ML18033B343

Proposed Tech Spec Change 273 Revising Tech Spec 3.7/4.7 Re Containment Sys

ML18033B343
Person / Time
Site:	Browns Ferry
Issue date:	06/04/1990
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18033B342	List: ML18033B340 ML18033B343
References
NUDOCS 9006070433
Download: ML18033B343 (62)

Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (TVA BFN TS 273) 9006070433 90060'5 PDR ADOCK 05000259 P PDC

I UNIT 1 EFFECTIVE PAGE LIST REMOVE INSERT 3.7/4.7-21 3.7/4.7-21 3.7/4.7-22 3.7/4.7-22 3.7/4.7-23 3.7/4.7-23*

3.7/4.7-24 3.7/4.7 24*

3.7/4.7-47 3.7/4.7-47 3.7/4.7-48 3.7/4.7-48

• Denotes overleaf or spillover page.

4 7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.F. Primar Containment Pur e 4.7.F. Prima Containment Pur e

~Ss~te ~Se tern

1. The primary contairohent purge 1. At least once every 18 system 'shall be OPERABLE for months, the pressure drop PURGING, except as specified across the combined HEPA in 3.7.F.2. filters and charcoal adsorber banks shall be

a. The results of the in-place demonstrated to be less cold DOP and halogenated than 8.5 inches of water hydrocarbon tests at design at system design flow flows on HEPA filters and rate (+ 10%).

charcoal adsorber banks shall show g 99% DOP removal a. The tests and sample l and g 99% halogenated hydro- analysis of Specifica-carbon removal when tested tion 3.7.F.l shall be in accordance with performed at least once ANSI N510-1975. per operating cycle or once every 18 months,

b. The results of laboratory whichever occurs first carbon sample analysis shall or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of show g 85% radioactive system operation and methyl iodide removal when following significant tested in accordance with painting, fire, or ASTM D3803 (130'C, chemical release in 95% R. H.). any ventilation zone communicating with the

c. System flow rate shall be system.

shown to be within g 10%

of design flow when tested b. Cold DOP testing shall in accordance with be performed after each ANSI N510-1975. complete or partial replacement of the HEPA

2. If the provisions of 3.7.F.l.a, filter bank or after b, and c cannot be met, the any structural mainte-system shall be declared nance on the system inoperable. The provisions of housing.

Technical Specification 1.C.1 do not apply. PURGING may con- c. Halogenated hydrocarbon tinue using the Standby Gas testing shall be Treatment System. performed after each complete or partial 3~ a ~ The 18-inch primary contain- replacement of the ment isolation valves asso- charcoal adsorber bank ciated with PURGING may be or after any structural open during the RUN mode maintenance on the for a 24-hour period after system housing.

entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode. The OPERABILITY of BFN 3.7/4.7-21 Unit 1

'L q

'

'7 4 7 0

CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.F. Primar Containment Pur e 4.7.F. Primar Containment Pur e

~Sstem ~Sstem 3.7.F.3 (Continued) these primary containment isolation valves is governed by Technical Specification 3.7.D.

b. Pressure control of the containment is normally performed by VENTING through 2-inch primary containment isolation valves which route effluent to the Standby Gas Treatment System.

The OPERABILITY of these primary containment isolation valves is governed by Technical Specification 3.7.D.

3,7.G. Containment Atmos here 4.7.G. Containment Atmos here Dilution S stem CAD Dilution S stem CAD

1. The Containment Atmosphere 1. S stem 0 erabilit Dilution (CAD) System shall be OPERABLE with:

a. Two independent a. Cycle each solenoid systems capable of operated air/nitrogen supplying nitrogen valve through at to the drywell and least one complete torus. cycle of full travel in accordance with Specification 1.0.MM, and at least once per

,month verify that each manual valve in the flow path is open.

b. A minimum supply of b. Verify that the CAD 2,500 gallons of System contains a liquid nitrogen per minimum supply of system. 2,500 gallons of liquid nitrogen twice per week.

BFN 3.7/4.7-22 Unit 1

3'.7 4.7 t

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS LIMITING CONDITIONS FOR OPERATION 3.7.G. Containment Atmos here 4.7.F. Containment Atmos here Dilution S stem CAD Dilution S stem CAD 2 ~ The Containment Atmosphere 2. When FCV 84-8B is inoper-Dilution (CAD) System shall able, each solenoid be OPERABLE whenever the operated air/nitrogen reactor is in the RUN valve of System B shall MODE. be cycled through at least one complete cycle of full travel and each manual valve in the flow path of System B shall be verified open at least once per week.

3~ If one system is inoperable, remain in the reactor may operation for a period of 30 days provided all active components in the other system are OPERABLE.

4~ If Specifications3.7.G.3 3.7.G.1 and 3.7.G.2, or cannot be met, an orderly shutdown shall be initiated and the reactor shall be in the Cold Shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

5. Primary containment pressure shall be limited to a maximum of 30 psig during repressurization 'following a loss of coolant accident.

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.

7. Specifications 3.7.G.6 and 4.7.G.2 are in effect until the first Cold Shutdown of unit 1 after July 20, 1984 or until January 17, 1985 whichever occurs first.

BFN 3.7/4.7-23 Unit 1

)

1

3a7 4. CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE(}UIREMENTS 3.7.H. Containment Atmos here 4.7.H. Containment Atmos here Mon torin CAM S stem- Monitorin CAM S stem HZ~Anal zar Hp ~Anal zar

1. Whenever the reactor is l. Each hydrogen analyzer not in Cold Shutdown, two system shall be independent gas analyzer demonstrated OPERABLE at systems shall be OPERABLE least once per quarter for monitoring the drywell by performing a CHANNEL and the torus. CALIBRATION using standard gas samples containing a nominal eight-volume percent.

hydrogen balance nitrogen.

2. With one hydrogen analyzer 2. Each hydrogen analyzer inoperable, restore at system shall be least two hydrogen demonstrated OPERABLE analyzers to OPERABLE by performing a CHANNEL status within 30 days or FUNCTIONAL TEST be in at least Hot Shutdown monthly.

within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. With no hydrogen analyzer OPERABLE the reactor shall be in Hot Shutdown within 24 hours.

BFN 3.7/4.7-24 Unit 1

11<

C 1A

~-

(Cont'd) 3~.7/4.7 BASES Pressure drop across the combined HEPA filters and charcoal adsorbers of less than six inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

Pressure drop should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082. Iodine removal efficiency tests shall follow ASTM D3803. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52. The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate operability of the filters and~ adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, be chemicals or foreign materials, the same tests and sample analysis shall performed as required for operational use. The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capability.

3.7.F/4.7.F Primar Containment Pur e S stem The Primary Containment Purge System is a non-safety related system that is normally isolated and normally not required to be functional during power operation. The system is designed to provide the preferred exhaust path for purging the primary containment system; however, the Standby Gas Treatment System can be used to perform the equivalent function.

When the Primary Containment Purge System is in operation, the exhaust from the primary containment is first processed by a filter train assembly and then channeled through the reactor building roof exhaust system.

BFN 3.7/4.7-47 Unit 1

f v

3.7/4.7 BASES (Cont'd)

The filter train assembly contains a HEPA (high efficiency particulate air) filter, charcoal adsorber, and centrifugal fan. In-place tests are performed to ensure leak tightness of the filter train assembly of at least 99% and a HEPA efficiency of at least 99% removal of DOP particulates. Laboratory tests are performed on adsorber carbon samples to ensure an 85% removal efficiency for radioactive methyl iodide. Tests are performed to ensure that the system is not operating at a flow significantly different from the design flow, which may affect the removal efficiency of the HEPA filters and charcoal pressure drop across the combined HEPA filters and charcoal adsorbers is adsorbers.'he checked once per operating cycle to be less than 8.5 inches of water at the system design flow rate to ensure that the filters and adsorbers are not clogged with excessive amounts of foreign matter.

The above tests are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082. ,Iodine removal efficiency tests shall follow ASTH D3803. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis shall be performed as required for operational use. The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

The primary containment isolation valves associated with the purging of the prim'ary containment are FCV 64-17, 64-18, 64-19, 64-29, 64-30, 64-32, 64-33, and 76-24. These valves may be open for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

Closure of these large diameter valves within the 24-hour period is needed to retain the reduced oxygen concentration specified in Technical Specification 3.7.A.5.b, and to minimize the time period which the primary containment is not isolated per the guidelines of Branch Technical Position CSB 6-4.

When the large diameter valves noted above are closed, primary containment venting is performed using valves FCV 64-31, 64-34, and 84-20 and the Standby Gas Treatment System. The operability of these primary containment isolation valves is governed by Technical Specification 3.7.D.'he operability of the Standby Gas Treatment System is governed by Technical Specification 3.7.B.

BFN 3.4/4.7-48 Unit 1

C 4

UNIT 2 EFFECTIVE PAGE LIST REMOVE INSERT 3.7/4.7-21 3.7/4.7-21 3.7/4.7-22 3.7/4.7-22 3.7/4.7-23 3.7/4.7-23*

3.7/4.7-24 3.7/4.7 24*

3.7/4.7-47 3.7/4.7-47 3.7/4.7-48 3.7/4.7-48

• Denotes overleaf or spillover page.

'+ V I

I

'I

\

7 4. CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS tern 3.7.F. Prima Containment Pur e 4.7.F. Prima Containment Pur e

~Ss ~Sstem

1. The primary containment purge 1. At least once every 18 system shall be OPERABLE for months, the pressure drop PURGING, except as specified across the combined HEPA in 3.7.F.2. filters and charcoal adsorber banks shall be

a. The results of the in-place demonstrated to be less cold DOP and halogenated than 8.5 inches of water hydrocarbon tests at design at system design flow flows on HEPA filters and rate (g 10%).

charcoal adsorber banks shall show g 99% DOP removal a. The tests and sample and g 99% halogenated hydro- analysis of Specifica-carbon removal when tested tion 3.7.F.1 shall be in accordance with performed at least once ANSI N510-1975. per operating cycle or once every 18 months,

b. The results of laboratory whichever occurs first carbon sample analysis shall or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of show g 85% radioactive system operation and methyl iodide removal when following significant tested in accordance with painting, fire, or ASTM D3803 (130 CS chemical release in 95% R. H.). any ventilation zone communicating with the

c. System flow rate shall be system.

shown to be within + 10%

of design flow when tested b. Cold DOP testing shall in accordance with be performed after each ANSI N510-1975. complete or partial replacement of the HEPA

2. If the provisions of 3.7.F.l.a, filter bank 'or after b, and c cannot be met, the any structural mainte-system shall be declared nance on the system inoperable. The provisions of housing.

Technical Specification 1.C.1 do not apply. PURGING may con- c. Halogenated hydrocarbon tinue using the Standby Gas testing shall be Treatment System. performed after each complete or partial 3 ~ a~ The 18-inch primary contain- replacement of the ment isolation valves asso- charcoal adsorber bank ciated with PURGING may be or after any structural open during the RUN mode maintenance on the for a 24-hour period after system housing.

entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode. The OPERABILITY of BFN 3.7/4.7-21 Unit 2

a Pl

4. CO AINME SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE(}UIREMENTS 3.7.F. Primar Containment Pur e 4.7.F. Prima Containment Pur e

~Ss tery ~Sstem 3.7.F.3 (Continued) these primary containment isolation valves is governed by Technical Specification 3.7.D.

b. Pressure control of the containment is normally performed by VENTING through 2-inch primary containment isolation valves which route effluent to the Standby Gas Treatment System.

The OPERABILITY of these primary containment isolation valves is governed by Technical Specification 3.7.D.

3.7.G. Containment Atmos here 4.7.G. Containment Atmos here Dilut on S stem CAD Dilution S stem C'

1. The Containment Atmosphere 1 S stem 0 erabilit Dilution (CAD) System shall be OPERABLE with:

a. Two independent a. Cycle each solenoid systems capable of operated air/nitrogen supplying nitrogen valve through at to the drywell and least one complete torus. cycle of full travel in accordance with Specification 1.0.MM, and at least once per month verify that each manual valve in the flow path is open.

b. A minimum supply of b. Verify that the CAD 2,500 gallons of System contains a liquid nitrogen per minimum supply of system. 2,500 gallons of liquid nitrogen twice per week.

BFN 3.7/4.7-22 Unit 2

(

3i 7 4 ~ CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.G. Containment Atmos here 4.7.F. Containment Atmos here Dilution S stem CAD Dilution S stem CAD

2. The Containment Atmosphere Dilution (CAD) System shall be OPERABLE whenever the reactor is in the RUN MODE.

3. If one system is inoperable, the reactor may remain in operation for a period of 30 days provided all active components in the other system are OPERABLE.

4. If Specifications 3.7.G.l and 3.7.G.2, or 3.7.G.3 cannot be met, an orderly shutdown shall be initiated and the reactor shall be in the Cold Shutdown condition within 24 hours.

5. Primary containment pressure shall be limited to a maximum of 30 psig during repressurization following a loss of coolant accident.

BFN 3.7/4.7-23 Unit 2

4 7 CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.H. Containment Atmos here 4.7.H. Containment Atmos here Monitorin CAM S stem- Monitorin CAM S stem HA~Anal zer HZ ~Anal zer

1. Whenever the reactor is l. Each hydrogen analyzer not in Cold Shutdown, two system shall be independent gas analyzer demonstrated OPERABLE at systems shall be OPERABLE least once per quarter for monitoring the drywell by performing a CHANNEL and the torus. CALIBRATION using standard gas samples containing a nominal eight-volume percent hydrogen balance nitrogen.

2. With one hydrogen analyzer 2. Each hydrogen analyzer inoperable, restore at system shall be least two hydrogen demonstrated OPERABLE analyzers to OPERABLE by performing a CHANNEL status within 30 days or FUNCTIONAL TEST be in at least Hot Shutdown monthly.

within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. With no hydrogen analyzer OPERABLE the reactor shall be in Hot Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BFN 3.7/4.7-24 Unit 2

3!7/4.7 BASES (Cont'd)

Pressure drop across the combined HEPA filters and charcoal adsorbers of less than six inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign tomatter.

Pressure drop should be determined at least once per operating cycle show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082. Iodine removal efficiency tests shall follow ASTM D3803. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. Each sample should be at least two inches in diameter and a length equal to of the bed. If test results are unacceptable, all- adsorbent in the the'hickness system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52. The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate operability of the filters and adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, tests and sample analysis shall be chemicals or foreign materials, the same performed as required for operational use. The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capability.

3.7.F/4.7.F Primar Containment Pur e S stem The Primary Containment Purge System is a non-safety related system that is normally isolated and normally not required to be functional during power operation. The system is designed to provide the preferred exhaust path for purging the primary containment system; however, the Standby Gas Treatment System can be used to perform the equivalent function.

When the Primary Containment Purge System is in operation, the exhaust from the primary containment is first processed by a filter train assembly and then channeled through the reactor building roof exhaust system.

BFN 3.7/4.7-47 Unit 2

PlI 1

4

3.'7/A.7 BASES (Cont'd)

~-

The filter train assembly contains a HEPA (high efficiency particulate air) filter, charcoal adsorber, and centrifugal fan. In-place tests are performed to ensure leak tightness of the filter train assembly of at least 99% and a HEPA efficiency of at, least 99% removal of DOP particulates. Laboratory tests are performed on adsorber carbon samples to ensure an 85% removal efficiency for radioactive methyl iodide. Tests are performed to ensure that the system is not operating at a flow significantly different from the design flow, which may affect the removal efficiency of the HEPA filters and charcoal adsorbers.

The pressure drop across the combined HEPA filters and charcoal adsorbers is checked once per operating cycle to be less than 8.5 inches of water at the system design flow rate to ensure that the filters and adsorbers are not clogged with excessive amounts of foreign matter.

The above tests are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082. Iodine removal efficiency tests shall follow ASTM D3803. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tr'ay for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could materials, become contaminated the tests from the fumes,.

analysis shall be chemicals, or foreign same and sample performed as required for operational use. The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

The primary containment isolation valves associated with the purging of the primary containment are FCV 64-17, 64-18, 64-19, 64-29, 64-30, 32, 64-33, and 76-24. These valves may be open for a 24-hour period after'ntering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

Closure of these large diameter valves within the 24-hour period is needed to retain the reduced oxygen concentration specified in Technical Specification 3.7.A,5.b, and to minimize the time period which the primary containment is not isolated per the guidelines of Branch Technical Position CSB 6-4.

When the large diameter valves noted above are closed, primary containment venting is performed using valves FCV 64-31, 64-34, and 84-20 and the Standby Gas Treatment System. The operability of these primary containment isolation valves is governed by Technical Specification 3.7.D. The operability of the Standby Gas Treatment System is governed by Technical Specification 3.7.B.

BFN 3.4/4.7-48 Unit 2

UNIT 3 EFFECTIVE PAGE LIST REMOVE INSERT iii iii iv*

iv 3.7/4.7-21 3.7/4.7-21 3.7/4.7-22 3.7/4.7-22 3.7/4.7-23 3.7/4.7-23*

3.7/4.7-23a 3.7/4.7 23a 3.7/4.7-45 3.7/4.7-45*

3.7/4.7-46 3.7/4.7-46 3.7/4.7-47 3.7/4.7-47 3.7/4.7-48 3.7/4.7-48*

• Denotes overleaf or spillover page.

,p1 a

.Section P~ae No.

t F. Recirculation Pump Operation . 3.6/4.6-12 G. Structural Integrity . 3.6/4.6-13 H. Snubbers 3.6/4.6-15 3.7/4.7 Containment Systems 3.7/4.7-1 A. Primary Containment. 3.7/4.7-1 B. Standby Gas Treatment System . 3.7/4.7-13 C. Secondary Containment. 3.7/4.7-16 D. Primary Containment Isolation Valves 3.7/4.7-17 E. Control Room Emergency Ventilation . 3.7/4.7-19 F. Primary Containment Purge System . 3.7/4.7-21 G. Containment Atmosphere Dilution System (CAD) 3.7/4.7-22 H. Containment Atmosphere Monitoring (CAM)

,System H2 Analyzer 3.7/4.7-23a 3.8/4.8 Radioactive Materials 3.8/4.8-1 A. Liquid Effluents . 3.8/4.8-1 B. Airborne Effluents 3.8/4.8-2 C. Radioactive Effluents Dose 3.8/4.8-6 D. Mechanical Vacuum Pump 3.8/4.8-6 E. Miscellaneous Radioactive Materials Sources 3.8/4.8-7 F. Solid Radwaste 3.8/4.8-9 3.9/4.9 Auxiliary Electrical System . 3.9/4.9-1 A. Auxiliary Electrical Equipment ~ ~ ~ 3.9/4.9-1 B. Operation with Inoperable Equipment. 3.9/4.9-8 C. Operation in Cold Shutdown . 3.9/4.9-14 3;10/4.10 Core Alterations 3.10/4.10-1 A. Refueling Interlocks . 3.10/4.10-1 Core Monitoring. 3.10/4.10-4 C. Spent Fuel Pool Water. 3.10/4.10-7 BFN Unit 3

Je

~

(

S'ection ~Pa e No D. Reactor Building Crane 3.10/4.10-8 E. Spent Fuel Cask. 3.10/4.10-9 F. Spent Fuel Cask Handling-Refueling Floor 3.10/4.10-9 3.11/4.11 Fire Protection Systems 3.11/4.11-1 A. Fire Detection Instrumentation . 3.11/4.11-1 B. Fire Pumps and Water Distribution Mains 3.11/4.11-2 C. Spray and/or Sprinkler Systems 3.11/4.11-7 D. C02 System . 3.11/4.11-8 E. Fire Hose Stations 3.11/4.11-9 F. Yard Fire Hydrants and Hose Houses 3.11/4.11-11 G. Fire-Rated Assemblies 3.11/4.11-12 H. Open Flames, Welding and Burning in the Cable. . . . 3.11/4.11-13 Spreading Room 5.0 Major Design Features 5.0-1 5.1 Site Features. ~

=

~ ~ ~ 5 ~0 1 5.2 Reactor. 5.0-1 5.3 Reactor Vessel 5.0-1 5.4 Containment. ~ ~ 5.0-1 5.5 Fuel Storage 5.0-1 5a6 Seismic Design . ~ ~ ~ 5.0-2 BFN Unit 3 iv AViBtot,!Et!7 HO. I4 0

t rh

St 4 CO t

A NMENT SYSTEMS SURVEILLANCE REQUIREMENTS LIMITING CONDITIONS FOR OPERATION 3.7.F. Primar Containment Pur e 4.7.F. Primar Containment Pur e

~Sstem ~Ss~te

1. The primary containment purge 1. At least once every 18 system shall be OPERABLE for months, the pressure drop PURGING, except as specified across the combined HEPA in 3.7.F.2. filters and charcoal adsorber banks shall be

a. The results of the in-place demonstrated to be less cold DOP and halogenated than 8.5 inches of water hydrocarbon tests at design at system design flow flows on HEPA filters and rate (g 10%).

charcoal adsorber banks shall show g 99% DOP removal a. The tests and sample )

and g 99% halogenated hydro- analysis of Specifica-carbon removal when tested tion 3.7.F.1 shall be in accordance with performed at least once ANSI N510-1975. per operating cycle or once every 18 months,

b. The results of laboratory whichever occurs first carbon sample analysis shall or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of show g 85% radioactive system operation and methyl iodide removal when following significant tested in accordance with painting, fire, or .

ASTM D3803 (130'C, chemical release in 95% R. H.). any ventilation zone communicating with the

c. System flow rate shall be system.

shown to be within g 10%

of design flow when tested b. Cold DOP testing shall in accordance with be performed after each ANSI N510-1975. complete or partial replacement of the HEPA

2. If the provisions of 3.7.F.l.a, filter bank or after b, and c cannot be met, the any structural mainte-system shall be declared nance on the system inoperable. The provisions of housing.

Technical Specification 1.C.1 do not apply. PURGING may con- c. Halogenated hydrocarbon tinue using the Standby Gas testing shall be Treatment System. performed after each complete or partial 3 ~ a~ The 18-inch primary contain- replacement of the ment isolation valves asso- charcoal adsorber bank ciated with PURGING may be or after any structural open during the RUN mode maintenance on the for a 24-hour period after . system housing.

entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode. The OPERABILITY of BFN 3.7/4.7-21 Unit 3

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4. CONTAINMENT SYS EMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.F. Pri ar Containment Pur e 4.7.F. Primar Containment Pur e

~Sstem ~Ss tern 3.7.F.3 (Continued) these primary containment isolation valves is governed by Technical Specification 3.7.D.

b. Pressure control of the containment is normally performed by VENTING through 2-inch primary containment isolation valves which route effluent to the Standby Gas Treatment System.

The OPERABILITY of these primary containment isolation valves is governed by Technical Specification 3.7.D.

3. 7.G. Containment Atmos here 4.7.G. Containment Atmos here Dilution S stem CAD Dilution S stem CAD

1. The Containment Atmosphere 1. S stem 0 erabilit Dilution (CAD) System shall be OPERABLE with:

a. Two independent a. Cycle each solenoid systems capable of operated air/nitrogen supplying nitrogen valve through at to the drywell and least one complete torus. cycle of full travel in accordance with Specification 1.0.MM, and at least once per month verify that each manual valve in the flow path is open.

b. A minimum supply of b. Verify that the CAD 2,500 gallons of System contains a liquid nitrogen per minimum supply of system. 2,500 gallons of liquid nitrogen twice per week.

BFN 3.7/4.7-22 Unit 3

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3 4. CONT I NT SYSTE S LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE UIREMENTS 3.7.G. Co tainme t Atmos here 4.7.F. Containment tmos here Dilution S stem CAD Dilution S stem CAD

2. The Containment Atmosphere Dilution (CAD) System shall be OPERABLE whenever the reactor is in the RUN MODE.

3. If one system is inoperable, the reactor may remain in operation for a period of 30 days provided all active components in the other system are OPERABLE.

4. If Specifications3.7.G.3 3.7.G.l and 3.7.G.2, or cannot be met, an orderly shutdown shall be initiated

,

and the reactor shall be in the Cold Shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

5. Primary containment pressure shall be limited to a maximum of 30 psig during repressurization following a loss of coolant accident.

BFN 3.7/4.7-23 Unit 3

7/4. CONTAINMENT SYSTEMS LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.H. Containment Atmos here 4.7.H. Containment Atmos here Mon torin CAM S stem- Monitorin CAM S stem HZ~Ana zar HZ A~nal zar

1. Whenever the reactor is 1. Each hydrogen analyzer not in Cold Shutdown, two system shall be independent gas analyzer demonstrated OPERABLE at systems shall be OPERABLE least once per quarter for monitoring the drywell by performing a CHANNEL and the torus. CALIBRATION using standard gas samples containing a nominal eight-volume percent hydrogen balance nitrogen.

2. With one hydrogen analyzer 2. Each hydrogen analyzer inoperable, restore at system shall be least two hydrogen demonstrated OPERABLE analyzers to OPERABLE by performing a CHANNEL status within 30 days or FUNCTIONAL TEST be in at least Hot Shutdown monthly.

within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. With no hydrogen analyzer OPERABLE the reactor shall be in Hot, Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BFN 3.7/4.7-23a

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These valves are highly reliable, have low service requirements and most, are normally closed. The initiating sensors and associated trip logic are also checked to demonstrate the capability for automatic isolation. The test interval of once per operating cycle for automatic initiation results in a failure probability of 1.1 x 10 7 that a .line will not isolate. More frequent testing for valve operability in accordance with Specification 1.0.MM results in a greater assurance that the valve will be operable when needed.

The main steamline isolation valves are functionally tested per Specification 1.0.MM to establish a high degree of reliability.

The primary containment is penetrated by several small diameter instrument lines connected to the reactor coolant system. Each instrument line contains a 0.25-inch restricting orifice inside the primary containment and an excess flow check valve outside the primary containment.

3.7.E/4.7.E Control Room Emer enc Ventilation The control room emergency ventilation system is designed to filter the control room atmosphere for intake air and/or for recirculation during control room isolation conditions. The control room emergency ventilation system is designed to automatically start upon control room isolation and to maintain the control room pressure to the design positive pressure so that all leakage should be out leakage. During cycle 6, CREVS has been declared inoperable only because it does not meet its design basis for essentially zero unfiltered inleakage. Reactor power operations and fuel movement are acceptable until just prior to startup for unit 2 cycle 7. During cycle 6, CREVS must be demonstrated to be functional by performing all applicable surveillances. In the event that the applicable surveillances are not successfully performed, the actions required by the LCOs must be complied with.

High efficiency particulate absolute (HEPA) filters are installed prior to the charcoal adsorbers to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential intake of radioiodine to the control room. The in-place test results should indicate a system leak tightness of less than 1 percent, bypass leakage for the charcoal adsorbers and a HEPA efficiency of at least 99 percent removal of DOP particulates. The laboratory carbon sample test results should indicate a radioactive methyl iodide removal efficiency of at least 90 percent, for expected accident conditions. If the efficiencies of the HEPA filters and charcoal adsorbers are as specified, the resulting doses will be less than the allowable levels stated in Criterion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10 CFR Part 50. Operation of the fans significantly different from the design flow will change the removal efficiency of the HEPA filters and charcoal adsorbers.

If the system is found to be inoperable, there is no immediate threat to the control room and reactor operation or refueling operation may continue for a limited period of time while repairs are being made. If the system cannot be repaired within seven days, the reactor is shutdown and brought to Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or refueling operations are terminated.

BFN 3.7/4.7-45 Unit 3

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Pressure drop across the combined HEPA filters and charcoal adsorbers of less than six inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

Pressure drop should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082. Iodine removal efficiency tests shall follow ASTM D3803. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all'dsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52. The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate operability of the filters and adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use. The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capability.

3.7.F/4.7.F Pr mar Containment Pur e S stem The Primary Containment Purge System is a non-safety related sy'tem that is normally isolated and normally not, required to be functional during power operation. The system is designed to provide the preferred exhaust path for purging the primary containment system; however, the Standby Gas Treatment System can be used to perform the equivalent function.

When the Primary Containment Purge System is in operation, the exhaust from the primary containment is first processed by a filter train assembly and then channeled through the reactor building roof exhaust system.

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The filter train assembly contains a HEPA (high efficiency particulate air) filter, charcoal adsorber, and centrifugal fan. In-place tests are performed to ensure leak tightness of the filter train assembly of at least 99% and a HEPA efficiency of at least 99% removal of DOP particulates. Laboratory tests are performed on adsorber carbon samples to ensure an 85% removal efficiency for radioactive methyl iodide. Tests are performed to ensure that the system is not operating at a flow significantly different from the design flow, which may affect the removal efficiency of the HEPA filters and charcoal adsorbers.

The pressure drop across the combined HEPA filters and charcoal adsorbers is checked once per operating cycle to be less than 8.5 inches of water at the system design flow rate to ensure that the filters and adsorbers are not clogged with excessive amounts of foreign matter.

The above tests are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with USAEC Report-1082. Iodine removal efficiency tests shall follow ASTM D3803. The charcoal adsorber efficiency test procedures should allow'for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least -two samples. Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52.

The replacement tray for the adsorber tray removed for the test should m'eet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed in accordance to ANSI N510-1975. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated tests from the fumes, analysis shall be chemicals, or foreign materials, the same and sample performed as required for operational use. The determination of significance shall be made by the operator on duty at the time of the incident.

Knowledgeable staff members should be consulted prior to making this determination.

The primary containment isolation valves associated with the purging of the primary containment are FCV '64-17, 64-18, 64-19, 64-29, 64-30, 64-32, 64-33, and 76-24. These valves may be open for a 24-hour period after entering the RUN mode and/or for a 24-hour period prior to entering the SHUTDOWN mode.

Closure of these large diameter valves within the 24-hour period is needed to retain the reduced oxygen concentration specified in Technical Specification 3.7.A.5.b, and to minimize the time period which the primary containment is not isolated per the guidelines of Branch Technical Position CSB 6-4.

When the large diameter valves noted above are closed, primary containment venting is performed using valves FCV 64-31, 64-34, and 84-20 and the Standby Gas Treatment System. The operability of these primary containment isolation valves is governed by Technical Specification 3.7.D. The operability of the Standby Gas Treatment System is governed by Technical Specification 3.7.B.

BFN 3.4/4.7-47 Unit 3

1 THIS PAGE INTENTIONALLY LEFT BLANK BFN s.u..7-48 (

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ENCLOSURE 2 TECHNICAL SPECIFICATION (TS) AMENDMENT DESCRIPTION AND JUSTIFICATION BROWNS FERRY NUCLEAR PLANT (BFN)

REASON FOR CHANGE BFN units 1, 2, and 3 TS section 3.7.F (Primary Containment Purge System) and its bases are being revised to more accurately reflect the operations of purging and venting of the primary containment.

DESCRIPTION OF THE PROPOSED CHANGE The existing TS Limiting Conditions for Operation (LCO) 3.7.F reads:

"1. The primary containment shall be normally vented and,purged through the primary containment purge system. The standby gas treatment system may be used when primary containment purge system is inoperable.

2. a. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g 99% DOP removal and g 99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

b. The results of laboratory carbon sample analysis shall show g 85%

radioactive methyl iodide removal when tested in accordance with ASTM D3803 (130'C 95% R. H.)

c. System flow rate shall be shown to be within g 10% of design flow when tested in accordance with ANSI N510-1975."

The proposed change to TS LCO 3.7.F would read:

"1. The primary containment purge system shall be OPERABLE for PURGING, except as specified in 3.7.F.2.

a. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show g 99% DOP removal and g 99% halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

b. The results of laboratory carbon sample analysis shall show g 85%

radioactive methyl iodide removal when tested in accordance with ASTM D3803 (130 C, 95% R. H.).

c. System flow rate shall be shown to be within g 10% of design flow when tested in accordance with ANSI N510-1975.

2. If the provisions of 3.7.F.l.a, b, and c cannot be met, the system shall be declared inoperable. The provisions of Technical Specification 1.C.1 do not apply. PURGING may continue using the Standby Gas Treatment System.

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Page 2 of 3 3.a. The 18 inch primary containment isolation valves associated with PURGING may be open during the RUN mode for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period after entering the RUN mode and/or- for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period prior to entering the SHUTDOWH mode. The OPERABILITY of these primary containment isolation valves is governed by Technical Specification 3.7.D.

b. Pressure control of the containment is normally performed by VENTING through 2 inch primary containment isolation valves which route effluent to the Standby Gas Treatment System. The OPERABILITY of these primary containment isolation valves is governed by Technical Specification 3.7.D."

The surveillance requirements in section 4.7.F are renumbered to match the revised LCO 3.7.F. The bases for section 3.7.F/4.7.F are revised to match the LCO revisions. The revision to the bases section is provided by Enclosure l.

JUSTIFICAT 0 FOR THE PROPOSED CHA GE The primary containment purge system (PCPS) is designed to provide the primary exhaust path for gases leaving the primary containment during purging operations and the capability to vent the containment. Purging is the controlled discharge of air or nitrogen from the containment such that replacement of air or nitrogen is required. The standby gas treatment system (SGTS) provides the primary exhaust path for venting the containment for the purpose of pressure control. Venting is the controlled discharge of air or gas such that replacement air or gas is not provided nor required. The SGTS also provides the secondary, and a safety related, exhaust path during purging operations. The PCPS filters the exhaust gas through a charcoal adsorber and a HEPA filter prior to discharge to the reactor building ventilation system.

This filtering ensures that releases through the PCPS do not result in site boundary doses in excess of 10 CFR 100 limits. Th'e SGTS, which provides the secondary and safety related exhaust path also provides filtering to ensure that site boundary doses do not exceed 10 CFR 100 limits. Figure 1 depicts the various purge and vent paths of interest relative to this TS change.

Figure 2 shows the inlet flow paths.

The PCPS is normally used only when the 18 inch diameter containment isolation valves are open. These valves are permitted to be open only for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period after entering the run mode and/or a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period prior to entering the shutdown mode for containment inerting/deinerting (TS LCO 3.7.A.5.b).

During other periods of operation while in the run mode, the PCPS is normally isolated from the primary containment by two isolation valves in series.

The exhaust gas processed through the PCPS is monitored by a radiation monitor in the reactor building ventilation system. If the setpoint on the radiation monitor is reached, a primary containment isolation signal is generated, which results (among other things) in the closing of the primary containment isolation valves to the PCPS.

The current TS states that the SGTS may be used when the PCPS is inoperable.

This statement, could be misinterpreted to mean that the large diameter vent path to the SGTS may be used during any mode of operation if the PCPS is inoperable. Proposed TS LCO 3.7.F.3.a clarifies that these primary containment isolation valves are to be open only during a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period after entering the run mode and/or a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period prior to entering the shutdown mode. This is consistent with TS LCO 3.7.A.5.b which governs oxygen control.

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Page 3 of 3 For maintaining primary containment pressure control during power operation, a 2 inch vent path with a remote-manual operated Containment Atmosphere Dilution (CAD) valve (FCV-84-20) is used. This path proceeds through the SGTS and the plant stack and is limited to 100 SCFM. There are radiation monitors located in this vent path to monitor any such releases. FCV-84-20 receives a primary containment isolation signal and is capable of closing within 10 seconds of receiving the signal. This is verified in accordance with TS table 3.7.A, Primary Containment Isolation Valves. In addition, the containment isolation valves (FCV-64-31 from the drywell and FCV-64-34 from the torus) are redundant primary containment isolation valves for FCV-84-20 and will close in 5 seconds following the receipt of an isolation signal. All of these valves are designed to close against the drywell design pressure of 56 psig. Therefore, the valves are capable of closing in LOCA conditions, and the radioactive release due to the use of these valves for pressure control at the initiation of a LOCA'ould be within the 10 CFR 100 limits. Proposed TS LCO 3.7.F.3.b clarifies that this is the method for primary containment. pressure control and that operability of the 2 inch primary containment isolation valves is governed by TS 3.7.D.

The requirements for HEPA filter, charcoal adsorber, and system flow rate testing remain unchanged but are relocated within TS 3.7.F from section 2.a,b,c to l.a,b,c, to more clearly fit with the revised TS 3.7.F. The surveillance requirements in section 4.7.F are also renumbered to match the revised LCO 3.7.F. No new surveillance requirements have been introduced.

The bases are also revised in line with these changes.

The 2 inch pressure control path is the acceptable venting path to be used during power operation. The actual use of the 18 inch diameter purge path is not changed by the proposed TS changes. The TS is being revised to clarify that the large diameter primary containment isolation valves are to be open only for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period after entering the run mode and/or a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period prior to entering the shutdown mode. This proposed change to TS 3.7.F does not affect operation of any system or any previously evaluated accident condition.

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ENCLOSURE 3 PROPOSED DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION BROWNS FERRY NUCLEAR PLANT (BFN)

DESCRI T 0 OF PROPOSED TECHNICAL SPECIFICATIO S AMENDMENT BFN units 1, 2, and 3 TS section 3.7.F/4.7.F (Primary Containment Purge System) and its bases are being revised to more accurately reflect the operations of purging and venting of the primary containment.

BASIS FOR PROPOSED NO SIG IFICANT HAZARDS CONSIDERATIO DETERMINATION NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident .

previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant. reduction in a margin of safety.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The primary containment purge system (PCPS) is designed to provide the primary exhaust path for gases leaving the primary containment during purging operations and the capability to vent the containment. The standby gas treatment system (SGTS) provides the primary exhaust path for venting the containment for the purpose of pressure control. It also provides the secondary exhaust path during purging operations.

The purpose of this proposed change is to more accurately describe the method by which BFN operates the PCPS. This change clarifies the use of the 18 inch primary containment isolation valves for the deinerting/inerting process for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after placing the reactor mode switch in the RUN position and/or for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reactor shutdown. This is the normal operation of the system. In the event the PCPS is unavailable, the 18 inch vent line through the SGTS may be used as a backup for purging the containment with the same time restrictions.

The two containment isolation valves associated with the PCPS receive a primary containment isolation signal. The alternate 18 inch line going through the SGTS is also isolated if these two valves are closed.

The vent path from primary containment is the small diameter containment atmospheric dilution (CAD) valves. These 2 inch valves are used to maintain primary containment pressure control during normal reactor operations. These valves receive a primary containment isolati.on signal which overrides the handswitch and closes the .valves.

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%4 Page 2 of 2 This change does not involve any physical alteration of the containment, design function of any existing equipment, or add any new equipment to

'FN. The operating conditions and analysis in the BFN Final Safety Analysis Report (FSAR) are still applicable and will not change as a result of this .change. This change only provides additional clarification and makes the TS more consistent with the operation of the plant. This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The change does not add any new equipment to the plant or require any existing equipment to be operated in a different manner from which it was designed to operate. Since a new failure mode is not introduced by the change, a new or different kind of accident could not result.

3. The proposed change does not involve a significant reduction in a margin of safety.

The primary containment isolation valves associated with purging are currently allowed to be open for purging. This change will specifically

-limit the time they are allowed to be open for purging to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the reactor is placed in the run mode and/or for up. to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reactor shutdown. If a LOCA were to occur, the isolation valves would receive a isolation signal and close.

The vent path to the outside environment is through the CAD valves. The dose consequences through an open pressure control path during a LOCA would be below the 10 CFR 100 limits. The pressure control valve also receives a primary containment isolation signal and is capable of closing within 10 seconds of the isolation signal.

Since this proposed TS only provides clarification and the initial design requirements are not altered, there is no reduction in the margin of safety at BFN.

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