Text

Proposed Tech Specs to Allow Operation During Cycle 6 of Unit 2 W/Control Room Emergency Ventilation Sys Declared Inoperable Only When Design Basis for Essentially Zero Unfiltered Inleakage Not Met
	ML18033A629
Person / Time
Site:	Browns Ferry
Issue date:	02/14/1989
From:	; TENNESSEE VALLEY AUTHORITY
To:	;
Shared Package
ML18033A628	List: ML18033A626; ML18033A629;
References
	NUDOCS 8902170153
	Download: ML18033A629 (29)
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ENCLOSURE I REVISED TECHNICAL SPECIFICATION PAGES FOR TEHPORARY TECHNICAL SPECIFICATION AHENDMENT NO. 265T 8902i70i53 8902i4 PDR 'AOOCK 05000259 P PDC

I 3'.7/I.7 COHTAImEHT SVS . S

.LIHITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREHEHTS 3.7.E. Control Room Emer enc Ventilation 4.7.E Control Room Emer enc Ventilation

1. Except. as specified in l. At least once evevy 18 months, Specification 3.7.E.3 below, the pressure drop across the both control room emevgency combined HEPA filters and pressurization systems charcoal adsorbev banks shall shall be OPERABLE at all be demonstvated to be less than times when any re.actor 6 inches of water at system vessel contains irradiated desipn flow rate (+ 10%%u.).

fuel.

2. a. The results of the inplace 2. a. The tests and sample cold DOP and halopenated analysis of Specification hydrocavbon tests at design 3. 7.E. 2 shall be per farmed flows on HEPA filtevs and at least once per operatinp charcoal adsorber banks cycle or once every "hall show >99% DOP removal 18 months, whichever occurs and >99% halopenated fivst for standby service hydrocavbon removal when or after every 720 houvs of tested in accordance with system operation and ANSI H510-1975. followinp sipnificant painting, fire, or chemical release in any ventilation zone communicatinp with the system.

b. The results of laboratory b. Cold DOP testinp shall be cavbon .=ample analysis .:hall performed after each show >90% radioactive methyl complete or pavtial iodide removal at a volocity replacement of the HEPA when teste'd in accordance filtev bank or after any with ASTH D3803 stvuctural maintenance on (130 C, 95% R.H.). the system housing.

CREVS i" consideved inoperable only becau "e it does not meet its desipn basis for essentially zero unf iltered inleakape. REACTOR POMER OPERATION and fuel movement, ave acceptable until just PRIOR TO STARTUP for unit, 2 cycle 7. Durinp cycle 6, CREVS must be demonstvated to be functional by performing all applicable surveillances. In the event that the applicablo surveillances are not successfully performed, the actions required by the LCO's must be complied with.

UFH 3.7/4.7-19 Unit 1

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3.7/4.7 COHTAIHMEHT SYST . S

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LIMITIHG CONDITIONS POR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Fmer enc 4.7.E. Contxol Room Fmex enc Ventilation Ventilation

c. System flow r;ate "hall be c. Halogenated hydrocar;bon shown to be withitl +10/ testing shall be performed design Elow when tested in after each complete or..

accordance with ANSI paxtial replacement of the N510-1975. charcoal adsovbex bank or after any stxwctural maintenance on tho system housirlp .

d. Hach civcuit, shall bo operated at least 10 hour:s every month.

3. Prom and after the date that 3. At least once evevy 18 months, one oE the contxol room automatic initiation of the emergency pr;essurizat,io'n control room emergency systems is made or found to pt.'essuxization system "hall be be INOPERABLE for any t.eason, demonstxated.

reactor opevation or refueling oper;ations i: permissible only durirrp the succeeding 7 days unless such circuit is sootier made OPERABLE.

4. If these condit,ions cannot be 4. During the simulated automatic met., reactov shutdown "hall be actuation test of this system initiated and all reactovs (see Table 4.2.G), it shall be shall be in Cold Shutdown ver.ified that the following wiUrin 24 hours for dampers operato as indicated:

and refuelittp veactox'per;ations operations:hall be terminated Close: PCO-150 B, D, E, arid F within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Open: FC0-151, FCO 152

"-* CREVS is considered inoperable only because it does not. meet. its design basis for essentially zevo unf iltered inleakapo. REACTOR POWER OPERATION and fuel movement ave acceptable until just PRIOR TO STARTUP for unit 2 cycle 7. During cycle 6, CREVS must be demonstrated to be functional by performing all applicable surveillancos. In the event that Ute appl.icable surveillances are not successfully perfoxmed, the actiorrs required by the LCO's must be complied with.

BFN 3.7/4.7-20 Unit 1

3. 7/4. 7 BASES (Cont'd) 3.7.E/4.7.E Control Room Emee enc Ventilation The control room emergency ventilation system is designed to Eilter the control room atmosphero foe intake aie and/or for recirculation during conteol coom isolation conditions. The control room emergency ventilation system is dosipned to automatically start upon control room isolation and to maintain the control coom pressueo to the design positive px.essure so that all leakape should be out leakage. During cycle 6, CREVS has been declared inoperable only because it does not meet its desipn basis Eor essentially zero unfiltex.'ed inleakape. Reactor powee opex;ation and fuel movement are acceptable until just prior to staetup for unit 2 cycle 7. Durinp cycle 6, CREVS must be demonstrated to be Eunctional by performing all applicable surveillances. In the event that the applicable sueveillances are not successfully performed, the actions eequired by tho LCOs must be complied with.

Hiph efficiency paeticulato absolute (HEPA) filters are installed prior to the charcoal adsoebees to peevent clopping of the iodine adsorbees. The charcoal adsorbers are installed to reduce the potential intake of radioiodine to the conteol room. The inplace test results should indicate a system leak tiphtness oE less than 1 percent bypass leakape foe the chaecoal adsoeboes and a HEPA efficiency of at least 99 peecent eemoval of DOP paeticulatos. Tho laboeatox;y carbon "ample test results should indicate a radioactive methyl iodide removal efficiency of at least 90 percent Eor expected accident conditions. If tho efficiencies of the HFPA filters and chax.coal adsoeboes aee as specified, the resulting doses will be less than the allowable levels statid in Ceitex.ion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10 CFR Pact 50. Opeeation of the fans sipnificantly difEerent feom the desipn flow will chanpe the removal efficiency of the HHPA filtees and charcoal adsorbees.

IE the'ystem is found to be inoperable, there is no immediate threat to the conteol x;oom and eeactor operation oe refueling, opeeation niay continue foe a limited period of time while repairs are being made. If the system cannot be eepaieed within seven days, the reactor is shutdown and brought to Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or refueling opeeations are terminated.

Pressux..e drop acx;oss the combined HEPA filters and charcoal adsorbors of loss than six inches of wator at the system desipn flow cate will indicate that the filters and adsorboes aee not clopped by excessive amounts of foroipn matter.

Peessuee deop should be determined at least once per opeeatinp cycle to show system performance capability.

The frequency of tests and sample analysis are necessaey to show that the HHpA filters and chax.'coal adsorbees can perform as evaluated. Tests oE the chaecoal adsoxbees with haloponated hydeocax;bon shall be performed in accoedanco with USAEC Report-1.082. Iodine removal efficiency tests shall follow ASTH D3803. The chaecoal adsorber efficiency test procedures should allow foe the removal of one adsoebee tray, emptyinp of one bed fx..om the tray, mixinp the adsorbent thoeouphly and obtaining at least two .amples. Fach sample .hould be at least two inche in diametee and a lenpth equal to the

- Uxicknoss of tho bod. If test eesults axe unacceptable, all adsoebont in the-system shall be x;eplaced with an adsorbent qualified according to Table 1 of Repulatoey Guide 1.52. Tho replacement tray Eor tho adsoeber tray removed foe tho test should meet Uxe same adsorbent quality. Tests of tho HFPA filtex;s with DOP aoeosol shall be performed in accordance to ANSI N510-1975. Any HEPA Eiltees found defective shall be replacod with filters qualified pursuant to Repulatoey Position C.3.d of Repulatoey Guide 1.52.

BFN 3.7/4.7-51 Unit 1

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3.7/4.7 COHTAIHHEHT SYS . S LIHITIHG CONDITIONS FOR OPERATION SURVEILLANCE REQUIREHEHTS

3. 7.E. Control Room Fmer enc Ventilation 4.7.E Control Room Fmer enc Ventilation

1. Except a . specified in 1. At least once every 18 months, Specification 3.7.E.3 below, the pressure drop across the bo'th control room emergency combined HEPA filters and pvessurization systems charcoal'dsorber. banks shall "hall be OPERABLE at, all be demonstvated to to be less times when a'y reactor than 6 inches of water at, system vessel contain" irradiated desipn flow rate (+ 10%).

fuel.

2. a. The results of the inplace 2: a. The tests and sample cold DOP and halopenated analysis of Specification hydrocarbon tests at desipn 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 >99'L halopenated first Eor standby service hydrocarbon removal when or after every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months oE tested in accordance with system operation and ANSI H510-1975. following, sipniEicant painting fire, or chemical release in any ventilation zone communicatinp with the system.

b. The re ults of laboratory b. Cold DOP testinp shall be carbon sample analysis shall performed aftev each show >90%%u. radioactive methyl complete ov partial iodide removal at, a velocity replacement oE the HEPA when tested in accordance filter bank or after any with ASTH D3803 structural maintenance on (130 C, 95/o R.H.). the system housinp.

CREVS is consideved inoperable only because it does not meet. its design basis for essentially zero unfiltered inleakape. REACTOR POWER OPERATION and fuel movement. are acceptable until just PRIOR TO STARTUP for unit, 2 cycle 7. Durinp cycle 6, CREVS must. be demonstrated to be functional by performinp all applicable surveillances. 'In the event that the applicable surveillances are not successfully performed, the actions required by the LCO's must be complied with.

BFH 3.7/4.7-19 Unit 2

3. 7/4. 7 COHTAItBlFHT SYS . S

~ LINITIHG CONDITIONS FOR OPERATION SURVEILLANCE REQVIREHENTS 3.7.E. Contxol Room Emer enc 4.7.E. Control Room Emer enc Ventilation Ventilation

c. System flow xato shall be c. Nalopenated hydrocarbon shown to be within +1.0% tes tiny shall be per formed design flow when tested in aftex each complete or accordance with ANSI paxtial replacement of the H510-1975. charcoal adsorber bank or after any structural maintenance on the system housing.

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

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

reactor operation or refueling, operations i permissible only during, the succeeding 7 days unle-s such cixcuit 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 xeactors (see Table 4.2.G), it shall be shall be in Cold Shutdown verified that Uxe following within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for reactox 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Open: FCO-151 I C0-152 CREVS i" considered its inoperablo only because it does not, meet design basis for essentially zero unfiltexed inleakape. REACTOR POMER OPERATION and fuel movement are acceptable until just PRIOR TO STARTUP for unit 2 cycle 7. During, cycle 6, CREVS must be demonstrated to be functional by performinp all applicable surveillances. In the event that the applicablo surveillances are not, successfully performed, the actions required by the LCO's must be complied with.

BFH 3.7/4.7-20 Unit 2

3.7//i.7 BASES (Cont'd) 3.7.H/4.7.E Control Room Fmer. enc Ventilation The control room emer:pency ventilation system is designed to Eilter the control x.oom atmosphex;e for intake air and/or for recirculation during control room isolation conditions. The control room emer:gency ventilation "ystem is dixsipned to automatically start upon control room isolation and to maintain the contvol x;oom pressure to tho desipn positive pressure so that all leakape should be out leakape. Duvinp cycle 6, CREVS has been declared inoperable only because it, does not meet its dosipn basis for essentially zero unfiltered inleakape. Reactor power operations and fuel movement are acceptable until just. priox. to star..tup for unit 2 cycle 7. Durinp cycle 6, CREVS nrust be demonstrated to be functional by porfoxming all applicable surveillancos. In Uxe event, that the applicable suvveillances are not successfully performed, the actions required by the LCOs must be complied with.

Hiph efficiency particulate absolute (HEPA) Eilters are installed prior to Ure charcoal adsorbers to prevent clogping of Uxe iodine adsovbers. The char..coal adsorbevs are installed to veduce the potential intake of vadioiodine to Ure control x.oom. The inplace test. results should indicate a system leak tightness of less Uran 1 pevcent bypass leakage for the chax;coal adsorbers and a HEPA eEficiency of at lea t 99 percent removal of DOP particulates. The laboratox;y cavbon "ample test r:esults should indicate a x;adioactive meUxyl iodide removal efficiency of at least 90 percent fov expected accident conditions. If the efficiencies of the HEPA filters and charcoal adsorbers are as specified, the resultinp dose" will be less than the allowable levels stated in Cviterion 19 of the Geneval Design Critevia for Nuclear Power Plants, Appendix A to 10 CFR Part 50. Operation oE the Eans signiEicantly different from the de.,ipn flow will chanpe the removal efficiency of the HEPA filters and charcoal adsorbevs.

If the system is found to be inoper.'able, there is no immediate threat to the coxxtrol room and reactov oper;ation or refuelinp operation nmy continue for a limited period of time while ropaivs are being made. If the system cannot be repaix;ed wiUxin seven days, the x.eactor is shutdown and broupht to Cold Shutdown within 2/i hours ov refuelinp operations are terminated.

Pressure drop acr:oss Ure combined lIHPA filters and chavcoal ad orbers of less than six inches of water at the system desipn flow rate will indicate that the filters and adsorbers are not clopped by excessive amounts of foreipn rnattev.

Pressure dvop should be,determined at least once per operating cycle to show system perfonnance capability.

The frequency oE test., and "ample analysis are necessar;y to show that the HEPA filtevs and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halopenated hydrocarbon shall be pevformed in accordance wiUx USAHC Repovt-1082. Iodine removal efficiency te. t shall follow ASTN D3803. The chax;coal adsorber efficiency test procedures should allow for Uxe removal oE one adsorber tvay, emptyinp of one bed from the tray, mixinp the adsorbent thorouphly and obtaininp at least two samples. Hach sample should be at least two inche" in diameter and a length equal to the thickrxess of the bed. IE te.,t vesults are unacceptable, all adsovbent in the system shal.l be replaced with an adsorbent qualified according to Table 1 of Repulatovy Guide 1.52. The replacement tvay Eox the adsovber tray removed fov the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol ..hall be performed in accordance to ANSI N510-1975. Any HEPA filters found deEective shall be r.oplaced with filtevs qualified pursuant to Repulatovy Po.,ition C.3.d of Regulatory Guide 1.52.

BFll 3.7//i.7-51 Utlit 2

~ a 3.7/4.7 CONTAINHENT SYS . S LzmTINC CONDITIONS FOR OPERATION SURVEILLANCE REQUIRHHHNTS 3.7.E. Control Room Hmer enc Ventilation 4.7.H Control Room Fmer enc Ventilation

1. Except as specified in 1. At least once every 18 months, Specification 3.7.E.3 below, the pvessure drop across the boU> contvol room emeegency combined IIHPA filters and pressurization systems charcoal adsorber banks shall shall be OPERABLE at all be demonstvated to to be less times when any reactor than 6 inches of water at vessel contains ireadiated system de ign flow rate fuel. (+ 10%) .

2. a. The results oE the inplace 2: a. The tests and sample cold DOP and halogenated analysis of Specification hydrocarbon tests at design 3.7.H.2 shall be performed flows on IIEPA filtees and at least once pev operating chaecoal adsovber banks cycle or once eveey shall show >99% DOP removal 18 months, whichever occuvs and >99% halogenated fivst for standby seevice hydvocaebon eemoval when or after evevy 720 houes oE tested in accordance with system operation and ANSI N510-1.975. following significant painting, five, or chemical eelease in any ventilation zone communicating with Uie system.

b. The ee.ults of laboeatory b. Cold DOP testing "hall be carbon sample analysis shall peeformed aftev each show >90% radioactive methyl complete or partial iodide eemoval at a velocity eeplacement of the IIHPA when tested in accoedance filter bank ov after any with ASTH D3803 structural maintenance on (130 C, 95% R.IC.). the .ystem housing.

CREVS is consideeed inoperable only because it does not meet its design basis Eov essentially zero unfiltered inleakage. REACTOR POMER OPERATION and fuel movement aee acceptable until just PRIOR TO STARTUP Eor unit. 2 cycle 7. Dueing cycle 6, CREVS must be demonsteated to be functional by perfoeming all applicable sueveillanc< s. In the event that the appl.icable sueveillancos ave not, successfully performed, the actions required by the LCO's must be complied with.

BFN 3.7/4.7-19 Unit 3

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3. 7/4. 7 COHTAIHMENT SYSTl. S

'LIHITIHG CONDITIOHS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.E. Control Room Rmer enc 4.7.E. Control Room Emez. enc Ventilation Ventilation

c. System flow rate shall be c. HaloBenated hydrocarbon shown to be within +10% testing shall bo performed design flow when tested in after each complete or accordance with ANSI partial replacement of the H510-1975 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 0.00278 hours 1.653439e-5 weeks 3.805e-6 months every month.

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 emer8ency systems is made or found to pressurization system .:.hall be be INOPERABLE for any reason, demonstrated.

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

4. If thes'e conditions cannot be 4. During the simulated automatic met, reactor shutdown "hall bo 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 followinp, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for reactor dampers operate as indicated:

operations and refueling operations shall be terminated Clo e: FCO-150 B, D, E, and F within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Open: FC0-151, FCO-152 CREVS i" considered inoperable only because it does not meet it- design basis for essentially zero unfiltered inleakape. REACTOR POMER OPERATION and fuel movement are acceptable until just PRIOR TO STARTUP for unit 2 cycle 7. During cycle 6, CREVS mu..t be demonstrated to be functional by performing all applicable surveillances. In the event that the applicable surveillances are not successfully performed, the actions required by the LCO's must be complied with.

BFH 3.7/4.7-20 Unit 3

3.7/4.7 MSHS (Cont'd)

~3.7.H/4.7.H Control Room Hmer enc Ventilation The control room emergency ventilation system is designed to filter the control room atmosphere for intake air and/or for recirculation during control room i olation condit.iona. The control room emergency ventilation system is designed to automatically start upon control room isolation and to maintain the control room pressure to the design positive pressure so that all leakage should be out leakage. During cycle 6, CRHVS has been declared inoperable only because it does not meet its design basis Eor essentially zero unfiltered inleakage. Reactor power operation and Euel movement are acceptable until just prior to startup for unit 2 cycle 7. During cycle 6, CRHVS must be demonstrated to be functional by performing all applicable surveillances. In Uie event that the applicable surveillances are not successfully performed, the actions required by the LCOs must be complied with.

1Ligh efficiency particulate absolute (1$ HPA) filter~ are installed prior to the charcoal adsorbers to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential intake of radioiodine to the control room. The inplace test results should indicate a system leak tightness oE less than 1 percent bypass leakage for the charcoal adsorbers and a lLHPA efficiency of at least 99 percent removal of DOP particulates. The laboratory carbon "ample test results should indicate a radioactive methyl iodide removal efEiciency of at least 90 percent for expected accident condition .. If the efficiencies of the NHPA filters and charcoal adsorbers are as specified, the resulting doses will be less than the allowable levels stated in Criterion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10 CLR Part. 50. Operation of the Eans significantly difEerent from the design flow will change the removal efficiency of the HHPA filters and charcoal adsorbers.

If the system i" found to be inoperable, there i" no immediate threat to the control room and reactor operation or refueling operation may continue for a limited period of time while repairs are being made. If the system cannot, be repaired within seven days, the reactor is shutdown and brought to Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or refueling operations are terminated.

Pressure drop across the combined lLHPA filters and charcoal adsorbers of le s than six inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of Eoreign matter.

Pressure drop should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and "ample analysis are necessary to show that the lLHPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAHC Report-1082. Iodine removal efficiency test" shall follow ASTH D3803. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. Fach sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52. The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HHPA filters with DOP aero ol shall be perEormed in accordance to ANSI N510-1975. Any lLHPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Hi%it 3 3.7/4,7-49

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ENCLOSURE 2 DFSCRIPTION AND JUSTIFICATION BROMNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 Descei tion of Chan e TVA pvoposes a tempovaey modification to the opeeability eequieements foe the Control Room Emeegency Ventilation System (CRFVS) in the units 1, 2, and 3 Technical Specification . Thi" change involves annotating limiting conditions fov opevation (LCOs) 3.7.E.1, 3.7.F..3, and 3.7.E.4 by an asterisk and defining the CREVS as being inoperable only because it does not meet its design basis for essentially zero unfiltered inleakage. Technical Specification Bases 3.7.E/4.7.H will also be vevised to describe this temporary change.

With the appeoval of this temporaey change, power operations and fuel movement will be acceptable until just prior to startup for unit 2 cycle 7. 'uring cycle 6, CREVS must be demon tvated to be functional by pevforming all applicable sueveillances. In the event that the applicable sueveillances aee not successfully performed, the actions required by the limiting conditions for opoeation must be complied with.

Reason foe Chan e Technical Specification LCO 3.7.H.1 eequiees both CREVS to be operable at all t.imes when any reactor vessel contains ivvadiated fuel, except as specified in LCO 3.7.8.3. Mhen one of the CREVS is made or found to be inoperable, reactor opevation oe eefueling opeeations aee permissible only for.. the succeeding seven days unless such ciecuit is sooner made opevable (LCO 3.7.E.3). 'If these condition" cannot be met, reactoe shutdown will be initiated and all eeactovs will be in Cold Shutdown within 24 houes foe reactor opevations and eefueling opeeations will be terminated within two hours (LCO 3.7.E. i).

Trmporary Technical Specification (TS) change TS-245T addressed and justified allowing both teains of the CREVS to be inopeeable dueing the unit 2 cycle 5 outage while no fuel was in any eeactor vessel. This was based primaeily on the fact. that, the BFN fuel has decayed at least three yeavs, so that the radiological consequences due to potential fuel handling accident weve much less seveee than normally predicted.

Temporary Technical Specification change TS-253 addeessed and justified CREVS not being opevable dueing unit 2 cycle 6 fuel loading and "ub-ceitical functional testing opeeations up to the time the fiest conteol rod is pulled to go ceitical foe unit 2 cycle 6.

The proposed temporary technical specification changes aee shown in enclosuee 1. Since the CREVS is a common system and since its operability is eequieed for the opeeation of any unit, the technical specification changes apply to all three BFN units. These changes will allow unit 2 cycle 6 opevation and permit the subsequent defueling, refueling, and sub-cvitical functional testing activities eequired until just, prior to .tavtup for unit 2 cycle 7.

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Hnclosure 2 Page 2 of 8 Technical Specification Bases 3.7.E/4.7.E state that the control room emergency ventilation -ystem is designed to automatically start upon control room isolation and to maintain Uxe control room pressure at a slight positive pressure so Uxat all lea'kage .,hould be outleakage. In x.'esponse to BFN Final Safety Analysis Report (FSAR) Question 10.2, TVA stated that in emergencies, the makeup air to the control room will pass through at least three, and pos..ibly four, air cleanup stages. (The fourth stage is the optional high efficiency particulate absolute (HEPA) filter in the ventilation system inlet tower.) A Condition Adverse to Quality Report identified a specific limited condition which could impact the ability of the CREVS to provide an envix.'onment -uitable for personnel occupancy at all times as committed to in FSAR Section 10.12.6. The control building is adjacent to, and north of, the reactor building ( .econdary containment). The control building ventilation supply towers are located on the north wall of the reactor building.

Following a loss of coolant accident, winds from the SSE, S, or SSVJ sectors at speeds greater than thirty-six (36) mile" per hour could offset, the negative pressure maintained in the secondary containment by the standby gas treatment system (SGTS) and produce exfiltration fx.om t'e reactor building. These atmospheric conditions could introduce contaminated air into the control building air upply ductwork through the ventilation supply towers. The ventilation fans, which are located in the ventilation towex.s, pressurize Uxe supply ductwork which tx;averses the main control room (HCR) habitability zone (HZ). The CREVS takes .uction from these ducts, which have not, been designed nor constructed to be leak tight. Therefore, unfiltered outside air could leak from Uxe seams/joints of the supply air ducts which traverse the control bay habitability zone and could bypass the CRHVS, introducing, a previously unanalyzed source of unfiltex.ed outside air into tho control bay habitability zone.

Based on tbe above, the current CREVS does not meet the Technical Specification Ba .es or FSAR design commitment for essentially zero inleakage of unfiltered outside air. The proposed temporary technical specification change is written to allow power operations and the subsequent defueling, x.efueling, and sub-critical functional testing required until just prior to startup for. unit 2 cycle 7 while a permanent resolution to this condition is determined and implemented.

Justification for Chan e k

The CREVS is designed to protect the control room operators and Technical Support Center (TSC) personnel by pressurizing the HCR HZ with filtered air during accident conditions which could result in x;adioactive releases into the HCR HZ. The CREVS uses charcoal adsorbers to assure the removal of radioactive iodine from tbe air and HHPA filters for removing particulate mattex.

The BMR operating states and applicable design basis events are identified in FSAR Appendix G. This was reviewed to determine which events bad the poterxtial for causing fuel damage and radioactive releases which could require the filtration provided by the CREVS. This review indicated that the CREVS is-required to mitigate events in each of the five W9R operating states (A, C, D,

Enclosure 2 E, and F) defined in FSAR Appendix G. The applicable design basis events and opeeatinp "tates aee summarized as follows:

Descei tion 0 eratin States Loss of Fuel Pool Cooling ALL Contvol Rod Dx;op Accident (RDA) D, F Pipe Beeak Outside Primacy Containment C, D, E, P

[Hain Steam Line Bveak (HSLB))

Purl Handling Accident. (PHA) A Loss of Coolant Accident (LOCA) C, D, E, F Of the e events, the LOCA. (desipn basis pipe break inside primary containment) postulated to occur in opeeatinp state F, is the contvolling event in teenxs of radioact.ivity velease and dose consequences. Each af these events and the affect of an inoperable CREVS is di cussed below.

Loss of Fuel, Pool Cooling The spent fuel pools and fuel pool cooling, and cleanup system ax.e described in FSAR Sections 10.3 and 10.5, eespectively. The fuel pool coolinp system is supplemented by the x.esidual heat vemoval (RHR) system which can be connected by opeeatox; action to the fuel pool cooling and cleanup system. The desipn includes a permanently installed crosstie to the RHR system which assuves adequate nxakeup undev all normal and off-normal conditions (i.e., fuel pool water boil-off). Therefore, significant eadioactivity release due to loss of coolinp or loss of inventoey and fuel uncovery is precluded and the CREVS is not, eequived to mitipate this event.

Contvol Rod Dvop (RDA) and Hain Steam Line Break (HSLB) Accident" TVA has evaluated the RDA and HSLB accident to determine the resulting doses to the conteol x.'oom opeeatoes and TSC pevsonnel. The contvol room operator dose" as a result, of the RDA and the HSLB accident were shown to be well below the 10 CPR ~0, Appendix A, Geneeal Desipn Criterion (GDC) 19 guidelines of 5 x.em whole body, or its equivalent to any part of tho body (30 vem thyroid),

even when the contvol voom is not isolated and the normal HVAC flow of unfiltered outdoov air is continuously supplied. The TSC personnel doses were well below the Envieonmental Protection Apency (EPA) Fmergency Morker and Lifesavinp Act.ivity Pvotective Act.ion Guides of 25 rem whole body or 125 rem thyroid dose, which are referenced fvom 10 CFR 50.47(b)(11).

Fuel Handling, Accident contr.ol room operatov and TSC personnel doses have recently beon calculated foe the PHA considevinp the depeaded performance of the CREVS. The calculation assumed that durinp the refueling, peeiod, a fuel bundle is dropped eithee into the x;eactov px.essuve vessel or into tho fuel stovage pool. The deopped fuel bundle tvikes additional bu'ndles, fractuving 125 fuel cods. The limitinp case is Uxe fuel dvop into the storage pool as descvibed in PSAR Section 14.6.4.

Enclosuee 2 The ouece tet~ in the model are the total core activities of noble pases and iodine.-. The iodines are split into 99.75 percent inorpanic and 0.25 percent ovpanic iodine proupinps. Ten percent of the iodine inventoey, plus 10 percent of all the noble gases inventoey (except 30 percent of Ke-85) are assumed to be released feom the feactured fuel rods. The accident is postulated to occur 24 houes after shutdown and the veactor fuel is assumed to have an avevape iveadiation time of 1,000 days at design powev.

The present analysis demonsteates that the dose contvibution to the operatovs fvom the stack release, ubsequent to isolation of the reEueling, zone exhaust, i.. neplipible. ThereEoee, only the activity released thvouph the vefuelinp zone exhaust in the period befoee it isolates is considered in the calculation oE the opeeatoe dose. A di pev ion factor of 1.25 x 10-4 sec/m3 is utilized foe the vefuelinp zone roof exhaust eelease point.

The calculation assumes 500 cfm oE flow into the conteol room which has been filteved Uu.ouph the CREVS and 2750 cEm oE unfiltered outdooe air leakape.

The 500 cfm of CREVS pvocessed air is the design value as stated in FSAR Section 10.12.5.3. In order to estimate the leakape of outdoor air into the conteol room, all llVAC supply air ductwork passing throuph the control bay habitability zone and opevatinp during control bay isolation mode was eeviewed. Initial estimates of the magnitude of leakape into the control bay habitability zone weve made u -inp Sheet Metal and Air Conditioning Contvactors'ational Association (SMACM) standards for leakape fvom this type of pocket-lock duct con-tt.uction. The leakage was estimated, on the ba i" of the size and length of duct in the habitability zone, to be between 726 and 2750 cfm.

Under these conditions, the contvol coom opevator and TSC personnel do .es ovee 30 days following, the FHA are pvedicted to be 0.03 vem pamma (whole body),

0.26 rem beta and 14 rem thyvoid (inhalation). These results ave below the 5 rem whole body, or its equivalent to any part of the body (30 eem thyeoid) guidelines of 10 CFR 50 Appendix A, GDC 19 and the puidelines eefeeenced Erom 10 CFR 50.47(b)(11) of 25 rem whole body or 125 rem thyroid for emergency workers'oss of Coolant Accident.

The control coom operator and TSC personnel doses resulting from the desipn basis LOCA were reevaluated considevinp 2750 cfm of CREVS bypass aie leakage.

A, second analysis was peeformed foe the controlling LOCA case to determine the opeeator dose considering the previously analyzed (FSAR Question 10.2) assumption of eeactoe building exfilteation due to hiph winds concuerent with the LOCA.

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Enclosure 2 The control room operator and TSC personnel doses resulting from the LOCA were calculated using the computer codes STP and COROD. The activity released to the environment during the accident was calculated with STP in accordance with the Regulatory Guide 1.3, Rev. 2. The predicted activity release was then input to COROD which calculated the resulting doses. Detail" of the individual models and as umptions are provided in the calculations. The models are generally the same except that the exfiltration model includes the additional exfiltration ground level release path with associated dispersion Eactor. The exfiltration was modeled as a puEE release beginning at the time of maximum concentration in the Reactor Building (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months post-LOCA). The rate of exfiltration was calculated considering the pressure differential induced across the exterior walls and roof of the Reactor Building as a funct,ion of wind speed and direction.

The results of the LOCA and FllA cases without the ~ecfiltration assumption are presented in Table 1 which show that the predicted doses to the control room operator and TSC personnel are below the allowable levels oE GDC 19 even with 2750 cfm of CREVS bypass.

Table 1 also presents the results of the LOCA case considering secondary containment exfiltration and CREVS bypass. The control room operator and TSC per onnel whole body gamma do..e due to exfiltration following a LOCA is less than 0.1 rem (with 2750 cfm of unfiltered bypass flow into the control bay).

The whole 'body gamma dose from stack releases and contained sources is less than 1.8 rem. ltence, the whole body gamma dose from all sources is less than 2 rem. The control room operator and TSC personnel beta dose due to exfiltration following a LOCA is less than 0.8 rem (with 2750 cfm of unfiltered bypass). The beta dose from stack releases is less than 0.4 rem.

The total beta dose Erom all sources post-LOCA is less than 1.1 rem. The control room operator and TSC personnel thyroid dose from stack releases is 6.2 rem (with 2750 cfm of unfiltered bypass). With tho secondary containment (Reactor Building) internal pressure at -0.25" M.G., the thyroid dose from possi'ble exfiltration aEter a LOCA, is 326.7 rem. The total iodine dose to the thyroid from all post-LOCA sources, without compensatory actions, is 332.9 rem.

llowever, the calculations for exfiltration rates show that the exfiltration rate i strongly dependent upon the negative pressure maintained by the Standby Gas Treatment System (SGTS) inside the secondary containment. For example, the thyroid dose reduce (due to reduced exfiltration rate with increased vacuum in the SC) from 332.9 rem at. -0.25" M.G. to 14.5 rem at

-0.60" M.G. Furthermore, the wind speed required to offset 0.60" M.G. vacuum is approximately 49 NPI4. A review of the latest meteorological data shows that (considering seven direction sectors) wind speeds greater than 40 HP)1 have occurred only five time- in the ten-year period from January 1, 1977 through December 31, 1987.

Technical Specification Surveillance Tnstruction 4.7.C. ensures the secondary containment capability to maintain (at least) 0.25" W.G. vacuum under calm wind condition., with a sy..tern leakage rate of less than 12,000 cfm.

Enclosure 2 age 6 of 8 The SGTS i expected to maintain move than the Technical Specification minimum eequirement of 0.25" M.G. vacuum in the Reactoe Building. Hach of the three SGTS trains is designed to process a flow rate of 9000 cfm. ThereEore, with two teains of SGTS opevating the secondary containment vacuum is expected to be on the oedev of 0.50" M.G.

Browns Fervy has three SGTS trains. All three trains start automatically upon receipt of high radiation in the eeactoe zone exhaust duct ov two downscales, high radiation in the refueling zone exhaust duct or two downscales, low eeactoe vessel water level, ov high deywell peessure signals. Technical Specification 3.7.8.1 requires all three trains be operable at all times when secondaey containment. integrity is required except, as specified in Specification 3.7.8.3. Technical Specification 3.7.8.3 states that Evom and after the date that one train of the SGTS is made or found to be inoperable, reactor operation and fuel handling is permissible-only during the succeeding seven days.

On this ba is, a LOCA concuerent with the wind conditions required to produce exfilteat.ion is considovod to be a highly unlikely event. Should this scenavio occue, the actual control room operator dose is expected to be consideeably less than the woest case prediction (332.9 rem) due to the inceea ed vacuum maintained inside secondary containment.

Xn order to provide assueance that the control room operatoe doses do not.

exceed the GDC 19 guidelines and TSC pevsonnel doses do not exceed the 10 CFR 50.47(b)(11) guidelines during the temporary period (cycle 6) in which the CREVS is considered inoperable, TVA has implemented the following compensatoey measuves:

1. The appvopeiate abnormal operating pvoceduve has been claeified to assure all available teains oE the SGTS will be operated during emergency conditions, to maximizo the negative peessuee (vacuum) in the secondavy containment.

2. During an emeegency, plant eadiological conditions will be continuously monitoeed to peovide an eaely indication that the contvol coom and TSC habitability may become degeaded. Advevse vadiological conditions would be high iodine activity in the reactor building. Upon deteemination that there is a possibility that the iodine uptake dose to the thyroid could exceed 10 rem, potassium iodide (KI) tablets will be disteibuted to all control coom opevatoes and TSC personnel.

The value of 10 eem wa " cho "en based upon comparison of tho medical risks feom eeceiving a 10 rem thyeoid dose to the medical eisk from taking the potassium iodide tablet and i . consistent with the recommendations of the tfational Council on Radiation Protection (ReEerenco 1).

The most effective method of preventing uptake of eadioiodine is to administee KI, which i" peimarily a blocking agent. Iodine is rapidly and completely absorbed by the gastvointestinal teact within 30 minutes of ingestion. One blocking dose of 300 mg of KI will, following metabolization, stop the uptake of eadioiodine by the thyroid (Refeeences 1 and 2).

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J Hnclo -ure 2 age 7 OE 8 There is sufficient time for the control room operatovs and TSC personnel to metabolize the KI tablets before they would exceed 30 vem to the thyroid.

Table 2 summarizes the contvol room and TSC inteprated iodine dose versus time. Under the conser.vative postulated scenario of a LOCA concurrent with wind conditions which produce exfiltvation from the reactor: building into the contvol room habitability zone starting two houvs post-LOCh and assuming no compensatory actions, the GDC 19 puideline of 30 vem would be reached in 2 houvs and 33 minutes. Assuming the TSC is staffed inrnrediately, the 10 CFR 50.47(b)(11) puideline of 125 rem to the TSC personnel would be r.cached in 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 25 minute-. Allowing 30 minutes for the metabolization of potassium iodide, over two hours would be available to determine the need for distribution and inpe -tion of the potassium iodide tablets by the contvol room operators prior to exceeding the GDC 19 guideline of 30 rem to the thyroid.

Table 2 and the above discussion apply to the case-of a LOCA with exEiltration bepinninp at. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the postulated accident. This is the case that maximizes the 30-day dose to the control room and TSC pevsonnel. Should the extreme wind conditions and resultant exfiltration from the secondary containment occuv within the first two hours post-LOCA, the 30-day dose without compensatory action would be reduced but the time period Eor compensatory action would also be reduced. A sensit,ivity study demonstrated that. the limitinp case for minimizing compensatory action time, is to consider the wind from time zero to 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . post-LOCA. Fov this case, the contvol room intepvated iodine dose vevsus time after a LOCA io presented in Table 3 which shows that the 30 rem thyroid limit (GDC 19 guideline, whole body equivalent) would not. be reached until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 15 minutes after the postulated LOCA without. compensatory action. Allowing 30 minutes for. the metabolization of KI, the minimum time period available fov compensatovy action would be 45 nlinutes ~

Conclusions Althouph the CREVS is technically inoperable for. the puvpooos of the technical opecificat,ions because it. does not. meet its essentially zero unfilteved inleakape commitment, the system will be operated durinp accident conditions to maintain a slipht.ly positive pressure in the contvol room and to provide some depvee of Eiltevinp of the outside aiv. To demonstr."ate that the CRHVS will be functional duvinp Cycle 6, all applicable sur..veillances will bo performed. In the event. that. the applicable sur.veillances are not successfully performed, the actions required by the LCOo will be complied with.

The calculations show that the contvol room operators whole body doses followinp the worst case desipn basis accident (LOCA) remain well below the puidelines of 10 CFR 50, Appendix A, General Design Criterion 19, "Control Room" and the TSC pevsonnel whole body doses remain well below the Environmental Pvotoction Apency (EPA) Fmerpency Morker and Lifesavinp Activity Protective Action Guides which ave referenced from 10 CFR 50,47(b)(11). The control room operators thyroid dose will be controlled by compensator:y act,ion.

and will bo well below the vequir.ements of 10 CFR 50, Appendix A, GDC 19. The TSC pevsonnel thyr.oid dose will be contvolled by the same compensatovy act,ions and will be oipnificantly below the HPA Emergency Worker and Lifesaving, Activity Protective Action Guides which ave veferenced fvom 10 CFR 50.47(b)(11). The compensator;y measures will be in effect throughout the period of applicability of the temporary technical specification amendment.

Enclosure 2 Page 8 of 8 Based on the above, TVA i" requesting the temporary relaxation of the CREVS technical .pecifications as specified in enclosure 1. This relaxation will allow unit 2 restart and will not compromise the health and safety of the public.

RRP ERm<Cr.S

1. "Hanapement of Persons Accidentally Contaminated Mith Radionuclides "

National Council on Radiat.ion Protection (NCRF) Report No. 65, April 15 1980

2. "Reactor Accidents; Public liealth Strategies and Their Hedical Implications," Journal of the American Hedical Association (JAHA),

Volume 258 No. 5, Pages 649-654, August 7, 1981

ENCLOSURE 2 TABLE 1 COHTROL ROOH AHD TECHNICAL SUPPORT CFNTER DOSES FOR LOCA AHD FUEL HANDLING ACCIDENT (Final)

CONSIDERING CREVS BYPASS LEAKAGE CASE PARAHETERS 30 DAY DOSE (rem)

Unfiltered SC Compensatory Niole Body Accident Bypass, Exfiltration, Action Gamma Beta Thyroid

( cfm) ( cfm)

LOCA 2750 Hone 1. 7a(>> 0.34 6.2 2750 Hone 0.03 0.26 14.0 LOCA 2750 1305 cfm(2) ,None I.B6(1) 1.10 332.9 at 2 hrs.

LOCA 2750 1305 cfm(2) 300 mg 1.S6(1) 1.10 Less at 2 hrs. of KI Than 30

'HOTES: 1. Includes 1.75 rem contribution from direct shine from the secondary containment and core spray piping,.

2. Based on a sustained Mind speed of 36 mph required to offset 0.25" M.G. vacuum inside secondary containment for the period from 2 hours to 4 hours post-LOCA.

ENCLOSURE 2 TABLE 2 COHTROL ROOM AHD TSC INTEGRATED IODINE DOSE VERSUS TIME AFTER LOCA CONSIDERING CREVS BYPASS LEAKAGE

'rlITH EXFILTRATION FROM SECONDARY CONTAINMENT AT 2 HOURS Time Dose Dose Total Aftet From From Thyroid LOCA, Stack, Exfiltration, Dose, (min.) (rem) (rem) (rem) 0 0.0 0.0 0.0 30 1.6 0.0 1.6 60 3.8 0:0 3.8 90 4.9 0.0 4.9 120 5.5 0.0 5.5 130 5.6 2.4 8.0 133 (2 hrs 13 mins) 10.0 140 5.7 9.2 14.9 150 5 8 19 5 25.3 153 (2 hrs 33 mins) 30.0 160 5.9 32.6 38 5 170 6.0 48.5 54 5 180 6.0 66.5 72.5 190 6.0 86.2 92.2 200 6.1 107.6 113.7 210 6.1 130.2 136.3 220 6.1 154.0 160.1 230 6.1 178.9 185.0 240 6.1 204.5 210.6 260 6.2 246.8 253.0 280 6.2 274.5 280.7 300 6.2 9P 5 298.7 330 6.2 308.7 314.9 360 6.2 317.3 323.5 480 (8 hrs) 6.2 326.7 332.9 960 6.2 326.7 332.9 1440 (1 day) 6.2 326.7 332.9 5760 6.2 326.7 332.9 43200 (30 days) 6.2 326.7 332.9 NOTE: Based on 2750 cfm of unfiltered CREVS bypass and 1305 cfm of exfiltration from secondary containment for the period from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours post-LOCA.

ENCLOSURE 2 TABLE CONTROL ROOM AND TSC INTEGRATED IODINE DOSE VERSUS TIME AFTER LOCA CONSIDERING CREVS BYPASS LEAKAGE MITM EXFILTRATION FROM SECONDARY CONTAINMENT AT TIME ZERO T H.me Dose Dose Total After Feom From Tllyeo ld LOCA, Stack, Exfiltration, Dose~

(min. ) (vem) (rem) (rem) 0 0.0 0.0 0.0 10 0.1 0.2 0.3 20 0.1 1.0'.7 1.1 30 O.l 2.8 40 0.1 5.8 5 9 49 0.1 9.9 10.0 50 0.1 10.5 10.6 60 O.l 16.8 16.9 70 0.1 24i.6 24i. 7 75 (1 be 15 mins) O.l 29.9 30.0 80 0.1 34.4 34.5 90 0.1 45 6 45 7 100 0.1 58.5 58.6 110 0.1 72.8 72.9 120 O.l 88.7 88.8 14i 0 O.l 115.4 115.5 160 0.1 133.0 133.1 180 0.1 144.5 144i.6 210 0.1 154.6 154. 7 240 0.1 160.0 160. 1 270 O.l 162.9 163.0 300 0.1 164.4 164i . 5 330 0.1 165.3 165.4 360 O.l 165 ' 165.8 480 0.1 165.7 165.7 1440 (1 day) 0.1 166.1 166.2 5760 O.l 166.1 166.2 Ii3200 (30 days) O.l 166.1 166.2 NOTE: Based on 2750 cfm of unfilteved CREVS bypass and 1305 cfm of exfilteation feom secondary containment for U>e period feom time zero to 2 houvs post-LOCA.

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EHCLOSURE 3

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DETERNIHATIOH OF HO SIGNIFICANT HAZARDS COHSIDERATIOH BROMHS FERRY NUCLEAR PLANT UNITS 1, 2 AHD 3 Descri tion oE Pro o .ed Technical S ecification Amendment The pvoposed amendment to the Browns Fevry Huclear Plant (BFH) units 1, 2, and 3 Technical Specifications consists of a temporary change to the opeeability t.equivements Eor the Control Room Emevgency Ventilation System (CREVS). This change involves annotatinp limitinp conditions Eor operation (LCOs) 3.7.E.1, 3.7.E.3, and 3.7.E.4 by an asterisk and defining, the CREVS as beinp inopeeable only because it, does not meet its design basis for essentially zero unfiltered inleakage. Technical SpeciEication Bases 3.7.E/4.7.E would also be eevised to descvibe this tempovary change. This amendment would allow powee opeeations and fuel movement until just px;iov to startup foe unit 2 cyclo 7. Durinp Cycle 6, CREVS must be demonstt:ated to be functional by performinp all applicable suvveillances. In the event that the applicable sueveillances ave not successfully peefox~ted, t'e actions eequived by the LCO". will be complied with. This will allow system evaluation, design and modificatiotxs to pvoceed in parallel with opet.ational activities until just prior to startup for unit 2 cycle 7.

Basis fov Pvo osed Ho Si nificant Hazat.ds Consideration Determination HRC has provided standax.ds fov detox+>ining whether a sipnificant hazaeds consideeation exists as stated in 10 CFR 50.92(c). A proposed amendment to an opet.'atinp license involves no ipnificant hazax;ds considerations if operation of the Eacility in accoedance with the pvoposed amendment would not (1) ixxvolve a sipnificant inceease in the peobability oe consequences of an accident, peeviously evaluated, (2) ceeate the possibility of a new oe diffe vent Rind of accident ft;om an accident peeviously evaluated, or (3) involve a sipnificant eeduction in a max;pin of safety.

The pvoposed amendment does not involve a sipnificant inceease in the peobability oe consequences of an accident pveviously evaluated. The peoposed tempovaey changes to the technical specifications involve velaxations to ystem opevability requieements Eor the CREVS duving those opeeational and fuel handling, activities leadinp to and just, peioe to taetup for unit 2 cycle 7.

This action docs not incvease in the probability of any accident pveviously evaluated since the peoposed tempoeary chanpes to the technical specifications do not affect the precuesors or initiatoes for these ace ldetlt s The loss of coolant accident (LOCA) evaluated in the Beown Feeey Hucleae Plant Final Safety Analysis Report (FSAR) Sections 1/i.6.3, 14.10.5, and the eesponse to FSAR Question 10.2 repvesents the most severe event that i" applicable in terms of eadioactive velease and dose consequences. The initiatinp event and accident scenario are still valid. The requested x.elaxation in system operability for the CREVS has been evaluated, The calculation of doses to the control coom opevators and Technical Suppovt Center (TSC) pevsonnel has been performed assuming the introduction of the estimated unfiltered air inleakage. The conteol coom opeeators whole body gamma and beta s1xin doses will be below tho puidelines of 10 CFR 50

Hnclosure 3 Appendix A, Genex.al Desipn Criterion (GDC) 19, "Contvol Room" and TSC per onnel whole body doses remain well below the Envivonmental Protection Apency (FPA) Emergency Morker and Lifesavinp Activity Px;otective Action Guides which are x.efex;enced fvom 10 CFR 50.47(b)(11). The control room opevators thyx.oid dose will be contvolled by compensatory actions and will be below the puidelines oE GDC 19. The TSC pevsonnel thyroid dose will be controlled by the same compensatory actions and will be significantly below the HPA Emex:gency Morker and Lifesavinp Activity Protective Action Guide. which are x.eferenced from 10 CFR 50.47(b)(11). Therefore, the proposed tempox.avy chanpes do not involve a sipniEicant increase in the consequence of an accident. previously evaluated.

2. The px;oposed amendment does not create the possibility of a new or diffex.'ent kind of accident from an accident previously evaluated. No new modes of plant operation are introduced which could contribute to the possibility oE a new or different kind of accident. The fuel handling and opevational activities involved are bounded by those analyzed in the PSAR. The loss oE coolant accident is the most severe event that could occur duvinp plant opevations or fuel handling or other activities being conducted just prior to startup for unit 2 cycle 7.

3. The proposed amendment does not involve a significant reduction in a marpin of safety. The px",oposed temporary technical speciEication chanpes will allow operation with the present system confipuration during plant operations and Euel handling or other activities being conducted just prior to startup oE unit 2 cycle 7. The whole body doses to the contvol room operators followinp the wox..st case desipn basis accident, considering, the dopvaded perfonnance of the CREVS, x.emain below tho GDC 19 guideline and the TSC pevsonnel whole body doses vemain below tho HPA Emergency Morker and Lifesaving Activity Px;otective Action Guides which are referenced from 10 CFR 50.47(b)(ll). The control room operators thyroid dose will be controlled by compensatory actions and will be below the puidelines of GDC 19. The TSC personnel thyroid dose will be controlled by the same compensatox.y actions and will be sipnificantly below the EPA Fmevpency Worker and Lifesaving Activity Protective Action Guide" which are veferexlced form 10 CFR 50.47(b)(11). These chanpes do not sipnificantly x.educe the margin of safety defined in the basis of any technical specification.

Determination of Basis for Pro osed No Si nifieant llazards Since the application for amendment involves a proposed chanpe that is encompassed by the critevia for which no significant hazards considoration exists, TVA has made a pvoposed detennixxation that the application involvos no sipnificant hazards considoxation.

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ML18033A629

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