ML18036A893

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Proposed TS Section 3.10.A/4.10.A Re Refueling Interlocks Associated W/Equipment Hoists & TS Section 3.10.B/4.10.B Re Core Monitoring
ML18036A893
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 10/09/1992
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18036A892 List:
References
NUDOCS 9210140310
Download: ML18036A893 (80)


Text

ENCLOSURE 1 PROPOSED TECHNICALSPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (TVABFN TS 324) 9210140310 921009 PDR ADOCK 05000259 P

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PROPOSED TECHNICALSPECIFICATION CHANGE BROGANS FERRY NUCLEAR PLANT UNIT 1 (TVASFN TS 324)

UNIT 1 EFFECTIVE PAGE LIST REHOVE INSERT 1.0-7 3.10/4.10-1 3.10/4.10-2 3.10/4.10-3 3.10/4.10-4 3.10/4.10-5 3.10/4.10-11 3.10/4.10-12 3.10/4.10-13 3.10/4.10-15 6.0-3 3.3.I.

1.0-7 3.10/4.10-1 3.10/4.10-2 3.10/4.10-3 3.10/4.10-4 3.10/4.10-5 3.10/4.10-11 3.10/4.10-12 3.10/4.10-13 3.10/4.10-15 6.0-3

Sdction 3.7/4.7 E.

Jet Pumps...

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F.

Recirculation Pump Operation G.

Structural Integrity H.

Snubbers Containment Systems A.

Primary Containment.

B.

Standby Gas Treatment System C.

Secondary Containment.

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Ne 3.6/4.6-11 3.6/4.6-12 3.6/4.6-13 3.6/4.6-15 3.7/4.7-1 3.7/4.7-1 3.7/4.7-13 3.7/4.7-16 D.

Primary Containment Isolation Valves 3.7/4.7-17 E.

Control Room Emergency Ventilation 3.7/4.7-19 F.

Primary Containment Purge System 3.7/4.7-21 G.

Containment Atmosphere Dilution System (CAD) 3.7/4.7-22 3.8/4.8 H.

Containment Atmosphere Monitoring (CAM)

System H2 Analyzer Radioactive Materials A.

Liquid Effluents B.

Airborne Effluents C.

Radioactive Effluents Dose D.

Mechanical Vacuum Pump 3.7/4.7-24 3.8/4.8-1 3.8/4.8-1 3.8/4.8-3 3.8/4.8-6 3.8/4.8-6 E.

Miscellaneous Radioactive Materials F.

Solid Radwaste 3.9/4.9 Auxiliary Electrical System A.

Auxiliary Electrical Equipment Sources.

3.8/4.8-7 3.8/4.8-9 3.9/4.9-1 3.9/4.9-1 B.

Operation with Inoperable Equipment.

3.9/4.9-8 C.

Operation in Cold Shutdown 3.10/4.10 Core Alterations A.

Refueling Interlocks 3.9/4.9-15 3.10/4.10-1 3.10/4.10-1 B.

Core Monitoring.

3;10/4.10-5 BFN Unit 1

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l.'O DEFINITIONS t'd)

Q.

0 eratin C cle Interval between the end of one refueling outage for a particular unit and the end of the next subsequent refueling outage for the same unit.

R.

Refuelin Outa e Refueling outage is the period of time between the shutdown of the unit prior to a refueling and the startup of the unit after that refueling.

For the purpose of designating frequency of testing and surveillance, a refueling outage shall mean a regularly scheduled outage;

however, where such outages occur within 8 months of the completion of the previous refueling outage, the required surveillance testing need not be performed until the next regularly scheduled outage.

S.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel,

sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel.

Movement of source range monitors, intermediate range monitors, traversing in-core probes, or special movable detectors (including undervessel replacement,)

is not considered a

CORE ALTERATION.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe location.

T.

Reactor Vessel Pressure Unless otherwise indicated, reactor vessel pressures listed in the Technical Specifications are those measured by the reactor vessel steam space detectors.

U.

Thermal Parameters 1.

Minimum Critical Power Ratio MCPR Minimum Critical Power Ratio (MCPR) is the value of the critical power ratio associated with the most limiting assembly in the reactor core.

Critical Power Ratio (CPR) is the ratio of that power in a fuel assembly, which is calculated to cause some point in the assembly to experience boiling transition, to the actual assembly operating power.

2.

Transition Boilin Transition boiling means the boiling regime between nucleate and film boiling.

Transition boiling is the regime in which both nucleate and film boiling occur intermittently with neither type being completely stable.

3.

Core Maximum Fraction of Limitin Power Densit CMFLPD The highest ratio, for all fuel types in the core, of the maximum fuel rod power density (kW/ft) for a given fuel type to the limiting fuel rod power density (kW/ft) for that fuel type.

4, Avera e Planar Linear Heat Generation Rate APLHGR The Average Planar Heat Generation Rate is applicable to a specific planar height and is equal to the sum of the linear heat generation rates for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

BFN Unit 1

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1 CORE ALT TIONS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.10 CORE ALTERATIONS 4.10 CORE ALTERATIONS licabilit Applies to the fuel handling and core reactivity limitations.

A licabilit Applies to the periodic testing of those refueling equipment interlocks and instrumentation required during refueling and CORE ALTERATIONS.

~Ob ective Ob ective To ensure that core reactivity is within the'apability of the control rods and to prevent criticality during refueling.

.,To verify.the OPERABILITY"of instrumentation and refueling equipment inter-locks required during refueling and CORE ALTERATIONS.

S ecification S ecification A.

Refuelin Interlocks A.

Refuelin Interlocks 1.

The reactor mode switch shall be locked in the REFUEL position during CORE ALTERATIONS.

The required refueling equipment interlocks shall be OPERABLE during in-vessel fuel movement with equipment associated with the interlocks except as specified in 3.10.Ae6 and 3.10.A.7 below.

1. Prior to any fuel handling with the head off the
vessel, the following required refueling equipment interlocks shall be functionally tested:

a.

All rods inserted b.

Refueling platform positioned near or over the core c.

Refueling platform main hoist is fuel loaded d.

Fuel grapple is not full up e.

One rod withdrawn BFN Unit 1 3e10/4e10-1

LIMITING CONDITION R OPERATION SURVE NCE RE UIREMENTS 3.10.A.

Refuelin Interlocks 4.10.A.

Refuelin Interlocks 4.10.A.1 (Continued)

  • f.

Refueling platform frame-mounted hoist is fuel loaded

  • g.

Monorail hoist is fuel loaded

  • h.

Service platform hoist is fuel loaded They shall be tested at weekly intervals

- thereafter until no longer required.

They shall also be tested following any repair work associated with the interlocks.

  • NOTE These interlocks are required to be OPERABLE only when the associated equipment is used for in-vessel fuel movement.

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Fuel shall not be loaded into the reactor core unless

. all control rods are fully inserted.

2.

No additional surveillance required.

3.

The fuel grapple hoist load switch shall be set at g 1,000 lbs.

3.

No additional surveillance required.

4. If the frame-mounted auxiliary hoist, the monorail-mounted auxiliary hoist, or the service platform hoist is to be used for handling fuel with the head off the reactor vessel, the load limit switch on the hoist to be used shall be set at 400 lbs.

4.

No additional surveillance required.

BFN Unit 1 3.10/4.10-2

3.'10/4.1 CORE AL TIONS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.10.A.

Refuelin Interlocks 4.10.A.

Refuelin Interlocks 5.

Maintenance may be performed on a single control rod or control rod drive without removing the fuel in the control cell if the following conditions are met:.

a.

The requirements of Specification 3.10.A.l are met, and b.

All control rods diagonally and face adjacent to the maintenance rod are fully inserted and have their directional control valves electrically disarmed.

5.

Prior to performing control rod or control rod drive maintenance on a control cell without removing fuel assemblies the surveillance require-ments of Specification 4.10.A.1 shall be performed and all rods face adjacent and diagonally adjacent to the maintenance rod shall be electrically disarmed per Specification 3.10.A.5.b.

6.

A maximum of two non-adjacent control rods may simultaneously be withdrawn from the core for the purpose of performing control rod and/or control rod drive maintenance without removing the fuel from the cells provided the following conditions are satisfied:

6.

Prior to performing control rod or control rod drive maintenance on two control cells simultaneously without removing the fuel from the cells, two SROs shall verify that the requirements of Specification 3.10.A.6 are satisfied.

a.

The reactor mode switch shall be locked in the REFUEL position.

The refueling interlock which prevents more than one control rod from being withdrawn may be bypassed for one of the control rods on which maintenance is being performed.

All other required refueling equipment interlocks shall be OPERABLE.

BFN Unit 1 3.10/4.10-3

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3.10.A.6 (Cont'd) b.

All directional control valves for remaining control rods shall be disarmed electrically except as specified in 3.10.A.7 and sufficient margin to criticality shall be demonstrated.

c.

The two maintenance cells must be separated by more than two control cells in any direction.

d.

An appropriate number of SRMs are available as defined in Specification 3.10.B.

7.

Any number of control rods may be withdrawn or removed from the reactor core providing the following conditions are satisfied:

a.

The reactor mode switch is locked in the REFUEL position.

The refueling interlock which prevents more than one control rod from being withdrawn may be bypassed on a withdrawn control rod after the fuel assemblies in the cell containing (controlled by) that control rod have been removed from the reactor core.

All other required refueling equipment interlocks shall be OPERABLE.

7.

With the mode selection switch in the REFUEL or SHUTDOWN mode, no more than one control rod may be withdrawn without first removing fuel from the cell except as specified in 4.10.A.6.

Any number of rods may be withdrawn once verified by two licensed operators that the fuel has been removed from each cell.

BFN Unit 1 3.10/4.10-4

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3.10.B.

4.10.B.

1.

During CORE ALTERATIONS, except as specified in 3.10.B.2, two SRMs (FLCs) shall be OPERABLE.

For an SRM (FLC) to be considered OPERABLE, the following shall be satisfied:

a.

The SRM shall be inserted to the normal operating level.

(Use of special

moveable, dunking type detectors during initial fuel loading and major CORE ALTERATIONS in place of normal detectors is permissible as long as the detector is connected to the normal SRM circuit.)

1.

Prior to making any CORE ALTERATIONS, the SRMs (FLCs) shall be functionally tested and checked for neutron response.

2.

Note:

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM (FLC) and no other fuel assemblies in the associated core quadrant.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS, verify that the associated SRM (FLC) is reading Z 3 cps with a signal-to-noise ratio 2. 3:l.

b.

Verify an OPERABLE SRM (FLC) is located in:

1.

The fueled region',

2.

The quadrant where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region; and 3.

A core quadrant adjacent to where CORE ALTERATIONS are being performed, when 'the associated SRM (FLC) is included in the fueled region.

Note:

One SRM (FLC) may be used to satisfy more than one of the above.

BFN Unit 1 3.10/4.10-5

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A.

Refuelin Interlocks The refueling interlocks are designed to back up procedural core reactivity controls during refueling operations.

The interlocks prevent an inadvertent criticality during refueling operations when the reactivity potential of the core is being altered.

To minimize the possibility of loading fuel into a cell containing no control rod, it is required that all control rods are fully inserted when fuel is being loaded into the reactor core.

This requirement assures that during refueling the refueling interlocks, as designed, will prevent inadvertent criticality.

The refueling interlocks reinforce operational procedures that prohibit taking the reactor critical under certain situations encountered during refueling operations by restricting the movement of control rods and the operation of refueling equipment.

The refueling interlocks include circuitry which senses the condition of the refueling equipment and the control rods.

Depending on the sensed condition, interlocks are actuated which prevent the movement of the refueling equipment or withdrawal of control rods (rod block).

Circuitry is provided which senses the following conditions.

1.

All rods inserted 2.

Refueling platform positioned near or over the core 3.

Refueling platform main hoist is fuel loaded 4.

Fuel grapple not full up 5.

One rod withdrawn 6.

Refueling platform frame-mounted hoist is fuel loaded 7.

Refueling platform monorail hoist is fuel loaded 8.

Service platform hoist is fuel loaded When the mode switch is in the "Refuel" position, interlocks prevent the refueling platform from being moved over the core if a control rod is withdrawn and fuel is on a hoist.

Likewise, if the refueling platform is over the core with fuel on a hoist, control rod motion is blocked by the interlocks.

When the mode switch is in the refuel position only one control rod can be withdrawn.

The refueling interlocks, in combination with core nuclear design and refueling procedures, limit the probability of an inadvertent criticality.

The nuclear characteristics of the core assure that the reactor is The refueling platform frame-mounted, monorail and the service platform fuel-loaded hoist interlocks are required to be OPERABLE only when utilized for in-vessel fuel movements.

BFN Unit 1 3.10/4.10-11

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3.10 BASES (Cont'd) subcritical even when the highest worth control rod is fully withdrawn.

The combination of refueling interlocks for control rods and the refueling platform provide redundant methods of preventing inadvertent criticality even after procedural violations.

The interlocks on hoists provide yet another method of avoiding inadvertent criticality.

Fuel handling is normally conducted with the fuel grapple hoist.

The total load on this hoist when the interlock is required consists of the weight of the fuel grapple and the fuel assembly.

This total is approximately 1,500 lbs, in comparison to the load-trip setting of 1,000 lbs.

Provisions have also been made to allow fuel handling with either of the three auxiliary hoists and still maintain the refueling interlocks.

The 400-lb load-trip setting on these hoists is adequate to trip the interlock when one of the more than 600-lb fuel bundles is being handled.

During certain periods, it is desirable to perform maintenance on two control rods and/or control rod drives at the same time without removing fuel from the cells.

The maintenance is performed with the mode switch in the refuel position to provide the refueling interlocks normally available during refueling operations.

In order to withdraw a second control rod after withdrawal of the first rod, it is necessary to bypass the refueling interlock on the first control rod which prevents more than one control rod from being withdrawn at the same time.

The requirement that an adequate shutdown margin be demonstrated and that all remaining control rods have their directional control valves electrically disarmed ensures that inadvertent criticality cannot occur during this maintenance.

The adequacy of the shutdown margin is verified by demonstrating that at least 0.38 percent Ak shutdown margin is available.

Disarming the directional control valves does not inhibit control rod scram capability.

Specification 3.10.A.7 allows unloading of a significant portion of the reactor core.

This operation is performed with the mode switch in the refuel position to provide the refueling interlocks normally available during refueling operations.

In order to withdraw more than one control rod, it is necessary to bypass the refueling interlock on each withdrawn control rod which prevents more than one control rod from being withdrawn at a time.

The requirement that the fuel assemblies in the cell controlled by the control rod be removed from the reactor core before the interlock can be bypassed ensures that withdrawal of another control rod does not result in inadvertent criticality.

Each control rod provides primary reactivity control for the fuel assemblies in the cell associated with that control rod.

Thus, removal of an entire cell (fuel assemblies plus control rod) results in a lower reactivity potential of the core.

The requirements for SRM OPERABILITY during these CORE ALTERATIONS assure sufficient core monitoring.

BFN Unit 1 3.10/4.10-12

'3.10 ghSP@ (Cont'dQ 3.10.A (Cont'd) 1.

Refueling interlocks (BFNP FSAR Subsection 7.6)

B.

The SRMs are provided to monitor the core during periods of station shutdown and to guide the operator during refueling operations and station startup.

Requiring two OPERABLE SRMs (FLCs) one in and one adjacent to"any core quadrant where fuel or control rods are being moved assures adequate monitoring of that quadrant during such alterations.

Each SRM (FLC) is not required to read ~ 3 cps until after four fuel assemblies have been loaded adjacent to the SRM (FLC) if no other fuel assemblies are in the associated core quadrant.

These four locations are adjacent to the SRM dry tube.

When utilizing FLCs, the FLCs will be located such that the required count rate is achieved without exceeding the SRM upscale setpoint.

With four fuel assemblies or fewer loaded around each SRM, even with a control rod withdrawn, the configuration will not be critical.

Under the special condition of removing the full core with all control rods inserted and electrically disarmed, it is permissible to allow SRM count rate to decrease below three counts per second.

All fuel moves during core unloading will reduce reactivity. It is expected that the SRMs will drop below three counts per second before all of the fuel is unloaded.

Since there will be no reactivity additions during this

period, the low number of counts will not present a hazard.

When sufficient fuel has been removed to the spent fuel storage pool to drop the SRM count rate below 3 cps, SRMs will no longer be required to be OPERABLE.

Requiring the SRMs to be functionally tested prior to fuel removal assures that the SRMs will be OPERABLE at the start of fuel removal.

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued OPERABILITY until the count rate diminishes due to fuel removal.

Control rods in cells from which all fuel has been removed and which are outside the periphery of the then existing fuel matrix may be armed electrically and moved for maintenance purposes during full core removal, provided all rods that control fuel are fully inserted and electrically disarmed.

1.

Neutron Monitoring System (BFNP FSAR Subsection 7.5) 2.

Morgan, W. R., "In-Core Neutron Monitoring System for General Electric Boiling Water Reactors,"

General Electric Company, Atomic Power Equipment Department, November 1968, revised April 1969 (APED-5706)

BFÃ Unit 1 3.10/4.10-13

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3.'lO.F S ent Fuel k H dli Refuelin Floor Although single failure protection has been provided in the design of the 125-ton hoist drum shaft, wire ropes, hook and lower block assembly on the reactor building crane, the limiting of liftheight of a spent fuel cask controls the amount of energy available in a dropped cask accident when the cask is over the refueling floor.

An analysis has been made which shows that the floor and support members in the area of cask entry into the decontamination facility can satisfactorily sustain a dropped cask from a height of three feet.

The yoke safety links provide single failure protection for the hook and lower block assembly and limit cask rotation.

Cask rotation is necessary for decontamination and the safety links are removed during decontamination.

4.10 BASES A.

Refuelin Interlocks Complete functional testing of all required refueling equipment interlocks before any refueling outage will provide positive indication that the interlocks operate in the situations for which they were designed.

By loading each hoist with a weight equal to the fuel

assembly, positioning the refueling platform, and withdrawing control
rods, the interlocks can be subjected to valid operational tests.

Where redundancy is provided in the logic circuitry, tests can be performed to assure that each redundant logic element can independently perform its function.

B.

Core Monitorin Requiring the SRMs to be functionally tested prior to any CORE ALTERATION assures that the SRMs will be OPERABLE at the start of that alteration.

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued OPERABILITY.

REFERENCES 1.

Fuel Pool Cooling and Cleanup System (BFNP FSAR Subsection 10.5) 2.

Spent Fuel Storage (BFNP FSAR Subsection 10.3)

BFN Unit 1 3.10/4.10-15

6.2.2 (Cont.)

d.

Two licensed reactor operators shall be in the control room during any cold startups, while shutting down the reactor, and during recovery from unit trip.

In addition, a person holding a senior operator license shall be in the control room for that unit whenever it is in an operational mode other than cold shutdown or refueling.

e.

A Health Physics Technician+ shall be present at the facility at all times when there is fuel in the reactor.

f.

Either a licensed SRO or licensed SRO limited to fuel handling who has no concurrent responsibilities during this operation shall be present during fuel handling and shall directly supervise all CORE ALTERATIONS.

g.

A site fire brigade of at least five members shall be maintained onsite at all times.*

The fire brigade shall not include the Shift Engineer and the other members of the minimum shift crew necessary for safe shutdown of the unit, nor any personnel required for other essential functions during a fire emergency.

  • The Health Physics Technician and fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected
absence, provided immediate action is taken to fillthe required positions.

BFN Unit l 6.0-3

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PROPOSED TECHNICALSPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 2 (TVABFN TS 324)

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UNIT 2 EFFECTIVE PAGE LIST REHOVE kv

1. 0-7 3.10/4.10-1 3.10/4.10-2 3.10/4.10-3 3.10/4.10-4 3.10/4.10-5 3.10/4.10-11 3.10/4.10-12 3.10/4.10-13 3.10/4.10-15 6.0-3 INSERT iv 1.0-7 3.10/4.10-1 3.10/4.10-2 3.10/4.10-3 3.10/4.10-4 3.10/4.10-5 3.10/4.10-11 3.10/4.10-12 3.10/4.10-13 3.10/4.10-15 6.0-3

Section

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Na 3.10/4.10 Core Alterations 3.10/4.10-1 A.

Refueling Interlocks 3.10/4.10-1 B.

Core Monitoring 3.10/4.10-5 C.

Spent Fuel Pool Water 3.10/4.10-7 D.

Reactor Building Crane 3.10/4.10-8 E.

Spent Fuel Cask 3.10/4.10-9 F.

Spent Fuel Cask Handling-Refueling Floor 3.10/4.10-10 3.11/4.11 Fire Protection Systems 3.11/4.11-1 A.

Fire Detection Instrumentation 3.11/4.11-1 B.

Fire Pumps and Water Distribution Mains 3.11/4.11-2 C.

Spray and/or Sprinkler Systems 3.11/4.11-7 D.

E.

C02 Systems a

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Fire Hose Stations 3.11/4.11-8 3.11/4.11-9 F.

Yard Fire Hydrants and Hose Houses 3.11/4.11-11 G.

Fire-Rated Assemblies 3.11/4.11-12 H.

Open Flames, Welding and Burning in Spreading Room the Cable

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3.11/4.11-13 5.0 Major Design Features 5.0-1 5.1 Site Features 5.0-1 5.2 Reactor 5.0-1 5.3 Reactor Vessel 5.0-1 5.4 Containment 5.0-1 5.5 Fuel Storage.

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1 5e6 Seismic Design

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2 BFN Unit 2 iv

1.0 DEFINITIONS (lgt'd)

Q.

0 eratin C cle Interval between the end of one refueling outage for a particular unit and the end of the next subsequent refueling outage for the same unit.

R.

Refuelin Outa e Refueling outage is the period of time between the shutdown of the unit prior to a refueling and the startup of the unit after that refueling.

For the purpose of designating frequency of testing and surveillance, a refueling outage shall mean a regularly scheduled outage;

however, where such outages occur within 8 months of the completion of the previous refueling outage, the required surveillance testing need not be performed until the next regularly scheduled outage.

S.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel,

sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel.

Movement of source range monitors, intermediate range monitors, traversing in-core probes, or special movable detectors (including undervessel replacement) is not considered a

CORE ALTERATION.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe location.

T.

Reactor Vessel Pressure Unless otherwise indicated, reactor vessel pressures listed in the Technical Specifications are those measured by the reactor vessel steam space detectors.

U.

Thermal Parameters 1.

Minimum Critical Power Ratio MCPR Minimum Critical Power Ratio (MCPR) is. the value of the critical power ratio associated with the most limiting assembly in the reactor core.

Critical Power Ratio (CPR) is the ratio of that power in a fuel assembly, which is calculated to cause some point in the assembly to experience boiling transition, to the actual assembly operating power.

2.

Transition Boilin Transition boiling means the boiling regime between nucleate and film boiling.

Transition boiling is the regime in which both nucleate and film boiling occur intermittently with neither type being completely stable.

3.

Core Maximum Fraction of Limitin Power Densit CMFLPD The highest ratio, for all fuel types in the core, of the maximum fuel rod power density (kW/ft) for a given fuel type to the limiting fuel rod power density (kW/ft) for that fuel type.

4.

Avera e Planar Linear Heat Generation Rate APLHGR The Average Planar Heat Generation Rate is applicable to a specific planar height and is equal to the sum of the linear heat generation rates for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

BFN Unit 2

10 4.1 CORE AL TIONS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.10 CORE ALTERATIONS 4.10 CORE ALTERATIONS A licabilit A licabilit Applies to the fuel handling and core reactivity limitations.

Applies to the periodic testing of those refueling equipment interlocks and instrumentation required during refueling and CORE ALTERATIONS.

Ob ective Ob ective To ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling.

To verify the OPERABILITY of instrumentation and refueling equipment inter-locks required during refueling and CORE ALTERATIONS.

S ecification A.

Refuelin Interlocks S ecification A.

Refuelin Interlocks 1.

The reactor mode switch shall be locked in the REFUEL position during CORE ALTERATIONS.

The required refueling equipment interlocks shall be OPERABLE during in-vessel fuel movement with equipment associated with the interlocks except as specified in 3.10.A.6 and 3.10.A.7 below.

1. Prior to any fuel handling with the head off the
vessel, the following required refueling equipment interlocks shall be functionally tested:

a.

All rods inserted b.

Refueling platform positioned near or over the core c.

Refueling platform main hoist is fuel loaded d.

Fuel grapple is not full up e.

One rod withdrawn BFN Unit 2 3.10/4.10-1

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'IMITING CONDITIONS R OPERATION SURVEI NCE RE UIREMENTS 3.10.A.

Refuelin Interlocks 4.10.A.

Refuelin Interlocks 4.10.A.1 (Continued)

  • f.

Refueling platform frame-mounted hoist is fuel loaded

  • g.

Monorail hoist is fuel loaded

  • h.

Service platform hoist is fuel loaded They shall be tested at weekly intervals thereafter until no longer required.

They shall also be tested following any repair work associated with the interlocks.

  • NOTE:

These interlocks are required to be OPERABLE only when the associated equipment is used for in-vessel fuel movement.

2.

Fuel shall not be loaded into the reactor core unless all control rods are fully inserted.

2.'o additional surveillance required.

3.

The fuel grapple hoist load switch shall be set at g 1,000 lbs.

3.

No additional surveillance required.

4. If the frame-mounted auxiliary hoist, the monorail-mounted auxiliary hoist, or the service platform hoist is to be used for handling fuel with the head off the reactor vessel, the load limit switch on the hoist to be used shall be set at

( 400 lbs.

4.

No additional surveillance required.

BFN Unit 2 3.10/4.10-2

41 CORE ALT TIONS LIMITI C CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.10.A.

Refuelin Interlocks 4.10.A.

Refuelin Interlocks 5.

Maintenance may be performed on a single control rod or control rod drive without removing the fuel in the control cell if the following conditions are met:

a.

The requirements of Specification 3.10.A.l are met, and b.

All control rods diagonally and face adjacent to the maintenance rod are fully inserted and have their directional control valves electrically disarmed.

5.

Prior to performing control rod or control rod drive maintenance on a control cell without removing fuel assemblies the surveillance require-ments of Specification 4.10.A.l shall be performed and all rods face adjacent and diagonally adjacent to the maintenance rod shall be electrically disarmed per Specification 3.10.A.5.b.

6.

A maximum of two non-adjacent control rods may simultaneously be withdrawn from the core for the purpose of performing control rod and/or control rod drive maintenance without removing the fuel from the cells provided the following conditions are satisfied:

6.

Prior to performing control rod or control rod drive maintenance on two control cells simultaneously without removing the fuel from the cells, two SROs shall verify that the requirements of Specification 3.10.A.6 are satisfied.

a.

The reactor mode switch shall be locked in the REFUEL position.

The refueling interlock which prevents more than one control rod from being withdrawn may be bypassed for one of the control rods on which maintenance is being performed.

All other required refueling equipment interlocks shall be OPERABLE.

BFN Unit 2 3.10/4.10-3

3.10.A.

4.10.A.

R t

k 3.10.A.6 (Cont'd)

All directional control valves for remaining control rods shall be disarmed electrically except as specified in 3.10.A.7 and sufficient margin to criticality

.shall be demonstrated.

c.

The two maintenance cells must be separated by more than two control cells in any direction.

d.

An appropriate number of SRNs are available as defined in Specification 3.10.B.

7.

Any number of control rods may be withdrawn or"removed from the reactor core providing the following conditions are satisfied:

a.

The reactor mode switch is locked in the REFUEL position.

The refueling interlock which prevents more than one control rod from being withdrawn may be bypassed on a withdrawn control rod after the fuel assemblies in the cell containing (controlled by) that control rod have been removed from the reactor core.

All other required refueling equipment interlocks shall be OPERABLE.

7.

With the mode selection switch in the REFUEL or SHUTDOWN mode, no more than one control rod may be withdrawn without first removing fuel from the cell except as specified in 4.10.A.6.

Any number of rods may be withdrawn once verified by two licensed operators that the fuel has been removed from each cell.

BFN Unit 2 3.10/4.10-4

0 4

~

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I!

~

~

G D

3.10.B.

4.10.B.

1.

During CORE ALTERATIONS, except as specified in 3.10.B.2, two SRMs (FLCs) shall be OPERABLE.

For an SRM (FLC) to be considered OPERABLE, the following shall be satisfied:

a.

The SRM shall be inserted to the normal operating level.

(Use of special moveable, dunking type detectors during initial fuel loading and major CORE ALTERATIONS in place of normal detectors is permissible as long as the detector is connected to the normal SRM circuit.)

b.

Verify an OPERABLE SRM (FLC) is located in:

1.

Prior to making any CORE ALTERATIONS, the SRMs (FLCs) shall be functionally tested and checked for neutron response.

2.

Note:

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM (FLC) and no other fuel assemblies in the associated core quadrant.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS, verify that the associated SRM (FLC) is reading Z 3 cps with a signal-to-noise ratio g 3:l.

1.

The fueled region; 2 ~ The quadrant where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region; and A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region.

Note:

One SRM (FLC) may be used to satisfy more than one of 'the above.

BFN Unit 2 3.10/4.10-5

~

~

A.

Refuelin Interlocks The refueling interlocks are designed to back up procedural core reactivity controls during refueling operations.

The interlocks prevent an inadvertent criticality during refueling operations when the reactivity potential of the core is being altered.

To minimize the possibility of loading fuel into a cell containing no control rod, it is required that all control rods are fully inserted when fuel is being loaded into the reactor core.

This requirement assures that during refueling the refueling interlocks, as designed, will prevent inadvertent criticality.

The refueling interlocks reinforce operational procedures that prohibit taking the reactor critical under certain situations encountered during refueling operations by restricting the movement of control rods and the operation of refueling equipment.

The refueling interlocks include circuitry which senses the condition of the refueling equipment and the control rods.

Depending on the sensed condition, interlocks are actuated which prevent the movement of the refueling equipment or withdrawal of control rods (rod block).

Circuitry is provided which senses the following conditions.

l.

All rods inserted 2.

Refueling platform positioned near or over the core 3.

Refueling platform main hoist is fuel loaded 4.

Fuel grapple not full up 5.

One rod withdrawn 6.

Refueling platform frame-mounted hoist is fuel loaded 7.

Refueling platform monorail hoist is fuel loaded 8.

Service platform hoist is fuel loaded When the mode switch is in the REFUEL position, interlocks prevent the refueling platform from being moved over the core=if a control rod is withdrawn and fuel is on a hoist.

Likewise, if the refueling platform is over the core with fuel on a hoist, control rod motion is blocked by the interlocks.

When the mode switch is in the refuel position only one control rod can be withdrawn.

The refueling interlocks, in combination with core nuclear design and refueling procedures, limit the probability of an inadvertent criticality.

The nuclear characteristics of the core assure that the reactor is The refueling platform frame-mounted, monorail and the service platform fuel-loaded hoist interlocks are required to be OPERABLE only when utilized for in-vessel fuel movements.

BFN Unit 2 3.10/4.10-11

~

~

3.10 BASES (Cont'd) subcritical even when the highest worth control rod is fully withdrawn.

The combination of refueling interlocks for control rods and the refueling platform provide redundant methods of preventing inadvertent criticality even after procedural violations.

The interlocks on hoists provide yet another method of avoiding inadvertent criticality.

Fuel handling is normally conducted with the fuel grapple hoist.

The total load on this hoist when the interlock is required consists of the weight of the fuel 'grapple and the fuel assembly.

This total is approximately 1,500 lbs, in comparison to the load-trip setting of 1,000 lbs.

Provisions have also been made to allow fuel handling with either of the three auxiliary hoists and still maintain the refueling interlocks.

The 400-lb load-trip setting on these hoists is adequate to trip the interlock when one of the more than 600-lb fuel bundles is being handled.

During certain periods, it is desirable to perform maintenance on two control rods and/or control rod drives at the same time without removing fuel from the cells.

The maintenance is performed with the mode switch in the refuel position to provide the refueling interlocks normally available during refueling operations.

In order to withdraw a second control rod after withdrawal of the first rod, it is necessary to bypass the refueling interlock on the first control rod which prevents more than one control rod from being withdrawn at the same time.

The requirement that an adequate shutdown margin be demonstrated and that all remaining control rods have their directional control valves electrically disarmed ensures that inadvertent criticality cannot occur during this maintenance.

The adequacy of the shutdown margin is verified by demonstrating that at least 0.38 percent.

Ak shutdown margin is available.

Disarming the directional control valves does not inhibit control rod scram capability.

Specification 3.10.A.7 allows unloading of a significant portion of the reactor core.

This operation is performed with the mode switch in the REFUEL position to provide the refueling interlocks normally available during refueling operations.

In order to withdraw more than one control rod, it is necessary to bypass the refueling interlock on each withdrawn control rod which prevents more than one control rod from being withdrawn at a time.

The requirement that the fuel assemblies in the cell controlled by the control rod be removed from the reactor core before the interlock can be bypassed ensures that withdrawal of another control rod does not result in inadvertent criticality.

Each control rod provides primary reactivity control for the fuel assemblies in the cell associated with that control rod.

Thus, removal of an entire cell (fuel assemblies plus control rod) results in a lower reactivity potential of the core.

The requirements for SRM OPERABILITY during these CORE ALTERATIONS assure sufficient core monitoring.

BFN Unit 2 3.10/4.10-12

3.IO 355FQ (Cont'd 3.10.A (Cont'd)

REKKBENZJK 1.

Refueling interlocks (BFNP FSAR Subsection 7.6)

B.

The SRMs are provided to monitor the core during periods of station shutdown and to guide the operator during refueling operations and station startup.

Requiring two OPERABLE SRMs (FLCs) one in and one adjacent to"any core quadrant where fuel or control rods are being moved assures adequate monitoring of that quadrant during such alterations.

Each SRM (FLC) is not'required to read Z 3 cps until after four fuel assemblies have been loaded adjacent to the SRM (FLC) if no other fuel assemblies are in the associated core quadrant.

These four locations are adjacent to the SRM dry tube.

When utilizing FLCs, the FLCs will be located such that the required count rate is achieved without exceeding the SRM upscale setpoint.

With four fuel assemblies or fewer loaded around each SRM, even with a control rod withdrawn, the configuration will not be critical.

Under the special condition of removing the full core with all control rods inserted and electrically disarmed, it is permissible to allow SRM count rate to decrease below three counts per second.

All fuel moves during core unloading will reduce reactivity.

It is expected that the SRMs will drop below three counts per second before all of the fuel is unloaded.

Since there will be no reactivity additions during this

period, the low number of counts will not present a hazard.

When sufficient fuel has been removed to the spent fuel storage pool to drop the SRM count rate below 3 cps, SRMs will no longer be required to be OPERABLE.

Requiring the SRMs to be functionally tested prior to fuel removal assures that the SRMs will be OPERABLE at the start of fuel removal.

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued OPERABILITY until the count rate diminishes due to fuel removal.

Control rods in cells from which all fuel has been removed and which are outside the periphery of the then existing fuel matrix may be armed electrically and moved for maintenance purposes during full core removal, provided all rods that control fuel are fully inserted and electrically disarmed.

REDREHQFN 1.

Neutron Monitoring System (BFNP FSAR Subsection 7.5) 2.

Morgan, W. R., "In-Core Neutron Monitoring System for General Electric Boiling Water Reactors," 'General Electric Company, Atomic Power Equipment Department, November 1968, revised April 1969 (APED-5706)

BFN Unit 2 3.10/4.10-13

3.XO.F S ent Fuel sk Handlin Refuelin Floor Although single failure protection has been provided in the design of the 125-ton hoist drum shaft, wire ropes, hook and lower block assembly on the reactor building crane, the limiting of liftheight of a spent fuel cask controls the amount of energy available in a dropped cask accident when the cask is over the refueling floor.

An analysis has been made which shows that the floor and support members in the area of cask entry into the decontamination facility can satisfactorily sustain a dropped cask from a height of three feet.

The yoke safety links provide single failure protection for the hook and lower block assembly and limit cask rotation.

Cask rotation is necessary for decontamination and the safety links are removed during decontamination.

4.10 BASES A.

Refuelin Interlocks Complete functional testing of all required refueling equipment interlocks before any refueling outage will provide positive indication that the interlocks operate in the situations for which they were designed.

By loading each hoist with a weight equal to the fuel

assembly, positioning the refueling platform, and withdrawing control
rods, the interlocks can be subjected to valid operational tests.

Where redundancy is provided in the logic circuitry, tests can be performed to assure that each redundant logic element can independently perform its function.

B.

Core Monitorin Requiring the SRMs to be functionally tested prior to any CORE ALTERATION assures that the SRMs will be OPERABLE at the start of that alteration.

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued OPERABILITY.

REFERENCES 1.

Fuel Pool Cooling and Cleanup System (BFNP FSAR Subsection 10.5) 2.

Spent Fuel Storage (BFNP FSAR Subsection 10.3)

BFN Unit 2 3.10/4.10-15

6.2.2 (Cont.)

d.

Two licensed reactor operators shall be in the control room during any cold startups, while shutting down the reactor, and during recovery from unit trip.

In addition, a person holding a senior operator license shall be in the control room for that unit whenever it is in an operational mode other than cold shutdown or refueling.

e.

A Health Physics Technician* shall be present at the facility at all times when there is fuel in the reactor.

f.

Either a licensed SRO or licensed SRO limited to fuel handling who has no concurrent responsibilities during this operation shall be present during fuel handling and shall directly supervise all CORE ALTERATIONS.

g.

A site fire brigade of at least five members shall be maintained onsite at all times.*

The fire brigade shall not include the Shift Engineer and the other members of the minimum shift crew necessary for safe shutdown of the unit, nor any personnel required for other essential functions during a fire emergency.

  • The Health Physics Technician and fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected
absence, provided immediate action is taken to fillthe required positions.

BFN Unit 2 6.0-3

PROPOSED TECHNICALSPECIFICATION CHANGE SROWNS FERRY NUCLEAR PLANT UNIT 3 (TVASFN TS 324)

UNIT 3 EFFECTIVE PAGE LIST RENOVE iii iv 1.0-7 3.10/4.10-1 3.10/4.10-2 3.10/4.10-3 3.10/4.10-4 3.10/4.10-5 3.10/4.10-10 3.10/4.10-11 3.10/4.10-12 3.10/4.10-14 6.0-3 INSERT iii iv 1.0-7 3.10/4.10-1 3.10/4.10-2 3.10/4.10-3 3.10/4.10-4 3.10/4.10-5 3.10/4.10-10 3.10/4.10-11 3.10/4.10-12 3.10/4.10-14 6.0-3

'ection

~Pa e

Ne 3.7/4.7 F.

Recirculation Pump Operation G,

Structural Integrity H,

Snubbers Containment Systems a

A.

Primary Containment.

B.

Standby Gas Treatment System C.

Secondary Containment.

D.

Primary Containment Isolation Valves E.

Control Room Emergency Ventilation F.

Primary Containment Purge System 3.6/4.6-12 3.6/4.6-13 3.6/4.6-15 3.7/4.7-1 3.7/4.7-1 3.7/4.7-13 3.7/4.7-16 3.7/4.7-17 3.7/4.7-19 3.7/4.7-21 G.

Containment Atmosphere Dilution System (CAD) 3.7/4.7-22 3.8/4.8 H.

Containment Atmosphere Monitoring (CAN)

System H2 Analyzer Radioactive Materials A.

Liquid Effluents B.

Airborne Effluents 3.7/4.7-23a 3.8/4.8-1 3.8/4.8-1 3.8/4.8-3 C.

Radioactive Effluents Dose 3.8/4.8-6 D.

Mechanical Vacuum Pump E.

Miscellaneous Radioactive Materials Sources F.

Solid Radwaste 3.9/4.9 Auxiliary Electrical System 3.8/4.8-6 3.8/4.8-7 3.8/4.8-9 3.9/4.9-1 A.

Auxiliary Electrical Equipment 3.9/4.9-1 B.

Operation with Inoperable Equipment.

3.9/4.9-8 C.

Operation in Cold Shutdown Condition 3.9/4.9-14 D.

Unit 3 Diesel Generators Required for Unit 2 Operation 3.9/4.9-14a BFH Unit 3

Section

~Pa e Ne.

3.10/4.10 Core Alterations A.

Refueling Interlocks B.

Core Monitoring C.

Spent Fuel Pool Water D.

Reactor Building Crane E.

Spent Fuel Cask 3.10/4.10-1 3.10/4.10-1 3.10/4.10-5 3.10/4.10-7 3.10/4.10-8 3.10/4.10-9 F.

Spent Fuel Cask Handling-Refueling Floor.

3.10/4.10-9 3.11/4.11 Fire Protection Systems 3.11/4.11-1 A.

Fire Detection Instrumentation 3.11/4.11-1 B.

Fire Pumps and Water Distribution Mains C.

Spray and/or Sprinkler Systems D.

C02 System 3.11/4.11-2 3.11/4.11-7 3.11/4.11-8 E.

Fire Hose Stations.

3.11/4.11-9 F.

Yard Fire Hydrants and Hose Houses G.

Fire-Rated Assemblies 3.11/4.11-11 3.11/4.11-12 H.

Open Flames, Welding and Spreading Room.

Burning in the Cable 3.11/4.11-13 5.0 Major Design Features 5.0-1 5.1 Site Features

5. 0-1 5.2 Reactor 5.0-1 5.3 Reactor Vessel 5.0-1 5.4 Containment 5.0-1 5.5 Fuel Storage 5.0-1 5e6 Seismic Design
5. 0-2 BFN Unit 3 iv

1.0 DEFINITIONS (

t'd)

Q.

0 eratin C cle Interval between the end of one refueling outage for a particular unit and the end of the next subsequent refueling outage for the same unit.

R.

Refuelin Outa e Refueling outage is the period of time between the shutdown of the unit prior to a refueling and the startup of the unit after that refueling.

For the purpose of designating frequency of testing and surveillance, a refueling outage shall mean a regularly scheduled outage;

however, where such outages occur within 8 months of the completion of the previous refueling outage, the required surveillance testing need not be performed until the next regularly scheduled outage.

S.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel,

sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel.

Movement of source range monitors, intermediate range monitors, traversing in-core probes, or special movable detectors (including undervessel replacement) is not considered a

CORE ALTERATION.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe location.

T.

Reactor Vessel Pressure Unless otherwise indicated, reactor vessel pressures listed in the Technical Specifications are those measured by the reactor vessel steam space detectors.

U.

Thermal Parameters 1.

Minimum Critical Power Ratio MCPR Minimum Critical Power Ratio (MCPR) is the value of the critical power ratio associated with the most limiting assembly in the reactor core.

Critical Power Ratio (CPR) is the ratio of that power in a fuel assembly, which is calculated to cause some point in the assembly to experience boiling transition, to the actual assembly operating power.

2.

Transition Boilin Transition boiling means the boiling regime between nucleate and film boiling.

Transition boiling is the regime in which both nucleate and film boiling occur intermittently with neither type being completely stable.

3.

Core Maximum Fraction of Limitin Power Densit CMFLPD The highest ratio, for all fuel types in the core, of the maximum fuel rod power density (kW/ft) for a given fuel type to the limiting fuel rod power density (kW/ft) for that fuel type.

4, Avera e Planar Linear Heat Generation Rate APLHGR The Average Planar Heat Generation Rate is applicable to a specific planar height and is equal to the sum of the linear heat generation rates for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

BFN Unit 3

1. 0-7

~

~

10 4.10 CORE ALT.

TIONS'IMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.10 CORE ALTERATIONS A licabilit 4.10 CORE ALTERATIONS A licabilit Applies to the fuel handling and core reactivity limitations.

Applies to the periodic testing of those refueling equipment interlocks and instrumentation required during refueling and CORE ALTERATIONS.

Ob ective Ob ective To ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling.

To verify the OPERABILITY of instrumentation and refueling equipment inter-locks required during refueling and CORE ALTERATIONS.

S ecification A.

Refuelin Interlocks S ecification A.

Refuelin Interlocks 1.

The reactor mode switch shall be locked in the REFUEL position during CORE ALTERATIONS.

The required refueling equipment interlocks shall be OPERABLE during in-vessel fuel movement with equipment associated with the interlocks except as specified in 3.10.A.6 and 3.10.A.7 below.

1. Prior to any fuel handling with the head off the
vessel, the following required refueling equipment interlocks shall be functionally tested:

a.

All rods inserted b.

Refueling platform positioned near or over the core c.

Refueling platform main hoist is fuel loaded d.

Fuel grapple is not full up e.

One rod withdrawn BFN Unit 3 3.10/4.10-1

L1'MITING C I

N R

PER ANCE RE UIREMENTS 3.10.A.

Refuelin Interlocks 4.10.A.

Refuelin Interlocks 4.10.A.1 (Continued)

  • f.

Refueling platform frame-mounted hoist is fuel loaded

  • g.

Monorail hoist is fuel loaded

+ h.

Service platform hoist is fuel loaded They shall be tested at weekly intervals thereafter until no longer required.

They shall also be tested following any repair work associated with the interlocks.

  • NOTE:

These interlocks are required to be OPERABLE only when the associated equipment is used for in-vessel fuel movement.

2.

Fuel shall not be loaded into the reactor core unless all control rods are fully inserted.

2.

No additional surveillance required.

3.

The fuel grapple hoist load switch shall be set at g 1,000 lbs.

3.

No additional surveillance required.

4. If the frame-mounted auxiliary hoist, the monorail-mounted auxiliary hoist, or the service platform hoist is to be used for handling fuel with the head off the reactor vessel, the load limit switch on the hoist to be used shall be set at

< 400 lbs.

4.

No additional surveillance required.

BFN Unit 3 3.10/4.10-2

3 '10 4 10 CORE AL'I TIONS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.10.A.

Refuelin Interlocks 4.10.A.

Refuelin Interlocks 5.

Maintenance may be performed on a single control rod or control rod drive without removing the fuel in the contr'ol cell if the following conditions are met:

a.

The requirements of Specification 3.10.A.1 are met, and b.

All control rods diagonally and face adjacent to the maintenance rod are fully inserted and have had their directional control valves electrically disarmed.

5.

Prior to performing control rod or control rod drive maintenance on a control cell without removing fuel assemblies the surveillance require-ments of Specification 4.10.A.1 shall be performed and all rods face adjacent and diagonally adjacent to the maintenance rod shall be electrically disarmed per Specification 3.10.A.5.b.

6.

A maximum of two non-adjacent control rods may be simultaneously withdrawn from the core for the purpose of performing control rod and/or control rod drive maintenance without removing the fuel from the cells provided the following conditions are satisfied:

6.

Prior to performing control rod or control rod drive maintenance on two control cells simultaneously without removing the fuel from the cells, two SROs shall verify that the requirements of Specification 3.10.A.6 are satisfied.

a.

The reactor mode switch shall be locked in the REFUEL position.

The refueling interlock which prevents more than one control rod from being withdrawn may be bypassed for one of the control rods on which maintenance is being performed.

All other required refueling equipment interlocks shall be OPERABLE.

BFH Unit 3 3.10/4.10-3

~

~

4 3.10.A.

4.10.A.

3.10.A.6 (Cont'd) b.

All directional control valves for remaining control rods shall be disarmed electrically except as specified in 3.10.A.7 and sufficient margin to criticality shall be demonstrated.

c.

The two maintenance cells must be separated by more than two control cells in any direction.

d.

An appropriate number of SRMs are available as defined in Specification 3.10.B.

7.

Any number of control rods may be withdrawn or removed from the reactor core providing the following conditions are satisfied:

a.

The reactor mode switch is locked in the REFUEL position.

The refueling interlock which prevents more than one control rod from being withdrawn may be bypassed on a withdrawn control rod after the fuel assemblies in the cell containing (controlled by) that control rod have been removed from the reactor core.

All other required refueling equipment interlocks shall be, OPERABLE.

7.

With the mode selector switch in the REFUEL or SHUTDOWN mode, no more than one control rod may be withdrawn without first removing fuel from the cell except as specified in 4.10.A.6.

Any number of rods may be withdrawn once verified by two licensed operators that the fuel has been removed from each cell.

BFN Unit 3 3.10/4.10-4

E

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4 ERE E

3.10.B.

1.

During CORE ALTERATIONS, except as specified in 3.10.B.2, two SRMs (FLCs) shall be OPERABLE.

For an SRM (FLC) to be considered OPERABLE, the following shall be satisfied:

The SRM shall be inserted to the normal operating level.

(Use of special moveable, dunking type detectors during initial fuel loading and major CORE ALTERATIONS in place of normal detectors is permissible as long as the detector is connected to the normal SRM circuit.)

b.

Verify an OPERABLE SRM (FLC) is located in:

1.

Prior to making any CORE ALTERATIONS, the SRMs (FLCs) shall be functionally tested and checked for neutron response.

2.

Note:

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM (FLC) and no other fuel assemblies in the associated core quadrant.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS, verify that the associated SRM (FLC) is reading Z 3 cps with a signal-to-noise ratio y 3:l.

1.

The fueled region; 2 ~ The quadrant where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region; and 3 ~

Note:

A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region.,

One SRM (FLC) may be used to satisfy more than one of the above.

BFN Unit 3 3elo/4elo-5

~

~

l ll I

3.10 BASES A.

Refuelin Interlocks The refueling interlocks are designed to back up procedural core reactivity controls during refueling operations.

The interlocks prevent an inadvertent criticality during refueling operations when the reactivity potential of the core is being altered.

To minimize the possibility of loading fuel into a cell containing no control rod, it is required that all control rods are fully inserted when fuel is being loaded into the reactor core.

This requirement assures that during refueling the refueling interlocks, as designed, will prevent inadvertent criticality.

The refueling interlocks reinforce operational procedures that prohibit taking the reactor critical under certain situations encountered during refueling operations by restricting the movement of control rods and the operation of refueling equipment.

The refueling interlocks include circuitry which senses the condition of the refueling equipment and the control rods.

Depending on the sensed condition, interlocks are actuated which prevent the movement of the refueling equipment or withdrawal of control rods (rod block).

Circuitry is provided which senses the following conditions.

1.

All rods inserted 2.

Refueling platform positioned near or over the core 3.

Refueling platform main hoist is fuel loaded 4.

Fuel grapple not full up 5.

One rod withdrawn 6.

Refueling platform frame-mounted hoist is fuel loaded 7.

Refueling platform monorail hoist is fuel loaded 8.

Service platform hoist is fuel loaded When the mode switch is in the REFUEL position, interlocks prevent the refueling platform from being moved over the core if a control rod is withdrawn and fuel is on a hoist.

Likewise, if the refueling platform is over the core with fuel on a hoist, control rod motion is blocked by the interlocks.

When the mode switch is in the refuel position only one control rod can be withdrawn.

The refueling interlocks, in combination with core nuclear design and refueling procedures, limit the probability of an inadvertent criticality.

The nuclear characteristics of the core assure that the reactor is The refueling platform frame-mounted, monorail and the service platform fuel-loaded hoist interlocks are required to be OPERABLE only when utilized for in-vessel fuel movements.

BFN Unit 3 3.10/4.10-10

0 l

Ci

3.10 BASES (Cont'ubcritical even when the highest worth control rod is fully withdrawn.

The combination of refueling interlocks for control rods and the refueling platform provide redundant methods of preventing inadvertent criticality even after procedural violations.

The interlocks on hoists provide yet another method of avoiding inadvertent criticality.

Fuel handling is normally conducted with the fuel grapple hoist.

The total load on this hoist when the interlock is required consists of the weight of the fuel grapple and the fuel assembly.

This total is approximately 1,500 lbs, in comparison to the load-trip setting of 1,000 lbs.

Provisions have also been made to allow fuel handling with either of the three auxiliary hoists and still maintain the refueling interlocks.

The 400-lb load-trip setting on these hoists is adequate to trip the interlock when one of the more than 600-lb fuel bundles is being handled.

During certain periods, it is desirable to perform maintenance on two control rods and/or control rod drives at the same time without removing fuel from the cells.

The maintenance is performed with the mode switch in the refuel position to provide the refueling interlocks normally available during refueling operations.

In order to withdraw a second control rod after withdrawal of the first rod, it is necessary to bypass the refueling interlock on the first control rod which prevents more than one control rod from being withdrawn at the same time.

The requirement that an adequate shutdown margin be demonstrated and that all remaining control rods have their directional control valves electrically disarmed ensures that inadvertent criticality cannot occur during this maintenance.

The adequacy of the shutdown margin is verified by demonstrating that at least 0.38 percent ilk shutdown margin is available.

Disarming the directional control valves does not inhibit control rod scram capability.

Specification 3.10.A.7 allows unloading of a significant portion of the reactor core.

This operation is performed with the mode switch in the REFUEL position to provide the refueling interlocks normally available during refueling operations.

In order to.withdraw more than one control rod, it is necessary to bypass the refueling interlock on each withdrawn control rod which prevents more than one control rod from being withdrawn at a time.

The requirement that the fuel assemblies in the cell controlled by the control rod be removed from the reactor core before the interlock can be bypassed ensures that withdrawal of another control rod does not result in inadvertent criticality.

Each control rod provides primary reactivity control for the fuel assemblies in the cell associated with that control rod.

Thus, removal of an entire cell (fuel assemblies plus control rod) results in a lower reactivity potential of the core.

The requirements for SRM OPERABILITY during these CORE ALTERATIONS assure sufficient core monitoring.

BFN Unit 3 3.10/4.10-11

3.1'0 ~ (Cont'd+

3.10.A (Cont'd)

EZEEEHQES 1.

Refueling interlocks (BFNP FSAR Subsection 7.6)

B.

The SRMs are provided to monitor the core during periods of station shutdown and to guide the operator during refueling operations and station startup.

Requiring two OPERABLE SRMs (FLCs) one in and one adjacent to any core quadrant where fuel or control rods are being moved assures adequate monitoring of that quadrant during such alterations.

Each SRM (FLC) is not required to read ~ 3 cps until after four fuel assemblies have been loaded adjacent to the SRM (FLC) if no other fuel assemblies are in the associated core quadrant.

These four locations are adjacent to the SRM dry tube.

When utilizing FLCs, the FLCs will be located such that the required count rate is achieved without exceeding the SRM upscale setpoint.

With four fuel assemblies or fewer loaded around each SRM, even with a control rod withdrawn, the configuration will not be critical.

Under the special condition of removing the full core with all control rods inserted and electrically disarmed, it is permissible to allow SRM count rate to decrease below three counts per second.

All fuel moves during core unloading will reduce reactivity. It is expected that the SRMs will drop below three counts per second before all of the fuel is unloaded.

Since there'ill be no reactivity additions during this

period, the low number of counts will not present a hazard.

When sufficient fuel has been removed to the spent fuel storage pool to drop the SRM count rate below 3 cps, SRMs will no longer be required to be OPERABLE.

Requiring the SRMs to be functionally tested prior to fuel removal assures that the SRMs will be OPERABLE at the start of fuel removal.

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued OPERABILITY until the count rate diminishes due to fuel removal.

Control rods in cells from which all fuel has been removed may be armed electrically and moved for maintenance purposes during full core removal, provided all rods that control fuel are fully inserted and electrically disarmed.

1.

Neutron Monitoring System (BFNP FSAR Subsection 7.5) 2.

Morgan, W. R., "In-Core Neutron Monitoring System for General Electric Boiling Water Reactors,"

General Electric Company, Atomic Power Equipment Department, November 1968, revised April 1969 (APED-5706)

BFN Unit 3 3.10/4.10-12

4

~

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3.10.F S ent Fuel k H dli R fuelin Floor Although single failure protection has been provided in the design of the 125-ton hoist drum shaft, wire ropes, hook and lower block assembly on the reactor building crane, the limiting of liftheight of a spent fuel cask controls the amount of energy available in a dropped cask accident when the cask is over the refueling floor.

An analysis has been made which shows that the floor and support members in the area of cask entry into the decontamination facility can satisfactorily sustain a dropped cask from a height of three feet.

The yoke safety links provide single failure protection for the hook and lower block assembly and limit cask rotation.

Cask rotation is necessary for decontamination and the safety links are removed during decontamination.

4.10 BASES A.

Refuelin Interlocks Complete functional testing of all required refueling equipment interlocks before any refueling outage will provide positive indication that the interlocks operate in the situations for which they were designed.

By loading each hoist with a weight equal to the fuel

assembly, positioning the refueling platform, and withdrawing control
rods, the interlocks can be subjected to valid operational tests.

'here redundancy is provided in the logic circuitry, tests can be performed to assure that each redundant logic element can independently perform its function.

B.

Core Monitorin Requiring the SRMs to be functionally tested prior to any CORE ALTERATION assures that the SRMs will be OPERABLE at the start of that alteration.

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued OPERABILITY.

REFERENCES 1.

Fuel Pool Cooling and Cleanup System (BFNP FSAR Subsection 10.5) 2.

Spent Fuel Storage (BFNP FSAR Subsection 10.3)

BFN Unit 3 3.10/4.10-14

6.2.2 (Cont.)

d.

Two licensed reactor operators shall be in the control room during any cold startups, while shutting down the reactor, and during recovery from unit trip.

In addition, a person holding a senior operator license shall be in the control room for that unit whenever it is in an operational mode other than cold shutdown or refueling.

e.

A Health Physics Technician* shall be present at the facility at all times when there is fuel in the reactor.

f.

Either a licensed SRO or licensed SRO limited to fuel handling who has no concurrent responsibilities during this operation shall be present during fuel handling and shall directly supervise all CORE ALTERATIONS.

g.

A site fire brigade of at least five members shall be maintained onsite at all times.*

The fire brigade shall not include the Shift Engineer and the other members of the minimum shift crew necessary for safe shutdown of the unit, nor any personnel required for other essential functions during a fire emergency.

  • The Health Physics Technician and fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected
absence, provided immediate action is taken to fillthe required positions.

BFN Unit 3 6.0-3

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

UNITS 1, 2, AND 3 (TVABFN TS 324)

REASON FOR THE CHANGE Changes to Technical Specification (TS) Section 3.10.A/4.10.A are proposed to allow for the testing of only those load sensing refueling interlocks which willbe used for fuel handling.

Under the current TSs, surveillance testing is performed on all hoist interlocks including those associated with equipment (e.g. refueling platform frame-mounted, refueling platform monorail, and service platform hoists) which are seldom utilized during refueling activities.

The proposed TS changes to TS Section 3.10.B/4.10.B willallow BFN to utilize the refueling methods recommended by GE and EPRI in NSAC - 164L, "Guidelines for BWR Reactivity Control During Refueling," April 1992.

These methods include core reload sequences which bring all four Source Range Monitors (SRMs) on-scale as soon as practicable while minimizing the use of Fuel Loading Chambers (FLCs).

Additionally, the proposed change adopts the new BWR Standard Technical Specification (Draft NUREG-1433) language for the definition of CORE ALTERATIONand Administrative Control 6.2.2.f.

DESCRIPTION OF THE PROPOSED CHANGE 1.

Definition 1.S, CORE ALTERATION, is deleted in its entirety and replaced with the following for all three units:

ORE ALTERATI N - CORE ALTERATIONshall be the movement of any fuel,

sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel.

Movement of source range monitors, intermediate range monitors, traversing in-core probes, or special movable detectors ( including undervessel replacement ) is not considered a CORE ALTERATION. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe location.

2.

Limiting Condition for Operation (LCO) 3.10.A.1 currently reads as follows for all three units:

The reactor mode switch shall be locked in the REFUEL position during core alterations and the refueling interlocks shall be OPERABLE except as specified in 3.10.A.6 and 3.10.A.7 below.

Page 2 of 9 This change revises this LCO as follows for all three units:

The reactor mode switch shall be locked in the REFUEL position during CORE ALTERATIONS. The required refueling equipment interlocks shall be OPERABLE during in-vessel fuel movement with equipment associated with the interlocks except as specified in 3.10.A.6 and 3.10.'A.7 below.

3.

TS ~Ibiii<<

f S

ill w

3 (SR34.13 4

Rlk f

all three units:

Applies to the periodic testing of those interlocks and instrumentation used during refueling and core alterations.

The proposed change revises this statement as follows for all three units:

Applies to the periodic testing of those refueling equipment interlocks and instrumentation required during refueling and CORE ALTERATIONS.

4.

The Qhective for SR 4.10 reads as follows for all three units:

To verify the operability of instrumentation and interlocks used in refueling and core alterations.

The proposed change revises this statement as follows for all three units:

To verify the operability of instrumentation and refueling equipment interlocks required during refueling and CORE ALTERATIONS.

5.

This change proposes the deletion of the existing SR 4.10.A.1 in its entirety and replaces it with the following for all three units:

Prior to any fuel handling with the head off the vessel, the following required refueling equipment interlocks shall be functionally tested:

a. Allrods inserted
b. Refueling platform positioned near or over the core c.

Refueling platform main hoist is fuel loaded

d. Fuel grapple is not full up e.

One rod withdrawn Page 3 of 9

f. Refueling platform frame-mounted hoist is fuel loaded g.

Monorail hoist is fuel loaded h.

Service platform hoist is fuel loaded They shall,,be tested at weekly intervals thereafter until no longer required.

They shall also be tested following any repair work associated with the interlocks.

  • Note:

These interlocks are required to be OPERABLE only when the associated refueling equipment is used for in-vessel fuel movement.

6.

The last sentence of LCOs 3.10.A.6.a and 3.10.A.7.a reads as follows for all three units:

...Allother refueling interlocks shall be OPERABLE.

The proposed change revises this text as follows for all three units:

...Allother required refueling equipment interlocks shall be OPERABLE.

7.

LCO 3.10.B.1 reads, in part, as follows for all three units:

During core alterations, except as specified in 3.10.B.2, two SRMs (FLCs) shall be OPERABLE, one in and one adjacent to any quadrant where fuel or control rods are being moved.

For an SRM (FLC) to be considered OPERABLE, the following shall be satisfied:...

The proposed change reads as follows for all three units:

During core alterations, except as specified in 3.10.B,2, two SRMs (FLCs) shall be OPERABLE. For an SRM (FLC) to be considered OPERABLE, the following shall be satisfied:...

Page 4 of 9 8.

LCO 3.10.B.l.b is deleted in its entirety and replaced with the following for all three units:

Verify an OPERABLE SRM (FLC) is located in:

1 ~ The fueled region;

2. The quadrant where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region; and
3. A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM (FLC) is included in the fueled region.

Note: One SRM (FLC) may be used to satisfy more than one of the above.

9.

SR 4.10.B presently reads for all three units:

Prior to making any alterations to the core, the SRMs (FLCs) shall be functionally tested and checked for neutron response.

Thereafter, while required to be OPERABLE, the SRMs willbe checked daily for response.

The proposed change renumbers this SR 4.10.B.1 and revises the text as follows for all three units:

V Prior to making any CORE ALTERATIONS, the SRMs (FLCs) shall be functionally tested and checked for neutron response.

10. The following new SR 4.10.B.2 is proposed for all three units:

Note:

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM (FLC) and no other fuel assemblies in the associated core quadrant.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS, verify that the associated SRM (FLC) is reading 2 3 cps with a signal-to-noise ratio 2 3:1.

11. The existing Bases 3.10.A reads in part:

...Circuitry is provided which senses the following conditions.

1. Allrods inserted 2.

Refueling platform positioned near or over the core Page 5 of 9 3.

Refueling platform hoists are fuel-loaded (fuel grapple, frame mounted hoist, monorail mounted hoist).

4.

Fuel grapple not full up 5.

Service platform hoist fuel-loaded 6.

One rod withdrawn When the mode switch is...

..The combination of refueling interlocks...

The proposed revision to Bases 3.10.A reads as follows for all three units:

...Circuitry is provided which senses the following conditions.

1. Allrods inserted 2.

Refueling platform positioned near or over the core 3.

Refueling platform main hoist is fuel-loaded 4.

Fuel grapple is not full up 5.

One rod withdrawn 6.

Refueling platform frame mounted hoist is fuel loaded 7.

Refueling platform monorail hoist is fuel loaded 8.

Service platform hoist is fuel-loaded When the mode switch is...

..The combination of refueling interlocks...

The refueling platform frame-mounted, monorail and the service platform fuel-loaded hoist interlocks are required to be OPERABLE only when utilized for in-vessel fuel movements.

Page 6 of 9

12. The first paragraph of Bases 3.10.B reads as follows for all three units:

The SRMs are provided to monitor the core during periods of station shutdown and to guide the operator during refueling operations and station startup.

Requiring two operable SRMs (FLCs) one in and one adjacent to any core quadrant where fuel or control rods are being moved assures adequate monitoring of that quadrant during such alterations.

The requirement of three counts per second provides assurance that neutron flux is being monitored and ensures that startup is conducted only ifthe source range flux level is above the minimum assumed in the control rod drop accident.

During a full core reload, the fuel willbe loaded in control cells that are contiguous to previously loaded control cells.

This provides coupling of the loaded fuel matrix which is being monitored by the SRMs (FLCs).

The following change to this paragraph is proposed for all three units:

The SRMs are provided to monitor the core during periods of station shutdown and to guide the operator during refueling operations and station startup.

Requiring two OPERABLE SRMs (FLCs) one in and one adjacent to any core quadrant where fuel or control rods are being moved assures adequate monitoring of that quadrant during such alterations.

Each SRM (FLC) is not required to read > 3 cps until after four fuel assemblies have been loaded adjacent to the SRM (FLC) ifno other fuel assemblies are in the associated core quadrant.

These four locations are adjacent to the SRM dry tube.

When utilizing FLCs, the FLCs willbe located such that the required count rate is achieved without exceeding the SRM upscale setpoint.

With four fuel assemblies or fewer loaded around each SRM, even with a control rod withdrawn, the configuration will not be critical.

13. The next to last sentence of Bases 3.10,B reads as follows for all three units:

The daily response check of the SRMs ensures their continued operability until the count rate diminishes due to fuel removal.

The proposed change to this sentence reads as follows for all three units:

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued operability until the count rate diminishes due to fuel removal.

14. The first sentence of Bases 4.10.A, Refueling Interlocks, is revised to read as follows for all three units:

Complete functional testing of all required refueling equipment interlocks before any refueling outage willprovide positive indication that the interlocks operate in the situations for which they were designed.

Page 7 of 9

15. The last sentence of Bases 4.10.B, Core Monitoring, presently reads for all three units:

The daily response check of the SRMs ensures their continued operability.

The proposed change reads as follows for all three units:

The once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verification of the SRM count rate and signal-to-noise ratio ensures their continued operability.

16. The existing Administrative Control 6.2.2.f is deleted in its entirety and replaced with the following:

Either a licensed SRO or licensed SRO limited to fuel handling who has no concurrent responsibilities during this operation shall be present during fuel handling and shall directly supervise all CORE ALTERATIONS.

JUSTIFICATION FOR THE PROPOSED CHANGES 1.

s ific tion For The Pro o ed han e To T 1.A/4.10.A During a refueling operation, the reactor vessel head is removed, allowing direct access to the core.

Refueling operations include the removal of the reactor vessel upper internals and the movement of spent and fresh fuel assemblies between the core and the fuel storage pool.

The service platform, refueling platform, and the equipment handling hoists on the platforms are used to accomplish the refueling task.

The refueling interlocks reinforce operational procedures that prohibit making the reactor critical due to refueling errors by restricting the movement of control rods and the operation of refueling equipment.

The frame mounted, monorail mounted and the service platform hoists are equipped with load cells which input "hoist loaded" signals into the refueling interlocks circuitry. Ifthese hoists are used to perform fuel moves, then they must pass the required "hoist loaded" interlock surveillance testing prior to use.

When not being used, these hoists do not provide useful inputs to the interlock circuitry. The proposed TS change clarifies the refueling interlock LCOs and SRs to allow for testing only the load sensing interlocks associated with the particular hoist(s) which willbe used for fuel handling.

These changes willnot require any physical plant modifications.

The proposed

changes, while eliminating unnecessary testing and maintenance activities, ensure the required refueling interlocks are operable to perform their intended safety function.

Page 8 of 9 ification For The ro o ed h n e To T 1 B410B In January of 1989, BFN Unit 2 began a full core reload with the TSs existing at that time. After loading 74 fuel assemblies the process was stopped due to concerns about adequate neutron monitoring.

The loading was continued with the use of FLCs and by changing the location of one SRM.

Subsequently, an industry survey was conducted and it was determined that many different approaches were used by utilities when conducting a full core reload.

An effort was begun by EPRI to determine which methods are acceptable and to develop a recommended approach.

In the interim BFN submitted a TS amendment request to correct the deficiencies in the existing BFN TSs.

These changes were intended to be temporary and were very conservative in nature.

BFN did not intend to conduct a core loading with these TSs.

However, it became desirable for BFN to off load and reload the core due to certain planned plant modifications.

Since EPRI had not completed its report at this time, BFN was compelled to use the TSs as they currently exist.

Fuel loading was again conducted with the use of FLCs.

This resulted in several delays and many additional plant activities on and offthe refueling floor.

In Aprilof 1992, EPRI Report NSAC-164L, "Guidelines For BWR Reactivity Control During Refueling" was issued.

In this report, it is recommended that fuel loading sequences be used which bring all four SRMs on-scale and monitoring the fueled region as soon as practicable.

The proposed changes to TS 3.10.B/4.10.B will accomplish this objective while minimizing the use of FLCs.

Problems associated with use of FLCs include the possibility of loose parts, decreased detector reliability, increased detector noise, and complications resulting from the additional refueling bridge movements required to position/reposition FLCs.

Inadvertent criticality concerns and events involving positive reactivity insertions have been evaluated in the BFN Updated Final Safety Analysis Report (Chapter 14).

These events include continuous control rod removal during refueling and a fuel assembly insertion error during refueling.

The evaluation of these events does not take credit for the function of the Source Range Monitors.

Inadvertent criticality is precluded in these events by the core and control rod design and by the presence of the refueling interlocks.

During any core alterations, and especially during core loading, it is desirable to monitor the neutron flux levels as the alterations are being made.

This provides reasonable assurance that even in the highly unlikely event of multiple errors, that any approach to criticality would be detected in time to suspend the operation.

The minimum count rate requirement accomplishes two functions in support of this safety objective: (1) it assures the presence of some neutron flux in the core, and (2) it demonstrates that the analog portion of the SRM channel is operable.

Page 9 of 9 The proposed change satisfies these objectives.

The TS willrequire that two SRMs be demonstrated operable prior to the first fuel assembly being loaded, even though no count rate requirements are in effect.

Proposed SR 4.10.B.2 adds signal-to-noise ratio criteria to the SRM operability requirements and requires that after the first four assemblies are loaded in any quadrant, the SRM in that quadrant must indicate a 3.0 cps before any additional fuel can be loaded.

This results in the verification that some neutron flux is present in the core and provides a continuous demonstration that the analog portion of the SRM channel is functioning.

Analysis has demonstrated that the core willremain subcritical with four fuel assemblies or less loaded adjacent to each SRM.

The proposed revision to LCO 3.10.B.1.b provides assurance that core reactivity additions are adequately monitored by operable SRMs.

The use of FLCs is also permitted when necessary.

The proposed changes to TS Section 3.10.B/4.10.B are consistent with the new BWR Standard Technical Specifications contained in draft NUREG-1433.

The revised definition of CORE ALTERATIONspecifies the types of incore instrumentation handling which are not considered CORE ALTERATIONS. This change is consistent with the draft NUREG-1433 definition. The revised Administrative Control 6.2.2.f also adopts the draft NUREG-1433 language.

The revised text willallow the responsible SRO to supervise non-fuel handling core alterations from the most appropriate location in the plant.

(For instance, control rod exercising may be more appropriately supervised from the main control room than from the refuel floor.)

0

ENCLOSURE 3 PROPOSED NO SIGNIFICANTHAZARDS CONSIDERATIONS DETERMINATION BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (TVABFN TS 324)

DESCRIPTION OF THE PROPOSED TECHNICALSPECIFICATION CHANGE The proposed amendment would revise the BFN Units 1, 2, and 3 Technical Specifications (TS) 3.10.A/4.10.A, Refueling Interlocks, to no longer require the surveillance testing of load sensing refueling interlocks associated with refueling equipment which willnot be used during refueling operations.

The proposed amendment also revises TS 3.10.B/4.10.B, Core Monitoring, to eliminate the requirement for a minimum Source Range Monitor (SRM) count rate when there are four or less fuel assemblies in a quadrant while they are positioned adjacent to the SRM in that quadrant.

Additionally the proposed amendment adopts language similar to the new BWR Standard Technical Specification (Draft NUREG-1433) language for Administrative Control 6.2.2.f and the definition for CORE ALTERATIONS.

BASES FOR PROPOSED NO SIGNIFICANTHAZARDS CONSIDERATION DETERMINATION NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.91(c).

A proposed amendment to an operating license involves no significant hazards considerations ifoperation 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.

The proposed TS amendment is judged to involve no significant hazards considerations based on the following:

1. The proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.

Inadvertent criticality concerns and events involving positive reactivity insertions have been evaluated in the BFN Updated Final Safety Analysis Report (Chapter 14).

These events include continuous control rod removal during refueling and a fuel assembly insertion error during refueling.

The evaluation of these events does not take credit for the function of the Source Range Monitors.

Inadvertent criticality is precluded in these events by the core and control rod design and by the presence of the refueling interlocks.

The proposed change to the refueling interlock Surveillance Requirement eliminates the testing of only the equipment which is not being utilized. The refueling interlocks

4 J

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Page 2 of 2 associated with the equipment which willbe used for refueling'must be operable.

Therefore, the Chapter 14 assumptions remain valid.

Based on the above arguments, no

'significant increase in the probability or consequences of any accident previously evaluated willresult from this license amendment.

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

The proposed amendments do not introduce any new or different modes of refueling operation nor do they contribute to the malfunction of any other equipment.

Therefore, the proposed amendments willnot create the possibility of a new or different kind of accident from any accident previously evaluated.

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

It has been demonstrated by analysis that a criticality cannot occur as a result of loading four fuel assemblies around each Source Range Monitor and no other fuel assemblies in the associated core quadrant.

Prior to proceeding with refueling in each quadrant, the associated Source Range Monitor must be indicating the required count rate, thereby ensuring adequate flux monitoring.

Operation of the facility in accordance with the proposed amendment will continue to ensure that the required refueling interlocks are in place to preclude any inadvertent criticality due a refueling error.

Only the refueling equipment which is not being used for fuel handling willnot be tested.

Proper function of the equipment interlocks in use willcontinue to be verified by surveillance testing.

Therefore, no significant reduction in the margin of safety willresult from the proposed amendment.

CONCLUSION TVA has evaluated the proposed amendment described above against the criteria given in 10 CFR 50.92(c) in accordance with the requirements of 10 CFR 50.91(a)(1).

This evaluation has determined that the proposed amendment will~no (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility for a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

Thus, TVA has concluded that the proposed amendment does not involve a significant hazards consideration.

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