ML20076H307
| ML20076H307 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/13/1983 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20076H294 | List: |
| References | |
| NUDOCS 8306160523 | |
| Download: ML20076H307 (5) | |
Text
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UNITS 1 AND 2 LIMITING CONDITIONS FOR O?ERATION SURVEILIJGICE REQUIREMENTS y
47 COFfAI180pT syst es 3.7 cowrAIMMENT SY"JJLs d.
Each train shall be operated a i
total of at l
least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.
e.
Test sealing of gaskets for housing doors shall be performed i
utilizing chemical smoke generators during each test perf ormed for compliance with specification 4.7.B.2.a and specification 3.7.B.2.a.
i' i
3.
From and af ter the 3.
a.
Once per date that one train operating cycle of the standby gas automatic treatment s'n. tem is initiation of made or found to be each branch of inoperable for any the standby gas reason, reactor treatment system operation and fuel shall be handling is demonstrated permissible only from each unit's 1
during the succeeding controls.
7 days unless such b.
At least once circuit is sooner per year manual made operable, operability of provided that during the bypass valve I
such 7 days all for filter active components of cooling shall be the other two standby demonstrated.
gas treatment trains shall be operable.
n 238 8306160523 830613 PDR ADOCK 05000259 P
UNIT 3 i
LIMITING CONDITIONS FOR O,7ERATION SURVEILLANCE REQUIREMENTS e
V 4.7 COlTTAI191ENT SYSTh48 3.7 coprAInnspT sYrnyJL8 e
d.
Each train shall be operated a total of at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.
e.
1tst sealing of gaskets for housing doors shall be performed i
utilizing chemical smoke generators during each test perf ormed for compliance with 3pecification 4.7.B.2.a and specification 3.7.B.2.a.
3.
From and after the 3.
a.
Once per date that one train operating cycle l
of the standby gas automatic treatment syttom is initiation of made or found to be each branch of inoperable for any the standby gas reason, reactor treatment system shall be
)
operation and fuel handling is demonstrated permissible only from each unit's l
during the succeeding controls.
7 days unless such b.
At least once l
circuit is sooner Per year manual made operable, operability of provided that during the bypass valve such 7 days all for filter active components of cooling shall be the other two standby demonstrated.
gas treatment trains shall be operable.
L 249 4
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ENCLOSURE 2 JUSTIFICATION AND EMERGENCY NATURE OF PROPOSED REVISION TVA BENP TS 189 BROWNS FERRY NUCLEAR PLANT The following discussion provides reasons why this emergency situation occurred and why it could not be avoided.
During a recent internal audit it was questioned whether technical specification annual surveillance requirement 4.7.B.3.a, which requires automatic initiation of each branch of the standby gas treatment system from each unit's controls was being fully satisfied. Investigation by the plant staff revealed that all requirements are being met, with the exception of several relays in the isolation logic circuits which are being tested once per operating cycle per Table 4.2.A rather than once per year per specification 4.7.B.3.a.
An interpretation that these relays should be tested as a part of the standby gas treatment logic scheme (spec-ification 4.7.B.3.a) resulted fran a review of standardized technical specifications for boiling water reactors and a review of a recent NRC inspection report for Hatch nuclear plant.
A review was made to detennine if all equipnent actuated by the It was surveillance testing could be tested with the units in service.
determined that several of the primary containment atmospheric control i
This is i
relays involved should not be tested with the units in service.
because various systems such as the reactor building ventilation system would be isolated during the test. Isolation of reactor building I
ventilation results in high steam tunnel temperatures which can result in
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unit trip and main steam line isolation.
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r.
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Table 4.2.A of the present technical specifications specifies a functional l
test frequency of once/ operating cycle for the group 2, 3, 6 and 8 logic components. Thus the frequency of testing for Table 4.2.A does not agree i
with the annual requirement of section 4.7.B.3.a.
In addition, the l
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e frequency of surveillance requirement 4.7.B.3.a does not agree with the once per refueling outage frequency implied in the Browns Fe'rry tech-nical specification bases for section 4.7.
Also, it does not agree with the once/ operating cycle frequency required in the BWR Standard Technical Specifications.
This emergency situation could not be avoided because the change in interpretation of what surveillance tests are required to satisfy section 4.7.B.3.a was only recently discovered. This situation was determined to exist by plant staff personnel only after a diligent effort to research and follow up on a TVA auditor's question, and after an effort to relate the recent Hatch violation to the Browns Ferry surveillance program.
Extensive research of plant drawings, related surveillance instructions, and BWR Standardized Technical Specifications was involved in determining 3
that existing surveillance test frequencies do not fully satisfy section 4.7.B.3.a.
Unless revised by July 3, 1983, the existing technical specification will require a unit shutdown to perform this testing.
We believe that the above discussion of this situation qualifies this requested technical specification revision as an emergency per 10 CFR 50.91.
ENCLOSURE 3 SIGNIFICANT HAZARDS CONSIDERATION FOR TECHNICAL SPECIFICATION CHANGE TVA BFNP TS 189 BROWNS FERRY NUCLEAR FLANT 1.
Does the proposed amendment involve a significant increase in the
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probability of consequences of an accident previously evaluated?
No. Be tests and inspections presently being perfonned on the Standby Gas Treatment System instruments and controls will not be changed by this amendment. B e proposed amendment involves only a change in test frequency from annually to once per operating cycle, Section 5.3 5.2 of the FSAR specifies that the instruments and controls will be tested periodically. Routine testing which requires unit shutdown is normally required to be done at a once per operating cycle frequency.
2.
Does the proposed amendment create the probability of a new or different kind qf accident frce any accident previously evaluated?
No. He test and inspections will not change; only the frequency of test and inspections will change. Berefore, the amendment will not create the possibility of a new or different kind of accident from any previously evaluated.
3 Does the proposed amendment involve a significant reduction in a margin of safety?
No. Be margin of safety will not be reduced but may potentially increase because the unit will not have to be shutdown for this test, and therefore will rot experience the transients associated with a unit shutdown. Be once per operating cycle test frequency is adequate to detect equipment deterioration prior to significant defects. H e test frequency requested -is that presently specified in BWR Standardized Technical Specifications.
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