ML18029A785

Proposed Tech Specs,Allowing Radiation Monitors to Be Taken Out of Svc for Up to 1 H for Purging During Routine Surveillance

ML18029A785
Person / Time
Site:	Browns Ferry
Issue date:	08/05/1985
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18029A783	List: ML18029A782 ML18029A785
References
NUDOCS 8508140230
Download: ML18029A785 (25)

Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION REVISIONS BROMNS FERRY NUCl EAR PLANT UNITS lo 2o AND 3 (TVA BFNP TS 211) 8508140230 850805 PDR ADOCK 05000259 I P PDR 4

0 l C

D

PROPOSED CHANGES UNIT 1,

0 l 3.2.D Off-Gas Post Treatment Isolation 4.2.D Off-Gas Post Treatment Isolation Functions Function (b) Frcm and after the date that one of the two offgas post treatment radiation monitors is made or found to be inop-erable, continued reactor power operation is permissible during the next seven days, provided that the inoperable monitor is tripped in the downscale posi-tion. One radiation monitor may be out of service for four hours for Qectional test and/

or calibration without the monitor being in a downscale tripped condition. Both moni-tors may be taken out of service for less than one hour for purg-ing of moriitors during SI perforate.

(c) Upon the loss of both off-gas post treatment radiation moni-tors, initiate an orderly shut-down and shut the mainsteam isolation valves or the off-gas isolation valve within 10 hrs.

Purging during'SI performance is not considered a,loss of monitoring capability.

E. E. D The limiting conditions of operation Instrunentation shall be calibrated and for the instrunentation that monitors checked as indicated in Table 4.2.E.

drywell leak detection are given in Table 3.2.E.

F. F.

'Ihe limiting conditions for the Instrunentation shall be cali-instrunentation that provides sur- brated and checked as indicated veillance information readouts are in Table 4.2.7.

given in Table 3.2.F.

G. G.

The limiting conditions for instrunen- Instrunentation shall be cali-tation that i,solates the control rocm brated and checked as indicated and initiates the control roan emer- in Table 4.2.G.

gency pressurization systems are given in. Table 3.2.G.

52

TASLE 3.2.0 mph~'. ESQ2 2, 0!i EBS&2. t .Xi2TATEOa

'Ao.

a. ~ Tri Level Setti"-e A~aa laa 2) R~a res Note 3 AorB l. 2 upscales, or I dovosca.'nd 1 upscale. or 2 Co2=-

scales vill iso'late of A gas '0e ~

Note 3 l. One trip syste= vith s to iso a Qa tranefer to another so ra 00TES

1. Vbc"~cr the "'ch.~ aMer operable cannot be set, the indi.ate~ action slall be takeo. Purging during the SX performance is not considered a loss of monitoring capability.

2 ~ A"a' A. Refer to Section 3.2.9.1.b B. Refer to Section 3.2.0.l.c

3. Trip cettwB to corzeapond to Specificatioa 3.2.D.1.2L

4. ~ One radiation monitor may beb t- f--service ta k en out-o ervice for o four hours for functional test and/or calibration without the monitor being in a downscale tripped condition.

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS

8. Radioactive gases released from each 4.8.8 Airborne Effluents unit's turbine and reactor building roof vents, the radwaste building roof vents, and the main stack shall be continuously monitored. To accomplish this, at least one reactor building and one turbine building vent monitoring system per unit shall be operating whenever that unit's building ventilation system is in service. Also, one radwaste building system vent monitoring channel shall be operating whenever the radwaste ventilation system is in service.

At least one main stack monitoring channel shall be operating whenever any unit's air ejector, mechanical vacuum pump, or a standby gas treatment system train is in service.

If normal monitoring systems are not available, temporary monitors or other systems shall be used to monitor effluent. A monitoring channel may be out-of-service for 4, hours for functional testing and calibration without providing a temporary monitor. Both stack monitors may be taken out-of-service for less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for purging of monitors during SI peiformance.

If these requirements are not satisfied for the stack or radwaste monitor, the reactors shall be in the hot shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the stack and 10 days for the radwaste vent. Purging during SI performance is not considered a loss of monitoring capability.

If these requirements are not satisfied for the reactor and turbine building vents, the affected reactor shall be in hot shutdown condition within 10 days.

285

PROPOSED CHANGES VNIT 2

I 3.2.D Off-Gas Post Treatment Isolation 4.2.D Off-Gas Post Treatment Isolation Fmctions Funct,ion (b) Fran and after the date that one of the two offgas post treatment radiation monitors is made or found to be inop-erable, continued reactor power operation is permissible during the next seven days, provided that the inoperable monitor is tripped in the downscale posi-tion. One radiation monitor may be out of service for fcur hours for functional test and/

or calibration without the monitor being in a downscale tripped condition. Both moni-tors may be taken out of service for less than one hour for purg-ing of monitors during SI performance.

(c) Upon the loss of both off-gas post treatment radiation moni-tors, initiate an orderly shut-down and shut the mainsteam isolation valves or the off-gas isolation valv'e within 10 hrs.

Purging during SI performance is not considered a loss of monitoring capabil ity.

E. E. D The limiting conditions of operation Instrunentation shall be calibrated and for the instrunentation that monitors checked as indicated in Table 4.2.E.

drywell leak detection are given in Table 3.2.E.

F. F.

The limiting conditions for the Instrunentation shall be cali-instrunentation that provides sur- brated and checked as indicated veillance information readouts are in Table 4.2.7.

given in Table 3.2.F.

G. G.

The limiting conditions for instrunen- Instrunentation shall be cali-tation that isolates the control rocm brated and checked as indicated and initiates the control rocm emer- in Table 4.2.G."

gency pressurization systems are given in Table 3.2.G.

52

TABLE 3.2.0 Ot G' ~ST 'p~s'q ~

1SQ ( ON INST%i .+itTATEO.i Kin. No.

Tri Level Set r inc Action 2) Remarks Off-Gas ."-cs: .reac=,enc Note 3 Aor8 2 upscales, o. l dovnsca';.

Hon I co. and 1 upscale, or . Coi=-

scales vill iso lcc 0 f gas cn 0"-S.= s. 'c erc Note 3 l. One trip syscen vich s co Isola c'on transfer to another so rce

1. %be"~er the MnM~ neer operable cannot be met the indicate" ~

tion shs11 be taken. Purging duxing the SI performance is not considered a loss of monitoring capability.

2. A" t[oa

h. Refer to Section 3.2.D.l.b B. Refer to Section 3.2.D.l.c

3. Trip settbxg to correspond to Specification 3.2.D.l.a

4. One radiation monitor may be taken out-of-service for four hours for functional test and/or calibration without the monitor being in a downscale tripped condition.

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS

8. Radioactive gases released from each 4.8.B Airborne Effluents unit's turbine and reactor building roof vents, the radwaste building roof vents, and the main stack shall be continuously monitored. To accomplish this, at least one reactor building and one turbine building vent monitoring system per unit shall be operating whenever that unit's building ventilation system is in service. Also, one radwaste building system vent monitoring channel shall be operating whenever the radwaste ventilation system is in service.

At least, one main stack, monitoring channel shall be operating whenever any unit's air ejector, mechanical vacuum pump, or a standby gas treatment system train is in service.

If normal monitoring systems are not available, temporary monitors or other systems shall be used effluent. 'A monitoring to'onitor channel may be out-of-service for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for functional testing and calibration without providing a temporary monitor. Both stack monitors may be taken out-of-service for less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for purging of monitors during,SI performance.

If 'these requirements are not satisfied for the stack or radwaste monitor, the reactors shall be in the hot shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the stack and 10 days for the radwaste vent. Purging during SI performance is not considered a loss of monitoring capability.

If these requirements are not satisfied for the reactor and turbine building ven'ts, the affected reactor shall be in hot shutdown condition within 10 days.

285

PROPOSED CHANGES UNIT 3

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.2 PROTECTIVE INSTRUMENTATION 4.2 PROTECTIVE INSTRUMENTATION D. Off-Gas Post Treatment Isolation Function continued reactor power operation is

'permissible during the next seven days, provided that the inoperable monitor is tripped in the downscale position.

One radiation monitor may be out-of-service for four hours for functional test and/or calibration without the monitor being in a downscale tripped condition. Both monitors may be taken out-of-service for less than one hour for purging of monitors during SI performance.

(c) Upon t'e loss of both off-gas post treatment radiation monitors, initiate an orderly shutdown and shut the mainsteam isolation valves or the off-gas isolation valve within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. Purging during SI,performance is not considered a loss of monitoring capability.

52

I Lb&LE 3.2.0 O~-G.-'e .-""ST "V~~i7 ISOMT'QS IÃS t Rl".ZiG'ATlOA Xfn. !lo.

(hers!!e (!l(!) Funcr!a Tr! Level Sett! e Ac t!.oa 2) Remarks 0""-" s ""cs r~a~-e-. Note 3 'A or 8 1. 2 upscales, or l dovascal-H'la! tcr d 1 upscale, or 2 doe=-

scales v!11 !so'.ate oct bote 3 l. Oae r!p syste" v! h s to

!solo t! o~ transude. to acother so'rN

, ~

1. K~e=~cr the "'c~~w a~er operable c aaot be act, the indicate" set!ca st>11 be takeo. Purging during the SI perforr.:ance is not considered a loss of monitoring capabi1ity.

2. 'A=e!on

h. Refer to Sect!oa 3.2.D.l.b B. R=fer to Sect!oa 3.2.D.l.c

3. Trip sett!aB to correspoad to SpecfficatLoa'3.2.D.l.a One radiation monitor may be taken out-of-service for four hours. for functional test and/or calibration without the monitor being in a downsca1e tripped condition.

'r 4 yh

LIMITING CONDITIONS FOR OPL'ION SURVI'.LLLANCI'. RL'(JU IREML'NTS

~ ~

~

8. Radioactive gases released from each 4.8.13 Airborne Ef fluents unit's turbine and reactor building roof vents, the radwaste building roof vents, and the main stack shall be continuously monitored. To accomplish this, at least one reactor building and one turbine building vent monitoring system per unit shall be operating whenever that unit's building ventilation system is in service. Also, one radwaste building system vent monitoring channel shall be operating whenever the radwaste ventilation system is in service.

At least one main stack monitoring channel shall be operating whenever any unit's air ejector, mechanical vacuum pump, or a standby, gas treatment system train is in service.

If normal monitoring systems are not available, temporary monitors or other systems shall be used to monitor effluent, A monitoring channel may be out-of-service for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for functional testing and calibration without providing a temporary monitor. Both stack monitors may be taken out-of-service for less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for purging of monitors during SI performance.

If these requirements are not satisfied for the stack or radwaste monitor, the reactors shall be in the hot shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the stack and 10 days for the radwaste vent. Purging during SI per formance is no t considered a loss of monitoring capability.

If these requirements are not satisfied for the reactor and turbine building vents, the affected reactor shall be in hot shutdown condition within 10 days.

306

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~~ ~ ~5 ENCLOSURE 2 DESCRIPTION, JUSTIFICATION, AND SAFETY ANALYSIS TVA BFNP TS 211 BROWNS FERRY NUCLEAR PLANT Descri tion of Chan es Units 1, 2, and 3 page 52 Specification 3.2.D(b), add the following:

"Both monitors may be taken out of service for less than one hour for purging of monitors during SI performance."

Specification 3.2.D(c), add the following:

"Purging during, SI performance is not considered a loss of monitoring capability."

Units 1 and 2, page 76; Unit 3, page 79 Revise Table 3.2.D, Off as Post Treatment Isolation Instrumentation, by adding to Note 1 the following statement: "Purging during the SI performance is not considered a loss of monitoring capability." And by adding a Note 4 that reads: "One radiation monitor may be taken out of service for four hours for functional test and/or calibration without the monitor being in a downscale tripped condition."

Units 1 and 2, page 285; unit 3, page 306 Add to specification 3.8.B.8 the following statement:

"Both stack monitors may be taken out of service for less than one hour for purging of monitors during SI performance."

and "Purging during SI performance is not considered a loss of monitoring capability."

Unit 3, page 307 reformatting of text to page 306

y~

Justification The proposed change to the technical specifications is justified on the basis that it will only be administrative in nature, and that it will clear up an inconsistency. As the technical specifications are currently written, required surveillance instructions force the plant into a limiting condition for operation. The proposed change would allow the offgas post-treatment and main stack radiation monitors to be taken out of service for up to one hour.

for purging when performing surveillance instructions without entering a limiting condition for operation, thus eliminating this contradiction within the technical specifications. The two radiation monitors are piped in series.

Safet Evaluation The proposed change to the technical specifications would allow both offgas post-treatment radiation monitors, and both main stack radiation monitors to be taken out of service at once for purging, which is required to perform surveillance instructions for these monitors. This change allows up to one hour for purging, and stipulates that this is not to be considered a loss of monitoring capability. This is judged to be a safe action since no change in actual plant procedure will take place. Rather, the only change will be how this activity is documented, since purging of stack monitors will no longer require declaring a limiting condition of operation. Hence, this change is acceptable from a safety analysis point of view.

Purging of these monitors is done as a deliberate action according to approved plant procedures. Purging is a necessary action to determine radiation detector responsiveness and to remove sample activity for background determinations and calibrations. Therefore, the monitors must be, purged to ensure satisfactory operability. The stack and post treatment monitors both sample offgas activity prior to release to the environment. These monitors are backed up by main steam line monitors which are offline detectors which do not require purging.

ENCLOSURE 3 PROPOSED DETERHINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION TVA BFNP TS 211 BROMNS FERRY NUCLEAR PLANT Descri tion of Chan e The proposed amendment is an administrative change being made to clarify when the offgas post-treatment radiation monitors and the main stack monitoring system is to be considered inoperable, In order to perform required surveillance .instructions, it is necessaxy to take these monitors out of service temporarily for purging. The current technical specifications require declaring a limiting condition for operation when purging fox surveillance instructions, This proposed change would allow these monitors to be taken out of sexvice for up to one hour for purging when performing xequired surveillance instructions, and would stipulate that this is not to be considered a loss of monitoring capability for the system.

Basis for No Si nificant Hazards Consideration Determination The Commission has provided guidance for the application of their criteria for a proposed no significant hazards considexation determination by providing examples of amendments that are not likely to involve significant hazards (48 FR 14870) which includes (i) "A purely administrative change to technical specifications: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature." In performance of required surveillance instructions on the offgas post-treatment radiation monitors or main stack radiation monitors, both monitors are taken out of service at once for purging, as the two are piped in series. This requires declaring a limiting condition for operation, as at least one monitor is required to be operable by technical specifications. This is clearly an inconsistency in the technical specifications, since surveillance requirements force a limiting condition for operation, The pxoposed change is purely administrative in nature since the actual plant procedures and practices will not be changed in any way, but rather only how these procedux'es are to be documented. Therefore, because this change is encompassed by example (i), TVA proposes to determine that this requested change involves a no significant hazards consideration.