ML18033B313

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Proposed Tech Specs Clarifying Limiting Conditions for Operation for RHR Svc Water & Emergency Equipment Cooling Water Sys
ML18033B313
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 05/18/1990
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18033B312 List:
References
TVA-BFN-TS-242, NUDOCS 9005240162
Download: ML18033B313 (33)
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Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATIONS REVISIONS I

BROGANS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (SUPPLEMENT TO TVA BFN TS 242)

@00518 PDOCK -

005240~% 0500025 PDC

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UNIT 1 EFFECTIVE PAGE LIST REMOVE INSERT 3.5/4.5-9 3.5/4.5-9 3.5/4.5-10 3.5/4.5-10*

3.5/4.5-11 3.5/4.5-11 3.5/4.5-1la 3.5/4.5-lla*

3.5/4.5-28 3.5/4.5-28 3.5/4.5-29 3.5/4.5-29

  • Denotes overleaf or spillover page.

/4. CORE AND CONTAINME COOLING S STEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.5.C RHR Service Water and Emer enc 4.5.C RHR Service Wate and Eme enc E ui ment Coolin Water S stems E ui ment Coolin Water S stems

~EE CWS ~EECWS

1. PRIOR TO STARTUP from a 1~ a~ Each of the RHRSW pumps COLD SHUTDOWN CONDITION, normally assigned to the RHRSW pumps, including automatic service on pump Dl or D2, shall be the EECW headers will OPERABLE and assigned to be tested service as indicated in automatically each time Table 3.5-1. the diesel generators are tested. Each of the RHRSW pumps and all associated essential control valves for the EECW headers and RHR heat exchanger headers shall be demonstrated to be OPERABLE in accordance with Specification 1.0.MM.
b. Annually each RHRSW pump shall be flow-rate tested. To be considered OPERABLE, each pump shall pump at least 4500 gpm through its normally assigned flow path.

c~ Monthly verify that each valve (manual, power-operated, or automatic) in the flowpath servicing safety-related equipment in the affected unit that is not locked, sealed, or otherwise secured in position, is in" its correct position.

BFN 3.5/4.5-9 Unit 1

4 CORE AND CONTAINMENT COOLING SYSTEMS LIMITING CONDITIONS FOR OPERATION l

SURVEILLANCE REQUIREMENTS 3.5.C RHR Service Wate and Emer enc 4.5.C RHR Se vice Water and E er enc E u ment Coolin Water S stems E ui ment Coolin Water S stems EECWS Continued EECWS Continued

2. During REACTOR POWER 2. No additional surveillance OPERATION, RHRSW pumps is required.

-must be OPERABLE and assigned to service as indicated in Table 3.5-1 for the specified time limits.

3. During REACTOR POWER 3. Routine surveillance for OPERATION, both RHRSW these pumps is specified pumps Dl and D2 normally in 4.5.C.l.

or alternately assigned to the RHR heat exchanger header supplying the standby coolant supply connection must be OPERABLE except as specified in 3.5.C.4 and 3.5.C.5 below.

AMENDMQ7g0 y 6g BFN 3.5/4.5-10 Unit 1

Table 3.5-1 Minimum RHRSW and EECW Pump Assignment 1.Unit Fueled 2 Units Fueled'nit 3 Units Fueled Time Limit 2 Units Defueled Defueled RHRSW EECW A RHRSW EECW R RSW EECW A None 4 and 3 5 and 3 7 and 3 5 and 2 7 and 2 30 Days 3 and 2 (or) , (or) 4 and 3 6 and 3 7 Days 2. and 2 4 and 2 6 and 2 Note:

(A) At least one OPERABLE pump must be assigned to each header. Only automatically s'tarting pumps may be assigned to EECW header service.

BFN 3.5/4.5-11 Unit 1

I THIS PAGE INTENTIONALLYLEFT BLANK BFN 3.5/4.5-1la Unit 1

~ 3.5 Bases (Cont'd)

The suppression chamber can be drained when the reactor vessel pressure is atmospheric, irradiated fuel is in the reactor vessel, and work is not in progress which has the potential to drain the vessel. By requiring the fuel pool gate to be open with the vessel head removed, the combined water inventory in the fuel pool, the reactor cavity, and the separator/dryer pool, between the fuel pool low level alarm and the reactor vessel flange, is about 65,800 cubic feet (492,000 gallons). This will provide adequate low-pressure cooling in lieu of CSS and RHR (LPCI and containment cooling mode) as currently required in Specifications 3.5.A.4 and 3.5.B.9. The additional requirements for providing standby coolant supply available will ensure a redundant supply of coolant supply. Control rod drive maintenance may continue during this period provided no more than one drive is removed at a time unless blind flanges are installed during the period of time CRDs are not in place.

Should the capability for providing flow through the cross-connect lines be lost, a 10-day repair time is allowed before shutdown is required.

This repair time is justified based on the very small probability for ever needing'RHR pumps and heat exchangers to supply an adjacent unit.

~RR RENCES

1. Residual Heat Removal System (BFNP FSAR subsection 4.8)
2. Core Standby Cooling Systems (BFNP FSAR Section 6) 3.5.C. RHR Service Water S stem and Emer enc E ui ment Coolin Water S stem BECK'S The EECW has two completely redundant and independent headers (north and south) in a loop arrangement inside and outside the Reactor Building.

Each header is supplied by two automatic RHRSW pumps. A crosstie at the RHRSW pump discharge provides the capability for, each header to be supplied by four automatically starting RHRSW pumps. Those components requiring EECW, except the control air compressors which are not safety related, are able to be fed from both headers thus assuring continuity of operation if eitheruse header asbecomes inoperable. The control air compressors only EECW an emergency backup supply.

There are four RHR heat exchanger headers (A, B, C, Sc D) with one RHR heat exchanger from each unit on each header. There are two RHRSW pumps on each header; .one normally assigned to each header (A2, B2, C2, or D2) and one on alternate assignment (Al, Bl, Cl, or Dl). One RHR heat exchanger header can adequately deliver the flow supplied by both RHRSW pumps to any two of the three RHR heat'xchangers on the header. One RHRSW pump can supply the full flow requirement of one RHR heat exchanger. Two RHR heat exchangers can more than adequately handle the cooling requirements-of one unit in any abnormal or postaccident situation.

BFN 3.5/4.5-28 Unit 1

3.5 BASES (Cont'd)

The RHR Service Water System was designed as a shared system for three units. The specification, as written, is conservative when consider-ation is given to particular pumps being out of service and to possible valving arrangements. If unusual operating conditions arise such that more pumps are out of service than allowed by this specification, a special case request may be made to the NRC to allow continued operation if the actual system cooling requirements can be assured.

Should one of the two RHRSW pumps normally or alternately assigned to the RHR heat exchanger header supplying the standby coolant supply connection become inoperable, an equal capability for long-term fluid makeup to the unit reactor and for cooling of the unit containment remains OPERABLE. Because of the availability of an equal makeup and cooling capability, a 30-day repair period is justified. Should the capability to provide standby coolant supply be lost, a 10-day repair time is justified based on the low probability for ever needing the standby coolant supply. Verification that the LPCI subsystem crosstie valve is closed and power to its operator is disconnected ensures that each LPCI subsystem remains independent and a failure of the flow path in one subsystem will not affect the flow path of the other LPCI subsystem.

With only one unit fueled, four RHRSW pumps are required to be OPERABLE for indefinite operation to meet the requirements of Specification 3.5.B.1 (RHR system). If only three RHRSW pumps are OPERABLE, a 30-day LCO exists because of the requirement of Specification 3.5.B.5 (RHR system).

3.5.D E ui ment Area Coolers There is an equipment area cooler for each RHR pump and an equipment area cooler for each set (two pumps, either the A and C or B and D pumps) of core spray pumps. The equipment area coolers take suction near the cooling air discharge of the motor of the pump(s) served and discharge air near the cooling air suction of the motor of the pump(s) served. This ensures that cool air is supplied for cooling the pump motors.

The equipment area coolers also remove the pump, and equipment waste heat from the basement rooms housing the engineered safeguard equipment. The various conditions under which the operation of the equipment air coolers is required have been identified by evaluating the normal and abnormal operating transients and accidents over the full range of planned operations. The surveillance and testing of area coolers in each of their various modes-is accomplished the'quipment.

during the testing of the equipment served by these coolers. This

-testing is adequate to assure the OPERABILITY of the equipment area coolers.

REFERENCES 1, Residual Heat Removal System (BFN FSAR Section 4.8)

2. Core Standby Cooling System (BFN FSAR subsection 6.7)

BFN 3.5/4.5-29 Unit 1

UNIT 2 EFFECTIVE PAGE LIST REMOVE INSERT 3.5/4.5-9 3.5/4.5-9 3.5/4.5-10 3.5/4.5-10*

3.5/4.5-11 3.5/4.5-11 3.5/4.5-lla 3.5/4.5-lla*

3.5/4.5-26 3.5/4.5-26 3.5/4.5-27 3.5/4.5-27

  • Denotes overleaf or spillover page.

3 5 4 CORE AND CO I COOLI G SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.5.C RHR Se vice Water and Eme enc 4.5.C RHR Service Water and Emer enc E ui ment Coolin Water S stems ui ment Coolin Water S stems

~EECWS ~EE CWS

1. PRIOR TO STARTUP from a 1~ a~ Each of the RHRSW pumps COLD SHUTDOWN CONDITION, normally assigned to the RHRSW pumps, including automatic service on one of pumps Dl, D2, B2 or the EECW headers will Bl, shall be OPERABLE and be tested assigned to service as automatically each time indicated in Table 3.5-1. the diesel generators are tested. Each of the RHRSW pumps and all associated essential control valves for the EECW headers and RHR heat exchanger headers shall be demonstrated to be OPERABLE in accordance with Specification 1.0.MM.
b. Annually each RHRSW pump shall be flow-rate tested. To be considered OPERABLE, each pump shall pump at least 4500 gpm through its normally assigned flow path.
c. Monthly verify that each valve (manual, power-operated, or automatic) in the flowpath servicing safety-related equipment in the affected unit that is not locked, sealed, or otherwise secured in position, is in its correct position.

BFN 3.5/4.5-9 Unit 2

/4 5 CORE A CONTAINMENT COOLING SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.5.C RHR Service Water and Emer enc 4.5.C RHR Service Water and Emer enc E ui ment Coolin Water S stems E ui ment Coolin Water S stems EECWS Continued EECWS Conti ued

2. During REACTOR POWER 2. No additional surveillance OPERATION, RHRSW pumps is required.

must be OPERABLE and assigned to service as indicated in Table 3.5-1 for the specified time limits.

3. During Unit 2 REACTOR 3. Routine surveillance for POWER OPERATION, any two these pumps is specified RHRSW pumps (Dl, D2, Bl, in 4.5.C.l.

and B2) normally or alternately assigned to the RHR heat exchanger header supplying the standby coolant supply connection must be OPERABLE except as specified in 3.5.C.4 and 3.5.C.5 below.

3.5/4.5-10 (MENOlHENT N0 g6g BFN'nit 2

Table 3.5-1 Minimum RHRSW and EECW Pump Assignment 1 Unit Fueled 2 Units Fueled 3 Units Fueled Time Limit 2 Units Defue ed 1 Unit Defueled RHRSW EECW A RHRSW EECW A RHRSW EECW A None 4 and 3 5 and 3 7 and 3 5 and 2 7 and 2 30 Days 3 and 2 (or) (or) 4 . and 3 6 and 3 7 Days 2 and 2 4 and 2 6 and 2 Note:

(A) At least one OPERABLE pump must be assigned to each header. Only automatically starting pumps may be assigned to EECW header service.

BFN 3.5/4.5-11 Unit 2

THIS PAGE INTENTIONALLYLEFT BLANK BFN 3.5/4.5-lla AMENDMENT g0. y6g Unit 2

3.5 Bases (Cont'd)

The suppression chamber can be drained when the reactor vessel pressure is atmospheric, irradiated fuel is in the reactor vessel, and work is not in progress which has the potential to drain the vessel. By requiring the fuel pool gate to be open with the vessel head removed, the combined water inventory in the fuel pool, the reactor cavity, and the separator/dryer pool, between the fuel pool low level alarm and the reactor vessel flange, is about 65,800 cubic feet (492,000 gallons).

This will provide adequate low-pressure cooling in lieu of CSS and RHR (LPCI and containment cooling mode) as currently required in Specifications 3.5.A.4 and 3.5.B.9. The additional requirements for providing standby coolant supply available will ensure a redundant supply of coolant supply. Control rod drive maintenance may continue during this period provided no more than one drive is removed at a time unless blind flanges are installed during the period of time CRDs are not in place.

Should the capability for providing flow through the cross-connect lines be lost, a 10-day repair time is allowed before shutdown is required. This repair time is justified based on the very small probability for ever needing RHR pumps and heat exchangers to supply an adjacent unit.

REFERENCES

1. Residual Heat Removal System (BFNP FSAR subsection 4.8)
2. Core Standby Cooling Systems (BFNP FSAR Section 6)

'3.5.C. RHR Service Water S stem and Emer enc E ui ment Coolin Water S stem EECWS The EECW has two completely redundant and independent headers (north and south) in a loop arrangement inside and outside the Reactor Building. Each header is supplied by two automatic RHRSW pumps. A crosstie at the RHRSW pump discharge provides the capability for each header to be supplied by four automatically starting RHRSW pumps.

Those components requiring EECW, except the control air compressors which are not safety related, are able to be fed from both headers thus assuring continuity of operation if either header becomes inoperable.

The control air compressors only use EECW as an emergency backup supply.

There are four RHR heat exchanger headers (A, B, C, Ec D) with one RHR heat exchanger from each unit on each header. There are two RHRSW pumps on each header; one normally assigned to each header (A2, B2, C2,'r D2) and one on alternate assignment (Al, Bl, Cl, or Dl). One RHR heat exchanger headercan adequately deliver the flow supplied by both RHRSW pumps to any two of the three RHR heat exchangers on the header.

One RHRSW pump can supply the full flow requirement of one RHR heat exchanger, Two RHR heat exchangers can more than adequately handle the

.cooling requirements of one unit in any abnormal- or postaccident situation.

BFN 3.5/4.5-26 Unit 2

3.5 BASES (Cont'd)

The RHR Service Water System was designed as a shared system for three units. The specification, as written, is conservative when consider

-ation is given to particular pumps being out of service and to possible valving arrangements. If unusual operating conditions arise such that more pumps are out, of service than allowed by this specification, a special case request may be made to the NRC to allow continued operation if the actual system cooling requirements can be assured.

Should one of the two RHRSW pumps normally or alternately assigned to the RHR heat exchanger header supplying the standby coolant supply connection become inoperable, an equal capability for long-term fluid makeup to the unit reactor and for cooling of the unit containment remains OPERABLE. Because of the availability of an equal makeup and cooling capability, a 30-day repair period is justified. Should the capability to provide standby coolant supply be lost, a 10-day repair time is justified based on the low probability for ever needing the standby coolant supply. Verification that, the LPCI subsystem crosstie valve is closed and power to its operator is disconnected ensures that each LPCI subsystem remains independent and a failure of the flow path in one subsystem will not affect the flow path of the other LPCI subsystem.

With only one unit fueled, four RHRSW pumps are required to be OPERABLE for indefinite operation to meet the requirements of Specification 3.5.B.1 (RHR system). If only three RHRSW pumps are OPERABLE, a 30-day LCO exists because of the requirement of Specification 3.5.B.5 (RHR system).

3.5.D E ui ment Area Coolers There is an equipment area cooler for each RHR pump and an equipment area cooler for each set (two pumps, either the A and C or B and D pumps) of core spray pumps. The equipment area coolers take suction near the cooling air discharge of the motor of the pump(s) served and discharge air near the cooling air suction of the motor of the pump(s) served. This ensures that cool air is suppl'ied for cooling the pump motors.

The equipment area coolers also remove the pump, and equipment waste heat from the basement rooms housing the engineered safeguard equipment. The various conditions under which the operation of the equipment air coolers is required have been identified by evaluating the normal and abnormal operating transients and accidents over the full range of planned operations. The surveillance and testing of the equipment area coolers in each of their various modes is accomplished during the testing of the equipment served by these coolers. This testing is adequate to assure the OPERABILITY of the equipment area coolers.

REFERE CES 1; Residual Heat Removal System (BFN FSAR Section 4.8)

2. Core Standby Cooling System (BFN FSAR subsection 6.7)

BFN 3.5/4.5-27 Unit 2

UNIT 3 EFFECTIVE PAGE LIST REMOVE INSERT 3.5/4.5-9 3.5/4.5-9 3.5/4.5-10 3.5/4.5-10*

3.5/4.5-11 3.5/4.5-11 3.5/4.5-118 3.5/4.5-lla*

3.5/4.5-29 3.5/4.5-29 3.5/4.5-30 3.5/4.5-30

  • Denotes overleaf or spillover page.

4 5 CORE AND CO AINMENT COOLI G SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3 '.C RHR Serv ce Water and Emer enc 4.5.C RHR Service Water and Emer enc E ui ment Coolin Water S stems .E ui ment Coolin Water S stems

~EECWS ~EECWS P

1. PRIOR TO STARTUP from a 10 a ~ Each of .the RHRSW pumps COLD SHUTDOWN CONDITION, normally assigned to the RHRSW pumps, including automatic service on pump Bl or B2, shall be the EECW headers will OPERABLE and assigned to be tested service as indicated in automatically each time Table 3.5-1. the diesel generators are tested. Each of the RHRSW pumps and all associated essential control valves for the EECW headers and RHR heat exchanger headers shall be demonstrated to be OPERABLE in accordance with Specification 1.0.MM.
b. Annually each RHRSW pump shall be flow-rate tested. To be considered OPERABLE, each pump shall pump at least 4500 gpm through its normally assigned flow path.

c~ Monthly verify that each valve (manual, power-operated, or automatic) in the flowpath servicing safety-related equipment in the affected unit that is not locked, sealed, or otherwise secured in position, is in its correct position.

BFN 3.5/4.5-9 Unit 3

4. CORE AND CONTAINMENT COOLING SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.5.C RHR Service Water and Emer enc 4.5.C RHR Service Water and Emer enc E u ment Coolin Water S stems E ui ment Coolin Water S stems EECWS Continued EECWS Continued
2. During REACTOR POWER 2. No additional surveillance OPERATION, RHRSW pumps is required.

must be OPERABLE and assigned to service as indicated in Table 3.5-1 for the specified time limits.

3. During REACTOR POWER 3. Routine surveillance for OPERATION, both RHRSW these pumps is specified pumps Bl and B2 normally in 4.5.C.1.

or alternately assigned to the RHR heat exchanger header supplying the standby coolant supply connection must be OPERABLE except as specified in 3.5.C.4 and 3.5.C.5 below.

BFN 3.5/4.5-10 AMVro~zrn rrO. T4 0 Unit 3

Table 3.5-1 Minimum RHRSW and EECW Pump Assignment 1 Unit Fueled 2 Units Fueled 3 Units Fueled Time Limit 2 Units Defueled 1 Unit Defueled RHRSW EECW A RHRSW EECW A RHRSW EECW A None 4 and 3 5 and 3 7 and 3 5 and 2 7 and 2 30 Days 3 and 2 (or) (or) 4 and 3 6 and 3 7 Days 2 and 2 4 and 2 6 and 2 Note:

(A) At least one OPERABLE pump must be assigned to each header. Only automatically starting pumps may be assigned to EECW header service.

BFN 3.5/4.5-11 Unit 3

THIS PAGE INTENTIONALLY LEFT BLANK AMENOMEIP go.

BFN 3. 5/4. 5-lla- X@O I

Unit 3

3'.5 Bases (Cont'd) p ~

The suppression chamber can be drained when the reactor vessel pressure is atmospheric, irradiated fuel is in the reactor vessel,'and work is not in progress which has the potential to drain the vessel. By requiring the fuel pool gate to be open with the vessel head removed, the combined water inventory in the fuel pool, the reactor cavity, and the separator/dryer pool, between the fuel pool low level alarm and the reactor vessel flange, is about 65,800 cubic feet (492,000 gallons).

This will provide adequate low-pressure cooling in lieu of CSS and RHR (LPCI and containment cooling mode) as currently required in Specifications 3.$ .A.4 and 3.5.B.9. The additional requirements for providing standby coolant supply available will ensure a redundant supply of coolant supply. Control rod drive maintenance may continue during this period provided no more than one drive is removed at a time unless blind flanges are installed during the period of time CRDs are not in place.

Should the capability for providing flow through the cross-connect lines be lost, a 10-day repair time is allowed before 'shutdown is required. This repair time is justified based on the very small probability for ever needing RHR pumps and heat exchangers to supply an adjacent unit.

REFERE CES

1. Residual Heat Removal System (BFNP FSAR subsection 4.8)
2. Core Standby Cooling Systems (BFNP FSAR Section 6) 3.5.C. RHR Service Water S stem and Emer enc E ui ment Coolin Mater S stem EECWS The EECW has two completely redundant and independent headers (north and south) in a loop arrangement inside and outside the Reactor Building. Each header is supplied by two automatic RHRSW pumps. A crosstie at the RHRSW pump discharge provides the capability for each header to be supplied by four 'automatically starting RHRSW pumps.

Those components requiring EECW, except the control air compressors which are not safety related, are able to be fed from both headers thus assuring continuity of operation if either header becomes inoperable.

The control air compressors only use EECW as an emergency backup supply.

There are four RHR heat exchanger headers (A, B, C, S D) with one RHR heat exchanger from each unit on each header. There are two RHRSW pumps on each header; one normally assigned to each header (A2, B2, C2,-

or D2) and one on alternate assignment (Al, Bl, Cl, or Dl). One RHR heat exchanger header can adequately deliver the flow supplied by both RHRSW pumps to any two of the three RHR heat exchangers on the header.

One RHRSM pump can supply the full flow requirement of one RHR heat exchanger. Two RHR heat exchangers can more than adequately handle the cooling requirements of one unit, in any abnormal or postaccident situation.

BFN 3.5/4.5-29 Unit'

3.5 The RHR Service Water System was designed as a shared system for three units. The specification, as written, is conservative when consider-ation is given to particular pumps being out of service and to possible valving arrangements. If unusual operating conditions arise such that more pumps are out of service than allowed by this specification, a special case request may be made to the NRC to allow continued operation if the actual system cooling requirements can be assured.

Should one of the two RHRSW pumps normally or alternately assigned to the RHR heat exchanger header supplying the standby coolant supply connection become inoperable, an equal capability for long-term fluid makeup to the unit reactor and for cooling of the unit containment remains OPERABLE. Because of. the availability of an equal makeup and cooling capability, a 30-day repair period is justified. Should the capability to provide standby coolant supply be lost, a 10-day repair time is justified based on the low probability for ever needing the standby coolant supply. Veri'fication that the LPCI subsystem cross-tie valve is closed and power tb its operator is disconnected ensures that each LPCI subsystem remains independent and a failure of the flow path in one subsystem will not affect the flow path of the other LPCI subsystem.

With only one unit fueled, four RHRSW pumps are required to be OPERABLE for indefinite operation to meet the requirements of Specification 3.5.B.l (RHR system). If only three RHRSW pumps are OPERABLE, a 30-day LCO exists because of the requirement of Specification 3.5.B.5 (RHR system).

3.5.D E ui ment Area Coolers There is an equipment area cooler for each RHR pump and an equipment area cooler for each set (two pumps, either the A and C or B and D pumps) of core spray pumps. The equipment area coolers take suction near the cooling air discharge of the motor of the pump(s) served and discharge air near the cooling air suction of the motor of the pump(s) served. This ensures that cool air is supplied for cooling the pump motors.

The equipment area coolers also remove the pump, and equipment waste heat from the basement, rooms housing the engineered safeguard equipment. The various conditions under which the operation of the equipment air coolers is required have been identified by evaluating the normal and abnormal operating transients and accidents over the full range of planned operations. The surveillance and testing of the equipment area coolers in each of their various modes-is accomplished during the testing of the equipment served by these coolers. This testing is adequate to assure the OPERABILITY of the equipment area coolers.

REFERENCES

1. Residual Heat Removal System (BFN FSAR Section 4.8)

S

2. Core Standby Cooling System (BFN FSAR subsection 6.7)

BFN 3.5/4.5-30 Unit 3

ENCLOSURE 2 REASON FOR CHANGE, DESCRIPTION, AND JUSTIFICATION BROWNS FERRY NUCLEAR PLANT (BFN)

REASO FOR CHA GE The BFN units 1, 2, and 3 technical specifications, as described below, are being revised to clarify the limiting condition for operation (LCO) for the residual heat removal service water (RHRSW) and emergency equipment cooling water (EECW) systems. Specifically:

1. LCO 3.5.C.1 is being revised to refer the user to table 3.5-1 for RHRSW pump operability requirements prior to startup from a cold shutdown condition.
2. Table 3.5-1 is being reformatted and revised.
3. Clarifications, corrections, and additions are being made to the base's section 3.5.C for RHRSW and EECW.

DESCRIPTION AND JUSTIFICATION FOR THE PROPOSED CHA GE

i. Revise LCO 3.5.C.1 Existing LCO 3.5.C.1 reads:

"1. PRIOR TO STARTUP from a COLD CONDITION, 9 RHRSW pumps must be OPERABLE, with 7 pumps (unit specific) assigned to RHRSW service and 2 automatically starting pumps assigned to EECW service."

Proposed change to LCO 3.5.C.l would read:

. "1. PRIOR TO STARTUP from a COLD SHUTDOWN CONDITION, the RHRSW pumps, including (unit specific) . . ., shall be OPERABLE and assigned to service as indicated in Table 3.5-1."

2. Reformat and revise table 3.5:1 to add a title to the table, to create separate columns for the minimum number of RHRSW and EECW pumps required to be operable based on the number of fueled units, and to delete notes which are unnecessary as a result of the reformatting and revision.

P lt 0 Enclosure 2 Page 2

3. Revise bases section 3.5.C for RHRSW and EECW.
a. The current bases for EECW are being replaced by the following "The EECW has two completely redundant and independent headers (north and south) in a loop arrangement inside and outside the Reactor Building. Each header is supplied by two automatic RHRSW pumps. A crosstie at the RHRSW pump discharge provides the capability for each header to be supplied by four automatically starting RHRSW pumps.

Those components requiring EECW, except the control air compressors which are not safety related, are able to be fed from both headers thus assuring continuity of operation air if either asheader only use becomes inoperable. The compressors EECW an emergency backup supply."

b. A correction is being made to the RHRSW bases for units 1 and 2 only to change "RHRSW" heat exchanger to "RHR" heat exchanger.
c. Add the following to the bases: "With only one unit fueled, four RHRSW pumps are required to be OPERABLE for indefinite operation to meet the requirements"of specification 3.5.B.1 (RHR system). If only three RHRSW pumps are OPERABLE, a 30 day LCO exists because of the requirement of specification 3.5.B.5 (RHR system).

The first change will refer the user directly to Table 3.5-1 for RHRSW/EECW pump operability requirements. This will ensure consistency in determining the number of pumps required to be operable prior to startup and during operation and prevent confusion as to the number of operable pumps required.

=

LCO 3.5.C.l will still list the plant specific pumps required. Table 3.5-1 will give the specific numbers of pumps, both RHRSW and EECW, required prior to .startup from a cold shutdown condition. Table 3.5.1 is currently used to define the number of pumps required to be operable during operation.

Table 3.5-1 is being reformatted by adding a title and creating separate columns for the minimum number of RHRSW and EECW pumps required operable based on the number of units that are fueled. Currently, TS LCO 3.5.B.l (RHR system) requires four RHRSW pumps to be operable indefinitely with two units defueled to supply the RHR heat exchangers. However, the current Table 3.5-1 requires only three RHRSW pumps to be operable indefinitely with two units defueled. Reformatting the table eliminates this conflict and facilitates its use. As a result of the reformatting, existing notes (3) and (4) are no longer needed and notes (1) and (2) have been combined into note A.

The revision to bases section 3.5.C for EECW will ensure that it correctly describes the arrangement and operation of the system. The minor revision to the RHRSW section corrects a typographical error that only exists on units 1 and 2. Statements have been added to the bases to describe the connection between the minimum number of RHRSW pumps required with one unit fueled and the RHR technical specifications.

ENCLOSURE 3 PROPOSED DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION BROWNS FERRY NUCLEAR PLANT (BFN)

DESCRIPT 0 OF PROPOSE EC ICA SPEC FICATIO AME BFN units 1, 2, and 3 technical specifications (TSs) are being revised to clarify the operability requirements for the residual heat removal service water (RHRSW) and emergency equipment cooling water (EECW) systems as follows:

1. Limiting condition for operation (LCO) 3.5.C.l is being revised to refer the user to table 3.5-1 for RHRSW pump operability requirements prior to startup from a cold shutdown condition.
2. Table 3.5-1 is being reformatted and revised.
3. Clarifications, corrections, and additions are being made to the bases section 3.5.C for RHRSW and EECW.

BASIS FOR PROPOSED 0 SIG IFICA HAZARDS CONSIDERATIO DETERMI ATIO NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license involves no significant hazards considerations 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 previously evaluated, or (2) create the possibility of a new or different kind of accident from an accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

1. The proposed change does not significantly increase the probability or consequences of an accident previously evaluated.

The RHRSW system is designed to provide cooling water for the RHR system.

heat exchangers which are required for a safe reactor shutdown following a design basis transient or accident. The system is remote-manually operated from each of the three unit control rooms. The RHRSW system is a twelve-pump, four-header system with four pairs of pumps assigned to the RHRSW system. Each of the pairs feeds one independent RHR service water header which, in turn, feeds. one RHR heat exchanger in each unit. Each pump has the capacity to supply 100 percent of the cooling water required by one RHR heat- exchanger in each unit.

The proposed amendment clarifies the RHRSW operability requirements prior to startup from a cold shutdown condition (LCO 3.5.C.1) by referring the user directly to Table 3.5-1. Table 3.5.1 currently is referred to for pump requirements during operation.

gp Enclosure 3 Page 2 The revisions to Table 3.5-1 ensure consistency with the requirements of the RHR system (LCO 3.5.B.1) for operation with only one unit fueled. The change will ensure that an adequate supply of RHRSW is available to supply the RHR pumps and to support EECW during startup and operation. The administrative changes to Table 3.5-1 will prevent confusion. The bases changes will clarify and correct the bases consistent with the arrangement and operation of the system. Based on the above, the proposed changes do not increase the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

This change does not add any new equipment to the plant or require any existing equipment to be operated in a different manner from which it was designed to operate. The requirements for RHRSW pump operability are consistent with the FSAR analysis of design bases accidents (chapter 14) and consistent with the operability requirements for the RHR system. The change will also eliminate a conflict under some operational modes between LCO 3.5.B.1 (RHR system) and Table 3.5-1. No operation outside the plant design basis is introduced, so there is no possibility for creation of a new or different kind of accident from any previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The changes are consistent with the existing BFN Safety Analysis Report.

No adverse safety impact or reduction in safety margins occurs due to the proposed changes. The changes do not affect the ability of the RHRSW system to perform its ultimate safety objective of heat removal from the primary water of the Residual Heat Removal system. The change does not physically modify any equipment, setpoints, or initiation sequence of equipment. The proposed change increases the number of RHRSW pumps required to be operable for continued operation with only one unit fueled, ensuring an adequate water supply will be available in order for the system to perform its intended safety function. Therefore, the proposed changes do not involve a significant reduction in a margin of safety-.

Th'ese changes have been reviewed by TVA. Based on this review TVA does not believe the changes present a Significant Hazards Consideration;

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