savedand a substantial reduction in occupational radiologicalexposure could be realized.

BFN is also proposing certain editorial and terminologychanges to TS Section 3.6.H/4.6.H and.the associated bases-to provide consistency between affected sectionsincorporating the changes recommended by GL 90-09 andthose sections not directly affected. These changes ,

include removal of the specific plant SI references andsubstitution of the term " type" for " group" in the TS '

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sections and bases describing functional testing.

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The proposed change would also remove a sentence in the TS'bases which states that the visual inspection frequency

. varies inversely with the observed snubber". . '

failures." This statement would not be an accurate'

description of the inspection interval proposed byGL 90-09 and is therefore deleted.

The statement in Section 4.7.9.c of' Enclosure B toGL 90-09 regarding snubbers connected to an inoperablecommon hydraulic fluid reservoir was not included in theproposed amendment because snubbers of this type are not '

installed at Browns Ferry.;

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

TVA has concluded that operation of Browns Ferry NuclearPlant (BFN) Units 1, 2, and 3 in accordance with theproposed change to the technical specifications, regardingalternate snubber visual inspection intervals, does not-involve a significant hazards consideration. TVA'sconclusion is based on its evaluation, in accordance with10 CFR 50.91(a)(1), of the three standards set forth in10 CFR50.92(c).

1. The proposed amendment does not involve a sicnificantincrease in the probability or conseauences of anaccident previously evaluated. !

Implementing the guidance specified in GL 90-09 will !

not introduce any new failure mode and will not alterany assumptions previously made in evaluating theconsequences of an accident. The proposed alternateschedule for visual inspections will maintain thesame operability confidence level as.the existing ,

schedule. Also, the surveillance requirement and ;

schedule for snubber functional testing remains thesame providing a 95 percent confidence' level that 90 .;

percent to 100 percent of the snubbers operate within |'

the specified acceptance limits. The proposed visualinspection schedule is separate from functionaltesting and provides additional confidence that theinstalled snubbers will serve their design functionand are being maintained operable. The proposed ,

changes do not affect limiting safety system settingsor operating parameters, and do not modify or add anyaccident initiating events or parameterr. Therefore, jthe proposed change does not significantly increase ,

the probability or consequences of an accident :

previously evaluated.

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2. The Droposed amendment does not' create the . iDossibility of a new or different kind of accident ' '

from any accident Dreviousiv evaluated.-gr

Implementing the recommendations specified in ;

GL 90-09 does not involve any physical alterations,to- o

plant equipment, changes to setpoints or operating '

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parameters, nor does it involve any potential !accident initiating event. As stated in the' generic |letter, the alternate schedule for' snubber visual !

inspections. maintains the same confidence level as- _!

the existing schedule. Additionally, functional |testing of snubbers provides a 95 percent confidence

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level that 90 percent to 100 percent of the snubbers- !

operate within specified acceptance limits. Since,

this TS change does not physically alter the plant >

equipment and the snubber confidence level remainsthe same there will not be any new.or differentaccident resulting from snubber failure from any Laccident previously evaluated.

3. The DroDosed amendment does not involve a siGnificant''

reduction in a margin of safety, i

The proposed change incorporates the surveillance !requirements for snubber visual inspection-intervals ??

following the. guidance provided in GL 90-09. As ~ !!stated in the generic letter, the' proposed snubbervisual inspection interval maintains the same >

confidence level as the existing snutber visualinspection interval. This surveillance requirement

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does not alter the current Limiting Condition for !Operation or the' accompanying actions for the t

snubber (s). The requirement for functional testing |of safety-related snubbers is unchanged and remains ;

the basis for the established margin of safety and_

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assures a 95 percent confidence level that 90 percent jto 100 percent of the snubbers operate within the '

specified acceptance limits. This functional testing :

along with the proposed visual inspection intervals jprovides adequate assurance _that the snubber will |

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perform its intended function. .Therefore, the i

proposed changes do not involve a significant |

_reduction in a margin of safety. |

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V. ENVIRONMENTAL IMPACT CONSIDERATION

The-proposed change does not invol'' a significant hazardsconsideration, a significant change in the types of orsignificant increase in the amounts of any effluent thatmay be released offsite, or a significant increase inindividual or cumulative occupational radiation exposure.Therefore, the proposed change meets the eligibility i

criteria for categorical exclusion set-forth in 10 CFR51. 2 2 (c) (9) . Therefore, pursuant to 10 CFR 51.22(b), anenvironmental assessment of the proposed-change is not

'required.

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