ML20077K217
| ML20077K217 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/04/1995 |
| From: | Salas P TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077K220 | List: |
| References | |
| TVA-BFN-TS-355, NUDOCS 9501100242 | |
| Download: ML20077K217 (16) | |
Text
4 q-TA Tennessee Valley Authority. Post Othce Box 2000 Decatur Alabama 35609 7
January 4, 1995 TVA-BFN-TS-355 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2 AND 3 -
TECHNICAL SPECIFICATION (TS) NO. 355 - REACTOR PROTECTION SYSTEM TS REQUIREMENTS FOR INTERMEDIATE RANGE MONITOR (IRM)
AND AVERAGE POWER RANGE MONITOR TRIP FUNCTIONS (APRM)
In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment (TS-355) to licenses DPR-33, DPR-52, and DPR-68 to change the TSs for Units 1, 2, and 3. The proposed change revises the applicability and surveillance requirements for IRM, APRM High Flux (15% Scram), and APRM Inoperative Trip Functions.
The IRM Reactor Protection System (RPS) Trip Functions are required to be functionally tested per TS Table 4.1.A at the minimum frequency of once per week during refueling and before each startup. APRM RPS High Flux (15% Scram) trip operability is required to be functionally tested per TS Table 4.1.A at the minimum frequency of weekly when required to be operable and before each startup. The IRM RPS High Flux Trip Function is required to be operable in the Startup/ Hot Standby, Shutdown and Refuel Modes. The IRM RPS Inoperative, APRM RPS High Flux (15% Scram), and APRM RPS Inoperative Trip Functions are required to be operable in the Startup/ Hot Standby and Refuel Modes. Also, the APRM RPS Inoperative Trip Function is required to be operable in the Run Mode.
As an enhancement, TVA proposes to adopt the Improved Standard Technical Specification (ISTS) (NUREG-1433) applicability and functional testing provisions for these
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9501100242 950104 PDA ADOCK 05CIOO259 - i P PM q )
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I U.S. Nuclear Regulatory Commission Page 2 January 4, 1995 trip functions. ISTS requires the functional test for each trip function to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Startup/ Hot Standby (Mode 2) from RUN (Mode 1) and every 7 days during applicable Modes. TVA proposes to adopt ISTS i provisions for Limiting condition.for operation applicability of Startup/ Hot Standby Mode and Refuel Mode with any control rod withdrawn from a core cell containing one or more fuel assemblies.
TVA has determined that there are no significant hazards .
considerations associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9) . The BFN Plant
- Operations Review Committee and the BFN Nuclear Safety Review Board have reviewed this proposed change and determined that operation of BFN Units 1, 2, and 3 in accordance with the proposed change will'not endanger the health and safety of 4 the public. Additionally, in accordance with -
10 CFR 50.91(b) (1) , TVA is sending a copy of this letter and i
enclosures to the Alabama State Department of Public Health.
Enclosure 1 to this letter provides the description and evaluation of the proposed change. This includes TVA's ,
determination that the proposed change does not involve a significant hazards consideration, and is exempt from environmental review. Enclosure 2 contains copies of the appropriate TS and bases pages marked-up to show the proposed change. Enclosure 3 forwards the revised TS and bases pages that incorporate the proposed change.
TVA requests that the revised TS be approved one month prior !
to Unit 3 fuel load, currently scheduled for November 1995, and made effective within 30 days of NRC approval. Deleting the requirement to perform the surveillance prior to each startup provides operational flexibility in planning the ,
Unit 3 power ascension while maintaining safety and ,
reliability. l t
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U.S. Nuclear Regulatory Commission Page 3 January 4, 1995 :
The proposed TS change also fulfills a commitment made [
, previously in Licensing Event Report (LER) 50-260/94009 and in TVA's response to NRC Violation 50-260/94-24-01. If you have any questions about this change, please contact me at
-(205) 729-2636.
Salas Manager of Site. Licensing Enclosures cc: See page 4 Subscribed and sworn t before me his 4th day of OxmaA 1995.
\ cuJ_ A.34 Notary Public mkslon Expires 10/06/SS My Commission Expires l
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U.S. Nuclear-Regulatory Commission Page 4 January 4~,.1995 k
Enclosures cc (Enclosures):- -
Mr. W. D. Arndt ;
General Electric Company 735 Broad Street Suite 804, James Building Chattanooga, Tennessee 37402 Mr. Johnny Black, Chairman -
Limestone County _ Commission 310 West Washington Street Athens, Alabama 35611 Mr. Mark S. Lesser, Section Chief U.S. Nuclear Regulatory Commission Region.II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer Alabama State Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-3017
s ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-355 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. DESCRIPTION OF THE PROPOSED CHANGE TVA is revising Units 1, 2, and 3 TS Table 3.1.A, Reactor Protection System (RPS) (Scram) Instrumentation Requirements, and Table 4.1.A, RPS Functional Test Requirements, to more closely reflect the requirements of the Improved Standard Technical Specifications (ISTS) for BWR/4s (NUREG-1433). Specifically, TVA proposes to adopt the requirements of ISTS Specification 3.3.1.1, Reactor Protection System, Limiting Condition for Operation (LCO)
Applicability and Surveillance Requirement (SR) 3.3.1.1.4 and SR 3.3.1.1.5 for the Intermediate Range Monitor (IRM),
Average Power Range Monitor (APRM) High Flux (15% Scram),
and APRM Inoperative Trip Functions.
The specific changes are described below.
- 1. Units 1 and 2, TS page 3.1/4.1-3, Technical Specification Table 3.1.A.
Current Instrumentation Requirement:
IRM High Flux and Inoperable Trip Functions are required to be OPERABLE during Startup/ Hot Standby and Refuel Modes. The IRM High Flux Trip Function is also ,
required to be OPERABLE in the Shutdown Mode.
Proposed Instrumentation Requirement:
Require the IRM High Flux and Inoperable Trip Functions to be OPERABLE only during the Startup/ Hot Standby Mode, and the Refuel Mode with any control rod withdrawn from a core cell containing one or more fuel assemblies. For the IRM High Flux Trip Function this is accomplished by deleting the "X" from the Shutdown Mode column and revising Note 22 as described in Item 5 below. For the IRM Inoperable Trip Function this is accomplished by making Note 22 applicable in the Refuel Mode. In addition, change the terminology 1 for the "IRM Inoperable" Trip Function to "IRM Inoperative" to make it consistent with Table 4.1.A l
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and Unit 3 Technical Specifications. Change the indentation for the IRM Inoperative Trip Function to match the IRM High Flux Trip Function.
- 2. Unit 3, TS page 3.1/4.1-2, Technical Specification Table 3.1.A.
Current Instrumentation Requirement:
IRM High Flux and Inoperative Trip Functions are required to be OPERABLE during Startup/ Hot Standby and Refuel Modes. The IRM High Flux Trip Function is also required to be OPERABLE in the Shutdown Mode.
Proposed Instrumentation Requirement:
Require the IRM High Flux and Inoperative Trip !
Functions to be OPERABLE only during the Startup/ Hot '
Standby Mode, and the Refuel Mode with any control rod withdrawn from a core cell containing one or more fuel assemblies. For the IRM High Flux Trip Function this is accomplished by deleting the "X" from the Shutdown Mode column and revising Note 22 as described in Item 6 below. For the IRM Inoperative Trip Function this is accomplished by making Note 22 applicable in the Refuel Mode. In addition, change the indentation for the IRM Inoperative Trip Function to match the IRM High Flux Trip Function.
- 3. Units 1 and 2, TS page 3.1/4.1-6, Notes For Table 3.1.A.
Current Note 21:
"The APRM High Flux and Inoperative Trips do not have to be OPERABLE in the REFUEL Mode if the Source Range . . .
Proposed Note 21:
"Only required with any control rod withdrawn from a core cell containing one ar more fuel assemblies. The APRM High Flux and Inoperative Trips do not have to be OPERABLE if the Source Range . . . "
- 4. Unit 3, TS ya;e 3.1/4.1-5, Notes For Table 3.1.A.
Current Note 21:
"The APRM High Flux and Inoperative Trips do not have to be OPERABLE in the REFUEL Mode if the Source Range . . .
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Proposed Note 21:
"Only required with any control rod withdrawn from a core cell containing one or more fuel assemblies. The APRM High Flux and Inoperative Trips do not have to be OPERABLE if the Source Range . . .
- 5. Units 1 and 2, TS Page 3.1/4.1-7, Notes For Table 3.1.A.
Current Note 22:
"The three required IRMs per trip channel is not
- required in the Shutdown or Refuel' Modes if . . . "
Proposed Note 22:
"Only required with any :.ontrol rod withdrawn from a core cell containing one or more fuel assemblies. For the IRM High Flux Trip Function, the three required IRMs per trip channel is not required if . . . "
- 6. Unit 3, TS page 3.1/4.1-6, Notes For Table 3.1.A.
Current Note 22:
"The three required IRMs per trip channel is not required in the Shutdown or Refuel Modes if . . . "
Proposed Note 22:
"Only required with any control rod withdrawn from a core cell containing one or more fuel assemblies. For the IRM High Flux Trip Function, the three required IRMs per trip channel is not required if . . . "
- 7. Units 1 and 2, TS page 3.1/4.1-8, Technical Specification Table 4.1.A.
Current Surveillance Requirement for IRM Trip Functions:
"Once/ Week During Refueling and Before Each Startup" Proposed Surveillance Requirement for IRM Trip Functions:
"Once/ Week (9)"
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- 8. Unit 3, TS page 3.1/4.1-7, Technical Specification Table 4.1.A.
Current Surveillance Requirement for IRM Trip Functions:
"Once Per Week During Refueling and Before Each Startup" Proposed Surveillance Requirement:
"Once/ Week (9)"
- 9. Units 1 and 2, TS page 3.1/4.1-8, TeC ;tica.
Specification Table 4.1.A.
Current Surveillance Requirement for AoM :1.gh lux (15% Scram) Trip Function:
"Before Each Startup and Weekly When Required to be Operable" Proposed Surveillance Requirement for APRM High Flux (15% Scram) Trip Function:
"Once/ Week (9)"
- 10. Unit 3, TS page 3.1/4.1-7, Technical Specification Table 4.1.A.
Current Surveillance Requirement for APRM High Flux (15% Scram) Trip Function:
"Before Each Startup and Weekly When Required to be Operable" Proposed Surveillance Requirement:
"Once/ Week (9)"
- 11. Units 1 and 2, TS page 3.1/4.1-10, Notes for Table 4.1.A.
Add Note 9 as follows:
"9. Not required to be performed when entering the STARTUP/ HOT STANDBY Mode from RUN Mode until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the STARTUP/ HOT STANDBY Mode."
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- 12. Unit 3, TS page 3.1/4.1-9, Notes for Table 4.1.A.
Add Note 9 as follows:
"9. Not required to be performed when entering the STARTUP/ HOT STANDBY Mode from RUN Mode until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the STARTUP/ HOT STANDBY Mode."
- 13. Unit 1 and 2, TS page 3.1/4.1-16, 3.1 Bases, second paragraph, second sentence.
Current Bases:
"Thus, the IRM is required in the REFUEL and STARTUP modes."
Proposed Bases:
"Thus, the IRM is required in the REFUEL (with any control rod withdrawn from a core cell containing one or more fuel assemblies) and STARTUP Modes."
- 14. Unit 3, TS page 3.1/4.1-15, 3.1 Bases, second paragraph, second sentence.
Current Bases:
"Thus, the IRM is required in the REFUEL and STARTUP modes."
Proposed Bases:
"Thus, the IRM is required in tha REFUEL (with any control rod withdrawn from a core cell containing one or more fuel assemblies) and STARTUP Modes."
- 15. Unit 1 and 2, TS page 3.1/4.1-16, 3.1 Bases, fourth paragraph.
Current Bases:
"The requirement to have the scram functions as indicated . . . does not diminish the need for the reactor protection system."
Proposed Bases:
Delete paragraph.
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- 16. Unit 3, TS page 3.1/4.1-15, 3.1 Bases, fourth paragraph.
Current Bases:
"The requirement to have the scram functions as indicated . . . does not diminish the need for the reactor protection system."
Proposed Bases:
Delete paragraph.
- 17. Unit 1 and 2, TS page 3.1/4.1-17, 4.1 Bases, second paragraph, Item C.
Current Bases:
"C. Devices which only serve a useful function during some restricted mode of operation, such as STARTUP or SHUTDOWN, or for which . . . "
Proposed Bases:
"C. Devices which only serve a useful function during some restricted mode of operation, such as STARTUP, or for which . . . "
- 18. Unit 3, TS page 3.1/4.1-16, 4.1 Bases, second paragraph, Item C.
Current Bases:
"C. Devices which only serve a useful function during some restricted mode of operation, such as ,
STARTUP or SHUTDOWN, or for which . . .
Proposed Bases:
"C. Devices which only serve a useful function during some restricted mode of operation, such as STARTUP, or for which . . . "
- 19. Unit 1 and 2, TS page 3.1/4.1-19, 4.1 Bases, second paragraph, second and third sentences.
Current Bases:
"For example, the IRM is active during STARTUP and inactive during full power operation. Thus, the only test that is meaningful is the one performed just prior to SHUTDOWN or STARTUP: 1.e., the tests that are performed just prior to use of the instrument."
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Proposed Bases:
"For example, the IRM is active during the STARTUP/ HOT STANDBY and REFUEL (with any control rod withdrawn from a core cell containing one or more fuel assemblies) Modes and inactive during full power operation. Thus, the only test that is meaningful is the one performed prior to entering the applicable Mode (i.e., the tests that are performed prior to use of the instrument). Since testing of the IRM functions is not practical in the RUN Mode, testing is not required to be completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the STARTUP/ HOT STANDBY Mode from the RUN Mode. Twelve hours is based on operating experience and in consideration of providing reasonable time in which to complete the test."
- 20. Unit 3, TS page 3.1/4.1-18, 4.1 Bases, second paragraph, second and third sentences.
Current Bases:
"For example, the IRM is active during STARTUP and inactive during full power operation. Thus, the only test that is meaningful is the one performed just prior to SHUTDOWN or STARTUP; i.e., the tests that are performed just prior to use of the instrument."
Proposed Bases:
"For example, the IRM is active during the STARTUP/ HOT STANDBY and REFUEL (with any control rod withdrawn from a core cell containing one or more fuel assemblies) Modes and inactive during full power operation. Thus, the only test that is meaningful is the one performed prior to entering the applicable Mode (i.e., the tests that are performed prior to use of the instrument). Since testing of the IRM functions is not practical in the RUN Mode, testing is not required to be completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the STARTUP/ HOT STANDBY Mode from the RUN Mode. Twelve hours is based on operating experience and in consideration of providing reasonable time in which to complete the test."
II. REASON FOR THE PROPOSED CHANGE The IRM Reactor Protection System (RPS) Trip Functions are currently required to be functionally tested per Technical Specification Table 4.1.A at the minimum frequency of once per week during refueling and before each startup. The APRM RPS High Flux (15% Scram) Trip Function is currently required to be functionally tested per Technical Specifications at a minimum frequency of before each l l
startup and weekly when required to be operable. To El-7 1
eliminate unnecessary testing and unavailability of Reactor Protection System instrumentation and for consistency with the Improved Standard Technical Specifications (ISTS), TVA proposes to adopt ISTS provisions for performance of these functional tests. ISTS requires the functional test to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Startup/ Hot Standby (Mode 2) from RUN (Mode 1) and every 7 days during applicable Modes. TVA also proposes to adopt ISTS provisions for LCO applicability (of Startup/ Hot Standby Mode, and Refuel Mode with any control rod withdrawn from a core cell containing one or more fuel assemblies) for the IRM High Flux, IRM Inoperative, APRM High Flux (15% Scram),
and APRM Inoperative Trip Functions.
Current Technical Specification (TS) Table 3.1.A requires that the IRM High Flux Trip Function be operable when the plant is in the Startup/ Hot Standby, Shutdown, and Refuel modes of operation. Current TS Table 3.1.A requires the IRM Inoperative, APRM High Flux (15% Scram), and APRM Inoperative Trip Functions to be operable in the Startup/ Hot Standby and Refuel modes. The APRM Inoperative Trip Function is also required to be operable in the Run Mode. However, the IRM High Flux Trip Function serves no useful purpose while in the Shutdown mode and the IRM, APRM High Flux (15% Scram), and APRM Inoperative Trip Functions serve no useful purpose in the Refuel mode when there are no control rods withdrawn from a core cell containing one or more fuel assemblies.
The changes to TS 3.1 and 4.1 Bases have been proposed to maintain consistency with the proposed Technical Specifications. One paragraph has been deleted since it no longer provides useful information.
The proposed changes will eliminate unnecessary tes* 'g and only require the IRM, APRM High Flux (15% Scram), an APRM Inoperative Trip Functions to be operable in the modes they are needed. The Technical Specifications will continue to require the IRM, APRM High Flux (15% Scram), and APRM Inoperative Trip Functions to be operable in modes where control rods can be withdrawn and the potential for criticality exists. BFN procedures require the removal of
" shorting links" to provide noncoincidence scram protection l from the Source Range Monitors (SRMs) when the IRMs and APRMs are inoperable. Changes to these procedures are controlled in accordance with the 10 CFR 50.59 process.
III. BAFETY ANALYSIS A. Design Considerations The Reactor Protection System provides timely l protection against the onset and consequences of l conditions that threaten the integrity of the fuel l
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barrier and the nuclear system process barrier. To provide protection for the fuel against high heat generation rates, neutron flux is monitored rad used to initiate a reactor scram.
The IRM subsystem monitors neutron flux from the upper portion of the source range to the lower portion of the power range. The IRM subsystem is the' primary source of information on the approach of the reactor to the power range. It has 8 IRM channels, each of which includes one detector that can be physically positioned in the core by remote control. The detectors are inserted into the core for a reactor startup and are withdrawn after the reactor mode selector switch is turned to "RUN." They are normally inserted any time the reactor is not at power.
The APRM channels receive input signals from the 43 local power range monitors (LPRMs) within the reactor core to provide an indication of the power distribution and local power changes. The APRM channels average these LPRM signals to provide a continuous indication of average reactor power from a few percent to greater than Rated Thermal Power (RTP).
The design basis setpoint for neutron monitoring in the STARTUP Mode is the APRM High Flux (15% Scram) trip.
The IRM, the APRM High Flux (15% Scram), and the APRM Inoperative Trip Functions must be OPERABLE during Startup/ Hot Standby when control rods may be withdrawn and the potential for criticality exists. In Refuel, they provide monitoring for and protection against unexpected reactivity excursions. Although current Technical Specifications require the IRM High Flux Trip Function to be operable in the Shutdown Mode, the trip function serves no useful purpose because rod withdrawal is precluded by the mode switch.
The IRM and APRM detectors and electronics are tested under operating conditions and verified to have the operational characteristics given in the description and, as such, provide the level of precision and reliability required by the Reactor Protection System safety design basis. Current Technical Specifications require the IRM and APRM High Flux (15% Scram) Trip Functions to be functionally tested before each startup and weekly during refueling (for the IRMs) or when required to be operable (for the APRM High Flux). 1 This could result in unnecessary testing if two startups occur within seven days of each other since i these trip functions will still be within the 7-day ;
periodicity of the functional test requirement but would still have to be retested due to literal interpretation of the Technical Specifications. The El-9
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l required periodic frequency has been determined to sufficiently verify that the IRMs and APRMs are properly functioning. Performing a reactor startup j does not impact the ability.of the monitors to perform i their required function. Therefore, an additional !
surveillance, required to be performed "before each startup," is unnecessary.
i B. Improved Standard Technical specifications one of the objectives of this proposed Technical ,
Specification is to make the requirements of the BFN '
Technical Specifications consistent with the requirements of the Improved Standard Technical Specifications (ISTS) for these IRM and APRM Trip Functions. NUREG-1433 is the ISTS for BWR/4s.
Section 3.3.1.1 provides the requirements for Reactor Protection System instrumentation. In summary, ISTS requires the IRM, APRM High Flux (15% Scram) and APRM Inoperative Trip Functions to be OPERABLE in Mode 2 (equivalent to BFN's Startup/ Hot Standby Mode), and Mode 5 (equivalent to BFN's Refuel Mode) with any control rod withdrawn from a cure cell containing one or more fuel assemblies. It also requires a ,
functional test to demonstrate operability within 12 r hours of entering Mode 2 from Mode 1 (equivalent to ;
BFN's Run Mode) and every 7 days while in applicable Modes. The APRM Inoperative Trip Function is also required to be OPERABLE in Mode 1.
The intent of the ISTS is to ensure that the IRM and APRM High Flux (15% Scram) functions are tested every 7 days (weekly) while in Mode 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies and within 7 days prior to startup. This is accomplished by requiring the functional test to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering Mode 2 from Mode 1 and weekly during applicable modes. The functional test is not required to be performed prior to entering Mode 2 from Mode 1, since testing of the Mode 2-required trip functions cannot be performed
- without utilizing jumpers, lifted leads, or movable links.
IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that eration of Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3 in accordance with the ,
proposed change to the technical specifications does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a) (1) , of the three standards set forth in 10 CFR 50.92(c).
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'A. The proposed amendment does n L involve a sianificant !
increase in the probability or consequences of an accident previousiv evaluated.
The proposed change revises the frequency of functional tests for the IRM and APRM High Flux (15% l Scram) Trip Functions and eliminates operability requirements for the IRM, APRM High Flux (15% Scram), '
and APRM Inoperative Trip Functions in certain modes of operation. The operation of these trip functions '
is not a precursor to any design basis accident or transient analyzed in the Browns Ferry Updated Final !
Safety Analysis Report. Therefore, this change does t not increase the probability of any previously evaluated accident. ;
The proposed change will eliminate the requirement to '
re-perform the functional tests for these trip functions prior to each startup if the test is within its periodicity (once per 7 days). It will also eliminate the operability requirement for the IRM High Flux Trip Function in the Shutdown Mode and IRM, APRM High Flux (15% Scram), and APRM Inoperative Trip. ,
Functions during the Refuel Mode except when any :
control rod is withdrawn from a core cell containing one or more fuel assemblies. The Specifications will ,
still provide for operability of the equipment in +
Modes where credit is taken in the safety analysis.
Therefore, this change does not increase the -
consequences of any previously evaluated accident.
B. The proposed amendment does not create the nossibility -
of a new or different kind of accident from any accident previously evaluated. ;
The proposed change to the Technical Specification requirements for the IRM, APRM High Flux (15% Scram) and APRM Inoperative Trip Functions does not involve a ,
modification to plant equipment. No new failure modes are introduced. There is no effect on the function of !
any plant system and no new system interactions are introduced by this change. Therefore, the proposed l amendment does not create the possibility of a new or r different kind of accident from any accident previously evaluated.
C. The Droposed amendment does not involve a significant reduction in a marcin of safety. i l
I The proposed change will eliminate the requirement to re-perform the functional test for the IRM and APRM High Flux (15% Scram) Trip Functions prior to each startup if the tests are within their periodicity i l
(once per 7 days). The proposed change will also i eliminate operability requirements for modes of ;
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operation in which the IRM, APRM High Flux (15% Scram) and APRM Inoperative Trip Functions provide no useful function. Since the ability of the trip functions to perform their safety function will not be degraded, the proposed amendment does not involve a reduction in a margin of safety.
V. ENVIRONMENTAL IMPACT CONSIDERATION The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the smounts of any effluents that may be release'3 offsite, or a significant increase in individual or ru.~ulative occupational radiation exposure.
Therefore, the pronosed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Accordingly, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.
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ENCLOSURE.2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-355 MARKED PAGES I. AFFECTED_PAGE_ LIST Unit 1 Unit 2 Unit 3 3.1/4.1-3 3.1/4.1-3 3.1/4.1-2 3.1/4.1-6 3.1/4.1-6 3.1/4.1-5 3.1/4.1-7 3.1/4.1-7 3.1/4.1-6 3.1/4.1-8 3.1/4.1-8 3.1/4.1-7 3.1/4.1-10 3.1/4.1-10 3.1/4.1-9 3.1/4.1-16 3.1/4.1-16 3.1/4.1-15 3.1/4.1-17 3.1/4.1-17 3.1/4.1-16 3.1/4.1-19 3.1/4.1-19 3.1/4.1-18 II. MARKED PAGES See attached.
,