ML18036B107

Proposed Tech Specs Re LPCI Operability When Rhrs Is Aligned to Shutdown Cooling Mode

ML18036B107
Person / Time
Site:	Browns Ferry
Issue date:	12/23/1992
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18036B106	List: ML18036B105 ML18036B107
References
TVA-BFN-TS-328, NUDOCS 9212300092
Download: ML18036B107 (24)

Text

PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 1 9212300092 921223 PDR ADOCK OS0002S9 P PDR

3.5.B t v t 4.5.B. t v t

~gt~ (LPCI and Containment gg~R (LPCI and Containment Cooling) Cooling)

1. The RHRS shall be OPERABLE l. a. Simulated Once/

Automatic Operating (1) PRIOR TO STARTUP Actuation Cycle from a COLD Test CONDITION; or

b. Pump OPERA- Per (2) when there is BILITY Specification irradiated fuel in l.O.MM the reactor vessel and when the reactor c~ Motor Opera- Per vessel pressure is ted valve Specification greater than OPERABILITY 1.0.MM atmospheric, except as specified in 'd ~ Pump Flow Once/3 Specifications 3.5.B.2, Rate months through 3.5.B.7.

e. Test Check Per Valve Specification 1.0.MM Verify that Once/Month each valve (manual, power-operated, or automatic) in the injection flow-path that is not locked, sealed, or otherwise secured in posi-tion, is in its correct position.

go Verify LPCI Once/Month subsystem cross-tie valve is closed an4 power removed from valve operator.

Low pressure coolant injection Except that an (LPCI) may be considered OPERABLE automatic valve during alignment and operation capable of auto-for shutdown cooling with reactor matic return to its steam dome pressure less than ECCS position when 105 psig in HOT SHUTDOWN, if an ECCS signal is capable of being manually present may be in realigned and not otherwise a position for another inoperable. mode of operation.

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8. If Specifications 3.5.B.1 8. No additional surveillance required.

through 3.5.B.7 are not met, an orderly shutdown shall be initiated and the reactor shall be placed in the COLD SHUTDOWN CONDITION within 24 hours.

9. When the reactor vessel 9. When the reactor vessel pressure is atmospheric and pressure is atmospheric, irradiated fuel is in the the RHR pumps and valves reactor vessel, at least one that are required to be RHR loop with two pumps or two OPERABLE shall be loops with one pump per loop demonstrated to be OPERABLE

. shall be OPERABLE. The per Specification 1.0.NN.

diesel generators pumps'ssociated must also be OPERABLE. Low pressure coolant injection (LPCI) may be considered OPERABLE during alignment and operation for shutdown cooling, if capable of being manually realigned and not otherwise inoperable.

10. If the conditions of 10. No additional surveillance Specification 3.5.A.5 are met, required.

LPCI and containment cooling are not required.

When there is irradiated fuel 11. The RHR pumps on the in the reactor and the reactor adjacent units which supply is not in the COLD SHUTDOWN cross-connect capability CONDITION, 2 RHR pumps and shall be demonstrated to be associated heat exchangers and OPERABLE per Specification valves on an adjacent unit 1.0.MM when the cross-must be OPERABLE and capable connect capability of supplying cross-connect is required.

capability except as specified in Specification 3.5.B.12 below. (Note: Because cross-connect capability is not a short-term requirement, a component is not considered inoperable if cross-connect capability can be restored to service within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.)

BFN 3.5/4.5-7 Unit 1

PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 2

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(LPCI and Containment 4.5 B

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1. The RHRS shall be OPERABLE l. a. Simulated Once/

Automatic Operating (1) PRIOR TO STARTUP Actuation Cycle from a COLD Test CONDITION; or

b. Pump OPERA- Per (2) when there is BILITY Specification irradiated fuel in 1.0.MM the reactor vessel and when the reactor c~ Motor Opera- Per vessel pressure is ted valve Specification greater than OPERABILITY 1.0.MM atmospheric, except as specified in d~ Pump Flow Once/3 Specifications 3.5.B.2, Rate months through 3.5.B.7.

e. Testable Per Check Specification Valve 1.0.MM Verify that Once/Month each valve (manual, power-operated, or automatic) in the injection flow-path that is not locked, sealed, or otherwise secured in posi-tion is in 1 ts correct position.

Verify LPCI Once/Month subsystem cross-tie valve is closed ~

removed from power valve operator.

Low pressure coolant injection Except that an (LPCI) may be considered OPERABLE automatic valve during alignment and operation capable of auto-for shutdown cooling with reactor matic return to its steam dome pressure less than ECCS position when 105 psig in HOT SHUTDOWN, if an ECCS signal is capable of being manually present may be in realigned and not otherwise a position for another inoperable. mode of operation.

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8. If Specifications 3.5.B.1 8. No additional surveillance through 3.5.B.7 are not met, required.

an orderly shutdown shall be initiated and the reactor shall be placed in the COLD SHUTDOWN CONDITION within 24 hours.

9. When the reactor vessel 9. When the reactor vessel pressure is atmospheric and pressure is atmospheric, irradiated fuel is in the the RHR pumps and valves reactor vessel, at least one that are required to be RHR loop with two pumps or two OPERABLE shall be loops with one pump per loop demonstrated to be OPERABLE

'hall 'be OPERABLE. The per Specification 1.0.NM.

diesel generators pumps'ssociated must also be OPERABLE. Low pressure coolant injection (LPCI) may be considered OPERABLE during alignment and operation for shutdown cooling, if capable of being manually realigned and not otherwise inoperable.

10. If the conditions of 10. No additional surveillance Specification 3.5.A.5 are met, required.

LPCI and containment cooling are not required.

When there is irradiated fuel 11. The RHR pumps on the in the reactor and the reactor adjacent units which supply is not in the COLD SHUTDOWN cross-connect capability CONDITION, 2 RHR pumps and shall be demonstrated to be associated heat exchangers and OPERABLE per Specification valves on an adjacent unit 1.0.NN when the cross-must be OPERABLE and capable connect capability of supplying cross-connect is required.

capability except as specified in Specification 3.5.B.12 below. (Note: Because cross-connect capability is not a short-term requirement, a component is not considered inoperable if cross-connect capability can be restored to service within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.)

BFN 3.5/4.5-7 Unit 2

PROPOSED TECHNICAL SPECIFICATION CHANGE BROWNS FERRY NUCLEAR PLANT UNIT 3

3.5.B t 4.5.B v tug

~HR53. (LPCI and Containment QER~ (LPCI and Containment Cooling) Cooling)

1. The RHRE shall be OPERABLE 1. a. Simulated Once/

Automatic Operating (1) PRIOR TO STARTUP Actuation Cycle from a COLD Test CONDITION; or b~ Pump OPERA- Per (2) when there is BILITY Specification irradiated fuel in 1.0.MM the reactor vessel and when the reactor c~ Motor Opera- Per vessel pressure is ted valve Specification greater than OPERABILITY 1.0.MM atmospheric, except as specified in d~ Pump Flow Once/3 Specifications 3.5.B.2, Rate months through 3.5.B.7.

e. Testable Per Check Specification Valve 1.0.MM Verify that Once/Month each valve (manual, power-operated, or automatic) in the injection flow-path that is not locked, sealed, or otherwise secured in posi-tion, iy in its correct" position.

Veri.fy LPCI Once/Month subsystem cross-tie valve is closed gag power removed from valve operator.

Low pressure coolant injection Except that an (LPCI) may be considered OPERABLE automatic valve during alignment and operation capable of auto-for shutdown cooling with reactor matic return to its steam dome pressure less than ECCS position when 105 psig in HOT SHUTDOWN, if an ECCS signal is capable of being manually present may be in realigned and not otherwise a position for another inoperable. mode of operation.

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8. If Specifications 3.5.B.1 8. No additional surveillance through 3.5.B.7 are not met, required.

an orderly shutdown shall be initiated and the reactor shall be placed 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 />.

9. When the reactor vessel 9. When the reactor vessel pressure is atmospheric and preSsure is atmospheric, irradiated fuel is in the .the RHR pumps and valves reactor vessel, at least one that are required to be RHR loop with two pumps or two OPERABLE shall be loops with one pump per loop demonstrated to be

,-.,shall be, OPERABLE. The OPERABLE per diesel generators pumps'ssociated Specification 1.0.MM.

must also be OPERABLE. Low pressure coolant injection (LPCI) may be considered OPERABLE during alignment and operation for shutdown cooling, if capable of being manually realigned and not otherwise inoperable.

10. If the conditions of 10. No additional surveillance Specification 3.5.A.5 are met, required.

LPCI and containment cooling are not required.

When there is irradiated fuel ll. The B and D RHR pumps on in the reactor and the reactor unit 2 which supply is not in the COLD SHUTDOWN cross-connect capability CONDITION, 2 RHR pumps and shall be demonstrated to associated heat exchangers and be OPERABLE per valves on an adjacent unit Specification 1.0.MM when must be OPERABLE and capable the cross-connect of supplying cross-connect capability is required.

capability except as specified in Specification 3.5.B.12

.below. (Note: Because cross-connect capability is not a short-term requirement, a component is not considered inoperable if cross-connect capability can be restored to service within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.)

BFN 3.5/4.5-7 Unit 3

ENCLOSURE 2 BROWNS FERRX NUCLEAR PLANT (BFN)

UNITS 1q 2 q AND 3 (TVA BFN TECHNICAL SPECIFICATION NO. 328)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION REASON FOR THE CHANGE The purpose of this change is to allow a Low Pressure Coolant Injection (LPCI) loop to be considered operable when it is aligned for shutdown cooling (SDC).

TVA has requested two waivers of compliance to allow a LPCI loop to be considered operable under these conditions, first on February 25, 1992 and last on September 28, 1992. In these requests for a waiver of compliance, TVA commi.tted to subsequently initiate a request for a TS change.

DESCRIPTION OF THE PROPOSED CHANGE The proposed-change applies to all three BFN units. The change adds a clarification to Limiting Condition for Operation (LCO) 3.5 as follows:

1. Add the following "g" footnote to present paragraph 3.5.B.1:

Low pressure coolant injection (LPCI) may be considered OPERABLE during alignment and operation for shutdown cooling with reactor steam dome pressure less than 105 psig in HOT SHUTDOWN, if capable of being manually realigned and not otherwise inoperable."

2. Add the following to the end of present paragraph 3.5.B.9:

"Low pressure coolant injection (LPCI) may be considered OPERABLE during alignment and operation for shutdown cooling, if capable of being manually realigned and not otherwise inoperable."

JUSTIFICATION FOR THE PROPOSED CHANGE Present LCOs in 3.5.B for operability of Residual Heat Removal (RHR), LPCI mode do not state that. a RHR loop aligned for SDC can be considered operable for LPCI i.f capable of being manually realigned and not otherwise inoperable.

This stated allowance for LPCI operability is included in the TSs for some later operating BWR plants and in the new improved standard BWR Technical Specifications, NUREG 1433. The speci.fic NRC approved allowance for some other utiliti.es and the new STS provides thi.s interpretation of operability for LPCI at lese than the cut-in pressure permissive for RHR Shutdown Cooling (105 psig for Browns Ferry) wi.th the reactor in hot or cold shutdown.

TS 3.5.B.1 addresses operability requirements for RHR (LPCI and Containment Cooling) for the conditions prior to startup from a cold condition or when there is irradiated fuel in the reactor vessel and reactor vessel pressure is greater than atmospheric. The proposed change for TS 3.5.B.l will add a footnote to clarify that below a reactor steam dome pressure of 105 psig in hot shutdown, LPCI may be considered operable during alignment and operation for SDC if capable of being manually realigned and not otherwise inoperable.

The proposed change will facilitate maintenance or repair activi.ties on the RHR loop not bei.ng used for SDC and will explicitly state when SDC can be utilized during plant shutdowns.

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ENCLOSURE 2 (CONTINUED) Page 2 of 2 BROWNS PERRY NUCLEAR PLANT (BFN)

UNITS 1~ 2~ AND 3 (TVA BFN TECHNICAL SPECIFICATION NO 328)

REASON FOR THE CHANGE DESCRIPTION AND i7USTXFXCATXON JUSTIFICATION FOR THE PROPOSED CHANGE (continued)

The NRC has granted two waivers of compliance (WOC) to Browns Ferry technical

. specification requirements in order to allow the LPCZ mode of RHR to be considered operable when capable of manual realignment from the SDC mode. The first WOC was requested by Browns Ferry on February 25, 1992, and granted by the NRC on February 26, 1992. This WOC was necessary to allow repairs to a leaking RHR valve. The second WOC was requested by Browns Ferry and granted by the NRC in letters dated September 28, 1992. This second WOC was also necessary to allow component repairs to one LPCZ loop. TVA committed to the NRC to change the TSs in order to avoid the necessity for another WOC.

Zn addition to TS operability requirements for RHR LPCZ mode in 3.5.B, present

.Browns Ferry TS 3.5.A requires operability of the core spray system. TS 3.5.A.1 requires operability of both core spray loops prior to startup from a cold condition and when there is irradiated fuel in the reactor vessel with reactor vessel pressure greater than atmospheric. Present TS 3.5.A.4 requires when the reactor vessel pressure is atmospheric and irradiated fuel is in the reactor vessel, that at least one core spray loop with one operable pump and associated diesel generator to be operable, except with the head removed. TS 3.5.A.5 allows all core spray to be inoperable with fuel in the vessel, provided that the reactor vessel head is removed, the cavity is flooded, the fuel pool gates are open, the fuel pool water level is maintained above the low level alarm point and one RHR service water pump and associated valves supplying the standby coolant supply are operable. Because of the low pressure conditions in the reactor (less than 105 psig) when the proposed TS change will be utilized, sufficient time will be available to manually align and initiate LPCI, if necessary, to provide core cooling prior to postulated

.core>uncovery.-..ihe .requirements for, core spiay operability in addition to the proposed TS change that will require one loop of RHR to be capable of alignment to the LPCZ mode, provides assurance that adequate water supplies are available when the reactor pressure is less than the RHR shutdown cooling cut-in permissive of 105 psig.

Present TS Bases 3.5 states that at atmospheric pressure, the minimum requirement is for one supply of makeup water to the core. The proposed change for TS 3.5.B.9 exceeds the TS Bases requirement for this reactor condition by ensuring that one loop of RHR LPCZ mode is available and that Core Spray TS requirements are met including automatic initiation capability.

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ENCLOSURE 3 BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1 ~ 2 AND 3 (TVA BFN TECHNICAL SPECIFICATION NO+ 328)

PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION DESCRIPTION OF THE PROPOSED TECHNICAL SPECIFICATION CHANGE The proposed technical specification change applies to BFN Units 1, 2 and 3.

The proposed change will add a clarifying footnote to TS 3.5.B.1 and a sentence to TS 3.5.B.9 which wi.ll allow the use of a RHR loop aligned'or SDC to meet the operability requirements for LPCI, if capable of being manually realigned to LPCI and not otherwise inoperable.

BASES FOR PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.91(c). A proposed amendment to an

~'operating license 'involves no significant hazards considerations if operation of the faci.lity 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 di.fferent ki.nd of accident from an accident previously evaluated, or (3) involve a signi.ficant reducti.on in a margin of safety. The proposed TS change is judged to involve no signi.ficant hazards considerations based on the following:

1. The proposed amendment does not i.nvolve a significant, increase in the probability or consequences of any accident previously evaluated.

Part of the proposed change will add a footnote to present TS 3.5.B.l.

This footnote will allow LPCI to be considered operable during alignment

,,and operation for shutdown cooling with reactor steam dome pressure less than 105 psig" in'hot shutdown, i.f capable of being manually realigned and not otherwise inoperable. The proposed change will explicitly state in the TS, LPCI operability provisions which are appropriate for the hot shutdown condition when less than the RHR cut-in permissive of 105 psig.

The proposed change ensures that credit can be taken for LPCI operability if manual reali.gnment from SDC is possible and only if LPCI i.s not inoperable due to causes other than the manual valve realignment. The proposed change does not decrease the requirement for operability of two loops of LPCI in the hot shutdown condition, but rather allows operability to be expanded to include manual realignment from SDC. The avai.lability of the LPCI loop'may be different than present provisions since automatic ini.tiation is replaced with manual realignment from the SDC mode of RHR; however, since the reactor is in hot shutdown at less than 105 psig, there is sufficient time for operators to realign to the LPCI subsystem if required. In addition to LPCI, present TS requirements for availability of the automatic initiation capability of core spray remain in effect and are not changed by this proposed TS amendment request.

The proposed change to TS 3.5.B.9 will retain the present requirements for one loop of LPCI to be available when the reactor vessel pressure is atmospheric and the reactor contai.ns i.rradiated fuel. The availability of the LPCI loop may be different than present provisions since automatic

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ENCLOSURE 3 (CONTINUED) Page 2 of 3 BROWNS FERRX NUCLEAR PLANT (BFN)

UNITS 1, 2q AND 3 (TVA BFN TECHNICAL SPECXFXCATXON NO+ 328)

REASON FOR THE CHANGE DESCRXPTXON AND JUSTIFICATION BASES FOR PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION (continued) initiation is replaced with manual realignment from the SDC mode of RHRg however, since the reactor is in cold shutdown, there is sufficient time for operators to realign to the LPCI subsystem if required. Zn addition to LPCI, present TS requirements for availability of the automatic initiati.on capability of core spray remain in effect and are not changed by thi.s proposed TS amendment request. The proposed changes to the TS do not modify equipment which could affect acci.dent precursors or i.ni.tiators.

LPCI injection is designed to reflood the vessel following a pipe break from 0.2 square feet to a Design Basis Accident (DBA) Loss of Coolant

. Accident (LOCA) .at rated pressure and power. LPCI functions independently, but in conjunction with the Core Spray system to limit fuel cladding temperature and prevent fuel failure. The function of LPCI is maintained by the proposed TS change since operator action to realign from SDC will provide LPCI in)ection, if required. The delay in providing LPCI infection due to realignment from the SDC mode is not significant since reactor pressure is low, the plant is in a shutdown condition, and the system reali.gnment will be performed expeditiously by operators trained to perform this evolution.

When the reactor is at atmospheric pressure, the need for LPCZ is less than when pressurized. The credible means for loss of vessel inventory at atmospheri.c pressure is inappropriate maintenance action or valve lineup errors and not pi.pe breaks. There are administrative controls and equipment interlocks to prevent such occurrences. If the Core Spray

...,,system starts and in)ects during a loss of vessel inventory event, with reactor pressure at atmospheric, then LPCI in)ection will not be required.

Zf there is a total failure of the Core Spray system during this postulated event, realignment of the RHR system will limit the consequences to less than those of the analyzed accidents and transients.

Therefore, the proposed changes do not involve a significant increase i.n the probabili.ty or consequences of an accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or di.fferent kind of accident from any accident previ.ously evaluated.

The proposed change will maintain the availability of LPCI when the reactor vessel pressure is less than 105 psig and in the hot shutdown or cold shutdown condition. Manual realignment of the RHR system from the SDC mode to LPCZ is procedurally controlled and is an evolution that reactor operators are thoroughly trained to perform. This manual reali.gnment will not si.gni.ficantly alter the ability of LPCI to perform its design function for these reactor conditions. The proposed not introduce any new modes of operati.on or modify existing equipment change'oes design. The requirements for operability of redundant reactor water in)ection sources such as the Core Spray system are not modified by thi,s

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ENCLOSURE 3 (CONTINUED) Page 3 of 3 BROlwtNS PERRY NUCLEAR PLANT (BPN)

UNITS 1q 2q AND 3 (TVA BFN TECHNICAL SPECIFICATION NO 328)

REASON FOR THE CHANGE DESCRIPTION AND JUSTIFICATION BASES FOR PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION (continued) proposed TS change. Therefore, the proposed change does not. create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed changes do not affect the automatic initiation capability of LPCI at reactor conditions other than hot shutdown at less than 105 psig in the vessel and in cold shutdown with irradiated fuel in the reactor.

~- ., The proposed change clarifies present provisions by allowing LPCI to be considered operable when capable of being manually realigned from the SDC mode. The impact of this change will be to increase the time to start providing makeup water to the reactor from LPCI in a loss of inventory event. However, as stated above, the Core Spray system availability has not been changed and will provide necessary makeup requirements. The response time for providing makeup water will only be increased if the Core Spray system fails and one loop of RHR is in SDC mode and the other loop is not available for service. For the reactor conditions where the proposed TS change can be utilized, there is ample time to manually realign the RHR loop in SDC mode to the LPCI mode. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

CONCLUSION TVA has evaluated the proposed amendment described above against the criteria given in 10 CFR 50.92(c) in accordance with the requirements of 10 CFR 50.91(a)(1). This evaluation has determined that the proposed amendment will not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility for a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Thust TVA has concluded that the proposed amendment does not involve a significant hazards consideration.

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