ML18037A488

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Proposed Tech Specs Re Requirements for Lab Sample Analysis of Charcoal Adsorbers to Reflect Latest ASTM Std
ML18037A488
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 09/29/1993
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18037A487 List:
References
NUDOCS 9310050138
Download: ML18037A488 (37)


Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNITS 1, 2,

AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341) 93i0050i38 930924 PDR ADOCK 05000259 P ', PDR,,

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TECHNICAL SPECIFICATION 341 EFFECTIVE PAGE LISTING UNIT 1 3.7/4.7-14 3.7/4.7-19 3.7/4.7-21 3.7/4.7-33 3.7/4.7-37 3.7/4.7-38 UNIT 2-3.7/4.7-14 3.7/4.7-19 3.7/4.7-21 3.7/4.7-33 3.7/4.7-37 3.7/4.7-38 UNIT 3 3.7/4.7-14 3.7/4.7-19 3.7/4.7-21 3.7/4.7-32 3.7/4.7-36 3.7/4.7-37

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PROPOSED TECHNICAL SPECIFICATION CHANGE BROMNS FERRY NUCLEAR PLANT UNIT 1 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

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CO AI SS MS L'IMITING CONDITIONS FOR OPERATIO SURVEILLANCE RE UIREME S

3.7.B. Standb Gas Treatment S stem 4.7.B.

Standb Gas Treatment

~Ss tetg

2. a. The results of the in-place cold DOP and halogenated hydrocarbon tests at g 10%

design flow on HEPA filters and charcoal adsorber banks shall show g99%

DOP removal and g99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

2 ~ a ~ The tests and sample analysis of Specification 3.7.B.2 shall be performed at least once per operating cycle or once every 18 months whichever occurs first for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory carbon sample analysis shall show g90% radioactive methyl iodide removal when tested in accordance with ASTM D3803.
b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing.
c. System shall be shown to operate within gl0% design flow.

c ~ Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

BFN Unit 1 3.7/4.7-14

4 CO AINME SYSTEMS LIMITI G CO ITIONS FOR OPERATION SURVEILLANCE RE UIREME S

3.7.E. Control Room Emer enc Ventilatio 4.7.E Control Room Emer enc Ventilation

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

The results of the inplace cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g99%

DOP removal and g99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

2. a.

The tests and sample analysis of Specification 3.7.E.2 shall be performed at least once per operating cycle or once every 18 months, whichever occurs first for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory carbon sample analysis shall show p90% radioactive methyl iodide removal at a velocity when tested in accordance with ASTM D3803.
b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA

'ilter bank or after any structural maintenance on the system housing.

BFN Unit 1 3.7/4.7-19

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4 CONTAINME SYSTEMS MITI G CO TIONS FOR OPERATIO SURVEILLA CE RE UIREME S

3.7.F.

a Containme t Pu e

~Ss tetg 4.7.F.

r ma Co ta nme t Pur e

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1. The primary containment purge system shall be OPERABLE for PURGING, except as specified in 3.7.F.2.

a.

The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g 99%

DOP removal and g 99% halogenated hydro-carbon removal when tested in accordance with ANSI N510-1975.

b. The results of laboratory carbon sample analysis shall show g 85% radioactive methyl iodide removal when tested in accordance with ASTM D3803.

I

c. System flow rate shall be shown to be within + 10%

of design flow when tested in accordance with ANSI N510-1975.

2. If the provisions of 3.7.F.l.a, b,

and c cannot be met, the system shall be declared inoperable.

The provisions of Technical Specification 1.C.1 do not apply.

PURGING may con-tinue using the Standby Gas Treatment System.

3. a.

The 18-inch primary contain-ment isolation valves asso-ciated with PURGING may be open during the RUN mode for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

The OPERABILITY of

l. At least once every 18
months, the pressure drop across the combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 8.5 inches of water at system design flow rate (g 10%).
a. The tests and sample analysis of Specifica-tion 3.7.F.1 shall be performed at least once per operating cycle or once every 18 months, whichever occurs first or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of

'ystem operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural mainte-nance on the system housing.
c. Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

BFN Unit 1 3.7/4.7-21

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3.7/4.7 BASES (Cont'd) containment is opened for refueling.

Periodic testing gives sufficient confidence of reactor building integrity and standby gas treatment system performance capability.

The test frequencies are adequate to detect equipment deterioration prior to significant defects, but the tests are not frequent enough to load the filters, thus reducing their reserve capacity too quickly.

That the testing frequency is adequate to detect deterioration was demonstrated by the tests which showed shipboard environment on the US Savannah (ORlg. '~2 ).

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

Heater capability, pressure drop and air distribution should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon refrigerant shall be performed in accordance with USAEC Report DP-1082.

Iodine removal efficiency tests shall follow ASTM D3803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorbe tra

, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

All elements of the heater should be demonstrated to be functional and OPERABLE during the test of heater capacity.

Operation of each filter train for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month will prevent moisture buildup in the filters and adsorber system.

With doors closed and fan in operation, DOP aerosol shall be sprayed externally along the full linear periphery of each respective door to check the gasket seal.

Any detection of DOP in the fan exhaust shall be considered an unacceptable test result and the gaskets repaired and test repeated.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign material, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

BFN Unit 1 3.7/4.7-33

3.7/4.7 BASES (Cont'd) limited period of time while repairs are being made. If the system cannot be repaired within seven days, the reactor is shutdown and brought to Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or refueling operations are terminated.

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

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

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated; Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082.

Iodine removal efficiency tests shall follow ASTM D3803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least.two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate OPERABILITY of the filters and adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determinati.on of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capability.

3.7.F/4.7.F Prima Containment Pur e

S stem The Primary Containment Purge System is a non-safety related system that is normally isolated and normally not required to be functional during power operation.

The system is designed to provide the preferred exhaust path for purging the primary containment system;

however, the Standby Gas Treatment System can be used to perform the equivalent function.

BFN Unit 1 3.7/4.7-37

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3.7/4.7 BASES (Cont'd)

When the Primary Containment Purge System is in operation, the exhaust from the primary containment is first processed by a filter train assembly and then channeled through the reactor building roof exhaust system.

The filter train assembly contains a HEPA (high efficiency particulate air) filter, charcoal adsorber, and centrifugal fan.

In-place tests are performed to ensure leak tightness of the filter train assembly of at least 99K and a HEPA efficiency of at least 99K removal of DOP particulates.

Laboratory tests are performed on adsorber carbon samples to ensure an 85K removal efficiency for radioactive methyl iodide.

Tests are performed to ensure that the system is not operating at a flow significantly different from the design flow, which may affect the removal efficiency of the HEPA filters and charcoal adsorbers.

The pressure drop across the combined HEPA filters and charcoal adsorbers is checked once per operating cycle to be less than 8.5 inches of water at the system design flow rate to ensure that the filters and adsorbers are not clogged with excessive amounts of foreign matter.

The above tests are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082.

Iodine removal efficiency tests shall follow AS'3803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

The primary containment isolation valves associated with the purging of the primary containment are FCV 64-17, 64-18, 64-19, 64-29, 64-30, 64-32, 64-33, and 76-24.

These valves may be open for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

Closure of these large diameter valves within the 24-hour period is needed to BFN Unit 1 3.7/4.7-38

PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 2 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

4 CO AI SYS EMS LIMITI G CONDITIONS FOR OPERATION SURVEILLANCE RE UIREME S

3.7.B. Standb Gas Treatment S stem 4.7.B.

Standb Gas Treatment

~Sstem

2. a.

The results of the in-place cold DOP and halogenated hydrocarbon tests at g 10%

design flow on HEPA filters and charcoal adsorber banks shall show g99%

DOP removal and g99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

2 ~

ao The tests and sample analysis of Specification 3.7.B.2 shall be performed at least once per operating cycle or once every 18 months whichever occurs first for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory carbon sample analysis shall show g90% radioactive methyl iodide removal when tested in accordance with ASTM D3803.
b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing.
c. System shall be shown to operate within F10% design flow.

c ~ Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

BFN Unit 2 3.7/4.7-14

~

~

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4 CO AI SYSTEMS I ITI G CO TIO S

FOR OPERATIO 3.7.E. Control Room Emer enc Ventilation SU LLA C RE UI E S

4.7.E Control Room Emer enc

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

The results of the inplace cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g99%

DOP removal and y99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

2. a.

The tests and sample analysis of Specification 3.7.E.2 shall be performed at least once per operating cycle or once every 18 months, whichever occurs first for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory carbon sample analysis shall show g90% radioactive methyl iodide removal at a velocity when tested in accordance with ASTM D3803.
b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing.

BFN Unit 2 3.7/4.7-19

4 CO AI SYSTEMS LI G

CO TIO S

FOR OPERATIO SURVE LA CE RE UIRE S

3.7.F.

Pr a

Contai e t Pur e

~Ss~te 4.7.F.

Pr a

Co ta t Pur e

~Sat em 1.

The primary containment purge system shall be OPERABLE for PURGING, except as specified in 3.7.F.2.

a.

The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g 99/

DOP removal and g 99/ halogenated hydro-carbon removal when tested in accordance with ANSI N510-1975.

b.

The results of laboratory carbon sample analysis shall show g 85/ radioactive methyl iodide removal when tested in accordance with ASTM D3803.

c.

System flow rate shall be shown to be within + 10/

of design flow when tested in accordance with ANSI N510-1975.

3 ~

a ~

The 18-inch primary contain-ment isolation valves asso-ciated with PURGING may be open during the RUN mode for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

The OPERABILITY of

2. If the provisions of 3.7.F.l.a, b,

and c cannot be met, the system shall be declared inoperable.

The provisions of Technical Specification 1.C.1 do not apply.

PURGING may con-tinue using the Standby Gas Treatment System.

1.

At least once every 18

months, the pressure drop across the combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 8.5 inches of water at system design flow rate (g lOX).

a.

The tests and sample analysis of Specifica-tion 3.7.F.l shall be performed at least once per operating cycle or once every 18 months, whichever occurs first or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b.

Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural mainte-nance on the system housing.

c.

Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

BFN Unit 2 3.7/4.7-21

3.7/4.7 BASES (Cont'd) containment is opened for refueling.

Periodic testing gives sufficient confidence of reactor building integrity and standby gas treatment system performance capability.

The test frequencies are adequate to detect equipment deterioration prior to significant defects, but the tests are not frequent enough to load the filters, thus reducing their reserve capacity too quickly.

That the testing frequency is adequate to detect deterioration was demonstrated by the tests which showed no loss of filter efficiency after two years of operation in t

e ru ed shipboard environment on the US Savannah

(~ORRD 2 ).

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

Heater capability, pressure drop and air distribution should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon refrigerant shall be performed in accordance with USAEC Report DP-1082.

Iodine removal efficiency tests shall follow ASTM 03803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tra

, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1

of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

All elements of the heater should be demonstrated to be functional and OPERABLE during the test of heater capacity.

Operation of each filter train for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month will prevent moisture buildup in the filters and adsorber system.

With doors closed and fan in operation, DOP aerosol shall be sprayed externally along the full linear periphery of each respective door to check the gasket seal.

Any detection of DOP in the fan exhaust shall be considered an unacceptable test result and the gaskets repaired and test repeated.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign material, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

BFN Unit 2 3.7/4.7-33

3.7/4.7 BASES (Cont'd) limited period of time while repairs are being made. If the system cannot be repaired within seven days, the reactor is shutdown and brought to Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or refueling operations are terminated.

Pressure drop across the combined HEPA filters and charcoal adsorbers of less, than six inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

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

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082.

Iodine removal efficiency tests shall follow AS339 03803-89.

The charcoal adsorher efficiency test procedures should

[

allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate OPERABILITY of the filters and adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capability.

3.7.F/4.7.F Prima Containment Pur e

S stem The Primary Containment Purge System is a non-safety related system that is normally isolated and normally not required to be functional during power operation.

The system is designed to provide the preferred exhaust path for purging the primary containment system;

however, the Standby Gas Treatment System can be used to perform the equivalent function.

BFN Unit 2 3.7/4.7-37

~,

~

~

3.7/4.7 BASES (Cont'd)

Shen the Primary Containment Purge System is in operation, the exhaust from the primary containment is first processed by a filter train assembly and then channeled through the reactor building roof exhaust system.

The filter train assembly contains a HEPA (high efficiency particulate air) filter, charcoal adsorber, and centrifugal fan.

In-place tests are performed to ensure leak tightness of the filter train assembly of at least 99K and a HEPA efficiency of at least 99K removal of DOP particulates.

Laboratory tests are performed on adsorber carbon samples to ensure an 85K removal efficiency for radioactive methyl iodide.

Tests are performed to ensure that the system is not operating at a flow significantly different from the design flow, which may affect the removal efficiency of the HEPA filters and charcoal adsorbers.

The pressure drop across the combined HEPA filters and charcoal adsorbers is checked once per operating cycle to be less than 8.5 inches of water at the system design flow rate to ensure that the filters and.adsorbers are not clogged with excessive amounts of foreign matter.

The above tests are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082.

Iodine removal efficiency tests shall follow ASTM D3803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of'egulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance'hall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

The primary containment isolation valves associated with the purging of the primary containment are FCV 64-17, 64-18, 64-19, 64-29, 64-30, 64-32, 64-33, and 76-24.

These valves may be open for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

Closure of these large diameter valves within the 24-hour period is needed to BFN Unit 2 3.7/4.7-38

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PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

~.

~

~

CO SYSES LIMITI G CONDITIO S FOR OPERATION SURVEILLANCE RE UIREME S

3.7.B.

Standb Gas Treatment S stem 4.7.B.

Standb Gas Treatment

~Suety

2. a.

The results of the in-place cold DOP and halogenated hydrocarbon tests at

2. 10%

design flow on HEPA filters and charcoal adsorber banks shall show g99%

DOP removal and 299% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

2 ~ a.

The tests and sample analysis of Specification 3.7.B.2 shall be performed at least once per operating cycle or once every 18 months whichever occurs first for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory carbon sample analysis shall show p90% radioactive methyl iodide removal when tested in accordance with ASTM D3803.
b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing.
c. System shall be shown to operate within +10% design flow.

c ~ Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

BFN Unit 3 3.7/4.7-14

4 CO AI SYSTEMS 0

L G

CO 0

S FOR OPERA ION SURVE LA CE E

IREME S

3.7.E. Control Room Emer enc Ventilation 4.7.E Control Room Emer enc e t t o

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

The results of the inplace cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g99%

DOP removal and g99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

2. a.

The tests and sample analysis 'of Specification 3.7.E.2 shall be performed at least once per operating cycle or once every 18 months, whichever occurs first for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b. The results of laboratory carbon sample analysis shall show g90% radioactive methyl iodide removal at a velocity when tested in accordance with ASTM D3803.
b. Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing.

BFN Unit 3 3.7/4.7-19

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4 7 CONTAINMENT SYSTEMS LI I G CONDITIONS FOR OPERATION SURVEILLANCE RE UIREME S

3.7.F.

Pri a

Containment Pur e

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4.7.F.

Prima Containme t Pur e

~Ss te>g 1.

The primary containment purge system shall be OPERABLE for PURGING, except as specified in 3.7.F.2.

a.

The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g 99%

DOP removal and g 99% halogenated hydro-carbon removal when tested in accordance with ANSI N510-1975.

b.

The results of laboratory carbon sample analysis shall show g 85% radioactive methyl iodide removal when tested in accordance with ASTM D3803.

c.

System flow rate shall be shown to be within g 10%

of design flow when tested in accordance with ANSI N510-1975.

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The 18-inch primary contain-ment isolation valves asso-ciated with PURGING may be open during the RUN mode for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

The OPERABILITY of

2. If the provisions of 3.7.F.l.a, b,

and c cannot be met, the system shall be declared inoperable.

The provisions of Technical Specification 1.C.1 do not apply.

PURGING may con-tinue using the Standby Gas Treatment System.

l.

At least once every 18

months, the pressure drop across the combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 8.5 inches of water at system design flow rate (g 10%).

a.

The tests and sample analysis of Specifica-tion 3.7.F.1 shall be performed at least once per operating cycle or once every 18 months, whichever occurs first or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire, or chemical release in any ventilation zone communicating with the system.

b.

Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural mainte-nance on the system housing.

c.

Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

BFN Unit 3 3.7/4.7-21

3.7/4.7 EASES (Cont'd) containment is opened for refueling.

Periodic testing gives sufficient confidence of reactor building integrity and standby gas treatment system performance capability.

The test frequencies are adequate to detect equipment deterioration prior to significant defects, but the tests are not frequent enough to load the filters, thus reducing their reserve capacity too quickly.

That the testing frequency is adequate to detect deterioration was demonstrated by the tests which showed no loss of filter efficiency after two years of operation in

~the ru ed shipboard environment on the US Savannah

(~ORMD 2 ).

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

Heater capability, pressure drop and air distribution should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon refrigerant shall be performed in accordance with USAEC Report DP-1082.

Iodine removal efficiency tests shall folios ASTM 03803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tra, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1

of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

All elements of the heater should be demonstrated to be functional and OPERABLE during the test of heater capacity.

Operation of each filter train for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month will prevent moisture buildup in the filters and adsorber system.

With doors closed and fan in operation, DOP aerosol shall be sprayed externally along the full linear periphery of each respective door to check the gasket seal.

Any detection of DOP in the fan exhaust shall be considered an unacceptable test result and the gaskets repaired and test repeated.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign material, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

BFN Unit 3 3.7/4.7-32

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S.7/4.7 BABES (Cont'd) limited period of time while repairs are being made. If the. system cannot be repaired within seven days, the reactor is shutdown and brought to Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or refueling operations are terminated.

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

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

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082.

Iodine removal efficiency tests shall follow ASTM D3803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate OPERABILITY of the filters and adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capability.

3.7.F/4.7.F Prima Containment Pur e

S stem The Primary Containment Purge System is a non-safety related system that is normally isolated and normally not required to be functional during power operation.

The system is designed to provide the preferred exhaust path for purging the primary containment system;

however, the Standby Gas Treatment System can be used to perform the equivalent function.

BFN Unit 3 3.7/4.7-36

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3.7/4.7 BASES (Cont'd)

When the Primary Containment Purge System is in operation, the exhaust from the primary containment is first processed by a filter train assembly and then channeled through the reactor building roof exhaust system.

The filter train assembly contains a HEPA (high efficiency particulate air) filter, charcoal adsorber, and centrifugal fan.

In-place tests are performed to ensure leak tightness of the filter train assembly of at least 99K and a HEPA efficiency of at least 994 removal of DOP particulates.

Laboratory tests are performed on adsorber carbon samples to ensure an 85/ removal efficiency for radioactive methyl iodide.

Tests are performed to ensure that the system is not operating at a flow significantly different from the design flow, which may affect the removal efficiency of the HEPA filters and charcoal adsorbers.

The pressure drop across the combined HEPA filters and charcoal adsorbers is checked once per operating cycle to be less than 8.5 inches of water at the system design 'flow rate to ensure that the filters and adsorbers are not clogged with excessive amounts of foreign matter.

The above tests are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082.

Iodine removal efficiency tests shall follow ASTM D3803-89.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality.

Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

The primary containment isolation valves associated with the purging of the primary containment are FCV 64-17, 64-18, 64-19, 64-29, 64-30, 64-32, 64-33, and 76-24.

These valves may be open for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

Closure of these large diameter valves within the 24-hour period is needed to BFN Unit 3 3.7/4.7-37

s ENCLOSURE 2

BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2,

AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION REASON FOR THE CHANGE These changes are proposed for the following reasons:

1)

The proposed change to Limiting Condition for Operation (LCO) 3.7.B.2.b for the Standby Gas Treatment System is necessary to allow the testing of carbon samples from the charcoal adsorber trays in accordance with the latest ASTM standard.

2)

The proposed change to LCO 3.7.E.2.b for the Control Room Emergency Ventilation System is necessary to allow the testing of carbon samples from the charcoal adsorber trays in accordance with the latest ASTM standard.

3)

The proposed change to LCO 3.7.F.1.b for the Primary Containment Purge System is necessary to allow the testing of carbon samples from the charcoal adsorber trays in accordance with the latest ASTM standard.

4)

The proposed change to Bases 4.7.B/4.7.C, Standby Gas Treatment System and Secondary Containment, is necessary to specify the latest ASTM standard.

5)

The proposed change to Bases 3.7.E/4.7.E, Control Room Emergency Ventilation, is necessary to specify the latest ASTM standard.

6)

The proposed change to Bases 3.7.F/4.7.F, Primary Containment Purge System, is necessary to specify the latest ASTM standard.

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Page 2 oS 6

ENCLOSURE 2 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2,

AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION DESCRIPT ON OF THE PROPOSED CHANGE

1) Proposed change to Standby Gas Treatment System Limiting Condition for Operation (LCO) 3.7.B.2.b:

Existing Technical Specifications:

"The results of laboratory carbon sample analysis shall show ~904 radioactive methyl iodide removal when tested in accordance with ASTM D3803 (130 Cg 95%

R H )."

Proposed Technical Specifications:

The results of laboratory carbon sample analysis shall show

~90% radioactive methyl iodide removal when tested in accordance with ASTM D3803.

2) Proposed change to Control Room Emergency Ventilation LCO 3.7.E.2.b:

Existing Technical Specifications:

"The results of laboratory carbon sample analysis shall show

>90% radioactive methyl iodide removal at a velocity when tested in accordance with ASTM D3803 (130OCI 95' H

)

Proposed Technical Specifications:

The results of laboratory carbon sample analysis shall show 290% radioactive methyl iodide removal at a velocity when tested in accordance with ASTM D3803.

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Page 3 oS 6

ENCLOSURE 2

(CONTINUED)

BROMNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION

3) Proposed change to Primary Containment Purge System LCO 3.7.F.1.b:

Existing Technical Specifications:,

"The results of laboratory carbon sample analysis shall show 2854 radioactive methyl iodide removal when tested in accordance with ASTM D3803 (130 C, 954 R.H.)."

Proposed Technical Specifications:

The results of laboratory carbon sample analysis shall show h854 radioactive methyl iodide removal when tested in accordance with ASTM D3803.

4) Proposed change to Bases 4.7.B/4.7.C, Standby Gas Treatment System and Secondary Containment:

Existing Bases:

"Iodine removal efficiency tests shall follow ASTM D3803 Proposed Bases:

Iodine removal efficiency tests shall follow ASTM D3803-89.

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4I Page 4 of 6 ENCLOSURE 2 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2,

AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION

5) Proposed change to Bases 3.7.E/4.7.E, Control Room Emergency Ventilation:

Existing Bases:

"Iodine removal efficiency tests shall follow ASTM D3803."

Proposed Bases:

Iodine removal efficiency tests shall follow ASTM D3803-89.

6) Proposed change to Bases 3.7.F/4.7.F, Primary Containment Purge System:

Existing Bases:

"Iodine removal efficiency tests shall follow ASTM D3803 Proposed Bases:

Iodine removal efficiency tests shall follow ASTM D3803-89.

Page 5 oS 6

ENCLOSURE 2 (CONTINUED)

BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION JUSTIFICATION FOR THE PROPOSED CHANGE 1-6)

The purpose of the adsorber trays in the Standby Gas Treatment, Control Room Emergency Ventilation, and Primary Containment Purge Systems is to remove radioactive iodine from the air streams.

Since the adsorber efficiency can degrade over time (due to contamination from painting fumes,

smoke, chemical release, or other foreign materials),

a carbon sample from the trays is periodically analyzed to ensure the adsorbers can perform as previously evaluated.

Regulatory Guide 1.52, Design, Testing, and Maintenance Criteria for Post. Accident Engineered-Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, refers licensees to American National Standards Institute (ANSI)

Standard N510-1975, Testing of Nuclear Air-Cleaning System.

ANSI N510-1975 requires that laboratory testing of samples be performed in accordance with RDT M 16-1T.

ANSI N510-1975 was revised in 1980 and the new revision was labeled as ANSI/ASME N510-1980.

ANSI/ASME N510-1980 refers to American Society for Testing and Materials (ASTM) Standard

D3803, Standard Test Method for Nuclear-Grade Activated Carbon, as the recommended testing procedure for methyl iodide removal efficiency.

The temperature and relative humidity currently specified in the BFN Technical Specifications was developed in response to a Notice of Violation for improper analysis of carbon samples from the Standby Gas Treatment System, that was cited in NRC Inspection Report 85-57, dated February 11, 1986.

In response, on February 11,

1987, TVA submitted a proposed Technical Specification amendment to perform carbon sample analysis in accordance with ASTM D3803-1979.

This amendment was approved by NRC letter, dated February 12, 1988.

Page 6 oS 6 ENCLOSURE 2

(CONTINUED)

BROMNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2,

AND 3 (TVA BFN TECHNICAL SPECIFICATION AMENDMENT 341)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION As discussed in Information Notice 86-76, Problems Noted in Control Room Emergency Ventilation Systems, dated August 28, 1986, laboratory testing of charcoal removal efficiency at temperatures higher than that expected during the course on an accident could result in erroneously high removal efficiency measurements.

As previously mentioned, ASTM Standard D3803 provided the currently accepted procedure for establishing the capability of new and used activated carbon to remove radio-labeled methyl iodide from air and gas streams.

Removal of the specification for testing carbon samples at 130'C and 95 percent relative humidity from the Limiting Condition for Operations for the Standby Gas Treatment

System, Control Room Emergency Ventilation System, and Primary Containment Purge System and the specification of ASTM D3803-89 in the Bases sections for these systems results in the testing of the carbon samples at a lower temperature (30.0'C) but at the same relative humidity (95 percent).

Therefore, these proposed changes will result in a more realistic estimate of the charcoal removal efficiency.

ENCLOSURE 3 BROWNS FERRY NUCLEAR PLANT (BFN)

PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION DESC IPTION OF THE PROPOSED TECHNICAL SPECIFICATION CHANGE 1)

The proposed change to Standby Gas Treatment System Limiting Condition for Operation (LCO) 3.7.B.2.b, Control Room Emergency Ventilation LCO 3.7.E.2.b, and Primary Containment Purge System LCO 3.7.F.1.b deletes the specification of 130'C and 95 percent relative humidity as test conditions for carbon sample analysis.

2) The proposed change to Bases 4.7.B/4.7.C, Standby Gas Treatment System and Secondary Containment, Bases 3.7.E/4.7.E, Control Room Emergency Ventilation, and Bases 3.7.F/4.7.F, Primary Containment Purge System specifies the 1989 edition of ASTM D3803 for Iodine removal efficiency tests.

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 50.92(c).

A proposed amendment to an operating license involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or conseguences 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:

Page 2 of 3 ENCLOSURE 3

(CONTINUED)

BROWNS FERRY NUCLEAR PLANT (BFN)

PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION 1.

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

The proposed deletion of the test conditions for carbon sample analysis does not reflect any significant change to any precursor for the design basis events or operational transients that are analyzed in the Browns Ferry Final Safety Analysis Report.

Therefore, the probability of an accident previously evaluated is not significantly increased.

The proposed removal of the test conditions for carbon sample analysis will allow a more realistic test to be performed on the adsorber trays.

This will result in a more realistic estimate of the charcoal removal efficiency.

Therefore, the proposed changes will not significantly increase the consequences of an accident previously evaluated.

2.

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

The purpose of the adsorber trays is to remove radioactive iodine from the air streams.

The adsorber trays are used to mitigate the consequences of an accident or to reduce the quantity of process effluents being released to the environment.

The proposed removal of the test conditions for carbon sample analysis of the charcoal in the adsorber trays does not require new system alignment, modification, or changes in operating procedures.

Therefore, these proposed changes do not create the possibility of a new or different kind of accident from an accident previously evaluated.

Page 3 of 3 ENCLOSURE 3

(CONTINUED)

BROWNS FERRY NUCLEAR PLANT (BFN)

PROPOSED 0 SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION 3 ~

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

The proposed removal of the test conditions for carbon sample analysis of the charcoal in the adsorber trays does not represent a change in the licensing or design basis removal efficiency for the trays.

The proposed removal of the test conditions for carbon sample analysis will allow a more realistic test to be performed on the adsorber trays.

This will result in a more realistic estimate of the charcoal removal efficiency.

Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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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