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{{#Wiki_filter:LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT
{{#Wiki_filter:LIMITING CONDITIONS   FOR OPERATION           SURVEILLANCE REQUIREMENT 3.7  CONTAINMENT SYSTEM                  4.7 CONTAINMENT SYSTEM
: 6. System  A may be  considered          2. When FCV 84-8B is inoperable, operable with FCV 84-8B                    each solenoid operated inoperable provided that all                air/nitrogen valve in System B active components in System B              shall be cycled through at least and all other active components            one complete cycle of full travel in  System  A are operable.                and each manual valve in System B shall be verified open at least once per week.
: 7. Specification 3.7.G.6 and 4.7.G.2 are in effect until the next cold shutdown of unit    1 after July 20, 1984 or until 180 days after that date.
248A S<080600a9 ea07S0 PDR ADGCK 0500025'P P


===3.7 CONTAINMENT===
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SYSTEM 4.7 CONTAINMENT SYSTEM 6.System A may be considered operable with FCV 84-8B inoperable provided that all active components in System B and all other active components in System A are operable.2.When FCV 84-8B is inoperable, each solenoid operated air/nitrogen valve in System B shall be cycled through at least one complete cycle of full travel and each manual valve in System B shall be verified open at least once per week.7.Specification 3.7.G.6 and 4.7.G.2 are in effect until the next cold shutdown of unit 1 after July 20, 1984 or until 180 days after that date.S<080600a9 ea07S0 PDR ADGCK 0500025'P P 248A
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~q ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION TVA BFNP TS 198 ENCLOSURE 2 Descri tion Page 248a is being added temporarily to permit operation of unit 1 with PCV 84-8B (CAD supply to the torus-System A)inoperable until the next cold shutdown.Additional surveillance has been added to the components in System B.Justification FCV 84-8B was declared inoperable on July 17, 1984 at 2000 hours when the valve failed to open during surveillance testing.The valve cannot be repaired without breaking primary containment, therefore, requiring the unit to be brought to a cold shutdown before repair s can be made.This situation meets the requirements of an emergency situation as described in 10 CFR 50.22(a)(5).
Safet Anal sis The CAD System is designed to dilute hydrogen and oxygen in the primary containment which may be generated in post-LOCA conditions.
It is a two-train system with each train having valves to admit nitrogen to the torus and drywell to delivery enough nitrogen flow to keep post-LOCA hydrogen below four percent and oxygen below five percent.The system also have valves to vent containment atmosphere to the Standby Gas Tr eatment System from the dr ywell and torus.


By design, torus hydrogen and oxygen are controlled by adding nitrogen from the CAD System directly into the torus via FCV 84-8B and FCV 84-8C.However, nitrogen introduced into the drywell will displace drywell atmosphere into the torus through the downcomers and effectively dilute both volumes.Inoperability of FCS 8f4-8B will leave only one path to introduce nitrogen directly into the torus and thus relaying up the downcomer path as a backup for dilution of the torus atmosphere.
ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION TVA BFNP TS 198
In the plant safety analysis, no credit is taken for intervolume mixing between the drywell and torus.However, if nitrogen is only added to the drywell, a mixing flow toward the torus will be established.
 
It will be further augmented if venting if done through the torus vent path.Flow between torus and drywell is also induced by intermittent operations of drywell sprays.Current operating instructions provide for adding and venting as necessary to control hydrogen in both the torus and drywell and to operate drywell sprays intermittently to promote mixing.Surveillance intervals on valves in the redundant train (System B)have been increased from once per month to once per week to decrease the probability of an undetected failure.As stated in a letter from D.G.Eisenhut to All Licensees of Operating Reactors dated May 8, 1984, and our response dated July 2, 1984, the Commission has determined that a Mark I Bt&plant such as Browns Ferry has been found not to rely upon purge/repressurization systems (CAD System)as the primary means of hydrogen control.Although this determination was not permission to operate with the CAD System less than fully operable, it should be considered in the safety evaluation for this temporary condition.
ENCLOSURE 2 Descri tion Page 248a    is being  added  temporarily to permit operation of unit        1 with PCV  84-8B (CAD supply to the torus      System    A) inoperable  until  the next cold shutdown. Additional surveillance has        been added  to the  components in  System B.
The overall effectiveness and reliability of the CAD System is not being reduced significantly due to this temporary condition and further the system is not needed at all to accomplish.the design basis intent of combustible gas control.Therefore, there is neglible effect on safety.
Justification FCV  84-8B was declared inoperable on July 17, 1984          at  2000 hours when the valve failed to open during surveillance testing.            The  valve cannot    be repaired without breaking primary containment, therefore, requiring the unit to  be  brought to a cold shutdown before repair s can be made.            This situation    meets the requirements    of  an emergency  situation  as described in  10 CFR  50.22(a)(5).
7'~II ENCLOSURE 3 SIGNIFICANT HAZARDS CONS IDERATIOiV DETERMINATION TVA BFNP TS 198 7 A 1 ENCLOSURE 3 Basis for Determination of No Si nificant Hazards The Commission has provided examples of amendments that are not likely to involve significant hazards considerations (48FR14870).
Safet    Anal sis The CAD System    is  designed to  dilute    hydrogen and oxygen    in the primary containment which    may be  generated    in  post-LOCA  conditions. It is  a two-train  system with each    train having valves to admit nitrogen to the torus and  drywell to delivery enough nitrogen flow to keep post-LOCA hydrogen below four percent and oxygen below        five percent. The system    also have valves to vent containment atmosphere to the Standby            Gas Tr eatment System from the dr ywell and torus.
Example (vi)involves a change which in some way reduces a safety margin but the results of the changes are clearly within all acceptance criteria with respect to the system or component specified in the Standard Review Plan.The proposed change involves the potential for inability to admit nitrogen to the torus from the CAD system.A single failure in the CAD system would be required to create this situation.
 
The consequences of such a failure are I that a possible reduction in the amount of mixing of containment atmosphere may take place;however, intermittent operation of containment sprays as called for by operating instruction is listed in Standard Review Plan 6.2.5., Criteria 3 as an acceptable means of ensuring mixing for combustible gas control.The condensation of steam and atmospheric temperature changes that result from operation of containment sprays cr cate large amounts of containment atmospher e to transfer between the drywell and torus to equalize pressure.The atmosphere in the torus is monitored during post-accident conditions, and dilution and mixing operations such as nitrogen addition and spraying are initiated as needed to alleviate high concentrations of combustible gas.The plant configuration and operation after this change is implemented are clearly within all acceptance criteria of the Standard Review Plan and therefore this example applies.  
By design, torus hydrogen and oxygen are controlled by adding nitrogen from the   CAD System   directly into the torus via FCV 84-8B and FCV 84-8C.
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However, nitrogen introduced into the drywell will displace drywell atmosphere into the torus through the downcomers and effectively dilute both volumes. Inoperability of       FCS 8f4-8B will leave   only one path to introduce nitrogen directly into the torus and thus relaying             up the downcomer path as a backup       for dilution of the torus atmosphere.
In the plant safety analysis,         no credit is taken for intervolume mixing between the   drywell   and   torus. However, if nitrogen   is only added   to the drywell,   a mixing   flow toward the torus       will be established. It will be further   augmented   if venting if done     through the torus vent path.       Flow between torus and drywell       is also induced   by intermittent operations of drywell sprays.     Current operating instructions provide for adding and venting as necessary to control hydrogen in both the torus             and drywell and to operate   drywell sprays intermittently to promote mixing.
Surveillance intervals       on valves in the redundant train (System B) have been increased   from once per month to once per week to decrease           the probability of   an undetected     failure.
As stated in a letter   from D. G. Eisenhut to     All Licensees of     Operating Reactors dated May 8, 1984, and our response dated July 2, 1984, the Commission has determined       that a Mark I Bt& plant   such as Browns Ferry has been found not to       rely upon   purge/repressurization   systems   (CAD System) as the primary means         of hydrogen control.     Although this
 
determination was not permission to operate with the   CAD System less than fully operable, it should be considered in the safety evaluation for this temporary condition.
The overall effectiveness and reliability of the CAD System   is not being reduced significantly due to this temporary condition and further the system is not needed at all to accomplish .the design basis intent of combustible gas control. Therefore, there is neglible effect on safety.
 
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II
 
ENCLOSURE 3 SIGNIFICANT HAZARDS CONS IDERATIOiV DETERMINATION TVA BFNP TS 198
 
7 A 1 ENCLOSURE 3 Basis for Determination of       No Si nificant Hazards The Commission has     provided examples of amendments that are not         likely to involve significant hazards considerations           (48FR14870). Example (vi) involves   a change which   in some way   reduces a safety margin but the results of the   changes are   clearly within     all acceptance   criteria with   respect to the system or component specified in the Standard Review Plan.               The proposed change involves the         potential for inability to admit nitrogen to the torus from the     CAD system. A single failure in the   CAD system would be required to create this situation.           The consequences   of such a failure are I
that a possible reduction in the amount of mixing of containment atmosphere may take place; however,     intermittent operation of containment sprays         as called for   by operating   instruction is listed in Standard       Review Plan 6.2.5., Criteria     3 as an acceptable     means of ensuring mixing for combustible gas control.
The condensation     of steam and atmospheric     temperature changes that result from operation of containment sprays cr cate large amounts of containment atmospher e   to transfer between the drywell       and torus to equalize pressure.
The atmosphere   in the torus is monitored during post-accident conditions, and dilution   and mixing operations such as nitrogen addition and spraying are initiated   as needed   to alleviate high concentrations of combustible gas. The plant configuration     and operation after this change     is implemented are     clearly within     all acceptance   criteria of the Standard Review Plan and     therefore this example applies.
 
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Latest revision as of 02:01, 22 October 2019

Proposed Changes to Tech Specs 3.7 & 4.7 to Permit Operation W/Flow Control Valve 84-8B (Containment Atmosphere Dilution Supply to Torus for Sys a) Inoperable Until Next Cold Shutdown
ML18026B124
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 07/31/1984
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18026B123 List:
References
NUDOCS 8408060029
Download: ML18026B124 (12)


Text

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT 3.7 CONTAINMENT SYSTEM 4.7 CONTAINMENT SYSTEM

6. System A may be considered 2. When FCV 84-8B is inoperable, operable with FCV 84-8B each solenoid operated inoperable provided that all air/nitrogen valve in System B active components in System B shall be cycled through at least and all other active components one complete cycle of full travel in System A are operable. and each manual valve in System B shall be verified open at least once per week.
7. Specification 3.7.G.6 and 4.7.G.2 are in effect until the next cold shutdown of unit 1 after July 20, 1984 or until 180 days after that date.

248A S<080600a9 ea07S0 PDR ADGCK 0500025'P P

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q

ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION TVA BFNP TS 198

ENCLOSURE 2 Descri tion Page 248a is being added temporarily to permit operation of unit 1 with PCV 84-8B (CAD supply to the torus System A) inoperable until the next cold shutdown. Additional surveillance has been added to the components in System B.

Justification FCV 84-8B was declared inoperable on July 17, 1984 at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> when the valve failed to open during surveillance testing. The valve cannot be repaired without breaking primary containment, therefore, requiring the unit to be brought to a cold shutdown before repair s can be made. This situation meets the requirements of an emergency situation as described in 10 CFR 50.22(a)(5).

Safet Anal sis The CAD System is designed to dilute hydrogen and oxygen in the primary containment which may be generated in post-LOCA conditions. It is a two-train system with each train having valves to admit nitrogen to the torus and drywell to delivery enough nitrogen flow to keep post-LOCA hydrogen below four percent and oxygen below five percent. The system also have valves to vent containment atmosphere to the Standby Gas Tr eatment System from the dr ywell and torus.

By design, torus hydrogen and oxygen are controlled by adding nitrogen from the CAD System directly into the torus via FCV 84-8B and FCV 84-8C.

However, nitrogen introduced into the drywell will displace drywell atmosphere into the torus through the downcomers and effectively dilute both volumes. Inoperability of FCS 8f4-8B will leave only one path to introduce nitrogen directly into the torus and thus relaying up the downcomer path as a backup for dilution of the torus atmosphere.

In the plant safety analysis, no credit is taken for intervolume mixing between the drywell and torus. However, if nitrogen is only added to the drywell, a mixing flow toward the torus will be established. It will be further augmented if venting if done through the torus vent path. Flow between torus and drywell is also induced by intermittent operations of drywell sprays. Current operating instructions provide for adding and venting as necessary to control hydrogen in both the torus and drywell and to operate drywell sprays intermittently to promote mixing.

Surveillance intervals on valves in the redundant train (System B) have been increased from once per month to once per week to decrease the probability of an undetected failure.

As stated in a letter from D. G. Eisenhut to All Licensees of Operating Reactors dated May 8, 1984, and our response dated July 2, 1984, the Commission has determined that a Mark I Bt& plant such as Browns Ferry has been found not to rely upon purge/repressurization systems (CAD System) as the primary means of hydrogen control. Although this

determination was not permission to operate with the CAD System less than fully operable, it should be considered in the safety evaluation for this temporary condition.

The overall effectiveness and reliability of the CAD System is not being reduced significantly due to this temporary condition and further the system is not needed at all to accomplish .the design basis intent of combustible gas control. Therefore, there is neglible effect on safety.

7'

~

II

ENCLOSURE 3 SIGNIFICANT HAZARDS CONS IDERATIOiV DETERMINATION TVA BFNP TS 198

7 A 1 ENCLOSURE 3 Basis for Determination of No Si nificant Hazards The Commission has provided examples of amendments that are not likely to involve significant hazards considerations (48FR14870). Example (vi) involves a change which in some way reduces a safety margin but the results of the changes are clearly within all acceptance criteria with respect to the system or component specified in the Standard Review Plan. The proposed change involves the potential for inability to admit nitrogen to the torus from the CAD system. A single failure in the CAD system would be required to create this situation. The consequences of such a failure are I

that a possible reduction in the amount of mixing of containment atmosphere may take place; however, intermittent operation of containment sprays as called for by operating instruction is listed in Standard Review Plan 6.2.5., Criteria 3 as an acceptable means of ensuring mixing for combustible gas control.

The condensation of steam and atmospheric temperature changes that result from operation of containment sprays cr cate large amounts of containment atmospher e to transfer between the drywell and torus to equalize pressure.

The atmosphere in the torus is monitored during post-accident conditions, and dilution and mixing operations such as nitrogen addition and spraying are initiated as needed to alleviate high concentrations of combustible gas. The plant configuration and operation after this change is implemented are clearly within all acceptance criteria of the Standard Review Plan and therefore this example applies.

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