ML20066D347

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Proposed Tech Spec Changes,Updating Specs & Clarifying Requirements Re Primary Containment Isolation Valves
ML20066D347
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 11/05/1982
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20066D330 List:
References
NUDOCS 8211110294
Download: ML20066D347 (15)


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ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION REVISIONS (TVA BFNP TS 176 SUPPLEMENT 1) l C'211110294 821105 PDR ADOCK 05000259 P

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4 UNIT 1

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w TA31.E 3.7. A FAIw.ARY CONTAIN4Dit ISOLATION val.9ES N mber of Power Maxt:nu;s Action es Operated Valves Operating Normal Initiating Croup Valve Identi'ication Inbc:rd 0atboard Tine (sec.)

Position Siteel 1

%1o steamline isolation valves 4

4 3<T<5 0

CC i

(FCV-1-14,26,37,658 jl-15, 27, 38, & 52) 1 Main steamline drain isolation 1

1 15 C

SC valves FCV-1-55 & 1-56 i

1*

Reactor 1.*ater sample line isole-1 1

5 C

SC tion valves U

2 R!!AS shutdown cooling supply isolation valves FCV-74-48 & 47 1

1 40 C

SC 2

MIRS

  • 1.FCI to reactor FCV-74-53, 67 2

30 C

SC 2

Reactor vessel head spray isola-tion valves FCi-74-77, 78 1

1 30 C

SC 2

RHRS flush and drain vent to suppression chamber 4

20 C

SC FCV-74-102, 103,'119, & 120 2

Suppression Charcher Drain 2

15 C

E FCV 75-57, -58 2

Dryve11 equipa.ent drain discharge tuolation valves FCV-77-15A, & 15B 2

15 0

GC 2

Drysell floor drain disch4rge ivalation valves FCV-77-2A & 2B 2

15 0

CC

  • These valves isolate only on reactor vessel low low water level (470") and main steam line high radiation of Group 1 isolations.

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.h t-TABLE 3.7.A (Continued)

H Nurbar of Power Maximum Action en

]

. Operated Valves Operating Nonnal Initiating h

Group Valve identi ficat <on Inboard Outboa rd Time (sec.) Position signal t

1.1 6

Suppression Chanter purge inlet

{,

(FCV-64-19)

I 2.5 C

SC 6

Drywell/ Suppression Chamber nitro-

  • gen purge inlet (FCV-76-17) 1 5

C SC

(

6 Drywell Exhaust Valve Bypass to 8

Standby Gas Treatment System

( FCV-64-31)

I 5

0 cc 6

Suppression Chan6er Exhaust Valve Bypass to Standby Gas Treatment System (FCV-64-34) 1 5

o oc 6

Drywell/ Suppression Chamber Nitrogen Purge Inlet (FCV-76-24) 1 5

c SC i

l6 System Suction Isolation Valves to Air Comoressors "A" and "B" 2

15 0

GC (FCV-32-62', 63) 7 RCIC Steamline Drain (FCV-71-6A, 68) 2 5

0 GC I

7 RCIC Condensate Punp Drain (FCV-71-7A,78) 2 5

c sc 7

HPCI Hotwell pump discharge isola-3 tion valves (FCV-73-17A,178) 2 5

C SC 1

7 HPCI steamline drain (FCV 73-6A, -6B) 2 5

0 GC i

.s 8

TIP Guide Tubes (5)

I per guide NA C

GC tube

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(,.0.

ADllNISTRATIVE CONTROL,5 All written reports requiring 24-hour notification to the g,

Commission.

All recognized indications of an unanticipated de' fici. ncy h.

in some aspect of design or operation of structures, systems, or' components that^tould affect. nuclear safety.

Reports and meeting minutes of the PORC.

1, S.

AUDITS Audits, of unit activities shall be performed under the cognizance of the NSRB. These audits shall encompass.

1he conformance of unit operation to provistuns contains within the Technical Specifications and applicabic license a.

conditions at least once per 12 months.

lin perf ormance, training and qualifications of the entire b.

unit staff at least once per 12 months.

The resulta of actions taken to correct deficiencies c.

occurring in unit equipment, strwitures, systems orleact method of operation that affect nuclear safety at per 6 months.

once The performance of activities required by the Operational d.

the criteria of Quality Assurance Program to meet least'once per 24 months.

Appendix "B",10 CFR 50, at The Site Radiological Emergency Plan and implementing e.

Ic'ast once per 24 months.

procedures at J

The Plant Physical Security Plan and implementing f.

procedures at least once per 12 months.

Any other area of unit operation considered appropriate I

g.

by the NSRB or the Manager of Power.

The Facility Fire Protection Program and implementing h.

least once per 24 months.

procedures at i

independent fire protection and loss prevention An i.

program inspection and audit shall be performed annuall:.

f ut ilizing either qualified offsite licensee personnel or -

an outside fire protection firm.

An inspection and audit of the fire protection and Ic m prevention program shall be performed by an outside qualified J.

l fire consultant at intervals no greater than 3 years.

l 334 I

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6.0 ADMILilgTRATIVE CONTROLS 3

Duticu_ sod _Reeggngibilliltu The l'OHC serveu in an advisory capacity to the plant superintendent and as an. investigating and reporting body to the Nuclea?" Safety Review Board' in matters related to safety in plant operations.

The plant superintendent has the final responsibility in determining the matters that.

should be referred to the Nuclear Safety Review Board.

The responsibility of the committee will include:

a.

Review all standard and emergency operating and maintenance instructions and any proposed revisions thereto, with principal attention to provisions for safe operation.

b.

Review proposed changes to the Technical Specifications.

c.

Review proposed changes to equipment or systems having safety significance, or which may constitute "an unreviewed safety question," pursuant to 10 CFR 50.59.

d.

Investigate reported or suspected incidents involving safety questions, violations of the Technical Specifications, and violations of plant instructions pertinent to nuclear safety.

e.

Review reportable occurences, unusual events, operating anomalies and abnormal perf ormance of plant equipment.

f.

Maintain a general surveillance of plant activities to identify possible safety hazards.

g.

Review plans for special fuel handling, plant maintenance, operations, and tests or l

experiements which may involve special safety considerations, and the results thereof, where applicable.

h.

(deleted) 1.

Review implementating procedures of the Radiological Emergency Plan and the Industrial Security Program on an annual basis.

336

0 0

0 UNIT 2

-. ~ - - - -

t

.i,0 Sinit:XSTRATIVV. CONT!M8LS All written reports requiring 24-hour notification to the g.

Comminston, i

h.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nucicar safety.

1.

Reports and meeting minutes of the PORC.

4 8.

AUDITS Audita of unit activities chall be performed under the cognizance of the fiSRii. These audits shall encompass.

i The conf ormance of un.it operat ion to provisions cont ained a.

within the Technical Specifications and applicable Jirenne conditions at least once per 12 months.

b.

. The perf ormance, training and qualifications of the ent tre unit staff at least once per 12 months.

The results of actions taken to correct deficiencies c.

occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at icast l

once per 6 months.

d.

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B",10 CFR 50, at least once per 24 months.

The Site Radiological Emergency Plan and irrplementing e.

procedures at least once per 24 months.

e I

f.

The plant Physical Security Plan and Leptementing I

procedures; at least once per 12 months.

Any other area of unit operation conaldered appropriate g.

by ihe NSRB or the fianager of Power.

h.

~l he racili.ty Fire Protection Program and implementing procedurea at 1 cast once per 24 months.

1.

An independent fire protection and loss prevention Irogram inspecticn and audit shall be performed annually ut ili::ing either qualified of f site licensee personnel er an outside fire protection firm.

J.

An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals ao s;reater.than 3 years.

314

6.0 ADMIUJSTRATIVE CONTROLS 3

Dutica_ cod _Baguenuibiliting The fonc serrveu in an advisory capacity to the plant nuperintendent and as an. investigating and reporting body to the Nuclear Safety Review Board in matters related to safety in plant operations.

The plant superintendent has the final responsibility in determining the matters that should be referred to the Nuclear Safety Review Board.

The responsibility of the committee will include:

Review all standard and emergency operatietg a.

and maintenance instructions and any prop > sed revisions thereto, with principal attention to provisions for safe operation.

b.

Review proposed changes to the Technical Specifications.

c.

Review proposed changes to equipment or systems having safety significance, or which may constitute "an unreviewed safety question," pursuant to 10 CFR 50.59.

d.

Investigate reported or suspected incidents involving saf ety questions, violations of the Technical Specifications, and violations of plant instructions pertinent to nuclear safety.

Review reporthble occurences, unusual events, e.

operating anomalies and abnornal perf ormance of plant equipment.

f.

Maintain a general surveillance of plant activities to identify possible safety hazards.

g.

Review plans for special fuel handling, plant maintenance, operations, and tests or experiements which may involve special safety considerations, and the results thereof, where l

applicable.

h.

(deleted) 1.

Review implementating procedures of the Radiological Emergency Plan and the Industrial Security Program on an annual basis.

336 I

F UNIT 3

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,s TABLE 3.7. A PRIMARY CONTAINMD4T 1:DIATION VALVES M

s Number of Power Maxi *em Action on Operated Valves Operating Normal Initiatirq Group Valve Identification Inboard Outboard Tise (sec.)

Position Signal 1

Main steamline isolation valves 4

_4 3<T<5 0

GC

( FCV 14, 26, 37, & 51; 1-15, 27, 38552) 0 GC

-1 Main steamline drain isolation 1

1 15 valves (FCV-1-55 & 1-56) 1*

Reactor Water saspie line-isola-1 1

5 C

SC tion valves 2

RERS shutdown cooling supply isolation valves (PCV-74-48 5 47) 1 1

te C

SC s

2 RdRS - 1.PCI to reactor 2

30 C

SC (FCV-74-53 6 67) 2 Reactor vessel head spray isola-tion valves (FCV-74-77 & 78) 1 1

30 C

SC 2

RERS flush and drain vent to

'4 20 C

SC M

suppression chamber (FCV-74-102, 103, 119, & 120) 2 15 C

SC 2

Suppression Chamber Drain (PCV-7 5-57 6 58) 2 Drywell equlpment drain discharge isolation valves (FCV-77-15A 6 158) 2 15 0

cc 2

Drywell floor drain discharge isolation valves (FCV-77-2A & 28) 2 15 0

GC t

  • These valves isolate only on reactor vessel low low water level (470") and main steam li,ne high radiation of Group 1 isolations.

TABLE 3.7.A (Ccctinuzd)

Number of Power Maricum Action on Operated Valves Operating Norac1 Initiating Inboard Outboard Time (Sec.)

Position Signal Group

1 Valve Identification _

7,.

6 Suppression Chamber purge inlet (FCV-64-19) 1 2.5 C

SC 1

5 C

'SC 6

Drywell/ Suppression Chamber nitro-

' gen purge inlet (FCV-76-17) 6 Drywell Exhaust Valve Bypass to Standby Cas Treatment Systes (FCV-64 ~.1) 1 5

0 CC 6

Suppression Chamber Exhaust Valve

{

Sypass to Standby Cas Trcatment 1

5 0

CC System (FCV-64-34) 6 System Section Isolation Valves f

to Air Compressors A" and "B" 2

15 0

CC (FCV-32-62, 63) 6 Drywell/ Suppression Chamber Nitrogen 1

5 C

SC Purge Inlet (FCV-76-24) 6 Torus Hydrogea Sample Line Valves 2

NA Note 1 SC Analyzer A (FSV-76-55, 56) 6 Torus Oxygen Sample Line Valves 2

NA Note 1 SC Analyzer A (FSV 53, 54) 6 Drywell Hydrogen Sample Line Valves Analyzer A (FSV-76-49, 50) 1 1

NA Note 1 SC 6

Drywell Oxygen Sample Line Valves Analyzer A (FSV-76-51, 52) 1 1

NA Note 1 SC 6

Sample Return Valves - Analyzer A 2

NA 0

CC (FSV-76-57, 58) 6 Torus Hydrogen Sample Line Valves 2

NA Note 1 SC Analyzer B (FSV-76-65, 66)

6.0 ADMINISTRATIVE CONTROLS,

All written reports requiring 24-hour notification to the y,.

comminnIon.

h.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that,could affect nuclear safety.

L.

Reports and meeting minutes of the PORC.

8.

AUDITS Audits of unit activities shall be performed under the cognizance of the NSRB. These audits shall encompass.

The conformance of unit operation to provisions contained a.

within the Technical" Specifications and applicable. license conditions at least once per 12 months.

b.

The performance, training and qualifications of the entire unit staff at least once per 12 months.

The results of actions taken to correct deficiencies c.

occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at 1 cast once per 6 months.

d.

The performance of activities r.?' ired by the Operational Quality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, at least onca per 24 months.

The Site Radiological Emergency Plan and implementing c.

procedures at 1, cast once per 24 months.

f.

The Plant Physical' Security Plan and implementing procedures at least once per 12 months.

g.

Any other area of unit operation considered appropriate by the NSRB or the Manager of Power.

h.

The Facility Fire Protection Program and implementing procedures at least once per 24 months.

i.

An independent fire protection and loss prevention program inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

j.

An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.

364

6.0 ADMIllISTRATIVE CONTROLJ S.

Duticu_ sad _Ensuonsib111 ting The Poite serveu in an advisory capacity to -the plant superintendent and as an investigating and reporting body to the Nuclear ~ Safety Review Board in matters related to safety in plant operations.

The plant superintendent has the final responsibility in determining the matters that.

should be referred to the Nuclear Safety Review Board.

The responsibility of the committee will include:

a.

Review all standard and emergency operating and maintenance instructions and any proposed revisions thereto, with principal attention to provisions for safe operation.

b.

Review proposed changes to the Technical Specifications.

c.

Review proposed changes to equipment or systems having safety significance, or which may constitute "an unreviewed safety question," pursuant to 10 CFR 50.59.

d.

Investigate reported or suspected incidents involving safety questions, violations of the Technical Specifications, and violations 'of plant instructions pertinent to nuclear safety.

e.

Review reportable occurences, unusual events, operating anomalies and abnorpal performance of plant equipment.

I f.

Maintain a general surveillance of plant activities to identify possible safety hazards.

g.

Review plans for special fuel handling, plant maintenance, operations, and tests or experiements which may involve special saf ety considerations, and the results thereof, where applicable.

h.

(deleted) 1.

Review implementating procedures of the Radiological Emergency Plan and the Industrial Security Program on an annual basis.

366 L_

ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION TVA BFNP TS 176 SUPPLEMENT 1

(

Reference:

TVA letter from L. M. Mills to H. R. Denton dated September 14,1982 (TVA BFNP TS 176))

Unit 1 - page 250 Unit 3 - page 262 One of the proposed changes to this page is the addition of the following footnote to reactor water sample line isolation valves: "There valvea isolate only on reactor vessel low ' low water level (470") and main steam line high radiation of Group 1 isolations."

This change is for clarification only. The footnote has been added to more accurately represent the isolation trips for these valves. It does not change the intent of the technical specifications and does not degrade the safety of the plant.

NOTE: This proposed revision for unit 2 was made in the unit 2 reload 4 submittal (TVA BFNP TS 179).

The other proposed revision to page 250 of unit 1 was previously made in TS 176 (see' reference). It is proposed to change "FCV 74-57,-58" to "FCV 75-57,-58."

This corrects a typographical error.

Unit 1

.page 252 Unit 3 - page_264 1.

It is proposed to change the " Normal Position" of the drywell exhaust valve bypass to SBGT system (FCV 64-31) and the suppression chamber exhaust valve bypass to SBGT system (FCV 64-34) from normally closed to normally open.

The drywell to torus A P compressor was installed to reduce the consequences of the upward and downward loads on the torus during-l the initial vent clearing phenomena of a LOCA. event. In order for l

the /LP compressor to function as designed, valves FCV 64-31 and FCV 64-34 must be open. Apparently Table 3.7.A of the technical i

specifications and section 7 3 or the FSAR failed to get revised to l

reflect this modification. Plant safety is not reduced by making l

valves FCV 64-31 and 64-34 normally open since these are PCIS valves and will close upon receipt of isolation signal. This change will permit the drywell to torus A P compressor to function as designed L

and will increase plant safety.

NOTE: This proposed change for unit 2 was made in the unit 2 reload 4 submittal (TVA BFNP TS 176).

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. 2.

Change " Normal Position" of FCV 71-7A,7B from "0" to "C" and change " Action on Initiating Signal" from "GC" to "SC." The normal position of these valves is closed.

3 Change "FCV 75-57,58" to "FCV 73-6A,6B."

Thoes valve numbers were incorrectly placed in the table.

Proposed changes 2 and 3 were proposed first in TVA BFNP TS 176.

Units 1 and 3 - page 334 Unit 3 - page 364 it is proposed to change specification 6.2.A.8.f to reflect a 12-month audit cycle for plant physical security plan and implementing procedures.

NRC Inspection Report 50-259/82-20, -260/82-20, -296/82-20, Item 10, outlined the various sources which require an audit of the physical security program every 12 months, including 10 CFR 73 55, 10 CFR 50.45(p), and the Browns Ferry Physical Security Plan. It is proposed to ahange this specification to be consistent with these other regulatory requirements.

There will be no effect on plant safety as a result of this change.

This change makes the audit cycle more conservative than the current technical specification requirements of 24 months.

Units 1 and 2 - page 336 Unit 3 - Page 366 It is proposed to delete the requirement of Appendix A specification 6.2.B.4.h to have the Plant Operations Review Committee (PORC) review the QA program. The adequacy of the quality assurance program is charged'to the Manager, Quality Assurance and Audit Staff, by Section 17.2.1.1.3.d of TVA-TR75-1, Revision 5.

The program is audited (Section 17.2.1.1.3) and reviewed (Section 17 2.1.1 3 2.e) and the status checked (Section 17.2.1.1 3 3.d) by members of his organization. Additionally, the NUC PR Chief, Quality Assurance and Compliance Branch is responsible for performing an annual review of the status and adequacy of the operational quality assurance program and reporting the results to the Director of Nuclear Power and the Manager, Quality Assurance and Audit Staff (Section 17.2.1.1.6).

Technical specifications require the NSRB to biyearly review the quality assurance program for compliance with the requirements of Appendix B, 10 CFR 50, and annually review for compliance with Regulatory Guide 4.15.

PORC review is an unnecessary redundancy.

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