Text

Proposed Tech Specs,Incorporating Improved TS (ITS) Bases Revs & Changes to Supporting Documentation Resulting from Responding to NRC Questions
	ML20198Q452
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Issue date:	11/05/1997
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JUSTIFICATION FOR CHANGES SECTION 2.0 - SAFETY LINITS ADMINISTRATIVE CHANGES Al Reformatting and renumbering are in accordance with the BWR Standard Technical Specifications, NUREG-1433. As a result the Technical Specifications should be more readily readable, and therefore, understandable by plant operators as well as other users.

The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is done to make consistent with NUREG-1433. During ITS development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) to the Technical Specifications. Addit 19nal infomation has also been added to more fully describe each subsection. This wording is consistent with the BWR Standard Technical Specifications, NUREG-1433.

Since the design is already approved, adding more detail does not result in a technical change.

A2 The reactor pressure limit unit of measure has been changed from psia to psig.

In addition, the requirement for when the MCPR limit is applicable has been reduced sligi.tly (by adding the " equal to" sign) for i

consistency with the BWR Standard Technical Specifications, NUREG-1433.

The limit on core flow is now specified as greater than or equal to.

The current Safety Limits do not address the situation when core flow is equal to the limit. While these changes are actually more restrictive, 1

since they are so minor, they are considered an administrative change.

A3 The Safety Limits were reworded without changing the intent of the Safety Limit (no technical changes were made).

Editorial rewording is consistent with the BWR Standard Technical Specification, NUREG-1433.

During its development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) to the TS. Units for pressure has been l

changed from psia to psig, t

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u BFN-UNITS 1, 2, & 3 1 of 4 Revision 2

JUSTIFICATION FOR CHANGES SECTION 2.0 - SAFETY LIMITS ADMINISTRATIVE CHANGES (continued)

A4 The ' equal to" was taken out of "les; than or equal to" symbol.

This l

was cone for consistency with the current BFN Bases for the Safety Limit which states that a core thermal power limit of 25 percent for reactor pressures below 800 psia (785 psig) is conservative. This is also consistent with NUREG-1433. Also the ' equal to' was taken out of 'less than or equal to" symbol as it relates to rated core flow to maintain consistency between the current technical specifications and NUREG-1433.

TECHNICAL CHANGES - MORE RESTRICTJJJ The itr.as identified a:. tore Restrictive (MR) are those which contain requirements that are more restrictive than Current Technical Specifications.

These MR requirements are based on the Standard Technical Specifications for BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been detemined to be appropriate and safe for BFN based on a review of current design bases.

M1 A new 2.2 requirement is added to the Safcty Limit Violations Section, which requires all SLs to be restored and all insertable rods inserted within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Exceeding a Safety Limit may cause fuel damage and create a potential for radioactive releases in excess of 10 CFR 100 l

limits. These requirements ensure that the operators take prompt l

remedial action and also ensure that the probability of an accident l

occurring when a Safety Limit is violated is minimal.

l l M2 The existing CTS Safety Limit was changed from 1575 psig at the lowest l

l point of the reactor pressure to reactor steam dome pressure of 1325 l

psig.

Pressure at the vessel botton is not directly measurable and l

reactor dome pressure instrumentation is used to verify the safety limit l

1s met by adding the static water height above the vessel bottom to the l

measured reactor steam dome pressure. The value of 1325 psig is j

conservative since the elevation difference is less than the equivalent l

height of 50 psig. The cycle-specific pressurization transients show l

that considerable margin exists to vessel pressure limits, hence, the l

use of a conservative value is not expected to result ir cperating j

limitations or inappropriate determinations of safety limits violations.

l Also, the CTS safety limit is applied only when irradiated fuel is in l

j the vessel whereas the proposed iTS is applicable at all times. Since, l

however, there are no planned or anticipated operational activities that l

would involve vessel pressurization with no fuel in the vessel, this l

l more restrictive requirement has no effect on plant operations.

BFN-UNITS 1, 2, & 3 2 of 4 Revision 2

JUSTIFICATION FOR CHANbES SECTION 2.0 - St.FETY LIMITS TECHNICAL CHANGES - LESS RESTRICTIVE

" Generic" LAl BFN proposes the requirements related to Safety Limit Violation reporting and restart authorization not be retained in Technical -

Specifications. Duplication of the regulations provided in 10 CFR 50.36, 50.72 and 50.73 is not necessary to assure safe operation of the

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facility. The current regulations require BFN to perform all the actions. currently required by Technical Specifications. This change is consistent Technical Specification Change Traveler TSTF-5 (approved by NRC on 11/27/95) and Revision 0 to Generic Change BWROG-09, which addressed several NRC and Industry initiatives to improve the content and presentation of Administrative Controls.

" Specific' L1 The proposed change deletes the " Power Transient" Safety Limit. The intent of this Safety Limit was to ensure that other Safety Limits are not axceeded. This Safety Limit is assumed to be exceeded when a scram is accomplished by ceans other than the expected scram signal. The i

scram setpoints a e established in order to ensure margin to the safety limits.

Exceeding.the scram setpoint, in and of itself, does not necessarily indicate that a Safety Limit has been exceeded. Section 2.1.B of the present BFN TS contains six power tr'ansient trip settings that initiate a reactor scram. These scram setpoints are included in Table 3.3.1.1-1 of the new ITS. The surveillance requirements imposed on these scram setpoints in Table 3.3.1.1-1 help to ensure that the t

margin to a safety limit is preserved. The redundancy built into the RPS system is maintained by the action provisions of. ITS 3.3.1.1.

Therefore, the intent of present Power-Transient Safety Limit 1.1.B is I

maintained by the proposed provisions in ITS 3.3.1.1 for the RPS.

Additionally, although the proposed changed deletes the requirement for assuming the Safety Limit is exceeded when scram is accomplished by means other than the expected scram signal, the proposed change does not preclude the required actions if the Safety Limit is actually violated.

J BFN-UNITS 1,.2, & 3 3 of 4 Revision 2 a

JUSTIFICATION FOR CHANGES SECTION 2.0 - SAFETY LINITS TECHNICAL CHANGES - LEss RESTRICTIVE (continued)

L2 The current Safety Limit for_ the reactor vessel water level is that level shall be maintained not less than 372.5 inches above vessel zero.

The proposed Safety Limit is that level should be greater than the top of the active irradiated fuel. Rather than specify a specific water level, the proposed change ties the Safety Limit to its bases of maintaining adequate core cooling, which is accomplished by ensuring

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water level is maintained above the top of active fuel.

The change is considered less. restrictive because the current specific level listed in the specifications is being removed. This is acceptable for the following reasons:

It is not necessary to specify the precise water level corresponding to the actual top of active irradiated fuel in order to establish the requirement to maintain level above this point. This change will not alter assumptions relative to mitigation of an accident or transient event. This change is consistent with the currer.t safety analysis assumptions that assume water level does not drop below 2/3 core height. The analysis assumes that by maintaining water level above the top of the active irradiated fuel, a point is provided that can be monitored and also provides adequate margin above 2/3 core height for effective action.

The change still ensures adequate margin for effective action in the event of a level drop. This change is consistent with NUREG-1433.

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BFN-UNITS 1, 2, & 3 4 of 4 Revision 2 I

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ITS Section 3.2 Power Distribution Limits Enclosure Contents.

Enclosed?

Response to NRC questions.

Yes Summary Description of ITS/ITS BASES Changes.

Yes ITS Revised Pages.

............... N/A ITS BASES Revised Pages.

Yes CTS Markup Revised Pages.

Yes Justifications for Changes to CTS (DOCS)

Revised Pages.

Yes NUREG-1433 BWR/4 STS Mark-up Revised Pages.

N/A NUREG-1433 BWR/4 STS Bases Markup Revised Pages Yes Justification for Changes to NUREG-1433 (JDs) e Revised Pages

................... N/A No Significant Hazards Considerations Revised Pages. Yes Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433.

Yes I

Response to NRC Questions f

ITS Section 3.2 3.2.1 NRC Description ofIssue statement: None NRC Comment: Providejustification for your plant relative to impact on

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- licensing basis, system design, and operational constraints.

Response: CTS DOCS M1 and M2 have been revised to provide additional discussion of these more restrictive changes.

3.2.1-2 ' NRC Description ofissue statement: In the event that the APLHGR cannot be restored within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , CTS 3.5.1 requires placing the plant in COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . With the same conditions present, ITS 3.2.1 REQUIRED ACTION B.1 requires reducing thermal power to <25% of RATED THERMAL POWER within four hours. The final condition (<25% RTP in the ITS vs. COLD SHUTDOWN CONDITION in the CTS), is a higher power level / MODE and that is a less restrictive change which has not been discussed.

NRC Comment: Provide justification for this less restrictive change.

The licensee submittal indicated that because CTS 1.0.C.1 states that action requirements are applicable during the operational conditions of each specification., the requirement to place the plant in cold shutdown is not applicable after thermal power is reduced below 25% RTP. However, the requirements of CTS 1.0.C.1 and CTS 3.5.1 conflict in this case and the most restrictive would be used.

Response: We agree with NRC comment. A new less restrictive DOC (L2) has been added to address this item.

3.2.2 1 NRC Description ofIssue statement: None NRC Comment: Provide justification for your plant relative to impact on licensing basis, system design, and operational constraints.

Response: CTS DOCS Mi and M2 have been revised to provide additional discussion of these more restrictive changes.

3.2.2-2 NRC Description of/ssue statement: CTS 3.5.K require observing the i

Minimum Critical Power Ratio (MCPR) limits during steady state power operation. ITS 3.2.2, Applicability, requires that MCPR limits be observed with i

TITERMAL POWER 225% RTP. Since the ITS does not enforce MCPR limits 1

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4 below 25% RATED THERMAL POWER, even if the plant is in steady state conditions, this is a less restrictive change.

NRC Comment! Provide justification for this less restrictive change.

Response: Based upon CTS 4.5X.1, MCPR is currently required to be checked daily during reactor power opera 6on at greater than or equal to 25% Rated Thermal Power (RTP). This equates to the applicability requirement of the ITS of" Thermal Power 2 25% RTP."" Steady State"in CTS means that the MCPR limit should be monitored when the reactor power level is not changing (due to rod movement or flow control) which could diminish the accuracy of the process computer calculations. In practice, rod movement and flow control, are temporarily halted in order to perform the corresponding surveillance.

Therefore, incorporation of the ITS results in no changes in application and the current administrative category is appropriate.

3.2.2-3 NRC Description of/ssue statement: In the event that the MCPR cannot be restored within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , CTS 3.5.K requires placing the plant in COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . With the same conditions present, ITS 3.2.2, REQUIRED ACTION B.1, requires reducing thermal power to <25% of RATED THERMAL POWER within four hours. The final condition (<25% RTP in the ITS vs. COLD SHUTDOWN CONDITION in the CTS), is a higher power level / MODE and that is a less restrictive change which has not been discussed.

NRC Comment: Providejustification for this less restr:a change.

The licensee submittal indicated that beca ise CTS 1.0.C.1 states that action requirements are applicable during the ope ational conditions of each specification., the requirement to place the phat in cold shutdown is not applicable afler thermal power is reduced below 25% RTP. However, the requirements of CTS 1.0.C.1 and CTS 3.5.K conflict in this case and the most restrictive would be used.

Response: We agree with NRC comments. A new less restrictive DOC (L?)

has been added to address this item.

3.2.3.1 NRC Description ofIssue statement: None NRC Comment: Same as 3.2.2-1 Response: CTO DOCS M1 and M2 have been revised to provide additional discussion of these more restrictive changes.

3.2.3-2 NRC Description ofIssue statement: CTS 3.5.3 requires LHGR limits be observed during steady state power operam. ITS 3.2.3, Applicability, requires that LHGR limits be observed with THERMAL POWER 225% RTP. Since the Page 2

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ITS does not enforce LHGR limits below 25% RATED THERMAL POWER, even if the plant is in steady state conditions, this is a less restrictive change.

NRC Comment: Provide justification for this less restrictive change.

. Response: Based upon CTS 4.5.J.1, LHGR is currently required to be diecked daily during reactor power operation at greater than or equal to 25% RTP. This ~

equates to the applicability requirement of the ITS of" Thermal Power 2 25%

RTP." " Steady State" in CTS means that the LHGR limit should be monitored when the reactor power level is not changing (due to rod moveme.nt or flow control) which could diminish the accuracy of the process computer calculations.

In practice, rod movement and flow control, are temporarily halted in order to perform the corresponding surveillance. Therefore, incorporation of the ITS results in no changes in application and the current administrative category is appropriate.

3.2.3 NRC Description of/ssue statement: In the event that the LHGR cannot be restored within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , CTS 3.5.J requires placing the plam in COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . With the same conditions, ITS 3.2.3, REQUIRED ACTION B.1, requires reducing thermai power to <25%

of RATED THERMAL POWER within four hours. The final condition (<25%

RTP in the ITS vs. COLD SHUTDOWN CONDITION in the CTS), is a higher power level / MODE and that is a less restrictive change which has not been discussed.

NRC Comment: Providejustification for this less restrictive change.

The licensee subr',ittalindicated that because CTS 1.0.C.1 states that action requirements are applicable during the operational conditions of each specification., t1e requirement to place the plant in cold shutdown is not applicable after thermal power is reduced below 25% RTP. However, the requirements of CTS 1.0.C.1 and CTS 3.5.J conflict in this case and the most restrictive would be used.

Response: We agree with NRC comments. A new less restrictive DOC (L2) has been added to address this item.

3.2.4.1 NRC Description ofissue statement: None NRC Comment: Same as previous Response: CTS DOCS M1 and M2 have been revised to provide additional discussion of these more restrictive changes.

3.2A-2 NRC Description ofIssue statement: In the event that the ratio of FRACTION RATED POWER (FRP) to CORE MAXIMUM FRACTION LIMITING POWER DENSITY (MFLPD)is <l.0, CTS 3.5.L.1 requires that the APRM Page 3

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1 Scram and Rod block setpoint be reduced by the fraction FRP/MFLPDf ITS 3.2,4 requires that either MFLPD be less than or equal to FRP (implying that

- FRP/MFLPD is 21.0), OR APRM Scram and Rod Block setpoints be reduced,

' OR APRM gains be adjusted such that APRM readings are 2100% times l

MFLPD. CTS 3.5.L.1 adds the ITS 3.2.4 option to allow increasing the APRM gains to cause the APRM to read 2100% times MFLPD. Allowing APRM gain adjustment to compensate for MFLPD > FRP is a less restrictive change that is not justified.

NRC Comment: The justification is acceptable, however, it is a less restrictive change.

Response: As explained in DOC A2 for ITS 3.2.4, to satisfy CTS 3.5.L, current practice is to adjust APRM gains or to adjust the scram / rod block lines by a ratio of FRP/CMFLPD. Either action maintains the required margins to scram and rod block trip setpoints. In ITS, the APRM gain e.djustment method is explicitly listed. Since there is no change in actual methods, this change is appropriately categorized as administrative.

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Summary Description of ITSIITS Bases Changes ITS Section 3.2 ITS Changes None ITS Bases Changes Updated GESTAR references for Unit 1, 2,

and 3 page B3.2-3 and page B3.2-7 to latest approved version

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BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.2 LIST OF REVISED PAGES UNIT I ITS BASES SECTIONS :

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).d If the APLHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months hfter THERMAL POWER is a 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. They are compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER a 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

REFERENCES 1.

NEDE-240ll-P-A-13 " General Electric Standard Application for Reactor Fuel," August 1996.

2.

FSAR, Chapter 3.

3.

FSAR, Chapter 14.

4.

FSAR, Appendix N.

5.

NEDC-32484P, " Browns ferry Nuclear Plant Units 1, 2, and 3, SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," Revision 1, February 1996.

6.

NRC No.93-102, " Final Policy Statement on Technical Speci?ication Improvements," July 23, 1993.

BFN-UNIT I B 3.2-3 Amendment *R1

MCPR B 3.2.2 BASES (continued) i SURVEILLANCE SR 3.2.2.1

. REQUIREMENTS The MCPR is-required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is a 25% RTP and then every-24 hours thereafter.

It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of-the _ slowness of changes in power distribution during nomal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER = 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels SR '3.2.2.2 Because the transient analysis takes credit for conservatism in-the scram speed performance, it must be demonstrated that the specific scram-speed distribution is consistent with o

that used in the transient analysis. SR 3.2.2.2 determines l

the value of r, which is a measure of the actual scram speed distribution compared with the assumed distribution. The MCPR operating-limit is-then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4,' Control Rod Scram Times") and Option B (realistic scram times) analyses.

The parameter r must be detemined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1 and SR 3.1.4.2 because the effective scram speed distribution may change during the cycle. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due-to the relatively minor changes in r expected during the.

fuel cycle.

REFERENCES-1.

NUREG-0562, " Fuel Rod Failure As a Consequence of Departure from Nucleate Boiling or Dryout," June 1979.

2.

NEDE-24011-P-A-13, " General Electric Standard Application for Reactor Fuel," August 1996.

3.

FSAR, Chapter 3.

4.

FSAR, Chapter 14.

(continued)

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APLHGR-B 3.2.1 BASES ACTIONS RJ (continued)_

If the APLHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is E. 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. They are compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months I

Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution j

during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER at 25% RTP is achieved is acceptable given the large inherent margin to operating limits at lo power levels.

I REFERENCES 1.

NEDE-240ll-P-A-13 " General Electric Standard Application for Reactor Fuel," August 1996.

l 2.

FSAR, Chapter 3.

l 3.

FSAR, Chapter 14.

4.

FSAR, Appendix N.

l 5.

NEDC-32484P, " Browns Ferry Nuclear Plant Units 1, 2, and 3, SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," Revision 1, February 1996.

l 6.

NRC No.93-102, " Final Policy Statement on Technical Specification Improvements," July 23, 1993.

1 l

i BFN-UNIT 2-B 3.2-3 Amendment *R1

MCPR-B 3.2.2 BASES (continued)

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The MCPR is required to be initially calculated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

It is compared to the specified limits

~

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is a 2 d RTP and then every' in the COLR to ensure that the reactor is operating within 1

the assumptions of the safety analysis. The 24 hour-Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER = 25% RTP is achieved is acceptable given the large. inherent margin'to operating limits at low power levels.

SR 3.2.2.2 Because the transient analysis takes credit for conservatism in the scram speed performance, it must be demonstrated that tho' specific scram speed distribution is consistent with that used in the transient analysis. SR 3.2.2.2 determines the value of r, which is a measure of the actual scram speed distribution compared with-the assumed distribution. The MCPR' operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4," Control Rod Scram Times") and Option B (realistic scram times) analyses. The parameter r must be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1 and SR 3.1.4.2 because.the effective scram speed distribution may change during the cycle. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable dus to the' relatively minor changes in r expected during the

-fuel cycle.

REFERENCES 1.

NUREG-0562, " Fuel Rod Failure As a Consequence of Departure from Nucleate Boiling or Dryout," June 1979.

2.-

NEDE-24011-P-A-13. " General Electric Standard Application for Reactor Fuel," August 1996.

3.

FSAR, Chapter 3.

4.

FSAR, Chapter 14.

(continued)

BFN-UNIT 2 B 3.2-7 Amendment *R1

.. -. _ _ _ -.. _ _.... ~.

- BRO _WNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.2 -

LIST OF REVISED PAGES --

UNIT 3 ITS BASES SECTIONS Replaced page B3.2-3 with B3.2 3 Raision 1

' Replaced page B3.2-7 with B3.2-7 Raision 1 m-

=En g _

e WW. -

4..s e

i t

1-e 4

e y

,-w m

nUr-r-,-

c

--nt--r-y-

+.,,r,,

.o.,-a e

'v

4 1

APLHGR 8 3.2.1 PASES.

ACTIONS.

L1 (continued)-

If the APLHGR cannot be restored to within its required i

limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LC0 does not apply. -To achieve this status,~ THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The-allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in en orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 2: 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. They are compared to the specified-limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation.- The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months al'owance after THERMAL POWER a: 25% RTP is achieved is -acre table given the large inherent margin to operating limits s: low power

-levels.

REFERENCES 1.

NEDE-24011-P-A-13 ' General Electric Standard l

Application for Reactor Fuel," August 1996, u

2.

FSAR, Chapter 3.

]

t 3.

FSAR, Chapter 14.

4.

FSAR, Appendix N.

l 5.

NEDC-32484P, " Browns Ferry Nuclear Plant Units 1, 2, and 3, SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," Revision 1. February 1956.

6.

NRC No.93-102, " Final Policy Statement on Techr

cal Specification Improvements," July 23, 1993.

1 BFN-UNIT 3 B 3.2-3 Amendment *R1

MCPR B 3.2.2 BASES (continued)

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The MCPR is required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is a 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereaftsr.

It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumpt hns of the safety analysis.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering. judgment and recognition of the slowness of changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER a 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

SR 3.2.2.2 Because the transient analysis takes credit for conservatism in the scram : peed performance, it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis.

SR 3.2.2.2 determines the value of r, which is a measure of the actual scram speed distribution compared with the assumed distribution. The MCPR operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4," Control Rod Scram Times") and Option B (realistic scram times) analyses. The parameter r must be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1 and.SR 3.1.4.2 because the effective scram speed distribution may change J

during the cycle.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due to the relatively minor changes in r expected during the i

fuel cycle, j

REFERENCES 1.

NUREG-0562, " Fuel Rod Failure As a Consequence of Departure from Nucleate Boiling or Dryout," June 1979.

j 2.

NEDE-240ll-P-A-13, " General Electric Standard Application for Reactor Fuel," Augu:t 1996.

3.

FSAR, Chapter 3.

4.

FSAR, Chapter 14.

(continued) l l

BFN-UNIT 3 8 3.2-7 Amendment *R1 l

l

BROWNS TTIRRY NUCLEAR PLANT. IhtPROVED TECHNICAL SPECIFICATIONS SEC110N 3.2 LIST OF REVISED PAGES UNIT I CTS htartup Replaxd CTS 3.2.1 page 2 of 2 (page 3.5/1.518) with CTS 3.2.1 page 2 of 2 (page 3.5/4,$.18) rnision 1 Replaced CTS 3.2.2 page 2 of 3 (page 3.5/4.519) with CTS 3.2.2 page 2 of 3 (page 3.$/4.519)inision 1 Replaced CTS 3.2.3 page 3 of 3 (page 3.3/4.519) with CTS 3.2.2 page 3 of 3 (page 3.5/4.519) rnision 1

Ng

=

W 9

i e

Rev.I Spos.i/e. L w 31 I i

a a..

=

MAYtc1993 l

t--. - x= u n

=

e--- > m-

/O i

l g Aumenna Planar tinaar Heat Averama Pl==a r tinaar Gamaration tata Emat Ganaration kata __

i h yl.d. Q M

N fg i.2 4 L i

Ias AFLNGE shall be checked ring steady-state power operation a

/tae Average raanar Linear Seat daily during reacter (dassembly at aar axial locaties aball Genersties Rate (AFL8GE) of aar fuel operation at i 155 rated Lte thermal power.

/.a.1

{met exceed the appropriate AFLE.lt limit provided in the C0tX OPERATI138 f'Y' d ^

5') e y 12MITS REP 0tT.

If at any time

I E 82II during steady state operation it is determined by aermal surveillance that the limiting to being exceeded, etiv.shgli dd pas lated within minutes te rest oraties t ithin t preacrib limital If the AFLEGE is (Retreturnedtowithintheprescribed F1 limits within two (2) heure, the P

'reacter shall be brosshe tenEe:55E~3 g,ghp E

g

.s

~^

/3arvetAAnase se s s..y l

ac shall con unti eter h

operat is within the prescrib limits. /

l J.

Llamar Raat cameration mate (f ue")

J.

Linaar Beat Canaration tata ' l 11 eel During steady-state power sparaties, the LEGE aball be checked the linear heat generaties rate daily during reacter sparaties.

(LEit) of aar red in aar fuel at i 155 rated thermal power.

assembly at par axial locaties aball l

not asseed the appropriate LEGE

[

k limit provided in the CORE O QIxrtsnaroar.

S*s ;f.s L C e d i 4 - (t,s,,,

h e e ve) arr 1.z l i

are 3.s/4.5-is MDW M.197

. m1 r-i-m t

c a.

f d. [

S p e d.,lio m 12. t.

e

. --na-.

FEB 2 41H5 6U _ _ _. -- -e ---..=rrn u.- - = = = = - - -

e-- - r-y.J Limaar meat cenaration Rate (Lace) 4.5.J Linaar Emat Gearation tata (1.act)

~

3.5.J (C6st'd)

If at any time during steady-state operation it is determined by aermal surveillance that the limitims'value for IJGE is being See Sv /et a he a b ( by escoeded, actica shall be

/,,.#/N fJr J. a.3 initiated within 15 minutes to restore operatism to within the 1

prescribed limits.

If the LEGE is j

met returned te vitkin the i

prescribed limits within two (2) hours, the reacter shall be brought to the COLD S ETDOWN

]

CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

I Surveillance and corresponding 4

acties shall contisse untti reseter operaties is within the

)

g rescribed limits.

p,,W 19. h.. & JeIt :

MMinism Critical Pavar Ratia

?.1.f Rinimma critical Power M

tatie (BEF11 3 R, 1.3 L I -

I[Theminianacriticalpowerratie

'1.

NCFt shall be checked daily (NCFR) aball be equal to or during reacter power 4.c o J greater than the operating limit operatica at 2. 255 rated _

1.12.

HCPR (0!JICFR) as provided in the thermal power _Jaa rollowtag\\

i CORE OPERATIM LIMITS REP 0t!.

4 saanse la power &(vel g

If at aar timefrGTa7s I

er([stribe that vDald toady-stata===***t== lit is h

esase D ratica ith a determined Wy aermal LIMITIM CONTROL R0D serveillance that the limitias vales for NCFR is beirna f( J. 74 i

gwg penseeded,fattes amall be 2.

".as NCFR limit at rated A

ti og withia 1F ulastema e flew and rated power shall estere les te within the be deterutined as provided reestibed limites at taa la the CORE OPERATI M staaer-etati NCFR is met LIMITS REPORT 4 stas returned te witkis the j

presaribed limits within two (2) g beurs, the reaeter = hall be O as defined la the Acr.w bbreaght te F ^-__" 1. J C g CORI O LIMITS S

JC00H W45- & ^; b r,

REP 0tf prior initial SWrfiTIramiii~aWrresponsing LM seren time as eats set shall e 5 unti k the cycle,

,h reset operaties It within tTe par la accordance grescribed limits. ;

with 8 ification

)

4.3.C.1.

j L

ars 3.5/4.5-19 ANMDW M.216 cait 1 e as% AT P M

,,ih, k e as PAGE A

OF_ l

Rex. I

\\

Spesn'0ml,'os f 2.3

\\

FD 14 e5 u

eeem.--n a._

(ED__summmasrugmanzm u_m,-

-== ru ;. u.n a M Linear Heat ceneration late (tact) d Linear Beat Janaration fata (LEG 1)

A---

s.._.

.i

.~.

If at any time during steady-state e?hratJon At is determined by a vaal surveillance that the 10miting value for LEGE is betas N Teo d exceededi fetica shall De h

t ed withia M 1iltes to 4

estere ration to withia rescribed 1 M 'ar If the LEGR is met returned to within the prescribed limits within two (2) hosts, the reactor shall be

<, t s 4 kv M'*

n.

a

.. n W....r

.n acti hall ces se unti j

f h

reactor raties is thin

/r, y g,,,j,,, 4 c (/,,,3, grescribed limits.j

, u #F' s e er.f.2.a.

,,K Minimum Critieml Power Ratin 4.5.K Minianum critical Power 7 M

Ratin UICP1)

The minime critical power ratie 1.

McFR shall be checked daily (MCFR) aball be equal to er during reactor power greater than the operating limit operaties at 2,255 rated MCFR (0!JICFR) as provided in the thermal power and fo11eving CORI OPERATING LIMITS REP 0t!.

any change in power level if at anF time during er distributies that would assady-state operaties it is cause operation with a determined bF noraal LIMITIM CORTROL 300 serve 111ance that the limiting PATTERE.

value for McFR is being i

esteeded, acties shall be 2.

The NCFR limit at rated initiated within 15 minutes to flew and rated power shall restere operattom te within the be determined as provided prescribed limits.

If the la the CORE OPERATING steady-etate McFR is met LIMITS IIP 0ff estagt returned to withis the prescribed limits within two (2) pr#

hours, the reactor shall be a.

U. as defined in the brossht to the COLD SEIFTDOWN CORI OPERATIN LIMITS COEDITION withia 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , IIFORT prior to initial serve 111ance and corresponding screa tias asasuressata action shall castians until for the cycle, remeter operatism is within the performed la accordance prescribed limits, with Spesification N

a.m.c.i.

ars 3.5/4.5-19 AMBRE R216 "it li PAGEJ OFJ D

i 5

flROWNS IT.RRY NUCLEAR PLANT. IMPROVED TECllNICAL Sl ECIFICATIONS SECTION 3.2 LIST OF REVISED PAGES UNIT 2 US Markup Replaced GS 3.2.1 page 2 of 2 (page 3.5/4.518) with CTS 3.2.1 page 2 of 2 (page 3.5/4.5 18) rnision 1 Replaced CTS 3.2.2 page 2 of 2 (page 3.5/4.519) with CTS 3.2.2 page 2 of 2 (page 3.5/4.519) rnision 1 Replaced CTS 3.2.3 page 2 of 3 (page 3.5/4.518) with CTS 3.2.2 page 2 of 3 (page 3.5/4.518) rnision !

i l

GAf.

pee:Zeth.,sz.I tt4Y 2 01993

~ ~ " -

au :. --...

l Q () ' M 4 Averama Pl==rttimane Emat q

-3_t __

Aye, man Flamar tinaar Heat t

Canaration Rata (AFLEEE) l Gamaratina Rata g,

- -~~~~

AFLEGt shall be abethod l A

tag steady-state power]

i

}-

peratiesf tae averase raanar daily during reactor Linear Esat Generation Rate operaties at 1 251 rated

} 100 (AFLEGR) of any fuel assembly thermal power.

sat any asial location shall met Md P *psa4 (i,s 4 r,,j,,,,y exceed the appropriate AFLIGE limit provided in the CORE

, / /#. J.2. s. l (0PRIATIBG LIMITS REPotT.

If at.

/asy time during operecies it is

[determinedbymoraal surveillance that the limiting '

l value for AFLEGt is being

~

shall (e u

\\u,4.,nhasceeded,tassa A

N Initiated withia 5 minu M to i

reet heoperaties t within the I

inreecrites limitM If the l

l AFLEGR te set returned to withia

_. _ _ _h the prescribed limits within two (2) hosts, the reacter aball b 4 ZiV ATP L

FNbe nI brenskt toa t ::"'..www.n 9 e b.

4 4. cr s

(5

'survetlaamse ens cortes da ac'qsa aball e inne unt11 A

reactM operation a within the tyrescribed limits f J.inaar Raat Canaration Rata {LECR)

J.

tAmmae amar a--ration la UM1 Darias steady-etate powar operaties, the L MR aball be checked the linear heat generaties rate daily during.resator fuel (Last) of ear red in ear fuel operatten at 1 255 rated assembly at ear axial locaties shall thermal povar.

not escoed the appropriate LEGE limit provided in the CORI O N LIMITS IIP 0tT.

If at say a g derias operaties it is Wad by aermal surveillance h # Nf.g.**I'd % u thus the limittas vales for LEER is beias suaeeded, attira shall be be-AFN 18 75 1.1.]

initiated within 15 tainates to restore operaties to withis the presaribed limita.

If the LEGE is met returned to within the-prescribed limits withis two (2) beure, the reacter aball be brouet to the COLD SEUfDOWN CONDITION J

withia 36 heure. Serveillance ands /

arn 3.s/4.5-1:

,JMDyMOG M. 414

.w

___y~.--

Sell. I cm ; w ie,.tz.i.

=~,....m_

(E ec=" --

a"' ~

u s ;== --n= r= a mi s a J.

1.inear Emat Generation Kate (LNCI)

J.

h ar Heat Generation kat UnEE11

(******)

su s;,st.%I,n 4e L e 3

I e #m t a r.: 1.21 corresponding action shall continue u til reseter operation )

within the prescribed limit js fse g.s f,p r,.pn el R f.t 2.)

Munt=um critical Power natie M 'Higim a. critical Power katie (MCF11 g

. CR l a31.

F fThe minima critical power ratie 1.

twra s'all be checked daily during reacter power operation (MCPR) shall be equal to or greater than the operating limit at i 151 rated ttsreal power geo J. 7:2.

MCPI (01MCP3) as provided in the

@ folleving chaage tag r level er stri ties i (CORI OPERATIM LIMITS REPotT.

f at any time K h

A that uld cause perat with a INITI N CONTROL 300/

@>eLahl tema.-atate emerati it is determined by aermal JATTERJN surveillance that the limiting y je 7. 2.u.

I value for MCPR is being ti z.

The MCPR 11 alt at rated flew i azteeded, faction shall ne and rated power shall be

^ [ Amt lated wit 15 minst\\q,to determined as provided in the resto operation e within th Cote OPERATIM LIMITS REP 0tf m erib limitsf If the esings r

{a. y steady-state MCFR is met U as d ined in the Cott returned to within the OPERA M LIMIT 8 REP 0tr (preacribed limits within two (2) heurs, the reactor shall be prio to initial scram

^*3 (l brought to the&' ? L. e.;h t

measurements for the Al le, performed,in 0

,CE""!!'^" t-de'- M beeco,"

(entveilisess uma corresponding ceerdance vi acRenshalle inne untK Specificati 4.3.C.1.

reactX operaties a within the basdef in CORE g{prescribedlimits.;

b.

OPERATI LIMITS tr fell the union ef as scram-time serveillanes test required

/.tsg # vf' bySpecifications4.3.C.1) and 4.3.C.R.

j ML 9, g.

/ k..,,

s st. L t.2.L

-- s The deteraiLattaa of the limit anst be completed withia 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of asch f

scram-time surveillance required by specificaties 4.3.C.

RPN 3.5/4.5-19 i

Dmit 2 sunc A

QF j

kv.'.len rpasike i 3.1. 3 3.1/1,!

Cont AWM f0WTATMwFerf Pont N Sve* Twt i.iruns conumuns ruz OFEia7IOT SUMiliin iZeUIElE 5 1

3.5.1 Avarame Planar Linear Heat 4.3.1 Averare Planar Linear Heat q

ceneration Pate Generation late (LPLNCT) l During steady-state power The AFLEGE shall be checked l

}-

operation, the Average Planar daily during reacter operation at A 25% rated Linear Beat Generation Rate (APLEGR) of any fnel assembly thermal power.

at any axial location shall not azceed the appropriate AFLHGR

[

limit providou in the CORE OFEIATING LIMITS RIP 0tT. If at any time during operation it is g g ),fgeg/,,, [,,- dt,y y determined by normal surveillance that the limiting 4,- g m es n 1 2.l

~

l value for AFLBGE is being exceeded, action shall be initiated within 15 minutes to restore operation to within the prescribed limita.

If the l

AFLEGt is not returned to within the prescribed limits within two (2) hours, the reactor shall be b:.ought to the COLD SEUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Surveillance and correspading action shall continue until reactor operation is within the (prescribedlimits.

A Linear Heat ceneration late (LMct)

.fr Linear Beat Generation late ArrLc4Lt.Q h (the 11asar heat generation rate ring steady-state povar operati h The LEGE shall be checked daily during reactor fuel I (LEGR) of any rod in any fuel operation at 2. 2$1 rated b'8 assembly at any axial location shall thermal power.

133 not exesed the appropriate LEGE limit provided in the Cote AJc1 p.g.J le f Fyh (0FEIATING LIMITS RIP 0ET.

If at any M'

e l i4 3.2. 2. (

/tiam during operation it is

[easarminedbynormalsurveillance that the limiting value for LEGE is being exceeded,Jction a 1 De]^

M tlates vunin g minutes

)<.TwJ estoriNtperation to withia

'h-A rescribed limit *J If the LEGE is not returned to within the M *"

Nrescribedlimitswithintwo(2) g gr< arP (hours. the reactor shall be brought w, A;. a/ d.-s A'

~

^

[ togo. ;51.L JauwGW CGELITIGE

,itii: M h -- G ur u qianc y RFil 3.5/4.5-1:

AM EDM W NO. 2 1 i Unit 2 PAug )

7

BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.2 LIST OF REVISED PAGES UNIT 3 CTS Markup Replaced CTS 3.2.1 page 2 of 2 (page 3.5/4.518) with CTS 3.2.1 page 2 of 2 (page 3.5/4.518) rnision 1 Replaced CTS 3.2.2 page 2 of 2 (page 3.5/4.519) with CTS 3.2.2 page 2 of 2 (page 3.5/4.518) rnision i Replaced CTS 3.2.3 page 2 of 2 (page 3.5/4.519) with CTS 3.2.2 page 2 nr2 (page 3.5/4.518) rnision 1 1

l

l 6(/.

l~1. I

~

5 pet lJ'. e.he m MAY 2 0153

= --== - - - - a w., _,,,

a on

~

.grg-"I" Avarman Planar Linear Heat W Averama Piamme 13near Heat Ganaration fata Ganaration. lata (AFLEGR) bM'M 5g, J.J. f.

l M

ring steady.etate power)

I s AFLEGR shall be c. hacked j

l pheration fthe Average rianar daily darias reacter fLiasar Esat Generation late operatica at 1 255 rated ue (AFLEGR) of aar fuel assembly at thermal power.

tal;'aar axial location shall not exceed MJ w.r.sadfed Prj g )

the appropriate,AFLEGE limit e

g W

e f /4 1.2.l.1 j

provided in the Cot 3 0FERATING J.IMITS REPORT.

If at any time

[normalsurveillancethattheduring operation it is deterM and by i

limiting vaine for AFLEGR is being M my exceeded.Jetion 1 be tinted store I

A p tatst 15 minutes t operatDra to within the eramerihad) limitaf If the AFLIGt is not i

\\ returned to within the prescribed (2*[A.hP M r.

limits within two (2) heure, freactoraut11bebroughtto.pa y

Scm Ae j

q%

a t

arvenaanse correspondias FactQaballcent uti M aster l

M operativa.is within the erameribed 4.inita.>

(J. Linear Raat Generation J.

Linaar Emat Ganaration I

tate (LEGR)

Rata (LEGR)

During steady-state power operaties, TheLEGRaballbechecked{

the 11asar heat generaties rate (LEGR) daily during reaeter

) ;

et aar red La aar faal assembly at ear operatism at 2.15E rated 1

axial loestian shall not exceed the thermal power.

appropriate LM R limit provided in i

the CORI OPERATING LIMITh M P0t!.

If at any tias during operaties it is i

determined by aermal surveillance See AN'd'M Of Ajo that the limiting valse for LEGE is 4e. W W J.2 3 W,easeeded, actien shall be initiated within 15 aiantes to restare operaties te within the presaribed limits. If the LEGE is met returned to within the prescribed limits within two (2) hosts, the reacter shall be brought to the COLD SIDTDOWN CONDITION withia 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Surveillanes and corresponding action shall castiana until reactor Leperation is withis the prescribed limits.-

i m

3.5/4.5-18

'b O_

d et/, I s,.n:r<. :. s a

'EB 2 41995 l

i

..._,.......,......................a-..

@). -. =

= = =- :

1=. ~

w. _ ~.. ~a

= = - -

d weed til F'eryne s, ef 24 r1L j

- m i -- uritieni nr

.?,,r glai-critient Power entia

4. ;,7 Ratie (MCFR) g tg S. 21. 0 ment - critical power ratio A.

m,rs shall be checked daily (MCFR) aka11 be equal to or greater during reacter power operation t

I.2 2.

than the operating limit MCFR at 1 151 rated thermal u,

(OIJICFR) as provided La the COII sas rollow any caanse sa OA*

WFERATING LIMITS R2703T.

If at any r level e distringstica would sans operettaa WalgTtissieurtaa standr-stata anaemum ps, it is determined by serimul vi LIMI,IES CORrtoL 200/

surve111anse that the limiting

,FATTIIIf

'g ', vales for McFR is beias esseeded, I

y tren mal es ustes g tsla

-ggm z.

The McFR limit at rated flev

^

5 shuntgs to res operatTsa to and rated power shall be i'him *ka nroscribed li=itsC If determined as provided la the the steady-state MCFR is met CORI OPERATING LIMITS REFot!

i(returned to within the prescribed r.

x ILimits within two (I) hears, the asd[finedintheCott

~ % [reacter shall be brought to the

\\ a. 0

,,i.x,1,,,,,0,,

34 t-s, parteillance ans 4Al prio to initial scraa L

rresponding ach ga shall gentinue t

measuransats for the et(reacter operaties is within le, perfo la the prescribed limits /

, coordamse th

Speciftsa em 4.3.C.1.

4 2.TX S TP b.

as d ined la CORE OM,,

v,'A y 4.,

OPERAT IIPORT fell comeinstea of each ser time surveillance test regstred bF Specifications 4.3.C.1 d 4.3.C.2.

1 sterminaties af the limit must be ceapleted withia 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of eseh seras-time surveillance required by Specificaties 4.3.C.

AlstDM Dif M, 1 9 0 BFW 3.5/4.5-19 Unit 3 g,. Q

% __0/ _

7

i j

CM trad..t r.n MAY 2 0 W (R) m,=.-

_z

,o,,

r--...

\\

.3 I Averana Planne Linear Emat 4.3.I Avarmaa F1mm2P Linear Heat Ganaration Rata Ganaration Rata (AFLEGR)

During steady-state pove'r The APLEGE shall be checked l

operaties, the Average Planar daily during reacter operaties at 2. 255 rated )

Linear Beat Generation Rate (AFLIGR) of aar fuel assembly at tharsal power.

j aar axial locatien shall not aseeed 7

the appropriate AFLIGE limit provided in tha' CORE OPERATING i

~

LIMITS REF0ET.

If at aar time during operation it is determined by

,q,g y,,p f,a / q,.

normal surveillance that the q

N W E Z* l limiting value for AFLEGE is being azeeeded, action shall be initiated within 15 miantes to restore operaties to within the prescribed limits. If the AFLIGE is not returned to within the preecribed limits within two (2) hours, the reactor shall be brought to the COLD SIUTDOWN CONDITIOR within 36 heure.

Surveillance and corresponding

)actiesshallcontinueuntilreactor I operaties is within the preeeribed (limita.

.>.'" Linear Raat Generation

$"ll"" Linaar Raat Canaration I

tate (tmen) gg (Lggg.)

gg E x r.L Wing steady-state power operatteiD Ina LEGR aball be checked the 11asar heat generatica rate (LEGR) daily during reactor i

(

uo of aar rod in aar faal assembly at aar opsraties at 2. 255 rated W axial locatism shall met ascoed ths

=al power.

l appropriate LEGE limit provided la (the CORE O M LIMITS IIP 0t!.

j,g,l h y 7,.,,

fIfataartiasdaringoperatismitla M A2.1.l j determined tr aermal serve 111ance that the limiting value for la W [t belas asseeded,Jetten anauyDe A

Irsnaustaa vitala@ mianth to M rea operaties to withis thaJ r

If the LEGR is not returned to within the presaribed limits withis two (2) heure, the g asy, gp tit

]""((I, reactor shall be brought to f) s.,,h./ !. r.s

='

Warvetu-- - serrespong settaa centimme a reacter i

operat is within the presernd limits.

/

AlstDutWillL170 RFI 3.5/4.5-18

?"183...

em-O

BROWNS FERRY NUCLEAR PLANT. IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.2 LIST OF REVISED PAGES JUSTIFICATION FOR CilANGES TO CURRENT TECll SPECS (DOCS)

Replaced ITS 3.2.1 page I and page 2 with ITS 3.2.1 page 1 and page 2 Rnision 1 Replaced ITS 3.2.2 page I and page 2 with ITS 3.2.2 page 1, page 2, and page 3 Rnision i Replaced ITS 3.2.3 page 1 and page 2 with ITS 3.2.3 page I and page 2 Revision 1 Replaced ITS 3.3.4 page 1 and page 2 with ITS 3.2.4 page 1 and page 2 Rnision 1 i

JUST!FICATIOM FOR CHANGES i

SFN ISTS 3.2.1 - AVERAGE PLANAR LINEAR HEAT SENERATION RATE-j ADMINISTRATIVE CHAN8ES Al Reformatting and renumbering are in accordance with the BWR Standard i

Technical ~ Specification, NUREG 1433.

These changes should make the BFN 4

Technical Specifications easier for the operator (and other users) to j

read and understand. During the reformatting and renumbering process, i

no technical changes (either actual or interpretational) were made j

unless they were identified and justified, j

A2 The Applicability has been changed from ' steady state power operation' to ' Thermal Power a 25% RTP.* This change is considered administrative in nature since, based on a CTS surveillance frequency of daily during reactor operation at k 25% rated thermal power, the intent of CTS is the l

same as the proposed ISTS specification.

A3 The requiremvat to continue the surveillance when the limits are not met has been deleted since the total allowed completion time for restoring the limit or placing the plant in a condition outside the Applicability r

is 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Since the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time frame is less than the Surveillance Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the surveillance would not be required to be i

performed again while the plant wa, in the action. The requirement to continue to comply with actions until the limits are met has been moved and is now addressed by LCO 3.0.2, which clarif tts that if an LC0 is met or is no longer applicable prior to the expiration of the specified Completion Time (s), completion of the Required Action (s) is not required, unless otherwise stated. As a result, these changes are considered administrative in nature, i

TECHNICAL CHANGE - NORE RESTRICTIVE l The items identified as More Restrictive (MR) are those which contain l requirements that are more restrictive than Current Technical Specifications.

l These MR requirements are based on the Standard Technical Specifications for l BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been i

l determined to be apropriate and safe for BFN based on a review of current l design baset N1

- A new Frequency has been added to require verification of APLHGR within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of reaching or exceeding 25%- RTP, This is an additional restriction on plant operation. CTS would allow up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after L

l reaching 25% RTP to perform the test. Verification of APLHGR is l

l perfomed by the process computer, does not require removal of equipment l

for service, and does not require significant resources to perfom. ~

BFN-UNITS 1, 2,-& 3 1

Revision 1 1

1

.-.ew--m----w.-..--r-

--.ee--we------en% -.

w-.--r.

ww-iww--x-,--v,,aw-,

m,--,w r.--trT-ww wr.

mm

.ww a-w%.,.

- e.-%,,,

ms v n,w-w r-w e-e w-

JUSTIFICATION FOR CHANSES BFW !$TS 3.2.1 - AVERASE PLANAR LINEAR NEAT SENERATION RATE l

Therefore, to maintain consistency with the NUREG, BFN is agreeable to l

l-this new requirement.

f M2 The requirement to place the plant in a COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the limit is not restored within the required completion time has been revised to reflect placing the plant in a non appif' cable l

condition.' The revised Action requires plant power to.be reduced to <

l 25% RTP (outside the applicable condition) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (if the APLNGR

~ ~~

l limithasnotbeenrestoredduringtheprevioustwohours). The current action allows 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to place the plant in a non applicable condition.

~

As such, this is an additional restriction on plant operation, i

l Operational experience indicates that four hours is sufficient time to l.

reduce power to below 25% in an orderly manner and without challenging-l plant systems. These changes are also added for consistency with the l

NUREG.

e TECMICAL CHANGES - LESS RESTRICTIVE ll

' Specific

L1 The requirement to initiate action within 15 minutes to restore the limit is relaxed and relocated to the Bases in the fom of a discussion that " prompt action' should be taken to restore the parameter to within limits.

Immediate action may not always be the conservative method to assure safety. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months completion time for restoration of the limit allows approprigte actions to be evaluated by the operator and completed in a timely manner.

l L2 The CTS requirement to place the plant in a COLD SHUTDOWN CONDITION l

within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the limit is not restored within the required l

completion time has been revised to reflect placing the plant in a non-l applicable condition. The revised Action requires plant power to be l

reduced to < 25% RTP (outside the applicable condition) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months l

and does not require plant shutdown. At power levels 125%, there is I

substantial margin to APLHGR limits; thus, this less restrictive change l

is acceptable.

BFN-UNITS 1, 2, &3 2

Revision 1

-.. -. ~ - - - -. - - - -

.I i

JUSTIFICATION FOR CHANGES

-l j

SFN ISTS 3.2.2 - N!NIMUN CRITICAL POWER RATIO 1

ADBHISTRATIVE CHAN8Q Al Refomatting and renumbering are in accordance with the BWR Standard l

Technical Specification, NUREG 1433. These changes should make the BFN Technical Specifications easier for the operator (and other users) to read and understand. During the reformatting and renumbering process, no technical changes (either actual or interpretational) were made i

unless they were identified and justified.

A2 The Applicability has been changed from ' steady state operation' to

" Thermal Power = 25% RTP.* This change is considered administrative in l

nature since, based on a CTS surveillance frequency of daily during reactor operation at a 25% rated thermal power, the intent of CTS is the i

same as the proposed ISTS specification.

A3 The requirement to continue the surveillance when the limits are not met has been deleted since the total allowed completion time for restoring the limit or placing the plant in a condition outside the Applicability is 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Since the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time frame is less than the Surveillance j

Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the surveillance would not be required to be performed again while the plant was in the action. The requirement to continue to comply with actions until the limits are met has been moved and is now addressed by LCO 3.0.2, which clarifles that if an LC0 is met or is no longer applicable prior to the expiration of the specified Completion Time (s), completion of the Required Action (s) is not required, unless otherwise stated. As a result, these changes are i

considered administrative in nature.

I TECittlCAL CHANGE - NORE RESTRICTIVE l The items identified as More Restrictive (MR) are those which contain l requirements that are more restrictive than Current Technical Specifications.

l These MR requirements are based on the Standard Technical Specifications for l BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been l determined to be appropriate and safe for BFN based on a review of current l design bases.

M1 A new Frequency has been added to require verification of MCPR within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of reaching'or exceeding 25% RTP.

This is an. additional-restriction on plant operation.

CTS _would allow up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after l

reaching 25% RTP to perfom the test. Verification of the MCPR is l

perfomed by the process computer, does not require removal of equipment l-

-from service, and does not require significant resources to perform.

BFN UNITS 1, 2, & 3 1

Revision 1

JUST!FICt. TION FOR CHANGES l

SFN 15TS 3.2.2 - MINIMUM CRITICAL P0WER RATIO l

Therefore, to maintain consistency with the NUREG, BFN is agreeable to l

l this new requirement.

l M2 The requirement to place the plant in a COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the limit is not restored within the required completion f

time has been revised to reflect placing the plant in a non applicable l

condition. The revised Action requires plant power to be reduced to l

< 25% RTP (outside the applicable condition) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (if the MCPR l

. limit har not been restored during the previous two hours).

The current action allows 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to place the plant in a non-applicable condition.

As such, this is an additional restriction on plant operation.

l Operational experience indicates that four hours is sufficient time to l

reduce power to below 25% in an orderly manner and without challenging l

plant systems. These changes are also added for consistency with the l

NUREG. Therefore, to maintain consistency with the NUREG, BFN is l

agreeable to this new requirement.

TECHNICAL CHANGES - LEss RESTRICJJyi

' Generic' LA1 The method used to determine r is moved to the Bases in the fom of a discussion (describing the ways to compute r). This infomation is also contained in the Core Operating Limits Report (COLR). The proposed change does not change tne intent of CTS.

' Specific' L1 The requirement to initiate action within 15 minutes to restore the limit is relaxed and relocated to the Bases in the form of a discussion that " prompt action' should be taken to restore the parameter to within limits.

Immediate action may not always be the conservative method to assure safety. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months completion time for restoration of the limit allows appropriate actions to be evaluated by the operator and completed in a timely manner.

L2 Since a limiting control rod pattern is currently defined as operating on a power distribution limit such as HCPR, the condition is extremely unlikely and the survalliance would almost never be required.

In the CTS, detemination that the plant is operating with a limiting control rod pattern would be found during performance of the daily Sps 4r thermal limits.

If operating with a themal limit in excess of CTS limits, proper actions are required to restore the plant to within BFN-UNITS 1, 2, & 3 2

Revision 1

\\

JUST!FICATION FOR CHANGES BFN ISTS 3.2.2 - NININUN CRITICAL POWER RATIO limits. To ensure thr* the plant is restored to within limits, the SRs must be performed anyw.y thus the additional SR frequency during limiting control rod pattern is not necessary.

l L3 The CTS requirement to place the plant in a COLD SHUTDOWN CONDITION l

within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the limit is not restored within the required l

completion time has been revised to reflect placing the plant in a non-l applicable condition.

The revised Action requires plant power to be l

reduced to < 25% RTP (outside the applicable condition) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months l

and does not require plant shutdown. At power level 5 25%. there is a l

large margin that ensures that the NCPR SL is not exceeded even if a l

limiting transient occurs.

Therefore, this less restrictive change is l

acceptable.

BfN-UNITS 1, 2, & 3 3

Revision 1 l

JUSTIFICATION FOR CHANGES

^

BFN ISTS 3.2.3 - LINEAR HEAT GENERATION RATE ADMINISTRATIVE CHAN6ES Al Reformatting and renumbering are in accordance with the BWR Standard Technical Specification, NUREG 1433. These changes should make the BFN Technical Specifications easier for the operator (and other users) to read and understand. During the refomatting and renumbering process, no technical changes (either actual or interpretational) were made unless they were identified and justified.

A2 The Applicability has been changed from ' steady-state power operation

to 'Themal Power a 25% RTP.' This change is considered administrative in nature since, based on a CTS surveillance frequency of daily during reactor operation at a 25% rated themal power, the intent of CTS is the same as the proposed ISTS specification.

A3 The requirement to continue the surveillance when the limits are not met has been deleted since the total allowed completion time for restoring the limit or placing the plant in a condition outside the Applicability l

1s 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Since the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time frame is less than the Surveillanca l

Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the surveillance would not be required to bc l

performed again while the plant was in the action. The requirement to continue to comply with actions until the limits are met has been moved and is now addressed by LCO 3.0.2, which clarifies that if an LCO is met or is no longer applicable prior to the expiration of the specified Completion Time (s), completion of the Required Action (s) is not required, unless othe mise stated. As a result, these changes are considered administrative in nature.

TECHNICAL CHANGE - MORE RESTRICTIVE l The items identified as More Restrictive (MR) are those which contain j requirements that are more restrictive than Current Technical Specifications.

l These MR requirements are based on the Standard Technical Specifications for l BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been l determined to be appropriate and safe for BFN based on a review of current l design bases.

M1 A new Frequency has been added to require verification of LHGR within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of reaching or exceeding 25% RTP. This is an additional restriction on plant operation.

CTS would allow up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after l

reaching 25% RTP to perform the test.

Verification of the LHGR is l

perfomed by the process computer, does not require removal of equipment l

trom service, and does not require significant resources to perfo m.

l l

BFN UNITS 1, 2, & 3 1

Revision 1 l

l

JUST!FICATION FOR C6tANGES BFN !$TS 3.2.3 - LINEAR HEAT GENERATION RATE l

Therefore, to maintain consistency with the NUREG, BFN is agreeable to l

this new requirement.

M2 The requirement to place the plant in a COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the limit is not restored within the rcquired completion time has been revised to reflect placing the plant in a non-applicable condition. The revised Action requires plant power to be reduced to <

l 25% RTP (outside the applicable condition) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (if the LHGR l

limit has not been restored during the previous two hours). The current action allows 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to place the plant in a non-applicable condition.

l As such, this is an additional restriction on plant operation.

l Operational experience indicates that four hours is sufficient time to l

reduce power to below 25% in an orderly manner and without challenging l

plant systems. These changes are also added for consistency with the l

NUREG. Therefore, to maintain consistency with the NUREG, BFN is l

agreeable to this new requirement.

TECHNICAL CHANGES - LESS_RESTRICUYi

" Specific

L1 The requirement to initiate action within 15 minutes to restore the limit is relaxed and relocated to the Bases in the form of a discussion that " prompt action" should be taken to restore the parameter to within limits.

Imediate action may not always be the conservative method to assure safety. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months completion time for restoration of the limit allows appropriate actions to be evaluated by the operator and completed in a timely manner.

l L2 The CTS requirement to place the plant in a CO D SHUTDOWN CONDITION l

within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the limit is not restored within the required l

completion time has been revised to reflect placing the plant in a non-l applicable condition. The revised Action requires plant power to be l

reduced to < 25% RTP (outside the applicable condition) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months l

and does not require plant shutdown. At core thermal power levels l

< 25%, the reactor is operating with substantial margin to the LHGR l

limits; therefore, this less restrictive change is acceptable.

BFN-UNITS 1, 2, & 3 2

Revision 1

l l

I JUSTIFICATION FOR CMANSES BFN ISTS 3.2.4 - APRN SAIN AW SETP0!NTS

)

ADMINISTRATIVE CMANGES l

Al Reformatting and renumbering are in accordance with the BWR Standard i

Technical Specification, NUREG 1433. These changes should make the BFN l

Technical Specifications easier for the operator (and other users) to l

read and understand. During the reformatting and renumbering process, no technical changes (either actual or interpretational) were made i

unless they were identified and justified.

I i

-A2-The current LC0 and the proposed ISTS LC0 ensure acceptable operating margins by limiting excess power-peaking or reducing the APRM flow biased neutron flux upscale scram setpoints by the ratio of the fraction of rated power and the core limiting value of the MFLPD. Proposed ISTS LCO Item c also provides the option of increasing the APRM gains to cause the APRM to read a:100 times NFLPD (in %). This condition is to l

account for the reduction in margin to the fuel cladding integrity safety limit and the fuel cladding 1% plastic strain limit.

Either a gain adjustment on the APRMs or an adjustment to the APRM setpoints has effectively the same result. tithough BFN Technical Specifications do not specifically call out APRM gain adjustments, they are interpreted as an acceptable alternative and are allowed by current BFN plant procedures.

For compliance with proposed LC0 Item b (APRM setpoint adjustment) or Item c (APRM gain adjustment), only APRMs required to be i

OPERABLE per proposed LC0 3.1.1.1 (RPS Instrumentation) are required to be adjusted.

A3 The CTS requirement (CTS 3.5.L.3) to reduce power to s 25% of rated l

thermal power within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months has been changed to < 25% of rated thermal power consistent with the LCO applicability for the CTS and the proposed BFN ISTS. The intent of the CTS action is to exit the LCO applicability i

and obviously this cannot be done until power is reduced below 25%.

The change is slightly more restrictive by the literal wording of the technical specifications, however, since it does not represent an actual change to the intent it has been classified as an administrative change.

TECttlICAL CHANGE - NORE RESTRICTIVE l The items : identified as More Restrictive (MR) are those which contain l requirements that are more restrict've than Current Technical Specifications.

l-These MR requirements are based on the Standard Technical Specifications for l BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been l determined to be appropriate and safe for BFN based on a review of current

-l design bases.

BFN-UNITS 1, 2, & 3 1

Revision 1

JUST!FICATION FOR CHANGES BFN ISTS 3.2.4 - APRM LAIN AND SETPOINTS M1 A new Frequency has been added to require verification of MFLPD within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of reaching or exceeding 25% RTP. This is an additional restriction on plant operation. CTS would allow up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after l

reaching 25% RTP to perform the test. Verification of the MFLPD is l

performed by the process computer, does not require removal of equipment l

from service, and does not require significant resources to perform.

l Therefore, to maintain consistency with the NUREG, BFN is agreeable to l

this new requirement.

M2 A new Surveillance Requirement (SR 3.2.4.2) has been added that specifically requires the licensee to verify that APRM setpoint or gains are adjusted for the calculated MFLPD when the method of complying with the LCO is to make these adjustments. Since this change adds a specific requirement where none existed before, the change is considered more l

restrictive. This change allows BFN to take advantage of setting the l

gains in the manner specified. This change is considered appropriate l

for BFN. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency is not consideref excessive and does not l

require significant resources to perform. Therefore, to maintain l

consistency with the NUREG, BFN is agreeabie to this new requirement.

BFN-UNITS 1, 2, & 3 2

Revision 1

BROWNS FERRY NUCLEAR PLANT.1MPROVED TECHNICAL SPECIFICATIONS SECTION 3.2 LIST OF REVISED PAGES NUREG 1433 BWR/4 STS BASES MARKUP Replaced page B3.2 9 with page D3.2 9 Revision i Replaced page B3.2-4 with page B3.24 Rnision I D

9 4

r&

i Ru:I APLHGR B 3.2.1 BASES ACTIONS 3.J (continued) operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR

3. 2. ld REQUIREMENTS APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 2 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. 'They are compared to the specified limits in the COLR to ensure that the reactor is operating vithin the assumptions of the safety analysis.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

[htDo-A40n-P A /3 REFERENCES 1.

M S 240!!

- " General Electric Standard Application for Reactor Fuel" :tect :.;~ v..ui..u k.d. u s

y>

2.

FSAR, Chapter Pt.

aps; ;9,p

({} a.

r=, Ch.ete, g).

Is

@ (D 38 FSAR,f5aptertMf'

@ 4.

Pleni apnific singie invy vper;;ur).

.-.. '..,. ". r i'"......r.....'....'.'....-

g 9 6.

8

[lant ecific A erage Power ange Moni or, Ro Q ock Mo tor a Techni 1 Specifica n impro ts R

) Proo V

u t't:r ".ethee." A h [ sf

E00 30130 A, "Ste:dy State u

my : =.4 HEDC 52484P, browns Fernj Wuclect Plant unib 1,2, and 3, 5.

Sut R/6e.5TR LOCA Lon-of-Ccolont Auident /W2l sis,"__

Revisioni, Febrogar i--

G.

PAGS f 6 OF 734 (continued)

gu. I MCFR B 3.2.2 BASES SURVE!LLANCE SR 3.2.2.1 (continued)

REQUIREMENTS recognition of the slowness of changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER t 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

SR 3.2.2.2 Because the transient analysis takes credit for conservatism in the scram speed performance, it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis.

SR 3.2.2.2 determines the value of r, which is a measure of the actual scram speed distribution compared with the assumed distribution.

The MCPR operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4 " Control Rod Scram Times") and Option 8 (realistic scram times) analyses.

The parameter r must be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time' tests required by SR 3.1.4.1 and SR 3.1.4.2 because the effective scram speed distribution may change during the cycle.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due to the relatively iainer changes in r expected during the fuel cycle.

TochM MOe d A M ~ Wn' ele? Depottbre K%_Alocleate So* jing or out,*

REFERENCES-1.

NUREG 0562,UJune 1979.

GE00;AM0ll1% ^ }'^11 " d " General Electric Standard Application 2.

..ED forReactorFuel"(hy;(em y f g ien).

3.

FSAR,Chapterh Erd As-s 0

FCAE, EheptU [6). -

% 4- [

F5AR, Chapter h 6.

(PlenispieiIis a irigic s uvp vyvi sl a via).

f.)

] Di rt ;p;gjfjg };;d line limit inilgiii).

% A '@

J PAGE 103 OF 77'1 ff (continued)

CME /4 373 -

B 3.2 9

-Re 1, S'/67/95

BROWNS FERRY NUCLEAR PLANT. IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.2 LIST OF REVISED PAGES r

NO SIGNIFICANT liAZARDS CONSIDERATIONS Replaced ITS Section 3.2 page 1 of 2 through 2 of 2 Revision 0 with ITS Section 3.2 page 1 of 3 through 3 of 3 Revision I

~

6

Ng e

m O

e 9

e f

L 1

c..

N0 $1GNIFICAE HAZARDS CONSIDERATIONS BFN !$TS SECTION 3.2 - POWER DISTRIBUTION LINITS IICHNICAL CHANGES - LESS RESTRICTIVE (L1 for 3.2.1. 3.2.2. and 3.2.3)

TVA has concluded that operation of Browns Ferry Nuclear Plant in accordance with the pro)osed change to technical specifications does not involve a significant gazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91 (a)(1), of the three standards set 1

forth in 10 CFR 50.92.

1.

The proposed awndent does not involve a siaidicant increase in the probability or consecuences of an accident prey ously evaluated.

The proposed change does not result in any herdware changes. The requirement to initiate action within 15 minutes to restore power distribution limits is not assumed to be an initiator of any analyzed event. The proposed change does not allow continuous operation with power distribution limits not maintained within limits.

The total time allowed for a rower distribution limit to be outside of limits is still maintained in tha Technical Specifications. As a result, deleting the requirement to initiate action to restore the parameters within limits does not impact the total time the plant is allowed to operate outside the limits. As a result, the consequences of an event occurring with the proposed change are the same as the consequences of an event Therefore, this change will occurring with the current requirements.

not involve a significant increase in the probability or consequences of an accident previously evaluattd.

2.

The proposed Ewndant does not create the possib'lity of a new or different k' nd of acetdent from any ace' dent prev'ously evaluated.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change will not allow continuous operation when power distribution limits are not met.

Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

l BFN-UNITS 1, 2, & 3 Page 1 of 3 Revision !

t

~

N0 $1GNIFICANT HAZARDS CONSIDERATIONS OFM ISTS SECTION 3.2 - POWER DISTRIBlJTION LINITS 1[GHNICAL CHANGES - LES$ RESTRICTIVE (L1) (CONTINUED) 3.

The proposed amendment does not involve a sienificant reduction in a marnin of safety.

No reduction in a margin of safety is involved with this change since the time allowed for o)eration with power E stribution limits not met has not been affected )y this change. Technical Specifications will continue to limit the amount of time operation is allowed when power distribution limits are not met.

In addition, the 15 minute action initiation time is not an assumption of a design basis accident or transient analysis. Therefore, this change does not involve a significant reduction in a margin of safety.

BFN-UNITS 1, 2, 1 3 Page 2 of 3 Revision 1

N0 $1GNIFICANT HAZARDS CONSIDERATIONS BFM ISTS SECTION 3.2 - POWER DISTRIBUTION LIMITS l

TECMICAL CHANGES - LES$ RESTRICTIVE IL2 for 3.2.1. L3 for 3.2.2. and L2 for 3.2.3)

TVA has concluded that operation of Browns Ferry Nuclear Plant in accordance with the proposed change to technical specifications does not involve a significant hazards consideration. TVA's conc ~usion 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.

1._

The crocosed amendment does not involve a sianificant increase in the probability or Consequences 67 an accident Dreviously evaluated.

The proposed change does not result in any hardware changes. The proposed change requires bringing the reactor _to a non-applicable condition (<25% RTP) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Based on the substantial margin to the power distribution limits at thermal power levels <25%, deleting the requirement to place the reactor in the COLD SHUTDOWN CONDITION within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

The crocored amendment does not create the nossibility of a new or different kind of accident from any accident previousiv eva' uated.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change will not allow continuous operation, in an applicable condition, when power distribution limits are not met. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

i 3.

Ihg.oroposed amendment does not involve a siunificant reduction in a marain of safety.

No reduction in a margin of safety is involved with this change since the Completion Time allowed for placing the plant in a non-applicable condition is reasonable, based on operating experience, to reduce reactor ptwer to <25% RTP in an orderly manner and without challenging plant systems. Therefore, this change does not involve a significant-4 reduction in a margin of rifety.

a BFN-UNITS 1, 2, & 3 3 of 3 Revision 1

e i

BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL FPE'CIFICATIONS SECTION 3.2 LIST OF REVISED PAGES BFN UNIT 1,2, and 3 CROSS-REFERENCE MATRLX Inserted new page 1 of 1 Revision 0

o BFN UNIT 1,2. AND 3 CROSS-REFERENCE MATRIX I

RELOCATED RELOCATED RELOCATED CTS MUMBER [*]

BFN ITS NUMBER NUREG NUMBER DELETED TO BASES TO TRM TO PROC RELOCATED CONTROL 35.8 3.2.1 Action A 3.2.1 Action A

%'S l

ITS 5.5.10 3.5.1 3.2.1 Action B 3.2.1 Action B 3.5.1 3.2.1 LCO 3.2.1 LCO 3.5 J 3.2.3 Action A 3.2.3 Action A YES ITS 5.5.10 3.5.J 3.2.3 Action B 3.2.3 Action B 3.5.J 3.2.3 LCO 3.23 LCO 3 5.K 3.2.2 Action A 3.2.2 Action A YES ITS 5.5.10 3.5_ K 3.2.2 Action B 3.2.2 Action B 3.5 K 3.2.2 LCO 3 2.2 LCO 3.5.L1 3.2.4 LCO 3.2.4 LCO 3.5 t_2 3.24 Action A 3 2.4 Action A 3.5.L3 3.2.4 Action B 3.2.4 Action B 4.5 i SR 3.2.1.1 SR 3.2.1.1 4.5.J SR 3.2.3.1 SR 3 2.3.1 4.5 K.1 SR 3.2.2.1 SR 3.2.2.1 YES 4.5 K 2 SR 3 2.2.2

.3.2.2.2 4.5 K.2.a NONE NONE YES ITS 5.5.10 4.5.K.2.b SR 3.2.2.2 SR 3.2.2.2 YES ITS 5.5.10 4.5 L SR 3 2.4.1 SR 3.2.4.1 NONE SR 3.2.4 2 SR 3 2 2 2 l

Units 1,2, and 3 except as indicated, Information in brackets is for Unit 3 unless noted otherwise.

1 cf 1 Revision 0

-.

ML20198Q452

Text

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