ML18030B114
| ML18030B114 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/12/1986 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18030B113 | List: |
| References | |
| TAC-60822, TAC-60823, TAC-60824, NUDOCS 8602210451 | |
| Download: ML18030B114 (17) | |
Text
ENCLOSURE 1
PROPOSED TECHHLCAL SPECIE>> ICAT10iV REVISIONS BROMNS FERRY HUCLEAR PLANT UMLT 1, 2, AtlD 3 t,'TVA BFVP TS 217)
S~O2a1OeSX S6O~i~
I PDR ADOCK 05000259 P
PDRl
PROPOSED CfkhtN'ES UtllT 1
l T
~
~
LXH TING CONDITIO!'JS FOR OPKPvXTXCN SURVEILLANCE RE'3UX RE!!Fl'ITS 6." ~an c
ST...<
OU':DARY
/<, 6 PRIORY SYST u Rorr!D >.,v Seismic Rns trains, Suonort Sc s !ic qescr<<<<c S
~
<<d S<uL'< r<
"< (<<! <<<<<4 <<<0<<
'4<
During all modes of operation, all seismic restraints,
All safety-related snubbers are listed in Surveillance Instruction BF SX 4.6.H.
l.
10.th one or more seismic restraint,
- support, or snubber inoperable on a system that is required to be operable in the current plant condition, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable seismic restraint(s),
support(s),
or snubber(s) to operable status and perfor m an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.
The su vei1 lance
<<1!qu: <<e! e<<<
of paragraph 4
~ 6 C cre c!e only requirements that apzly co anv seismic e<s!.ra
<<u!porc 0<'1 e c'1' snubbc Fac1
~a
~ /
c!a e" sn roe
~
1 be demonstrated OPERABL".
BY perinrmancc of chc fo o'"
auguncntc'n ezvice in"!c""'oa progr m and tne rcquir<<ments o:
Soecifi 1cion 3.6.Y/4.6.H.
These sn.!bbers are I'sceG Su<<ve illanc(
I!lettuce 0 1 BF SI 4.6.!!.
~
Insn<!reit!n Group; Thi! <<Ilubb< I 8 ma/ hc cace-gor'd into tvo major groups based on uhcthcr che snubbers arc acccssib'e or inacces"ible during reactor operation.
Th>>sc major grouos may b>> further subdivided inco groups based on dc"ign, envir-
- onment, or oth>>r features uh' mav be exnecced co affect the operability o.
the snubbers lithic the group.
8'ach
, roup mav bc ins;ected indeprn'cnclv ir.
accordance with 4.6.H.2 through 4.6. H.9.
Vise 1 1 Insane Cion Sckledul c
<nd '.<; Si=c Thc ".'"."c inservice visual in paction of nubbcrs not previously included in these cechnical specificacions anc uhose visual inspection has noc baca periormcd and documented previously, shall be oeriorm d vithin six month.". for accessible snub-ber's and beiore r<<suming pouer airer che first refueling outage 185
YROPOSED CfKtlGES UiVlT 2
L tl TING CONDITIO'.7S FOR OPERATIC,J SURVEILLANCE REQUXRENENTS
..6 PP. '!A"Y SYSTEM., B"F.:DARY 4 ~ 6 PRTi~ARY SvSTE!! Min!D>;,v Sc'"-.'c Restraints.
- Supports, 5
i bbe~e and Sttubbers
~
~
~.
During all modes of operation, all seismic restraints,
All safety-related snubbcrs are listed in Surveillance Instruction BF SI l!.6.H.
1.
Mith one or more seismic restraint,
- support, or snubber inoperable on a system that is required to be operable in the current plant condition, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable seismic restraint(s),
support(s),
or snubber(s) to operable status and per form an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.
The suzve'llance zpqu et en>>
p of par p aoh 4.u.Q ize he only t.c.qt t.
em nt tiat qpo o any seismic zestza'nt oz "u"po <<~le t t i nuait.
s ac>>a it.
<<e'a r" ~n oat.
s~
l be demonstrated OPE";iABLE BY pezfot:;, nte o. t!tc fo' u'"".
au!;um 'n: t.
insc r vice in".'>e;: t'n prost'am and he zrrui eme.
~t s o
'neci f'ation
- 3. i. H/4. u. H.
Suzve'lance jn"tzuetion BF 5!
l ~
?nsnuction t rouos Tltu s.>>ubb>> re t t". g be cate-gori <<d into tvo major groups based on whether the snubbcrs are accessib'c or inaccessible durina re ctoz opezat'on.
Tlte c pa)or grouos may be further subd vidcd into groups based on design.
rn;"-'z-one:ent, or other features Mh ch may
)e e"Dectc '0 affect the operabi'itv of the snubbers uithin the grot.p.
Each group mav bc ins;ected indeorndcn:t r acccrdance with 4.o.l!.2 throu
~h 4.6.H.9.
Visual Tnsnectiott Sched le.
and 'o" Si c Thc." rst inservice ri"ual inspection of snubbers not previously included in these technical spec'fications and whose visual 'nspcction has not been oerfozmcd and documented previously, shall be perform d within six mon h
foz acccs: iblc "nub-bezs and betore resum!.ng pouez a rer thc first refueling outage 105
PROPOSED ClfAHGI".S UNIT 3
C
~
~
r
~
~
4 Y, TING CONDITIO'3S FOR OPEPvXTIG'8 URUEILLANCE REQUIREMENT'1TS 3.6 PRIMARY S
l <<OUNDARY
- 4. G i gg gg'RY SY'ST !l <<OrNDAPv H.
Seismic 'Aastzaints, S>>onozts, and Snubbcx s During all modes of operation, all seismic restraints,
hll safety-related snubbers are listed in Surveillance Instruction BF SI 4.6.H.
1.
llith one or more seismic restraint,
- support, or snubber inoperable on a system
- that, is requi'red to be operable in the current plant condition, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restor e the inoperable seismic restraint(s),
support(s),
or snubber(s) to operable status and perform an engineering evaluation on the attached component or declare the attached system inoperable and follow the appropriate Limiting Condition statement for that system.
Seismi- <cstrain-s and Snubbers u vex. ianca
<qx, ep(Q 5
or pazag a Jh 4. G. G are the only requirements thax, apn'y to any sexs'ale zest a'n ox'upport o her than snubbazs.
Each sa:ety-relate" sn bber sha.l be demonstrated OPER.EB!.E BY perxnz:"anc<< of thc foouinz augumcnxu
'nsezvice ins iecz ion progr m and the requirements o:
Snecif a ion 3.G.H/4.G.H These sn.sbbars aze 1 stad Surveiilancc instzuction BF SI 4. G. ll.
1.
Tn'ec ion Groups Tl>>: ia>>ibbers city be cace-gorixud into tvo na)or groups based on xshethez the snubbers are acccssib'e ox inacces iblc during zeacrox operation.
These ~a)oz groups may bc further subdivided inro groups based on design, envir-onment, ox'ther features uhich aav bc exncctad to affect the opcrabilirv o:
the sn>>b be rs xsithin t h c groi.p.
Each group mai bc ins", acted indepcndcntls in accordance xsith A.G.H.2 thzntlgh 4.6.H.9.
2.
Visual. Insncction Schedule.
an" 't 5 i-c Thc first 'nservice viual in paction of nubbcrs not prcvinusly included in these technical specificacions anc whose visual inspection ha" nox bean performed and documented previously, snail bc perform d within six months fox accessible snub-ber=
and bexora zesuning
~ pouez after the fiz t refueling outage 198
ENCLOSURE 2
OESCRTPTrON hNO JUSTXFICAVrON BROL(NS FERRY NUCLEAR PLhi~1T UNITS 1, 2, AND 3 (TVA BFHP TS 217)
Description and Justification Descri tion of Chan e
Page 198 of unit 3 and page 185 of units 1 and 2 technical specifications are revised in section 3.6.H to reflect the limiting conditions for operation given in Standard Technical Specifications (STS) for seismic restraints,
- supports, and snubbers (SRSS).
This results in improved clarity and allows for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to replace or restore the inoperable SRSS when in the shutdown or refueling modes.
The requirements in effect for startup/standby mode and run will not be changed since the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to perform corrective action in these modes is already allowed.
- However, the restriction that all SRSS be operable prior to reactor startup would be deleted by adopting STS language.
Reason for Chan e
The present wording of technical specifications does not allow any time to perform corrective action on SRSS when in the shutdown or refueling modes, resulting in overly restrictive limiting conditions when snubbers are out of service during those operating modes.
Justification for Chan e
Section 3.6.H specifies limiting conditions and actions applicable to SRSS for all safety systems.
The basis for this requirement is to ensure integrity of the safety systems which depend upon SRSS to accommodate anticipated loads during a seismic event.
Because SRSS are only required for relatively low probability events, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for repair or replacement.
The proposed amendment would not compromise plant safety in that the only substantive change requested is to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to replace or restore the inoperable SRSS when in the shutdown or refueling mode.
This allowance is already provided for in the startup and run modes which normally have more restrictive requirements than shutdown and refueling.
Therefore, no significant loss of safety margin should result by allowing the same time period to perform corrective actions when in shutdown or refueling modes that is allowed in startup and run modes.
The proposed amendment also reflects the guidance provided in NUREG-0123, the Standard Technical Specifications.
Tho impact on nuclear safety of starting up with an inoperable SRSS and
- thereby, entering a 72-hour LCO is equivalent to having an SRSS inoperable in any 72-hour period during reactor operation.
Therefore, elimination of the specific restriction on reactor startup with an inoperable SRSS versus 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />" allowable repair time has no significant safety impact. It should be noted that instances of starting the reactor prior to completing a
SRSS repair would rarely occur.
The BblR Standard Technical Spocificatlons contain no similar restriction on tartup.
ENCLOSURE 3
DETERHIHATIOH OP HO SIGHll"ICAHT ltA'IARDS COHSIDERATIOH BRO&JNS FERRY NUCLEAR PLANT UNITS 1, 2, AHD 3 (TVA BFHP TS 2l7)
I
Determination of No Significant Hazards Consideration Descri tion of Amendment Re uest The proposed amendment would change the technical specifications of Browns Ferry Nuclear Plant, units 1, 2, and 3, to clarify the requirements for Seismic Restraints, Supports and Snubbers (SRSS) by adopting STS requirements which would also allow for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to perform corrective actions on the SRSS when in the refueling or shutdown modes, as is already allowed for in the startup and run modes of operation, and delete the requirement that all SRSS be operable prior to reactor startup.
Basis for No Si nificant Hazards Consideration Determination The Licensee has evaluated the proposed amendment in accordance with the standards provided in 10 CFR 50.92(C) and determined that:
1.
The proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated since the probability of occurrence of any evaluated accident does not depend on SRSS being operable and the consequences of any accident which would be dependent on the operability of SRSS, would be less severe during shutdown or refueling mode than a similar accident in the startup or run modes of operation which already have a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowance to perform repair or replacement of the SRSS.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because this change does not remove any equipment or affect the performance of any equipment in ways not previously evaluated.
3.
The proposed amendment does not involve a significant reduction in the margin of safety for the same reasons as described in items (1) and (2)
- above, and also because the proposed technical specification is consistent with the guidance provided in Standard Technical Specifications and finally because no surveillance requirements would be changed.
Therefore, TVA proposes to determine that the proposed amendment does not involve significant hazards considerations.