ML18036B151

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Proposed Tech Specs,Reflecting Decrease in Reporting Frequency for Radiological Effluent Rept from Semiannual to Annual,Per Guidance in GL 89-01
ML18036B151
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 01/29/1993
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18036B150 List:
References
GL-89-01, GL-89-1, NUDOCS 9302110008
Download: ML18036B151 (101)
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Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNITS 1g 2p AND 3 (TVA BFN TECHNICAL SPECIFICATION 301 SUPPLEMENT 1) cygO2iioooe OgggP289'3Qi2~

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PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 1 (TVA BFN TECHNICAL SPECIFICATION 301 SUPPLEMENT 1)

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~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ 6~0 1 6.2.1 Offsite and Onsite Organizations......................... 6.0-1 6.2.2 P lant Staff.............................................. 6.0-2

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~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~0 5 6.5.1 Plant Operations Review Committee (PORC)................. 6.0-5 6.5.2 Nuclear Safety Review Board (NSRB)....................... 6.0-11 6.5.3 Technical Review and Approval of Procedures.............. 6.0-17 s.o-zs 6.0-19 t

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6o0 20 6.8.1 Procedures........................-..................-..- 6.0-20 D rills 11t 6.0-21

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. 6.8.3 Radiation Control'rocedures............................. 6.0-22 6.8.4 Radioactive Effluent Controls/Radiological Environmental Monitoring Programs..................... 6.0-23 6.0-24 6.9.1 R outine Reports.......................................... 6.0-24 Startup Reports.......................................... 6.0-24 Annual Operating Report.................................. 6.0-25 Monthly Operating Report................................. 6.0-26 Reportable Events........................................ 6.0-26 Annual Radiological Environmental Operating Report.......

S ource Tests............................................. 6.0-26 The Annual Radioactive Effluent Release Report........... 6.0-26a 6.9.2 S pecxal Reports.......................................... 6.0-27

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1.0 (Cont'd) t A functional test is the manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances (e.g., the manual start of a core spray pump to verify that it runs and that it pumps the required volume of water).

Qh~~wu The reactor is in a shutdown condition when the reactor

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mode switch is in the shutdown mode position and no core alterations are being performed.

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  • the actions of which are essential to a safety action required in response to accidents.

Z0 R conditions specified in Section 50.73 to 10 CFR Part 50.

BB. Qf t ~glgQ~QQQ~ Shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.5 and 6.9.1.7.

CC. The controlled process of discharging air or gas from the primary containment to maintain temperature, pressure, humidity, concentration, or other operating condition in such a manner that replacement air or gas is required to purify the containment.

DD. ~~am Shall contain the current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61 and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.

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FF. )(pent' The controlled process of discharging air or gas from the primary containment to maintain temperature, pressure, humidity, concentration, or other operating condition in such a manner that replacement air or gas is not provided or required. Vent, used in system names, does not imply a venting process.

BFN 1.0-10 Unit 1

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1. The explosive gas 1. Each of the explosive monitoring instruments gas monitoring listed in Table 3.2.K shall instruments shall be be OPERABLE with the applica- demonstrated OPERABLE bility as shown in Tables by performance of 3.2.K/4.2.K. Alarm/trip tests in accordance setpoints will be set to with Table 4.2.K.

ensure that the limits of Specification 3.8.B.9 are not exceeded.

2. The action required when the number of OPERABLE channels is less than the Minimum Channels OPERABLE requirement is specified in the notes for Table 3.2.K. Exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, prepare and submit a special report to the commission pursuant to

,Specification 6.9.1.4 to explain why the inoperability was not corrected in a timely manner.

3. (Deleted)
4. (Deleted)
5. The provisions of Specification 1.0.C are not applicable.

BFN 3.2/4.2-6 Unit 1

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3.2 g~g (Cont'd)

The APRM rod block function is flow biased and prevents a significant reduction in MCPR, especially during operation at reduced flow. The APRM provides gross core protection; i.e., limits the gross core power from withdrawal of control rods in the normal withdrawal 'ncrease sequence. The trips are set so that MCPR is maintained greater than 1.07.

The RBM rod block function provides local protection of the core; i.e.,

the prevention of critical power in a local region of the core, for a single rod withdrawal error from a limiting control rod pattern.

If the IRM channels are in the worst condition of allowed bypass, the sealing arrangement is such that for unbypassed IRM channels, a rod block signal is generated before the detected neutrons flux has increased by more than a factor of 10.

A downscale indication is an indication the instrument has failed or the instrument is not sensitive enough. In either case the instrument will not respond to changes in control rod motion and thus, control rod motion is prevented.

The refueling interlocks also operate one logic channel, and are required for safety only when the mode switch is in the refueling position.

For effective emergency core cooling for small pipe breaks, the HPCI system must function since reactor pressure does not decrease rapid enough to allow either core spray or LPCI to operate in time. The automatic pressure relief function is provided as a backup to the HPCI in the event the HPCI does not operate. The arrangement of the tripping contacts is such as to provide this function when necessary and minimize spurious operation. The trip settings given in the specification are adequate to assure the above criteria are met. The specification preserves the effectiveness of the system during periods of maintenance, testing, or calibration, and also minimizes the risk of inadvertent operation; i.e., only one instrument channel out of service.

Four radiation monitors are provided for each unit which initiate Primary Containment Isolation (Group 6 isolation valves) Reactor Building Isolation and operation of the Standby Gas Treatment System. These instrument channels monitor the radiation in the reactor zone ventilation exhaust ducts and in the refueling zone.

BFN 3.2/4.2-68 Unit 1

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3.2 gal+ (Cont'd)

The OPERABILITY of the meteorological instrumentation ensures that sufficient meteorological data is available for estimating potential radiation dose to the public as a result of routine or accidental relea'se of radioactive materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public.

The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the seismic response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for Browns Ferry Nuclear Plant and to determine whether the plant can continue to be operated safely. The instrumentation provided is consistent with specific portions of the recommendations of Regulatory Guide 1.12 "Instrumentation for Earthquakes."

The instrumentation in Tables 3.2.K/4.2.K monitors the concentration of potentially explosive gas mixtures in the offgas holdup system. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 63 of Appendix A to 10 CFR Part 50.

ATWS/RPT, Anticipated Transients without Scram/Recirculation Pump Trip system provides a means of limiting the consequences of the unlikely occurrence of a failure to scram during an ATWS event. The response of the plant to this postulated event (ATWS/RPT) follows the BWR Owners Group Report by General Electric NEDE-31096-P-A and the accompanying NRC Staff Safety Evaluation Report.

ATWS/RPT utilizes the engineered safety feature (ESF) master/slave analog trip units (ATU) which consists of four level and four pressure channels total. The initiating logic consists of two independent trip systems each consisting of two reactor dome high pressure channels and two reactor vessel low level channels. A coincident trip of either two low levels or two high pressures in the same trip system causes initiation of ATWS/RPT. This signal from either trip system opens one of two EOC BFN 3.2/4.2-70 Unit 1

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The conclusions to be drawn are these:

1. A 1-out-of-n system may be treated the same as a single channel of choosing a -test interval; and in'erms
2. more than one channel should not be bypassed for testing at any one time.

The radiation monitors in the refueling area ventilation duct which initiate building isolation and standby gas treatment operation the are arranged in two 1-out-of-2 logic systems. The bases given for rod blocks apply here also and were used to arrive at the functional testing frequency. Based on experience with instruments of similar design, a testing interval of once every three months has been found adequate.

The automatic pressure relief instrumentation can be considered to be a 1-out-of-2 logic system and the discussion above applies also.

The RCIC and HPCI system logic tests required by Table 4.2.B contain provisions to demonstrate that these systems will automatically restart on a RPV low water level signal received subsequent to a RPV high water level trip.

BFN 3.2/4.2-73 Unit 1

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3.8.A. 4.8.A.

4. (Deleted) 4. (Deleted)
5. The maximum activity to be 5. (Deleted) contained in one liquid radwaste tank or temporary storage tank that can be discharged directly to the environs shall not exceed 10 curies excluding tritium and dissolved/entrained noble gas.
6. With radioactive liquid 6. The quantity of waste exceeding 3.8.A.5 radioactive material limits, wi.thout delay contained in any suspend all additions of outside liquid radioactive material to the radwaste storage tank and within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, tanks shall be reduce the tank contents to determined to be within the limit. Events within the above leading to this condition limit by analyzing a must be reported in the next representative Annual Radioactive Effluent sample of the tank's Release Report (Section 5.2 contents at least of the'DCM). once per 7 days when radioactive materials are being added to the tank.

BFN 3.8/4.8-2 Uni.t 1

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e. Review of all proposed changes to the Technical Specifications.
f. Review of safety evaluation for proposed tests or experiments to be completed under the provisions of 10 CFR 50.59.
g. Review proposed changes to the Offsite Dose Calculation Manual and Process Control Program.
h. Review adequacy of the Process Control Program and Offsite Dose Calculation Manual at least once every 24 months.
i. Review changes to the radwaste treatment systems.
j. Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendation, and disposition of the corrective action to prevent recurrence to the Senior Vice President, Nuclear Power, and to the Nuclear Safety Review Board.
k. Review of all safety evaluations for modifications to structures, systems or components that affect nuclear safety to verify that such actions did not constitute an unreviewed safety question as defined in 10 CFR 50.59, or requires a change to these Technical Specifications.

BFN 6.0-8 Unit 1

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for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiological Work Permit.

6.8.3.2 Each high'adiation area in which the intensity of radiation is greater than 1,000 mrem/hr shall be subject to the provisions of (1) above'and, in addition, access to the source and/or area shall be secured by lock(s). The key(s) shall be under the administrative control of the shift engineer. In the case of a high radiation area established for a period of 30 days or less, direct surveillance to prevent unauthorized entry may be substituted for permanent access control.

  • Health Physics personnel, or personnel escorted by Health Physics personnel, in accordance with approved emergency 0 procedures, shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

6.8.4 RADIOACTIVE EFFLUENT CONTROLS/RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMS The following programs shall be established, implemented, and maintained.

BFN 6.0-23 Unit 1

6.8.4.1 RADIOACTIVE EFFLUENT CONTROLS PROGRAM A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on the OPERABILITY of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM.

0 b. Limitations on 'the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 CFR Part 20, Appendix B, Table II, Column 2.

c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.106 and with the methodology and parameters in the ODCM.
d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from each unit to unrestricted areas conforming to Appendix I to 10 CFR Part 50.
e. Determination of cumulative and projected dose contributions from radioactive effluents for the current BFN 6.0-23a Unit 1

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calendar quarter and current year in accordance with the methodology and parameters in the ODCM at least every '31 days.

f. Limitations on the OPERABILITY and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50.
g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the site boundary conforming to the doses associated with 10 CFR Part 20, Appendix B, Table II, Column l.
h. Limitations of the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50.

Limitations on the annual and quarterly doses to a member of the public from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50.

j. Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

BFN 6.0-23b Unit 1

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6.9.1.7 THE ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year of operation shall be submitted by April 1, of each year. The report shall include summaries of the quantitities of radioactive liquid and gaseous effluents and solid waste released from the unit. A single submittal may be made for a multi-unit station. The submittal should combine those sections that are common to all units at the station', however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit. The material provided shall be (1) consistent with the objectives outlined in the ODOM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

BFN 6.0-26a Unit 1

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6.11 L G Changes to the PCP:

1. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.1.r. This documentation shall contain:
a. Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and
b. A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations.
2. Shall become effective after review and acceptance by the PORC and the approval of the Plant Nanager.

6.12 Changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.1.r. This documentation shall contain:
a. Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change.

BFN 6.0-32 Unit 1

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b. A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part '50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.
2. Shall become effective after review and acceptance by the PORC and the approval of the Plant Manager.
3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month/year) the change was implemented.

6.13 (Deleted)

BFN 6.0-33 Unit 1

PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 2 (TVA BFN TECHNICAL SPECIFICATION 301 SUPPLEMENT 1)

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~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~0 1 6.2.1 Offsite and Onsite Organizations... ..................... ~ 6.0-1 6.2.2 P lant Staff.............................................. 6.0-2

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6o0 5 Zggg o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-5

~ ~ ~ ~ ~ l ~ 0 ~ ~ ~ 0 4 ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-5 6.5.1 Plant Operations Review Committee (PORC)................. 6.0-5 6.5.2 Nuclear Safety Review Board (NSRB)....................... 6.0-11 6.5.3 Technical Review and Approval of Procedures.............. 6.0-17 6.0-18 6.0-19 t

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6o0 20 6.8.1 Procedures ~ ~ 0 ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-20 6.8.2 D rills ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-21 6.8.3 Radiation Control Procedures............................. 6.0-22 6.8.4 Radioactive Effluent Controls/Radiological Environmental Monitoring Programs..................... 6.0-23 6.8.5 P rograms ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-23c

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ s ~ 6 ~0 24 6.9.1 R t outre Reports.......................................... 6.0-24 Startup Reports.......................................... 6.0-24 Annual Operating Report.................................. 6.0-25 Monthly Operating Report................................. 6.0-26 Reportable Events........................................ 6.0-26 Annual Radiological Environmental Operating Report....... 6.0-26 S ource Tests............................................. 6.0-26a The Annual Radioactive Effluent Release Report........... 6.0-26a 6.9.2 S pecxal Reports.......................................... 6.0-27 D ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~ 0 29 G ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-32

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~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-32 6.0-33 BFN Unit 2

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1.0 I ~ (Cont'd) initiation of a system, functions within design spray pump to verify volume of water).

that subsystem, tolerances it runs or component to verify that (e.g., the manual start of a core and that it pumps the required it Qg~i~ The reactor is in a shutdown condition when the reactor mode switch is in the shutdown mode position and no core alterations are being performed.

Y. I actions of which are essential to a safety action required in response

'll to accidents.

Z. E~t~~~ggg A reportable event shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.

BB. III and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.5 and 6.9.1.7.

CC.

from the primary containment to maintain temperature, pressure, humidity, concentration, or other operating condition in such a manner that replacement air or gas is required to purify the containment.

DD. Shall contain the current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61 and 71, State regqlations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.

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FF. ~i~t'gg The controlled process of discharging air or gas from the primary containment to maintain temperature, pressure, humidity, concentration, or other operating condition in such a manner that replacement air or gas is not provided or required. Vent, used in system names, does not imply a venting process.

BFN Unit 2

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1. The explosive gas monitoring 1. Each of the explosive instruments listed in gas monitoring Table 3.2.K shall be OPERABLE instruments shall be with the applicability as demonstrated OPERABLE shown in Tables 3.2.K/4.2.K. by performance of tests Alarm/trip setpoints will be in accordance with set to ensure that the limits Table 4.2.K.

of Specification 3.8.B.9 are not exceeded.

2., The action required when the number, of OPERABLE channels is less than the Minimum Channels OPERABLE requirement is specified in the notes for Table 3.2.K. Exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, prepare and submit a special report to the commission pursuant to Specification 6.9.1.4 to explain why the inoperability was not corrected in a timely manner.

3. (Deleted)
4. (Deleted)
5. The provisions of Specification 1.0.C are not applicable.

BFN 3.2/4.2-6 Unit 2

3.2 3~+ (Cont'd) adequate to assure the above criteria are met. The specification preserves the effectiveness of the system during periods of maintenance, testing, or calibration, and also minimizes the risk of inadverten't operation; i.e., only one instrument channel out of service.

Four radiation monitors are provided for each unit which initiate Primary Containment Isolation (Group 6 isolation valves) Reactor Building Isolation and operation of the Standby Gas Treatment System. These instrument channels monitor the radiation in the reactor zone ventilation exhaust ducts and in the refueling zone.

Trip setting of 100 mr/hr for the monitors in the refueling zone are based upon initiating normal ventilation isolation and SGTS operation so that none of the activity released during the refueling accident leaves the Reactor Building via the normal ventilation path but rather all the activity is processed by the SGTS.

Flow integrators and sump fill rate and pump out rate timers are used to system whereby the time interval to determine leakage in the drywell. A fill a known volume will be utilized to provide a backup. An air sampling system is also provided to detect leakage inside the primary containment (See Table 3.2.E).

For each parameter monitored, as listed in Table 3.2.F, there are two channels of instrumentation except as noted. By comparing readings between the two channels, a near continuous surveillance of instrument performance is available. Any deviation in readings will initiate an early recalibration, thereby maintaining the quality of the instrument readings.

Instrumentation is provided for isolating the control room and initiating a pressurizing system that processes outside air before supplying it to the control room. An accident signal that isolates primary containment will also automatically isolate the control room and initiate the emergency pressurization system. In addition, there are radiation monitors in the normal ventilation system that will isolate the control room and initiate the emergency pressurization system. Activity required to cause automatic actuation is about one mRem/hr.

Because of the constant surveillance and control exercised by TVA over the Tennessee Valley, flood levels of large magnitudes can be predicted in BFN 3.2/4.2-69 Unit 2

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3.2 g~Q (Cont'd) advance of their actual occurrence. In all cases, full advantage will be taken of advance warning to take appropriate action whenever reservoir levels above normal pool are predicted. Therefore, during flood conditions, the plant will be permitted to operate until water begins to run across the top of the pumping station at elevation 565. Seismically qualified, redundant level switches each powered from a separate division of power are provided at the pumping station to give main control room indication of this condition. At that time an orderly shutdown of the plant will be initiated, although surges even to a depth of several feet over the pumping station deck will not cause the loss of the main condenser circulating water pumps.

The OPERABILITY of the meteorological instrumentation ensures that sufficient meteorological data is available for estimating potential radiation dose to the public as a result of routine or accidental release of radioactive materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public.

The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the seismic response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for Browns Ferry Nuclear Plant and to determine whether the plant can continue to be operated safely. The instrumentation provided is consistent with specific portions of the recommendations of Regulatory Guide 1.12 "Instrumentation for Earthquakes."

The instrumentation in Tables 3.2.K/4.2.K monitors the concentration of potentially explosive gas mixtures in the offgas holdup system. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 63 of Appendix A to 10 CFR Part 50.

BFN 3.2/4.2-70 Unit 2

4.2 g~E (Cont'd)

If two similar channels are used in a 1-out-of-2 configuration, the test interval for minimum unavailability changes as a function of the rules for testing. The simplest case is to test each one independent of the other.

In this case, there is assumed to be a finite probability that both may be bypassed at one time. This case is shown by Curve No. 2. Note that the unavailability is lower as expected for a redundant system and the minimum occurs at the same test interval. Thus, if the two channels are tested independently, the equation above yields the test interval for minimum unavailability.

A more usual case is that the testing is not done independently. lf both channels are bypassed and tested at the same time, the result is shown in Curve No. 3. Note that the minimum occurs at about 40,000 hours, much longer than for cases 1 and 2. Also, the minimum is not nearly as low as Case 2 which indicates that this method of testing does not take full advantage of the redundant channel. Bypassing both channels for simultaneous testing should be avoided.

The most likely case would be to stipulate that one channel be bypassed, tested, and restored, and then immediately following,.the second channel be bypassed, tested, and restored. This is shown by Curve No. 4. Note that there is no true minimum. The curve does have a definite knee and very little reduction in system unavailability is achieved by testing at a shorter interval than computed by the equation for a single channel.

The best test procedure of all those examined is to perfectly stagger the tests. That is, if the test interval is four months, test one or the other channel every two months. This is shown in Curve No. 5. The difference between Cases 4 and 5 is negligible. There may be other arguments, however, that more strongly support the perfectly staggered tests, including reductions in human error.

The conclusions to be drawn are these:

l. A 1-out-of-n system may be treated the same as a single channel in terms of choosing a test interval; and
2. more than one channel should not be bypassed for testing at any one time.

The radiation monitors in the refueling area ventilation duct which initiate building isolation and standby gas treatment operation are arranged in two 1-out-of-2 logic systems. The bases given for the rod blocks apply here also and were used to arrive at the functional testing frequency. Based on experience with instruments of similar design, a testing interval of once every three months has been found adequate.

The automatic pressure relief instrumentation can be considered to be a 1-out-of-2 logic system and the discussion above applies'lso.

BFN 3.2/4.2-73 Unit 2

I The RCIC and HPCI system logic tests required by Table 4.2.B contain provisions to demonstrate that these systems will automatically restart on a RPV low water level signal received subsequent to a RPV high water level trip.

BFN 3.2/4.2-73a Unit 2

~

J J

3.8.A. 4.8.A.

4. (Deleted) 4. (Deleted)
5. The maximum activity to be 5. (Deleted) contained in one liquid radwaste tank or temporary storage tank that can be discharged directly to the environs shall not exceed 10 curies excluding tritium and dissolved/entrained noble gas.
6. With radioactive liquid waste 6. The quantity of exceeding 3.8.A.5 limits, radioactive material without delay suspend all contained in any additions of radioactive outside liquid radwaste material to the tank and storage tanks shall be within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the determined to be within tank contents to within the the above limit by limit. Events leading to this analyzing a condition must be reported in representative sample the next Annual Radioactive of the tank's contents 0 Effluent Release Report (Section 5.2 of the ODCM).

at least days when once per 7 radioactive materials are being added to the tank.

BFN 3.8/4.8-2 Unit 2

e. Review of all proposed changes to the Technical Specifications.
f. Review of safety evaluation for proposed tests or experiments to be completed under the provisions of 10 CFR 50.59.
g. Review proposed changes to the Offsite Dose Calculation Manual and Process Control Program.
h. Review adequacy of the Process Control Program and Offsite Dose Calculation Manual at least once every 24 months.
i. Review changes to the radwaste treatment systems.
j. Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendation, and disposition of the corrective action to prevent recurrence to the Senior Vice President, Nuclear Power, and to the Nuclear Safety Review Board.
k. Review of all safety evaluations for modifications to structures, systems or components that affect nuclear safety to verify that such actions did not constitute an unreviewed safety question as defined in 10 CFR 50.59, or requires a change to these Technical Specifications.
1. A review of the Appendix R Safe Shutdown Program and implementing procedures. Submit all PORC approved changes to NSRB.

BFN 6.0-8 Unit 2

4 positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiological Work Permit.

6.8.3.2 Each high radiation area in which the intensity of radiation is greater than 1,000 mrem/hr shall be subject to the provisions of (1) above; and, in addition, access to the source and/or area shall be secured by lock(s). The key(s) shall be under the administrative control of the shift engineer. In the case of a high radiation area established for a period of 30 days or less, direct surveillance to prevent unauthorized entry may be substituted for permanent access control.

  • Health Physics personnel, or personnel escorted by Health Physics personnel, in accordance with approved emergency procedures, shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

6.8.4 RADIOACTIVE EFFLUENT CONTROLS/RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMS The following programs shall be established, implemented, and maintained.

BP5 6.0-23 Unit 2

6.8.4.1 RADIOACTIVE EFFLUENT CONTROLS PROGRAM A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on the OPERABILITY of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM.
b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 CFR Part 20, Appendix B, Table II, Column 2.
c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.106 and with the methodology and parameters in the ODCM.
d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from each unit to unrestricted areas conforming to Appendix I to 10 CFR Part 50.
e. Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current year in accordance with the methodology and parameters in the ODCM at least every 31 days.

BFN 6.0-23a Unit 2

~g E

f. Limitations on the OPERABILITY and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to red'uce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50.
g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the site boundary conforming to the doses associated with 10 CFR Part 20, Appendix B, Table II, Column 1.
h. Limitations of the annual and quarterly ai'r doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50.

Limitations on the annual and quarterly doses to a member of the public from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50.

j. Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

BFN 6. 0-23b Unit 2

'4 6.9.1.6 SOURCE TESTS Results of required leak tests performed on sources if the tests reveal the presence of 0.005 microcurie or more of removable contamination.

6.9.1.7 THE ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year of I

operation shall be submitted by April 1, of each year. The report shall include summaries of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. A single submittal may be made for a multi-unit station.

The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit. The material provided shall be (1) consistent with the objectives outlined in the ODCH and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 'of Appendix I to 10 CFR Part 50.

BFN 6.0-26a Unit 2

b. A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.
2. Shall become effective after review and acceptance by the PORC and the approval of the Plant Manager.
3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month/year) the change was implemented.

6.13 (Deleted)

BFN 6.0-33 Unit 2

e t

PROPOSED TECHNICAL SPECIFICATION CHANGE BROGANS FERRY NUCLEAR PLANT UNIT 3 (TVA BFN TECHNICAL SPECIFICATION 301 SUPPLEMENT 1)

II

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~0 1

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~0 1 6.2.1 Offsite and Onsite Organizations......................... 6.0-1 6.2.2 Plant Staff.............-.............-......-. 6.0-2 AF ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~0 5 XE ggg G~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6. 0-5

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~0 5 6.5.1 Plant Operations Review Committee (PORC)................. 6.0-5 6.5.2 Nuclear Safety Review Board.(NSRB)....................... 6.0-11 6.5.3 Technical Review and Approval of Procedures.............. 6.0-17

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ i ~ ~ ~ 6o0 18 t

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~ 0 19

~ ~ ~ ~ ~ ~ ~ i ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ 6 ~ 0 20 6.8.1 P rocedures....................-.......-.-... 6.0-20 6.8.2 Drills ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6.0-21 6.8.3 Radiation Control Procedures............................. 6.0-22 6.8.4 Radioactive Effluent Controls/Radiological Environmental Monitoring Programs..................... 6.0-23

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ a ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~ 0 24 6.9.1 Routine Reports.......................................... 6.0-24 Startup Reports.......................................... 6.0-24 Annual Operating Report.................................. 6.0-25 Monthly Operating Report................................. 6.0-26 Reportable Events........................................ 6.0-26 Annual Radiological Environmental Operating Report....... 6.0-26 Source Tests............................................. 6.0-26 The Annual Radioactive Effluent Release Report........... 6.0-26a 6.9.2 S pecial Reports.......................................... 6.0-27

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 6 ~ 0 29 G ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 ~ ~ ~ ~ 6.0-32 6.0-32 2 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

6.0-33 BFN Unit 3

F 1.0 (Cont'd)

L1

  • initiation of a system, subsystem, or components to verify that it functions within design tolerances (e.g., the manual start of a core spray pump to verify" that it runs and that it pumps the required volume of water).

~~t ~ - The reactor is in a shutdown condition when the reactor switch is in the shutdown mode position and no core alterations

~

mode are being performed.

Y. An engineered safeguard is a safety system the actions of which are essential to a safety action required in response to accidents.

Z~ P

  • conditions specified in section 50.73 to 10 CFR Part 50.

BB. ~QQ Shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.5 and 6.9.1.7.

CC.

from the primary containment to maintain temperature, pressure, humidity, concentration, or other operating condition in such a manner that replacement air or gas is required to purify the containment.

DD. t - Shall contain the current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61 and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.

EE.

FF. ~t gg primary The'controlled process of discharging air or containment to maintain temperature, pressure, gas from the humidity, concentration, or other operating condition in such a manner that replacement air or gas is not provided or required. Vent, used in system names, does not imply a venting process.

BFN Unit 3

G 3.2.K 42K Qg 'v t t t t

1. The explosive gas monitoring l. Each of the explosive instruments listed in Table gas monitoring 3.2.K shall be OPERABLE with instruments shall be the applicability as shown in demonstrated OPERABLE Tables 3.2.K/4.2.K. Alarm/ by performance of tests trip setpoints will be set in accordance with to ensure that the limits of Table 4.2.K.

Specification 3.8.B.9 are not exceeded.

2. The action required when the number of OPERABLE channels is less than the Minimum Channels OPERABLE requirement is specified in the notes for Table 3.2.K. Exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, prepare and submit a special report to the commission pursuant to Specification 6.9.1.4 to explain why the inoperability was. not corrected in a timely manner.
3. (Deleted)
4. (Deleted)
5. The provisions of Specificati.on 1.0.C are not applicable.

BFN 3.2/4.2-6 Unit 3

e, 3.2 g~g (Cont'd)

The APRM rod block function is flow biased and prevents a significant reduction in MCPR, especially during operation at reduced flow. The APRM provides gross core protection; i.e., limits the gross core power increase from withdrawal of control rods in the normal withdrawal sequence. The trips are set so that MCPR is maintained greater than 1.07.

The RBM rod block function provides local protection of the core; i.e.,

the prevention of critical power in a local region of the core, for a single rod withdrawal error from a limiting control rod pattern.

If the IRM channels are in the worst condition of allowed bypass, the scaling arrangement is such that for unbypassed IRM channels, a rod block signal is generated before the detected neutrons flux has increased by more than a factor of 10.

A downscale indication is an indication the instrument has failed or the instrument is not sensitive enough. In either case the instrument will not respond to changes in control, rod motion and thus, control rod motion is prevented.

The refueling interlocks also operate one logic channel, and are required for safety only when the mode switch is in the refueling position.

For effective emergency core cooling for small pipe breaks, the HPCI system must function since reactor pressure does not decrease rapid enough to allow either core spray or LPCI to operate in time. The automatic pressure relief function is provided as a backup to the HPCI in the event the HPCI does not operate. The arrangement of the tripping contacts is such as to provide this function when necessary and minimize spurious operation. The trip settings given in the specification are adequate to assure the above criteria are met. The specification preserves the effectiveness of the system during periods of maintenance, testing, or calibration, and also minimizes the risk of inadvertent operation~ i.e., only one instrument channel out of service.

Four radiation monitors are provided for each unit which initiate Primary Containment Isolation (Group 6 isolation valves) Reactor Building Isolation and operation of the Standby Gas Treatment System. These instrument channels monitor the radiation in the reactor zone ventilation exhaust ducts and in the refueling zone.

BFN 3.2/4.2-67 Unit 3

l I 3.2 ~gg5 (Cont'd)

The OPERABILITY of the meteorological instrumentation ensures that sufficient meteorological data is available for estimating potential radiation dose to the public as a result of routine or accidental release of radioactive materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public.

The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the seismic response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for Browns Ferry Nuclear Plant and to determine whether the plant can continue to be operated safely. The instrumentation provided is consistent with specific portions of the recommendations of Regulatory Guide 1 12 "Instrumentation for Earthquakes."

~

The instrumentation in Tables 3.2.K/4.2.K monitors the concentration of potentially explosive gas mixtures in the offgas holdup system. The OPERABILITY and use of this instrumentation is consistent with the 1 requirements of General Design Criteria 63 of Appendix A to 10 CFR Part 50.

ATWS/RPT, Anticipated Transients without Scram/Recirculation Pump Trip system provides a means of limiting the consequences of the unlikely occurrence of a failure to scram during an ATWS event. The response of the plant to this postulated event (ATWS/RPT) follows the BWR Owners Group Report by General Electric NEDE-31096-P-A and the accompanying NRC Staff Safety Evaluation Report.

ATWS/RPT utilizes the engineered safety feature (ESF) master/slave analog trip units (ATU) which consists of four level and four pressure channels total. The initiating logic consists of two independent trip systems each consisting of two reactor dome high pressure channels and two reactor vessel low level channels. A coincident trip of either two low levels or two high pressures in the same trip system causes initiation of ATWS/RPT. This signal from either trip system opens one of two EOC BFN 3.2/4.2-69 Unit 3

4.2 Q~+ (Cont'd)

The conclusions to be drawn are these:

l. A 1-out-of-n system may be treated the same as a single channel in terms of choosing a test interval; and
2. more than one channel should not be bypassed for testing at any one time.

The radiation monitors in the refueling area ventilation duct which initiate building isolation and standby gas treatment operation are arranged in two 1-out-of-2 logic systems. The bases given for the rod blocks apply here also and were used to arrive at the functional testing frequency. Based on experience with instruments of similar design, a testing interval of once every three months has been found adequate.

The automatic pressure relief instrumentation can be considered to be a 1-out-of-2 logic system and the discussion above applies also.

The RCIC and HPCI system logic tests required by,Table 4.2.B contain provisions to demonstrate that these systems will automatically restart on a RPV low water level signal received subsequent to a RPV high water level trip.

BFN 3.2/4.2-72 Unit 3

0 4.8.A.

4. (Deleted) 4. (Deleted)
5. The maximum activity to be 5. (Deleted) contained in one liquid radwaste tank or temporary storage tank that can be discharged directly to the environs shall not exceed 10 curies excluding tritium and dissolved/

entrained noble gas ~

6. With radioactive liquid waste 6. The quantity of exceeding 3.8.A.5 limits,, radioactive material without delay suspend all contained in any outside additions of radioactive liquid radwaste storage material to the tank and tanks shall be within 48 hours, reduce the determined to be within tank contents to within the the above limit by limit. Events leading to analyzing a this condition must be representative sample of reported in the next Annual the tank's contents at Radioactive Effluent Release least once per 7 days Report (Section 5.2 of the when radioactive ODCN). materials are being added to the tank.

BFN 3.8/4.8-2 Unit 3

~r ~

.~

e. Review of all proposed changes to the Technical Specifications.
f. Review of safety evaluation for proposed tests or experiments to be completed under the provisions of 10 CFR 50.59.
g. Review proposed changes to the Offsite Dose Calculation Manual and Process Control Program.
h. Review adequacy of the Process Control Program and Offsite Dose Calculation Manual at least once every 24 months.
i. Review changes to the radwaste treatment systems.
j. Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendation, and disposition of the corrective action to prevent recurrence to the Senior Vice President, Nuclear Power, and to the Nuclear Safety Review Board.
k. Review of all safety evaluations for modifications to structures, systems or components that affect nuclear safety to verify that such actions did not constitute an unreviewed safety question as defined in 10 CFR 50.59, or requires a change to these Technical Specifications.

BFN 6.0-8 Unit 3

U ~

within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiological Work Permit.

6.8.3.2 Each high radiation area in which the intensity of radiation is greater than 1,000 mrem/hr shall be subject to the provisions of (1) above; and, in addition, access to the source and/or area shall be secured by lock(s). The key(s) shall be under the administrative control of the shift engineer. In the case of a high radiation area established for a period of 30 days or less, direct surveillance to prevent unauthorized entry may be substituted for permanent access control.

  • Health Physics personnel, or personnel escorted by Health Physics personnel, in accordance with approved emergency procedures, shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

6.8.4 RADIOACTIVE EFFLUENT CONTROLS/RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMS The following programs shall be established, implemented, and maintained.

BPK 6.0-23 Unit 3

6.8.4.1 RADIOACTIVE EFFLUENT CONTROLS PROGRAM A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements'.

a. L'imitations on the OPERABILITY of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology'n the ODCM.
b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 CFR Part 20, Appendix B, Table II, Column 2.
c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.106 and with the methodology and parameters in the ODCM.
d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from each unit to unrestricted areas conforming to Appendix I to 10 CFR Part 50.
e. Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current year in accordance with the methodology and parameters in the ODCM at least every 31 days.

BFN 6.0-23a Unit 3

4 ~

f. Limitations on the OPERABILITY and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce

, releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50.

g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the site boundary conforming to the doses associated with 10 CFR Part 20, Appendix B, Table II, Column l.
h. Limitations of the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50.
i. Limitations on the annual and quarterly doses to a member of the public from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50.
j. Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

BFN 6.0-23b Unit 3

4 Cl

6.9.1.7 THE ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year of operation shall be submitted by April 1, of each year. The report shall include summaries of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. A single submittal may be made for a multi-unit station.

The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit. The material provided shall be (1) consistent with the objectives outlined in the ODOM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

BFN 6.0-26a Unit 3

~ b" 4

b. A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint ca'lculations.
2. Shall become effective after review and acceptance by the PORC and the approval of the Plant Manager.
3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month/year) the change was implemented.

6.13 (Deleted)

BFN 6.0-33 Unit 3

,~ l ENCLOSURE 2 BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1q 2g AND 3 (TVA BFN TECHNICAL SPECIFICATION 301 SUPPLEMENT 1)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION REASON FOR THE CHANGE TS-301 was submitted to the NRC on March 25, 1992, to address relocation of programmatic controls and procedural details for radioactive effluents and radiological environmental monitoring for all BFN units per the guidance provided by Generic Letter (GL) 89-01. This supplement clarifies the original amendment and incorporates changes to implement revised regulation 10 CFR 50.36a(a)(2).

DESCRIPTION OF THE PROPOSED CHANGE

1. The original TS-301 submittal for Units 1, 2 and 3 (LCO) paragraph 3.2.K.1, page 3.2/4.2-6 reads:

The explosive gas monitoring instruments listed in Table 3.2.K shall be OPERABLE with the applicability as shown in Tables 3.2.K/4.2.K.

The proposed supplement to TS-301 for Units 1, 2 and 3 adds a sentence to the (LCO) paragraph 3.2.K.1., page 3.2/4.2-6 which reads:

The explosive gas monitoring instruments listed in Table 3.2.K shall be OPERABLE with the applicability as shown in Tables 3.2.K/4.2.K.

Alarm/trip setpoints will be set to ensure that the limits of Specification 3.8.B.9 are not exceeded.

2. The current TS BASES page 3.2/4.2-68 for Unit 1, page 3.2/4.2-69 for Unit 2 and page 3.2/4.2-67 for Unit 3 reads:

Two post treatment offgas radiation monitors are provided and, when their trip point is reached, cause an isolation of the off-gas line.

Isolation is initiated when both instruments reach their high trip point or one has an upscale trip and the other a downscale trip or both have a downscale trip.

Both instruments are required for trip, but the instruments are set so that the instantaneous stack release rate limit given in Specification 3.8 is not exceeded.

The proposed supplement to TS-301 deletes the BASES text.

0 ENCLOSURE 2 (CONTINUED) 2 of 4 BROWNS FERRY NUCLEAR PLANT (BFN)

REASON FOR THE CHANGE DESCRIPTION AND J'USTIFICATION

3. The current TS BASES page 3.2/4.2-70 for Unit 1, page 3.2/4.2-70 for Unit 2, and page 3.2/4.2-69 for Unit 3 reads:

The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The alarm/trip setpoints for these instruments will be calculated in accordance with guidance provided in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20.

This instrumentation also includes provisions for monitoring the concentration of potentially explosive gas mixtures in the offgas holdup system. The operability and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and of Appendix A to 10 CFR Part 50.

The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The alarm/trip setpoints for these instruments shall be calculated in accordance with guidance provided in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20 Appendix B, Table II, Column 2. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

The proposed supplement to TS-301 deletes the second paragraph and revises the first paragraph to read as follows: The instrumentation in Tables 3.2.K/4.2.K monitors the concentration of potentially explosive gas mixtures in the offgas holdup system. The operability and use of this instrumentation is consistent with the requirements of General Design Criteria 63 of Appendix A to 10 CFR Part 50.

4. The current TS BASES page 3.2/4.2-73 for Unit 1, pages 3.2/4.2-73 6 73a for Unit 2, and page 3.2/4.2-72 for Unit 3 reads:

"The off-gas post treatment monitors are connected in a 2-out-2 logic arrangement".

"The criteria for ensuring the reliability and accuracy of the radioactive gaseous effluent instrumentation is listed in Table 4.2.K."

"The criteria for ensuring the reliability and accuracy of the radioactive liquid effluent instrumentation is listed in Table 4.2.D."

t 5.

The proposed sentences.

The 3

original reads:

supplement to TS-301 paragraph Review proposed changes TS-301 BASES deletes 6.5.1.6.g, to the Offsite Dose the above three page 6.0-8 for Units Calculation Manual.

1, 2 and

Li

~ a (

0

ENCLOSURE 2 (CONTINUED) 3 of 4 BROWNS FERRY NUCLEAR PLANT (BFN)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION The proposed supplement to TS-301 paragraph 6.5.1.6.g, page 6.0-8 for Units 1, 2 and 3 reads:

Review proposed changes to the Offsite Dose Calculation Manual and Process Control Program.

6. The original TS-301 paragraph 6.5.1.6.h, page 6.0-8 for Units 1, 2 and 3 reads:

Review adequacy of the Process Control Program at least once every 24 months.

The proposed supplement to TS-301 paragraph 6.5.1.6.h, page 6.0-8 for Units 1, 2 and 3 reads: (NOTE: This supplement change to paragraph 6.5.1.6.h does not revise the existing TS.)

Review adequacy of the Process Control Program and Offsite Dose Calculation Manual at least once every 24 months.

7. The original TS-301 paragraph 6.8.4 page 6.0-23 for Units 1, 2 and 3 reads:

The following programs shall be established, implemented, and maintained.

Quality Assurance procedures shall be established, implemented, and maintained for these programs using the guidance in Regulatory Guide 1.21, Rev.l, June 1974 and Regulatory Guide 4.1, Rev. 1, April 1975 or Regulatory Guide 4.15, December 1977.

The proposed supplement to TS-301 paragraph 6.8.4 page 6.0-23 for Units 1, 2 and 3 reads:

The following programs shall be established, implemented, and maintained.

(Note) information deleted from paragraph 6.8.4 page 6.0-23 for Units 1, 2 and 3 was moved to the ODOM.

8. The original TS-301 paragraph 6.9.1.7 page 6.0-26a for Units 1, 2 and 3 reads:

The Semiannual Radioactive Effluent Release Report covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1, and July 1 of each year.

The proposed supplement to TS-301 paragraph 6.9.1.7, page 6.0-26a for Units 1, 2 and 3 reads:

The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year of operation shall be submitted by April 1, of each year.

9. Paragraph 6.9.1.7 page 6.0-26a change the title from "SEMIANNUAL

" THE ANNUAL RADIOACTIVE EFFLUENT RADIOACTIVE EFFLUENT RELEASE REPORT" to

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ENCLOSURE 2 (CONTINUED) 4 of 4 BROWNS FERRY NUCLEAR PLANT (BFN)

REASON FOR THE CHANGE DESCRIPTION AND LTUSTIFICATION RELEASE REPORT"

10. The original TS-301, Unit 2 only, table of content section 6.8.5, page v changed page "6.0-23" to "6.0.23c".
11. The original TS-301, Unit 3 only, page 6.0-10 changed to 1.0-10.
12. Minor editorial changes (i.e., semiannual) to annual throughout, capitalized "operable" where appropriate; added periods on page 6.0-23a and b where appropriate, Unit 3, page 1.0-10, item DD, line 5 word "as"changed to "a", Unit 1 only, page 6.0-32, paragraph 6.12 title changed "calculational" to calculation". All three units Table of Contents, page v, item 6.6 "Actions" changed to "Action". Unit 2 only Table of Contents, page v, item 6.9.1 Source Tests, page number "6.0-26" changed to "6.0-26a"
13. The reference to the main condenser identified if GL 89-01 is not applicable to BFN.

a7USTIFICATION FOR THE PROPOSED CHANGE This supplement to TS-301 follows the guidance of GL 89-01 and implements the provisions for programmatic controls for radioactive effluents and radiological environmental monitoring. The proposed changes which respond to NRC comments do not change the intent of the original TS-301 submittal. The change in the length of the reporting period from semiannual to annual is in response to a change in regulation 10 CFR 50.36a(a)(2) as published in Federal Register notice (57 FR 39353-39358) dated August 31, 1992.

ENVIRONMENTAL IMPACT EVALUATION The proposed supplement changes do not involve an unreviewed environmental question because operation of BFN Units 1, 2 and 3 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the Staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or decisions of the Atomic Safety and Licensing Board.
2. Result in a significant change in effluents or power levels.
3. Result in matters not previously reviewed in the licensing basis for BFN that may have a significant environmental impact.

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ENCLOSURE 3 BROWNS FERRY NUCLEAR PLANT (BFN)

PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION DESCRIPTION OF THE PROPOSED TECHNICAL SPECIFICATION CHANGE The proposed changes provides resolution to NRC comments. In addition TVA is implementing the new radiological effluent reporting requirements as defined in 10 CFR 50.36a(a)(2). The change to the Code of Federal Regulations revises the reporting frequency for the radiological effluent report from semiannually to annually. The proposed supplement changes to TS 301 do not change the intent of the original submittal dated March 25, 1992.

BASES FOR PROPOSED NO SIGNIFICANT HAZARDS 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 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. The proposed TS change 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.

The proposed supplement to BFN TS-301 revises the original submittal to incorporate NRC comments. The proposed changes do not change the intent of the original submittal. The changes in reporting requirements is administrative in nature. Since this administrative change does not affect the operability of plant equipment or alter the design of the plant, the probability or consequences of any accident previously evaluated have not been increased.

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

The proposed changes in this supplement do not change the intent of the original submittal. The change to reporting requirements is administrative. Therefore, there is no possibility of a new or different kind of accident being created.

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

The proposed changes in this supplement conform to the guidance contained in Generic Letter 89-01 and the revised rule change to 10 CFR 50.36a(a)(2). The proposed changes do not change the intent of the original submittal. Therefore, the proposed changes do not reduce any margin of safety.

0 ~tgsh Page 2 of 2 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 not (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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