Text

Proposed Tech Specs Section 3.8.1,revising AC Sources- Operating
	ML20248C515
Person / Time
Site:	Browns Ferry
Issue date:	05/27/1998
From:	; TENNESSEE VALLEY AUTHORITY
To:	;
Shared Package
ML20248C492	List: ML20248C488; ML20248C515;
References
	NUDOCS 9806020171
	Download: ML20248C515 (20)
	v • d • e

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, BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 Revision 5 LIST OF REVISED PAGES UNIT 2 CURRENT TECH SPECS SECTIONS Add Section 3.8.1, page 10a of 22 (3.9/4.9-9)

Add Section 3.8.1, page 14a of 22 (3.9/4.9-15a)

)

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4 9906020171 990527 5 PDR ADOCK 05000259 R P PDR /

,3,9/4.9 AUX 2LTARY ELEs*I*PICAL SYSTEM g gg jgg7 f,IMIh'ING COND7TIONS FOR OPERATION StiRVEIT LANCE REOUTREMENTS

( 3.9.B. Operation Witn Inocerable 4.9.B. Coeration With Inocerable Eauioment Ecuinment

. 3. When one of the units 1 3. When one of the and 2 diesel generator is units 1 and 2 diesel INOPERABLE, continued generators is found 3 REACTOR POWER OPERATION is to be INOPERABLE, permissible during the all of the restaining succeeding 7 days, diesel generators provided that 2 offsite shall be demonstrated power sources are to be OPERABLE within available as specified 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and power in 3.9.A.1.c and all of availability for the the CS, RHR (LPCI and '

associated boards containment cooling) scall be verified systems, and the remaining within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and three units 1 and 2 diesel at least once per Q enerators are OPERABLE.

8hoursthereafter.)

~.__ _

[ __ Temporad Change:fThe pr

/{7-day LpO we liadt may p extended to 14 dd to support /

, completian of phtenapee activitiet t

during the time perio4 from /

Jinuary 1,)998, to february 1,,2999, M -

I after whipfi time t)fs temporary change is no lon,ger valid This allowance g pg g, g cgp4ye,3 g4,[/ .\

s

, g,,, ,, , g te a O ca. 2 aw tug, itqe4c,orzz,,

ind)(idual di , I generato .] /

1

[ be fmet, this requirement cannot an orderly shutdown shall be initiated and the reactor shall be in the COLD SHUTDOWN CONDITION within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

. When one units 1 and 2 4. When one 4-LV 4-kV shutdown board is shutdown board is INOPERABLE, continued found t.o be REACTOR POWE'R OPEPATION INOPERABLE, all is permissible for a period diesel generators of 5 days provided that associated with the k 2 offsite newer sources remaining 4-kV are available as shutdown boards shall specified in 3.9.A.1.c be demonstrated to be and the remaining 4-kV OPERABLE within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , shutdown boards and and power availability

{ associated diesel for the remaining 4-kV T generators, CS, RHR (LPCI shutdown boards and containment cooling) shall be verified systems, and all 480-V within 1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and emergency power boards at least once per

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i are OPFRABLE. If this requirement cannot be 8 houre thereafter. ;

met, an orderly shutdown g shall be initiated and /

l the reas"or shall be in /

the COLD SHUTDOWN CONDITION /

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . f BFN 3.9/4.9-9

R2c)e. 10a cf 22 i

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9% O e y Y

, 9/4.9 A6XILIARY EDI ciu, s r s u m -

0[C 2 2 )997 LIMITING CONDITIONS FOR OPEPATION SURVEILLANCE REOUTPIMENTS 3.9.D piesel Generators Pecuired for 4.9.s Diesel Generators Pecuired '

priit s 1. 7, and 3 Shared Systems for Units 1, 1. and 3 Shared

'

Systems

1. Whenever standby gas treatment is required to be OPERABLE in Surveillance requirements are accordance with Specification as specified in 4.9.A.1, 3.7.8 and/or control room 4.9.A.2, 4.9.A.3, and 4.9.A.4 emergency ventilation is with the folicwing required to be OPERABLE in provisions:

accordance with Specification 3.7.E, the associated diesel

1. The testing provisions of generator alignaa to supply 4.9.A.l.b do not apply emergency power to that for a defueled unit.

equipment shall be OPERABLE.

2. The common accident

a. Standby gas creatment train signal testing required A and/or control room by 4.9.A.3 requires the ,

emergency ventilation train signal to originate only l A - Diesel generstor 1/2A from units that require . !

or 1/2B. OPERABILITY of the I standby gas treatment k l

b. Standby gas treatment train system and/or the control)

B - Diesel generator 1/2D room emergency or 1/2B. ventilation system. This test will verify the

c. Standby gas treatment train automatic start of the C - Diesel generator 3D. diesel generatcrs aligned to the standby gas

d. Control room emergency treatment system and/or ventilation train B - the control room Diesel generator _3C or 38. emergency ventilation s - _ _

w-- system.

[ Temporary change When xthe allgned diekel gene ter ip

\

I inoperable o a unit hat is 4

i

\ g not in cold utdown, refuehng, or tiefueled, the\n\TS b io $ t'(IScohh feVis;o n P n 3 8. /

2 m %g h 0eg etg~,/

\ '

1.C.2 applies fbr the purposes g

, of OPERp ILITY determinat'ons /

for the above affheted ,

equipmentN This change is valid during the thne period An from Januahy 1, 199(,to M j \ February 1, \1999 ) . \,

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BFN 3.9/4'.9-15a AMENDMENT NO. 2 5 0 Lnit 2 Pac >e .h 4 22 l

BROWNS FERRY NUCLEAR PLANT - IMPROVED TECliNICAL SPECIFICATIONS SECTION 3.8 Resision 5 LIST OF REVISED PAGES UNIT 3 CURRENT TECH SPECS SECflONS Add Section 3.8.1, page 9a of 21 (3.9/4.9-8)

Add Section 3.8.1, page 13a of 21 (3.9/4.9-14a)

l FPec @ica rica 3. e .1 5?e u s' 39/4.9 AUXI??ARY ELE c"*R IcAL s1 stim g gg jgg7 i LIMITING wnufTIONS FOR OPERATION SURVEILLANCE PIOUTRIMENS Ooeration with Inecerable 3.9.B. overation with Inocerable 4.9.B.

Ecuioment

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J Ecu ir -ent Whenever the reactor is in STARTUP mode or RUN mode and i I

not in a cold Condition, the l availability of electric power shall be as specified in 3.9.A except as specified herein. ,

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1. From and after the date 1. When only one that only one offsite '.offsite power source power source is available, is OPERABLE, all unit 3 reactor operation is diesel generators must permissible under this be demonstrated to be condition for seven days. OPERABLE within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and power availability for the associated boards shall i be verified within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. When one unit 3 diesel 2. When one unit 3 diesel generator (3A, 3B, 3C, generator is found to be )

or 3D) is inoperable, inoperable, all of the 1 continued reactor operation remaining unit 3 diesel, is permissible during the ge:nerators shall be succeeding 7 days, provided den:enstrated to be that two offsite power OPERAgLE within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , sources are available as and power availability specified in 3.9.A.1.c. for the associated boards and all of the CS, RER shall be verified within (LPCI and containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once (

cooling) systems, and the per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. l remaining three unit 3 diesel generators arm y

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OPERABLE y

[ ([7-day LCO thne be limit mTemporarAchange[e preceding) extended to IAdays to su prt N co'mpletion of A=iata== ara activities during the time period from .

January 1,1998, to February 1999,

\ tempo change

\after w%ch is no lo time r valid. f all can be only onc6\ {or each inkdual el generator.]

~ fe(et h, 5yaftu.the n 3.8.1 If this requirement cannot be met, an (C0K.oo A Nt N fo3e 9el2j orderly shutdovn shall /

os inatiated and the reactor shall be shut P i down and in the Cold l Condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . J l

BFN 3.9/4.9-a AMENDMENT NO. 2 0 9 Unit 3 C A k

- - - - - ~ - _ _ _

4 NC sbb 6c n 3 9.l $l5 DEC 2 21997 N

3.9/4.9 AUXILIARY ELECTRICAL u- '%.

SURVEILLANCE REQUIREMENTS LIMITING CONDITIONS FOR OPERATION 4.9.D Diesel Generators peovired \

2, and Shared 3.9.D Diesel Generators Beauired for 2, and 3 Shared Systems for Units 1, '3

' Units 1, Svetems s i N

Whenevet' standby gas treatment Surveillance requirements are

\

1.

is required to be OPERABLE in as specified.in 4.9.A.1, accordance with Specification 4.9.A.2, 4.9.A.3, and 4.9.A.4 '/

3.7.B and/or control room with the following emergency ventilation is provisions:

required to be OPERABLE in accordance with Specification ,1. The testing provisions of 3.7.E, the associated diesel .

4.9.A.l.b do not apply generator aligned to supply '

for a defueled unit.

emergency power to that equipment shall be OPERABLE. 2. The cocunon accident signal testing required

a. Standby gas treatment train by 4.9. A.3 requires the A and/or control room signal to originate only emergency ventilation train from units that require A - Diesel generator 1/2A OPERABILITY of the or 1/28. standby gas treatment I system and/or the control

b. Standby gas treatment train room emergency B - Diesel generator 1/2D ventilation system. This

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) or 1/28. test will verify the I automatic start of th's

c. Standby gas treatment train diesel generators aligned c - Diesel generator 3D. to the standby gas treatment system and/or

\ d. Control room emergency ventilation train B -

the control room amargency ventilation

( Q iesel generator 3C or 38.-

- system. -

[ Temporary'changiiT~Trhen the

l align &d diesel generator is i g inoperable on a bnit that '

is g.g g gf,ge;f.cqp,e n 3. e ,1

not in cold shutdown, i refueling, or defueled, then TS (t45'.oo 2. ma<Kuf fctgeI5of2/

11C.2 applies for the purposes l

' of\0PERABIf4TY determsnatlons \

N I

for'\the abob affecthd equipment. t(tis chan'ge is valid \during the time perio g from Jgnuary 1,\ 1998, to g February,1, 199 . \

t A9 /

AMENDMENT NO. 2 0 9 3.9/4.9-14a BFN Unit 3 Tge fa_ cf 2/

BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

. . Raision 5 LIST OF REVISED PAGES JUSTIFICATION FOR CHANGE TO CURRENT TECHNICAL SPECIFICATIONS Replaced section 3.8.1 page 1 of 12 through 12 of 12 Revision 4 with pages 1 of 12 through 12 of 12 revision 5 t.

L____-----_-_____---___-_:__-____

JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-OPERATING ADMINISTRATIVE Al All reformatting and renumbering is in accordance with the BWR/4 Standard Technical Specifications (STS), NUREG-1433. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant operators as well as other users. t The reformatting, renumbering, and rewording process involves no technicii changes to existing Technical Specifications. j Editorial rewording (either adding or deleting) is made consistent with NUREG-1433. During ISIS development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) to the Technical Specifications. Additional information has also been added to more 1 fully describe each subsection. This wording is consistent with the BWR Standard Technical Specifications, NUREG-1433. Since the design is already approved by the NRC, adding more detail does not result in a technical change.

A2 Notes 1, 2, 3, and 4 to proposed ITS SR 3.8.1.2 have been added. Note 1 l to ITS SR 3.8.1.2 allows gradual loading. Note 2 to ITS SR 3.8.1.2 l clarifies that momentary transients outside the load range do not invalidate this Surveillance. Note 3 to ITS SR 3.8.1.2 only allows the i SR to be performed on one DG at a time, which is consistent with the CTS application of testing on a " staggered test basis". Note 4 to ITS SR 3.8.1.2 requires that the loading be immediately preceded by a successful- performance of ITS SR 3.8.1.1 or ITS SR 3.8.1.4, with an intermediate warmup period. This is acceptable since the notes do not remove any testing requirements, reflect current approved testing methodology, and provide clarification which will ensure consistency and l proper controls on testing. All of these changes are consistent with '

the BWR Standard Technical Specifications, NUREG-1433, and are considered administrative in nature.

A3 Not used.

BFN UNITS 1, 2, & 3 1 af 12 Revision 5

JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-OPERATING A4 The Unit 3 DG requirements for Unit 1 and 2 TSs to support SGT and control room emergency ventilation are presented in proposed ITS 3.8.1.c. Unit 3 iechnica) 2ptcifications will require the operability .

of all Unit 3 DGs and provide appropriate compensatory actions for j inoperable Unit 3 DGs in support of Unit 3 operations. To support the . I operation of Unit 1 and 2, the Unit I and 2 LC0 for AC Sources -

Operating also requires the necessary Unit 3 DG(s) to support SGT and CREVS required by LCO 3.8.7, Distribution Systems - Operating, for ,

supplying the Unit 3 4.16 kV shutdown boards. Since the Unit I and 2 CTS only impose Actions for an inoperable Unit 3 DG when Unit 3 is in cold shutdown, refueling or defueled, this presentation is consistent with current requirements. Therefore, the conversion is administrative.

1 AS Certain equipment needed to meet Unit I and 2 accident analysis is i powered from Unit 3 AC Sources. Current TS Surveillance only apply to the Unit I and 2 AC sources; the Unit 3 TS govern testing of.the Unit 3 DGs. Consistent with the current approach, a proposed Note applicable to all SRs and SR 3.8.1.10 have been added to ensure Unit 3 sources are addressed in the Surveillance as they are in the LC0 and ACTIONS.

Therefore, this change is considered administrative.

A6 Not used.

A7 The Unit 1 and 2 DG requirements for Unit 3 TSs to support SGT and control room emergency ventilation are presented in ITS 3.8.1.c. Unit 1 q and 2 Technical Specifications will require the operability of all Unit I and 2 DGs and provide appropriate compensatory actions for inoperable Unit 1 and 2 DGs in support of Unit I and 2 cperations. To support the operation of Unit 3, the Unit 3 LC0 for AC Sources - Operating also requires the necessary Unit 3 DG(s) to support SGT and CREVS required by LC0 3.8.7, Distribution Systems - Operating, for supplying the Unit 1 and 2 4.16 kV shutdown boards. Since the Unit 3 CTS only impose Actions for an inoperable Unit 1 and 2 DG when Unit 1 and 2 are in cold shutdown, refueling or defueled, this presentation is consistent with current requirements. Therefore, the conversion is administrative. I

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A8 Certain equipment needed to meet Unit 3 accident analysis is powered i from Unit I and 2 AC Sources. Current TS Surveillance only apply to '

the Unit 3 AC sources; the Unit I and/or 2 TS govern. testing of the Unit I and 2 DGs. . Consistent with the current approach, a proposed Note applicable to all SRs and SR 3.8.1.10 have been added to ensure Unit I and 2 sources'Are addressed in the Surveillance as they are in the LCO and ACTIONS. Therefore, this change, is considered administrative. I i

BFN UNITS 1, 2, & 3 2 of 12 Revision 5 l

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JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-0PERATING A9- Subsequent to the original submittal of the ITS, a CTS (TS-391T) change was approved which provided a temporary extension of the EDG allowed outage time to accommodate vendor recommended 12-year maintenance.

Since the 12-year maintenance has been successfully completed for all eight BFN EDGs, the temporary change is no longer needed and it is being deleted as an administrative change. A separate mark-up page is provided to reflect this change. A similar request for ITS was withdrawn by TVA's letter to NRC dated May 7, 1998.

TECHNICAL CHANGE - MORE RESTRICTIVE The items identified as More 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 determined to be appropriate and safe for BFN based on a review of current design bases.

M1 Proposed Specification 3.8.1, AC Sources - Operating, will be applicable in MODES 1 (Run), 2 (Startup), and 3 (Hot Shutdown) which is more restrictive t.han CTS 3.9.B. CTS 3.9.B requires action for inoperable equipment "Whenever the reactor is in Startup Mode or Run Mode ar.d not in a cold condition." Thus CTS would not require the stated requirements in the Startup Mode prior to reaching 212 degrees F or in a Hot Shutdown condition, whereas the proposed TS will. The proposed change establishes requirements for OPERABILITY of AC Sources consistent with the OPERABILITY requirements for the functions that these AC sources are required to support including ECCS and Primary Containment Isolation System. This change is consistent with the BWR Standard Technical Specifications, NUREG-1433.

M2, Not used.

M3 Not used.

M4 CTS 3.9.A.2 allows one less AC power source than required for continuous operation, to startup from the Hot Standby Condition. By elisainating this explicit allowance in the ITS, the more restrictive proposed addition of LCO 3.0.4 will result in precluding this startup. This more restrictive change will assure that the required AC Sources are available prior to any reactor startup from any condition.

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BFN UNITS 1, 2, & 3 3 of 12 Revision 5

JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-0PERATING MS Proposed SRs 3.8.1.1, 3.8.1 4, 3.8.1.5, and 3.8.1.9 add the acceptance criteria for voltage and frequency. These acceptance criteria are consistent with proper operation of the governor and voltage controls necessary to assure DG OPERABILITY. In addition, SR 3.8.1.9.c has an added DG start time requirement consistent with the accident analysis.

Since these requirements are not stated in CTS, their addition is considered more restrictive.

M6 A new more restrictive requirement to be in MODE 3 (Hot Shutdown) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of entry into the LC0 has been added. This is more restrictive since before the only requirement was to be in mode 4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and now the operator must place the reactor in a shutdown condition within a shcrter time period. This requirement is consistent with the ER Standard Technical Specifications, NUREG-1433, and is appr opriate for BFN since it adds ar additional measure of control for safe shutdown of the reactor and can be achieved safely in the time allotted.

M7 Not used.

M8 Proposed SR 3.8.1.8 demonstrates proper operation for the DBA loading sequence which ensures that DGs (and offsite circuits) are not overloaded, and that the required loads are started in sufficient time to adequately support the assumed function. BFN TSs currently do not have a similar specific SR directly tied to DG operability. The CTS requirements for individual pump timer testing included in CTS Table 3.2.B and the SR requirement in CTS 4.9.A.l.b for load sequencing verify the ir+' ' between each timed load block is within the calibration tolera.... . a each individual timer and serve the same function, therefore this additional requirement is within the current BFN design.

M9 Condition G addresses the situation where both one required offsite circuit and one DG are inoperable and affect only one 4.16 kV shutdown board. The Note clarifies the applicability. The Required Action is to declare the affected 4.16 kV shutdown board inoperable immediately.

This requires entry into the applicable Conditions and Required Actions of LC0 3.8.7, " Distribution Systems - Operating," which provides the appropriate restrictions for the affected 4.16 kV shutdown board. LC0 3.8.1 Conditions and Required Actions continue'to apply until the required offsite circuit and DG are made OPERABLE.

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BFH UNITS.1, 2, & 3 4 of 12 Revision 5 i ;

JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-0PERATING TECHNICAL CHANGE - LESS RESTRICTIVE

" Generic" LAl The details of what constitutes OPERABILITY of an offsite power source have been relocated to the Bases. Thus, the LC0 has been written to tell what is needed, but the details of the specific requirements for operability of an offsite power source and the boards needed to route the offsite power to the shutdown boards have been relocated to the Bases. Any references to the 4-kv bus tie board and cooling tower transformer have been deleted since this source of power is no longer qualified as an offsite power source. The details of having the start buses and shutdown buses 1 and 2 energized have been relocated to the Bases since this detail is used to support an operable offsite power source. Relocation of these items to the- Bases is acceptable since the details of what constitutes operability are not necessary to establish the requirement for operability. The LCO requirement for the operability of offsite power circuits is unaffected by the removal of these details. Thus the details can be moved to the Bases and controlled by the provisions of the proposed Bases Control Program in Section 5 of the Technical Specifications.

For MODE 1, 2, and 3 operation, all SGT and emergency ventilation trains, as well as all four Unit I and 2 DGs for Unit 1 and 2 and all four Unit 3 DGs for Unit 3, will be required to be OPERABLE. The details relating to system design (which DGs are associated with which Systems) are included in plant drawings which will be used to determine necessary power supplies. The U2A DG, 1/2B DG, and 1/2D DG listed in CTS 3.9.D are the same DGs as listed as DG A, B, and D elsewhere in CTS.

The design features and system operation are also described in the FSAR.

Thus, the LC0 has been written to simply specify the required DGs be OPERABLE, but the details of the specific requirements for OPERABILITY have bean relocated to the Bases. Changes to the current requirement to associate these required OPERABLE DGs with the required OPERABLE Systems will be controlled via changes to the Bases by the provisions of the proposed Bases Control Program in Section 5 of the Technical Specifications. Changes to the FSAR will be controlled by the provisions of 10 CFR 50.59. Relocation of these details to the Bases is acceptable since the inclusion of these details is not necessary to establish the LCO requirement.

LA2 Not used.

LA3 Deleted in response to NRC comment NUREG M/V LCO 3.8.1, Issue 25.

Replaced by L10.

BFN UNITS 1, 2, & 3 5 of 12 Revision 5

JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-OPERATING LA4 CTS 4.9.A.l.a requires all DG starts to be logged. The proposed change removes this specific requirement from TS. This is acceptable since inclusion of the details of what data to record is not necessary to establish the requirement for surveillance testing. Thus removal of this Surveillance from the Technical Specifications will have no effect on DG OPERABILITY.

LA5 This change involves the removal of specific details on how to perform a surveillance while leaving the actual requirement to perform testing unchanged. Removal of these details from the Technical Specifications is acceptable since their inclusion is not necessary in order to establish the testing requirements and test methods necessary to ensure operability.

LA6 This change involves the movement of descriptive details for the performance of CTS surveillance 4.9.A.3.b to the Bases. The purpose of this SR is inherent in the manner in which the test is performed and is described in the Bases for proposed ITS 'SR 3.8.1.9 (load shedding).

Therefore, the description has been relocated to the Bases. This is

acceptable since inclusion of the descriptive details is not necessary in order to establish the requirement to perform the SR. Changes to the Bases will be controlled by the provision of the proposed Bases Control Program in Section 5.0 of the proposed BFN ITS.

.LA7 Deleted. Replaced by L11.

LA8 The descriptive details concerning testing of the CAS logic have been relocated to the Bases for proposed ITS SR 3.8.1.6. This provides a

.better location for details on where the accident signal originates.

The requirement to perform the surveillance test is unaffected.

Relocation of this information is acceptable since inclusion of the descriptive details is not necessary in order to establish the requirement to perform the SR.. Changes to the Bases will be controlled by the provision of the proposed Bases Control Program in Section 5.0 of the' proposed BFN ISTS.

" Specific" L1 Proposed LCO 3.8.1, Condition A (one offsite source or one shutdown bus inoperable) will not include the requirement of CTS 4.9.B.1 (Units 1,2,3), 4.9.B.2 (Units 1,2), 4.9.B.3 (Unit 3), and 4.9.B.5 (gnits 1,2) to demonstrate the OPERABILITY of the remaining DGs within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following loss .of the power source. This change acknowledges that inoperability of an offsite circuit (or shutdown bus) is-not indicative of a similar condition in the DG unless a common failure is suspected.

Additionally, the-periodic Frequencies specified to demonstrate DG l OPERABILITY have been demonstrated adequate to provide a high degree of g assurance that'the DG is OPERABLE. Therefore, this change allows credit l-j BFN UNITS 1, 2, & 3 6 of 12 Revision 5 L

JUSTIFIC,ATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES 4)PERATING 4

to be taken for the normal periodic Surveillance as a demonstration of DG OPERABILITY and reduces the challenges and wear to the DGs.

Minimizing DG starts is recommended to avoid unnecessary DG wear, thereby enhancing overall DG reliability (refer to Generic Letter 84-15). This action is consistent.with BWR STS, NUREG-1433, and the design j of BFN.

L2- Not used. l I

L3 Proposed Required Action B.3.1 has been added to provide an allowance to l avoid unnecessary testing of OPERABLE DGs when a DG is declared inoperable if it can be confirmed that no common cause failure has rendered more than one DG inoperable. This assurance can be ascertained j in many cases by means other than the existing requirement to I demonstrate DG operability by starting the DG. If.an assessment can l determine no common cause failure exists on the remaining OPERABLE DG(s), proposed Required Action B.3.1 eliminates the DG start.

Minimizing DG starts is recommended to avoid unnecessary DG wear, thereby enhancing overall DG reliability (refer to Generic Letter 84-15). This action is consistent with BWR STS, NUREG-1433, and the design of BFN. .This change is acceptable since the action-to determine that t the remaining DGs are not inoperable due to a common cause failure will ensure DG OPERABILITY is maintained and Required Action B.3.2 provides an alternate method to test the DG in the event this determination cannot be made without testing.

L4 The time to reach MODE 4, Cold Shutdown has been extended from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This provides the necessary time to shut down and cool down the plant in a controlled and orderly manner that is within the capabilities of the unit, assuming the minimum required equipment is

- OPERABLE. This extra time reduces the potential for a unit upset that could challenge safety systems. This time is consistent with the BWF Standard Technical Specifications, NUREG 1433. The increased time allowed to reach MODE 4 is acceptable based on the small probability v an event during this time and the desire.to minimize plant transients.

The requested 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months extension will provide sufficient time for the unit to reach MODE 4 in an orderly manner. As a result, the potential for human error will be reduced. In addition, the unit is now required to be in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (a shutdown condition). As such, any reduction in a margin of safety will be insignificant and offset by the benefit gained from providing sufficient time to reach MODE 4, thus avoiding potential plant' transients from attempting to reach MODE 4 in the current time and the benefit of being subcritical (MODE 3) in a j

shorter. required time.

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BFN UNITS 1, 2, & 3 7 of 12 Revision 5 1 .

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JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-OPERATING L5 The following changes have been made to LC0 3.8.1:

a. Proposed ACTION E provides an out-of-service time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , when two or more offsite circuits are concurrently inoperable,

' prior to requiring a unit shutdown, with a reduced allowance of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with a redundant component inoperable. The allowed completion times allow the~ operator time to evaluate and repair any discovered inoperabilities. With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. Thus, the completion time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable _ of meeting its design criteria.

b. Proposed ACTION F provides an out-of-service time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , '

when a DG and an offsite circuit are concurrently inoperable, prior to requiring a unit shutdown. The allowed completion times allow the operator time to evaluate and repair any discovered inoperabilities. The allowed completion time takes into accennt the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

c. Proposed ACTION'H provides an out-of-service time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , when two or more DGs are concurrently inoperable, prior to requiring a unit shutdown. The twc hour completion time is acceptable since it provides a reasonable time for repairs considering the reduced capacity and capability of the remaining AC sources, the low probability of a DBA occurring during this period minimizes the risk associated with continued operation while making repairs, and any increase in risk is offset by the risk associated with an immediate controlled shutdown (due to potential grid disturbances which could lead to a total loss of offsite AC power).

d. Proposed ACTION J provides a Required Action to enter LC0 3.0.3 l immediately for conditions where all redundancy in the AC electrical power. supplies has been lost. The NUREG wording has been changed to reflect BFN specific plant details which clearly define the combinations of power sources for which this ACTION applies. The changes in the NUREG wording are administrative and serve only to incorporate plant specific details. In this case, ar.y -further losses in the AC electrical power system will cause a loss of function. Therefore, no additonal time is justified for continued operation and a shutdown per LC0 3.0.3 is warranted.

I BFN UNITS 1, 2, & 3 8 of 12 Revision 5

JUSTIFICATION FOR CHANGES l BFN ISTS 3.8.1: AC SOURCES-0PERATING l

e. New restrictions have been added to proposed LC0 3.8.1 to limit the maximum time the requirements are not met (the second completion time of 14 days for the restoration actions for Actions A and B). The 14 day completion time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The limit of 14 days is acceptable based on the the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

Currently, items a, b, c, and d would result in imposing an immediate plant shutdown in accordance with current 1.0.C.1 (proposed LC0 3.0.3).

Items a, b, and c now provide for additional time for operation while effecting repairs, as discussed above. These new ACTIONS are consistent with the BWR Standard Technical Specifications, NUREG 1433, and with the recommendations of Regulatory Guide 1.93.

The proposed Completion Times to restore multiple, inoperable AC Sources to OPERABLE status prior to requiring a shutdown is acceptable based on the overall probability of an event requiring the inoperable AC Sources during this time period. Providing Completion Times will minimize the potential for plant transients that can occur during shutdown by providing some time to restore the affected AC Sources prior to requiring a shutdown. In addition, the NRC has previously evaluated these new times and approved them in Regulatory Guide 1.93. As such, any reduction in a margin of safety by the addition of these Completion Times will be offset by the benefit gained in avoiding an unnecessary plant transient by providing time to restore the inoperable AC Source.

L6 The requirements for operability in CTS 1.0.C.2 when an offsite or onsite power source is inoperable ha've been retained in LC0 3.8.1, in the form of proposed Required Actions A.2, B.2, E.1, and K.1. These proposed Required Actions are the same as the current requirements, except for the proposed Completion Times associated with these checks.

Therefore, the movement of the current requirements to this LC0 is strictly administrative. The addition of Completion Times to verify that redundant features are not inoperable (in proposed Required Actions A.2, B.2, E.1, and K.1 proposed to be 24, 4, 12, and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , respectively) will allow the operator time to evaluate and repair any discovered inoperabilities which minimizes the risk due to subjecting the unit to transients associated with shutdown. The proposed Completion Times also consider the capacity and capability of the remaining AC. sources and the low probability of a DBA occurring during this period.

BFN UNITS 1, 2, & 3 9 of 12 Revision 5

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JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-0PERATING CTS 3.5.A.2, 3.5.B.3, 3.5.B.5, and 3.5.B.6, allow a specified restoration time for an inoperable CS or RHR pump, only if all DGs are OPERABLE; and 3.9.B.3 for Units 1 and 2 (3.9.B.2 for Unit 3) allows a specified restoration time for an inoperable DG only if all CS and RHR systems are OPERABLE. (br example, if a CS pump ano its associated DG are inoperable', the CTS require an immediate shutdown. The proposed ACTIONS only require the OPERABILITY of components redundant to the components' supported by the inoperable AC source. This results in the ITS allowance for a component (e.g., RHR or CS pump) and its associated offsite~ circuit or DG to be concurrently inoperable without imposing immediate shutdown restrictions as in the CTS.

Additionally, the proposed Required Actions A.2, B.2, E.1, and K.1 provide another allowance to avoid an immediate forced shutdown when a DG or offsite circuit is inoperable concurrent with a required " feature" (i.e., system, subsystem, component) inoperability. Certain combinations of inoperable components may allow for satisfactory compensatory actions or have been justified for some allowed restoration time. By. allowing " features" associated with the inoperable offsite circuit or DG to be declared inoperable, the appropriate ACTIONS can be taken. This can potentially eliminate unnecessary forced shutdowns, and the associated risk of plant transients, while maintaining ACTION provisions previously provided concerning the specific circumstances.

This allows the. individual component specification te determine the restriction on continued operation based ~upon the components that are

.' inoperable and whose function is impaired due to the combination of power sources inoperable and individual component inoperabilities. This different approach does not reduce the level of safety and is witnin the l analyses for_BFN in the FSAR.

L7 The proposed 24-hour Surveillance reduces the required load, which is currently required to be greater than 2800 kW for the full 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , to between 2680 kW and 2805 kW for the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months then between 2295 and 2550 kW for the remainder of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months test. DG 24-hour testing is recommended by Regulatory Guide 1.9 to be perfor.T.ed for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at 105 to 110% of the continuous rating. The remainder of the 24-hour run is not required to exceed the continuous rating of the DG. Additionally, in an NRC Safety Evaluation dated December.21, 1989, the NRC requested a long duration test be added to the ' Technical Specifications with load ranges consistent with those proposed in this change. NRC later acknowledged in NRC SER dated February 12, 1991 that the proposed testing of DGs at 2800 kW for the entire 24. hours is more conservative than the NRC requested . earlier. The RFN DGs are designed with a 2-hour rating and continuous. rating of 2800 kW snd .2550 kW respectively.

Therefore these changes are consistent with accepted NRC recommendations for this test. This change is acceptable since performance of testing as prescribed in the proposed surveillance will continue to adequately demonstrate the OPERABILITY.of the DG while minimizing the potential BFN UNITS 1, 2, & 3 10 of 12 Revision 5 !

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JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC SOURCES-0PERATING degradation to the DG as a result of operating the DG above its continuous rating for an extended time period beyond that required to demonstrate its capabilities.

L8 This change removes the requirement for the RHR and CS systems to be operable as a condition for the allowance of a 7 day A0T in the event of inoperability of one division of logic. When one division of logic (480 V load shed or common accident signal) is inoperable, CTS 3.9.B.9 for Units 1. and 2 (3.9.8.7 for Unit 3) allows continued operation for 7 days provided all of the CS and RHR (LPCI and containment cooling) systems are operable. ~The requirement for all CS and RHR (LPCI and containment cooling) systems to be operable when a division of logic is inoperable is overly conservative. This change is acceptable since the logic systems consist of two fully redundant divisions, either of which is capable of ensuring DG operability and neither logic operability impacts the operability of Core Spray or RHR. Loss of both divisions of logic would have to occur to impact DG operability, since each logic is 100%

redundant to its companion logic. The inoperability of one division of logic is addressed by proposed Conditions C and D and loss of both logics is addressed by proposed Condition I of ITS section 3.8.1.

L9 T.he DG loading requirements have been reduced using the guidance provided by R39ulatory Guide 1.9 R3. This regulatory guide recommends Load-Run testing at 2295 to 2550 kW (90-100% of the continuous rating) and Endurance and Margin testing at 2678 to 2805 kW (105-110% of the continuous rating) for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months followed by 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months at 2295 to 2550 kW (90-100% of the continuous rating). Loading is required by current technical specifications to be 2600 kW or greater during Load-Run testing and 2800 kW or greater for Endurance and Margin testing. This change is acceptable since performance of testing as prescribed in the proposed surveillance will continue to adequately demonstrate the operability of the DG while minimizing the potential degradation to the DG as a result of operating the DG above its continuous rating for an extended time period beyond that required to demonstrate its capabilities.

L10 Current Technical Specification Table 4.9. A, which provided requirements for accelerated DG testing, has been deleted. BFN has implemented 10 CFR 50.65, Maintenance Rule, f.or the diesel generators. Under Maintenance Rule, DG reliability is monitored to ensure it is maintained within the reliability assumptions of BFN's Probability Safety Assessment. Deletion of the accelerated testing program and replacement with the monitoring and actions required by 10 CFR 50.65 is consistent with the guidance of Regulatory Guide 1.60 and will ensure continued DG reliability.

BFN UNITS 1, 2, & 3 11 of 12 Revision 5

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JUSTIFICATION FOR CHANGES BFN ISTS 3.8.1: AC $00RCES4PERATING L11 CTS 3.9.B.9 for Units 1 and 2 (3.9.B.7 for Unit 3) requires the NRC to be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one division of the logic system is inoperable. This condition is not reportable to the NRC per 10 CFR 50.72, 50.73, or other 10 CFR requirements and as such is being removed from TS.

Relocated Specifications R1 Current TS 4.9.A.I.d requires DG inspections in accordance with the manufacturer's recommendations once every 24 months. The proposed change relocates this specific inspection requirement to the Technical Requirements Manual. Although this type of surveillance is a good practice and does aid in improving long term reliability and performance of the DGs, this inspection does not verify or prove the DG will perform its required safety function. There is no credit taken for this inspection in the accident or transient analysis nor does the inspection

, verify proper DG- response assumed in the accident or transient analysis.

Performance.of this inspection surveillance: 1) does not involve or affect instrumentation used to detect or indicate degradation of the reactor coolant pressure boundary, 2) is not a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis, 3) is not part of the primary success path that functions or actuates to mitigate a DBA or transient, and 4) is not credited with ensuring operability of a structure, system, or component which operating experience or PSA has shown to be significant to public health and safety. Therefore, the requirements specified in current Specification 4.9.A.I.d do not satisfy the NRC Final Policy Statement technical specification screening criteria and thus are not required by 10 CFR 50.36. Performance of this inspection will be relocated to the Technical Requirements Manual and controlled in accordance with 10 CFR 50.59.

BFN UNITS 1, 2, & 3 12 of 12 Revision 5

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ML20248C515

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