ML18032A726

Proposed Tech Specs,Deleting Absolute Surveillance Intervals for Five Surveillance Requirements & Allowing Use of Interval Extension That Is Part of Plant Tech Spec Definition of Surveillance

ML18032A726
Person / Time
Site:	Browns Ferry
Issue date:	02/24/1988
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18032A725	List: ML18032A724 ML18032A726
References
TAC-00037, TAC-00038, TAC-00039, TAC-37, TAC-38, TAC-39, TAC-R00310, TAC-R00311, TAC-R00312, TAC-R310, TAC-R311, TAC-R312, NUDOCS 8802290043
Download: ML18032A726 (33)

Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATIONS REVISIONS BRO'ttttNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (TVA BFN TS 238) eg pp9 Pgg @80224 P

REMOVE/INSERT PAGE LIST UNITS le 2s AND 3 Remove Insert 3.7/4.7-19 3.7/4.7-19 3.7/4.7-20 3.7/4.7-20 3.7/4.7-21 F 7/4.7-21 3.9/4.9-4 3.9/4.9-4 3.11/4.11-3 3.11/4.11-3

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Emer enc Ventilation 4.7.E Control Room Emer enc Ventilation

1. Except as specified in 1, At least once every 18 months, Specification 3.7.E.3 below, the pressure drop across the both control room emergency combined HEPA filters and pressurization systems charcoal adsorber banks "hall shall be OPERABLE at all be demonstrated to be less than times when any reactor 6 inches of water at system vessel contains irradiated design flow rate (+ 10'L).

fuel.

2. a. The results of the in-place 20 a ~ The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.E.2 shall be performed flows on HEPA filters and at least once per operating charcoal adsorber banks cycle or once every shall show >997. DOP removal 18 months, whichever occurs and >991. halogenated first Eor standby service hydrocarbon removal when or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of tested in accordance with system operation and ANSI N510-1975. following significant painting, Eire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory b. Cold DOP testing shall be carbon sample analysis shall performed after each show >90%, radioactive methyl complete or partial iodide removal at a velocity replacement of the HEPA when tested in accordance filter bank or after any with ANSI N510-1975 structural maintenance on (130 C, 95'L R.H.). the system housing.

c. System Elow rate shall be c ~ Halogenated hydrocarbon shown to be within +1GC testing shall be performed design flow when tested in after each complete or accordance with ANSI partial x.eplacement of the N510-1975. charcoal adsorber bank or after any structural maintenance on the system housing.

d. Each circuit shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.

BFN 3.7/4.7-19 Unit 1

C+

3.7/4.7'ONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Emer enc 4.7.E. Control Room Emer enc Ventilation Ventilation

3. From and after the date that 3. At least once every 18 months, one of the control room automatic initiation of the emergency pressurization control room emergency systems is made or found to pressurization system shall be be INOPERABLE for any reason, demonstrated.

reactor operation or refueling operations is permissible only during the succeeding 7 days unless such circuit is sooner made OPERABLE.

4. If these conditions cannot be 4. During the simulated automatic met, reactor shutdown shall be actuation test of this system initiated and all reactors (see Table 4.2.G), it shall be shall be in Cold Shutdown verified that the following within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for reactor dampers operate as indicated:

operations and refueling operations shall be terminated Close: FCO-150 B, D, E, and F within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Open: FC0-151, FCO-152 BFN 3.7/4.7-20 Unit 1

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCEternREQUIREMENTS

3. 7 .F. Primar Containment Pur e 4.7.F. Primar Containment Pur e

~estem ~em

1. The primary containment shall 1. At least once every 18 months, be normally vented and purged the pressure drop across the through the primary containment combined HEPA filters and purge system. The standby gas charcoal adsorber banks shall treatment system may be used be demonstrated to be less than when primary containment purge 8.5 inches of water at system system is INOPERABLE. design flow rate (+ 107.').

2. a. The results of the in-place 2. a. The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.F.2 shall be performed flows on HEPA filters and at least once per operating charcoal adsorber banks shall cycle or once every show >991m DOP removal and 18 months, whichever occurs

>991m halogenated hydrocarbon first or af ter 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> removal when tested in of system operation and accordance with following significant ANSI N510-1975. painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory b. Cold DOP testing shall be carbon sample analysis performed after each shall show >851. radioactive complete or partial methyl iodide removal when replacement of the HEPA tested in accordance with filter bank or after any ANSI N510-1975 structural maintenance on (130 C 95Vo R.H.). the system housing.

c. System flow rate shall be c. Halogenated hydrocarbon shown to be within +10'1. of testing, shall be performed design flow when tested in after each complete or accordance with ANSI N510- partial replacement of the 1975. charcoal adsorber bank or after any structural maintenance on the system housing.

BFN 3.7/4.7-21 Unit 1

1 3.9/4.9 AUXILIARY ELECTRICAL SYSTEM LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.9.A. Auxiliar Electrical E ui ment 4.9.A. Auxiliar Electrical S stem

2. The reactor shall not be 2. DC Power System Unit started up (made critical) Batteries (250-V), Diesel-from the hot standby condition Generator Batteries (125-V) unless all of the following and Shutdown Board Batteries conditions are satisfied: (250-V)

a. At least one offsite power a. Every week the specific source is available as gravity, voltage and specified in 3.9.A.l.c. temperature of the pilot cell and overall battery voltage shall be measured and logged.

b. Three units 1 and 2 diesel b. Every three months the generators shall be measurement shall be made OPERABLE. of voltage of each cell to nearest O.l volt, specific gravity of each cell, and temperature of every fifth cell. These measurements "hall be logged.

c ~ An additional source of c. At least once every 24 power consisting of one months, a battery rated of the following: discharge (capacity) test shall be performed (1) A second offsite and the voltage, time, power source available and output current as specified in measurements shall 3.9.A.l.c. be logged.

(2) A fourth OPERABLE units 1 and 2 diesel generator.

Requirements 3.9.A.3 through 3,9.A.6 are met.

BFN 3.9/4.9-4 Unit 1

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3 '.E. Control Room Emer enc Ventilation 4.7.E Control Room Emer enc Ventilation

1. Except as specified in l. At least once every 18 months, Specification 3.7 '.3 below, the pressure drop across the both control room emergency combined HEPA filters and pressurization systems charcoal adsorber banks shall shall be OPERABLE at all be demonstrated to be less than times when any reactor 6 inches of water at system vessel contains irradiated design flow rate (t 101.).

fuel.

2. a. The results of the in-place 2. a. The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.E.2 shall be performed flows on HEPA filters and at least once per operating charcoal adsorber banks cycle or once every shall show >99% DOP removal 18 months, whichever occurs and >991o halogenated first for standby service hydrocarbon removal when or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of tested in accordance with system operation and ANSI N510-1975. following significant painting, f ire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory b. Cold DOP testing shall be carbon sample analysis shall performed after each show >901'adioactive methyl complete or partial iodide removal at a velocity replacement of the HEPA when tested in accordance filter bank or after any with ANSI N510-1975 structural maintenance on (130 Cy 951o R H ) the system housing.

c. System flow rate shall be c. Halogenated hydrocarbon shown to be within +10'/. testing shall be performed design flow when tested in after each complete or accordance with ANSI partial replacement of the N510-1975. charcoal adsorber bank or after any structural maintenance on the system housing.

d, Each circuit shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.

BFN 3.7/4.7-19 Unit 2

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~

l 3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Emer enc 4.7.E. Control Room Emer enc Ventilation Ventilation

3. From and after the date that 3. At least once every 18 months, one of the control room automatic initiation of the emergency pressurization control room emergency systems is made or found to pressurization system shall be be INOPERABLE for any reason, demonstrated.

reactor operation or refueling operations is permissible only during the succeeding 7 days unless such circuit is sooner made OPERABLE.

4. If these conditions cannot be 4. During the simulated automatic met, reactor shutdown shall be actuation test of this system initiated and all reactors shall be in Cold Shutdown (see Table 4.2.G), it shall be verified that the following within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for reactor dampers operate as indicated:

operations and refueling operations shall be terminated Close: FCO-150 B, D, E, and F within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Open: FCO-151 FCO-152 BFN 3,7/4.7-20 Unit 2

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS

3. 7. F. Pr imar Containment Pur e 4.7.F: Frimar Containment Pur e

~System ~sat em

1. The primary containment shall At least once every 18 months, be normally vented and purged the pressure drop across the through the primary containment combined HEPA filters and purge system. The standby gas charcoal adsorber banks shall treatment system may be used be demonstrated to be less than INOPERABLE'.

when primary containment purge system is 8.5 inches of water at system design flow rate (+ 10%).

2. a. The results of the in-place 2. a. The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.F.2 shall be performed flows on HEPA filters and at least once per operating charcoal adsorber banks shall cycle or once every show >997 DOP removal and 18 months, whichever occurs

>997 halogenated hydrocarbon first or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> removal when tested in of system operation and accordance with following significant ANSI N510-1975. painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory b. Cold DOP testing shall be carbon sample analysis performed after each shall show >851. radioactive complete or partial methyl iodide removal when replacement of the HEPA tested in accordance with filter bank or after any ANSI N510-1975 structural maintenance on

( 130 C 95'Fa R H )

~ ~ ~ the system housing.

c. System flow rate shall be c. Halogenated hydrocarbon shown to be within +10%, of testing shall be performed design flow when tested in after each complete or accordance with ANSI N510- partial replacement of the 1975. charcoal adsorber bank or after any structural maintenance on the system housing.

BFN 3.7/4.7-21 Unit 2 sm meeee

3.9/4.9 AUXILIARY ELECTRICAL SYSTEM LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.9.A. Auxiliar Electrical E ui ment 4.9.A. Auxiliar Electrical S stem

2. The reactor shall not be 2. DC Power System Unit started up (made critical) Batteries (250-V), Diesel-from the hot standby condition Generator Batteries (125-V) unless all of the following and Shutdown Board Batteries conditions are satisfied: (250-V)

a. At least one offsite power a. Every week the specific source is available as gravity, voltage and specified in 3.9.A.l.c. temperature of the pilot cell and overall battery voltage shall be measured and logged.

b, Three units 1 and 2 diesel b. Every three months the generators shall be measurement shall be made OPERABLE. of voltage of each cell to nearest 0.1 volt, specific gravity of each cell, and temperature of every fifth cell. These measurements shall be logged.

c. An additional source of c. At least once every 24 power consisting of one months, a battery rated of the following: discharge (capacity) test shall be performed (1) A second offsite and the voltage, time, power source available and output current as specified in measurements shall 3.9.A.l,c. be logged.

(2) A fourth OPERABLE units 1 and 2 diesel generator.

d. Requirements 3.9.A.3 through 3.9,A.6 are met.

BFN 3.9/4.9-'4 Unit 2

I 3.11/4.11 FIRE PROTECTION SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.11.A. Hi h Pressure Fire Protection 4.11.A. Hi h Pressure Fire

~Ss tern Protection S stem area where protection is lost is checked hourly.

3. If only one high 3. Raw Service Mater pressure fire pump is S stem Testin OPERABLE, the reactors may remain Item ~Fee mene in operation for a period not to exceed Simulated Once/year 7 days, provided the automatic requirements of and manual Specification actuation 3.11.A,l.b above of raw service are met. water pumps and operation of tank level switches.

4, If Specification 4. The high pressure 3,11.A.3 cannot be fire protection met, the reactors system pressure shall be placed in shall be logged the Cold Shutdown daily.

condition in 24 hours.

5. Removal of any 5. Principal header component in the High and component Pressure Fire System isolation valves from service for any shall be checked reason other than open at least once testing or emergency every 3 months.

operations shall require Plant Superintendent approval.

6. The Raw Service ~<later storage tank level shall be maintained above level 723'7" by the raw service water pumps.

3.11/4.11-3 Unit 1

3.11/4.11 FIRE PROTECTION SYSTEMS tern LIMITING CONDITIONS FOR OPERATION SURVEILlANCE REQUIREMENTS 3.11.A. Hi h Pressure Fire Protection 4.11.A. Hi h Pressure Fire

~Ss Protection S stem area where protection is lost is checked hourly.

3. If only one high 3. Raw Service Water pressure fire pump is S stem Testin OPERABLE, the reactors may remain Item ~Fre uene in operation for a period not to exceed Simulated Once/year 7 days, provided the automatic requirements of and manual Specification actuation 3.11.A.l,b above of raw service are met. water pumps and operation of tank level switches.

4. If Specification 4. The high pressure 3.11.A.3 cannot be fire protection met, the reactors system pressure shall be placed in shall be logged the Cold Shutdown daily.

condition in 24 hours.

5 ~ Removal of any 5. Principal header component in the High and component Pressure Fire System isolation valves from service for any shall be checked reason other than open at least once testing or emergency every 3 months.

operations shall require Plant Superintendent approval.

6. The Raw Service Water storage tank level shall be maintained above level 723'7" by the raw service water pumps BFN 3.11/4.11-3 Unit 2

J 1

lu

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Emer enc Ventilation 4.7.E Control Room Emer enc Ventilation

l. Except as specified in 1. At least once every 18 months, Specification 3.7.E.3 below, the pressure drop across the both control room emergency combined HEPA filters and pressurization systems charcoal adsorber banks shall shall be OPERABLE at all be demonstrated to be less than times when any reactor 6 inches of water at system vessel contains irradiated design flow rate (+ 107').

fuel.

2. a. The results of the inplace 2. a. The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.E.2 shall be performed flows on HEPA filters and at least once per operating charcoal adsorber banks cycle or once every shall show >99fo DOP removal 18 months, whichever occurs and >997 halogenated first for standby service hydrocarbon removal when or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of tested in accordance with system operation and ANSI N510-1975. following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory b. Cold DOP testing shall be carbon sample analysis shall performed after each show >901+ radioactive methyl complete or partial iodide removal at a velocity replacement of the HEPA when tested in accordance filter bank or after any with ANSI N510-1975 structural maintenance on (130 C, 95% R.H.). the system housing.

c. System flow rate shall be c. Halogenated hydrocarbon shown to be within testing shall be performed flow when tested in

+10'esign after each complete or accordance with ANSI partial replacement of the N510-1975. charcoal adsorber bank or after any structural maintenance on the system housing.

d. Each circuit shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.

BFN-Unit 3 3.7/4.7-19

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Emer enc 4.7.E. Control Room Emer enc Ventilation Ventilation

3. From and after the date that 3. At least once every 18 months, one of the control room automatic initiation of the emergency pressurization control room emergency systems is made or found to pressurization system shall be be INOPERABLE for any reason, demonstrated.

reactor operation or refueling operations is permissible only during the succeeding 7 days unless such circuit is sooner made OPERABLE.

4. If these conditions cannot be 4. During the simulated automatic met, reactor shutdown shall be actuation test of this system initiated and all reactors (see Table 4.2.G), it shall be shall be in Cold Shutdown verified that the following within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for reactor dampers operate as indicated:

operations and refueling operations shall be terminated Close: FCO-150 B, D, E, and F within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Open: FC0-151, FCO-152 BFN-Unit 3 3.7/4.7-20

3.7/4.7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.F. Primax Containment Pux e 4.7.F. Primar Containment Pur e

~metes ~set em 1 ~ The primary containment shall l. At least once every 18 months be normally vented and purged the pressux'e drop across the thxough the primary containment combined HEPA filters and purge system. The standby gas charcoal adsorber banks shall treatment system may be used be demonstrated to be less than when primary containment purge 8.5 inches of watex't system system is INOPERABLE. design flow rate (+ 101.).

2. a. The results of the in-place 2. a. The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.F.2 shall be performed flows on HEPA filters and at least once per operating charcoal adsorber banks "hall cycle or once every show >99'5 DOP removal and 18 months, whichever occurs

>99fo halogenated hydrocarbon first or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> removal when tested in of system operation and accordance with following significant ANSI N510-1975. painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory b. Cold DOP testing shall be carbon sample analysis performed after each shall show >85'L radioactive complete ox paxtial

- methyl iodide removal when replacement of the HEPA tested in accordance with filter bank or after any ANSI N510-1975 structural maintenance on (130 C 951m R H ~ ) the system housing.

c. System flow rate shall be c. Halogenated hydrocaxbon shown to be within +101m of testing shall be performed design flow when tested in after each complete or accordance with ANSI N510- partial replacement of the 1975. charcoal'dsorbex bank or after any structural maintenance on the system housing.-

BFN-Unit 3 3.7/4.7-21

4 3.9/4.9 AUXILIARY ELECTRICAL SYSTEM LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.9.A. Auxiliar Electrical E ui ment 4.9.A. Auxiliar Electrical

~Setem

2. The reactor shall not be 2. DC Power S stem Unit started up (made critical) Batteries (250-V),

from the Hot Standby condition Diesel-Generator unless all of the following Batteries (125-V)and conditions are satisfied: Shutdown Board Batteries (250-V)

a. At least one offsite power a. Every week the source is available as specific gravity, specified in 3,9.A.l.c. voltage, and temperature of the pilot cell, and overall battery voltage shall be measured and logged.

b. Three units 3 diesel b. Every three month" generators shall be the measurements OPERABLE. shall be'made of voltage of each cell to nearest 0.1 volt, specific gravity of each cell, and temperature of every fifth cell.

These measurements shall be logged.

Ce An additional source of c. At least once every 24 power consisting of one months, a battery rated of the following: discharge (capacity) test shall be performed (1) A second offsite and the voltage, time, power source available and output current as specified in measurements hall 3.9.A.l.c. be logged.

(2) A fourth unit 3 diesel generator OPERABLE.

d. Requirements 3.9.A.3 through 3.9.A.6 are met.

BFN-Unit 3 3.9/4.9-4 P

'e em emmet wee 4u

3.11/4.11 FIRE PROTECTION SYSTEMS tern LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.11.A. Hi h Pressure Fire Protection 4.11.A. Hi h Pressure Fire

~em Protection S stem 3.11.A.2. (Cont'd) area where protection is lost is checked hourly.

3. If only one high 3 ~ Raw Service Water pressure fire pump is S stem Testin OPERABLE, the reactors may remain Item ~eee ueee in operation for a period not to exceed Simulated Once/year 7 days, provided the automatic requirements of and manual Specification actuation 3.11.A,l.b above of raw service are met. water pumps and operation of tank level switches.

4, If Specification 4. The high pressure 3.11.A.3 cannot be fire protection met, the reactors system pressure shall be placed in shall be logged the Cold Shutdown daily.

condition in 24 hours.

5. Removal of any 5. Principal header component in the High and component Pressure Fire System isolation valves from service for any shall be checked reason other than open at least once testing or emergency every 3 months.

operations shall require Plant Superintendent approval.

6. The Raw Service Water storage tank level shall be maintained above lovel 723'7ee by the raw service water pumps.

BFN-Unit 3 3.11/4.11-3

ENCLOSURE 2 Description and Justification Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Descri tion of Chan e BFN Units 1, 2, and 3 Technical Specifications are being revised to replace "not to exceed" with "at least once every" for five Surveillance Requirements. This will allow interval extensions per BFN Technical Specification definition of surveillance.

The following technical specification Surveillance Requirements (SR) are affected by this change:

SR 4.7.E.1 (page 3.7/4.7-19) Control Room Emergency Ventilation System pressure drops across the combined HEPA filters and charcoal adsorber banks.

SR 4,7 '.3 (page 3.7/4,7-20) Control Room Emergency Ventilation System automatic initiation of the system.

SR 4.7,F,1 (page 3.7/4.7-21) Primary Containment Purge System pressure drop across the combined HEPA filters and charcoal adsorber banks.

The current .technical: specification words "at least once per operating cycle, not to exceed 18 months" are replaced by "at least once every 18 months."

SR 4.9.A.2.c (page 3.9/4.9-4) Auxiliary Electrical System battery rated discharge test.

The current technical specification words "at intervals not to exceed 24 months" are replaced by "at least once every 24 months."

SR 4,11.A.5 (page 3,11/4.11-3) High Pressure Fire Protection System, Raw Service Mater System principal header, and component isolation valve checks.

The current technical specification words "at intervals no greater than 3 months" are replaced by "at least once every 3 months,"

Reason for Chan e These five SR intervals are unlike other BFN Technical Specification surveillance intervals in that their language does not permit application of BFN TS definition 1.0 'L, Surveillance. This results in inconsistency and a potential for misapplication o'f the surveillance intervals.

t~

Justification for Chan e The language change makes these five surveillance requirements consistent with other BFN surveillance intervals in that it permits the application of surveillance (definition 1.0.LL page 1.0-11). This definition allows a maximum extension of a single surveillance interval not to exceed 25 percent of the interval. The combined time for any three consecutive surveillance intervals is not to exceed 3.25 times the specified surveillance interval.

Thus this wording change adds flexibility to the surveillance scheduling without any significant impact on the surveillance intervals.

Surveillance Requirement 4.7.E.l demonstrates that the Control Room Emergency Ventilation filters and adsorbers are not clogged with excessive amounts of foreign matter. This is done by measuring the pressure drop across the combined filters and charcoal adsorber banks. A review of the data collected during performance of the surveillance shows that the recorded pressure drop is less than one half of the technical specification limit. This surveillance is normally scheduled during refuel outages. This change is in agreement with standard technical specifications and the custom technical specifications of Peach Bottom and Cooper Nuclear Station, Deleting the once-per-operating cycle phrase will not result in a significant change in the requirements since the 18-month interval corresponds to the planned operating cycle and will almost always be the most restrictive surveillance interval.

Surveillance Requirement 4,7.E.3 demonstrates the automatic initiation function of the Control Room Emergency Ventilation System. The same justification as above applies to this surveillance requirement. In addition, the circuitry is not anymore time dependent than any of the other initiation circuits which are tested at 18-month intervals.

The same justification applies to surveillance requirement 4.7.F.1 which demonstrates that the Primary Containment Purge System filters and adsorbers are not clogged with foreign material.

Surveillance requirement 4.9.A,2.c demonstrates that the unit batteries, the diesel generator batteries, and the shutdown board batteries have maintained their rated capacities by performing a rated discharge. The change in the surveillance interval to "at least once every 24 months" does not decrease the confidence that the batteries are. at rated capacity. Pilot cell and individual cell tests are performed at frequencies that would indicate irregularities long before failure.

Surveillance requirement 4.11,A.5 verifies that the fire protection header and component isolation valves are open. The change to once every three months is consistent with other surveillance intervals and will not increase the probability of a mispositioned valve going undetected for a long period of time.

The intent of surveillance requirements to ensure system operability is not affected by this change. Although the average surveillance interval may be slightly longer, the definition of surveillance allows for this. No adverse safety consequences result from the proposed change. The change improves nuclear safety by minimizing unnecessary plant shutdowns that may be required by inadvertently exceeding the present absolute time intervals.

ENCLOSURE 3 Determination of No Significant Hazaxds Consideration Bxowns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Descxi tion of Pro osed TS Amendment The proposed amendment would change the BFN TS for units 1, 2, and 3 to eliminate the unnecessary and inappropriate use of absolute surveillance intervals for TS 4.7.ED 1, 4.7.8.3, 4.7.F.1, 4.9.A.2.c, and 4.11.A.5. This amendment would then allow application of the provisions of BFN TS Definition 1.0.LL, Surveillance.

Basis for Pro osed No Si nificant Hazards Consideration Determination NRC has provided standards fox'etermining whether a change to the facility operating license ox the technical specifications involves a significant hazards consideration, as stated in 10 CFR 50.92(c). A proposed amendment to an operating license for a facility 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 pxeviously evaluated, ox (2) cxeate the possibility of a new ox diffexent kind of accident from any accident pxeviously evaluated, ox (3) involve a significant reduction in the margin of safety.

A discussion of these standards, as they relate to this amendment, is as fo llows.

1. The probability ox consequences of an accident previously evaluated in the BFN Final Safety Analysis Report (FSAR) would not be affected by these TS changes. The BFN systems affected by these proposed amendments are not typically considered in determining accident probabilities. The consequences of an accident are not affected since the limiting conditions for opex'ation and the types .of suxveillance testing used to confirm operability are not changed. In addition, the SR interval extension which would be allowed under the application of TS Definition 1.0.LL is consistent with the original intent of the TS surveillances for these BFN systems (as evidenced by other BFN TS surveillance intervals, other BUR custom TS, and the General Electric Standard TS for similax system applications). As such, the criteria set forth in 10 CFR 50.92(c)(1) is satisfied.

2. The possibility of a new ox different kind of accident than previously evaluated in the BFN FSAR would not be created by the proposed TS changes. These changes will not eliminate or modify any protective functions and will not permit any new plant operational conditions. In addition, these changes do not eliminate or modify the type of surveillance testing done on these systems. Application of TS Definition

Basis for Pro osed No Si nificant Hazards Consideration Determination (Cont'd) 1.0.LL in these cases cannot create a new type of accident since flexibility in the SR time intervals is the only change proposed. Based on this, the criteria set forth in 10 CFR 50.92(c)(2) is satisfied.

3. The margin of nuclear safety is not reduced by the proposed changes.

These changes do not modify the intent of BFN TS. Application of TS Definition 1.0.LL to these BFN SRs is consistent with similar system applications in other BFN TS surveillances, other BMR custom TS surveillances, and the GE-STS. Based on this, the criteria set forth in 10 CFR 50.92(c)(3) is satisfied.

Since the application for amendment involves a proposed change that is encompassed by the criteria for which no significant hazards consideration exists, TVA proposes to determine that the proposed amendment does not involve a significant hazards consideration.